ML20031F364
| ML20031F364 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 10/08/1981 |
| From: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| To: | Clark R Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19260J146 | List: |
| References | |
| NUDOCS 8110190634 | |
| Download: ML20031F364 (5) | |
Text
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BALTIMORE GAS AND ELECTRIC CHARLES CENTER P.O. BOX 1475 BALTIMORE, MARYLAND 21203 ARTHUR [, LUNDVALL. JR.
October 8,1981 Vict PRE 3sDENT SUPPLV 8 ' T d ~l 4
Office of Nuclear Rector Regulation U. S. Nuclear Regulatory Commission
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Washington, D. C. 20555
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ATTENTION: Mr. R. A. Clark, Chief u.s"ocun eD' ) 't Operating Reactors 3 ranch #3
%'88 Division of Licensing Q
SUBJECT:
Calvert Cliffs Nuclear Power Plant p
Unit Nos. I and 2, Docket Nos 50-317 and 50-318'-d\\
Responses to Second Round Questions on the Statistical Combination of Uncertainties (SCU)
Program, CEN-124(B)
REFERENCE (A):
A. E. Lundvall to R. A. Clark letter dated 6/2/81, Response to Questions on SCU, CEN-124(B)
Gentlemen:
Reference (A) responded to the bulk of the second round questions on SCU. The enclosed report contains the answer to the last question asked by Battelle. That answer provides the measured data used for the uncertainty evaluations of monitored parameters.
Enclosu:es (1) and (2) are proprietary and nonproprietary versions of the report, respectively. Enclosure (3)is an affidavit from Combustion Engineering, Inc. requesting that NRC withhold Enclosure (1) f rom public disclosure in accordance with 10 CFR 2.790.
Very truly yours, BALTIMORE GAS AND ELECTRIC COMPANY y,
g A. 6. Ltfndvall, Jr.
Vice Prksident - Supply Copies To:
- 3. A. Biddison, Esquire (w/o Encl)
G. F. Trowbridge, Esquire (w/o Enct) p ol D. H. Jaffe - NRC (w/o Encl) 8 P. W. Kruse - CE (w/o Encl)
Er. closures:
(1) CEN-124(B)-P, Part 4, Part 3 - Part 2 -
/ 13 fvw-Pap September 1981,(Proprietary). Copies 5-29 g
(2) CEN-124(B), Part 1, Part 3 - Part 2 -
September 1981, (Nonproprietary).15 Copies (3) Proprietary Affidavit 8110190634 811008 PDR ADOCK 05000317 P.
AFFIDAVIT PURSUANT T010 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, P. L. McGill depose and say that I am the Vice President, Comercial of Combustion Engineering, Inc., duly authorized to make this affidavit, and have reviewed or caused to have reviewed the infornetion which is identified as proprietary and referenced in the paragraph imediately 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 Co.. for withholding this information.
The information for which proprietary treatment is sought is contained b the following document:
Responses to Second Round Questions on the Statistical Combination of Uncertainties Program:
(CEN-124(B) - P, Part 1, Part 3) - Part 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.
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The inforaation sought to be withheld from public dikclosure is the justification for combining specific components of uncertainty via stochastic simulation analyses of the interaction of plant parameters, which is ewned 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 4
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 December 2,1974. This system was applied in determining that the subject documents herein are proprietary.
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4.
The information is being transmitted to the Commission in confidence under the provisions of 'to CFR 2.790 with the understanding that it is M 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.
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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 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 sur.h information, a competitor would also require considerable time and inconvenience related to the development of methods and the justification for combining specific components of uncertainty via stochastic simulation analyses of the interaction of plant parameters.
d.
The information required significant effort and expense to obtain the licensing approvals necessary for application cf 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.
The informatior, consists of the justification for combining e.
specific components of uncertainty via stochastic simulation analyses of the interaction of plant parameters, 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 actior,s to improve their product's position or impair the position of Combuttion Engineering's product, and avoid developing similar data and analyses in support of their processes, niethods 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.
g.
Use of the informatica 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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P. L. McGill Vice President Commercial Swor1 to before me this 05 day of 2f Ull2hL.,/98V f
AWN 42/7W6f Notary Public DAWN E. SANDER, NOTARY TU0dC State of Connecticut No. 6!536 Commission Expires March 31,1986 i
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