ML13308B933

Forwards Proprietary & Nonproprietary Versions of Cpc/ Ceac Sys,Phase II Software Verification Test Rept, San Onofre Nuclear Generating Station 2,Cycle 1,CPC & Ceac Data Base Document, Cpc/Ceac Sys,Phase 1,Software....

ML13308B933
Person / Time
Site:	San Onofre
Issue date:	08/13/1981
From:	Baskin K Southern California Edison Co
To:	Miraglia F Office of Nuclear Reactor Regulation
Shared Package
ML13308B934	List: ML13308B933 ML20010C770 ML20010C772 ML20010C774 ML20010C778 ML20010C782
References
NUDOCS 8108200397
Download: ML13308B933 (25)

Text

e REGULATO ORMATION DISTRIBUTION M (RIDS)

'ACCESSION NdR:8108200397 DOCDATE: 81/08/13 NOTARIZED: YES DOCKET #

FACIL:50-361 San Onofre Nuclear Station, Unit 2, Southern Californ 50-362 San Onofre Nuclear Station, Unit 3, Southern Californ AUTH:.NAME- AUTHOR AFFILIATION BASKIN,K!.P. Southern California Edison Co.

RECIP.NAME1 RECIPIENT AFFILIATION MIRAGLIAF. Licensing Branch 3 >

SUBJECT:

Forwards proprietary & nonproprietary versions of "CPC/

CEAC SysPhase II Software Verfication Test Rept," "Sa OnofreiNuclear Generating Station 2,Cycle 1,CPC & CEAC Data Base Document,." "CPC/CEAC SysPhase 1,Software...."

DISTRIBUTION CODE.: P01S COPIES RECEIVED:LTR L ENCLi, SIZE: Ta TITLE!: Proprietary Review Distribution - Pre OL NOTES:Send all FSAR & ER amends to L Chandler, 05000361 I cy:J Hanchett (Region V).0 Scalettit cy of all envir into Send all FSAR & ER amends to L Chandler. 05000362 1 cy:J Hanchett (Region V).D Scalettir1 cy of all envir info RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAMEi LTTR ENCL: ID CODE/NAME LTTR1ENCL2 "ACTION:, LIC BR43 BC 1 0 LIC BR #3 LA 1 0.

ROODF 02 1 1 INTERNAL: DIRECTOR NRR 1 0 1&4. 03 3 MPA 1 0 1 0 QELD 1 0 cR'EGFIL 1,- I I EXTERNAL: ACRS Ob 0 1& LPDR 1 0 NSIC 1 0 NTIS 1 0 liL TOTAL NUMAFR OF COPPSREQUIRTEDr.ITTR 3,0 ENCir

Southern California Edison Company P. O. BOX 800 2244 WALNUT GROVE AVENUE ROSEMEAD. CALIFORNIA 91770 K. P. BASKIN TELEPHONE MANAGER OF NUCLEAR ENGINEERING, August 13, 1981 213) 572-1401 SAFETY, AND LICENSING Director, Office of Nuclear Reactor Regulation Attention: Mr. Frank Miraglia, Branch Chief Licensing Branch No. 3 U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Gentlemen:

Subject:

Docket Nos. 50-361 and 50-362 San Onofre Nuclear Generating Station Units 2 and 3 The following proprietary Combustion Engineering reports were previously transmitted to the NRC relative to the Core Protection Calculator (CPC) Open Item which was most recently identified as SER Open Item No. 2, CPC, in supplement No. 2 to the San Onofre Units 2 and 3 SER dated May, 1981:

1. Functional Description Document for the Control Element Assembly Calculator (CEAC) (SCE letter dated January 19, 1981).

2. Functional Description Document for the CPC (SCE letter dated January 21, 1981).

3. Preliminary version of the SONGS-2 Cycle-1 CPC and CEAC Data Base Document. (SCE letter dated February 4, 1981.)

In connection with this Open Item, please find enclosed three (3) copies each of the following proprietary Combustion Engineering documents including affidavits setting forth the basis on which the information may be withheld from public disclosure by the Commission and addressing specifically the consideration listed in 10 CFR 2.790(b) of the Commission's regulations.

Enclosure 1. CEN-173(S)-P, CPC/CEAC System, Phase II Software Verification Test Report. (Copy Nos. 002, 003 and 004.) 8 1 Enclosure 2. CEN-175(S)-P, SONGS-2 Cycle 1 CPC and CEAC Data Base Document. /

(Copy Nos. 002, 003 and 004.) /13 Enclosure 3. CEN-176(S)-P, CPC/CEAC System, Phase I Software Verification Test Report. (Copy Nos. 002, 003 and 004.)

aiO20039 6106913 PDR ADOCK 05000361 A PDR-)

Mr. Frank Miraglia August 13, 1981 It is respectfully requested that the above information which is proprietary to Combustion Engineering, Inc., be withheld from public disclosure in accordance with 10 CFR 2.790(b) of the Commissions regulations.

If you should have any questions concerning the proprietary nature of the material transmitted herewith, please address these questions directly to:

Mr. A. E. Scherer Director of Licensing (9438-1922)

Combustion Engineering 1000 Prospect Hill Road Windsor, Connecticut 06095 It is also requested that you provide a copy of any questions concerning the proprietary nature of this submittal to SCE and SDG&E.

Three (3) copies of the following nonproprietary documents are enclosed to satisfy the requirements for transmittal of proprietary information to the NRC: . CEN-147(S)-NP, Functional Design Specification for a Core Protection Calculator. . CEN-148(S)-NP, Functional Design Specification for a Control Element Assembly. . CEN-173(S)-NP, CPC/CEAC System Phase II Software Verification Test Report. . CEN-175(S)-NP, SONGS-2 Cycle 1 CPC and CEAC Data Base Document. . CEN-176(S)-NP, CPC/CEAC System, Phase I Software Verification Test Report.

Also enclosed (Enclosure 9) are three (3) copies of the SONGS-2 Cycle 1 Core 'Protection Calculator Time to Trip Analysis which was requested by the NRC staff during the March 9, 1981 meeting in Bethesda, Maryland.

The enclosed documentation addresses all previously identified NRC requirements relative to this issue and provides the information necessary to resolve the CPC Open Item.

If you have any questions or comments concerning this matter, please contact me.

Very truly yours, Enclosures

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 Southern California Edison Co., for withholding this information.

The information for which proprietary treatment is sought is contained in the following document:

CEN-173(S)-P, CPC/CEAC Systems Phase II Software Verification Test Report, August 5, 1981.

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 ihformation.

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.

-- gg

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 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.-E. Sceer Director Nuclear Licensing Sworn to before me this 6. day of Notary Pu li CAREY J. WENZEL, NOTARY PUBLIC State of Connecticut No. 59962 Commission Expires March .31, 1985

-- 9.

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 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 information.

c. In order to acquire such information, a competitor would also require considerable time and inconvenience related to the development of test methods for Core Protection Calculator and Control Element Assembly Calculator System Software.

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 detailed descriptions of the testing performed and quantitative data and evaluation of the tests and test acceptance criteria, 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.

g@ @o

1. The information sought to be withheld from public disclosure are detailed descriptions of the testing performed and quantitative data and evaluation of the tests on the Core Protection Calculator and Control Element Assembly Calculator System Software and test acceptance criteria, 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 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 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 made pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence.

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 Southern California Edison Co. for withholding this information.

The information for which proprietary treatment is sought is contained in the following document:

CEN-176(S)-P, CPC/CEAC Systems Phase I Software Verification Test Report, August 5, 1981 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 i.n the above referenced document, should be withheld.

1) -2

1. The information sought to be withheld from public disclosure are the CPC/CEAC System Phase I Software Verification Test Hardware Configuration, Test Apparatus Application programs, and Memory maps for the Application Programs and Executive 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 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 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 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:

-3

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 information.

c. In order to acquire such information, a competitor would also require considerable time and inconvenience related to the development of test methods for software verification.

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 detailed descriptions of the CPC/CEAC System Phase I Software Verification Test Hardware configuration, Test Apparatus, Application Programs, and Memory maps for the Application Programs and Executive 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, significant research, development, engineering, analytical, manufacturing, licensing, quality assurance and other costs and expenses must be included.

-4 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 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. E . S ere'r Director Nuclear Licensing Sworn to before me this day of CG.u Notary Pu i CAREY J. WENZEL, NOTARY UBLpQ State of Connecticut No. 5996Z ionis~sion Exnires Mach't '11 :108

ENCLOSURE 9 SONGS-2 CYCLE 1 CORE PROTECTION CALCULATOR TIME TO TRIP ANALYSIS As a result of the 3-9-1981 meeting with the NRC Staff, C-E committed to provide results of a comparison of the CPC transient and design transient calculations for certain transients for SONGS-2 Cycle 1. These transients are:.

1. Four pump loss of flow.

2. -One pump coast down for four pumps running.

3. Full length CEA drop.

4. Primary coolant depressurization

5. CEA bank withdrawal from 1% power.

The design transient response of the NSSS was determined by simulating the event with the CESEC code. The CESEC code is normally used by C-E for portions of the Chapter 15 transient analysis. The CPC transient response was determined by simulating the events as input to the CPC FORTRAN code. Maximum CPC system calculational delays were used to assure the latest trip would be obtained.

Tables 1 & 2 sumriarize the initial conditions for the analysis. Figures 1-5 provide traces of the CESEC analysis DNBR vs. time; the required trip time, determined from the CESEC analysis; as well as the CPC trip times as simulated by the CPC.FORTRAN.

Table 3 summarizes the results. In all cases the CPC FORTRAN provided a trip before the time required from the CESEC analysis.

TABLE 1 INITIAL CONDITIONS FOR FULL POWER CASES (CASES 1-4)

Initial Power 3410 MWt Initial Core Inlet Temperature 553.50F, Initial RCS Pressure 2225 psia Initial.Core Flow 2.64 x 106 bm/hr-ft2 Axial Shape Index -0.212 Initial Fr 145 Time Interval to Generate Trip 0.15 seconds Holding Coil Delay Time 0.30 seconds CEA Configuration All Rods Out 1.45 0.5seod

TABLE 2 CEA WITHDRAWAL FROM 1% POWER CASE DATA (CASE 5)

Initial Power 34.1 MWt Initial Core Inlet Temperature 544.60F Initial RCS Pressure . 2225 psia Initial Core Flow 2.6t x 106 ibm/hr-ft2 ASI -.269 Initial Fr 2.13 Reactivity Insertion 1.5 x 10-4 Ap/sec CEA Configuration Bank 6-100% Inserted Bank 5-100%1 Inserted Bank 4-100% Inserted Bank 3-50% Inserted End Time is 40 Seconds

TABLE 3 COMPARISON OF REQUIRED (CESEC) AND OBSERVED (CPC)

TRIP TIMES FOR SONGS-2 CYCLE 1 (INSECONDS)

CASE CESEC CPC

1. 4 pump loss of flow 4.0 0.264

2. 1/4 pump loss of flow 11.4 1.114

3. Full length CEA drop * *

4. Primary coolant depressurization 319.0 208.930

5. CEA withdrawal from 1% power

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AFFIDAViT PURSUANT TO 10 CFR 2.790 Combustion Engineering, Inc.

State of Connecticut County of Hirtford ) SS.:

1, 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 infomation which is identified as proprietary and referenced In the paragraph iimdiately bela. X on, submitting this affidbvit in conformance with the provisions of 10 CFR 2.790 of the Commuission's regulations and in conjunction with the application of Southern California Edison Co. for withholding this information.

The infomatica for which proprietary treatment is sought is contained in the following document:

CEW-175-(S)-P. CPC/CEAC Data Base Document, August 5, 1981.

This document has been appropriately designated as proprietary.

I have personal knowledge of 'the criteria and procedures utilized by CGmbustion Engineering in designating information as a trade secret, privileged or as confidential comercial or financial informtion.

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 Conission in determining whether the information sought to be withheld fronm public disclosure, included in the above referenced document, Should be withheld.

1. The information sought to be withheld from public disclosure are detailed descriptions of the names of the constants and their values in Tho SONGS-2 Lyi le I ( Pi /LLAC System data base which is owned and has beeon held in confidente by lombustion 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 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-S37 from F.N. Stern to Frank Schroeder dated December 2, 1974. This system was applied in determining that the subject documnts herein are proprietary.

4. The information.is being transmitted to the Comidssion in confidence under the provisions of 10 CFR 2.790 with the understanding that it is to be received in confidence by the Comission.

S. The information, to the best of my knowledge and belief, is not availdble in public sources, and any disclosure to third parties has been iade pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence.

to Public disclosure of the information is likely to cause'substantial hor io the competitive position of Combustion rnqineering becauSe:

, --- 3-

a. A similar product is manufactured and sold by major pressurized tater reactors comptitors of Cowbustion Engineering.

b. Development of this information by C-E required thousands of Qanhours of effort and hundreds of thousands of dollars. To the best of my kncoledge and belief a comwptitor would have to undergo similar expense in generating equivalent Information.

e. go ordrP to acquire such Infomation, a campetitor would also reqoire mmsiorable the ond Inconvenienco relatod to the developmnt of Mhe coatants fr the Sy=te softwar.

d. The informtica rqrd significant effort and epnse to shtoM the ticeaVsft aRProe lcessay for applICatiR oq thG infomamtion.

AvOIdsce of this cenpnse nolAd decreaso &copetr coqt in applying thez< inforMtn ad carketig the poduct to whch the Informationi is Q. The') infoRapte congists of dotailed descriptios of Me ac:a of As conts and teir ves in tM2 S-2 Ccle CPC/CEAC Syste

• 0baso Urh O e cthich Providesw a Cca 9Itive ecomic advantoge. Yk availability of such inomtion to canitors uld enablo them to C3Mfy their Product to better compete uwth Cawustion Eho tCkOexotig odwar actions to improo thoir proUct's Pos10itc or IotPO the position of C ustion nin s product, and avoideveloping sIMiar data and onelyses 1P support of their processes, thods or opparatus.

• f. Inpricing Ceabustion Engineering's products and services, significant resrch, development, engineering, analytical" Rnufacturing, licensing, quality asurance and other costs ond eonsos iust be included.

-.4-w 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.

9. 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 developm2nt.

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

Further the deponent sayeth not.

A. E. S rer Director Nuclear Licensing Sworn to before me this* day of // /

CARESA J. WENZEL Norga yPWIL State of Conncticut o. 5AM Commo heims L Cpredm Rf