ML20023B933

Forwards Proprietary & Nonproprietary Response to NRC Questions on CESSAR-F Statistical Combination of Uncertainties in Thermal Margin Analysis for Sys 80, (SER Item 7).Proprietary Response Withheld (Ref 10CFR2.790)

ML20023B933
Person / Time
Site:	05000470
Issue date:	05/03/1983
From:	Scherer A ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
To:	Eisenhut D Office of Nuclear Reactor Regulation
Shared Package
ML19301C195	List: ML20023B933 ML20023B950
References
LD-83-037, LD-83-37, NUDOCS 8305090338
Download: ML20023B933 (6)

Text

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C-E P;w:r Syltims Tel 203/688-1911 Combustion Engineenng. Inc. Telex 99297 1000 Prospect Hill Road Windsor, Connecticut 06095 POWER M SYSTEMS Docket No.: STN 50-470F May 3,1983 LD-83-037 Mr. Darrell G. Eisenhut, Director Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

CESSAR-SER Confirmatory Item 7, Question Response

References:

(A) Letter, C. O. Thomas to A. E. Scherer, dated March 7, 1983 (B) Letter LD-83-010, A. E. Scherer to D. G. Eisenhut, dated February 28, 1983

Dear Mr. Eisenhut:

Reference (A) transmitted to Combustion Eagineering (C-E) a set of questions requesting additional information on the CESSAR-F docket. The questions address our submittal (Reference B) describing C-E's application of Statistical Combination of Uncertainty methodology to determine system parameter uncertainties in the thermal margin analysis of System 80'. Enclosed are twenty-five (25) proprietary and fifteen (15) non-proprietary copies of C-E's response to these questions.

Due to the proprietary nature of the material contained in the enclosure, we request that it be withheld from public disclosure in accordance with the

! provision of 10 CFR 2.790 and that this material be safeguarded. The reasons go3 for the proprietary classification of this report is delineated in the enclosed 3 affidavit.

l If I can be of any further assistance in this matter, please contact me or Mr. ,/is u.a-Pa.p G. A. Davis of my staff at (203) 688-1911, extension 2803.

ClaxyC. SQ Very truly yours, ?D;t / NP COMBUSTION ENGINEERING, INC. l ff & MS n 15 , up D.E.Scherer Director Nuclear Licensing AES:las F72087

Enclosures:

Page 2 8305090338 830503 PDR ADOCK 05000470 E PDR k

Mr. Darrell G. Eisenhut LD-83-037 May 3, 1983 Page 2

Enclosures:

1-P to LD-83-037, " Response to NRC Questions on CESSAR-F Statistical Combination of Uncertainty in Thermal Margin Analysis for System 80".", Proprietary Version (Copies 0001-0025) 1-NP to LD-83-037, " Response to NRC Questions on CESSAR-F Statistical Combination of Uncertainty in Thermal Margin Analysis for System 80"", Non-Proprietary Version,15 copies Affidavit attesting to the proprietary nature of this report

4 AFFIDAVIT PURSUANT TO 10 CFR 2.790 Combustion Engineering, Inc. )

State of Connecticut )

County of Hartford ) SS.:

I, P. L. McGill, depose and say that I am the Vice President, Commercial, 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 for withholding this information.

The information for which proprietary treatment is sought is con'tained in the following document:

Enclosure IP to LD-83-037, " Response to NRC Questions on CESSAR-F Statistical Combination or Uncertainty in Thermal Margin Analysis for System 80".

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.

f

1. The information sought to be withheld from public disclosure is the application of statistical methods in combining measurement uncertainties associated with Limiting Safety System Settings and Limiting Conditions for Operation of Combustion Engineering's Nuclear Steam Supply Systems, which is owned and has been held in confidence by Combustion Engineering.

2. The information consists of test data cr 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 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:

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 manhours 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 applying the method of statistical combination to the overall analysis for operation of a nuclear steam supply system.

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 unique use of stattstical methods in the overall uncertainty analysis for operation of nuclear reactors, 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, licensing, quality assurance and other costs and expenses must be included.

l The ability of Combustion Engineering's competitors to utilize such information without.similar expenditure of resources may enable them to sell at prices i

reflecting significantly lower costs.

l

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.

f/b{

P. L. McGill Vice President Commercial Sworn to before me this d day of $

i.niDEF 6 D a0 Notary Public U 4

I