ML20004E996

Forwards Proprietary & Nonproprietary Versions of Responses to Statistical Combination of Uncertainties. CEN-139(A)-NP & CEN-124(B)-NP-Part 2.Proprietary Versions Available in Central Files Only

ML20004E996
Person / Time
Site:	Calvert Cliffs
Issue date:	06/02/1981
From:	Lundvall A BALTIMORE GAS & ELECTRIC CO.
To:	Clark R Office of Nuclear Reactor Regulation
Shared Package
ML19276K116	List: ML20004E996 ML20004E997 ML20004E999
References
NUDOCS 8106160324
Download: ML20004E996 (10)

Text

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A BALTIMCRE GAS AND ELECTRIC CHARLES CENTER

• P.O. BOX 1475

• BALTIMORE. MARYLAND 21203 ARTHun E. LuNov4LL. Jn.

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June 2, 1981 en

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Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission -

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ATTENTION: Mr. R. A. Clark, Chief C 3 ,, *, con **}T cc #

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Operating Reactors Branch #3 ;s Division of Licensing 4 ,

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit No. I and Unit No. 2 Docket Nos. 50-317 and 50-318 Response to Questions on SCU, CEN-124(B)

REFERENCE (A): A. E. Lundvall to R. A. Clark letter dated 6/26/80 Gentlemen:

Reference (A) trmismitted Statistical Combination of Uncertainties (SCU), Part 2 Report, CEN-124(B), for your review and approva!. Enclosures (1) through (4) are our responses to first and second round questions posed by NRC staff on that report. Enclosures (5) and (6) are affidavits ! om Combustion Engineering, Inc.,

requesting that informatien in Enclosures (1) anc. (3) respectively be withheld from public disclosure in accordance with 10 CFR 2.790.

Very truly yours, BALTIMORE GAS AND ELECT RIC COMPANY

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, v_ -, ,i.. -w . * -l w A. E. Lundvall, Jr. /

Vice President - Supply WJL/AEL/djw 810616v M P

Office of Nuclear Reactor Regulation June 2,1981 Page 2

Enclosures:

(1) Responses to first round questions on SCU, Part 2, CEN-124(B)-P, May 1981. Copies 4-43 (2) Responses to first round questions on SCU, Part 2, CEN-124(B)-NP, May 1981. 20 copies (3) Responses to second round questions on SCU, Part 2, CEN-124(B).P, April 1981. Copies 21-60 (4) Responses to second round questions on SCU, Part 2, CEN-124(B)-NP, April 1981. 20 copies (5) Proprietary Affidavit for Enclosure (1).

(6) Proprietary Affidavit for Enclosure (3)

Copies To: 3. A. Biddison, Esquire (w/out Encl)

G. F. Trowbridge, Esquire (w/out Encl)

E. L. Conner, Jr., NRC P. W. Kruse, CE (w/out Enct)

~~

. Enclosure (5)

AFFIDAVIT PURSUANT T0 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 immedi-ately 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 treatuent is sought is contained

n the following document:

Response to First Round Question on the Statistical Combination of Uncertainties Program: CETOP-D Code Structure and Modeling Methods, Part 2 CEN-124 (B) - P.

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,

1. The information sought to be withheld from public disclosure are the C-E thermal margin analysis methodology and thermal hydraulic characteristics of C-E cores, 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.

3. The information is of a type customarily held in confidence by Combustion Engineering and not custanarily 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 Decenber 2,1974. This system was applied in determining that the subject documents herein are proprietary.

4. The information is being transmitted te the Commission in con- ._

fidence 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 Ccmbustion Engineering because:

a. A similar product is manufactured and sold by major pressurized water reactors competitors of Combustion Engineering.

b. Development of this information by C-E required thousands of manhours 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 infonnation.

c. In order to acquire such information, a competitor would also require considerable time and inconvenience related to the development of methods for the statistical combination of uncertainties in thermal margin analyses,

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 C-E thermal margin analysis methodology and thermal hydraulic characteristics of C-E cores, the appli-cation of which provides a competitive economic aavantage. 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,

, s'gnificant research, development, engineering, analytical, manufacturing, licensing, quality assurance and other costs and expenses must be included.

O e - - --- - -

4 The ability of Combustion Engineering's competitors to utilize such information I 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 technolegy development.

In addition, disclosure would have an adverse economic impact or. Combustion Engineering's potential for obtaining or maintaining ~ foreign licensees.

Further the deponent sayetn not.

_ ~ _,

A3,ScIrer Director Nuclear Licensing Sworn to before me this ' day of ee v; a

NotaryPubJic /

CAREY J. ENZEL, NOT.tRY PUBUQ Sta:e of Connec:!c;: no. 59962 Commission Expires March 31, 1985

. Enclosure (6)

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:

Response to Second Round Questions on Statistical Combination of __

Uncertainties, CEN-139(A) -P and CE'N-124(B) -P, Part 2.

i This document has been appropriately designated as propric'ary.

I 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.

l. The information sought to be withheld from public disclosure are the C-E thermal margin analysis methodology and the thermal hydraulic characteristics of C-E Cores, 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 advantagt 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 systeu were provided to the Nuclear Regulatory Commission via letter DP-537 frca F.M. Stern to Frank Schroeder dated December 2, 1974. This system was applied in determining that the subject documents 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 1

! made pursuant to regulatory provisions or proprietary agreements which provide for maintcnance of the information in confidence.

l l

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 rajor pressurized water reactors competitors of Combustion Engineering.

b. Development of this information by C-E required thousands of manhours of effort and tens 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 methods for the statistical combination of the uncertainties in thermal margin analysis,

d. The infonnation 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 C-E thermal margin analysis methodology and the thermal hydraulic characteristics of C-E cores, 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 . ctions 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.

, , ,---.n - - . . - - - . - - ,. -

~~ ~

4 The ability of Combustion Engineering's competitors to utilize such information without similar expenditure of resot.rces 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 abili.ty 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 Enginearing's potential for obtaining or maintaining foreign licensees.

Further the deponent sayeth not.

._ ^ ^ un

'A. E. M erer Director Nuclear Licensing Sworn to before me __

this - day of ,_

Notary Public '

CAREY 1. WEN 2EL, NOTARY PUBLIC State of Connecticut No. 59962 Commissicn Ex;;ias Match 31, L985

.