ML20008E937
| ML20008E937 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 03/03/1981 |
| From: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| To: | Clark R Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19260G693 | List: |
| References | |
| NUDOCS 8103100571 | |
| Download: ML20008E937 (6) | |
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.a B ALTIMORE G AS AND ELECTRIC COMP ANY P.O. B O X 14 7 5 B ALTIMO R E. M A R Y L A N D 21203 ARTHum E. LUNOVALL,dR
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March 3, 1981 s
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Office of Nuclear Reactor Regulation h
'd U. S. Nuclear Regulatory Commission U49O
\\'g'd6 o,z k7 D Sp7g Washington, D. C. 20L.g
- 'c*r ATTENTION: Mr. R. A. Clark, Chief
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Operating Reactors Branch #3 i
Division of Licensing s,
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit No.1, Docket No. 50-317 Concluding Response to NRC/Battelle Questions on STATISTICAL COMSINATION 0F UNCERTAINTIES (CEN-124(B)-P)
REFERENCE (A):
A. E. Lundvall to R. A. Clark letter dated 2/9/81, same subject d
Gentlemen:
The NRC, Battelle, and Combustion Engineering, Inc. working groups I
appeared to have had a successful meeting on November 25, 1980, rela-tive to CE Statistical Combination of Uncertainties (SCU) methodology.
j CE made commitments at that meeting to provide answers to questions and additional information concerning SCU.
Reference (A) was a partial i
response to those commitments.
Enclosures (1) and (2) complete CE's responses to commitments made at that meeting.
Enclosure (3) is an affidavit from CE requesting that infomation in Enclosure (1) be withhe:d from public disclosure in accordance with 10 CFR 2.790.
Very truly yours, BALTIM0RE GA< AND LEC,C OMPANY J&<
c u-A.E.Lundvabr.
Vice President - Supply AEL:WJL:mit r
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100 Nl'i l
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Office of Nuc'. ear Reactor Regulation March 3, 1981 Page 2 j
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Enclosures:
(1)
" Responses to First Ecund Questions on the Statistical Coc.bination of Uncertainties Program, Part 2 (CEN-124(E)-P)," February 1981 (Proprietary) copies 7-31.
(2)
" Responses to First Pcund Questions t.: the Statistical Cor.bination of Uncertainties Prcgram, Part 2 (CEN-124(E)-NP), February 1981," (Ncn-Procrietary) 20 copies.
(3) Proprietary affidavit.
Copies To:
J. A. Biddiscn, Escuire (w/out Encl.)
G. F. Trowbridge, Escuire (w/out Encl.)
E. L. Conner, Jr., NRC l
P. 'd. Kruse, CE (w/out Encl. )
ENCLOSURE ( 3)
AFFIDAVIT PURSUANT T010 CFR 2.790 Combustion Engineering, Inc.
)
State of Connecticut
)
County of Hartford
)
SS.:
I, J. M. West depose and say that I am the Vice President, Nuclear Power Systems, 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 Baltimore Gas and Electric Company, for withholding tnis information.
The information for which proprietary treatment is sought is contained in the following document:
Responses to First Round Questions on the Statistical Combination of Uncertainties, Part 2 (CEN-124(B)-P).
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 i
or as confidential comercial or financial information, j
Pursuant to the provisions of paragraph (b) (4) of Section 2.790 of l
the Commission's regulations, the following is furnished for consideration l
I by the Commission in determining whether the information sought to be j
withheld from public disclosure, included in the above referenced document, j
should be withheld.
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. 1.
The information sought to be withheld from public disclosure are the C-E thermal margin analysis methodoloay and thermal hydraulic characteristics of C-E cores, 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 dicciosed 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 Commissica 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.
1 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
.uade pursuant to regulatory provisions or proprietary agreements which orovide for maintenance 'of the infoimation in confidence.
6.
Public disclosure of the information is likely to cause substantial harm to the competitive position of Combustion Engineering because:
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E a.
A similar product is maiiuiat 09 red and sold by major pressurized water reactors competitors of Combustion Engineering.
b.
Development of this information by C E required thousands of man-hos.rs of effort and hundreds of thousands of dollars.
To the best of my knowledge and belief a competitor would have to undergo similter expense in generating equivalent information.
c.
In order to acquire such information, a competitor would also require censiderable time and inconvenience related to the d?velopment of methods for the statistical combination of the uncertainties in thermal margin analyses.
d.
The information required significant effort and expense to obtain the licensing approvals necessary for application of the information.
i 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 C-E thermal margin analysis methodology and the thermal hydraulic characteristics of C-E cores, 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 l
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.
..~
_4 The ability of Combustion Engineering's competitors to utilize such infomation i
without similar expenditure of resourcc s may enable them to sell at prices reflecting significantly lower costs.
4 I
g.
Use of the information by competitors in the irternational marketplace would increase their ability to market nuclear staam supply systemt by reducing the costs associated with their technology development.
i In addition, disclosure would have an adverse econcmic impact on Combustion J
Engineering's potential for obtaining or maintaining foreign licensees.
Further the deponent sayeth not.
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J. M. West t
Vice President Nuclear Power Systems Sworn to before me day of / el % a g I/
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this 1
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Ishis, V u
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Notary Publi.c'
/
CAREY J. WENZEL. NOTARY PUBLIC r
l Sta:e of Connecticut No. 59962 l
Commission Expires March 31.1985 l
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