ML20040D011
| ML20040D011 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 01/22/1982 |
| From: | Baskin K SOUTHERN CALIFORNIA EDISON CO. |
| To: | Miraglia F Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19297F285 | List: |
| References | |
| NUDOCS 8201290475 | |
| Download: ML20040D011 (23) | |
Text
,
Southern Ca/ifornia Edison Company SCE P. O. BOX 8 00 2 244 W ALNUT GROVE AVEN U E RO S E M E AD. C A LIP'OR NI A 9 9 7 70 K. P. B AS K tN 3 '
3 ser rv,Ano ce ma January 22, 1982
<X RECENgg
_3 MN28 Narau'm;g82* =
/
. Director, Office'of Nuclear Reactor Regulation
[$8WD ',
Attention:
Mr. Frank Mi raglia, Branch. Chief 6
e Licensing Branch No. 3 U. S. Nuclear Regulatory Commission Washington, D.C.
20555 N
c1 Gentlemen:
Subject:
Docket Nos. 50-361 and 50-362 San Onofre Nuclear Generating Station Units 2 and 3 In connection with the thermal-hydraulic design of San Onofre Units 2 and 3, SCE has held numerous meetings and discussions with the NRC Core Performance Branch (CPB) during the past several months.
Revisions.to the San Onofre Units 2 and 3 thermal-hydraulic documentation were required to reflect the clarification requested by the NRC CPB. The revisions were previously provided to the NRC CPB and were subsequently approved by them.
The purpose of this letter is to formally document transmittal of the revised thermal-hydraulic design documentation for San Onfre Units E and 3 to the NRC. Accordingly please find enclosed three (3) copies each of ti e following revised proprietary Combustion Engineering documents, including affidavits setting forth the basis on which the information may be witheid from public disclosure by the Commission and addressing specifically the considerations listed in 10 CFR 2.790 (b) of the Commission's regulations:
&, f - CEN-160(S)-P, REV. 1-P, CETOP-D Code Structure and I
Modeling Methods for San Onofre Nuclear Generating Station Units 2 and 3.
(Copy Nos. 003, 004 and 005)
/.1 N4[
.S~ m W - CEN-184(S)-P, REV. 2-P, Responses to Questions on Documents Supporting SONGS 2 License Submittal.
(Copy Nos. 003, 004 and 005) - CEN-176(S)-P, REV. 01. CPC/CEAC System Phase I Sof tware Verification Test Report.
(Copy Nos. 003, 004 and 005) - CEN-173(S)-P, REV. 02, CPC/CEAC System Phase II Software Verification Test Report.
(Copy Nos 00013, 00014 and 00015)
KO!hhohhg PDR 1
Mr. Frank Mi raglia It is respectfully requested that the above information, which is proprietary to Combustion Engineering, Inc., be witheid from public disclosure in accordance with 10 CFR ?.790(b) of the Commission's regulations.
If you should have any question concerning the proprietary nature of the 7.aterial 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 SDGLE.
Also enclosed are five (5) copies each of the following nonproprietary versions of the above documentation in order to satisfy the requirements for transmittal of proprietary information to the NRC: - CEN-160(S)-NP, REV.1-NP, CETOP-D Code Structure and Modeling Methods f or San Onofre Nuclear Generating Station Units 2 and 3. - CEN-184(S)-NP, REV. 2-NP, Responses to Question on Documents Supporting SONGS 2 License Suhmittal. - CEN-176(S)-NP, REV. 01, CPC/CEAC System Phase I Software Verification Test Report. - CEN-173(S)-NP, REV. 02, CPC/CEAC System Phase 11 Software Verification Test Report.
The enclosed doucmentation reflects revisions requested and previously approved by the NRC CPB and fulfills all documentation requirements relative to the thermal-hydraulic design of San Onof re Units 2 and 3.
If you have any questions or comments concerning this matter, please contact me.
Very truly yours, A
Enclosures i
l i
J
a ~,-
a m__
e e
p ENCLOSURE 1 a
i 1
i
- -... _, -.. ~ -. -
....- --.-m
..r
-y,
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 l
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 l
application of Southern California Edison Co. and San Diego Gas and Electric j
Co., for withholding this information.
The information for which proprietary treatment is sought is contained in the following document:
CEN - 160(S) - P, Revision 1-P, CETOP - D Code Structure and Modelling Methods for San Onofre Nuclear Generating Stations Units 2 and 3.
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.
4 Pursuant to the provisions of paragraph (b) (4) of Section 2.790 of the Commission's regulations, the following is furnished for consideration i
by the Commission in determining whether the information sought to be withheld from public disclosure, included in the above referenced document, should.be withheld.
1
, 1.
The information sought to be withheld from public disclosure are the C-E thermal margin analysis methodology and thermal hydraulic character-istics of C-E cores, 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 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.
,v,,_,.
3.,,,
e.,
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 methods for the statistical combination of uncertainties in thermal margin analysis.
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 the CE thermal margin analysis and the thermal hydraulic characteristics of CE cores, 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.
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.
c P. L. McGill Vice President Conmercial Sworn to before me this ?]S "d'ay of Q2bC/Ylbbt,Icjp,
/)
/
m Notary Public
/('t^ (Y
/
Iit ?/(
9"l DAWN E. SANDER, NOTARY PUC'.10 State of Connecticut No. 613%
Commission Expires March 31,1986
e e
ENCLOSURE 2
l dP' AFFIDAVIT PURSUANT T0 10 CFR 2.790 l
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 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-184(S) - P, Revision 2 - P, Response to Questions on Documents Supporting SONGS 2 License Submittal.
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 Conmission'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.
i 1.
The information sought to be withheld from public disclosure are the sensitivity analysis results of the TORC /CE-1 methodology and the CETOP methodology as well as measurements and algorithim uncertainties used in the Reactor Protection System, which is owned and has been held in con-fidence by Combustion Engineering.
2.
The information consists of test data or other similar data 4
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 Comission 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 n1y 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.
?
w g
wp3.---, - - - - - -
---~ty
,+;y,e
-y
- - -,y-*----
m--g--m r--
s
m 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 hundreds of manhours of effort and tens of thousands of dollars. To the best of my knowledge and belief a competitor would have to undergo similar expense in generating equivalent information.
i c.
In order to acquire such information, a competitor would also require considerable time and inconvenience related to the analysis of the TORC /CE-1 and CETOP methodologies as well as development of the measurement and algorithim uncertainties used in the Reactor Protection System.
4 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 the sensitivity analysis results of the TORC /CE-1 methodology and the CETOP methodology as well as measurements and algorithim uncertainties used in the Reactor Protection System, 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.
j.
The ability of Combustion Engineering's competitors to utilize such information without similar expenditure of resources may enable them to sell at prices i
~ 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.
3 Further the deponent sayeth not.
.'l P. L. McGill Vice President Commercial Sworn to before me
.ay of Oe w h o, M /
this 7 CLL2M b
[4 Junn.)
flotary Public/J
/
CAREY J. WEN 7f1 NOTARY PUBLIC 4
Statt of Comettcut tio. 59352 Comm:ston Es;rres Varch 31, 1955
~
i I
J
o2,---amu
+ m
- a. 4 nsw--
_,La_ws a n.1au sm O.2an,,-4anos an,E --
a s-A-
-s.us-o a
+waa==+rua.
a--,e
--,a+-p-a a1.
m a,a.,-
1 i
i i.
f 4
i i
E N
h 4
3 ENCLOSURE 3 1
I J
h s
i 1
i w
4 i
f f,
b s
t 4
h i
s s
t w
f
=
i s
e a
s 5
,e i k r--, row - -.. -
.w,=w,---
..-em-----,,~,g
-.-wr-
- - -, - - - *. - -. ~. - -.. - -. - - - - - -
-- - -- - -r
a AFFIDAVIT PURSUANT T0 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. and San Diego Gas and Electric Co. for withholding this information.
The information for which proprietary treatment is sought is contained in the following document:
CEN-176(S)-P, Rev. 01, CPC/CEAC Systems Phase I Software Verification Test Report, November, 1981.
This document has been appropriately designated as proprietary.
I have personal knowledge of the criteria and procedures utilized by Combustion Engineering in designeting information as a trade secret, privileged or as confidential commercial or financial information.
Pursuant to the provisicn; of paragraph (b) (4) of Section 2.790 of the Commission's regulations, the following is furnished for consider 0 tion by the Commission in determining whether the information sought to be withheld from public disclosure, included in the above referenced ?;cument, should be withheld.
l 1.
The information sought to be withheld from public disclosure are the CPC/CEAC System Phase I Software Verification Test Hardware Configuration, Test Apparatus and Test results, 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 i
made pursuant to regulatory provisions or proprietary agreements which
{
provide for maintenance of the information in confidence.
e 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 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 Appal atus and Test results, 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 ia 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 expentes 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 j
Engineering's potential for obtaining or maintaining foreign licensees.
ll Further the deponent sayeth not.
2 _. _-. L '
- A.Edberer Director Nuclear Licensing Sworn to before me this /0 day of [)Cf#1b j/
ubt l - LUmt,_
Notary Publ,1c (/
6 l
CAREY J. WES7.EL. NOTARY PUBUC State of Connecticut No. 59962 Commission Expires March 31, 1985 i
i I
m,
---,-,a
t t
h t
.1 a
4 I
4
-7 EFCLOSURE 4 6
6
't 5
'f O
d i
i e
i f
.. - - +. -
,,.,-.e-
,-.-..c---
..,,,,.-----r..
- ~. -,.,
AFFIDAVIT PURSUANT T0 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 of 10 CFR 2.790 of the Commission's regulations and in conjunction with the application of Southern California Edison Co. for withholding this I
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, Revision 02, November, 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 in the above referenced document, should be withheld.
I i
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 Conmission 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.
R
. 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 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.
f.
In pricing Combustion Engineering's products and services, significant research, development, engineering, analytical, ranufacturing, 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.
I.L.kcGili
.Vice President Commercial Sworn to before me this #5 day af M>4wz'//t6 / FE-/
l/Dd S k&
Notary Public DAWN E. SANDER, NOTARY PUEllC State of Connecticut No. 61536 Commission Exp, ires March 31,1986
M O
h h
ENCLOSURE 5 P