ML20028G308

Forwards Proprietary & Nonproprietary Verions of, Suppl to Waterford 3,Cycle 1,CPC/CEAC Phase II Software Verification Test.

ML20028G308
Person / Time
Site:	Waterford
Issue date:	01/27/1983
From:	Maurin L LOUISIANA POWER & LIGHT CO.
To:	Knighton G Office of Nuclear Reactor Regulation
Shared Package
ML19303B514	List: ML20028G308 ML20028G313
References
3-A1.01.04, Q-3-C31-02, Q-3-C31-2, W3P83-0329, W3P83-329, NUDOCS 8302070616
Download: ML20028G308 (6)

Text

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l 142 DELARONDE STREET POWER & LIGHT P O BOX 6008

• NEW ORLEANS LOUISIANA 70174 * (504) 366 2345 UT t t [ bYS [

L. V MAURIN Voce Presodent Nuclear Operations January 27, 1983 W3P83-0329 3-A1.01.04 Q-3-C31.02 Director of Nacicar Reactor Regulation Attention: Mr. G. Knighton, Chief Licensing Branch No. 3 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555

SUBJECT:

Waterford SES Unit 3 Test Report Supplement CPC/CEAC Phase II Software verification CPC Software Functional Inconsistency  ;

REFERENCES:

1) W3P82-1733 dated June 25, 1982

2) W3P82-2340 dated September 3, 1982 ENCLOSURES: 1) CEN 208 (c)-P, Supplement 1-P

2) CEN 208 (c)-NP, Supplement 1-NP

3) Affidavit of proprietary status pursuant to 10 CFR 2.790

Dear Mr. Knighton:

The NRC staff identified, in Question 221.15, specific information regarding the CPC/CEAC system which was required for their review prior to issuance of an operating license. In response Reference (1) transmitted several documents to the NRC, one of which was CEN-208 (c)-P and NP, Waterford 3 Cycle 1 CPC/CEAC Phase II Software Verification Test Report.

Reference (2) and CEN 208 (c) identified a discrepancy in the Control Element Assembly Calculators (CEACs) between the "as built" software and the C-E functional requirements. The discrepancy involves a failure to apply penalty factors in certain circumstances associated with failed CEACs. Reference (2) also noted that a quality assured analysis to document the acceptability of the present software was being performed and would be forwarded to the NRC.

This letter transmits the aforementioned analysis. Attached please find proprietary copies 000003 through 000005 of Enclosure (1). Four copies of the nonproprietary document, Enclosure (2), are also included. Proprietary

( copy 000002 has baen sent directly to Mr. G. Shii.

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• W3P83-0329 Page Two.

1 The analysis demonstrates that in the restricted circumstances where a penalty factor is not applied, the associated trip function (with or  !

without the penalty factor) is not r aquired for plant protection. Under these conditions the plant protectiM function of the CPC is maintained (

in the DNBR calculation. Thus the present software is acceptable for i operation. The discrepancy with the functional specification will be corrected at the next planned CPC software modification prior to first reload.

Please be advised that the data listed in Enclosure (1) contains informa-tion which is proprietary to Combustion Engineering. Pursuant to Section 2.790 10 CFR part 2, you are requested to withhold this information from public disclosure. An affidavit attesting the proprietary nature of the material is provided as Enclosure (3). Also, in accordance with 10 CFR Section 2.790 (b), we recognize that withholding this information from public inspection shall not affect the right, if any, of persons properly and directly concerned to inspect the information.

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 Nuclear Licensing (9438-1922)

Combustion Engineering, Inc.

1000 Prospect Hill Road Windsor, CT 06095 We also request that you provide a copy of any questions concerning the proprietary nature of this submittal ta Louisiana Power and Light Company.

Yours very truly, L. V. Maurin LVM/MJM/pco Enclosures cc: W. M. Stevenson, E. L. Blake, J. Wilson, G. Shii

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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 inmediately 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 Louisiana Power and Light Company, for withholding this information.

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

CEN-208(C)-P, Supplement 1-P, Supplenent to Waterford 3, Cycle 1 CPC/CEAC Phase II Software Verification Test Report, Novenber 1982 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 Ccniaission's regulations, the following is furnished for consideration by the Connission in deternining whether the information sought to be withheld from public disclosure, included in the above referenced document, should be withheld.

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, 1. The information sought to be withheld from public disclosure are a description of the testing, quantitative data, evaluation of test results, and CPC/CEAC system software methodology, 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, i 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 Ccmmission via letter DP-537 from l

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 i

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 Engineeriog.

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 a t

i CPC/CEAC data base, CPC/CEAC software methodology and its testing.  !

l i d. The information required significant effort and expense to  !

1 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 descriptions of the testing, quantitative data, evaluation of test results, and CPC/CEAC system software methodology, the applicatico of which provides a competitive economic advantage.

The availability of such information to competitors would enable them to modify their product to bet ter 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 ecveloping similar l

datL and analyses in support of their processes, methods or apparatus.

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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 infomation by competitors in the international marketplace would increase their ability to narket 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.

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AIE.(herer Director Nuclear Licensing Sworn to before me this.)l dayof{hteuh<, Mind

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<'-1 i Notary Public

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