ML20080T307
| ML20080T307 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 10/14/1983 |
| From: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| To: | John Miller Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19268E208 | List: |
| References | |
| NUDOCS 8310200241 | |
| Download: ML20080T307 (6) | |
Text
i BALTI M O R E GAS AND ELECTRIC CHARLES CENTER.P. O. BOX 1475 BALTIMORE, MARYLAND 21203 kRTHUR E. LUNOVALL, JR.
v>CE PRESIDENT sum.
October 14,1983 Office of Nuclear Reactor Regulation Attention: Mr. J. R. Miller, Chief Operating Reactors Branch #3 Divisic,n of Licensing U. S. Nuclear Regulatory Commission Washington, D. C. 20555
SUBJECT:
Calvert Cliffs Nuclear Power Unit 1 Docket No. G0-317 Refinements to Zircaloy Growth Correlation for Unit 1 Cycle 7
REFERENCE:
(A) A. E. Lundvall, Jr. to J. R. Miller letter dated September 1,1983," Supplement 1 to Seventh Cycle License Application" Gentlemen:
The evaluation of shoulder gap clearance for Unit 1 Cycle 7 Reload Engineering and Analysis was done with modified zirealoy growth correlations. Reference was made to (he modified correlations in section 4.1 of the Cycle 7 license submittal (Reference (A)). Enclosures 1 and 2 are proprietary and non-proprietary versions of the Revised 7ircaloy-4 Growth Correlations. is an affadavit from Combustion Engineering, Inc., requesting that information in Enclosure 1 be withheld from public disclosure in accordance with 10CFR2.790.
The modified correlations more adequately predict performance of the current Calvert Cliffs reactors fuel designs and reflect a large quantity of recent growth measurement data at extended burnups. It should be noted that no changes have been made to the methodology and criteria by which the correlations were utilized in the design process. The explicit modifications and the data supporting these refinements are provided for your information in Enclosure 1.
Yours very truly,
/
/
- BALfiMORE GAS AND ELECT IC COMPANY
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pp T -Revised Zirealoy-4 Growth Correlations - Proprietary, October 4,1983, copies 3-21 -Revised Zircaloy-4 Growth Correlations - Non-proprietary, October 4, 1983, 15 copics -Proprietary Affadavit (1 copy) g
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, Mr. J. R. Mill:r October 14,1983 cc:
J. A. Biddison, Jr., Esq. (w/o encl)
G. F. Trowbridge, Esq. (w/o encl)
Mr. D. H. Jaffe, NRC (w/o encl)
Mr. R. E. Architzel, NRC (w/o encl)
Mr. R. R. Mills, CE ( w/o encl)
Mr. R. E. Corcoran, DHMH (w/o encl) i i
I n
AFFIDAVIT PURSUANT TO 10 CFR 2.790 Combustion Engineering, Inc.
)
State of Conrecticut
)
County of Hartford
)
SS.:
I, A. E. Scherer, depose and say that I an 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 a Electric Company for withholding this information.
The information for which proprietary treatment is sought is contained in the following document:
l Letter Attachment, " Revised Zircaloy-4 Growth Correlations", October 4,1983 l
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 l
Commission in determining whether the information sought to be withheld from l
public disclosure, included in the above referenced document, should be withheld.
1.
The information sought to be withheld from public disclosure are the mathematical equations and supporting experimental data for design predictions of fuel assembly axial growth, 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 hold 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 deternining that the subject document 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 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.
6.
Public disclosure of the information is likely to cause substantial harm to the competitive position of Combustion Engineering because:
1
a.
A similar product is manufactured and sold by major pressurized water reactor competitors of Combustion Engineering.
b.
Development of this information by C-E required hundreds of man-hours of effort 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 related to the development of mathematical equations and supporting experimental data for design predictions of fuel assembly axial growth, 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 mathematical equations and supporting experinental data for design predictions of fuel assembly axial growth, 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 actions to improve their product's position or impair the position of Combustion Engineering's product, and avo1J 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.
The ability of Combustion Engineering's competitors to utilize such information
e 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.
'W
. RTerer Sworn to before me this W day of dC7ec(E, FIS3 df00nm @7* T h % ADM v Notary Public/
My Commission Expires Mar. 31, linio