ML20111C113: Difference between revisions

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#REDIRECT [[LD-85-009, Forwards Proprietary & Nonproprietary Comprehensive Vibration Assessment Program for Palo Verde Nuclear Generating Station Unit 1 (Sys 80 Prototype),Evaluation of Predictions.... Proprietary Rept Withheld (Ref 10CFR2.790)]]
| number = ML20111C113
| issue date = 03/07/1985
| title = Forwards Proprietary & Nonproprietary Comprehensive Vibration Assessment Program for Palo Verde Nuclear Generating Station Unit 1 (Sys 80 Prototype),Evaluation of Predictions.... Proprietary Rept Withheld (Ref 10CFR2.790)
| author name = Scherer A
| author affiliation = ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
| addressee name = Thompson H
| addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| docket = 05000000, 05000470, 05000528
| license number =
| contact person =
| case reference number = RTR-NUREG-0852, RTR-NUREG-852
| document report number = LD-85-009, LD-85-9, NUDOCS 8503140213
| package number = ML19269B180
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, VENDOR/MANUFACTURER TO NRC
| page count = 5
}}
 
=Text=
{{#Wiki_filter:C-E Power Systems                                  T:1.203/688-1911 Combustion Engineenng. Inc.                        Telex: 99297 1000 Prospect Hill Road Windsor, Connecticut 06095 H POWERSYSTEMS Docket No. STN 50-470F                                                      March 7, 1985 LD-85-009 Mr. Hugh L. Thompson, Director Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.          20555
 
==Subject:==
Conprehensive Vibration Assessment Program
 
==Reference:==
NUREG-0852, Safety Evaluation Report, dated November 1981
 
==Enclosure:==
Proprietary Affid<ivit for CEN-263(V)-P, Revision 1
 
==Dear Mr. Thompson:==
 
Combustion Engineering hereby submits the final Comprehensive Vibration Assessment Program (CVAP) report from the prototype System 80' plant as required by Section 3.9.2 of the Reference. As required in Section 3.9.2 of Supplement 2 to the Reference, the results of the CVAP are evaluated against the Winter 1982 addendum to the ASME Code.
Twenty-five (25) copies (nambered 0001-0025) of the proprietary version and fifteen (15) copies of the non-proprietary version are provided. Enclosed you will also find the appropriate supporting prop-tetary af fidavit. C-E believes that submittal of this final report fulfills the commitments in CESSAR with respect to Regulatory Guide 1.20 tf we can be of of any additional assistance in this matter, please feel f ree to call me or Mr. T. J. Collier of my staf f at (203) 285-5215.
Very truly yours, COMBUSTION ENGINEERING, INC.
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l                                            AFFIDAVIT PURSUANT TO 10 CFR 2.790 l
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 siebmitting this affidavit in conformance with the provisions of 10 CFR 2.790 of the Commission's regulations for withholding this information.
The information for which proprietary treatment is sought is contained in the following document:
CEN-263(V)-PRevision1-P,AComprehensiveVibrationAssessmentProgramfor Palo Verde Nuclear Generating Station Unit 1 (System 80 Prototype) Evaluation of Predictions and Pre-Core Hot Functional Measurement and Inspection Programs, Final Report, January 1985.
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 l          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 are data and the final evaluation of that data obtained from the Palo Verde Nuclear Generating Station Unit 1 Comprehensive Vibration Assessment Program testing including comparison with analytical predictions and the results of visual examinations, 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.
l
: 3. The information is of a type customarily held in confidence by i
Combustion Engineering and not custonarily disclosed to the public. Combustion Engineering has a rational basis for determining the types of information custocarily 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 testing and evaluation 4
of the Palo Verde Nuclear Generating Station Unit I reactor vessel internals I    design.
: d. The information required significant effort and expense to obtain the licensing approvals necessary for application of the information.
1    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 data and the final evaluation of that data obtained from the Palo Verde Nuclear Generating Station Unit 1 Comprehensive Vibration Assessment program testing including comparison with analytical predictions and the results of visual examinations, 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 j      compete with Canbustion 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 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 dddition, disclosure would have an adverse economic impact on Combustion Engineering's potential for obtaining or maintaining foreign licensees.
Further the deponent sayeth not.
_ _ _    ,      JA t:-J A.E.Sc(rer Director Nuclear Licensing Sworn to before me this /d5 day of MGM g %T MA k              MM kbf.NbEN                    9%
JUSTICE OF THE PEACE 33G TAYLOR ROAD          !
ENFIELD, CT 06082        (
TERM EXPlRES:._6(@h. i .-            -
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