ML20082P852
| ML20082P852 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 11/30/1983 |
| From: | William Jones OMAHA PUBLIC POWER DISTRICT |
| To: | John Miller Office of Nuclear Reactor Regulation |
| References | |
| LIC-83-300, NUDOCS 8312090210 | |
| Download: ML20082P852 (5) | |
Text
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S' Omaha Public Power District 1623 Harney Omaha, Nebraska 68102 402/536-4000 November 30, 1983 LIC-83-300 Mr. J.
R.
Miller, Chief U.
S. Nuclear Regulatory Commission Of fice of Nuclear Reactor Regulation Division of Licensing Operating Reactors Branch No. 3 Washington, D.C.
20555
Reference:
Docket No. 50-285
Dear Mr. Miller:
Statistical Combination of Uncertainties Report in Support of the Port Calhoun Station Cycle 9 Reload Submittal The above report was submitted to the Commission by Omaha Public Power District on November 11, 1983.
The attached affidavit was inadvertently omitted from that submittal.
Please include this affidavit with the District's November 11, 1983 letter (LIC-83-283).
Sincerely,
!bll;ye i
W. CJ Jones Divid on Manager Production Operations WCJ/JCB:jmm Attachment cc:
LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.
i Washington, D.C.
20036 Mr.
E.
G.
Tourigny, Project Manager Mr.
L.
A.
Yandell, Senior Resident Inspector D
O 000 5
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45 5124 Employment with Equal Opportunity i
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L AFFIDAVIT PURSUANT TO 10 CFR 2.790 Combustion Engineering, Inc.
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State of Connecticut
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County of Hartford
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SS.:
I, J. M. West, depose and say that I am the Vice President Nuclear Power Systems, 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 L
CFR 2.790 of the Commission's regulations and in conjunction with the application of Omaha Public Power District, for withholding this information.
The information for which proprietary treatment is sought is contained in the following document:
CEN-257(0)-P, Statistical Combination of Uncertainties.
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.
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methods of developing uncertainty, distributions, limiting values of thermal
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lsetpoints and technical specifications, which is owned and has been held in
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t of confidence. by Combustion Engineering.
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.2.. - The information consists of test data or other similar data concd (ing n
j a process, method or component, the application of which-results in [i I$
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T' substantial competitive advantage-to Combustion Engineering.-
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The information is-of a type customarily heid in confidence by - '
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Combustion Engineering and not customarily disclosed to the public., Combustion ~
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-Engineering has a rational-basis for'det,ermining the types of infor ation v
customarily held in confidence by it and, in that c6nnection, utilikes a systim '
- to ' determine when and whether to hold certain' t9 pes of infbrmation in confidence. The details of the aforementioned system were provided to the 3
t Nuclear Regulatory Commission via letter DP-537 from F.M. Stern to Frank
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Schroeder dated December 2, 1974. This system was applied in determining >that y..
the sub ject document herein are proprietary.
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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.
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The information, to the best of my knowledge and belief, is not j(%
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pursuant to regulatory prov(sion]s or proprietary agreements which provide,for h*
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j maintenance of the information in confidence.
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.6. 'Public disclosure of the information is. likely to cause substantial
. harm to the competitive position of Combustion Engineering because:
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- a. - A similar product is manufactured and sold by major pressurized water reactor comnetitors of Combustion Engineering, b.
Development of this information by C-E required thousands of manhours-of effort and hundre'ds of thousands of do1;1ars. To the best of my knowledge and belief a competitor would have to undergo similar expense in generating equivalent information.-
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In order to acquire l',such information, a competitor would also I
require considerable time and inconvenience to develop methods related to I
uncertainty distributions and therma 12 hydraulic variables as applied to setpoints and. technical specifications.
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- d. -The information required significant effort and expense to.obtain the licensing approvals necessary for application'of the information.
. Avoidance af this expense would decrease a competitor's cost in applying the information and. marketing the product to which the information is applicable, e.
The'informatiion consis5s of statistical methods used to combine
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uncertainties in the development.of setpoints. and technical specifications, the application of which provides a competitive economic advantage.
The availability of such information tc :ompetitors would enable them to modify
- their product to better competie with Combustion Engineering, 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,Lmethods or apparatus.
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.In pricing Combustion Engineering's products and services, i
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significant research, development, engineering, analytical, manufacturing,
-licensing. quality assurance and other costs and expenses must be included.
-The ability of Combustion:Engideering's competitors to utilize such information
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wittiout 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.
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J. ti.' West Vice President Nuclear Power Systems Sworn to before me this 8 day of Do(emb_ra, N N 3
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' Notary Public' U
THERESA fA. REGAN, NOTARY PUBLIC JTATE OF CONNECTICUT fl0. 05097 COMMISS!0tt EXPlRES MARCH 31,1988 n
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