ML20079E536

Final Deficiency Rept DER 83-55 Re Missing Liner in Safety Injection Sys Line.Item Determined Not Reportable Per 10CFR50.55(e).C-E Rept Re Safety Injection Nozzle Thermal Liner Withheld (Ref 10CFR 2.790)

ML20079E536
Person / Time
Site:	Palo Verde
Issue date:	01/03/1984
From:	Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	Licitra E NRC
References
CON-DER-83-55 ANPP-28525-KCP, DER-83-55, NUDOCS 8401170349
Download: ML20079E536 (7)

Text

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.7 i Arizona Pubhc Service Company F O. BOX 21666 + PHOENIX ARIZONA 85036 January 3, 1984 ANPP-28525-KCP/BSK U. S. Nuclear Regulatory Commission Phillips Building

.7920 Norfolk Avenue Bethesda, Maryland- 20814

-cAttention: Mr..E. Licitra, Project Manager

Subject:

Final Report - DER 83-55 A 50.55(e) Report-Relating to Missing Liner in the Safety Injection System Line File: 84-019-026; D.4.33.2 l

Reference:

ANPP-28514, dated December 30, 1983 (Final Report) l'

Dear. Sir:

i -

t Attactied is our final written report of the deficiency referenced above, which has been determined to be Not Reportable under the requirements of 10CFR50.55(e). Proprietary Copy No. 27 is attached for your use.

Proprietary copies 1 through 25 were forwarded to Mr. Richard DeYoung, Director, Office of' Inspection and Enforcement, should you need additional copies.

Very truly yours, I

( d

, CLLC_. /1 L L E. E. Van Brunt, Jr.

APS Vice President Nuclear Projects Management

.ANPP Project Director EEVB/KCP:db Attachments: Final Report - DER 83-55 CE letter V-CE-19506 CE Doc. No. CEN-264(v)-P, Proprietary

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'8401170349 840103 Afvg PDR ADOCK 05000528PDR ,_

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January 3, 1984

'Mr. E. Licitra Page 2 cc (w/o attachments): T. G. Woods, Jr.

G. C. Andognini J. A. Roedel B. S. Kaplan W. F. Quinn T. R. Bradish l

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, C-E Power Systems Tel. 203/688-1911 Combustion Engineering. Inc. Telex: 99297 1000 Prospect Hill Road -

Windsor, Connecticut 06095 H POWER SYSTEMS December 29, 1983 V-CE-19506 Mr. E. E. Van Brunt, Jr.

Arizona Nuclear Power Project P.O. Box 21666 Phoenix, Arizona 85036

Subject:

10CFR50.55(e) Report on SIS Thermal Sleeves '

Dear Mr. Van Brunt:

Enclosed for your submittal to the Nuclear Regulatory Commission is the final 10CFR50.55(e) report on the thermal sleeves of the safety injection nozzles, along with the proprietary affidavit. Copies 1 through 25 of the proprietary report are intended for submittal to the NRC. Copies 26 through 43 are provided for APS use. In addition, 25 copies of the non-proprietary version l are also enclosed. Although the reports on the other RCS problems will be i " interim" reports, this report on the thermal sleeves is considered complete and it is not our intent to update it later.

g Very truly yours, 1

y .

g 2."Ferguson Project Manager CF:MLS Enclosure cc: Messrs:

i G. C. Andognini w/ Copy 44 J. Vorees W. H. Wilson W. G. Bingham w/ Copy 45 R. H. Holm J. W. Dilk G. A. Butterworth S. N. Mager D. B. Amerine w/ Copy 46 W. L. MacDonald J. R. Bynum E. Gouvier

AFFIDAVIT PURSUANT __

TO 10 CFR 2.790 i

Combustion Engineering, Inc. )

State of Connecticut- )

County of Hartford ) SS.:

I,'A. E. Scherer, depose and say that I am the Director, Nuclear Licensing, of Combustion Engineering, Inc., duly authorized to make this affidavit, and

• have reviewed or caused to have reviewed the information which is identified as proprietary and referenced in the paragraph immediately below. I am submitting this affidavit in conformance with the provisions of 10 CFR 2.790 of the Commission's regulations and in conjunction with the application of Arizona Public Service for withholding this information.

The information for which proprietary treatment is sought is contained in the following document:

CEN-2C4(V)-P, " Report on Palo Verde Unit 1 Safety Injectio' Nozzle Thermal Liner".

This document has been appropriately designated as proprietary.

I have personal knowledge of the criteria and procedures utilized by Combustion Engineering in designating information as a trade secret, privileged or as confidential commercial or financial information.

Pursuant to the provisions of paragraph (b) (4) of Section 2.790 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure, included in the above referenced document, should be withheld. ~

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1. The information sought to be withheld from public disclosure is the methodology related to the determination of usage factors and design features of reactor coolant system components, which is owned and has been held in confidence by Combustion Engineering.

, 2. The information consists of test data or other similar data concerning a process, mathod or component, the application of which results in a substantial competitive advantage to Combustion Engineering.

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3. The information is of a type customarily held in confidence by Combastion Engineering and not customarily disclosed to the public. Conbustion Engineering has a rational basis for determining the types of information custocarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The details of the aforementioncd system were provided to the Nuclear Regulatory Commission via letter DP-537 from F.M. Stern to Frank Schroeder dated December 2, 1974 This system was applied in determining that the subject document herein are proprietary.

4. The information is being transmitted to the Commission in confidence under the provisions of 10 CFR 2.790 with the understanding that it is to be received in confidence by the Commission.

5. The information, to the best of my knowledge and belief, is not available in public sources, and any disclosure to third parties has been made pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence.

6. Public disclosure of the information is likely to cause substantial harm to the competitive position of Combustion Engineering because:

a. A similar product is manufactured and sold by major pressurized water reactor competitors of Combustion Engineering,

b. Development of this information by C-E required thousands of manhours of effort and tens of thousands of dollars. To the best of my  ;

I knowledge and helief a competitor would have to undergo similar expense in '

generating equivalent information.

c. In order to acquire such information, a competitor would also require considerable time and inconvenience related to the development of methodology to determine usage factors and design features of reactor coolant system components.

d. The information required significant effort and expense to obtain the licensing approvals necessary for application of the information.

Avoidance of this expense would decrease a competitor's cost in applying the information and marketing the product to which the information is applicable,

e. The information consistr of methodology related to the determination of usage factors and design features of reactor coolant system components, the application of which provides a competitive economic adycrtage.

The availability of such information to competitors would enable them to modify their product to better compete with Combustion Engineering, j take marketing or other actions to improve their product's position or impair l the position of Combustion Engineering's product, and avoid developing similar data and analyses in support of their processes, methods or apparatus,

f. In pricing Combustion Engineering's products and services, significant research, development, engineering, analytical, manufacturing, licensing, quality assurance and other costs and expenses must be included. -

The ability of Combustion Engineering's competitors to utilize such information

without similar expenditure of resources may enable them to sell at prices reflecting significantly lower costs.

g. Use of the information by competitors in the international marketplace would increase their ability to market nuclear steam supply systems by reducing the costs associated with their technology development. In addition, disclosure would have an adverse economic impact on Combustion Engineeri:ig's potential for obtaining or maintaining foreign licensees.

Further the deponent sayeth not.

2 'M f 4 A. E. SrMirer ~ ~

Direr. tor Nuclear Licensing Sworn to before me this h3 day of DEC, \9,91 s

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