ML20040H131
| ML20040H131 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 02/12/1982 |
| From: | Mayer L NORTHERN STATES POWER CO. |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19268A743 | List: |
| References | |
| NUDOCS 8202170242 | |
| Download: ML20040H131 (7) | |
Text
/M Northern States Power Company 414 Nicollet Mall Minneapohs, Minnesota 55401 Telephone (612) 330-5500 February 12, 1982 C
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Director pi FEB J g I9826- ~6 Office of Nuclear Reactor Regulation U S Nuclear Regulatory Commission N
Washington, DC 20555 7,
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PRAIRIE ISLAND NUCLEAR GENERATING PLANT g
Docket Nos. 50-282 License DPR-42
'83 50-306 DPR-60 Submittal of NSP Proprietary Reload Methodology Topicsl Reports Twenty-five copies of two proprietary topical reports concerning reload methodology are being submitted for your review. On December 30, 1981 the abstracts of these topicals were submitted for your review. On January 27, 1982, Mr D E Di Ianni requested submittal of the topicals.
Attached is the affidavit of Mr T 0 Anderson and Mr J R Fisher which states the basis for exemption from public disclosure of these topical reports. The attached reports are:
NSPNAD-810lP Qualification of Reactor Physics Methods for Application to PI Units NSPNAD-8102P Reload Safety Evaluation Methods for Application to PI Units (and Errada and Addenda sheet)
The non proprietary versions of these topical reports are being submitted with a separate letter to be dated February 18, 1982.
Please notify us when a meeting with our technical people would be beneficial to your review or if the submittal of additional information is necessary. As explained in our December 30, 1981 letter, a completion date for your review of January 1, 1983 is requested.
V L 0 Mayer, PE Manager of Nuclear Support Services LOM/TMP/bd cc: Regional Admin-III, NRC (w/o attachments) gg h NRR Proj Mgr, NRC NRC Resident Inspector (w/o attachttents)
G Charnoff Attachments contain 10 CFR Part 2.790(a)(4) Information F202170242 8202I2 PDR ADOCK 05000282 P
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i AFFIDAVIT Before me, the undersigned authorities, personally appeared John R.
Fisher, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Nuclear Associates International (NAI), a consulting service of Control Data Corporation, and Roger 0. Anderson, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Northern States Power Company (NSP), and that the averments of fact set forth in this Affidavit are true and correct to the be-t of their knowledge, information, and belief:
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d John R. Fisher Yechnical Director Nuclear Associates International (NAI)
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~ Roger 0. Anderson General Supt., Nuclear Analysis Northern States Power Company (NSP) i Sworn to and subscribed before me this l& N day of Fehturh 1982.
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Notary Public L y
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e 1.0 J. R. Fisher is Technical Director of Nuclear Associates International (NAI), a consulting service of Control Data Corporation (CDC), and Roger 0. Anderson is General Superintendent of Nuclear Analysis of Northern States Power Company (NSP), and as such we have been speci-fically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing or rule-making proceedings, and are authorized to apply for its withholding on behalf of NAI and NSP.
2.0 We are making this Affidavit in conformance with the provisions of 10 CFR Section 2.790 of the Commission's regulations and in conjunction with NAI/NSP application for withholding accompany this affidavit.
3.0 We have personal knowledge of the criteria and procedures utilized by NAI/NSP in designating information es a trade secret, privileged or as confidential commercial or financ.'al information.
4.0 The following is furnished, per Section 2.790 paragraph (b) (4) of the Commission's regulations, for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.
- 1) A significant part of NAI/NSP's present and future consulting business to utilities is based on the licensing of proprietary computer codes, proprietary procedures for setup and application of these codes, and proprietary results used for validating said system of computer codes and procedures.
- 2) The information sought to be withheld from public disclosure is owned and has been held in confidence by NAI and its licensees.
- 3) This information is the type normally held proprietary by NAI/NSP and not customarily disclosed to the public. There is rational basis for determining the types of information that NAI/NSP normally holds proprietary.
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4.1 Informaticn is held prsprictary if its relcase might result in the loss of existing or potential competitive advantage. These types of information are categorized as follows:
- 1) The information reveals the distinguishing aspects of a program, methodology, algorithms, procedures, etc.
where prevention of their use without license provides a competitive advantage over other companies.
- 2) The information consists of supporting data, including test data, which aids in validation of methodologies and thereby provides a competitive advantage, e.g.,
computer runtime, reduced number of computer runs, creditability, etc.
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- 3) The use of the information by a competitor would reduce his expenditure of resources and/or improve his competi-tive position in application or licensing of a similar
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product.
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- 4) The information reveals aspects of past, present, or j
future NAI/CDC and/or NSP funded development plans and programs of potential commercial value to NAI/NSP.
- 5) The information is not the property of NAI or NSF, but must be treated as proprietary by NAI and NSP according to agreements with the owner.
l 4.2 There are valid reasons for NAI and NSP establishing these categories for evaluation of the confidentiality of information which include the following:
It is, therefore, withheld from disclosure to protect the NAI competitive position..
- 2) It is information which is marketable in many ways.
The extent to which such information is available to competi-tors diminishes NAI's and NSP's ability to license systems and services involving the use of the information.
- 3) Use by our competitor would put NAI and NSP at a competitive disadvantage by reducing his expenditure of resources at our expense.
- 4) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage.
If competitors acquire components of proprietary information any one component would provide sufficient indication of the total thereby depriving NAI and NSP of a competitive advantage.
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Unrestricted disclosure would jeopardize a potential advantage in this market.
- 6) The NAI/NSP capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage in the licensing of systems and services.
5.0 The information is being transmitted to the Commission in confidence and under the provision in 10 CFR Section 2.790; it is to be received in confidence by the Commission.
6.0 The information is not available in public sources to the best of our knowledge and belief.
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7.0 The proprietary information sought to be withheld in this submittal is that which is appropriately marked in the report. " Qualification of Reactor Physics Methods for Application to PI Units."
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The document is being submitted as a Topical Report and will be referenced in future licensing or standardized reference approval a ppl ications.
The information enables NAI and NSP to:
- 1) Justify the methodology and procedures used in the reload analysis.
- 2) Assist its clients to obtain licenses.
- 3) Provide greater flexibility and additional reload design options to its clients and through in-house capability.
- 4) Provide to its clients a means of supporting the plant on a day-to-day basis and hence the potential of increasing aval - bility.
In addition, the information presented in the subject documents and other similar endeavors is of commercial value to NAI and NSP and can be a source of considerable sums of money, for example:
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- 1) NAI and NSP use the information to support the methodology, I-procedures, and services that NAI/NSP provide to their clients.
- 2) NAI and NSP use the information to provide a database whic'n aids in the validation of the system of computer codes and provedures which NAI and NSP license to their clients.
- 3) Based on the experience gained and the methods developed from this and like information for other clients, NAI and NSP are automating the approach and procedures described and plan to license the resulting system.
8.0 Public disclosure of information concerning the " Qualification of Reactor Physics tiethods for Application to PI Units" program is likely to cause substantial harm to the competitive position of NAI and NSP by allowing their competitors to develop similar analysis methods and models at a much reduced cost. The analysis performed in this, --
endeavor is a result of an analytical system (methodology, programs and procedures) which has been developed at NAl and NSP over a period of years.
This represents a significant amount of-highly qualified development effort resulting in NAI's and NSP's current business posture.
Should a potential competitor be able to use the results of this analyses and descriptions of methodology in the attached document to establish and verify their own programs and procedures, the technical and monetary effort to achieve a comparable capability would be vastly reduced.
NAI and NSP have expended a significant amount of money and technical resource to achieve their current position, a position which a competitor can attain only through a like investment of money and qualified technical talent.
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