ML20066C382
| ML20066C382 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 10/28/1982 |
| From: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| To: | Clark R Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20066C384 | List: |
| References | |
| NUDOCS 8211090484 | |
| Download: ML20066C382 (5) | |
Text
BALTIMORE GAS AND ELECTRIC CHARLES CENTER P.O. BOX 1475 BALTIMORE, MARYLAND 21203 ARTHUR E. LUNOVALL. JR.
v.cc pacs.orm October 28,1982 Suppty Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 ATTENTION: Mr. R. A. Clark, Chief Operating Reactors Branch #3 Division of Licensing
SUBJECT:
Calvert Cliffs Nuclear Power Plant Units No. I and 2, Docket Nos. 50-317 and 50-318 Supplemental Information on FATES 3 Stored Energy Conservatism (CEN-220(B)-P)
Gentlemen:
Enclosed is a supplemental report concerning the FATES 3 code. This information should assist you in assessing the degree of conservatism in FATES 3 - computed fuel temperatures at linear heat rates and burnups associated with the ECCS analysis.
Enclosures (1) and (2) are proprietary and non proprietary versions respectively of the report. Enclosure (3) is an affidavit requesting that Enclosure (1) be withheld from public disclosure is accordance with the provisions of 10 CFR 2.790.
Very truly yours, BALTIMORE GAS AND ELECTRIC COMPANY
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A. E. Lundvall, Jr
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Vice President - S pply AEL:WJL:fid
Enclosures:
(1)
CEN-220(B)-P, Supplemental Information on FATES 3 Stored Energy Conservatism (Proprietary) Copies 2 - 25 (2)
CEN-220(B)-NP, Supplemental Information on FATES 3 Stored Energy Conservatism (Non-proprietary)- 15 copies (3)
Proprietary Affidavit Copies To:
- 3. A. Biddison, Esquire 6 a*
4;
- < 1 G. F. Trowbridge, Esquire
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[ ggg, N M C )' k D. H. Jaffe - NRC (Copy #25)
I p.,, [tf f A)T4$
P. W. Kruse - CE R. E. Architzel - NRC (Copy #26)
(9211090484 821028 PDR ADOCK 05000317 P
AFFIDAVIT PURSUANT TO 10 CFR 2.790 1
Combustion Engineering, Inc.
)
State of Connecticut
)
County of Hartford
)
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 Commission's regulations and in conjunction with the application of Baltimore Gas and Electric Company, for withholding this information.
The information for which proprietary treatment is sought is contained in the following document:
CEN-220(B)-P, Supplemental Information on FATES 3 Stored Energy Conservation, October 5, 1982.
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.
1.
The infomation sought to be withheld from public disclosure are C-E's fuel performance code and supporting experimental data, 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 determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to told certain types of 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.
4.
The information is being transmitted to the Comission 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 infomation, 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.
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 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 such information, a competitor would also require considerable time and inconvenience related to the development of a fuel performance code and the data collection from experiments.
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 C-E's fuel performance code and supporting experimental data, 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 En;ineer-ing,-take marketing 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, significant research, development, engineering, analytical, manufacturing, licensing, quality assurance and other costs and expenses must be included.
l --
4 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 information 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.
J AleN Director Nuclear Licensing Sworn to before me this /9' bay of 0 C/ONA IKON f
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Notary Publ1c Q4REE JLWENZEL. NOTAltY PUllLIC Sda of Connecticut f(0. 59962 Shamislan Engitt.s ALuh al, L985 l
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