ML17212B321
| ML17212B321 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 01/19/1982 |
| From: | Robert E. Uhrig FLORIDA POWER & LIGHT CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML17212B322 | List: |
| References | |
| L-82-19, NUDOCS 8201250289 | |
| Download: ML17212B321 (10) | |
Text
REGUL, Y I VFORMATI ON DilS TR I BUT' YSTEiM~ (RIDS)
'CCESSIOV, NBR: 8201250?89 DOCi, DATE': 8'2/01/19 NOIT'ARIZEO'.
YES FACILI:50 389 Sit>>.. Lbci e Piliagti Uni t" 2g Fil oridat Power:
L Llight C'oI.>>
AUTH ~ N A.4IEt
. AVTHQR AFFiILIIATION UHRIGE R,EI,,
Fil o>r i daI ?bye r.,
LIi g h t i C'o'<.
REC IP ~VA'iIEI,R" CIIPilEIV>TI AFFIILIIATI 0>>V EIISENHUT~D,G'.,
DIi v>i si op>> oIfi Liicensing, SUBJEC>T:
F'or we'r ds "CKSECI DIi gi ta'I>> Simul at i on>> of>> C: EI IVSSS.."B Encli wi thh'd (r ef>> 10CFR2 ~ 790).Af f i devi t enc'li..
DISTRIBUTION COOEi:
PB01S COP>IKS RECEI VED: LITR i ENCLI SIZEI:
T'ITLE". Propri esotery Aevi ew DIi strIibuti on>>
P>re OLI NOTES:
DOCKEITI 4l i
05000389 I
R ECIIPil EIViTI COPilKS ID CODEI/ VAIMEI LITiTR'NCLI ACITiION:
I.IICil BRI tii.3>> BCI 0
>VERSESTE V'., +N-1; 1
R ECilPIIE'NiTI ID'I CODE'/IVIAiRKI LIICI BR 43I 'kl COP IES LITTR='NCLI 1,
0>
INTERN ALI: ELO HP EXTERNAl(:
ACRS VRCI PORl OA +he L~
1>>
d l.
+06-Z/ ib 1
E. %Aron
>. &uH-IEI iVRR'IR 16 LPDR.
0 NTIIS 1,-
0'.
0>>
g) 29'OTALI NU>>>BEE Oi>> CORIKB REQUTRKO I.ITTR RI>
ERCLI Pl, Rna~
J f
~
I(
~
I r,
i t
h N
9
~f!-i'.'t
'lL' I
~
~
WITHHOLD FROM PUBLIC DISCLOSURE 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 2 9
Docket No. 50-389 Re ort on the CESEC-III NSSS Simulation Code ygll+<
i>>.A FLORIDAPOWER & LIGHT COMPANY January 19, 1982 L-82-19 8
necr~vcg 4
'<8281982~
])
B@ma~
~ CNQ~@
Enclosures:
1)
CESEC Digital Simulation of a Comubstion Engsneering Nuclear Steam Supply System,
- December, 1981, Copies 00043-00045.
2)
Affidavit from Combustion Engineering attesting to the proprietary nature of Enclosure l.
Pursuant to 10CFR2, Section 2.790, the NRC is requested to withhold this
,information from public disclosure.
Also, in accordance with Section 2.790(b),
it is recognized that withholding this information from public inspection shall not affect the right, if any, of persons properly and directly concerned with the inspection of the proprietary information.
If you should have any questions concerning the proprietary nature of material transmitted herewith, please address these questions directly to:
Mr. A. E. Scherer Director of Licensing (9438-1922)
Combustion Engineering 1000 Prospect Hill Road
- Windsor, CT 06095 We also request that you provide a copy of any questions on the proprietary nature of the enclosed report to FPL.
Very truly yours, t 820i250289 820ii9 PDR *ppcK ppppppsp Robe E. Uhrig, A
>>R Vice President Advanced Systems
& Technology REU/DME/ah Enclosure cc:
J.
P. O'Reilly, Regional Administrator (w/o enclosure)
Harold F. Reis, Esquire (w/o enclosure) ga>>L
~
~
~
8 Vgr4m l J
<~
6 Z'u>>I~an i
S$
~o
$ seLO PEOPLE... SERVING PEOPLE In the review of the St. Lucie Unit 2 FSAR, NRC requested additional information on the CESEC-III computer code used by Combustion Engineering for NSSS safety analyses (guestions 440.67, 440.80, and 440.81).
A draft report was provided in August 1981.
This letter transmits the final proprietary version of that report.
Copies of the final report should be provided to E. Throm and J.
Guttman of the Reactor Systems Branch.
4 t
l E
\\
II J
4 4
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, for withholding this information.
The information for which proprietary treatment is sought is contained in the following document:
CESEC Digital Simulation of a Combustion Engineering Nuclear Steam Supply System,
- December, 1981.
This document has been appropriately designated as proprietary.
I have personal knowledge of the cri teria and procedures utilized by Combustion Engineering in designating information as a trade seel et, 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.
~
y
~
1.
The information sought to be withhel d from publ i c disclosure are the methodology related to the determination of the pool boiling coefficient in the steam generator secondary side and the enthalpy transport algorithm in the core and steam generator primary nodes, 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 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.
1 6.
Public disclosure of the information is likely to cause substantia'1 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 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 the development of methods for calculating the NSSS response for Chapter 15 events in the safety analysis reports.
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 models f'r the deterqjnqtjon of pool lt boiling heat transfer in the steam generator secondary side and enthalpy distribution in the core and steam generator primary system
- nodes, 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, manufacture'lngi licensing, quality assurance and other costs and expenses must be included.
~
~ o
~
Q 'g 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 s
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. McGill Vice President Commercial Sworn to before me this day of PAAR~,
Notary Publ c
r h
REY > <ENZEL, NOTARY PUBLIC State of Connecticut No. 59962 Commission Expires triarch 31, 1985
a.
~ y, 14 9{'/
~
H