LD-88-008, Forwards Proprietary Base Line Level 1 PRA for Sys 80r NSSS Design. Rept Presents Methodology & Results of Sys 80 PRA to Be Used for Evaluation of Design trade-offs for Sys 80+ Std Design

Forwards Proprietary Base Line Level 1 PRA for Sys 80r NSSS Design. Rept Presents Methodology & Results of Sys 80 PRA to Be Used for Evaluation of Design trade-offs for Sys 80+ Std Design

ML20148L987
Person / Time
Site:	05000470
Issue date:	01/22/1988
From:	Scherer A ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
To:	Vissing G NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), Office of Nuclear Reactor Regulation
Shared Package
ML19341D837	List: LD-88-008, Forwards Proprietary Base Line Level 1 PRA for Sys 80r NSSS Design. Rept Presents Methodology & Results of Sys 80 PRA to Be Used for Evaluation of Design trade-offs for Sys 80+ Std Design
References
LD-88-008, LD-88-8, NUDOCS 8801280263
Download: ML20148L987 (7)

Text

COMBUSTION ENGINEERING January 22, 1988 LD-88-008 Docket No. STN 50-470F Mr. Guy S. Vissing, Program Manager Standardization and Non-Power Reactor Project Directorate Attn: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Probabilistic Risk Assessment for the System 80R Design

Enclosures:

(1)-P "Base Line Level 1 Probabilistic Risk Assessment for the System 80 R NSSS Design", January 1988 (Copy Nos. 00001-00008) 1 (2) Proprietary Affidavit

Dear Mr. Vissing:

Tile purpose of this letter is to transmit six (C) copies of a report on the i Probabilistic Risk Assessment (PRA) for the System 80Rdesign. The enclosed reports are being providad only as lackground information for our Design Certification Program.

1 The enclosed report presents the methodology and results of the System 80 l PRA. This PRA will be used during the design process to evaluate design  !

trade-offs for the System 80+ MStandard Jesign. Those results are 1 considered by Combustion Engineering to ao proprietary in nature. As I such, we request that they be withheld f'om public disclosure in accordance with the provisions of 10 CFR 2.790 and that this material be safeguarded accordingly. The reasons for the classification of th's material as proprietary are delineated in the affidavit provided in Enclosure (2).

He kl Z,,eu TC: Glen <{LI I 0A ' C. CleLiib. . 3 2003 i g Oly; ${h gg ,, ,f Cr . Artart

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, a e d osv rau i Power Systems 1000 Prospect HiU Road (203) 688 1911 Combustion Engineering, Inc. Post Office Box 500 Telex: 99297 l 8801280263 880122'?

PDR ADOCK 05000470 A PDR

Mr. Guy S. Vissing LD-88-008 January 22, 1988 Page 2 If you have any questions regarding this matter, please do not hesitate to call me or Mr. S. E. Ritterbusch of my staff at (203) 285-5206.

Very truly yours, COMBUSTION ENGINEERING, INC.

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A. dcIte'rer '

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Director Nuclear Licensing AES:blr '

Enclosures 1

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Enclosure (2) to LD-88-008 Affidavit Pursuant to 10 CFR 2.790 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 proprietary and referenced in the paragraph immediately below. I am submittir.g 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:

1) "Base Line Level 1 Probabilistic Risk Assessment for the System 80 RNSSS Design", Combustion Engineering, Inc., January 1988. l l

This. document has been appropriately designated as proprietary.

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

l 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  ;

CommissioM 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 numerical results of the System 80 RProbabilistic Risk Assessment, 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 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

'n i 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 manufactured and sold by major pressurized-water reactor competitors of Combustion Engineering.

b. Development of this information by C-E required thousands of hours' of labor and hundreds of thousands of dollars. To the best.of my knowledie-and belief, a competitor would have to undergo similar expense in generating equivalent information.

c. In order to acquire such information, a competitor wei:! t also require considerable time and inconvenience to develop the reported numerical ,

R results of the System 80 Probabilistic Risk Assessment.

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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.  !

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e. The information consists of numerical results of the System 80 Prababilistic Risk Assessment, the application of which provides a competitive l economic advantage. The availability of such information to competitors would l 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 I

developing similar data and analyses in support of their processes, methods or apparatus,

f. In pricing Combustion Engineering's products arid services, 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 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 1

Engineering's potential for obtaining or maintaining foreign licensees.

Further the deponent sayeth not.

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A. E. herer Director Nuclear Licensing Sworn to before me this g?A day of Tg , /9g7 L 2 dd/

Notary Public()

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THIS J.L DAY OF TM4M6 194.

ANN L [7)s9EL, NOTARY PUBUC STATE OF CONNECTICUT NO.81559 COMMISSION EXPIRES MARCH 31,1992 l

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