LD-82-001, Forwards Proprietary & Nonproprietary Versions of Cesec Digital Sumulation of C-E Nsss. Proprietary Version Available in Central Files Only
| ML20039E991 | |
| Person / Time | |
|---|---|
| Site: | 05000470 |
| Issue date: | 01/06/1982 |
| From: | Scherer A ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20039E992 | List: |
| References | |
| LD-82-001, LD-82-1, NUDOCS 8201110696 | |
| Download: ML20039E991 (5) | |
Text
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C-E Power Systems Tel. 203/688-1911 Combustion Engineering, ?nc.
TeMx 99297 1000 Prospect Hill Road Windsor. Connecticut 06095 POWER H SYSTEMS Docket No.: STN-50-470 January 6, 1982
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n Mr. Darrell G. Eisenhut, Director k
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U. S. Nuclear Regulatory Commission q,
Washington, D. C.
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Subject:
CESEC-III NSSS Simulation Code
Enclosure:
Description of the C-E CESEC-III NSSS Simulation Code copy # 1 thru 40
Dear Mr. Eisenhut:
Transmitted herewith is 40 proprietary and 40 non-proprietary copies of the Combustion Engineering CESEC-III NSSS Simulation Code Description (proprietary copy and non-proprietary copy).
The enclosure is transmitted for the Staff review of the CESSAR Final Safety Analysis Report.
Due to the proprietary nature of the material contained in the enclosure, we request that it be withheld from public disclosure in accordance with the provisions of 10 CFR 2.790 and that this material be safeguarded. The reasons for the proprietary classification of this report are delineated in the enclosed affidavit.
Very truly yours, COMBUSTION ENGINEERING, INC.
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PDR ADOCK 05000470 A
AFFIDAVIT PURSUANT 4
T0 10 CFR 2.790 Combustinn Engineering, Inc.
State of Connecticut County of Hartford
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I, P. L. McGill depose and say that I am the Vice President, Commercial 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 subritting this affidavit in conformance with the provisions of 10 CFR 2.790 of the Commi:sion's regulations and in conjunction with the application of CESSAR, 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.
i 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 fir. social information.
l 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 referencnd document, I
should be withheld.
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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 secondary side and the enthalpy 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 documents 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.
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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 reactors 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 inconveniuce related to the development 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 af 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 3: ;csition 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, sigt.ificant research, development, engineering, analytical, manufacturing, licensing, quality assurance and other costs and expenses must be included.
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r 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 Engineering's potential for obtaining or maintaining foreign licensees.
Further the deponent sayeth not.
l P. L. McGill Vice President Commercial Sworn to before me this 6 day of a/unt
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Notary Public DAWN E. SANDIR, NOTARY Funic Stato of Connecticut No. 61536 Commission Er.r. ire. !E :h.S,1736 i
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