LD-83-036, Forwards Sys 80 CESSAR Fsar,Responses to Questions on Steam Line Break Method, Per SER Confirmatory Item 14.Proprietary Responses Withheld (Ref 10CFR2.790)

Forwards Sys 80 CESSAR Fsar,Responses to Questions on Steam Line Break Method, Per SER Confirmatory Item 14.Proprietary Responses Withheld (Ref 10CFR2.790)

ML20069L783
Person / Time
Site:	05000470
Issue date:	04/26/1983
From:	Scherer A ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
To:	Thomas C Office of Nuclear Reactor Regulation
Shared Package
ML19268B484	List: LD-83-036, Forwards Sys 80 CESSAR Fsar,Responses to Questions on Steam Line Break Method, Per SER Confirmatory Item 14.Proprietary Responses Withheld (Ref 10CFR2.790) ML20069L787
References
LD-83-036, LD-83-36, NUDOCS 8305020400
Download: ML20069L783 (6)

Text

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C-E Power Systems Tel 203/6881911 ,

Combustion Engineenng. inc. Telex 99297 -

1000 ProspecWil Ros'd Windror, Connbeticut o6095 POWER H SYSTEMS Docket No.: STN 50-470F April 26,1983 LD-83-036 Mr. Cecil 0. Thomas, Chief Standardization and Special Projects Branch Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

CESSAR-F SER Confirmatory Item 14, Responses to Questions

References:

(A) Letter, C. O. Thomas to A. E. Scherer, dated February 7, 1983 (B) Letter LD-83-027, A. E. Scherer to C. O. Thomas, dated March 29, 1933

Dear Mr. Thomas:

Reference (A) transmitted in its Enclosure (1) a set of questions on the small feedwater and small steam line break methodologies. Responses to questions one through four, which address feedwater line break methodology (CESSAR-F SER Confirmatory Item 15) were provided via Reference (B). Attached are responses to questions 6, 7, 8, 9 and 13 which concern small steam line break methodology. We are providing these responses now to facilitate the review of CESSAR-F. The remaining questions concerning the System 80" design methodology will be submitted by May 9, 1983 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.

If I can be of any further assistance in this matter, please contact me or Mr.

G. A. Davis of my staff at (203) 688-1911, extension 2803. 3 Very truly yours, 60i gp COMBUSTION ENG NEERING, INC.

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A. E. erer m~D C "Y ' G ?

Director

{ qp l Nuclear Licensing tpg I tvP AES:las F72088 /V5'C- I NE cc: Gary Meyer (Project Manager / USNRC) without enclosures

Enclosures:

Page 2 ggI Np l n 0 0 0 E PDR

Mr. Cecil 0. Thomas LD-83-036 l April 26, 1983 Page 2

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Enclosures:

1-P to LD-83-036, " Responses to Questions on SLB Method".

Proprietary Version (Copies 0001-0025) 1-NP to LD-83-036, " Responses to Question on SLB Method". Non-Proprietary Version,15 copies Affidavit attesting to the proprietary nature of this report I

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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 propriettry 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 for withholding this information.

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

Erclosure 1-P to LD-83-036, Responses to Questions on SLB Method, April 1983.

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.

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.

l

1. The information sought to be withheld from public disclosure are the non-uniform flux factor and the critical heat flux ratio calculations, 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 end, 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 l 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 l

maintenance of the information in confidence.

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

a. A similar product is manufactured and sold by major pressurized i

water reactor competitors of Combustion Engineering.

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b. Development of this information by C-E required hundreds of manhours of effort and tens 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 c,mpetitor would also require considerable time and inconvenience related to the formulation and computation of the non-uniform flux factor and the critical heat flux ratio.

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 the non-uniform flux factor and the critical heat flux ratio calculations, 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 Combustion Engineering's competitors to utilize such information without similar expenditure of resources may enable them to tell 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.

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Director Nuclear Licensing Sworn to before me thishb day of 0.pa, l?P3

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