ML20198N862
| ML20198N862 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 01/09/1998 |
| From: | Sorensen J NORTHERN STATES POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9801210238 | |
| Download: ML20198N862 (7) | |
Text
i Northern States Power Company Prairie Island Nuclear Generating Plant 1717 Wakonado Dr. Eart Welch, Minnesota $$089 l
l January 9,1998 U S Nuclear Regulatory Commission Attn: Document Control Desk j
Washington, DC 20555 PRAIRIE ISLAND NUCLEAR GENERATING PLANT Docket Nos. 50-282 License Nos DPR-42 50-306 DPR-60 Revised ABB Combustion Engineering Affidavit l
By letter dated November 10,1997, NSP submitted a copy of the proprietary version of ABB Combustion Engineering report CEN-620-P Revision 04-P, " Series 44 3 51 Design Steam Generator Tube Repair Using a Tube Rerolling Technique", Dated October 1997. An affidavit from ABB Combustion Engineering was provided with the November 10,1997 submittal supporting the proprietary nature of the repcrt. However, the ABB Combustion Engineering affidavit erroneously referred to report CEN-620-P Revision 04-P as being dated September 1997. To correct this error, a revised ABB Combustion Engineering affidavit is attached.
In this letter we have made no new Nuclear Regulatory Commission commitments.
Please contact Gene Eckholt (612-3881121) if you have any questions related to this letter.
h Joel P Sorensen Plant Manager Prairie Island Nuclear Generating Plant
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USNRC NORTHERN STATES POWER COMPANY i
January 9,1998 i
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c: Regional Administrator - Region lil, NRC Senior Resident inspector, NRC i
NRR Project Manager, NRC J E Silberg
Attachment:
Combustion Engineering Affidavit s
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ATTACHMENT Combustion Engineering Affidavit
AFFIDAVIT PURSUANT
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TO 10 CFR 2.790 V
I, Ian C. Rickard, depose and say that I am the Director, Operations 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 i
referenced in the paragraph immediately below.
I am submitting this affidavit in j
conjunction with the application of Northern States Power Company, and in conformance with the provisions of 10 CFR 2.700 of the Commission's regulations.
The information for which proprietary treatment is sought is contained in the following document:
Report CEN-620-P, Rev. 04-P," Series 44 & 51 Design Steam Generator Tube Repair Using a Tube Rerolling Technique", October,1997.
(3 This document has been appropriately designated as proprietary.
'v' 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 documents, should be withheld.
1.
The information sought to be withheld from public disclosure, is owned and has been held in confidence by Combustion Engineering, it consists of details and supporting test data related to a tube rerolling technique for returning steam generator tubes to service.
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' 2.,
The information consists of test data or other similar data concerning a 1
process, method or component, the application of which ' results in substantial competitive advantage to Combustion Engineering.
3.
The information is of a type customarily held in confidence by Combustion 4
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 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 2.700 with the understanding that it is to be O
received in confidence by the Commission.
V 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 maintenar'ce 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 reactor competitors of Combustion Engineering, b.
Development of this information by Combustion Engineering required tens of thousands of dollars and hundreds of manhours of effort. A competitor would have to undergo o_
similar expense in generating equivalent information.
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In order to acquire such infomiation, a ompeti'or would also (V
require considerable time and inconvenience to develop and validate a similar tube rerolling repair technique.
d.
The information consists of details and supporting n data related to a tube rerolling technique for returning t.eam generator tubes to service, the application of which provides a competitive economic advantage. The availability of such information to competitors would enable them to modif/ 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 avoid developing similar data and analyses in support of their processes, methods or apparatus.
e.
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 without similar expenditure of resources may enable them to sell at prices reflecting significantly 'ower costs, f.
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 irnpact on Combustion Engineering's potential for obtaining or maintaining foreign licensees.
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Further the deponent sayeth not.
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pf lan ard Director, Operations Licensing Sworn to before me this,JJt day of _
.1997 oA Notary Public
- My~ commission expires: i 3l 93 O
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