ML20008F583
| ML20008F583 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 04/14/1981 |
| From: | Trimble D ARKANSAS POWER & LIGHT CO. |
| To: | Clark R Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19260H041 | List: |
| References | |
| 2R-0481-03, 2R-481-3, NUDOCS 8104210319 | |
| Download: ML20008F583 (5) | |
Text
i ARKANSAS POWER & LIGHT COMPANY POST OFFICE BOX 551 LITTLE ROCK ARKAPEAS 72203 (501)371-4000
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April 14,1981 4
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Director of Nuclear Reactor Regulation 6,s ATTN: Mr. Robert A. Clark, Chief Operating Reactors Branch 3 m
y Division of Licensing U, S. Nuclear Regulatory Comnission Washington, D.C.
20555
SUBJECT:
Arkansas Nuclear One - Unit 2 Docket No. 50-368 License No. NPF-6 Response to Themal Hydraulic Section Questions Regarding the AN0-2, Cycle 2 Reload Application Gentlemen:
In res.conse to NRC Staff (Core Perfomance Branch, Thermal Hydraulic Section) questions regarding the AN0-2, Cycle 2 reload application, the enclosed infomation is provided. The NRC questions were provided to AP&L during a March 26, 1981 meeting with the staff and fomally transmitted to AP&L on April 1,1981.
Advance copies of all but two of the enclosed responses were hand delivered to Mr. Bob Martin of your i
staff on April 6 and April 10, 1981. The remaining two items were telexed to Mr. Martin on April 14, 1981.
It is requested that portions of this information be classified as proprietary infomation in accordance with the provisions of 10 CFR 2.790. The appropriate affidavit from Combustion Engineering is attached.
For your convenience five (5) proprietary ard five (5) non-proprietary versions of this information, designated as CEN-157 (A)-P, are attached as enclosure (1).
i The responses to questions 492.23 and 24 are not part of the CEN-157 (A)-P i
l document and are, therefore, included separately as enclosure (2).
l Additionally, your letter of March 23, 1981 contained NRC Reactor Physics Section questions regarding the ANO-2 Cycle 2 reload application.
i contains our responses to these questions. Five (5) copies of these responses and five (5) copies of a referenced C.E. paper, l
TIS-6368, are provided for your convenience.
Very truly yours, Yb David C. Trimble l
810A2103lT
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nanager, Licensing DCT:1p MEMOEA M100LE SOUTH UTIUTIES SYSTEM
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AFFIDAVIT PURSUANT T0 10 CFR 2.790 Combustion Engineering, Inc.
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State of Connecticut
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County of Hartford
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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 Comission's regulations and in conjunction with the application of Arkansas Power and Light Co.,
for withholding this information.
The information fcr which proprietary treatment is sought is contained in the following document:
CEH-157(A) - P, Responses to Questions on Documents Supporting the ANO-2 Cycle 2 License Submittal.
This document has been appropriately designated as proprietary.
j I have personal knowledge of the criteria and procedures utilized by Combustion Engineering in designating infonnation 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 Comission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be l
withheld from public disclosure, included in the above referenced document, 1
i should be withheld.
l 1
I b
1.
The information sought to be withheld from public disclosure are new calculational methods for thermal-hydraulic 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 rational basis for detennining 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 OP-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 l
provide for maintenance of the information in confidence.
6.
Public disclosure of the information is-likely to cause substantial harm to the canpetitive position of Combustion Engineering because:
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.o 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 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 development of methods and models for thermal-hydraulic analysis.
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 infonnation consists of new calculational methods for l
thermal-hydraulic analyses, the application of which provides a competitive l
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 l
position or impair the position of Combustion Engineering's product, and l
avoid developing similar data and analyses in support of their processes, 1
l 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.
l 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 infonnation 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.
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A. E. d ere'r Director Nuclear Licensing Sworn to before me this /O day of @M, /98
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(Khn1A Notary Ppblif 4
CGEY J. WENZEL. NOT.GY PUBLIC i
l State of Cor.necticut No. 59952 Cepm:ssion Expires f,tarch 31,1935 i
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