L-80-160, Forwards Five C-E Repts Re Code for Calculating PWR Scram Activities,Control Element Assembly Group Withdrawal & three-part Rept for Statistical Combination for Uncertainties.Proprietary Version Withheld (Ref 10CFR2.790)
| ML17208A684 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 05/29/1980 |
| From: | Uhrig E FLORIDA POWER & LIGHT CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML17208A685 | List: |
| References | |
| L-80-160, NUDOCS 8006060310 | |
| Download: ML17208A684 (35) | |
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~'EGULATO FORIrlATI ON DISTRIBUTION EM. (RIDS)
ACCESSION NBRe'8006060310 DOCSDATEe 80/05/29 NOTARIZEDe NO FACIL:50 335 St.
Lucie 'Plenty Unit ii Florida Power 8 Light Co, AUTH ~ NAM~
AUTHOR AFFILIATION UHRIGiE.ED Florida Power 8 Light Co.
REC IP. NAME
RECIP IENT AFFILIATION EISENHUTED.G ~
Division of Licensing DOCKET 05000335
SUBJECT:
Forwards
'f ive C
E repts r e code for calculating P~'IR scf am activitiesgcontrol element assembly group withdrawal 8
~
three-part rept for statistical combination for uncento i ties.p ropy i ster y v
re i one rrithheld Rer IOCPRE.790.
DISTR ISUTION COD; A005S COPIE RECEI ED LTR f ENCLrrrggl SIZE:~
TITLE: General Distribution for after Issuance of Operating Lic NOTES:
"ACTION:
,, INTERNAL:
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RECIPIENT ID CODE/NAME 05 BC@'R8 Qg 01 REG FILE 12 ICE 17 ENGR BR 19 PLANT SYS BR 21 EFLT TRT SYS OELD
'<EXTERNAL: 03 LPDR 23 ACRS I
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H S417 H COP IES LTTR ENCL 7
7 1
1 2
2 1
1 1
1 1
1 1
0 1
1 16 16 RECIPIENT ID CODE/NAME 02 NRC PDR 15 CORE PERF BR 18 REAC SFTY BR
'0 EEB EPB DOR STS GROUP LEADR 00 NSIC COPIES LTTR ENCL 1
1 1
1 1
1 1
1 1
1 1
1 poor uE ~: i=yr Es orBGRs REQ <Iu K
/4'/
~UN Zo >980 TOTAL NUMBER OF COPIES REQUIRED:
LTTR 38 ENCL 37 r
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l P.O. BOX 529100 MIAMI,FL 331S2 FLORIDAPOWER & LIGHTCOMPANY WITHHOLD ATTACHMENTS FROM PUBLIC DISCLOSURE May 29, 1980 L-80-160 Office of Nuclear Reactor Regulation Attention:
Mr. Darrell G. Eisenhut, Director Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.
C.
20555
Dear Mr. Eisenhut:
Re:
St. Lucie Unit 1
Docket No. 50-335 CE Desi n Methodolo Re orts Enclosed for your review/approval are fiv'e (5) copies of the following Combustion Engineering Reports:
CEN-JgZ(F), ".Fiesta, A One Dimensional, Two Group Space-Time Kinetics Code for Calculating PWR Scram Reactivities";
CEN-126(F)-P, "CEAW, Method of Analyzing Sequential Control Element Assembly Group Withdrawa'1, Event for Analog Protected Systems (Copy Nos.
000035-000039) and CEN-123(F)-P, "Statistical Combination of, Uncertainties, Parts 1, 2, and 3" (Copy Nos. 000011 000015).
Also enclosed are an additional forty (40) copies of CEN-122(F),
CEN-126(F)-NP (non-proprietary version of CEN-126(F)-P and CEN-123(F)-NP, Parts 1,
2, and 3 (non-proprietary version of CEN-123(F)-P; and also errata sheets for CEN-123(F)-P, Part"1 (Copy Nos.
000011 000015) and CEN-123(F)-NP, Parts 1 and 2.
These documents were developed for Florida Power 8 Light Company by Combus-tion Engineering and it is our intent to use them in support of future licensing actions for St. Lucie Unit 1.
Due to the proprietary nature of the material contained in CEN-126(F)-P and CEN-123(F)-P, Parts 1, 2, and 3, we request that they be withheld from public disclosure in accordance with 10 CFR 2.790 and that the material contained therein be safeguarded.
Affadavits addressing the bases for this classification are included.
Very tr ly yours, Robert E. Uhrig Vice President Advanced Systems 8 Technology REU/TCG/ah Enclosures cc:
J.
P. O'Rei lly, Region II (w/o enclosures)
Harold F. Reis, Esquire (w/o enclosures) peoeol>
PEOPLE... SERVING PEOPLE Florida Power 8 Light Company considers this application to be a special project review in accordance with 10 CFR 170.21.
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DOCMT NO. 4 eS BQ DATE:
o o
NOTE TO NRC AND/OR LOCAL PUBLIC DOCKENT ROOi>IS The following item submitted with let"er dated from
~
is being withheld from public disclosure in accordance with Section 2.r90.
PROPRIETARY INFORMATION Distribution Service's Branch
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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 Manager, 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 this affidavit in conformance with the provisions of 10 CFR 2.790 of the Commiss'ion's regulations and in conjunction with the application of Florida Power and Light Company, for withholding this information.
The information for which=proprietary treatment is sought is contained in the following document:
CEN-123(F)-P, "Statistical Combination of Uncertainties Methodology Part 1:
C-E Calculated Local Power Density and Thermal Margin/Low Pressure LSSS for St. Lucie Unit l."
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 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.
1.
The information sought to be withheld from public disclosure is the method for combining uncertainties used in the generation of limiting safety system settings, 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 resul.ts 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 be'ing 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 harm to the competitive position of Combustion Engineering because:
a.
A similar product is manufactured and sold by major pressurized
',C water reactors competitors of Combustion Engineering.
b.
Development of this information by C-E required thousands of man-hours 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 inconvenience related to methods development, data reduction and uncertainty evaluations.
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 methodology and data for the statistical combination of uncertainties, the application of which provides a competitive economic advantage.
The availability of such information to L
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, de'velopment, engineering, analytical, manufacturing, licensing, quality assurance and other costs and expenses must be included.
The ability of Combustion Engineering's competitors to utilize such infor-mation without similar expenditure of resources may enable them to sell at
,4 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.
'n addition, disclosure would have an-adverse'economic impact on Combustion Engineering's potential for obtaining or maintaining foreign licensees.
Further the deponent sayeth not.
A. E.
S rer
- Manager, Licensing Sworn to before me
'his / + day of LISA G. WAICUNAS, NOTARY PUBLIC State of Connecticut No. 54492 Commfssfon ExPIres March 31, 1983
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AFFIDAVIT PURSUANT TO 10 CFR 2.790 Combustion Engineering, Inc.
State of Connecticut County of Hartford I, A.
E. Scherer depose and say that I am the Hanager, 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 this affidavit in conformance with the provisions of 10 CFR 2.790 of the Commission's regulations and in conjunction with the application of Florida Power and Light Company, for withholding this information.
The information for which proprietary treatment is sought is contained in the following document:
CEN-123(F)-P, "Statistical Combination of Uncertainties Hethodology, Part 2:
Combination of System Parameter Uncertainties in Thermal Hargin Analysis for St. Lucie Unit.
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 financial -information.
Pursuant to the'provisions'f paragraph (b) (4) of Section 2.790 of the Commission's regulations, the following is furnished'or 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.
~
~ 1.
The information sought to be withheld from public disclosure is the method for combining uncertainties in the reference thermal margin
- analyses, 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 ra'tional 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.H. Stern to Frank Schroeder dated Dece'mber 2, 1974.
This'ystem was applied in determining that the subject documents herein are proprietary.
>I 4.
The information is being transmitted. to the Commission in confidence F.
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 fo'r 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 reactors competitors of Combustion Engineering.
b.
Development of this information by C-E required thousands of man-hours 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 inconvenience related to methods development, data reduction and uncertainty evaluations.
d.
The information required significant effort and expense to obtain the licensing approval's 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 methodology and data for the statistical combination of uncertainties, 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 sell at prices reflecting significantly lower costs.
g.
Use of the information by competitors in the internatio'nal marketplace would increase their ability to market nuclear steam supply systems by reducing the costs associated with their technology development.
In addition, disclosure would hav'e an adverse economic impact on Combustion Engineering's potential for obtaining or maintaining foreign licensees.
Further the deponent sayeth not.
E.
erer
- Hanager, Licensing Sworn.totbefore me this /itr day of No ary Public LISA G. WAICUNAS, NOTARY PUBLIC State of Connecticut No. 54492 Commission Expires hlarch 31, 1983
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AFFIDAVIT PURSUANT TO 10 CFR 2.790 Combustion Engineering, Inc.
'tate of Connecticut" County of Hartford 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 submitting this affidavit in conformance with the provisions of 10 CFR 2.790 of the Commission's regulations and in conjunction with the application of Florida Power and Light Company, for withholding this information.
The information for which proprietary treatment is sought is contained in the following document:
CEN-123(F)-P, "Statistical Combination of Uncertainties Methodology Part 3:
C-E Calculated Departure from Nucleate Boiling and Linear Heat Rate Limiting Conditions for Operation for St. Lucie Unit 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 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.
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1.
The information sought to be withheld from public disclosure is the method for combining uncertainties used in the generation of limiting conditions for operation, 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, A
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.H. Stern to Frank Schroeder dated December 2, 1974.
This system was applied in determining that the subject-documents herein are proprietary.
I 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 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 man-hours 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 inconvenience related to methods development, data reduction and uncertainty evaluations.
- d. 'he 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 methodology and data for the statistical combination of uncertainties, 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 iiiformation without similar expenditure of resources-may enable them to sell at prices reflecting significantly lower costs.
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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.
P.
L. McGil 1 Vice President Commercial Sworn to'efore me thi i '/D~daj'PdGCi(, if@
ary u l LISA G. V/AICUNAS, IIOTARY PUBLIC State ot Connecticut tto. 54492 Commtsston Expires March 31, 1983
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AFFIDAVIT PURSUANT TO 10 CFR 2.790 Combustion Engineering, Inc.
State of Connecticut County of Hartford 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 submitting this affidavit in conformance with the provisions of 10 CFR 2.790 of the Commission's regulations and in conjunction with the application of Florida Power and Light Company, for withholding this information.
The information for which proprietary treatment is sought is contained in the following document:
Errata Sheet -
P for CEN-123(F)-P, "Statistical Combination of Uncertainties Methodology Part 1:
C-E Calculated Local Power Density and Thermal Margin/
Low Pressure LSSS for St. Lucie Unit 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 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.
1.
The information sought to be withheld from public disclosure is the method for combining uncertainties used in the generation of limiting safety system settings, 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.N. 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 Comnission.
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 harm to the competitive position of Combustion Engineering because:
a.
A similar product is manufactured and sold by major pressurized
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t water reactors competitors of Combustion Engineering.
b.
Development of this information by C-E required thousands of man-hours 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 inconvenience related to methods development, data reduction and uncertainty evaluations.
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 methodology and data for the statistical combination of uncertainties, 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 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. NcGill Vice President Commercial Sworn "to before me this Ig~~da>'
iY~~/IP Notary Pub ic,c'ISA G. WAICUNAS, NOTARY PUBLIC State of Connecticut No. 54492 Commission Expires March 31, 1983
AFFIDAVIT PURSUANT TO 10 CFR 2.790 Combustion Engineering, Inc.
State of Connecticut County of Hartford I, A.
E. Scherer depose and say that I am the Manager, Licensing, of Combustion Engineeiring, 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 this affidavit in conformance with the provisions of 10 CFR 2.790 of the Commission's regulations and in conjunction with the application of Florida Power and Light Company, for withholding this information'he information for which proprietary treatment is sought is contained in the following document:
CEN-126(F)-P; CEAW Method of Analyzing Sequential Control Element Assembly Group Withdrawal Event for Analog Protected Systems'his 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 financial information.
Pursuant to the provisions of'aragraph (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.
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1.
The information sought to be withheld from public disclosure is new methods used in analyzin'g the sequential CEA Group Withdrawal (CEAW) event for C-E's 'analog protected
- systems, 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 Combustio'n 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.
6.
Public disclosure of the information is likely to cause substantial harm to the competi.tive positi'on of Combustion Engineering because:
a.
. A similar product is manufactured and sold by major pressurized 0 0 water reactors competitors of Combustion Engineering.
b.
Development of this information by C-E required hundreds of man-hours 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 competitor would also require considerable time and inconvenience related to computer modeling and algorithm development.
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 supporting data for the reclassifi-cation of the CEA Group Withdrawal event to a category where sufficient initial steady state thermal margin is built into DNB and Linear Heat Rate Limiting Conditions for Operations to ensure that DNB and CTM SAFDL's are not exceeded, 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'upport of their processes, methods or apparatus.
f.
In pricing Combustion Engineering's products and services, significant research, development, engineering, analytical,, manufacturing,
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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
\\
Engineering's potential for obtaining or maintaining foreign licensees.
Further the deponent sayeth not.
A.
E.
Sc re
- Manager, Licensing Sworn to before me this 15th day of January 1980 if Notary Public My Commis:ion Expires f1ar. 31, 1983
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UNITED STATES NUCLEAR REGULATORY COMM. ~ION WASHINGTON, D. C. 20555 OR.Mlle FOR:
TZRP. Corp.
FROM:
SUBJECT:
US ttRC/TIDC/Distribution Services Branch Special Document Handling Requirements 1.
Please use the following special distribution list for the attached document.
0 2.
The attached document requires the following special considerations:
Do not send oversize enclosure to the DRC PDR.
0 Only one oversize enclosure was received please return for Regulatory File storage.
cM( rtJ roprietary information send affidavit only to the ttRC PDR-I 0 Other: (specify) cc:
DSB Files TTZC/DSB Authorized Signature
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