ML20002A091

Forwards Proprietary & Nonproprietary Versions of High Burnup Demonstration Program Presented to NRC on 781220. Proprietary Version Withheld (Ref 10CFR2.790).W/encl Affidavit

ML20002A091
Person / Time
Site:	Calvert Cliffs
Issue date:	02/07/1979
From:	Lundvall A BALTIMORE GAS & ELECTRIC CO.
To:	Reid R Office of Nuclear Reactor Regulation
Shared Package
ML19289A080	List: ML20002A091 ML20002A096
References
NUDOCS 7902210086
Download: ML20002A091 (7)

Text

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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 Manager, Licensing of Combustion Engineerir.g, 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 presentation to the NRC on December 20, 1978 by Baltimore Gas & Electric Company, for withholding this information.

The information for which pr]prietary treatment is sought is contained in the following document:

Slides Depicting Scout-1 High Burnup Demonstration Program 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 is specific details of a fuel demonstration program 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 confidenc- 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 Conmission via letter DP-537 from F.M. Stern to Frank Sct.roeder 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 Conmission.

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 i

o water reactors competitors of Combustion Engineering.

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b. Development of this information by C-E required hundreds of l man-hours and tens of thousands of dollars. To the best of my krsowledge and belief a competitor would have to undergo similar expense in generating l equivalent information.

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. In order to acquire such information, a competitor would also require considerable time and inconvenience related to modeling, planning, scheduling and to obtaining access to test reactor facilities and conducting extensive in-pile testing.

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 in 'onsists of specific details and plans of a fuel demonstration program, 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, I

significant research, development, engineering, analytical, manufacturing, .

I licensing, quality assurance and other costs and expenses must be included.

l The ability of Combustion Engineering's competitors to utilize such information l l

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_4 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.

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A. E cherer Manager, Licensing Sworn to before me this eighteenth day of January 1979

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o C E Power Systems tel 203/rm-1911 I Cu 'a,' -nLr y e org.r.c Teter DC J7  ;

1000 Pro: ac' mn Roa J W,o j cr. Cer.ra ' cut CGOB POWER SYSTEMS January 22, 1979 BG&E-9676-191 Baltimore Gas and Electric Company Lusby Post Office Lusby, Maryland 20657 Attention: W. J. Lippold

Subject:

fiuclear Steam Supply Systems Calvert Cliffs Installation BG&E Order flumber 02264F CE Contract flumber 9676 f;RC SCOUT f1EETIfiG SLIDES

Enclosure:

(1) Slides Depicting SCOUT-1 h:<jh Burnup Demonstration Program (Proprietary Version)

(41 copies)

(2) Slides Depicting SCOUT-1 High Burnup Demonstratier, Program (flon-Proprietary Version) (20 Copies)

(3) Proprietary Affidavit

Dear f1r. Lippold:

Enclosures (1) and (2) forward proprietary and non-proprietary versions of the subject slides. This classification is being requested based on the proprietary nature of information relating to the development of techniques used to achieve high burnup necessary for the 18 month fuel cycle. It is requested that Enclosure (3) be submitted with the slides to the flRC. Your cooperation is sincerely appreciated.

Sincerely,

/ { w_.

P. W.'Kruse flanager, Engineering Services PWK:mtm cc: R. C. L. Di.an (Enclosure 1, 2, 3).