LD-82-025, Forwards Sample Environ Test Rept of Type Which Will Be Generated by Use of Topical Rept on Class IE Qualification, CENPD-255.Rept Withheld (Ref 10CFR2.790)

Forwards Sample Environ Test Rept of Type Which Will Be Generated by Use of Topical Rept on Class IE Qualification, CENPD-255.Rept Withheld (Ref 10CFR2.790)

ML20069C142
Person / Time
Site:	05000470
Issue date:	03/03/1982
From:	Scherer A ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
To:	Eisenhut D Office of Nuclear Reactor Regulation
Shared Package
ML20011B339	List: LD-82-025, Forwards Sample Environ Test Rept of Type Which Will Be Generated by Use of Topical Rept on Class IE Qualification, CENPD-255.Rept Withheld (Ref 10CFR2.790)
References
LD-82-025, LD-82-25, NUDOCS 8203080271
Download: ML20069C142 (5)

Text

C-E Power Systems Tel. 203/688-1911 Combustion Engineenng, Inc. Telex 99297 1000 Prospect Hill Road Windsor. Connecticut 06095 H POWERSYSTEMS e riEcavEn d

8], MAR 0519825 [2 Docket No.: STN-50-470F NON Q gM March 3, 1982

), Doc & LD-82-025 4

<n Mr. Darrell G. Eisenhut, Director Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Subject:

Sample Environmental Test Report

Reference:

A. E. Scherer letter to D. G. Eisenhut, dated January 29, 1982

Dear Mr. Eisenhut:

The referenced letter promised a sample environmental test report for Staff review. The sample report, along with appendices discussing thermal equiv-alence and test uncertainties, is attached. This report was synthesized from existing data, where available, and is being provided only as a sample of the type of report which will be generated by the use of our Topical Report on Class 1E Qualification, CENPD-255 (It is not intended to serve in any way as the formal submittal of the test report for this, or any other, particular piece of equipment.) This report is proprietary and the non-proprietary version will be provided within the next two weeks.

If we can be of any additional assistance, please feel free to contact either myself or Mr. G. A. Davis of my staff at (203)688-1911, Extension 2803 Very truly yours, COMBUSTION ENGINEERING, INC.

A. E. Scherer Director Nuclear Licensing AES:ctk '

Attachment g, go 8203080271 820303 PDR ADOCK 05000470 A PDR

AFFIDAVIT PURSUANT TO 10 CFR 2.790 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 i

this affidavit in conformance with the provisions of 10 CFR 2 790 of the Commission's regulations and in conjunction with the application of CESSAR-F, for withholing this information.

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

Qualification Test Report for Electrical Filter Assembly, LD-82-025 This document has been appropriately designated as proprietary.

I have personal knowledge of the criteria and procedures utilized by.

4 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 docunent, should be

, withheld.:

1. - The information sought' to be withheld from public disclosure is calculations and analysis of- aging, thermal equivalence and test uncertainties

{ which;is owned and has been held in confidence by Combustion Engineering.

L.

2 4

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 I

Schroeder dated December 2, 1974. This system was applied in determining that the subject docunent 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 t 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 and tens of thousands of dollars. To the best'of my knowledge and i

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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 in performing the necessary research calculations and analysis,

d. The information required significant effort and expense to obtain the licensing approvala 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 detailed analyses of thermal equivalence, aging and test uncertainties,the application of which provides a competitive. economic advantage. The availability of such information to i

, 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, i

significant research, development, engineering, analytical, manufacturing, l

' 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. -

l marketplace would increase'their ability to market nuclear steam supply'. systems

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4 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.

1. M et7erer Director, Nuclear Licensing Sworn to before me this j 'day of 87## >

(Et'd&f bl//fbW Notary Public DAWN E. SANDER, NOTARY PUBUC State of Connecticct No. 61536 Commission Exp;ros M7'd 31, I?36 l