ML20100J137

Forwards Proprietary & Nonproprietary C-E Repts Re Core Protection Calculator Methodology Changes for Cycle 5, in Support of 850128 Tech Spec Change.Affidavit Encl. Proprietary Repts Withheld (Ref 10CFR2.790)

ML20100J137
Person / Time
Site:	Arkansas Nuclear
Issue date:	03/29/1985
From:	Tison Campbell ARKANSAS POWER & LIGHT CO.
To:	John Miller Office of Nuclear Reactor Regulation
Shared Package
ML19269B331	List: ML20100J137 ML20100J155 ML20100J180 ML20100J199 ML20100J222
References
2CAN038508, 2CAN38508, NUDOCS 8504100370
Download: ML20100J137 (7)

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ARKANSAS POWER & LIGHT COMPANY FIRST COMMERCIAL BUILDING /P.O. BOX 551/ilTTLE ROCK. ARKANSAS 722o3/(501) 371-7901 March 29, 1985 T. GENE CAMPBELL Vice President Nuclear Operations l

2CAN038508 Director of Nuclear Reactor Regulation ATTN: Mr. James R. Miller, Chief Operating Reactors Branch #3 Division of Licensing U. S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

Arkansas Nuclear One - Unit 2 Docket No. 50-368 License No. NPF-6 CPC Methodology Changes for Cycle 5 Additional Information Submittal Gentlemen:

Attached for your review are the following Combustion Engineering (CE) documents for use in conjunction with the ANO-2 Cycle 5 CPC software update.

A description of the software update was contained in CEN-288(A), submitted by our letter 2CAN118402 dated November 9, 1984. This information is also in support of the Technical Specification change request submitted by our letter 2CAN018505 dated January 28, 1985.

• CEN-296(A), "ANO-2 CPC and CEAC Data Base Listing", March 1985.

• CEN-298(A), "AN0-2 CPC System Phase I Design Qualification Test Report", March 1985.

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• CEN-162(A), "AN0-2 CPC/CEAC System Phase II Software Verification Test Report", March 1985.

• Enclosure IP to A-CE-R-92, " Typical Data Base Constants for ANO-2", March 1985.

These documents are provided in response to additional information requests from your staff to assist in their review.

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' Mr. James - R. Miller-- March 29,-1985 The respective CPC algorithms for ANO-2 Cycle 5 and the methodology used to i

. generate.-the typical data base constants for ANO-2 Cycle 5 are identical to  ;

those. reviewed by the NRC for San Onofre Nuclear Generating Station Unit 2 Cycle 2.

' Due to the proprietary nature of the. attached r.aterial, CE has requested

'that certain portions of these documents.be withheld from public disclosure.

To accommodate this request five copies of both the proprietary (copies-numbered 01-05) and nonproprietary versions are provided. Four copies of 1 each are attached; one copy of each was' hand delivered to Mr. Bob Lee of your staff on March 29, 1985. An affidavit in support of this proprietary determination is also provided.

Very truly yours, A WM T. Gene Campbel TGC/RBT/ac Attachments L

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' STATE OF ARKANSAS. )

.) SS COUNTY OF PULASKI )

I, T. Gene Campbell,'being duly sworn, subscribe to and say that I am Vice President, Nuclear Operations, for Arkansas Power & Light Company; that I have full authority to execute this oath; that I have read the document numbered 2CAN538558 and know the contents thereof; and that to the best of my knowledge, information and belief the statements in it are true.

24wf T. Gene Campb SUBSCRIBED AND SWORN T0 before me, a Notary Public in and for the County and State above named, this 99 day of [AO- rJ ,

1985.

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My Commission Expires:

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I 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 conjunction with the application of Arkansas Power & Light Company for withholding this information.

The information for which proprietary treatment is sought is contained in the following documents:

CEN-296(A)-P, ANO-2 CPC and CEAC Data Base Listing, March 1985.

CEN-298(A)-P, ANO-2 CP_C System Phase I Design Qualification Test Report, March 1985.

CEN-162(A)-P, Revision 01, AN0-2 CPC/CEAC System Phase II Sof tware Verification Test Report, March 1985.

Enclosure 1-P to A-CE-R-92, " Typical Data Base Constants for ANO-2.

These documents have 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 a i ..

description of the testing, quantitative data, test evaluation, and acceptance criteria for the CPC/CEAC system software, which is owned and has been held in confidence by Combustion Engineering.

2. .The information consists of test data or other similar data concerning 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 Combusti n Engineering and not customarily disclosed to the public. Combustion-Engir y has a rational basis for determining the types of information customari'j te d in confidence by it and, in that connection, utilizes a system to deternn u shen 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.

i 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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Ib a. A similar product is manufactured and sold by major pressurized l

l Water reactgr competitors of Combustion Engineering.

H bI ! Development of this information by C-E required tens of thousands I - of man-hours of effort:and hundreds of thousands of dollars. To the best of my l} . knowledge and belief a competitor woilld have to undergo similar expense in igenerating equivalent information ..

c. In order to acquire such information, a competitor would.also I require considerable time and inconvenience related to the development of a CPC/CEAC data base and testing ofLCPC/CEAC software.

d. The information required significant effort and expense to obtain the licensing approvals necessary for application of the information.

Avoidance:of this expense would decrease. a competitor's cost in applying the information and marketing the product to which the information is applicable.

e. The information consists of a description of the testing, quantitative data, test evaluation, and acceptance. criteria for the CPC/CEAC system software, the application of which provides a competitive economic l' . , 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, L

1 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

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t without similar expenditure of resources may enable them to sell at prices l

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 l-Engineering's potential for obtaining or maintaining foreign licensees.

Further the deponent sayeth not.

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l P. L. McGill Vice President Commercial l Sworn to before me this lh day of I%tl.sp l9fI dua nm>P7. tam o w '

i Notary Public' My commission expires March 31,1988.

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