ML19341A233
| ML19341A233 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 01/09/1981 |
| From: | Trimble D ARKANSAS POWER & LIGHT CO. |
| To: | Clark R Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19260G483 | List: |
| References | |
| 2-011-11, 2-11-11, NUDOCS 8101220414 | |
| Download: ML19341A233 (5) | |
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[h ARKANSAS POWER & LIGHT COMPANY
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%e POST OFFICE BOX 551 LITTLE ROCK, ARKANSAS 72203 (501) 371-4000 i
January 9,1981 kQ 2-011-11 Director of Nuclear Reactor Regulation ATTN:
Robert A. Clark, Chief Operating Reactors Branch #3 Division of Licensing U. S. Nuclear Regulatory Comm.
Washington, D.C.
20555
SUBJECT:
Arkansas Nuclear One - Unit 2 Docket No. 50-368 License No. NPF-6 CPC/CEAC Software Modifications for Arkansas Nuclear One - Unit 2 (File: 2-1510)
Gentlemen:
E Enclosed are forty (40) copies of CEN-443(A)-P (proprietary) document numbers 000001-000040 and twenty (20) copies of CEN-143(A)-Np (Non-proprietary) "CPC/CEAC Sof tware Modifications for Arkansas Nuclear One-Uni t 2".
This report describes the modifications to be made to the CPC/CEAC sof tware to support cycle 2 of operation and contains a new algorithm, a greater number of addressable constants and increased diagnostic capabilities.
This report will be referenced in the up-coming AND-2 cycle 2 reload report to be submitted in the near future.
Due to the proprietary nature of the material contained in CEN-143(A)-P, we request this report be withheld from public disclosure in accordance with the provisions of 10 CFR 2.790 and that this material be safeguarded.
The reasons for the proprietary classification of this report are delineated in the enclosed affidavit.
Any questions regarding the proprietary nature of this material should be addressed to:
Combustion Engineering A. E. Scherer Director, Nuclear Licensing 1000 Prospect Hill Road Windsor, Connecticut 06095 8101am&{h MEMBER MICOLE SOUTH UTILITIES SYSTEM
Mr. Robert A. Clark January 9, 1981 All other questions should be addressed to AP&L.
Very truly yours, hCukkh.
David C. Trimble Manager, Licensing DCT:JTE:1p Enclosure e
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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 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 Arkansas Power & Light Co. for withholdir.g this information.
The information for which proprietary treatment is sought is contained in the following document:
CEN-143(A)-P, "CPC/CEAC Software Modifications for Arkansas Nuclear One - Unit 2".
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.
1.
The information sought to be withheld from public disclosure is a description of modifications to the CPC/CEAC software, consisting of a new algorithm, a greater number of addressable constants and an increased diagnostic capability, 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 Engi,neering 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 Frar,t. 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 confi-dence 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 sub-stantial harm to the competitive position of Combustion Engineering because:
i a.
A similar product is manufactured and sold by major pressurized water reactors competitors of Combustion Engineering, b.
Development of this information hy 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 to perform the parametric studies and analytical _ comparisons related to the development of the algorithms and to expend time and effort reviewing plant start-up and operating data to gain these diagnostic capabilities.
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 4
applicable.
e.
The information consists of updates to the CPC/CEAC functional specifications, 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 informa-tion 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.
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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.
.<.c w A. E. -ScheYer Director, Nuclear Licensing Sworn to before me this /[ day of Ou.c.nx/cA 1up 0
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