ML20205F629
| ML20205F629 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 03/17/1987 |
| From: | Tiernan J BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19292H018 | List: |
| References | |
| NUDOCS 8703310227 | |
| Download: ML20205F629 (6) | |
Text
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B ALTIMORE GAS AND ELECTRIC CHARLES CENTER R O. BOX 1475 BALTIMORE, MARYLAND 21203 JOSEPH A.TIERNAN Vict Pats.9tni NUCLEAR ENERGY March 17,1987 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Request for Approval of CEN-348(B)-P, Extended Statistical Combination of Uncertainties Report, January,1987
REFERENCES:
(a) " Statistical Combination of Uncertainties Part 1", CEN-124(B)-F, December,1979 (b) " Statistical Combination of Uncertainties Part 2", CEN-124(B)-P, January,1980.
(c) " Statistical Combination of Uncertainties Part 3", CEN-124(B)-P, March,1980.
(d) " Extended Statistical Combination of Uncertainties", CEN-348(B)-P, January,1987.
Gentlemen:
This request introduces CEN-348(B)-P, the Extended Statistical Combination of Uncertainties (ESCU) method.
This method is an enhanced version of the existing Statistical Combination of Uncertainties previously introduced by References (a),(b), and (c).
The report describes an improved methodology for statistically combining the uncertainties involved in the Departure from Nucleate Boiling (DNB) and its associated l
analog system setpoints.
l The ESCU method consists of incorporating the DNB ratio probability density function which includes system parameter uncertainties and critical heat flux correlation uncertainties into the stochastic simulation models of DNB Limiting Safety System Settings (LSSS) and DNB Limiting Conditions for Operations (LCO).
REQUEST FOR EXTENDED STATISTICAL COMBINATION OF UNCERTAINTIES APPROVAL Baltimore Gas & Electric Company hereby requests NRC review / approval of report CEN-348(B)-P (Reference (d)) for use as an improved method for atistically combining 9703hi7 fo(I
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f ocument Con. trol Desk March 17,1987 Page 2 uncertainties for the Combustion Engineering calculated Thermal Margin / Low Pressure LSSS and DNB LCOs for Calvert Cliffs I and II. Current intentions are to adopt ESCU methods for support of the Unit 1 Cycle 10 reload analysis. Unit 1 Cycle 10 is scheduled to begin critical operation in May,1988.
Copies numbered 000001 through 000003 of CEN-348(B)-P are herewith enclosed to facilitate NRC review. CEN-348(B)-P is a proprietary documen': and should be treated accordingly. The relevant proprietary affidavit for the subject material is enclosed as well.
FEE DETERMINATION Pursuant to 10 CFR 170.21, we are including BG&E Check No. 1909576 in the amount of
$150.00 to the NRC to cover tha application fee for this request.
Very truly yours, STATE OF MARYLAND:
TO WIT:
COUNTY OF CALVERT
- _ _.._ TNE :
m..
Joseph A. Tiernan, being duly sworn states that he is Vice President of the Baltimore Gas and Electric Company, a corporation of the State of Maryland; that he provides the foregoing response for the purposes therein set forth; that the statements made are true and correct to the best of his knowledge, information, and belief; and that he was authorized to provide the response on behalf of said Corporation.
WITNESS my Hand and Notarial Scal:
37hX4JC N7C UI, Notary Public ILM /,
liN My Commission Expires:
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cDate JAT/DSE/Imt Attachments cc: D. A. Brune, Esquire
- 3. E. Silberg, Esquire A. C. Thadani, NRC S. A. McNeil, NRC T. E. Murley, NRC T. Foley/D. A. Trimble, NRC
AFFIDAVIT PURSUANT TO 10 CFR 2.790 Combustion Engineering, Inc.
)
State of Connecticut
)
County of Hartford
)
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 Company for withholding this information.
The information for which proprietary treatment is sought is contained in the following document:
Extended Statistical Combination of Uncertainties CEN348(B)-P This document has been appropriately designated as proprietary.
I have personal knowledge of the criteria and procedures utilized by Combusticn Engineering in designating information as a trade secret, privileged or as confidential commercial of 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.
1.
The information sought to be withheld from public disclosure concerns the methodology, specific results and estimates of benefits of applying C-E's extended statistical combination of uncertainties method 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 substantial 1
competitive advantage to Combustion Engineering.
i 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 determining 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:
. 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 thousands of man-hours of effort and hundreds 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 a similar methodology for the extended statistical combination of uncertainties.
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 the methodology, specific results, and estimates of the benefits of applying this methodology 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 avoid 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
e
- information 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.
22d A"E. W r6r Director Nuclear Licensing Sworn to before me this /0 th day of November, / 7 P6, hv
< < m,q m, - <
Notary Public
$USMINE SMITH, NOTARY PUBUC Sigts of Connt:tcut No. 74143 Commiss!cn Expires March 31.1990 l
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