LD-86-024, Forwards Proprietary & Nonproprietary Rev 0 to CEN-330,Rev 01 to CEN-304 & Rev 01 to CEN-305 Re Improvement Program. Proprietary Repts Withheld (Ref 10CFR2.790).Affidavit for Withholding Repts Encl.Fee Paid

Forwards Proprietary & Nonproprietary Rev 0 to CEN-330,Rev 01 to CEN-304 & Rev 01 to CEN-305 Re Improvement Program. Proprietary Repts Withheld (Ref 10CFR2.790).Affidavit for Withholding Repts Encl.Fee Paid

ML20155J480
Person / Time
Site:	Palo Verde, Arkansas Nuclear, Waterford, San Onofre, 05000000
Issue date:	05/21/1986
From:	Scherer A ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
To:	Knighton G Office of Nuclear Reactor Regulation
Shared Package
ML19298E013	List: LD-86-024, Forwards Proprietary & Nonproprietary Rev 0 to CEN-330,Rev 01 to CEN-304 & Rev 01 to CEN-305 Re Improvement Program. Proprietary Repts Withheld (Ref 10CFR2.790).Affidavit for Withholding Repts Encl.Fee Paid ML20155J491 ML20155J505 ML20155J523
References
LD-86-024, LD-86-24, NUDOCS 8605230274
Download: ML20155J480 (10)

Text

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May 21, 1986 COMBUSTION ENGINEENING LD-86-024

[0- $l3l0(,'$'

George W. Knighton, Director PWR Project Directorate #7 80 ~

Division of PWR Licensing-B 80 " U 82 9 80 U.S. Nuclear Regulatory Commission Washington, D. C. 20555

Subject:

Submission of Reload Data Block Constants Program Documents, (Part C of the CPC Improvement Program)

References:

(A) CEN-308-P-A, "CPC/CEAC Sof f. ware Modifications for the CPC Improvement Program," April 1986.

(B) CEN-310-P-A, "CPC and Methodology Changes for the CPC Improvement Program," April 1986.

(C ) CEN-39(A)-P, Rev 03-P, "CPC Protection Algorithm Change Procedure," February 1986.

(D) CEN-323-P, Rev 00-P, " Reload Data Block Constant Installation Guidelines," February 1986.

(E) CEN-39(A)-P, Supplement 1-P, Rev 03-P, "CPC Protection Algorithm Sof tware Change Procedure Supplement,"

April 1986.

Dear Mr. Knighton:

The COLSS/CPC Oversight Committee, consisting of Arizona Uuclear Pever Project, Arkansas Power & Light Company, Louisiana Power & Light Company and Southern California Edison Company, with Combustion Engineering as its technical consultant, has developed the CPC Improvement Program. This program of CPC Modification and Methodology Improvements is scheduled to be implemented in 1986 and 1987.

The CPC Improvement Program consists of three major areas. The first two parts are addressed by References (A) and (B), which have been reviewed and approved by the NRC staff. References (C ), (D) and (E) were submitted in support of Part C of the program in February and April 1986. In further support of Part C of the program, Enclosure (1) is hereby submitted for NRC review; Enclosures (2) and (3) are provided for information only.

Enclosure ( 1 ) is CEN-330-P, "CPC/CEAC Software Modifications for the CPC Improvement Program Reload Data Block". Enclosure (1 ) documents the Reload Data Block (RDB) Constants sof tware modification and describes how RDB constants will be used. Enclosures ( 2) and ( 3) are Revisions 01-P of CEN-304-P and CEN-305-P respectively. These documents provide the functional design requirements for the CEAC and CPC Systems and the subject revisions incorporate the approved software modifications of Reference (A). Enclosures (4), (5) and p (6) provide non-proprietary versions of Enclosures (1), (2) and (3) respectively. , _ _ , _ _ _ _,

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t. PDR ADOCK 05000206 mP _. ._. ..__ .P DR _ .- ,

Power Systems 1000 Prospect Hill Road (203) 688-1011 Qt 9c,%

8 Cornbuston Engineenng Inc. Post Offce Box 500 Windsor, Connecticut 06095-0500 Telex: 99297 /t Q

0 L-2250'qponrar {I 9 *f />)

Mr. George W. Knighton May 21, 1986 Page 2 LD-86-024 Combustion Engineering is submitting CEN-330-P on behalf of the CPC Oversight Committee and is requesting NRC review of this document on a schedule consistent with initial implementation for Waterford 3 Cycle 2 (January 1987).

This submittal is only applicable to an individual licensee when the submittal is referenced by the licensee on its docket. (Enclosure (1) will be referenced by Louisiana Power 'and Light Company in their Waterford 3 Cycle 2 reload licensing submittal.) It is requested that any questions you have within the scope of this submittal be addressed to the Chairman of the CPC Oversight Committee, with copies to each Committee member and C-E. Attachment (A) lists the individuals to whom copies should be addressed.

Enclosures (1), (2) and (3) contain information considered by C-E to be proprietary in nature. As such, we request that they be withheld from public disclosure in accordance with the provisions of 10 CFR 2.790 and that this material be safeguarded. The reasons for the classification of this material as proprietary are delineated in the affidavits provided as Attachments (B) and (C).

Enclosed herewith is a check for $150.00 to cover the application fee for review of Enclosure (1).

Enclosures (2) and (3) are being provided for informational purposes only and no review or approval . . being requested. Combustion Engineering believes that no fees are to be incurred as a result of their submittal.

Should you have any gaestions on the contents of this letter, please contact me or Mr. J. E. Rogers of my staff at (203) 285-5204.

Very truly yours, COMBUSTION ENGINEERING, INC.

. [-- b ..

S,ALb l

LA . E. Sc erer Director Nuclear Licensing AES : BKH occ: L. Kopp (NRC) - letter only G. Schwenk (NRC) - letter only Attachments: (A) Correspondence List, COLSS/CPC Oversight Committee (B) Affidavit Attesting to the Proprietary Nature of CEN-330-P.

(C) Affidavit Attesting to the Proprietary Nature of CEN-304-P, Rev 01-P, and CEN-305-P, Rev 01-P.

Mr. George W. Knighton May 21, 1986 Page 3 LD-86-024 Enclosures (1) CEN-330-P, "CPC/CEAC Sof tware Modifications for the CPC Improvement Program Reload Data Block," May 1986: Copies 000001 thru 000009.

(2) CEN-304-P, Rev 01-P, " Functional Design Requirements for a Control Element Assembly Calculator," May 1986: Copies 000001 thru 000009.

(3) CEN-305-P, Rev 01 -P, " Functional Design Requirement for Core Protection Calculators," May 1986: Copies 000001 thru 000009.

(4) C EN-330-NP : Non-proprietary Version of Enclosure (1):

9 Copies Enclosed.

(5) CEN-304-NP, Rev 01-NP: Non-proprietary Version of Enclosure (2):

9 Copies Enclosed.

(6) CEN-305-NP, Rev 01-NP: Non-proprietary Version of Enclosure (3):

9 Copies Enclosed.

n; -

0 Attachment (A)

LD-86-024 Correspondence List Chairman of the CPC Oversight Committee

-Mr. R. M. Wilkins Louisiana Power & Light Company P.O. Box 60340 317 Baronne Street Mail Unit 17 New Orleans, Louisana 70160 Members of the CPC Oversight Committee Arkansas Power & Light Company A. G. Mansell Arkansas Power & Light Company P.O. Box 551 Little Rock, Arkansas 72203 Arizona Nuclear Power Project P. F. Crawley Arizona Nuclear Power Project P.O. Box 21666 Mail Station 4090 Phoenix, Arizona 85036 Southern California Edison Company E. J. Donovan Southern California Edison Company Room 316 G.O.1 P.O. Box 800 Rosemead, California 91770 Louisiana Power & Light F. J. Drummond Louisiana Power & Light Company P.O. Box 60340 317 Baronne Street Mail Unit 17 New Orleans, Louisiana 70160 Combustion Engineering, Inc.

A. E. Scherer Director, Nuclear Licensing Combustion Engineering, Inc.

1000 Prospect Hill Road P.O. Box 500 Windsor, Connecticut 06095

' Attachment (B)

LD-86-024 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 conf ormance 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-330-P, CPC/CEAC Sof tware Modifications for the CPC Improvement Program Reload Data Block, May, 1986 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.

E ei N 4 lu  ?

1. The information sought to be withheld f rom public disclosure is the reload data block feature of the core protection calculators, which is owned and has been held in confidence by Combustion Engineering.

s:

2.

~

The infor$ation consists of test data or,other similar data cchcerning a process, method or component, the application of which re#ults-in a' ei sub's tantial competitive advantage to Combustion Engineering.

3. The information is of a type customarily held in confidence by

^

- i Combustica 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 conf'i dence. ' The details of the aforementioned system were provided to the l

Nuclear Regulatory Commission via letter DP-537 f rom F.M. Starn to Frank Schroeder dated December 2, 1974. This system was applied in determining.that t

the subject document herein are proprietary.

, -O 1

4. The information is 'bein'g transmitted to the Conmission in confidence

~

p

- under tNe provisions of 10 CFR 2.790 with the understanding that it is to be received in confidence by the Commission. '

5. The informa, tion, ' to the best of my kno'wledge' and belief, is not

.available in public: sources,' and any disclosure to third parties has been made pursuant to regul tory ro : ,

provis' ions or proprietary agreements which provide for maintenance of the information'in confidance. -

/ ,.;

6. Publicdisclosureof-the[informationinlikelytocausesubstantial ew -

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harm to the competitive position of Combustion Engineering because: ,

a

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. . _ . . . . . _ _ _ .___m . ._. _. _

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 hundreds of manhours of effort and tens of thousands of dollars. To the best of my knowledge and belief a cempetitor 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 in the development of a reload data block feature for the core protection calculators.

d. The information required significant effort and expense to obtain j the licensing approvals necessary for application of the information.

l- Avoidance of this expense would decrease a competitor's cost in applying the r'

information and marketing the product to which the information is applicable.

e. The information consists of the reload data block feature of the core protection calculators, 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 L

apparatus.

l

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 l

I 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 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.

A AHN A. E. S rer Director Nuclear Licensing Sworn to before me this[b y of 36 j -

, A/1--stntAt / _2 $

Notary Public SUSANNE SMITH. NOTARY PUBUC State of Connecticut No. 74148 Commissfort Expires March 31,1990

MODIFICATIONS T0

" FUNCTIONAL DESIGN REQUIREMENTS FOR A CEAC" CEN-304-NP, REVISION 00, JULY 1985 TO PRODUCE

" FUNCTIONAL DESIGN REQUIREMENTS FOR A CEAC" CEN-304-NP, REVISION 01, MAY 1986 The attached 49 pages were revised for Revision 01 of the non-proprietary document " Functional Design Requirements for a CEAC", '

CEN-304-NP.

PAGES TO BE REPLACED: Cover, III, IV, V, VI l-1, 1-2, 1-3 2-l*, 2-2 3-1, 3-2, 3-3, 3-4, 3-6, 3-7, 3-8, 3-9*,

3-10*, 3-11*, 3-12, 3-13, 3-14* 3-16*, 3-17, 3-18*

4-l*, 4-2, 4-3, 4-4, 4-5*, 4-6*, 4-16*,

4-17*, 4-33*, 4-34*, 4-37, 4-38, 4-39*,

p 4-40*, 4-41*

Al, A2, A3, A4, A6 PAGES TO BE DELETED: A7, A8.

PAGES TO BE ADDED: 4-42.*

NOTES:

1. Adjacent bar at right margin [l] indicates change and/or addition.

2. Adjacent bar with small circle [(] indicates deletion.

3. Pages without the above mentioned marked bars indicate only pagination rather than content has changes. These pages are marked above with asterisks (*).

(cag/053.TXT)

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