ML20031F385
| ML20031F385 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 10/14/1981 |
| From: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| To: | Clark R Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19260J148 | List: |
| References | |
| NUDOCS 8110190711 | |
| Download: ML20031F385 (5) | |
Text
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GAS AND ELECTRIC CHARLES CENTER + ?.O. BOX 1475 BALTIMORE, MARYLAND 21203 ARTHUR E. LUNOVALL. JR.
October 14,1981 v,cc p c.,m,
- sum, Office of Nuclear Reactor Regulation J. S. Nuclear Regulatory Commission O
D Washington, D. C. 20555 g
q cQf VQ ATTENTION: Mr. R. A. Clark, Chief Operating Reactors Branch #3 1
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Division of Licensing I--i o
SUBJECT:
Calvert Cliffs Nuclear Power Plant M
Unit Nos. I and 2, Docket Nos. 50-317 and W318 q
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Responses to NRC Questions on the
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Amendment to Environmental Report 4
REFERENCE (A):
A. E. Lundvall to R A. Clark letter dated 9/18/81, Amendment to Enviroamental Report (B):
A. E. Lundvall to R. A. Clark letter dated 3/23/81, Amendment to Environmental 11cport Gentlemen:
Reference (A) provided the scope and schedule for responses to several informal questions or Reference (B). Enclosures (1) and (2) are proprietary and nonproprietary versions respectively of responses to those questions. Enclosure (3) is an affidavit from Conibustion Engineering, Inc. requesting that Enclosure (1) be withheld from public disclosure in accordance witn 10 CFR 2.790.
Very truly yours, BALTIMORE GAS AND ELECTRIC COMPANY Ol 3
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! 30 "* Asd LL A.' E. Lundvall, Jr.
D 749 Vice President - Su ly Copies To:
- 3. A. Biddison, Esquire (w/o Encl)
G. F. Trowbridge, Esquire (w/o Enct)
D. H. Jaffe - NRC (w/o Encl)
P. W. Kruse - CE (w/o Encl)
Enclosures:
(1) Responses to NRC Questions on CEN-122(B)-P (Proprietary) Copies 5-44 (2) Responses to NRC Questions on CEN-122(B)-NP (Nonproprietary) 20 Copies (3) Proprietary Affidavit
'8110190711 811014 PDR ADOCK 05000317 PDR sP
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AFFIDAVIT PURSUAi1T T010 CFR 2.790 Combustion Engin7ering, Inc.
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State of Connectient
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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, Commer.ial 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 applicatica of Baltimore Gas and Electric Co., for withhciding this information.
The information for which proprietary treatment is sought is contained in_the following document:
CEN-186(B)-P, Responses to flRC Questions on CEN-122(B)-P (" Environmental Impact of Extended Burnup Fuel Cycles in Calvert Cliffs Units 1 and 2",
dated Ma rch, 1981 ), ' October, 1981.
This ' ocument has been appropriately designated as proprietary.
d 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 detennining whc-Ser the information sought to be withheld from public disclosure, included in the above referenced document, should be withheld.
1.
The information sought to be withheld from public disclosure are the detailed data and analyses regarding performance of C-E fuel, 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 infomation 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.
i.ie 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 detennining 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 infonnation, 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 a nfidence.
m 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 mar.ufactured and sold by major pressurized water reactors competitors of Combustion Engineering.
b.
Development of this information by C-E required hundreds of manhours of effort and tens of thousands of dcllars. 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 data acquisition and performance of analyse', on fuel performance.
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 the detailed data and analyses regarding fuel performance, 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 ma.keting 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, I
t i-;nificant research, development, engineering, analytical, manufacturing, licensing, quality assurance and other costs and expenses must be included.
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l The ability of Combustion Engineering's competitors to utilize such information without similar expenditure of resources may enable them to sell at prices
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reflecting significantly lower costs.
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Use of the information by competitors in the international marketplace would increase their ability to market nuclear s+.eam. supply systems by reducing the costs associeted with their technology development.
In add cion, disclosure would have an adverse economic impact on Combustion Engineering's potential for obtaining or maintaining foreign licensees.
Further the deponent sayeth not.
1 S
P. L. McGill Vice President Commercial Sworn to before me day of Ot/ch, / M '
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Notary FtsbliU g
1 CAREY J. Weizil, xoDRY PUBLIC State of Carechett (b. 59902 Comdssica Exp;rc f.b.ch 31,1935