ML17206A651

Submits Info Re Steam Generator Cleaning Process Solvent Formulation.Info Withheld (Ref 10CFR2.790).Affidavit Encl

ML17206A651
Person / Time
Site:	Saint Lucie
Issue date:	02/05/1979
From:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
To:	Stello V Office of Nuclear Reactor Regulation
References
L-79-33, NUDOCS 7902120193
Download: ML17206A651 (10)

Text

REGULAT< RY INF(IRMATI(IM DISTRIBUTIOQSYSTEM (BIDS)

ACCESS I.OA NBR< 79021201 9 DOC.DATE: 79/02/05 NOTARIZED < YES DOCKET 0 Unit,l, Florida FACIL--50-335 St. Luci e .Plant, Power 8 Light Co. 05000335 AUTH. NAME AUTHOR AFF I LIATI,ON

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UHRIG, R.E. Florida, Power 8, Light Co.

RECIP.NAMF RECIPIENT AFFILIATION STELLO,.V. 'ivision of Operating Reactors SUBJECT--'ubmits info re steam generator cleaning process solvent Xormu lati on. Info wi thhedl (ref .IOCFR2.790) .Aff idavit .encl.

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0 t P.O. BOX 013100, MIAMI, FL 33101 gy9lh'i kSv~CW FLORIDA POWER & LIGHT COMPANY February 5, 1979 L-79-33 WITHHOLD ENCLOSURES FROM PUBLIC DISCLOSURE Office of Nuc1 ear Reactor Regul ati on Attention: Mr. Victor Stello, Director Division of Operating Reactors U. S. Nuclear Regulatory Commission Washington, D C. 20555

Dear Mr. Stello:

Re: St. Lucie Unit No. 1 Docket No. 50-335 Cleanin of Steam Generators One copy of proprietary information relating to the Dow Chemical Company steam generator cleaning process solvent, formulation is enclosed for your information. This information is being submitted to satisfy a commitment made in our letter L-78-390 dated December 18, 1978.

Due to the proprietary nature of the information, the Dow Chemical Company has requested that the material enclosed be withheld from public disclosure in accordance with 10 CFR 2.790. An application from the Dow 'Chemical Company to that effect and an affidavit which supports that request are also enclosed.'s stated in our previous letter, FPL.will continue to keep the Commission informed of the status of the program and to provide supple-mental information as it becomes available, or is requested.

l Yours very truly, Robert E. Uhri g Vice President REU:TG:cf Enclosures cc: Mr . James P. O'Rei lly, Region II, w/o enclosures Harold F. Reis, Esquire, w/o enclosures WITHHOLD ENCLOSURES FROM PUBLIC DISCLOSURE 7808%8 0'RP PEOPLE... SERVING PEOPLE

DOCKET NO ~

DATE: g NOTE TO NRC AND/OR LOCAL PUBLIC DOCUMENT ROOMS The following item submitted with letter dated from is being withheld from public disclosure in accordance with Section 2.790.

PROPRIETARY INFORKATION Distribution Service's Branch

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D o THE DOW CHEMICAL COMPANY MIDlAND, MICHIGAN 48640 January 15, 1979 Director Office of Nuclear Reactor Regulation United States Nuclear Reactor Commission Washington, D. C. 20555 Re: Florida Power & Light Co. Steam Generator Chemical Cleaning Program for St. Lucie Plant Unit No'. 1 APPLICATION FOR WITHHOLDING INFORMATION FROM PUBLIC DISCLOSURE Pursuant to the provisions of 10 C.F.R. Section 2.790 (b)(l), The Dow Chemical Company hereby requests that the accompanying document (and the contents thereof), consisting of a letter from Francis P. Frauson to R. McFedries, dated January ll, 1979, be withheld from public disclosure.

It is considered that this document contains proprietary data, trade secrets and confidential information of The Dow Chemical Company pursuant to 10 C.F.R. 9.5(a)(4) of the NRC's regulations.

Applicant hereby presents an affidavit pursuant to 10 C.F.R. 2.790(b)(l) which supports such request.

When the need for use of the information contained in such document no longer exists, it that the document be returned to Dow.

is respectfully requested s ectfully submitted ruce M. Kanuch Managing Counsel BMK/dd Encl.

AFFXDAVXT STATE OF MXCHXGAN

,SS o County of Midland ROBERT McFEDRXES, duly sworn, deposes and says:

1. THAT he is the Director of Research and Development for the Functional Products and Systems Department of The Dow Chemical Company;

2. THAT the Nuclear Services Group, a business group within the Functional Products and Systems Department, falls within his area of responsibility;

3. THAT he is responsible for identifying confidential and trade secret information in the field of cleaning steam generators associated with nuclear power plants which the Nuclear Services Group commercially exploits;

4. THAT the information set forth in the letter from Francis P. Frauson to myself enclosed in the attached envelope marked Trade Secrets of The Dow Chemical Company, which he has read, has been identified by Dow as proprietary and confidential and constitutes trade secrets in accordance with procedures at least as stringent, as Dow's normal procedure with respect to such identification; S. THAT this information has been treated as a trade secret by Dow and has not been made available to the public; I

6. THAT in instances where any portion of such informa-tion has been disclosed or made available to others outside Dow it has been done so only'nder the terms of a written secrecy and/or non-analysis agreement requiring the recipient to not.

disclose, divulge, analyze. or otherwise use said information;

7. THAT the maintenance of the trade secret status of this information is vital'to the competitive advantage which 5

Dow now possesses in this field. Dow does not know of any competitive process or chemicals which are capable of achieving the results achieved'y using the Dow Trade Secret information; nor of any other product which has been subjected to such a battery of verification testing;

8. THAT making this information available to the public would cause Dow substantial harm since competitors would be able to use the information without incurring the sub-stantial research and, development expense incurred by Dow in developing the information and perfecting its use;

9. THAT the Trade Secrets cannot, in my opinion, be readily duplicated by independent research.

Further Affiant sayeth not.

Robert, Mc ies Sworn to and subscribed before me thisrSrL day of 1979.

ary Pubic.c NINA 3 hfoHLMANN Nope~ PubIfc, +I'II~" County, QIqQI.,

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DE SECRETS OF THE DOW CI ICAL COMPANY D o DOW CHEMICAL U.S.A.

January ll, 1979 LARKIN LABORATORY 1691 N. SWEDE RD.

MIDLAND, MICHIGAN 48640 R. McFedries Director of Research and Development Functional Products and Systems STEAM GENERATOR CLEANING PROCESS SOLVENT FORMULATION DOW TRADE SECRET The steam generator cleaning research program has led to the development of four chemical solutions which will be utilized in the cleaning process. The chemical dissolution of iron oxide deposits will be accomplishe utilizing a chemical formulation know as NS-5 which c ains ammonium hydroxide, ammonium sulfate, citric acid, osion inhibitor NI-,100, deionized water, diethylene i YneJIentaacetic acid, ethylene-diaminetetraacetic acid, 1+d %9-q>~, and sodium pyrophosphate.

The chemical dissoluti ~c~e~knd copper oxide deposits will be accomplished mg 1bcscIIijhical iormnlation known as NC-300 which co a s<<g'1IImoL1q<q&icarbona te, ammonium hydroxide, ammo peqpulfgite stand deionized water. A chemical rinse known as gg84hi& q8ntains ammonium hydroxide, deionized water, an8 qgA$ "Sediaminetetraacetic acid will be utilized between altN~ ng NS-5 and NC-300 stages. The steel surfaces will be passivated using an aqueous solution containing a chemical formulation known as NP-100 which contains disodium phosphate, monosodium phosphate, and sodium nitrite.

These four formulations are considered Dow trade secrets and as such will not be disclosed outside The Dow Chemical Company except after the execution of a confidentiality agreement acceptable to Dow by the outside party.

I Sincerely, Francis P. Frauson, Jr.

Research Specialist Decontamination Systems RED fo TRADE SECRETS OF THE DOW CHEMICAL COMPANY AN OPERATINO UNIT OF THE DOW CHEMICAL COMPANY

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