ML17195A045
| ML17195A045 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 11/30/1983 |
| From: | Rybak B COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML17195A046 | List: |
| References | |
| 7710N, NUDOCS 8312130335 | |
| Download: ML17195A045 (6) | |
Text
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- ...,. 80 Commonwe.-.,dison
- One First Nation~~. Chicago. Illinois Address Reply to: Post Office Box 767 Chicago. Illinois 60690 November 30, 1983 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission:
Washington, DC 20555 Subje6t:
Dresden Station Unit 3 Use of ASEA-Atom CRD Blades Durin~.Cycle 9~ Supplemental Information.
Re fer.enc e ( a ) :
D ~ M : Cr u t ch fie 1 d. to D.. L ~ Fa r r a r 1 e t t er dated November 1, 1~83~
Dear Mr:
Denton:
The r~ference l~tter requested additional material,
concerning our* submittal of _July 18, 1983 regarding the use of ASEA-Atom (A~A) CRD blades dVring the ~pcomin~ operating cycle.
We have *entlosed, in the form of.attachments to this letter, our response to yo.ur.questions*.*.. Attachment 1 (A-A report PM BR 83-277).
directly answers the questions raised, ~hile Attachments 2 through 5 are rep or ts referenced in.th.at attachment re si:ronse. is a summary-of operating expeii~nce of A-A control bl~des.
- Finally as the infcitmation in Attachment~ 1 throught *4 'is co~sider~d proprietary to ASEA-Atom.we have enclosed. their ~ffidavit attesting to the proprietary nature: o*f the reports.
One (l) signed original of this letter and forty *(40) copies of this letter is provided for ypt.Jr use.* Due to the size and basic prop~ietary nature *of the attachments*only six (6) copies are enclosed~
Very truly yours, Administrator
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... 2-Attachments
( 1)
AA -PM BR 83-277 * - Response to U.SNRC Que*stions ;on, ASEA-Atom-Blades foi Dresden Unit j.
~
(2)
AA PM KUA 82-115 Rev~ 1 EPRI Control Rod Stress Analysis (3)
AA PM KUA 82-160 Rev~ 1 EPRI Control Rod End-of-life Properties and Seismic Considerations (4)
AA PM BR 83-265 B4C Temperatures in AA Control Blades (5)
Nutech Incorporated Report COM-45-003 Technical Review of ASEA-Atom's Control Blades for compatibility with Reactor for Dresden Units 2 and 3.
(6)
Op~rating experience with A-A control blade.
(7)
A-A Affidavit; G~G~ A~- Bernander dated 11/24/83~
cc:
NRC Resident Inspector-Dresden Robert Gilbert NRR 7710N bg
1 AFFIDAVIT I, Goran G.A. Bernander, hereby say and depose:
- 1.
I am Manager, Reactor Core Design, for AB ASE A-A TOM
("AA"), and as such I am authorized to. execute this Affidavit.
- 2.
I am familiar with AA's detailed ~ocument control system and policies which govern the protection and control of information.
- 3.
I am familiar with the following document entitled:
"Response to USNRC.Questions on ASEA-A TOM Blades for Dresden-3" (PM BR 83-277) and three documents added in support:
"EPRI Control Rod Stress Analysis" (PM KUA 82-115 Rev. 1)
"EPRI Control Rod End-of-Life Properties and Seismic Considerations" (PM KUA 8~-115 Rev. 1) 11B4C Temperatures in AA Control Blades" (PM BR 83-265)
All four documents are ref erred to as * "Documents".
Information contained in these Documents have been
. classified by AA as proprietary in accordance with the system and policies established by AA for the control and protection of information.
,.J 2
- 4.
The Doc;uments contain information of* a proprietary and confidential nature and are of* the type customarily held in confidence by AA and not made available to the public.
Based on my experience, I am aware that other companies regard information of the kind contained in these Documents as being proprietary and confidential.
- 5.
The Documents have been made available to the United States. Nuclear Regulatory Commission in confidence, with the request that the information contained in the Documents not be disclosed or divulged.
- 6.
The Documents contain information which is vital to a competitive advantage of AA and would be helpful to competitors of AA when competing with AA.
- 7.
The information contained in these Documents is c.onsidered to be proprietary by AA because it reveals certain distinguishing features of a proven, uniql!e. BWR longlife control blade design and includes information utilized by AA in its business whkh affords AA an opportunity to obtain a competitive advantage over its competitors who do not or
- may not know or use the information contained in these
'Documents.
- 8.
The disclosµre of the proprietary information contained in these Documents to a competitor would permit. the competitor to reduce its expenditure of money and manpower and to improve its competitive position by giving
- it extremely valuable insights into AA's BWR control blade design and performance data and would result in substantial harm to the competitive position of AA.
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- 9.
The Documents contain proprietary information which is held in confidence by AA and is not available in public sources.
- 10.
In accordance with AA's policie*s governing the protection and control of information, proprietary information contained in these Documents has been made available, on a limited basis, to others outside AA only as required and under suitable agreement providing for non-disclosure and limited use of the information.
- 11.
AA policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.
- 12.
These Documents provide information which reveals AA control blade design developed by AA over the past ~ifteen years. AA has invested substantial amounts of money and many man-years of efforts in the related development and has more than ten years of successful reactor operation experience with this unique control blade design* Assuming a competitor had available the same background data and incentives as AA, the competitor might, at a minimum, develop the information for the same expenditure of manpower, money and reactor operating time as AA.
- 13.
Based on my experience in the industry, I do not believe that the background data and incentives of AA's competitors are sufficiently similar to the corresponding background data and incentives of AA to reasonably expect such competitors would be in a position to duplicate AA's proprietary information contained in these Documents.
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, THAT the statements made hereinabove are, to the best of my knowledge, information, and belief, thruthful and complete.
FURTHER AFFIANT SAYETH NOT.
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......... 2................... ~
Goran G.A. Bernander Confirmed and subscribed before me this 24th day of November, 1983.
Vasteras, Sweden.
) fficio// z_f Birger
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Notary Public of the city VCister~s r!r~?eao SEK