ML20235T622
| ML20235T622 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 10/02/1987 |
| From: | Lippold W BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML19304B558 | List: |
| References | |
| NUDOCS 8710130151 | |
| Download: ML20235T622 (7) | |
Text
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BAl. TIM O RE GAS AND ELECTRIC CHARLES CENTER P.O. BOX 1475 BALTIMORE, MARYLAND 21203 W. JAME3 LtPPOLD MANAGER NUCLEAR rNQlNEERING $ERvlCES DE PARTMENT October 2,1987 U. S. Nuclear Regulatory Comniission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Control Element Assembly (CEA) Center Finger Crackine at Calvert Cliffs Gentlemen:
As has been previously discussed, cracking of CEA center fingers was observed during CEA exams performed at Calvert Cliffs Unit I (End of.' Cycle 8) and Unit 2 (End of Cycle 7). The attached report describes the CEA examination program including results i
l of data evaluations and assessments of the cause and safety significance of the observed cracks. The report concludes that the observed cracking did not result in either a significant safety or operating concern.
This report is to be treated as proprietary as described in 10 CFR 2.790. A proprietary affidavit to that effect is also attached.
Should you have further questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours,
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WJL/PAF/Imt 1
Attachments J
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Document Control Desk October 2,1987 Page 2 cc:
D. A. Brune, Esquire (w/o attch) i J. E. Silberg, Esquire (w/o attch) l R. A. Capra, NRC (w/o attch)
S. A. McNeil, NRC (w/ attch)
W. T. Russell, NRC (w/ attch)
T. Foley/D. C. Trimble, NRC (w/ attch)
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e 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, P. L. McGill, depose and say that I am.the Vice-Fresident, Nuclear Fuel, 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 for withholding this information.
The information for which proprietary treatment is sought is contained in the following document:
Control Element Assembly (CEA) Center Finger Cracking at Calvert Cliffs, CEN-364(B)-P, September, 1987.
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 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 dete'rmining 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 observations of cracking in CEA cladding at Calvert Cliffs and its relationship to cladding material-properties, CEA design, CEA performance 'at other C-E plants and the results of corrosion tests that relate irradiated cladding properties to susceptibility to intergranular attack, 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 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 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:
'-S-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-l knowledge and belie'( 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 developing-similar correlations between CEA cladding material properties, CEA design and CEA performance..
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 correlations between CEA cladding material properties, CEA design and CEA performance, the application of which provides a competitive economic advantage. The availability of such 1
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 c - - ___-_ _ _
_ = _ _ _ _ _ - _.
. l 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.
P. L. McGill Vice-President
' Nuclear Fuel Sworn to before me this chl day of g 4 j /W7 W7 m
Notary Public ()
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