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{{#Wiki_filter:Contract 2005431.17 JL IRIm P'LIPID Calculation | {{#Wiki_filter:Contract 2005431.17 JL IRIm P'LIPID Calculation Appendix Appendix Appendix | ||
~ | ~ rt ~~~ | ||
Yes X No | ~~ | ||
a/C f~->t-PS Independent Reviewer.Name/Signa reJDate | pages pages Pages Pages Calculation Number V-PENG-CALC-007 Revision 01 Title RSB 5-1 Shutdown Coolin Anal sis for 102% Stretch Power Usin DESCENT Code Palo Verde Nuclear Generatin Units 1 2 k,3 Author Kat M. Leroux Date 2 1 R5 Calculation contains safety related design information: Yes X No VERIFICATIONSTATUS: COMPLETE The Safety-Related design information contained in this document has been verified to be correct by means of Design Review using Checklist(s) 2 of /Alai-101. | ||
No assumptions were identified requiring further validation. | a/C f~ ->t- PS Independent Reviewer. Name/Signa reJDate Approved by F. P. Ferraraccio Su ervisor Date l Distribution F. P. Ferraraccio W. J. Palo C. A. Nielse PENG File E. Ja eler Summary | ||
The conclusions reached in this analysis were determined to be technically reasonable and acceptable. | |||
9605300i75 96052i PDR ADOCK 05000528 p PDR ABB Combustion Engineering Nuclear Operations | ==Purpose:== | ||
-Palo Verde Nuclear Generating Station, Unit No.3, Docket No.STN-50-530, Appendix"A" to License No.NPF-74.3.13 APS Palo Verde Nuclear Generating Station, | The purpose of this calculation is to analyze the shutdown cooling system operation following a natural circulation cooldown. | ||
Method and Results ofReview: | |||
rp t i r i I Calculation No.V-PENG-CALC-007 Rev.01 Page 6 of 17 METHOD OF ANALYSIS Shutdown Cooling System performance was modeled parametrically in a series | The method used to verify this calculation was an independent review. The DESCENT gg), ot computer code input data for each case were reviewed and confirmed to be accurate and appro'priate for use in this analysis. Input data were also compared to code output listings to-confirm acceptable results. All assumptions were also reviewed and confirmed to be appropriate. No assumptions were identified requiring further validation. The conclusions reached in this analysis were determined to be technically reasonable and acceptable. | ||
('F)m SDC Flow (gpm)125 132 143.4 3400 | 9605300i75 96052i PDR ADOCK 05000528 p PDR ABB Combustion Engineering Nuclear Operations | ||
The'value of 0 indicates the option for Card 6 variables is not desired.Further explanation of the Card 6 variable is provided on page 10 of Reference[g<<oi 3.6.x ABB Combustion Engineering Nuclear Operations ENCLOSURE 2 | |||
~~i D V SU 010 C 2 90 I, I.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 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 ofArizona Public Services for withholding this information. | Calculation No. V-PENG-CALC-007 Rev. 01 Page 2 of 17 Record ofRevision Extent of Revision Date Author Reviewer A royal Revision 01 12/01/95 K. M. Leroux R Orsulak F. Ferraraccio pp.l, 2, 5, 6, 11 00 10/27/95 K. M. Leroux W. Palo F. Ferraraccio Ori 'lIssue Replace pages 1, 2, 5, 6, and 11 ofRevision 00 with pages 1, 2, 5,6 and 11 of Revision 01. | ||
The information for which proprietary treatment is sought is contained in the following document: CEN-385-P,"RSB 5-1 Natural Circulation Cooldown Analysis At Uprated Power Conditions (3876 Mwt Core Power)For Palo Verde Nuclear Generating Station Units 1, 2 and 3", November 1995 This document has been appropriately designated as proprietary. | III ABB Combustion Engineering Nuclear Operations | ||
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. | J t | ||
0 1.The information sought to be withheld from public disclosure, is owned and has been held in confidence by Combustion Engineering. | t | ||
It consists of information regarding the application of the LTC computer code and methodology for analysis of plant natural circulation cooldown.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. | Calculation No. V-PENG-CALC-007 Rev. Ol Page 5 of 17 3.4 ABB/CE Sofbvare Verification and Validation Report Number CODES-FS-C-.008, Rev. 02, "Verification ofDESCENT VlMO on the Hewlett-Packard (HP)9000/700 Series Workstations", dated 11/22/93. (See Appendix A) 3.5 00000-PE-CV31/2-00, Computer Code Description and Verification Report for DESCENT, 2/24/78, Version 2, Rev. 00. | ||
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. | 3.6 ABB/CE Calculation K-FS-C-051, Rev. 00, "Verification of Computer Code DESCENT, Version 3," dated 8/18/88. | ||
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. | 3.7 APS Memo, Hamid Mortazavi to BillPalo, "PVNGS Shutdown Cooling Analysis," | ||
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. | dated 11/12/92 (see Appendix A). | ||
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. | 3.8 Bechtel Calculation 13-NC-SP-005, Rev. 0, "Reactor Core and Spent Fuel Pool Decay Heat Loads," dated 5/8/86. | ||
II I | J 3.9 ABB/CE Calculation V-PEC-067, Rev. 00, "DESCENT (Shutdown Cooling) Code Input Parameters for System 80 Plants," dated 5/6/77. | ||
In order to acquire such information, a competitor would also require considerable time and inconvenience for development of a computer code application and methodology for analysis of plant natural circulation cooldown.The information consists of the application of the LTC computer code and methodology for analysis of plant natural circulation cooldown;the application of which provides a competitive economic advantage. | 3.10 ABB/CE Calculation SP-PEC-139, Rev. 00, "CESSAR-FSAR Shutdown Cooling System Performance (One 8'c Two Train Cooldown)," dated 3/3/78. | ||
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. | 3.11 a. NUREG-75-087, Rev. 1, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, LWR Edition, Section 5.4.7, "Residual Heat Removal ~) System". | ||
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 signiTicantly lower costs.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. | : b. Branch Technical Position RSB 5-1, -"Design Requirements of the Residual Heat Removal System," attached to SRP Section 5.4.7. | ||
In addition, disclosure would t 1I have an adverse economic impact on Combustion Engineering's potential for obtaining or maintaining foreign licensees. | 3.12 NUREG-1287, Technical Specifications - Palo Verde Nuclear Generating Station, Unit No. 3, Docket No. STN-50-530, Appendix "A" to License No. NPF-74. | ||
Further the deponent sayeth not.I.'rd, Director Operations Licensing Sworn to before me this~day o dnuuM cZ, 1996 ,Notary Public',Viy commission expires: F~l lQ~>'Eq}} | 3.13 APS Palo Verde Nuclear Generating Station, AuxiliaryFeedwater System Design Basis Manual, Rev. 0, dated 4/12/91. | ||
3.14 ABB/CE Calculation V-MECH-CALC-007, Rev. 00, "EfFects of NCW/EW Temperature on SCS Performance, Palo Verde Nuclear Generating Station, Units 1; 2, Ec 3," dated 4/20/93. | |||
ABB Combustion Engineering Nuclear Operations = | |||
rp t | |||
i r | |||
i I | |||
Calculation No. V-PENG-CALC-007 Rev. 01 Page 6 of 17 METHOD OF ANALYSIS Shutdown Cooling System performance was modeled parametrically in a series ofDESCENT cases for the cooldown parameters presented in Table 4.1. The QA veriQed code DESCENT (Reference 3.4) was used, with inputs as given in Section 5 below. The Essential Water (EW) temperature and Reactor Coolant Qow through the shutdown c'ooling system (hereaQer referred to as shutdown cooling flow) are varied parametrically to produce a matrix of cases. | |||
EW temperature ranges Rom 125'F to 143.4'F, and shutdown cooling Qow ranged &om 3400 gpm to 5000 gpm. Input parameters were selected to be consistent with the references in Section 3.0. | |||
Table 1: SU1IdNARY OF COOLOOWN SCENARIOS 13.3 hrs Decay Heat, 12,600 gpm EW How, 1 LPSI Pump in Service EW Temperature | |||
('F)m SDC Flow (gpm) 125 132 143.4 3400 Case 1 Case 5 (Case not run) 4000 Case 2 Case 6 Case 9 4500 Case 3 Case 7 Case 10 5000 Case 4 - Case8 Case 11 ABB Combustion Engineering Nuclear Operations | |||
I( | |||
l f | |||
g | |||
Calculation No. V-PENG-CALC-007 Rev. 01 Page 11 of 17 5.29 RATEMIN RATEMN= 0. | |||
The value of 0. indicates RATEMINis not in eQect. | |||
5.30 CARD6 CARD6 = 0 Since this analysis uses DESCENT (Reference 3.4) it is necessary to provide an input ~',0 1 for CARD6 which willidentify ifa sixth input card is desired to define specific heat exchanger variables. The'value of 0 indicates the option for Card 6 variables is not desired. Further explanation of the Card 6 variable is provided on page 10 of Reference [ | |||
g<<oi 3.6. | |||
x ABB Combustion Engineering Nuclear Operations | |||
ENCLOSURE 2 | |||
~ | |||
~ | |||
i | |||
D V SU 010 C 2 90 I, I.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 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 ofArizona Public Services for withholding this information. | |||
The information for which proprietary treatment is sought is contained in the following document: | |||
CEN-385-P, "RSB 5-1 Natural Circulation Cooldown Analysis At Uprated Power Conditions (3876 Mwt Core Power) For Palo Verde Nuclear Generating Station Units 1, 2 and 3", November 1995 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. | |||
0 | |||
: 1. The information sought to be withheld from public disclosure, is owned and has been held in confidence by Combustion Engineering. It consists of information regarding the application of the LTC computer code and methodology for analysis of plant natural circulation cooldown. | |||
: 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 is 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. | |||
II I | |||
Development of this information by Combustion Engineering required tens of thousands of dollars and hundred of manhours of effort. A competitor would have to undergo similar expense in generating equivalent information. | |||
In order to acquire such information, a competitor would also require considerable time and inconvenience for development of a computer code application and methodology for analysis of plant natural circulation cooldown. | |||
The information consists of the application of the LTC computer code and methodology for analysis of plant natural circulation cooldown; 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. | |||
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 signiTicantly lower costs. | |||
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 | |||
t 1I | |||
have an adverse economic impact on Combustion Engineering's potential for obtaining or maintaining foreign licensees. | |||
Further the deponent sayeth not. | |||
I. 'rd, Director Operations Licensing Sworn to before me this ~ day o dnuuM cZ, 1996 | |||
,Notary Public | |||
',Viy commission expires: F ~l | |||
lQ ~> | |||
'Eq}} |
Latest revision as of 20:45, 2 December 2019
ML17312A784 | |
Person / Time | |
---|---|
Site: | Palo Verde ![]() |
Issue date: | 12/01/1995 |
From: | Leroux K ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY |
To: | |
Shared Package | |
ML17312A782 | List: |
References | |
V-PENG-CALC-007, V-PENG-CALC-007-R01, V-PENG-CALC-7, V-PENG-CALC-7-R1, NUDOCS 9605300175 | |
Download: ML17312A784 (18) | |
Text
Contract 2005431.17 JL IRIm P'LIPID Calculation Appendix Appendix Appendix
~ rt ~~~
~~
pages pages Pages Pages Calculation Number V-PENG-CALC-007 Revision 01 Title RSB 5-1 Shutdown Coolin Anal sis for 102% Stretch Power Usin DESCENT Code Palo Verde Nuclear Generatin Units 1 2 k,3 Author Kat M. Leroux Date 2 1 R5 Calculation contains safety related design information: Yes X No VERIFICATIONSTATUS: COMPLETE The Safety-Related design information contained in this document has been verified to be correct by means of Design Review using Checklist(s) 2 of /Alai-101.
a/C f~ ->t- PS Independent Reviewer. Name/Signa reJDate Approved by F. P. Ferraraccio Su ervisor Date l Distribution F. P. Ferraraccio W. J. Palo C. A. Nielse PENG File E. Ja eler Summary
Purpose:
The purpose of this calculation is to analyze the shutdown cooling system operation following a natural circulation cooldown.
Method and Results ofReview:
The method used to verify this calculation was an independent review. The DESCENT gg), ot computer code input data for each case were reviewed and confirmed to be accurate and appro'priate for use in this analysis. Input data were also compared to code output listings to-confirm acceptable results. All assumptions were also reviewed and confirmed to be appropriate. No assumptions were identified requiring further validation. The conclusions reached in this analysis were determined to be technically reasonable and acceptable.
9605300i75 96052i PDR ADOCK 05000528 p PDR ABB Combustion Engineering Nuclear Operations
Calculation No. V-PENG-CALC-007 Rev. 01 Page 2 of 17 Record ofRevision Extent of Revision Date Author Reviewer A royal Revision 01 12/01/95 K. M. Leroux R Orsulak F. Ferraraccio pp.l, 2, 5, 6, 11 00 10/27/95 K. M. Leroux W. Palo F. Ferraraccio Ori 'lIssue Replace pages 1, 2, 5, 6, and 11 ofRevision 00 with pages 1, 2, 5,6 and 11 of Revision 01.
III ABB Combustion Engineering Nuclear Operations
J t
t
Calculation No. V-PENG-CALC-007 Rev. Ol Page 5 of 17 3.4 ABB/CE Sofbvare Verification and Validation Report Number CODES-FS-C-.008, Rev. 02, "Verification ofDESCENT VlMO on the Hewlett-Packard (HP)9000/700 Series Workstations", dated 11/22/93. (See Appendix A) 3.5 00000-PE-CV31/2-00, Computer Code Description and Verification Report for DESCENT, 2/24/78, Version 2, Rev. 00.
3.6 ABB/CE Calculation K-FS-C-051, Rev. 00, "Verification of Computer Code DESCENT, Version 3," dated 8/18/88.
3.7 APS Memo, Hamid Mortazavi to BillPalo, "PVNGS Shutdown Cooling Analysis,"
dated 11/12/92 (see Appendix A).
3.8 Bechtel Calculation 13-NC-SP-005, Rev. 0, "Reactor Core and Spent Fuel Pool Decay Heat Loads," dated 5/8/86.
J 3.9 ABB/CE Calculation V-PEC-067, Rev. 00, "DESCENT (Shutdown Cooling) Code Input Parameters for System 80 Plants," dated 5/6/77.
3.10 ABB/CE Calculation SP-PEC-139, Rev. 00, "CESSAR-FSAR Shutdown Cooling System Performance (One 8'c Two Train Cooldown)," dated 3/3/78.
3.11 a. NUREG-75-087, Rev. 1, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, LWR Edition, Section 5.4.7, "Residual Heat Removal ~) System".
- b. Branch Technical Position RSB 5-1, -"Design Requirements of the Residual Heat Removal System," attached to SRP Section 5.4.7.
3.12 NUREG-1287, Technical Specifications - Palo Verde Nuclear Generating Station, Unit No. 3, Docket No. STN-50-530, Appendix "A" to License No. NPF-74.
3.13 APS Palo Verde Nuclear Generating Station, AuxiliaryFeedwater System Design Basis Manual, Rev. 0, dated 4/12/91.
3.14 ABB/CE Calculation V-MECH-CALC-007, Rev. 00, "EfFects of NCW/EW Temperature on SCS Performance, Palo Verde Nuclear Generating Station, Units 1; 2, Ec 3," dated 4/20/93.
ABB Combustion Engineering Nuclear Operations =
rp t
i r
i I
Calculation No. V-PENG-CALC-007 Rev. 01 Page 6 of 17 METHOD OF ANALYSIS Shutdown Cooling System performance was modeled parametrically in a series ofDESCENT cases for the cooldown parameters presented in Table 4.1. The QA veriQed code DESCENT (Reference 3.4) was used, with inputs as given in Section 5 below. The Essential Water (EW) temperature and Reactor Coolant Qow through the shutdown c'ooling system (hereaQer referred to as shutdown cooling flow) are varied parametrically to produce a matrix of cases.
EW temperature ranges Rom 125'F to 143.4'F, and shutdown cooling Qow ranged &om 3400 gpm to 5000 gpm. Input parameters were selected to be consistent with the references in Section 3.0.
Table 1: SU1IdNARY OF COOLOOWN SCENARIOS 13.3 hrs Decay Heat, 12,600 gpm EW How, 1 LPSI Pump in Service EW Temperature
('F)m SDC Flow (gpm) 125 132 143.4 3400 Case 1 Case 5 (Case not run) 4000 Case 2 Case 6 Case 9 4500 Case 3 Case 7 Case 10 5000 Case 4 - Case8 Case 11 ABB Combustion Engineering Nuclear Operations
I(
l f
g
Calculation No. V-PENG-CALC-007 Rev. 01 Page 11 of 17 5.29 RATEMIN RATEMN= 0.
The value of 0. indicates RATEMINis not in eQect.
5.30 CARD6 CARD6 = 0 Since this analysis uses DESCENT (Reference 3.4) it is necessary to provide an input ~',0 1 for CARD6 which willidentify ifa sixth input card is desired to define specific heat exchanger variables. The'value of 0 indicates the option for Card 6 variables is not desired. Further explanation of the Card 6 variable is provided on page 10 of Reference [
g<<oi 3.6.
x ABB Combustion Engineering Nuclear Operations
ENCLOSURE 2
~
~
i
D V SU 010 C 2 90 I, I.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 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 ofArizona Public Services for withholding this information.
The information for which proprietary treatment is sought is contained in the following document:
CEN-385-P, "RSB 5-1 Natural Circulation Cooldown Analysis At Uprated Power Conditions (3876 Mwt Core Power) For Palo Verde Nuclear Generating Station Units 1, 2 and 3", November 1995 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.
0
- 1. The information sought to be withheld from public disclosure, is owned and has been held in confidence by Combustion Engineering. It consists of information regarding the application of the LTC computer code and methodology for analysis of plant natural circulation cooldown.
- 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 is 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.
II I
Development of this information by Combustion Engineering required tens of thousands of dollars and hundred of manhours of effort. A competitor would have to undergo similar expense in generating equivalent information.
In order to acquire such information, a competitor would also require considerable time and inconvenience for development of a computer code application and methodology for analysis of plant natural circulation cooldown.
The information consists of the application of the LTC computer code and methodology for analysis of plant natural circulation cooldown; 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.
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 signiTicantly lower costs.
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
t 1I
have an adverse economic impact on Combustion Engineering's potential for obtaining or maintaining foreign licensees.
Further the deponent sayeth not.
I. 'rd, Director Operations Licensing Sworn to before me this ~ day o dnuuM cZ, 1996
,Notary Public
',Viy commission expires: F ~l
lQ ~>
'Eq