ML17297B605

Forwards Proprietary & Nonproprietary Comprehensive Vibration Assessment Program for Prototype Sys 80 Reactor Internals,Palo Verde Nuclear Generating Station,Unit 1. Proprietary Version Withheld (Ref 10CFR2.790)

ML17297B605
Person / Time
Site:	Palo Verde, 05000000, 05000470
Issue date:	07/02/1982
From:	Scherer A ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
To:	Eisenhut D Office of Nuclear Reactor Regulation
Shared Package
ML17297B606	List: ML17297B605 ML20054L705
References
LD-82-064, LD-82-64, NUDOCS 8207080377
Download: ML17297B605 (12)

Text

REGULATOR INFORMATION DISTRIBUTION TFN (BIDS)

AGCY'.SSION NUR:8207080377 OUTDATE: 82/07/02 NOTARIZED: YES DOCKET ¹ FACIL:50-000 Gener ic Doc@et 05000000 STN-50-470 CESSAH System 80R Combustion Engineering 05000470 STN-50-528 palo Yerde Nuclear StationR Unit l~ Arizona Publi AUTH DNA!eiE AUTHOR AFFILIATION SCMERERRA ~ ED Con'bust>on Engineeringp Ines REC IP ~ NANAK HEC IPIEN I'FF ILIATION EISFNMUTR0.G, Division of Licensing SlBJECT: Forwards propf ietary 6 nonproprietary "Comprehensive Vibration Assessment Program for Prototype Sys 80 Reactor InternalsEPalo Verde Nuclear Generating Station2Unit 1,"

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I C-E Power Systems Tel. 203/688-1911 Combustion Engineering, inc. Telex: 99297 1000 Prospect Hill Road Windsor, Connecticut 06095 SYSTEMS Docket No.: STN-50-470F July 2, 1982 LD-82-064 Mr. Darrell G. Eisenhut, Director Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Subject:

CESSAR SER Confirmatory Item Number 1

Dear Mr. Eisenhut:

Enclosed please find sixteen (16) copies of the proprietary and twenty five (25) copies of the non-proprietary versions of Combustion Engineering 's (C-E's )

Comprehensive Vibration Assessment Program (CVAP) for the System 80 prototype reactor (Palo Verde, Unit 1). The submittal of this document fulfills C-E's requirement to supply information in response to confirmatory Item 1 of the Safety Evaluation Report (SER) regarding the preoperational vibration testing program for the System 80 reactors.

A final report sumarizing the program results will be submitted to the Nuclear Regulatory Commission following completion of the testing. The CVAP has been prepared according to Regulatory Guide 1.20, which, as 'committed to in CESSAR, shall also be used as a guideline for the preparation and submittal of the final report.

guestions concerning implementation of this program may be di rected to either myself or Mr. G. A. Davis of my staff at (203)688-1911, Extension 2803.

Very truly yours, grdce COMBUSTION ENGINEERING, INC.

. E cerer Director Nuclear Licensing AES:ctk Enclosures goO3 i//(g O~L[

gg @Ion- litt(

8207080377 820702 PDR ADOCK 05000470 E PDR

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 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 the Combustion Engineering Standard Safety Analysis Report, for withholding this information.

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

CEN-202(V) - P, A Comprehensive Vibration Assessment Program for the Prototype System 80 Reactor Internals (Palo Verde Nuclear Generating Station Unit e).

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.

r

1. The information sought to be withheld from public disclosure are the results of the detailed performance analyses of the System 80 reactor internals, 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.M. Stern to Frank Schroeder dated Oecember 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 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 manhours of effort and tens of thousands of dollars. To the best of my knowledge and belief a competitor would have to undergo similar expenses in generating equivalent information.

c. In order to acquire such information, a competitor would also require considerable time and inconvenience related to the implementation of sophisticated analytical computer models required to generate the specific mechanical characteristics contained in this repor t.

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 detailed analytical information about the System 80 reactor internals which provide specific performance criteria, 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.

I

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. er r Director, Nuclear Licensing Sworn to before me this ~days of ~gAVZ N ary Pub ic NOTARY PUSUC A T. KAilArFA, NO.

TAT" OF COiiNECTICUT 31 1987 Commission Expires March