ML20126M592
| ML20126M592 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 06/02/1981 |
| From: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| To: | Clark R Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19276K134 | List: |
| References | |
| NUDOCS 8106190235 | |
| Download: ML20126M592 (6) | |
Text
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g( bl,\\ 1 M (1 GAS AND g-ELECTRIC J
ls CHARLES CENTER P.O BOX 1475 BALTIMORE MARYLAND 21203 b-
,y M e 2' M k'*"7i b'M ARTHUR c. LUNDVALL JR.
WCC PetSIDENT so.u 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 Unit No. I and Unit No. 2 Docket Nos. 50-318 and 50-319 Response to Question on B ASSS, CEN-il9(B)
-REFERENCE (Ah A. E. Lundvall to R. A. Clark letter, dated 6/26/80 Gentlemen:
Reference (A) transmitted Better Axial Shape Selection System (BASSS) report, CEN-il9(B). for your review and approval.
Enclosed is our reponse to c.
questien posed by NRC staff on that report.
Enclosures (1) and (2) are proprietary and non-proprietary versions respectively.. Enclosure (31 is an affidavit from Combustion Engineering, Inc., requesting that informction in Enc!csure (1) be withheld from public disclosure in accordance with 10 CF2 2.790.
Very truly yours, BALTIMORE GAS AND E,LECTRIC COMPANY 7-o 4 d
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,6 THIS DOCUMENT CONTAINS POOR QUAL.lTY PAGES
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Office of Nuclear Reactor Regulation June 2,1981 Page 2
Enclosures:
(1)
Responses to questions on BASSS, CEN-119(B)-P, May 1981. Copies 1-40 (2)
Responses to questions on BASSS, CEN-119(B)-NP, May 1981. 20 Copies (3)
Proprietary Affidavit Copies To:
- 3. A. Biddison, Esquire (w/out Encl)
G. F. Trowbridge, Esquire (w/out Encl)
E. L. Conner, Jr., NRC P. W. Kruse, CE (w/out Enc 1) 4
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ENCLOSURE (3)
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, 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 Co.,
for withholding this information.
The'information for which proprietary treatment is sought is contained in the following document:
Responses to Second Round Questions from the NRC on the Better Axial Shape Selection Sys tem (BASSS) Report (CEN-119(B)-P).
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 Concission's requietions The following in furnished Ar censideration ty the Coccissioc in t r -- i i m. ! s -- the inforr.mtic:, sought to be c
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4 1.
The information sought to be withheld from public disclosure is the setpoint methodology used to calculate the BASSS BLIM coefficients, 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 frcm 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 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 er proprietary agreements which l
l provide for maintenance of the information in confidence.
l 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
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water reactors competitors of Combustion Engineering, b.
Development of this information by C-E required thousands of manhours 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 setpoint methodology used to calculate the BASSS BLIM coefficients.
d.
The infe mation 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 the setpoint methodology used to calculate the BASSS CLIM coefficients, the application of which provides a competitive economic advanta,ge.
The availability of such information to competitors would enable them to modify their product to better cc:npete 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 thcir Srocesses, me*, nods or apparatus.
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In pricing Combustien Erg meci r' T
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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.
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Use of t,he infore tion by competitors in the international I
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 1 s_g A. E. b erer Director Nuclear Licensing Sworn to before me this ((U day of NtL) ; I ) E I i;
Notary Public l
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