2CAN128310, Forwards Proprietary & Nonproprietary, Digital Simulation of C-E Nsss. Proprietary Rept Withheld (Ref 10CFR2.790)
| ML20083F824 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 12/27/1983 |
| From: | John Marshall ARKANSAS POWER & LIGHT CO. |
| To: | John Miller Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19268E665 | List: |
| References | |
| 2CAN128310, NUDOCS 8401050577 | |
| Download: ML20083F824 (5) | |
Text
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ARKANSAS POWER & LIGHT COMPANY POST OFFICE BOX 551 LITTLE ROCK. ARKANSAS 72203 (501) 371-4000 December 27, 1983 2CAN128310 Director of Nuclear Reactor Regulation ATTN: Mr. James R. Miller, Chief Operating Reactors Branch #3 Division of Licensing U. S. Nuclear Regulatory Commission Washington, DC 20555
SUBJECT:
Arkansas Nuclear One - Unit 2 Docket No. 50-368 license No. NPF-6 Combustion Engineering's System Excursion Code (CESEC) Verification Gentlemen:
Our March 27, 1981, letter (2CAN038117) submitted the results of the CESEC verification test.
Attached are five (5) proprietary copies, 000115 through 000119, of CESEC Digital Simulation of a Combustion Engineering Nuclear Steam Supply System.
Also attached are five (5) nonproprietary copies of the same.
In accordance with 10CFR2.790, we request this information be handled as proprietary and withheld from public disclosure.
The required affidavit justifying this request is attached.
Very truly yours, John R. Marshall Maneger, Licensing JRM:PC:s1 vb,Aa/,.
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yC Attachments 4
Doh o!$o$(g PDR MEME1ER MOOLE SOUTH UTIUTIES SYSTEM
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'l AFFIDAVIT PURSUANT TO 10 CFR 2.790 Combustion Engineering, Inc.
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State of' Connecticut
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County of Hartford--
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SS.:
I, P. L. McGill, depose and say that I am the Vice President, Conmercial, of Combustion Engineering, Inc., duly authorized to make this affidavit, and have reviewed or caused to have reviewed the information which is identified as it
_ propr e a ry 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 Arkansas Power and Light Co. for withholding this information.
The information for which proprietary treatment is sought is contained in the following document:
CESEC Digital Simulation of a Combustion Engineering Nuclear Steam Supply System December, 1981.
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 i
or as confidential commercial or financial information.
1 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 fron j
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 are the methodology related to the determination of the pool boiling coefficient in the steam generator side and the enthaply transport algorithm in the core and steam generator primary nodes, 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, method or component, the application of which results in a substantial competitive advantage to Combustion Engineering.
3.
The information is of a type customarily held in confidence by Combustion Engineering and not customarily disclosed to the public. Combustion Engineering has a rational basis for determining the types of information customarily 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 aforementioned 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 nanufactured 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 hundreds of thousands of dollars. To the best of my knowledge and belief 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 (9velopment of methods for calculating the NSSS response for Chapter 15 events in the safety analysis reports, 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 consists of models for the determination of pool boiling heat transfer in the steam generator secondary side and enthalpy distribution in the core and steam generator primary system nodes, the application of which provides a competitive economic advantage.
The availability of such information to competitors would enable them to modify their product to better compete with Combustion Engineering, take marketing or other actions to improve their product's position or impair 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 Conbustion Engineering's competitors to utilize such information r
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 Engineering's potential for obtaining or maintaining foreign licensees.
Further the deponent sayeth not.
bf P. L. McGill Vice President Commercial 9
Sworn to before me this @* day of MTDo, N d khc 5-ck> d Notary Public.
V TriERESA M.'REGAN, NOTAfsY PUBUC STATE Of CONiiECTICUT NO. 66097 CONSSION:EfiRES MARCH 31,1983
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