ML18023A034
| ML18023A034 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/27/1983 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Knighton G Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML18023A035 | List: |
| References | |
| RTR-NUREG-0857, RTR-NUREG-857 ANPP-27418, NUDOCS 8308010367 | |
| Download: ML18023A034 (20) | |
Text
REGULATORNFORMATION DISTRIBUTION 'TEM (RIOSI ACCESSION 'NBR:8308010367 DOC ~ DATE: 83/07/27 NOTARIZED: YES rr'AGfL:STN-50-528 Palo Verde Nuclear Stations Unit 1E Arizona Publi y'AUTH BYNAME STN-50 529 Palo Verde Nuclear Stationi Unit 2E Arizona Pub'li
.STN 50 530 Palo Verde Nuclear ='StationE Unit 3F Arizona 'Publi AUTHOR AFFILIATION AAN BRUNT ~ E ~ E.
Arizona Public Service Co ~
'RED IP ~ NAME R EC IP I EN]'FF ILIAT ION KNIGHTONF G ~
Licensing Branch 3
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SUBJECT:
Forwards proprietary 8 nonproprietary versions ofIreVised test pepts r e acceptable implementation of CPC sof twat e
,verification (ref SER NUREG-0857)
~ P,r opt ietary repts withheld (ref 10CFR2
~ 790)
~ Items closed.
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TITLE: Licensing Sub it al:
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PHOENIX. ARIZONA 65036 July 27, 1983 ANPP-27418 WFg/MSN 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 Pile:
83-056-026; G.l.01.10
Reference:
(A) NUREG-0857, "Safety Evaluation Report related to the opexation of Palo Verde Nuclear Generating
- Station, Units 1,
2 and 3", dated
- November, 1981.
(B) APS letter, ANPP-23163, from E. E. Van Brunt, Jr. to G.
W. Knighton, NRC, dated Maxch 3, 1983.
Dear Mr. Knighton:
Section 7.2.4 of Reference (A) requested plant specific data for the PVNGS Unit 1 Core Protection Calculators (CPC's) and the Control Element Assembly Calculators (CEAC's).
Reference (B) submitted the plant specific reports on the CPC/CEAC software verification testing and the PVNGS Unit 1, Cycle 1 Data Base Document.
Reference (B) stated that as a
result of the Phase II testing, we had identified discrepancies between the CPC simulator and the actual software calculation of certain flow xelated variables.
Reference (B) also stated that these discrepancies would be evaluated, that any related errors in the CPC's would be corrected, and that revised test reports demonstrating acceptable implementation would be provided.
Attached are the revised test reports.
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 10 CFR 2.790 and that this material be safeguarded.
The reasons for the proprietary classification of this report are delineated in the enclosed affidavit.
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8308010367 830727 PDR ADOCK 05000528 P
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Mr. G.
W. Knighton Page 2
July 27, 1983 ANPP-27418 WFQ/MSN We believe this closes the portion of Reference (A) confirmatory item (16) in Section 7.2.4 part (2),
CPC software modifications.
Please contact us if you have any questions on this matter.
Very truly yo rs, E. E.
Van Brunt, Jr.
APS Vice President Nuclear Projects Management ANPP Project Director EEVB/MSN/sp Attachment cc:
E. A. Licitra A. C. Gehr T. G. Woods
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Mr. G.
W. Knighton Page 3
July 27, 1983 ANPP-27418 WFQ/MSN
Enclosures:
Proprietary Affidavit CPC/CEAC System Phase I Software Verification Test Report; CEN-217(V), Revision 01, June 1983;
-P, Proprietary Version, Copies 0001-0025;
-NP, Non-Proprietary Version, 15 copies CPC/CEAC System Phase IX Software Verification Test Report; CEN-219(V), Revison 01, June 1983;
-P, Proprietary Version, Copies 0001-0025;
-NP, Non-Proprietary Version, 15 copies PVNGS-1 Cycle 1 CPC and CEAC Data Base Listing, CEN-251(V),
Revision 00, June 1983;
-P, Proprietary Version, Copies 0001-0025;
-NP, Non-Proprietary Version, 15 Copies
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July 27, 1983 ANPP-27418 MFQ/NSN STATE OF ARIZONA )
) ss.
COUNTY OF HARICOPA)
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.
U n~
Edwin E. Van Brunt, Jr.
Sworn to before me this day of
..,> 1983.
Hy Commission expires:
My Commhsfon Expires April6, $887 Nota,iy;public
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Mr. G.
W. Knighton Page 4
July 27, 1983 ANPP-27418 WFQ/MSN bcc:
A. C. Rogers W. F. Quinn T. F.
Quan K. E. Jones E.
C. Sterling J.
Y. Morita M. A. Jones R. J. Pinkerton G.
C. Andognini K. W. Gross S. R. Frost J.
M. Allen J. R. Bynum E. L. Lewis P. F. Crawley W. H. Wilson W. G. Bingham S.
Shepherd C. Ferguson M. Barnoski
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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 on 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 01, CPC/CEAC System Phase I Software Verification Test Report, June 1983 CEN-219(V)-P Revision 01, CPC/CEAC System Phase II Software Verification Test Report, June 1983 CEN-251(V)-P Revision 00, PVNGS-1 Cycle 1
CPC and CEAC Data Base Listing, June 1983 These documents have been appropriately designated as proprietary.
0 IP "I
I have personal knowledge of the criteria and procedures utilized by Combustion Engineering in designating information as a trade secret, priviledged, 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 determi ning whether the information sought to be withheld from public disclosure, included in the above referenced documents, should be withheld.
1.
The information sought to be withheld from public disclosure is 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
- 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 werre provided to the Nuclear Regulatory Commission via letter DP-537 from F. H. 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.
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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 my major pressurized water reactors competitors of Combustion Engineering.
b.
Development of this information by C-E required tens of thousands of man-hours 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 tesing,"
quantitative data, test evaluation, and acceptance criteria for 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'p 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, si gnificant research, development, engineering, analyti cal,'anufacturing, 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 ref 1 ecting si gni ficantly 1 ower costs.
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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.
rAY P. L. McGi1 1 Vice President Commerical Sworn to before m
this 8~day of a/g 8+
M. aEQPI'l, htOTARY PUBLl COfrlhi'i~SIQiV EX'ifES
.)
S MilRCH 31, 1988
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