ML13333A543
| ML13333A543 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/18/1980 |
| From: | Baskin K Southern California Edison Co |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| TASK-03-04.B, TASK-3-4.B, TASK-RR NUDOCS 8003200642 | |
| Download: ML13333A543 (13) | |
Text
Southern California Edison Company P. O. BOX 800 2244 WALNUT GROVE AVENUE ROSEMEAD. CALIFORNIA 91770 K. P. BASKIN TELEPHONE MANAGER, NUCLEAR ENGINEERING (213) 572-1401 AND LICENSING March 18, 1980 Director of Nuclear Reactor Regulation Attention:
D. G. Eisenhut, Acting Director Division of Operating Reactors U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Gentlemen:
Subject:
Docket No. 50-206 Turbine Disc Integrity San Onofre Nuclear Generating Station Unit 1 Enclosed are:
- 1.
One (1) copy - Application for withholding.
- 2.
One (1) copy - Affidavit AW-80-4.
- 3.
One (1) copy of the letter from J. M. Schmerling, Westinghouse Electric Corporation to Darrell G. Eisenhut, Nuclear Regulatory Commission, March 14, 1980.
- 4.
One (1) copy - Appendix A (Proprietary) -
Responses to Site Specific Questions.
- 5.
One (1) copy - Appendix B (Non-proprietary) -
Responses to Site Specific Questions.
The purpose of this letter is to respond to your request for information of February 25, 1980, relative to turbine disc integrity in operating Westinghouse nuclear low pressure turbines. Per your request in the subject letter, responses to the generic questions have been coordinated through a task force whose representation includes all owners of Westinghouse nuclear low pressure turbines and is chaired by Mr. Wayne Stiede of Commonwealth Edison. The concensus responses to the generic questions have been submitted to you by Westinghouse at the request of the task force (Enclosure 3).
Since we adopt the consensus responses 'as our own, we incorporate those response by reference.
Jr.
V09 SA
Darrell March 18, 1980 The site specific responses contain proprietary information of the Westinghouse Electric Corporation (Appendix A (Proprietary)). In conformance with the requirements of 10CFR Section 2.790, as amended, of the Commission's regulations, we are enclosing with the submittal an application for withholding from public disclosure (Enclosure 1) and an affidavit (Enclosure 2).
The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission.
Correspondence with respect to the affidavit or application for withholding should reference AW-80-4 and should be addressed to Mr. R. Williamson, Manager, Customer Order Engineering, Westinghouse Electric Corporation, Steam Turbine Divisions Lester Branch Box 9175, Philadelphia, Pennsylvania, 19113.
As discussed in Enclosures 3 and 4:
- 1)
The largest postulated ratio of crack size to critical crack size is conservatively calculated to be much less than 1.0 (see Enclosure 4, Table 1, Section G) for all discs at the turbine design overspeed,
- 2)
The results of previous turbine inspections has not revealed stress corrosion cracking problems with San Onofre Unit 1 turbine components, and
- 3)
Previous review of the overall probability of turbine missiles damaging the San Onofre Unit 1 plant and leading to consequences in excess of the 10CFR Part 100 guidelines indicated that such probability is acceptabily low.
Therefore, it is concluded that continued operation of the San Onofre Unit 1 low pressure turbines until the Spring, 1980 refueling outage does not represent an undue risk to public safety.
If you have any questions concerning this matter, please let me know.
Subscribed on this If day of 1980.
By K. P. Baskin Subscribed and sworn to before me this day of 244
/
,k1980.
4RAL WEA AGNES CRABTREE NOTARY PUBUIC - CAUIFORNIA PRINCIPAL OFFICE IN LOS ANGELES COUNTYl Not y Public in and for the County of Fa.
Los Angeles, State of California Enclosures
DOCKET NO._
DATE:
NOTE TO NRC AND/OR LOCAL PUBLIC DOCUMENT ROOMS The following item submitted with letter dated _
from S#&
//5d/S
- is being withheld from public disclosure in accordance with Section 2.790.
PROPRIETARY INFORMATION Distribution Service's Branch
ENCLOSURE 1
AW-80-4 March 14, 1980 Darrell G. Eisenhut Division of Operating Reactors Office of Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington DC 20555 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
San Onofre Nuclear Generating Station Unit 1 Docket #50-206 Information in Response to NRC Request for Information of February 25, 1980, Relative to Low Pressure Turbine Disc Integrity.
Reference:
Appendix A letter from Robert Dietch to Eisenhut, dated 3/18/80
Dear Mr. Eisenhut:
This application for withholding is submitted by Westinghouse Electric Corporation ("Westinghouse") pursuant to the provisions of paragraph (b)(1) of Section 2.790 of the Commission's regulations. Withholding from public disclosure is requested with respect to the subject information which is further identified in the affidavit accompanying this application.
The undersigned has reviewed the information sought to be withheld and is authorized to apply for its withholding on behalf of Westinghouse, STG-TOD.
The affidavit accompanying this application sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.790 of the Commission's regulations.
Accordingly, it is respectfully requested that the subject information which is proprietary to Westinghouse and which is further identified in the affi davit be withheld from public disclosure in accordance with 10CFR Section 2.790 of the Commission's regulations.
Correspondence with respect to this application for withholding or the accom panying affidavit should be addressed to the undersigned.
Very truly yours, R. Williamson, Manager Customer Order Engineering Westinghouse Electric Corporation
ENCLOSURE 2
Of:
AW-80-4 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF DELAWARE:
Before me, the undersigned authority, personally appeared Robert Williamson, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Corporation ("Westinghouse") and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:
Robert Williamson, Manager Customer Order Engineering Sworn toQad s cribed ore me HENRY E. SQUILLACE Notary Public, Marple Twp., Delaware Co.
-My Commission Expires Oct. 18, 1980
(1) I am Manager, Customer Order Engineering in the Steam Turbine Generator Technical Operations Division of Westinghouse Electric Corporation and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing, and am authorized to apply for its withholding on behalf of the Westinghouse Power Generation Divisions.
(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.790 of the Commission's regulations and in conjunction with the Westinghouse application for withholding accompanying this Affidavit.
(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse Power Generation Divisions in designating informa tion 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 con sideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.
(i)
The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.
(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the pub lic.
Westinghouse 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 confi dence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.
Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential com petitive advantage, as follows:
(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.)
where prevention of its use by any of Westinghouse's competitors without license from Westinghouse consti tutes a competitive economic advantage over other companies.
(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.
(c) Its use by.a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.
(d) It reveals cost or price information, production capac ities, budget levels, or commercial strategies of West inghouse, its customers or suppliers.
(e) It reveals aspects of past, present, or future Westing house or customer funded development plans and programs of potential commercial value to Westinghouse.
(f) It contains patentable ideas, for which patent protec tion may be desirable.
(g) It is not the property of Westinghouse, but must be treated as proprietary by Westinghouse according to agreements with the owner.
(h) Public disclosure of this information would allow un fair and untruthful judgments on the performance and reliability of Westinghouse equipment components and improper comparison with similar components made by competitors.
There are sound policy reasons behind the Westinghouse system which include the following:
(a) The use of such information by Westinghouse gives West inghouse a competitive advantage over its competitors.
It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.
(b) It is information which is marketable in many ways.
The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.
(c) Use by our competitor would put Westinghouse at a com petitive disadvantage by reducing his expenditure of resources at our expense.
(d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If com petitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.
(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition in those countries.
(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.
(iii)
The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Sec tion 2.790, it is to be received in confidence by the Commission.
(iv)
The information is not available in public sources to the best of our knowledge and belief.
(v)
The proprietary information sought to be withheld in this submittal is that which is appropriately marked in Appen dix A to letter from K. P. Baskin Eisenhut, dated March 18, 1980 concerning infor mation in response to NRC request for information of February 25, 1980, relative to low pressure turbine disc integrity.
The information enables Westinghouse to:
(a) Develop test inputs and procedures to satisfactorily verify the design of Westinghouse supplied equipment.
(b) Assist its customers to obtain licenses.
Further, the information has substantial commercial value as follows.
(a) Westinghouse can sell the use of this information to customers.
(b) Westinghouse uses the information to verify the design of equipment which is sold to customers.
(c) Westinghouse can sell services based upon the exper ience gained and the test equipment and methods developed.
Public disclosure of this information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to design, manufacture, verify, and sell electrical equipment for commercial turbine-generators without commensurate expenses. Also, public disclosure of the information would enable others having the same or similar equipment to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.
The development of the equipment described in part by the information is the result of many years of development by Westinghouse and the expenditure of a considerable sum of money.
This could only be duplicated by a competitor if he were to invest similar sums of money and provided he had the appro priate talent available and could somehow obtain the requi site experience.
Further the deponent sayeth not.
ENCLOSURE 3