ML17254A881

Requests Withholding of Proprietary Revised DNBR Licensing Basis for Steam Break Analysis at Reduced Pressure.Encl Withheld (Ref 10CFR2.790)

ML17254A881
Person / Time
Site:	Ginna
Issue date:	07/20/1984
From:	Wiesemann R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	Crutchfield D Office of Nuclear Reactor Regulation
Shared Package
ML17254A876	List: ML17254A874 ML17254A881
References
CAW-84-70, NUDOCS 8408070257
Download: ML17254A881 (9)

Text

Westinghouse Nuc! ear Fuel Oivision Water Reactor Electric Corporation Divisions Box 3912 Pittsoury Pervtsylvania 15230 July 20, 1984 Director of Nuclear Reactor Regulation CAW-84-70

. Attention: Dennis M. Crutchfield U.S. Nuclear Regulatory Commission Phillips Building 7920 Norfolk Avenue Bethesda, Maryland 20014 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE Ref.: R. E. Ginna Nuclear Plant, letter, Cook to Denton, April 1984

Dear Mr. Crutchfield:

The proprietary material for which withholding is being requested by the Rochester Gas and Electric Company is proprietary to Westinghouse and with-holding is requested pursuant to the provisions of Paragraph (b)(l) of Section 2.790 of the Commisss"on'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 proprietary material transmitted by the referenced letter supplenents the proprietary material previously submitted. Further, the affidavit submitted to justify the previous material was approved by the Commission on April 17, 1978, and is equally applicable to the subject material.

Accordingly, withholding the subject information from public disclosure is requested in accordance with the previously submitted affidavit, AW-76-60, a copy of which is attached.

Accordingly, this letter authorizes the use of the proprietary information and affidavit AW-76-60 by the Rochester Gas and Electric Company for the R. E.

Ginna Nuclear plant.

Correspondence with respect to this application for withholding or the accompanying affidavit should reference CAW-84-70 and be addressed to the undersigned.

Yer truly yours, Robert A. Wiesemann, Manager Regulatory and Legislative Affairs

'8408070257 84073i

/mh PDR, ADQCK 05000244 P

Enclosure(s)

PDR L cc: E. C. Shomaker, Esq-Office of the Evecutive Legal Director, NRC

AW-76-60 AFFIDA'/IT.

COYu~i0hWEALTH OF PEhHSYLYAiV IA'OUHTY ss OF ALLEGHEflY:

Before me, the undersigned authority, personally appeared Robert A. Wiesemann, who, being by me duly sworn according to law, de-poses and says that he is authorized to execute this Affidavit on behal of Westinghouse Electric Corporation ("'lestinghouse") and that, the aver-ments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:

(/- 4/

~ Robert i. Ni es emann, teenage r Licensing Programs Sworn to and subscribed beforeme. this ~ day .

of Z a'i'ixdSG ..1'976.

/ Hotary'ub i c 1

'M-.76-60 I am thanager, Licensing Programs, .in the Pressurized Mater Peactor System Division, of '!estinghouse Electric Corporation and as such,

,I have be n specific lly delegat d the function of rev'ewing the proprietary information sought to b withheld from public dis-closure in connection with nuclear power plant licensing or rule-making proceedings, and am authorized to apply for its withholding on behalf of the r'estinghouse Hater Peactor 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 con-junction with the Hestinghouse application for withholding ac-companying this Affidavi (3) I have personal knowledg of the criteria and procedures utilized by l(estinghouse Nuclear Energy Systems in designating information

~

as a trade secret, privileged or as confid=ntial commercial or financi al information.

(4) Pursuan 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 in-formation sought to be withheld from public disclosure should be wi thh el d.

(i) The information sought,to be withheld from public disclosure's-owned and has been held in.confidence. by l"estinghouse.

w3 AW-76-60 The information is of a type customarily held in confidence by Mestingl ouse and not customarily disclosed to the public.

Westinghouse has a rational basis for determining the types cf information customarily held in confidence by it and, in that connection, utilizes a system to determine when. and whe.her to hold certain types of information in'confidence. The ao-plication of that system and the substance of that syst m constitut s 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 in ormation reveals the distinguishing aspects o a process (or component, structure, tool, method, etc.)

where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including tes ~ .data, relative to a process (or component; st.ucture, tool, method, etc.), the application of which data sec"res a competi tive economic advantage, e.g., by optimization or improved marketabi1 i ty.

AH-76-60 (c) Its use by a competitor would reduce his expenditure of resources or improve his competitive posi.ion in the design, manufacture, shipment, installat',on, assurarc of quality, or licensing a similar produc..

II (d) It reveals cost or price information, produc.ion cap-acities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future hest-inghouse or customer funded development plans and pro-grams of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent pro-tection may be desirab.ie.

(g) It is not the property of Westinghouse, but must be treated as proprietary by W stinghouse according to agre ments with the owner.

There are sound policy reasons behind the Westinghouse system. which include the following:

(a) The use of such information by Westinghiouse gives Westinghouse a- competitive advantage over its com-petitors. It is, therefore, withheld from disclosure to protect the Westinghouse competi ti .e posi ticn.

AW-76-60 (b) It is information which is marketable in many ways.

The ext nt 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 competitive disadvantage by reducing his expendi t re of resourc s at our expense.

(d) Each component of proprietary information per.inent to .a particular competitive advantage is potentially as valuable as the total competi'tive advantage. If competitors acquire components of'roprietary infor-mation, any one component may be the key to the enti re puzzle, thereby depriving Westinghouse of a competitive advantage.

(e)

'f Unrestricted disclosure would jeopardize the position prominence of Westinghouse in,'he world market, and thereby give a market advantage to the competition in those countries.

(f) The Westinghouse capaci y to invest corporate assets in research 'and development, depends upon the success in obtaining and maintaining a competi.tive advan.age.

Al<-76-60 (iii) The infor'mation is being transmit.od to the Commission in confidence and, under .he provisions of 10 C."-R Section 2,790, it, is to be received in confidenc by the Commission.

(iv) The information is not available in public sources to the best of our knowledge and belief.

(v) The proprietary informiation sought to be withheld in this sub-mittal is that which is appropri'ately,marked in the attach-ment to Westinghouse letter number NS-CE-1298, Eicheldinger to Stolz, dated December I, 1975, concerning information relating to HRC rev ew of WCAP-C567-P and '..CAP-8568 onii tIed, "Improved Thermal Design Procedure," defin'.'rg the sensi ivity of OHB ratio to various core parameters. one letter and attachment.

are being submitted in response to the HRC request at the October 29, 1976 HRC/i,"estinghouse meeting.

This information enables Westinghouse to:

(a) Justi fy the llestinghouse design.

(b) Assist its cus.omers to obtain licenses.

(c) Meet warranties.

(d) Provide greater operational flexibility to cust"... rs assuring them of safe and reliable ope. ation.

(e) Justiiy increased oower capability or operating ilal gin for plants while assur'.ng sa,e and rel'able operation.

AW-76-,60 (f) Optimize reactor design and per=ormance while maintaining a high level of fuel int grity.

Further, the in ormation gained from the improved thermal design procedure is of sigrifi.canc. co:..,iercial value as follows:

(a) Westinghouse uses the information to perform and justify analyses which are sold to customers.

(b) Westinghouse sells analysis services based upon the

. experience gai ned .and the method" developed ..

Public disclosure of this information concerning design pro-cedures is likely to cause substantial harm to the competitive position of Westinghouse because competitors could utilize this information to assess and justify their own designs without commensurate expense.

The parametric analyses performed ard their evalu tion represent a considerable amount of highly qualified develop-ent ef ort.

This work was contingent upon a design method development pro-gram which has be n underway during the past two years.

Altogether, a substantial amount of money and effor. has'een f

expended by Westinghouse which could only be duplica. d by a competitor if he were to invest similar sums of money and pro-vi ded he had the appropri ate tal ent avai 1 bl e.

Further the deponent sayeth not.

'. E:- GINNA REVISED DNBR LICENSING BASIS FOR STEAMBREAK ANALYSIS AT REDUCED PRESSURE I

(Response to NRC question Concerning Use of W-3 Correlation for Steamline Break)

..The following is provided in response to a question from the NRC staff concerning the validity of the W-3 correlation at low pressures, such as those which occur during a steamline break.

The test data used to develop the W-3 correlation were taken at pressures ranging from 1000 to 2300 psia (Ref. 1).

For the steamline break transient presented in the Reload Transition Safety Report (RTSR) for Ginna, the pressure during the steamline break-is as.low as ( ]+a~c psia at the limiting condition, i.e., the point of minimum DNBR. For Ginna, the W-3 correlation is used to calculate the DNBR for the steamline break event. Thus, the applicability of the .

W-3 correlation must be reviewed with respect to this low pressure.

Evaluations using the same source of data as'sed in the development of the W-3 correlation have shown that the pressure range of the correlation can be extended below 1000 psia. Note that this approach has previously been used to extend the range of the W-3 correlation, the one most similar to Ginna being the Prairie Island analysis of 1972 (Ref. 2). Based on this evaluation, Westinohouse concludes that'he results of the W-3 correlation are acceptable for the Ginna steamline break analysis and that the DNB design basis is met. This information was previously transmitted to the NRC in Ref. 3.,

Also, Westinghouse has demonstrated that the DNBR is greatly in excess,.

of the design basis limit of 1.30. The minimum DNBR calculated for the transition core following a steamline break is actually [ ]+ . The

~

minimum DNBR may differ slightly in future cycles but this value is indicative of the large margin available to the design basis limit of 1.30. Thus, any uncertainties associated with the calculation of a DNBR below the standard lower bound of 1000 psia for the W-3 correlation are amply compensated by the DNBR calculated for the steamline break event. Therefore, Westinghouse believes that the Ginna DNB design basis continues to be met, even if this additional uncertainty is taken into account.

References

1. Tong, L. S., AEC Critical Review Series, "Boiling Crisis and Critical Heat Flux,',.'ID-25887, August 1972.

n

2. Prairie Island FSAR, Amendment 20, P. 14.2-30, Docket -.":50-282, August 4, 1972.

3. Reference of RGE Responses to NRC.