ML17298A228
| ML17298A228 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 03/03/1983 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Knighton G Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML17298A229 | List: |
| References | |
| RTR-NUREG-0857, RTR-NUREG-857 ANPP-23163-WFQ, NUDOCS 8303100345 | |
| Download: ML17298A228 (16) | |
Text
REGULATOR" INFORMATION DISTRIBUTION STEM (RIDS)
ACCESSION NBR; 83031003Il5 DOC ~ DATE: 83/03/03 NOTARIZED: YES FACIL:STN 50-528 Palo Verde Nuclear Stationi Unit li Arizona Publi AUTH,fvANE AUTHOR AFFILIATION VAN BRUNTiE ~ ED Arizona Public Service Co ~
RECIP,NANT RECIPIEN J AFFILIATION KNIGHTONrGB Licensing Branch 3
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SUBJECT:
Forwards proprietary 5 nonproprietary repts on core protection calculations 8 control element assembly calculatorsiper ShR NUREG 0857.Affidavit for withholding per 10CFR2,790 encl'roprietary repts withheld (ref 19CFRR 790)
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Arizona Public Service Company P.O. BOX 2<666
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PHOENIX, ARIZONA 65036 March 3, 1983 ANPP-23163 WFQ/TFQ Director of Nuclear Reactor Regulation Attention:
Mr. George Knighton, Chief Licensing Branch No.
3 Division of Licensing U.
S. Nuclear Regulatory Commission Washington, D.
C.
20555
Subject:
Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2 and 3
Docket Nos.
STN-50-528/529/530 File:
83-056-026'.l.01.10
References:
(A)
NUREG-0857, "Safety Evaluation Report related to the operation" of Palo Verde Nuclear Generating Station Units 1, 2 and 3, dated
- November, 1981.
Letter LD-82-039, from A. E. Scherer, CE, to D.
G. Eisenhut, NRC, dated March 30, 1982.
Dear 1h;. Knighton:
Section 7.2.4 of Reference (A) requested plant specific data for the PVNGS Unit 1 Core Protection Calculations (CPC's) and the Control Element Assembly Calculators (CEAC's).
Attached for your review are reports on the CPC/CEAC software verification testing and the PVNGS Unit 1, Cycle 1 Data Base.
Reference (B) provided that portion of the CPC/CEAC system which is generic to the System 80 reactor, on the CESSAR docket.
This generic submittal included:
(1) a description of the CPC software changes; (2) the CPC qualification test plan; and (3) a summary of the safety analysis for application of the CPC's in System 80 reactors.
As a result of the Phase II testing, we have identified a discrepancy between the CPC simulator and the actual software calculation of certain flow related variables.
These discrepancies will be evaluated and any related errors in the CPC's will be corrected.
A supplemental test report demonstrating acceptable implementation will be provided by April, 1983.
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 provisions of 10CFR 2.790 and that this material be safeguarded.
The reasons 8303100345 830303 PDR ADOCK 05000528 E
-~ PDR
Mr. G. Knighton March 3, 1983 ANPP-23163 WFQ/TFQ Page 2
for the propriet'ary classification. of this report are delineated in the enclosed affivadit.
Please contact me if you have any questions on this matter.
Very truly yours, E.
E. Van Brunt, Jr.
APS Vice President, Nuclear Projects ANPP Project Director EEVBJr/TFQ/sp Attachment cc:
E. A. Licitra K. Berlin A. C.
Gehr Attachments:
Proprietary Affidavit CPC/CEAC System Phase I Software Verification Test Report; CEN-217 (V), Revision 00, January 1983; -P, Proprietary Version Copies Number 0001-0025;
-NP, Non-Proprietary Version, 15 Copies CPC/CEAC System Phase II Software Verification Test Report, CEN-217 (V), Revision 00, January 1983; -P, Proprietary
- Version, Copies Number 0001-0025;
-NP, Non-Proprietary Version, 15 Copies PVNGS Cycle 1
CPC and CEAC Data Base
- Document, CEN-226(V),
Revision 00, January 1983; -P, Proprietary Version, Copies Number 0001-0025;
-NP, Non Proprietary Versions, 15 Copies
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STATE, OF ARIZONA
)
) ss.
COUNTY OF MARICOPA)
I, Edwin E. Van Brunt, Jr., represent that I am Vice President Nuclear Projects of Arizona Public Service
- Company, that the foregoing document has been signed by me on behalf of Arizona Public Service Company with full authority so to do, that I have read such document and know its contents, and that to the best of my knowledge and belief, the statements made therein are true.
4b~a(
n C Edwin E. Van Brunt, Jr.
Sworn to befo're me this day of Ma c'c-4
, 1983.
My Commission expires:
My Comm}sslon Qp)~g ggy ',g <gg Notary Public
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N AFFIDAVIT PURSUANT TO 10 CFR 2.790 Combustion Engineering, Inc.
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State of Connecticut
)
County of Hartford
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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 the Arizona Public Service Company, for withholding this information.
The information for which proprietary treatment is sought is contained in the following documents:
CEN-217(V)-P Revision 00, CPC/CEAC System Phase I Software Verification Test Report, January 1983.
CEN-219(V)-P Revision 00, CPC/CEAC System Phase II Software Verification Test Report, January 1983.
I i
, I CEN-226(V)-P, PVNGS-1 Cycle 1
CPC and CEAC Data Base Doc'ument, January 1983.
These documents have 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.
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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 documents, should be withheld.
l.
The information sought to be withheld from public disclosure are a
description of the testing, quantitative data, test evaluation and acceptance criteria for the CPC/CEAC system software, 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.hl. 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 s't be received in confidence by the Commission.
h 5.
The, information,'to the best of my knowledge and belief, is not I
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.
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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 tens of thou-sands 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 CPC/CEAC data base and testing of CPC/CEAC 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 a description of the testing, quantitative data, test evaluation, and acceptance criteria for the CPC/CEAC system software, 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.
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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.
erer Director Nuclear Licensing Sworn to before me this day of R, L Ofsen JAN30 1983 RRRÃg MC4 ZusM.ce of the 1'eace 336 Taylor Rd.
En'.eld, CT'6082
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