ML13309B484

Forwards Proprietary CEN-291(S)-P. Response to NRC Questions on San Onofre Nuclear Generating Station Unit 2, Cycle 2. Proposed Units 2 & 3 Changes Should Be Reviewed to Support Unit 2 Restart.Encl Withheld (10CFR2.790)

ML13309B484
Person / Time
Site:	San Onofre
Issue date:	12/19/1984
From:	Medford M Southern California Edison Co
To:	Knighton G Office of Nuclear Reactor Regulation
Shared Package
ML13309B485	List: ML13309B484
References
NUDOCS 8412210222
Download: ML13309B484 (14)

Text

ACCESSION NBR:8412210222 DOC.DATE: 84/12/19 NOTARIZED: YES DOCKET #

FACIL:50 361 San Onofre aion, Unit 2, Southern Californ 05000361 50-362 San OnoeNuclear Station, Unit 3, Southern Californ 05000362 AUTHNAME AUTHOR AFFILIATION MEDFORD,M,0, Southern California Edison Co.

RECIP,NAME. RECIPIENT AFFILIATION KNIGHTONrGo. Licensing Branch 3

SUBJECT:

Forwards proprietary CEN-291(s)-P,. "Response to NRC Questions on San Onofre Nuclear Generating Station Unit 2, Cycle 2." Proposed Units 2 & 3 changes should be reviewed to support Unit 2 restart.Encl withheld (10CFR2.790),

DISTRIBUTION CODE: PA01D COPIES RECEIVED:LTRi ENCL . SIZE:.J.....L TITLE: ProPrietary Review Uistribution-Operating Reactor NOTES:J Hanchett icy PDR Documents, ELD Chandler icy. 05000361 OL:02/16/82 J Hanchett Icy POR Documents, ELD Chandler icy, 05000362 OL:11/15/82 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL NR 6BC 7 7 INTERNAL: 6 6 ELD/HS2 1 0 REG FILE4Wi 1 1 RGN5- 1 1 EXTERNAL: LPDR 1 0 NRC PDR 1 0 NTIS i 0 NOTES: 2 2

TOTAL NUMBER OF COPIES REQUIRED: LTTR 21 ENCL .17

Southern California Edison Company P. 0. BOX 800 2244 WALNUT GROVE AVENUE ROSEMEAD, CALIFORNIA 91770 M.O. MEDFORD TELEPHONE MANAGER, NUCLEAR LICENSING December 19, 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 Nos. 50-361 & 50-362 Responses to Questions on the Cycle 2 Proposed Technical Specification Changes and Statistical Combination of Uncertainty Reports San Onofre uclear Generating Station (SONGS)

Units 2 an,3 The purpose of this letter is to transmit responses (Enclosure 1) to questions received informally from the NRC staff on November 2 and November 20, 1984 pertaining to the SONGS Cycle 2 proposed Technical Specification changes and the Statistical Combination of Uncertainties Report. The responses to the questions were informally transmitted to the NRC staff during the period of November 16 to December 7, 1984. Since some of the responses contain proprietary information, SCE is providing both proprietary and nonproprietary versions of the responses. For completeness we have also included the responses to questions received informally from the NRC staff on October 25, 1984 which were previously submitted by SCE letter dated November 9, 1984.

Please find enclosed three (3)copies of the following proprietary Combustion Engineering document 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.

Enclosure 1 CEN-291(S)-P, Responses to NRC Questions on SONGS 2 Cycle 2, December 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:

8412210202 8412i9 PDR ADOCK 05000361 E

- __ PDR

Mr. G. W. Knighton December 19, 1984 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:

Enclosure 2 CEN-291(S)-NP, Responses to NRC Questions on SONGS 2 Cycle 2, December 1984.

SCE requests that the NRC complete its review of the proposed Technical Specifications changes for SONGS Units 2 and 3 in an expeditious manner in order to support San Onofre Unit 2 restart following the ongoing refueling outage.

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 1 Copy No. 000004 and Enclosure 2)

Y. (Gene) Hsii, NRC Core Performance Branch (to be opened by addressee only - Enclosure 1 Copy No. 000005 and Enclosure 2)

F. R. Huey, NRC Senior Resident Inspector (Enclosure 2 only)

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 of 10 CFR 2.790 of the Commission's regulations and in conunction 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-291(S)-P, "Response to NRC Questions on SONGS 2 Cycle 2" 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.

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1. The information sought to be withheld from public disclosure is the Core Protection Calculator System algorithms and corresponding setpoint 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, 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:

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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 man hours and millions 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 to develop the Core Protection Calculator System algorithms and corresponding setpoint methodology.

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 Core Protection Calculator System algorithms and corresponding setpoint methodology, 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.

P. L. McGill Vice President Commercial Sworn to before me this da of i

,N ary Publi LYDIA A. SMITH, NOTARY PUBLIC STATE OF CONNECTICUT No. 68542 COMMISSION EXPIRES MARCH 31, 1989

ENCLOSURE 1 C~'LAZco Th Cd December 19, 1984 Director, Office of Nuclear Reactor Regulation Attention: Mr. George W. Knighton, Branch Chief Licensing Branch No. 3 U. Nuclear Regulatory Comission Mashington, D.C. 20555 Gentlemen:

Subject:

Docket Vos. 50-361 & 50-362 Responses to questions on the Cycle 2 Proposed Technical Specification Changes and Statistical Combination of Uncertainty Sn Onofre Nuclear Generati(ngStation (SONGS)

Units 2and .3 The purpos of this letter is to transmit responses-(Enclosure 1) to uestles Voveber -20, received-afdreally 1984 pbertainlng to theree095Cycle theMRC staff on ovember 2 and 2 proposed Technical pecification changesand-the StatisticilCombinatoR of Uncertainties Report The responses tothe questins'ire info 113ltransmitted to the NRC W staff durting the perid of Wovembr1 to fDecembe7,. 1984. -Since some of the included the r-spont e i ferally froe the atC staff on Octber 25; 1984-t ~1~wre previously submitted by SCE letter daiid A ee _Cer1984.

9, on hichi the inforat W ay be witbbeld from public disclosure by the Coiso e dres@Aeiiil t considerations listed In 10CF 2.790(b) of the Commissoa'kregulations~

-a res)- tesponses to RC est n SN

...................... C

• c2&ew 1984. (Copy Mo 000001 0000 and 00003)

It is respectfully requested that the above 1nformation which proprietary to CE be withheld freo public Is disclosure in accordance mvi,,

10 CFR 2.790(b) of the C sion'S regulations. If you should questions concerateg the proprta here ith, please address these questions directly to:

.1..1SONG Wes at- of the material transmitted with have any

Sche-er

,c 1cea r L censing Co.n Eng ineerng 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 Enclosure 1 is also enclosed to'satisfy the requirements of proprietary information to the NRC: for transmittal of Enclosure.2 CEN-291(S)-NP, Responses to NRC Questions on SONGS 2 Cycle 2, December 1984.

SCE requests that the NRC complete its review Technical Specifications changes for-SONGS Units 2 and 3of the proposed manner in order to support San Onore Unit 2 restart following in an expeditious refueling outage. the ongoing If you have any questions or comments, please let me know.

Very truly yours, Enclosures cc: Narry Rood. NRC Project Manager (to be opened by addressee only Enclosure 1 Copy No. 000004 and Enclosure 2)

Y. (Gene) listi, NRC Core Performance Branch (to be opened by only - Enclosure 1 Copy No. 000005 and Enclosure 2) addressee F. R. Huey, NRC Senior Resident Inspector (Enclosure 2 only)

TO I CFR 2.790 CombustiC Lngineering, Inc.

St!ate of Connecticu-.)

County of Hartford SS.

1, 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 caustd 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 t Commission's regulations and in conunction 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-291(S)-P, "Response to NRC Ouestions on SONGS 2 Cycle 2" 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 informdtion.

Pursuant to the provisions of paragraph (b) (4) of Section 2.790 of the Commission's regulations, the following is furnished for considerdtion by the Commission in determining whether the information sought to be withheld from public disclosure, included in the above referenced document, should be withheld.

ht n' ode agy ni ' wd and has benr rel. in~ confidence~ by fa.u

':1~

Eni neerI g.

2. The information consists of test datd or other S ailar d'at concerning a process, method or component, the dpplicdtion of which results in a substantial competitive adVdntage to Combustion Engineerir.

3. The information is of a type customarily held in confidence by Combustion Engineering and not customarily disclosed to th-e public. Combustion Engineering has a rational basis for determining the types of information customarily held in confidence by it and, in thdt cnnnection, utilizes a syster to determine whEn and whether to hold certain types of information in confidence. The details of the aforementioned system were provi.n. 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 iN to be received in confidence by the Commission.

S. The information, to the best of my knowledge and belief, is not available in public sources, and any disclosure tn third parties has been made pursuant to regulatory provisions or proprietary agreements which provile for maintenance of the linformadtion In confidence.

6. Public disclosure of the information is likely to cause substantial harm to the competitive position of Combustion Engineering because:

. s neIduct is ranjfactu.red1 -ind So d by !..I water reacr compet1to s of Combustioo Engineering,

b. Development of this informdtion by C-F retquired thousdnds of mir hours and millions of dollars. To the best of my knowledge and belief d co'petitor would have to undergo similar expense in generating equivalent informat ion.

. In order to acquire such information, a competitor would dilso require considerable time and inconvenience to develop the Core Protection Calculator System algorithms and corresponding setpoint methodology.

d. The information required significant effor- 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 rarketing the product to which the informdtion is applicatble..

e. The information consists of the Core Protection Calculator System algorithms and corresponding setpoint methodology, the application of which provides a competitive economic advantage. The availability of such information to cometitors 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 anI 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

01

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l :Simi idr expnditurt- of resources Idy enable them to ref icting sIgnIfICantiy'-owter Costs.

9, Use of the information by competitors in the interndtiOnal ma rketplace would increase. their ability to Tdrket 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 obtdining or maintaining foreign licensees.

Further the deponent sayeth not.

P. L. McGill Vice President Commercial Sworn to before me this Aiday of ta 4 /9I"4

• ~ CCIdryar1 PI. ,'r