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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217P7111999-10-26026 October 1999 Informs That Licensee 990330 Response to GL 97-06 Provides Reasonable Assurance That Condition of Licensee Steam Generator Internals Is in Compliance with Current Licensing Bases for Plant ML20217K3571999-10-21021 October 1999 Discusses Use of SONGS as Generic Safety Issue 191 Ref Plant.Future Requests for Info & Addl Coordination Activities Be Handled Through D Evans of Organization.With Diskette ML20217K8541999-10-21021 October 1999 Forwards Revised Pages to ERDS Data Point Library,Per Requirements of 10CFR50,App E,Section VI.3.a.Described Unit 2 & 3 Changes for 2/3R7813 Were Completed on 990924 ML20217L9491999-10-21021 October 1999 Forwards SONGS Emergency Response Telephone Directory, for Oct-Dec 1999 ML20217J8631999-10-15015 October 1999 Forwards Insp Repts 50-361/99-12 & 50-362/99-12 on 990808- 0918.One Violation Identified Involving Inoperability of Emergency Diesel Generator in Excess of Allowed Outage Time ML20217E3221999-10-13013 October 1999 Forwards MORs for Sept 1999 for Songs,Units 2 & 3.No Challenges Were Noted to Psvs for Either Units 2 or 3 ML20217E7671999-10-12012 October 1999 Forwards Rev 62 to NRC Approved Aug 1983, Physical Security Plan,Songs,Units 1,2 & 3, IAW 10CFR50.54(p).Changes,as Described in Encls 1 & 2,do Not Reduce Effectiveness of Plan.Encl Withheld,Per 10CFR73.21 ML20217B5981999-10-0606 October 1999 Informs That Staff Concluded That All Requested Info for GL 98-01, Year 2000 Readiness in Us Nuclear Power Plants, Provided for San Onofre Nuclear Generating Station,Units 2 & 3 ML20216H8741999-09-29029 September 1999 Provides Requested Written Response to GL 99-02, Lab Testing of Nuclear-Grade Activated Charcoal. Lab Testing of Charcoal Adsorber Samples for Creacus & Pacu Satisfies Listed Requirements ML20216H8541999-09-29029 September 1999 Submits Encl Request for Relief from ASME Code,Section III Requirements in 10CFR50.55(a)(3) to Use Mechanical Nozzle Seal Assembly as Alternate ASME Code Replacement at SONGS, Units 2 & 3 for Period of Operation Beginning with Cycle 11 ML20216J2631999-09-28028 September 1999 Forwards Copy of Final Accident Sequence Precursor (ASP) Analysis of Operational Event at Songs,Unit 2,reported in LER 361/98-003 ML20212H4461999-09-28028 September 1999 Forwards Suppl Info,As Discussed with NRC During 990812 Telcon,To Support Risk Informed Inservice Testing & GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs ML20212G5611999-09-24024 September 1999 Informs NRC That SCE Remains Committed to Performing Eddy Current Examinations of 100% of Reactor Vessel Head Penetrations at Songs,Unit 3.Exams Will Not Be Performed During Cycle 11 RFO 05000361/LER-1999-005, Forwards 30-day follow-up LER 99-005-00,describing Loss of Physical Train Separation in Control Room.Any Actions Listed Intended to Ensure Continued Compliance with Existing Commitments1999-09-23023 September 1999 Forwards 30-day follow-up LER 99-005-00,describing Loss of Physical Train Separation in Control Room.Any Actions Listed Intended to Ensure Continued Compliance with Existing Commitments ML20212D9921999-09-16016 September 1999 Informs That on 990818,NRC Staff Completed Midcycle PPR of San Onofre.Nrc Plan to Conduct Core Insps & One Safety Issues Evaluation of MOVs at Facility Over Next 7 Months. Details of Insp Plan Through March 2000 Encl ML20212A4061999-09-14014 September 1999 Forwards Revised Pages to ERDS Data Point Library.Described Unit 2 Changes for 2R7817 & 2R7828 Were Completed on 990818 & Unit 3 Change for 3R7828 Was Completed on 990903 ML20216E6031999-09-10010 September 1999 Provides Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams, Dtd 990820.Schedule Shown on Attachment 1, Operator Licensing Exam Data, Provides Util Best Estimate Through Cy 2003 ML20217B9011999-09-10010 September 1999 Responds to Which Addressed Concerns Re Y2K Issue & Stockpiling of Potassium Iodide (Ki) Tablets by Informing That San Onofre Nuclear Station Already Completed All Work Required to Be Ready for Y2K Transition ML20211K4191999-09-0303 September 1999 Final Response to FOIA Request for Documents.Documents Listed in App a Being Withheld in Part (Ref FOIA Exemptions 5 & 7) ML20211N0261999-09-0303 September 1999 Forwards Exemption from Certain Requirements of 10CFR50.44 & 10CFR50,app A,General Design Criterion 41 in Response to Util Request of 980910,as Supplemented 990719 & SER 05000206/LER-1999-001, Forwards LER 99-001-00 for Occurrence Re Unattended Security Weapon Inside Protected Area.Single Rept for Unit 1 Is Being Submitted,Iaw NUREG-1022,Rev 1,since Condition Involves Shared Sys & Is Applicable to Units 1,2 & 31999-08-31031 August 1999 Forwards LER 99-001-00 for Occurrence Re Unattended Security Weapon Inside Protected Area.Single Rept for Unit 1 Is Being Submitted,Iaw NUREG-1022,Rev 1,since Condition Involves Shared Sys & Is Applicable to Units 1,2 & 3 ML20211H3321999-08-30030 August 1999 Discusses 1999 Emergency Preparedness Exercise Extent of Play & Objectives.Based on Review,Nrc Has Determined That Exercise Extent of Play & Objectives Are Appropriate to Meet Emergency Plan Requirements ML20211J7151999-08-27027 August 1999 Forwards Insp Repts 50-361/99-09 & 50-362/99-09 on 990627- 0807.Two Violations Being Treated as non-cited Violations ML20211H8561999-08-23023 August 1999 Forwards SE Accepting Licensee 970625 Requests for Relief RR-E-2-03 - RR-E-2-04 from Exam Requirements of Applicable ASME Code,Section Xi,For First Containment ISI Interval ML20211J5821999-08-23023 August 1999 Corrected Copy of ,Changing Application Date from 970625 to 990625.Ltr Forwarded SE Accepting Licensee 990625 Requests for Relief RR-E-2-03 - RR-E-2-08 from Exam Requirements of Applicable ASME Code,Section XI as Listed ML20210V4271999-08-16016 August 1999 Forwards Proprietary Certified Renewal Applications for SROs a Harkness,R Grabo & T Vogt & RO D Carter,Submitted on Facsimile Form NRC-398 & Certified NRC Form 396.Encls Withheld ML20210R6681999-08-13013 August 1999 Forwards Response to NRC RAI Re SCE License Amend Applications 173 & 159 for Songs,Units 2 & 3,proposed Change Number 485,which Requests Addition of SR to TS 3.3.9, CR Isolation Signal ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210Q6451999-08-12012 August 1999 Forwards Monthly Operating Repts for July 1999 for SONGS, Units 2 & 3,per TS 5.7.1.4.There Were No Challenges to Pressurizer Safety Valves for Either Units ML20210P5711999-08-11011 August 1999 Forwards Amend Application Number 189 for License NPF-10 & Amend Application Number 174 to License NPF-15,replacing Analytical Limits Currently Specified as Acceptance Criteria with Allowable Values,Per Encl Calculation E4C-098 ML20210P4681999-08-11011 August 1999 Forwards COLR for Cycle 10 for Songs,Units 2 & 3,IAW TS Section 5.7.1.5.d, Colr. Changes to COLR Parameters Have Been Conducted IAW Approved COLR Methodologies & All Applicable Limits of Safety Analysis Were Met ML20210P6221999-08-10010 August 1999 Forwards Replacement Pages for Attachments E & F of Amend Application Numbers 168 & 154 for Songs,Units 2 & 3.Pages Are Provided to Correct Errors to Pagination & Headings in 970618 Submittal ML20210N9721999-08-10010 August 1999 Responds to Appeal of FOIA Request for Documents Re Osre Issue.No Osre Visit Scheduled for Sept 1996 at Plant,Per 990722 Telcon.V Dricks,In Ofc of Public Affairs Should Be Contacted Re Osre Issue ML20210N0901999-08-0909 August 1999 Informs That 990312 Application Requested Amends to Licenses DPR-13,NPF-10 & NPF-15,respectively,being Treated as Withdrawn.Proposed Change Would Have Modified Facility TSs Pertaining to SONGS Physical Security Plan ML20210N5051999-08-0909 August 1999 Forwards Cycle 10 Update to TS Bases,Which Have Been Revised Between 980101-990630,per 10CFR50.71(e) 05000361/LER-1999-004, Forwards LER 99-004-00 Re Automatic Tgis Actuation.Event Affected Units 2 & 3 Equally Because Tgis Is Shared Sys. Single Rept Is Being Provided for Unit 2 IAW NUREG-1022, Rev 1.No New Commitments Are Contained in Encl1999-08-0606 August 1999 Forwards LER 99-004-00 Re Automatic Tgis Actuation.Event Affected Units 2 & 3 Equally Because Tgis Is Shared Sys. Single Rept Is Being Provided for Unit 2 IAW NUREG-1022, Rev 1.No New Commitments Are Contained in Encl ML20210L2311999-08-0505 August 1999 Forwards ISI Summary Rept,Including Owners Repts of Repairs & Replacements,For Songs,Unit 3.Rept Covers 970916 Through 990509,date Unit 3 Returned to Service Following Cycle 10 Refueling Outage ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML20216D9671999-07-29029 July 1999 Provides Response to RAI to Support Proposed TS Change 460 Re Containment Isolation Valve Completion Time for SONGS, Units 2 & 3.Rev 3 to Abnormal Operating Instruction SO23-13-14, Reactor Coolant Leak, Encl ML20210C1821999-07-22022 July 1999 Forwards Rept Providing Results of Insp of Eggcrate Tube Supports Done on Secondary Side of Sgs,Using Remote Controlled Visual Equipment ML20210B2451999-07-21021 July 1999 Forwards Response to NRC 990615 RAI Re GL 95-07, Pressure Locking & Thermal Bldg of SR Power-Operated Gate Valves, for Songs,Units 2 & 3 ML20210B9891999-07-20020 July 1999 Ack Receipt of Transmitting Plant Emergency Plan Implementing Procedure SO123-VIII-1, Recognition & Classification of Emergencies ML20209J5241999-07-19019 July 1999 Provides Clarification of Util Intentions Re Disposition of Systems for Which Exemption & TS Changes Were Requested in Licensee .Deferment of Action Re Hydrogen Monitors,Encl ML20210N2881999-07-19019 July 1999 Forwards Rev 61 to Physical Security Plan,Rev 21 to Safeguards Contingency Plan & Rev 20 to Security Force Training & Qualification Plan,Per 10CFR50.54(p),for Plant. Screening Criteria Forms Encl.Plans Withheld ML20210A2911999-07-19019 July 1999 Submits Withdrawal Request Submitted by Ltr Dtd 990312, Requesting NRC Approval of Revs to Physical Security Plan & Safeguards Contingency Plan Tactical Response Plan ML20209G3421999-07-15015 July 1999 Forwards Table of 16 Affected Tube Locations in SG E089, Discovered During Cycle 10 Outage Insp,Which Were Probably Not Examined by Bobbin During Cycle Outage Insp ML20209D8051999-07-12012 July 1999 Discusses Licensee Response to RAI Re GL 92-01,Rev 1,Suppl 1, Rc Structural Integrity, Issue on 950519 to Plant. NRC Revised Info in Reactor Vessel Integrity Database & Is Releasing It as Rvid Version 2 ML20209F5681999-07-0909 July 1999 Forwards Insp Repts 50-361/99-08 & 50-362/99-08 on 990516- 0626.One Violation Identified & Being Treated as Noncited Violation,Consistent with App C of Enforcement Policy ML20209C1571999-07-0202 July 1999 Forwards Response to NRC RAI Re SCE Submittal Dtd 980710,re GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions ML20196K6721999-07-0202 July 1999 Discusses 990628 Meeting Conducted in Region IV Office Re Status of San Onofre Nuclear Generating Station Emergency Preparedness Program.List of Attendees & Licensee Presentation Encl 1999-09-03
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217L9491999-10-21021 October 1999 Forwards SONGS Emergency Response Telephone Directory, for Oct-Dec 1999 ML20217K3571999-10-21021 October 1999 Discusses Use of SONGS as Generic Safety Issue 191 Ref Plant.Future Requests for Info & Addl Coordination Activities Be Handled Through D Evans of Organization.With Diskette ML20217K8541999-10-21021 October 1999 Forwards Revised Pages to ERDS Data Point Library,Per Requirements of 10CFR50,App E,Section VI.3.a.Described Unit 2 & 3 Changes for 2/3R7813 Were Completed on 990924 ML20217E3221999-10-13013 October 1999 Forwards MORs for Sept 1999 for Songs,Units 2 & 3.No Challenges Were Noted to Psvs for Either Units 2 or 3 ML20217E7671999-10-12012 October 1999 Forwards Rev 62 to NRC Approved Aug 1983, Physical Security Plan,Songs,Units 1,2 & 3, IAW 10CFR50.54(p).Changes,as Described in Encls 1 & 2,do Not Reduce Effectiveness of Plan.Encl Withheld,Per 10CFR73.21 ML20216H8741999-09-29029 September 1999 Provides Requested Written Response to GL 99-02, Lab Testing of Nuclear-Grade Activated Charcoal. Lab Testing of Charcoal Adsorber Samples for Creacus & Pacu Satisfies Listed Requirements ML20216H8541999-09-29029 September 1999 Submits Encl Request for Relief from ASME Code,Section III Requirements in 10CFR50.55(a)(3) to Use Mechanical Nozzle Seal Assembly as Alternate ASME Code Replacement at SONGS, Units 2 & 3 for Period of Operation Beginning with Cycle 11 ML20212H4461999-09-28028 September 1999 Forwards Suppl Info,As Discussed with NRC During 990812 Telcon,To Support Risk Informed Inservice Testing & GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs ML20212G5611999-09-24024 September 1999 Informs NRC That SCE Remains Committed to Performing Eddy Current Examinations of 100% of Reactor Vessel Head Penetrations at Songs,Unit 3.Exams Will Not Be Performed During Cycle 11 RFO 05000361/LER-1999-005, Forwards 30-day follow-up LER 99-005-00,describing Loss of Physical Train Separation in Control Room.Any Actions Listed Intended to Ensure Continued Compliance with Existing Commitments1999-09-23023 September 1999 Forwards 30-day follow-up LER 99-005-00,describing Loss of Physical Train Separation in Control Room.Any Actions Listed Intended to Ensure Continued Compliance with Existing Commitments ML20212A4061999-09-14014 September 1999 Forwards Revised Pages to ERDS Data Point Library.Described Unit 2 Changes for 2R7817 & 2R7828 Were Completed on 990818 & Unit 3 Change for 3R7828 Was Completed on 990903 ML20216E6031999-09-10010 September 1999 Provides Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams, Dtd 990820.Schedule Shown on Attachment 1, Operator Licensing Exam Data, Provides Util Best Estimate Through Cy 2003 05000206/LER-1999-001, Forwards LER 99-001-00 for Occurrence Re Unattended Security Weapon Inside Protected Area.Single Rept for Unit 1 Is Being Submitted,Iaw NUREG-1022,Rev 1,since Condition Involves Shared Sys & Is Applicable to Units 1,2 & 31999-08-31031 August 1999 Forwards LER 99-001-00 for Occurrence Re Unattended Security Weapon Inside Protected Area.Single Rept for Unit 1 Is Being Submitted,Iaw NUREG-1022,Rev 1,since Condition Involves Shared Sys & Is Applicable to Units 1,2 & 3 ML20210V4271999-08-16016 August 1999 Forwards Proprietary Certified Renewal Applications for SROs a Harkness,R Grabo & T Vogt & RO D Carter,Submitted on Facsimile Form NRC-398 & Certified NRC Form 396.Encls Withheld ML20210R6681999-08-13013 August 1999 Forwards Response to NRC RAI Re SCE License Amend Applications 173 & 159 for Songs,Units 2 & 3,proposed Change Number 485,which Requests Addition of SR to TS 3.3.9, CR Isolation Signal ML20210Q6451999-08-12012 August 1999 Forwards Monthly Operating Repts for July 1999 for SONGS, Units 2 & 3,per TS 5.7.1.4.There Were No Challenges to Pressurizer Safety Valves for Either Units ML20210P5711999-08-11011 August 1999 Forwards Amend Application Number 189 for License NPF-10 & Amend Application Number 174 to License NPF-15,replacing Analytical Limits Currently Specified as Acceptance Criteria with Allowable Values,Per Encl Calculation E4C-098 ML20210P4681999-08-11011 August 1999 Forwards COLR for Cycle 10 for Songs,Units 2 & 3,IAW TS Section 5.7.1.5.d, Colr. Changes to COLR Parameters Have Been Conducted IAW Approved COLR Methodologies & All Applicable Limits of Safety Analysis Were Met ML20210P6221999-08-10010 August 1999 Forwards Replacement Pages for Attachments E & F of Amend Application Numbers 168 & 154 for Songs,Units 2 & 3.Pages Are Provided to Correct Errors to Pagination & Headings in 970618 Submittal ML20210N5051999-08-0909 August 1999 Forwards Cycle 10 Update to TS Bases,Which Have Been Revised Between 980101-990630,per 10CFR50.71(e) 05000361/LER-1999-004, Forwards LER 99-004-00 Re Automatic Tgis Actuation.Event Affected Units 2 & 3 Equally Because Tgis Is Shared Sys. Single Rept Is Being Provided for Unit 2 IAW NUREG-1022, Rev 1.No New Commitments Are Contained in Encl1999-08-0606 August 1999 Forwards LER 99-004-00 Re Automatic Tgis Actuation.Event Affected Units 2 & 3 Equally Because Tgis Is Shared Sys. Single Rept Is Being Provided for Unit 2 IAW NUREG-1022, Rev 1.No New Commitments Are Contained in Encl ML20210L2311999-08-0505 August 1999 Forwards ISI Summary Rept,Including Owners Repts of Repairs & Replacements,For Songs,Unit 3.Rept Covers 970916 Through 990509,date Unit 3 Returned to Service Following Cycle 10 Refueling Outage ML20216D9671999-07-29029 July 1999 Provides Response to RAI to Support Proposed TS Change 460 Re Containment Isolation Valve Completion Time for SONGS, Units 2 & 3.Rev 3 to Abnormal Operating Instruction SO23-13-14, Reactor Coolant Leak, Encl ML20210C1821999-07-22022 July 1999 Forwards Rept Providing Results of Insp of Eggcrate Tube Supports Done on Secondary Side of Sgs,Using Remote Controlled Visual Equipment ML20210B2451999-07-21021 July 1999 Forwards Response to NRC 990615 RAI Re GL 95-07, Pressure Locking & Thermal Bldg of SR Power-Operated Gate Valves, for Songs,Units 2 & 3 ML20210A2911999-07-19019 July 1999 Submits Withdrawal Request Submitted by Ltr Dtd 990312, Requesting NRC Approval of Revs to Physical Security Plan & Safeguards Contingency Plan Tactical Response Plan ML20210N2881999-07-19019 July 1999 Forwards Rev 61 to Physical Security Plan,Rev 21 to Safeguards Contingency Plan & Rev 20 to Security Force Training & Qualification Plan,Per 10CFR50.54(p),for Plant. Screening Criteria Forms Encl.Plans Withheld ML20209J5241999-07-19019 July 1999 Provides Clarification of Util Intentions Re Disposition of Systems for Which Exemption & TS Changes Were Requested in Licensee .Deferment of Action Re Hydrogen Monitors,Encl ML20209G3421999-07-15015 July 1999 Forwards Table of 16 Affected Tube Locations in SG E089, Discovered During Cycle 10 Outage Insp,Which Were Probably Not Examined by Bobbin During Cycle Outage Insp ML20209C1571999-07-0202 July 1999 Forwards Response to NRC RAI Re SCE Submittal Dtd 980710,re GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions ML20210N9871999-07-0101 July 1999 Appeals Denial of Documents Re Sept 1996 Osre for San Onofre Nuclear Generating Station.Requests Copies of Sept 1996 Osre Rept & Any More Recent Osre Repts ML20209B3571999-06-28028 June 1999 Submits Response to GL 98-01,Suppl 1 Y2K Readiness of Computer Sys at Nuclear Power Plants. GL 98-01 Requested Response on Status of Facility Y2K Readiness by 990701. Disclosure Encl ML20209B4831999-06-25025 June 1999 Requests NRC Approval of Six Relief Requests from ASME Code Requirement for Containment ISI Exams.Six Relief Requests, Provided as Enclosures 1-6,are as Listed ML20196A9801999-06-17017 June 1999 Responds to NRC 990420 RAI Re Proposed risk-informed Inservice Testing & GL 96-05 Programs at Songs,Units 2 & 3. Revised Pages to risk-informed Inservice Testing Program, Encl ML20195G8091999-06-14014 June 1999 Forwards Response to RAI Made During 990511 Telcon Re LARs 184 & 170 for SONGS Units 2 & 3.Amend Applications Proposed Restriction on Operation with Channel of RAS or Efas in Tripped Condition ML20195K4201999-06-11011 June 1999 Forwards LERs 99-003-00 & 99-004-00 Re Manual Esfas (Reactor Trips) Due to Problems with Main Feedwater Control.Two Events Are Being Reported Separately Because Actual Causes Are Considered Different & Independent of Each Other ML20195H1561999-06-10010 June 1999 Forwards MORs for May 1999 for Songs,Units 2 & 3.There Were No Challenges to Pressurizer Safety Valves for Either Unit 2 & 3 ML20195E4981999-06-0808 June 1999 Forwards Application for Amends 188 & 173 to Licenses NPF-10 & NPF-15 for SONGS Units 2 & 3,respectively.Amends Would Revise TS 3.5.2,3.1.9,3.7.1 & 5.1.7.5 Re Small Break LOCA Charging Flow & Main Steam Safety Valve Setpoints ML20196L3191999-05-24024 May 1999 Forwards ISI Summary Rept,Including Owners Repts of Repairs & Replacements for Songs,Unit 2.Rept Covers Period of 970916-990226 ML20207A3831999-05-24024 May 1999 Responds to NRC 990326 RAI on DG Srs.Proposed to Add Listed Sentence to TS Bases for SRs 3.8.1.7,3.8.1.12 & 3.8.1.15,as Result of Discussion with NRC During 990427 Telcon ML20211K4261999-05-18018 May 1999 FOIA Request for Documents Re San Onofre OI Repts 4-98-041, 4-98-043 & 4-98-045 ML20206S7161999-05-17017 May 1999 Forwards MORs for Apr 1999 for Songs,Units 2 & 3.There Were No Challenges to Pressurizer Safety Valves for Either Unit 2 or 3 ML20206N4711999-05-13013 May 1999 Provides Info Requested by NRC Re Reduced Pressurizer Water Vol Change Amends Application 172 & 158 for Songs,Units 2 & 3,respectively.Proposed Change Will Reduce Pressurizer Water Level Required for Operability ML20206M7791999-05-13013 May 1999 Informs NRC of Changes Being Made to Emergency Response Data Sys (ERDS) at SONGS Unit 3.Revised Page to ERDS Data Point Library Is Provided in Encl ML20206K6891999-05-11011 May 1999 Forwards Approved Amends to NPDES Permits CA0108073,Order 94-49 & CA0108181,Order 94-50 & State Water Resources Board Resolution ML20206M0681999-05-10010 May 1999 Submits Correction to Info Contained in Licensee to NRC Re Proposed TS Change Number NPF-10/15-475.Stated Info Was Incorrect in That Overtime Provisions Were Not Contained in TR at Time of Was Submitted ML20206H0451999-05-0404 May 1999 Forwards Annual Financial Repts for Listed Licensees of Songs,Units 1,2 & 3.Each Rept Includes Appropriate Certified Financial Statement Required by 10CFR50.71(b) ML20206H1931999-05-0303 May 1999 Forwards 1998 Annual Rept, for SONGS Units 2 & 3 & PVNGS Units 1,2 & 3.SCEs Form 10K Annual Rept to Securites & Exchange Commission for Fiscal Yr Ending 981231,encl ML20206C5151999-04-29029 April 1999 Forwards 1998 Radiological Environ Operating Rept for Songs,Units 1,2 & 3. Annual Radiological Environ Operating Rept Covers Operation of Songs,Units 1,2 & 3 During CY98 & Includes Summaries Interpretations & Analysis of Trends ML20206E5851999-04-29029 April 1999 Forwards Annual Radioactive Effluent Release Rept for 1998 for SONGS Units 1,2 & 3. Also Encl Are Rev 13 to Unit 1 ODCM & Rev 31 to Units 2 & 3 Odcm 1999-09-29
[Table view] Category:UTILITY TO NRC
MONTHYEARML20059C1071990-08-24024 August 1990 Forwards Addenda 10-1A,10-1B & 10-1C to Physical Security Plan.Encls Withheld (Ref 10CFR73.21) ML20059E6951990-08-24024 August 1990 Forwards Rev 30 to Physical Security Plan.Rev Withheld (Ref 10CFR73.21) ML20059B8861990-08-22022 August 1990 Advises That Dl Hill Employment W/Util Terminated,Effective 900817.Operator License OP-50333 Expired ML13302B3411990-08-21021 August 1990 Responds to NRC Bulletin 88-010 Re Nonconforming molded-case Circuit Breakers (Mccbs).Affected MCCBs Purchased for Use in safety-related Applications,Including MCCBs Used W/Motor Controllers.Outage Rept Encl,Per 890330 Ltr ML20064A2161990-08-16016 August 1990 Responds to NRC Re Violations Noted in Insp Repts 50-361/90-16 & 50-362/90-16.Reply to Notice of Violation Not Required Due to Sufficient Info Provided in ,Per 900807 Discussion W/R Huey ML13309A9211990-08-14014 August 1990 Forwards Monthly Operating Repts for Jul 1990 for San Onofre Units 2 & 3,revised Unit 2 Monthly Operating Rept for June 1990 & Rev 22 to ODCM ML20058Q2961990-08-14014 August 1990 Forwards Util & June 1990 NPDES Monitoring Rept. W/O Rept ML20058N0371990-08-0909 August 1990 Advises That on 900713,new Land Use Located W/Calculated Dose Greater than Value Currently Calculated.New Location Results in Annual Dose Increase of 27% for Units 2 & 3 & 39% Increase for Unit 1 ML20056A1781990-08-0202 August 1990 Discusses Review of Possibility of Accelerating Schedule for Performing & Submitting Results of Individual Plant Exams for Units 1,2 & 3.Util Believes That Submittal Schedule for Unit 1 Can Be Accelerated to 920102 ML18041A2221990-07-31031 July 1990 Responds to NRC 900518 Ltr Re Violations Noted in Insp Repts 50-206/90-10,50-361/90-10 & 50-362/90-10.Corrective Action: computer-based Mgt Sys Will Be Developed to Permit Incoming Revised Info to Be Matched W/Documents Requiring Review ML20055H9641990-07-27027 July 1990 Responds to NRC Re Violations Noted During Special Safety Sys Functional Insp on 891030-1130.Corrective Action:Util Will Review & Revise Operating & Calibr Procedures by 901031 ML20055H5731990-07-24024 July 1990 Provides Notification of Completion of Installation of Backup Nitrogen Sys Isolation Check Valves & Test Connections at Facility ML20055H2631990-07-23023 July 1990 Discusses Model 3RE-7870 Not Being Declared Operable Due to Lack of Process Flow.Monitor Failed on 900708.Caused by Moisture Intrusion Into Housing.All Affected Components Repaired or Replaced ML20055F1901990-07-0909 July 1990 Informs That Ej Schoonover Employment W/Util Terminated, Effective 900629 ML20044A4121990-06-27027 June 1990 Requests Approval of Use of Plugs Fabricated of nickel-chromiun-iron Uns N-06690 Matl to Plug Tubes in Plant Steam Generators.Change to Use Alloy 690 Tube Plugs Results from Matl Corrosion Consideration ML20056A8841990-06-25025 June 1990 Responds to NRC Forwarding Insp Repts 50-206/90-10,50-361/90-10 & 50-362/90-10.Results of Review of Awareness & Response to Industry Check Valve Concerns & Evaluation of Need to Establish Dedicated Program Provided ML20043H7851990-06-19019 June 1990 Informs That Jl Mullins Employment W/Util Terminated Effective 900608.Operator License OP-50089-2 Expired ML20043H5101990-06-19019 June 1990 Informs That Wk Giffrow Employment W/Util Terminated. Operator License OP-50050-2 Expired ML13304A4861990-06-0404 June 1990 Forwards Evaluation of Unisolable Piping from RCS W/Potential for Leakage Induced Thermal Stresses in Response to NRC Bulletin 88-008 SONGS 2 & 3, in Response to Request ML20043B4911990-05-22022 May 1990 Submits Rept:On 900507,eddy Current Insp of Steam Generator Tubing Completed.Of 2,106 Tubes Inspected in Steam Generator E-088 No Tubes Found Defective.One Tube in Steam Generator E-089 Found Defective & Plugged ML20043B1411990-05-17017 May 1990 Informs That Senior Reactor Operator License No Longer Needed for JW Ryder,Effective 900425.License SOP-50288 Expired on 900425 ML13309A9151990-05-14014 May 1990 Forwards Monthly Operating Repts for Apr 1990 for San Onofre Nuclear Generating Station Units 2 & 3 ML20043A0051990-05-0404 May 1990 Informs of Expiration of WR Seiler Senior Reactor Operator License,Effective 900502 ML20042G6531990-05-0303 May 1990 Forwards Addendum 10-1B to Physical Security Plan.Encl Withheld (Ref 10CFR73.21) ML20042F7101990-05-0202 May 1990 Informs That Gb Swift Transferred to Position Not Requiring Operator License,Effective 900423 & License Expired,Per 10CFR55.55(a) ML20012E8341990-03-29029 March 1990 Advises That Reactor Operator License OP-50072-2 Expired on 900312 & No Longer Needed ML13303B1981990-03-12012 March 1990 Forwards Table Re FSAR Chapter 15 Design Basis Event & Rev 0 to M-89047, Instrument Drift Study San Onofre Nuclear Generating Station Units 2 & 3, in Support of Proposed Change Notices 275 & 280,per NRC Request ML20012B6701990-03-12012 March 1990 Advises That Response to SSFI Repts 50-361/89-200 & 50-362/89-200 Will Be Provided by 900412 Due to Unexpected Diversion of Resources to Address Other Issues Such as Trip of Unit 3 on 900223 & Safety Valve Evaluations ML13304A4591990-03-0707 March 1990 Forwards Rev 0 to M 86420, Spurious Actuation Evaluation Component Cooling Water Sys - Operability Assessment. ML20012B8061990-03-0505 March 1990 Responds to NRC 900205 Ltr Re Violations Noted in Insp Repts 50-361/89-33 & 50-362/89-33.Corrective Actions:Action Taken W/Responsible Supervisor to Ensure That Health Physics Technician Overtime Controlled & Authorized ML13304A4551990-02-16016 February 1990 Forwards Rev 6 to Spent Fuel Pool Reracking Licensing Rept. Encl 1 Lists Summary of Rev 6 Changes & Encl 2 Lists Changes (Insert Pages) to Rev 5 Reracking Licensing Rept ML20006E8801990-02-14014 February 1990 Informs That Dl Daily Employment W/Util Terminated Effective 900209.License SOP-50229-1 Expired ML20006D9661990-02-0707 February 1990 Advises That Listed Individuals No Longer Require Senior Reactor Operator Licenses,Effective on 900117 ML20011E5041990-02-0707 February 1990 Informs of Termination of Rl Sprague Employment W/Util, Effective 900125 ML13303B1871990-01-18018 January 1990 Forwards Rev 5 to Amend Applications 64 & 78 to Licenses NPF-10 & NPF-15,respectively,re Spent Fuel Pool Reracking. New Racks Will Increase Number of Storage Locations in Each Spent Fuel Pool from 800 to 1,542 Elements ML20011F0381990-01-18018 January 1990 Documents Commitment Re Impact of outage-related Overtime, Based on Interview at Site on 900112.Util Will Not Schedule Heavy Use of Overtime for Duration of Refueling Outage for Personnel Addressed by Tech Specs Assigned to Unit ML13303B1791990-01-0808 January 1990 Forwards Amend Applications 70 & 56 to Licenses NPF-10 & NPF-15,respectively,revising Tech Spec 3/4.3.3.5, Remote Shutdown to Increase Interval for Refueling Surveillance Tests to Nominally 24 Months & Max of 30 Months ML13303B1841990-01-0808 January 1990 Forwards Amend Applications 69 & 55 to Licenses NPF-10 & NPF-15,respectively,consisting of Proposed Tech Spec Change NPF-10/15-275 Re Refueling Interval Surveillances ML19332F0631989-12-0505 December 1989 Informs of Termination of MP Mcdonnell Employment W/Util, Effective 891128 ML19332F1181989-12-0505 December 1989 Provides Schedule for Installation of Diverse Emergency Feedwater Actuation Sys at Plant,Per 890808 Commitment. Schedule for Significant Conceptual Engineering Tasks Completed & Major Tasks to Be Completed Summarized ML20005D7331989-12-0505 December 1989 Advises That RW Dougherty Transferred to Position within Util Which Does Not Require Reactor Operator License, Effective 891204.License OP-50193-1 Expired ML19332D8731989-11-27027 November 1989 Responds to NRC 891027 Ltr Re Violations Noted in Insp Repts 50-361/89-24 & 50-362/89-24.Corrective Actions:Temporary Cables Passing Through Doorway Removed & Maint Order Revised & Reissued to Incorporate Creacus Boundary Requirements ML19332D3261989-11-20020 November 1989 Responds to NRC 891027 Ltr Re Violations Noted in Insp Repts 50-361/89-24 & 50-362/89-24.Corrective Actions:Requirements of Tech Spec 3.0.3 Applied & Applicability Reinforced W/Appropriate Personnel ML19332F4321989-11-15015 November 1989 Forwards Addendums 10-1B & 10-1C to Physical Security Plan. Encl Withheld (Ref 10CFR73.21) ML13304A4381989-11-0909 November 1989 Forwards Proprietary WNEP-8926 & Nonproprietary WNEP-8930, San Onofre Units 2 & 3 Fuel Rack Seismic Analysis for Final Pool Layout. Util Application for Withholding Ltr, CAW-89-104,Proprietary Info Notice & Affidavit Also Encl ML13303B1621989-11-0202 November 1989 Forwards Rev 4 to Amend Applications 78 & 64 to Licenses NPF-10 & NPF-15,respectively,re Spent Fuel Reracking & Proposed Tech Spec on Request from Staff Requiring Min Spent Fuel Pool Boron Concentration ML19325D9781989-10-19019 October 1989 Discusses Completion of Steam Generator Tubing Insp.Total of 4,316 Tubes Inspected & 62 Tubes Removed from Svc by Mechanical Plugging.Insp Significantly Exceeded Amount of Tubing Required to Be Inspected ML19325D1881989-10-0606 October 1989 Informs of Termination of Employment of RA Barnes as Licensed Senior Reactor Operator on 890929 ML20248G6821989-09-29029 September 1989 Advises That Wj Kirkpatrick Employment Terminated on 890922 & License Expired ML20248H1101989-09-29029 September 1989 Advises That Wc Kingsley Employment W/Util Terminated, Effective 890915 1990-08-09
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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.
-2
- 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:
-3
- 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
-4
- 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