ML13309B456
| ML13309B456 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 09/28/1984 |
| From: | Medford M Southern California Edison Co |
| To: | Knighton G Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML13309B457 | List: |
| References | |
| NUDOCS 8410020331 | |
| Download: ML13309B456 (11) | |
Text
Southern California Edison Company P. 0.
BOX 800 2244 WALNUT GROVE AVENUE
- ROSEMEAD, CALIFORNIA 91770 M.O. MEDFORD TELEPHONE MANAGER, NUCLEAR LICENSING September 28, 1984 (213) 572-1749 Director, Office of Nuclear Reactor Regulation Attention:
Mr. George W. Knighton, Branch Chief Licensing Branch No. 3 U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Gentlemen:
Subject:
Docket No. 50-361 & 50-362 Reload Analysis Report San Onofre Nuclear Generating Station Units 2 and 3 The purpose of this letter is to transmit the SONGS Unit 2, Cycle 2 Reload Analysis Report And to request that your review be completed by November 30, 1984. Accordingly, please find enclosed three (3) copies of the SONGS Unit 2, Cycle 2 Reload Analysis Report identified as Enclosure 1. The Technical Specification changes which are required for Cycle 2 consistent with the Reload Analysis are also identified in Section 10 of this report. It should be noted that the required Technical Specification changes identified in Section 10 are being submitted separately as formal license amendment applications consistent with the requirements of 10 CFR 50.90 as shown in Table 1. Other Technical Specification changes not identified in the Reload Analysis Report but also required to support the SONGS Unit 2 refueling outage and Cycle 2 operation have been submitted as formal license amendment applications as shown in Table 2. Additional Technical Specification changes that are highly desirable to support the SONGS Unit 2 refueling outage and Cycle 2 operation have been and will be submitted as formal license amendment applications as shown in Table 3. SCE requests your review and approval of the Technical Specification changes discussed above be completed by the dates shown in Tables 1, 2 and 3.
Even though the Reload Analysis Report was prepared specifically for SONGS Unit 2, SCE and CE consider that the Technical Specification changes and the CPC software update documentation are also applicable to SONGS Unit 3, Cycle 2. The Reload Analysis Report for SONGS Unit 3, Cycle 2 will be confirmatory relative to the Reload Analysis Report for SONGS Unit 2, Cycle 2. Therefore, the Technical Specification changes and the CPC software update documentation have been written to also apply for SONGS Unit 3, Cycle 2.
In accordance with Unit 2 License Condition 2.C(6) "High Burnup Fission Gas Release" the fission gas release analysis was performed for Cycle 2 operation. As discussed in Section 4.3 of the Reload Analysis Report, the analysis was performed using the NRC approved version of the FATES3A fuel evaluation model including the NRC imposed restriction on fuel grain size, which enhances fission gas release. The maximum peak pin burnup analyzed for U
Cycle 2 was 32,600 MWO/MTU. The analysis meets the requirements of Unit 2 License Condition 2.C(6_)thr oughthe-end-of-Cycle 2 operation 9410020331 840928 PDR ADOCK 05000361 PF;k PDR
Mr. G.
September 28, 1984 As you know, the NRC staff was provided with early notification of CPC software and methodology changes which will be incorporated into Cycle 2 for SONGS 2 and 3 during the June 29, 1984 meeting at the NRC Offices in Bethesda, Maryland. The proprietary information presented during the June 29, 1984 meeting was formally transmitted to the NRC by letter dated July 20, 1984. As stated during the June 29, 1984 meeting and the July 20, 1984 letter, SCE committed to provide the NRC with a Statistical Combination of Uncertainties Report and a Phase I/Phase II CPC Test Report for SONGS Units 2 and 3 in addition to the Reload Analysis Report for SONGS Unit 2. Part 1 of the Statistical Combination of Uncertainties Report for SONGS Units 2 and 3 has been completed and is also being transmitted with this letter (Enclosures 2 and 3).
Parts 2 and 3 of the Statistical Combination of Uncertainties Report for SONGS Units 2 and 3 and the Phase 1/ Phase II CPC Test Report for SONGS Units 2 and 3 will be transmitted to the NRC by November 15, 1984.
Accordingly, please find enclosed three (3) copies of each of the following proprietary Combustion Engineering documents including an affidavit setting forth the basis on which the information may be withheld from public disclosure by the Commission and addressing specifically the considerations listed in 10 CFR 2.790(b) of the Commission's regulations.
CEN-283(S)-P, Statistical Combination of Uncertainties, Part 1, Combination of System Parameter Uncertainties in Thermal Margin Analyses for SONGS Units 2 and 3, June 1984. (Copy Nos. 000001, 000002 and 000003)
It is respectfully requested that the above information which is proprietary to CE be withheld from public disclosure in accordance with 10 CFR 2.790(b) of the Commission's 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, Nuclear Licensing Combustion Engineering Inc.
P. 0. Box 500 Windsor, Connecticut 06095-0500 It is also requested that you provide a copy of any questions concerning the proprietary nature of this document to SCE and SDG&E.
Three (3) copies of the following nonproprietary version of is also enclosed to satisfy the requirements for transmittal of proprietary information to the NRC:
CEN-283(S)-NP, Statistical Combination of Uncertainties, Part 1, Combination of System Parameter Uncertainty in Thermal Margin Analyses for SONGS Units 2 and 3, June 1984.
In summary, SCE requests your review of the SONGS Unit 2, Cycle 2 Reload Analysis Report be completed by November 30, 1984 and your review and approval of related Technical Specification changes required to support SONGS Unit 2, Cycle 2 operation be completed by the dates shown in Table 1. SCE also requests your review and approval of the additional Technical
Mr. G.
September 28, 1984 Specification changes needed to support the refueling outage and Cycle 2 operation be completed by the dates shown in Tables 2 and 3. SCE is available to assist the NRC staff's review and approval of the enclosed information.
If you have any questions or comments, please let me know.
Very truly yours, Enclosures cc:
Harry Rood, NRC Project Manager (to be opened by addressee only, Enclosure 2 Copy No. 000004)
Larry Phillips, NRC Core Performance Branch Chief (to be opened by addressee only - Enclosure 1, Enclosure 2 Copy No. 000005)
A. E. Chaffee, NRC Senior Resident Inspector (Enclosures 1 and 3 only)
TABLE 1 Technical Specification Changes Identified in the Reload Analysis Report As Required to Support Cycle 2 Operation Proposed Amendment Date Date NRC Change No.
Unit Application To NRC Approval Requested*
52, Revised 2
10/5/84 1/2/85 3
10/5/84 85, Revised 2
10/5/84 12/28/84 3
10/5/84 138 2
26 4/10/84 1/2/85 3
12 4/10/84 148 2
29 10/1/84 12/28/84 3
15 10/1/84 150 2
29 10/1/84 1/2/85 3
15 10/1/84 151 2
29 10/1/84 12/28/84 3
15 10/1/84 152 2
29 10/1/84 12/28/84 3
15 10/1/84 153 2
29 10/1/84 12/28/84 3
15 10/1/84 160 2
29 10/1/84 12/28/84 3
15 10/1/84 161 2
28 8/21/84 11/18/84 3
14 8/21/84 162 2
29 10/1/84 12/28/84 3
15 10/1/84 163 2
28 8/27/84 11/18/84 3
164 2
29 10/1/84 12/28/84 3
15 10/1/84
.168 2
29 10/1/84 12/28/84 3
15 10/1/84 169 2
29 10/1/84 12/28/84 3
15 10/1/84 Notes Unit 2 will shutdown approximately 2 weeks later than the date used to determine the dates in this column.
Dates to be determined for SONGS Unit 3. Dates requested for NRC approval of Technical Specification changes will be consistent with the start of the Unit 3 refueling outage currently scheduled for April 1985.
TABLE 2 Additional Technical Specification Changes Required to Support the SONGS 2 Refueling Outage and Cycle 2 Operation Proposed Amendment Date Date NRC Change No.
Unit Application To NRC Approval Requested*
50
- 2.
27 6/27/84 9/27/84 3
13 6/27/84 99 2
25 3/2/84 12/28/84 3
11 3/2/84 102 2
25 3/2/84 12/28/84 3
11 3/2/84 126 2
27 7/9/84 12/28/84 179 2
27 7/18/84 9/27/84 3
13 7/18/84 180 2
27 6/27/84 9/27/84 3
13 6/27/84 Notes Unit 2 will shutdown approximately 2 weeks later than the date used to determine the dates in this column.
Dates to be determined for SONGS Unit 3. Dates requested for NRC approval of Technical Specification changes will be consistent with the start of the Unit 3 refueling outage currently scheduled for April 1985.
GvN:2459F
TABLE 3 Additional Technical Specification Changes That Are Highly Desirable To Support the SONGS 2 Refueling Outage and Cycle 2 Operation Proposed Amendment Date Date NRC Change No.
Unit Application To NRC Approval Requested*
15 2
11 9/3/82 12/28/84 3
2 1/25/83 127 2
26 4/24/84 12/28/84 3
12 4/24/84 141 2
27 6/29/84 10/4/84 3
13 6/29/84 142 2
28 9/11/84 12/3/84 3
14 9/11/84 149 2
30 10/12/84 1/2/85 3
16 10/12/84 165 2
30 10/12/84 1/2/85 3
16 10/12/84 Notes Unit 2 will shutdown approximately 2 weeks later than the date used to determine the dates in'this column.
Dates to be determined for SONGS Unit 3. Dates requested for NRC approval of Technical Specification changes will be consistent with the start of the Unit 3 refueling outage currently scheduled for April 1985.
GvN:2459F
Page 1 of 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, Commerical, 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 Company for withholding this information.
The information for which proprietary treatment is sought is contained in the following document:
CEN-283(s)-P, Statistical Combination of Uncertainties Part I, June 1984.
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.
Page 2 of 4
- 1. The information sought to be withheld from public disclosure are fuel fabrication data, input and performance data, and thermal hydraulic methods, 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 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:
Page 3 of 4
- 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 development of fuel fabrication data, input and performance data, and thermal hydraulic methods.
- 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 fuel fabrication data, input and performance data, and thermal hydraulic methods, 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.
'Page 4 of 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.
P. L. McGill Vice President Commercial Sworn to before me this 9k day of i9V tary Public EIA X BNMr NOTARY PUBLIC STATE OF CONNECTICUT No. 68542 COMMISSION EXPIRES MARCH 31, 1989
ENCLOSURE 1