ML20078N896

Forwards Copy of Ltr NFBWR-94-033

ML20078N896
Person / Time
Site:	05200002
Issue date:	12/01/1994
From:	Ebelingkoning ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY, ASEA BROWN BOVERI, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NFBWR-94-080, NFBWR-94-80, NUDOCS 9412150067
Download: ML20078N896 (1)

Text

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December 1,1994 NFBWR-94-080 Document Control Desk

'U. S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Transmittal of Duplicate Copy of NFBWR-94-033

Dear Sir:

Per your request enclosed is another copy of our letter number NFBWR-94-033.

Derek Ebeling-Koning WLhh -

Manager, Licensing & Safety Analysis BWR Fuel Operations jet

Enclosure:

As Stated i

9412150067 941201 lDR ADOCK 03200002 PDR ABE CENO Fuel Operations I y s m  ?$nsasn / I 1

l N )I$h MilDED August 2,1994 NFBWR 94-033 CENPD 292-P Document Control Desk j U.S. Nuclear Regulatory Commission Washington, DC 20555 ATTN: Chief, Planning Program and Management Support Branch

Subject:

Transmittal for NRC review of CENPD 292-P, " BISON - One Dimensional Dynamic Analysis Code for Boiling Water Reactors: Supplement 1 to Code Description and Qualification"

Reference:

1. " BISON - One Dimensional Dynamic Analysis Code for Boiling Water Reactors: Code Description and Qualification," RPA-90-90-P-A, December 1991.

Dear Sir:

Please find as Enclosure I twenty three (23) copies of the Licensing Topical Report CENPD 292-P titled, " BISON - One Dimensional Dynamic Analysis Code for Boiling Water Reactors: Supplement 1 to Code Description and Qualification." Licensing Topical Report CENPD 292-P is being subm%ted for NRC review and acceptance for referencing in licensing actions at a future date. Also provided are ten (10) non-proprietary copies of the Licensing Topical Report identified as CENPD-292 NP.

This Licensing Topical Report described modifications to the BISON transient analysis system code supplementing the approved methods described and qualified in Reference 1. This supplemental Licensing Topical Report is part of the ABB generic BWR reload licensing methodology being submitted in support of SVEA-96 fuel deliveries commensing the beginning of 1996.

The material in CENPD 292-P contains Combustion Engineering, Inc.

proprietary information consisting of trade secrets, commercial, or financial information which we consider privileged or confidential pursuant to 10 CFR 2.790(4). In conformance with the requirements of 10 CFR Section 2.790, as amended, of the Commission's regulations, we are submitting as Enclosure II an Affidavit supporting this request for Withholding Proprietary Information. The affidavit sets forth the basis on VO.

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' - NFBWR-94-033.

Page 2 EA BACf.N eo tt e.

which the information may be withheld from public disclosure by the .

Comm1Sslon.

This material is for your internal use only and may be used only for the purpose for which it is submitted. It should not~ be otherwise used, disclosed, duplicated or disseminated,in whole or in part, to any person or organization outside the Office of Nuclear Reactor Regulation without the prior written approval of Combustion Engineering, Inc. Correspondence with respect to the Application for Withholding, should reference NFBWR -

94 033 and be addressed to D. B. Ebeling-Koning, Manager of Licensing and Safety Analysis, BWR Fuel Operations, CEP 5330 AD07, ABB Combustion Engineering,1000 Prospect Hill Road, Windsor, CT 06095.

Very truly yours, NO .

D. B. Ebeling-Koning Manager, Licensing and Safety Analysis BWR Fuel Operations cc: T. Collins /NRC M. Chatterton/NRC

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Enclosure I: Copies No. 00001-00023 '

Enclosure II: Affidavit l

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l 1

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Enclosure II to NFBWR-94-033

- Page1 AFFIDAVIT PURSUANT

'1Q .10 CEB 2.790 Combustion Engineering, Inc. )

State of Connecticut )

County of Hartford ) SS.: Windsor I, D. B. Ebeling-Koning, depose and say that I am the Manager, Licensing and Safety Analysis, BWR Fuel Operations, of Combustion Engineering, Inc., duly authorized to make this afTidavit, 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 for withholding this information.

The information for which proprietary treatment is sought is contained in the following document:

CENPD-292-P, " BISON One Dimensional Dynamic Analysis Code for Boiling Water Reactors: Supplement 1 to Code Description and Qualification," August 1994.

This document has been appropriately designated as proprietary.

I have personal knowledge of the criteria and procedures utilized by Combustion Engineering, Inc. 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.

Enclosure II to NFBWR-94-033

• Page 2

1. The information sought to be withheld from public disclosure, which is '

owned and has been held in confidence by Combustion Engineering, Inc.,

includes transient analytical methods and, analysis methodology, and benchmark calculationsand and data.  ;

2. The information consists of test data or other similar data concerning a process, method or component, the application of which results in substantial competitive advantage to Combustion Engineering, Inc.

3. The information is of a type customarily held in confidence by Combustion Engineering, Inc. and not customarily disclosed to the public.

Combustion Engineering, Inc. has a rational basis for determining the types ofinformation customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types ofinformation 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 document herein is proprietary.

4. The information is being transmitted to the Commission in confidence under the provisions of 10 CFR 2.790 with the understanding thatit 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 saurces, 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, Inc. because:

a. A similar product is manufactured and sold by major light water reactor competitors of Combustion Engineering, Inc.

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Enclosure II to NFBWR-94-033 L -

• Page 3

b. Development of this information by Combustion Engineering, Inc. '

. required thousands of manhours 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 to develop the extensive analytical models, analysis methodology, and calculational results and data.

d. The information required significant effort and expense to obtain the licensmg 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 includes extensive analytical models, analysis methodology, and calculational results and 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 Engineering, Inc., take marketing or other actions to improve their product's position or impair the position of Combustion Engineering, Inc.'s product, and avoid developing similar data and analyses in support of their processes, methods or apparatus.

f. In pricing Combustion Engineering, Inc.'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.

Enclosure II to NFBWR-94-033 page 4 -

g. vse 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, Inc.'s potential for obtaining or maintaining foreign licensees.

Further the deponent sayeth not.

__b__N___________)' ___ _ _____

D. B. Ebeling-Komng Manager, Licensing and Safety Analysis BWR Fuel Operations Sworn to before me this M day of _Oyuand ,1994 d

b__j_odMA,_______

N ry Public My commission expires: 3/,)?99

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