L-81-492, Application to Amend Licenses DPR-31 & DPR-41,clarifying mini-in-core Distribution Surveillance & Basis of Engineering Uncertainty Factor
| ML17341A635 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 11/23/1981 |
| From: | Robert E. Uhrig FLORIDA POWER & LIGHT CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML17341A636 | List: |
| References | |
| AW-76-10, L-81-492, NUDOCS 8112010329 | |
| Download: ML17341A635 (24) | |
Text
RKQULAITQRY~c'NFORMA>>TION>> D>>ISTRIBUT>>ION SY' E~I'RIOS)
\\
ACCESSIOQi N9R:
FACIL~:50:"250 50:-251 AUTH~,NAME>>
UMRISg R ~ Ei, RECIPE 9'ALKI KKSENHU T'g D ~ G i 8112910329.
DOC ~ DA>>TEI: 81/11/2'3 Turkiey Point Pl ant'i Und t~ 3v Fl ori T'portray Point Plant~.- Un>>iti Qr Flori AUTHOR'F F ILIATION Flor>>id@>> Power 5 Light C'os R E CI PIE N T AF FIIiIAiT'I0 bl >>
Division of L>>icensing NO>>TARIZKD:" YES QOCKKil" 0 da Power" and>> Lig>>hit'I 05000250 da Power and>> Ligal C',
05090251 SUBJKC>>T:: A>plicat>>ion to, amend Ilcenses DPR-31 mini incore di stributi on>> surve>>i l>>l ance uncer tainty factor ~
DiiSTRIBJTiIQN CQDKl: PA01S COPIES RKCEE,VKO! LA R TlITLKl:i~roar ietery Remi eh Distr iibutlon 0'perati
'40TE S'.:
8 DPR "Q 1 r c I ai fying 8 basi s of eng,i neer>>ing,
'NCL'SIZEi::
ng Reactor REC1PX KNT'OPIES IOi CODE/l4AMKI LiTTR ENCL(
ACTION::
ORGI 01 BCI
+5g~)]
7 7
RECIPIENT COPZEB ID" CODE'/NAMEI LOITRI ENCL(
GRO>>TENHUISg M Ci 1
1 INTERN ALi:
KLO<
~>> FILE EXTERNALc ACR8 NRCl PDQl NTiIB
>>>>>>>> 2!>>>>>>
F6 1
1
~
16 0
0 I KI LP DR'i
%SIC.
4$3p 4f 2
2' 0
1 0
/9 /I E/.tres 7 o 'A
@p"c>>tn>>>>i)>>e ie P,'f
+A Qc>>
TOiT'AL l>>IURBKRl OF COPIES" REQUIRED:: LiTTR 32>>
ENCL(
27
0 i.
JL I
~
~ '
,e FLORIDAPOWER 8 LIGHTCOMPANY November 23, 1981 L-81-492 WITHHOLD ATTACHMENT 3 FROM PUBLIC DISCLOSURE Office of Nuclear Reactor Regulation Attention:
Mr. Darrell G. Eisenhut, Director Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.
C.
20555
Dear Mr. Eisenhut:
Re:
Turkey Point Units 3
8 4
Docket Nos.
50-250 8 50-251 Proposed License Amendments Base Load and Radial Burndown In accordance with 10 CFR 50.90, Florida Power 8 Light Company submits herewith three (3) signed originals and forty (40) copies of a request to amend Appendix A of Facility Operating Licenses DPR-31 and DPR-41.
These pages will supersede pages with the same number submitted via L-81-198, dated May 11, 1981.
The remai,nder of that submittal remains applicable.
The proposed amendment is described below and shown on the accompanying pages bearing the date of this letter in the lower right hand corner.
These amendments are in response to the request of Mr. M. Dunenfeld of your staff for additional information on the Mini-Incore Distribution Surveillance System (MIDS), and additional clarification regarding the basis of the engineering uncertainty factor.
Pa es 3.2-3, 3.2-3a, 3.2-3b, 3.2-3c and 3.2-4 The specification regarding Augmented Surveillance was revised to include provisions for use of the llIDS under certain conditions of operation.
The peaking factor nomenclature in the Figure is changed to that now in use.
~Pe e 6-22 A requirement for reporting Peaking Factor Limits is added.
parol S
,/vo 8ii20i0329.8iii23 PDR ADOCK 05000250 P
PDR PEOPL'E... SERVING PEOPL'E
4>
1 li f"; ~/
-~yp I,
l',.'~'".
'f 1
I 1
Office of Nuclear Reactor Regulation Page Two Pa es B3.2-4, B3.2-8 and B3.2-8a A description of the measurement of F~ utilizing the MIDS is expanded and clarified.
Please note that our response contains information considered to be proprietary by the Westinghouse Electric Corporation.
In conformance with 10,CFR 2.790, we are also forwarding an application for withholding information from public disclosure (Attachment
- 1) and an Affidavit (Attachment 2), setting forth the basis on which the proprietary information contained in Attachment 3 may be withheld from public disclosure by the Commission.
Attachment 3 contains a Safety Evaluation supporting the proposed Technical Specification changes.
The proposed amendment has been reviewed by the Turkey Point Plant Nuclear Safety Committee and the Florida Power 5 Light Company Nuclear Review Board.
As this submittal supplements, at NRC request, our earlier Proposed License Amendments (L-81-198) of May 11,
- 1981, no fee is transmitted.
Very tr
- yours,
-Yc X'obert E. Uhrig Vice President Advanced Systems 8 Technology REU/JEM/ah Attachments cc:
Mr. J.
P. O'Reilly, Director, Region II Harold F. Reis, Esquire
I f
~
g t.
1
~'
4
~
<I ATTACHt'1ENT I r '
~
AM-76-.1O AFFIDAVIT COr"rhOi'it1EALTH'F PENiNSYLYANIA:
'COUNTY OF ALLEGHENY:
ss Before me, the undersigned authority, personally appeared Robert A. Wiesemann, who, being by me duly sworn according to law, de-poses and says that he is authorized to execute this Affidavit on behalf of westinghouse Electric Corporation
("Mestinghouse")
and that the aver-ments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:
I a
'+~!Lcd'.t;.'obert A. Wiesemann, i~lanager Licensing Programs Sworn to and subscribed before me this ~day of 7-'~ ~ <
1976.
C s
~
~% P.'L s I
(
Notary Public
- .ng
.GENEVIEVE.K!SH. NOTA RY PUSVC
. bIOtkROEVILLE BOROLrGN i uLt >>c,:0r r.'Ur;STY QY-ColttdrSSiUtI EXARES JULY U, l976
4>>
~
~
,~4
AH-76-10 (1)
I am Manager, Licensing Programs, in the Pressurized'ater Reactor Systems Division, of Westinghouse Electric Corporation and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public dis-closure in connection with nuclear power plant licensing or rule-making proceedings, and am authorized to apply for its withholding on behalf of the Westinghouse Water Reactor Oivis'ions.
(2)
I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.790 of the Commission's regulations and in con-junction with the Westinghouse application for withholding ac-
'ompanying this Affidavit.
(3)
I have personal knowledge of the criteria and procedures utilized by Westinghouse Nuclear Energy Systems in designating infcrmation as a trade secret, privileged or as confidential cormercial or financial information.
(4)
Pursuant to the provisions of paragraph (b)(4) of Section 2.790 of the Commission's regulations, the following is furnished for
.'onsideration by the Commission in determining whether the in-formation sought to be withheld from public disclosure should be withheld.
(i)
The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.
4t
~ 1
'L 1
I w3w'M-76-10 (ii).The information is of a type customarily. held in confidence by Mestinghouse and not customarily disclosed to the public.
Mestinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connecti'on, utilizes a system to determine when and whether to hold certain types of information in confidence.
The application,.of that system and the substance of that system constitutes Mestinghouse policy and provides the rational basis required.
C e
Under that system, information is held in confidence if it falls in one or more of several
- types, the release of which might result in. the loss of an existing or potential com-petitive advantage, as follows:
(a),
The in ormation revea'ls the distinguishing aspects of a process (or component, structure, tool, method, etc.)
where prevention of its use by any of Mestinghouse's competitors without license from. Mestinghouse consti-tutes a competitive economic advantage over other companies..
(b) It consists of supporting data, including test data, relative to a process (or c=mponent, structure, tool, method, etc.), the application of which data secures a
competitive economic advantage, e.g.,
by optimization
.or improved marketabi.lity.
I
~
~
(c)
Its use by a competitor would reduce his expenditure of resources or improve his competitive position in. the
- design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.
(d) It reveals cost or price information, production cap-
- acities, budget levels, or commercial strategies of Mestinghouse, its customers or suppliers.
(e) It reveals aspects of past,
- present, or future Mest-inghouse or customer funded development plans and pro-grams of potential commercial value to Mestinghouse.
(f) It contains patentable
- ideas, for which patent pro-
'tection may be desirable.
(g) It is not the property of Mestinghouse, but must be treated as proprietary by Mestinghouse according to agreements with the owner.
There are sound policy reasons behind the Mestinghouse system which include the following:
(a)
The use of such information by Mestinghouse gives Mestinghouse a competitive advantage over its com-petitors.
It is, therefore, withheld from disclosure to protect the Hestinghouse competitive position.
l~
~
II I
I
,AM-76-10 (b) It is information which is marketable in many ways.
The extent to which.such information is available to competitors diminishes the Westinghouse abi.lity to sell'roducts and services involving'the use of the information.
(c)
Vse by our competi.tor would put Westinghouse at a
competitive disadvantage by reducing his expenditure of resources at our expense.
(d)
Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage.
If competitors acquire components of proprietary infor-
- mation, any one component may be the key to the entire
- puzzle, thereby depriving l,estinghouse, of a competitive advantage.
(e)
Unrestricted disclosure would jeopardize the position of prom-:.nence of Westinghouse in the world market, and thereby give a market advantage to the competition in those countries.
(f)
The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining. and maintaining a competitive advantage.
AW-76-10 (iii)
The information-is being transmitted to the Commission in confidence
- and, under the provisions of 10 CFR Section 2.790.
it is to be received in confidence by the Comnission.
(iv)
The information is not available in public sources to the best of our knowledge and belief.
(v)
The proprietary information sought to be withheld in this submittal is that which is appropriately marked in Attachment II to Commonwealth Edison Company letter, Pliml to Purple dated May, 4, 1976, concerning reload safety and licensing.
This information is being provided in support of a reload review of Comnonwealth Edison's Zion Station Unit 1, plant for cycle 2
operation.
This information is required per HRC Branch Technical Position CPB 4.3-1 "Westinghouse Constant Axial Offset Control (CAOC)" since the applicant proposes cyc;e 2
CAOC operation for F~ = 2.25.
This information enables Westinghouse to:
(a)
Justify the design basis for the fuel (b)
Assist its customers to obtain licenses (c)
Meet warranties Further, th'is information has substantial commercial value as follows:
(a)
Westinghouse sells the use of the information to its customers for purposes of meeting HRC requirements for licensing documentation.
Ql I
. (b)
Westinghouse uses the.'information to perform and justify analyses which are sold to customers.
(c)
Mestinghouse uses the information to sell nuclear fuel and related services to its customers.
Public disclosure of this information. is likely to cause sub-stantial harm to the competitive position of Westinghouse in selling nuclear fuel and related services.
Westinghouse retains a marketing advantage by virtue of the knowledge, experience and competence it has gained through long involvement and considerable investment in all aspects of the nuclear power generation industry.
In particular'Mestinghouse has developed a unique understanding
'of the factors and parameters which are variable in the process of design of nuclear fuel and which do affect the in.service performance of the fuel and its suitability for the purpose for which it was provided.
In all cases that purpose is to generate energy in a safe and efficient manner while enabling the operating nuclear generating station to meet all
- regulatory requirements affected by the core loading of nuclear fuel.
Cohfidence in being able to accomplish this comes from the exercise of judgement based on experience, in the application of empirically derived models based on prior data and in the use f proven analytical models to simulate behavior of the fuel in normal operation and under hypothetical transients.
II I
~
~
AM-76-10 Thus, the essence of the competitive advantage in this field lies in an understanding of which analyses should be performed and in the
- methods and models used to perform these analyses.
A substantial part of this competitive advantage will be lost if the competitors of Hestinghouse are able to use the results of the analyses in the attached document to normalize or verify their own methods or models or if they are able to claim an equivalent understanding by demonstrating that they
. can arrive at the same or similar results.
Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design and licensing of a similar product.
This information is a product of Westinghouse design technology.
As. such, it is broadly applicable to the sale and licensing of fuel in pressurized water reactors.
The development of this information is the result of many years of Westinghouse effort and the expenditure of a considerable sum of money.
While the analyses for this specific application were not unique, in order for competitors of Westinghouse to duplicate this information would require the investment of substantially the same amount of effort and expertise that Westinghouse possesses and which was acquired over a period of more than fifteen years and by the investment
- of, millions of dollars.
Over the years, this has included the development of heat transfer codes, nuclear analysis codes, transient analysis
- codes, core and system simulation methods and an experimental data base to support them.
Further the deponent sayeth not.
Oi
0 STATE OF FLORIDA
)
COUNTY OF DADE Robert E. Uhri
, being first duly sworn, deposes and says:
That he is Vice President the Licensee herein; of Florida Power 8 Light Company, That he has executed the foregoing document; that the statements made in this document are true and correct to the best of his knowledge, information, and belief, and that he is authorized to execute the document on behalf of said Licensee.
Attachment 3 (Pages 1 - 4) of the enclosed material is/CNC exempt from public disclosure sn accordance with Section 2.790 of the HRC "Rules of Practice", Title 10, Code of Federal Regulations.
Pursuant to section(s)
-b this information is exempt from disclosure because Attachment 3 contains rivile ed and confidential information.
Robert E. Uhrig Subscribed and sworn to before me this ding 0+
. t9 Ei
'4CIARY 'PUBL'IC in and for the County otDade', Sta of Florida.
. pubtic, Stato of po;ado at Lcrgo mis>>on expires My co~~a
'Qo Qpra3 or
'g
4~
)
)
II~I J