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Category:CORRESPONDENCE-LETTERS
MONTHYEARML17250B3041999-10-20020 October 1999 Forwards Changes to Tech Specs Bases for Re Ginna Nuclear Power Plant.Change Bars Indicate Those Revs Which Have Been Incorporated IR 05000244/19990081999-10-14014 October 1999 Forwards Insp Rept 50-244/99-08 on 990809-0919.Severity Level IV Violation of NRC Requirements Occurred & Being Treated as non-cited Violation Consistent with App C of Enforcement Policy ML17265A7651999-10-0808 October 1999 Forwards Fifteen Relief Requests That Will Be Utilized for Ginna NPP Fourth Interval ISI Program That Will Start on Jan 1,2000.Attachment 1 Includes Summaries & Detailed Description of Each Relief Request ML17265A7631999-10-0505 October 1999 Requests Approval for Use of Relief Request Number 43 to Address Volumetric Examination Limitations (Less than 90%) Associated with a & B RHR Heat Exchanger Outlet Nozzle to Shell Welds.Approval Is Requested by Dec 31,2000 ML17265A7641999-10-0505 October 1999 Requests Approval for Use of Relief Request Number 42 to Address Volumetric Examinations Limitations (Less than 90%) Associated with Eight Class 1 Identified Welds or Areas of Reactor Pressure Vessel ML20212J3561999-09-30030 September 1999 Forwards Four Copies of Re Ginna NPP Training & Qualification Plan for Security Officers, Rev 7,dtd 990930. Synopsis of Changes,Encl.Encl Withheld Per 10CFR73.21 ML20212J3801999-09-30030 September 1999 Forwards Four Copies of Rev to Re Ginna NPP Security Plan.Rev Changes Contingency Weapons Available to Response Force to Those Most Effective in Current Defensive Strategy.Encl Withheld Per 10CFR73.21 IR 05000244/19990051999-09-24024 September 1999 Forwards More Detailed Response Re Main Steam Check Valve Performance Questions Arising from NRC Insp Rept 50-244/99-05 Following Completion of Independent Assessment Being Performed by Duke Engineering & Svcs ML17265A7571999-09-24024 September 1999 Forwards More Detailed Response Re Main Steam Check Valve Performance Questions Arising from NRC Insp Rept 50-244/99-05 Following Completion of Independent Assessment Being Performed by Duke Engineering & Svcs IR 05000244/19992011999-09-24024 September 1999 Forwards Insp Rept 50-244/99-201 (Operational Safeguards Response Evaluation) on 990621-24.No Violations Noted. Primary Purpose of Osre to Assess Licensee Ability to Respond to External Threat.Insp Rept Withheld ML17265A7461999-08-31031 August 1999 Submits Response to NRC Administrative Ltr 95-03,rev 2, Availability of Reactor Vessel Integrity Database,Version, Dtd 990726 ML17265A7401999-08-26026 August 1999 Requests Approval for Use of Relief Request Number 35 Re Use of ASME Section XI Code,1995 Edition,1996 Addenda.Code Will Be Used to Develop Plant Fourth 10-year Interval ISI Program on Class 1,2 & 3 Components ML17265A7411999-08-26026 August 1999 Forwards LER 99-004-01 Re Plant Being Outside Design Basis Due to Containment Recirculation Fan Moisture Separator Vanes Being Incorrectly Installed.Part 21 Notification of 990512 Is Being Rescinded ML17265A7451999-08-23023 August 1999 Forwards fitness-for-duty Performance Data Rept for Six Months Ending 990630,per 10CFR26.71(d) ML17250B3021999-08-23023 August 1999 Informs That Util & NRC Had Conference Call on 990816 to Review Approach in Responding to Questions,As Result of Questions Re Main Steam Check Valve Performance Included in Insp Rept 50-244/99-05,dtd 990806 ML17265A7271999-07-30030 July 1999 Forwards 10CFR21 Interim Rept Per Reporting of Defects & Noncompliance,Section 21 (a) (2).Interim Rept Prepared Because Evaluation Cannot Be Completed within 60 Days from Discovery of Deviation or Failure to Comply ML17265A7151999-07-23023 July 1999 Forwards LER 99-007-01 Re Personnel Error Which Caused Two Channels to Be in Tripped Condition,Resulting in Reactor Trip.Further Investigation of Event Identified Addl Corrective Actions ML17265A7061999-07-22022 July 1999 Forwards LER 98-003-02,re Actuations of CR Emergency Air Treatment Sys.All Creats Actuations,Including Those Originally Believed to Be Valid Actuations,Were,In Fact Invalid Actuations ML17265A7191999-07-21021 July 1999 Forwards Ginna Station ISI Rept for Refueling Outage Conducted in 1999 ML17265A7141999-07-21021 July 1999 Withdraws Relief Request 35 for Plant Inservice Insp Program Section XI Requirements,Submitted on 980806.Licensee Plans to Resubmit Relief Request,Which Includes Addl Level of Detail,In Near Future ML17265A7041999-07-16016 July 1999 Submits Info Re Specific Licensing Actions Which May Be Expected to Generate Complex Reviews,In Response to Administrative Ltr 99-02,dtd 990603 ML17265A6911999-06-30030 June 1999 Responds to NRC Request for Info Re Y2K Readiness at Nuclear Power Plants.Gl 98-01 Requested Response on Status of Facility Y2K Readiness by 990701.Readiness Disclosure Attached ML17265A6871999-06-22022 June 1999 Forwards Response to RAI Made During 990225 Telcon Re GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves. Calculation Encl. Encl ML17265A6841999-06-21021 June 1999 Informs That Util Wishes to Amend Extend of Alternate Exams Provided for Relief Request Re ISI Program ASME Section XI Require Exams for First 10-Yr Interval for Containment ML17265A6741999-06-15015 June 1999 Submits Annual ECCS Rept IAW 10CFR50.46(a)(3)(ii) Requirements.No Changes Have Been Made to Large Break LOCA PCT & Small Break LOCA PCT ML17265A6751999-06-11011 June 1999 Responds to NRC RAI Re Licensee GL 96-05 Program.Encl Info Verifies That Util Is Implementing Provisions of JOG Program on MOV Periodic Verification ML17309A6551999-06-0707 June 1999 Responds to NRC 990310 RAI Re Verification of Seismic Adequacy of Mechanical & Electrical Equipment ML17265A6671999-06-0101 June 1999 Requests Approval of Ginna QA Program for Radioactive Matl Packages,Form 311,approval Number 0019.Ginna QA Program for Station Operation, Was Most Recently Submitted to NRC by Ltr Dtd 981221 & Supplemented on 990301 ML17265A6641999-05-25025 May 1999 Forwards Addl Info on Use of GIP Method a for Re Ginna Nuclear Power Plant.Copy of Re Ginna Station USI A-46 Outlier Resolution Table as Requested ML17265A6611999-05-24024 May 1999 Forwards LER 99-007-00 Re Personnel Error Which Caused Two Channels to Be in Tripped Condition,Resulting in Rt.Util Is Planning to Submit Suppl to LER by 990730 ML20206U0921999-05-13013 May 1999 Forwards Four Copies of Rev R to Gnpp Security Plan,Per Provisions of 10CFR50.54(p).Rev Clarifies Armed Response Team Assignments & Does Not Degrade Physical Security Effectiveness.Rev Withheld,Per 10CFR73.21 ML17265A6461999-05-12012 May 1999 Forwards 1998 Annual Radioactive Effluent Release Rept & 1998 Annual Radiological Environ Operating Rept, for Re Ginna NPP ML17265A6411999-05-12012 May 1999 Forwards LER 99-004-00 IAW 10CFR50.73 & 10CFR21.Further Assessment Will Be Provided in Suppl to LER by 990630 ML20206E7221999-04-29029 April 1999 Forwards Four Copies of Rev Q to Re Ginna Nuclear Power Plant Security Plan,Per 10CFR50.54(p).Changes Do Not Degrade Physical Security Effectiveness.Encl Withheld,Per 10CFR73.21 ML20206H6911999-04-22022 April 1999 Forwards Info Requested During Informal Telcon on 980408 Concerning Upcoming Osre at Ginna Station.Info Requested Listed.Without Encls ML17265A6271999-04-19019 April 1999 Forwards Rev 0 & Rev 1 to Colr,Cycle 28 for Re Ginna NPP, Per TS 5.6.5 ML17309A6501999-04-14014 April 1999 Forwards Revised Ginna Station EOPs & Procedures Index ML17265A6121999-03-29029 March 1999 Forwards Rept on Status of Decommissioning Funding for Re Ginna Npp,For Which Rg&E Is Sole Owner,Per 10CFR50.75. Data Presented Herein,Current as of 981231 ML17265A6041999-03-24024 March 1999 Forwards LER 99-001-00,IAW 10CFR50.73(a)(2)(ii)(B) & 10CFR21.Addl Analyses Are Being Performed to Support Future Cycle Operation & Supplemental LER Is Scheduled to Be Submitted by 990618 ML17265A5671999-03-0101 March 1999 Forwards Application for Amend to License DPR-18,to Revise TSs Battery Cell Parameters Limit for Specific Gravity (SR 3.8.6.3 & SR 3.8.6.6).Supporting Tss,Encl ML17265A5641999-03-0101 March 1999 Forwards Response to NRC 990217 RAI Concerning Changes to QA Program for Re Ginna Station Operation.Rg&E Is Modifying Changes Requested in 981221 Submittal.Modified QA Program,Encl ML17265A5551999-02-25025 February 1999 Informs That Util Is in Process of Revising fitness-for-duty Program,Developed in Accordance with 10CFR26.Util Will Continue to Use Dept of Health & Human Svcs Certified Test Facility for Majority of Tests During Yr ML17265A5561999-02-22022 February 1999 Forwards FFD Performance Data Rept for Six Months Ending 981231,per 10CFR26.71(d) ML17265A5451999-02-12012 February 1999 Forwards Simulator Four Year Certification Rept,Per 10CFR55.45(b)(5)(ii) ML17309A6491999-02-12012 February 1999 Forwards Ginna Station EOPs ML17265A5431999-02-0909 February 1999 Supplements 980806 Relief Request with Attached Table.Util Third 10-Yr ISI of Reactor Vessel Being Performed During 1999 Refueling Outage,Beginning on 990301 ML17265A5361999-02-0202 February 1999 Forwards Response to NRC 981203 RAI Re Resolution of Unresolved Safety Issue USI A-46.Util Does Not Agree with NRCs Interpretation.Detailed Bases,Encl ML17311A0691999-01-25025 January 1999 Forwards Revs to Ginna Station Emergency Plan Implementing Procedures (Epips).Previous Rev Had Incorrect Effective Date ML17311A0671999-01-14014 January 1999 Forwards Revised Emergency Operating Procedures for Re Ginna NPP ML17265A5131999-01-12012 January 1999 Forwards Revised Cover Page for Ginna Station Technical Requirements Manual (Trm), Rev 7,correcting Error in Effective Date 1999-09-30
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML17250B3041999-10-20020 October 1999 Forwards Changes to Tech Specs Bases for Re Ginna Nuclear Power Plant.Change Bars Indicate Those Revs Which Have Been Incorporated ML17265A7651999-10-0808 October 1999 Forwards Fifteen Relief Requests That Will Be Utilized for Ginna NPP Fourth Interval ISI Program That Will Start on Jan 1,2000.Attachment 1 Includes Summaries & Detailed Description of Each Relief Request ML17265A7631999-10-0505 October 1999 Requests Approval for Use of Relief Request Number 43 to Address Volumetric Examination Limitations (Less than 90%) Associated with a & B RHR Heat Exchanger Outlet Nozzle to Shell Welds.Approval Is Requested by Dec 31,2000 ML17265A7641999-10-0505 October 1999 Requests Approval for Use of Relief Request Number 42 to Address Volumetric Examinations Limitations (Less than 90%) Associated with Eight Class 1 Identified Welds or Areas of Reactor Pressure Vessel ML20212J3561999-09-30030 September 1999 Forwards Four Copies of Re Ginna NPP Training & Qualification Plan for Security Officers, Rev 7,dtd 990930. Synopsis of Changes,Encl.Encl Withheld Per 10CFR73.21 ML20212J3801999-09-30030 September 1999 Forwards Four Copies of Rev to Re Ginna NPP Security Plan.Rev Changes Contingency Weapons Available to Response Force to Those Most Effective in Current Defensive Strategy.Encl Withheld Per 10CFR73.21 IR 05000244/19990051999-09-24024 September 1999 Forwards More Detailed Response Re Main Steam Check Valve Performance Questions Arising from NRC Insp Rept 50-244/99-05 Following Completion of Independent Assessment Being Performed by Duke Engineering & Svcs ML17265A7571999-09-24024 September 1999 Forwards More Detailed Response Re Main Steam Check Valve Performance Questions Arising from NRC Insp Rept 50-244/99-05 Following Completion of Independent Assessment Being Performed by Duke Engineering & Svcs ML17265A7461999-08-31031 August 1999 Submits Response to NRC Administrative Ltr 95-03,rev 2, Availability of Reactor Vessel Integrity Database,Version, Dtd 990726 ML17265A7401999-08-26026 August 1999 Requests Approval for Use of Relief Request Number 35 Re Use of ASME Section XI Code,1995 Edition,1996 Addenda.Code Will Be Used to Develop Plant Fourth 10-year Interval ISI Program on Class 1,2 & 3 Components ML17265A7411999-08-26026 August 1999 Forwards LER 99-004-01 Re Plant Being Outside Design Basis Due to Containment Recirculation Fan Moisture Separator Vanes Being Incorrectly Installed.Part 21 Notification of 990512 Is Being Rescinded ML17250B3021999-08-23023 August 1999 Informs That Util & NRC Had Conference Call on 990816 to Review Approach in Responding to Questions,As Result of Questions Re Main Steam Check Valve Performance Included in Insp Rept 50-244/99-05,dtd 990806 ML17265A7451999-08-23023 August 1999 Forwards fitness-for-duty Performance Data Rept for Six Months Ending 990630,per 10CFR26.71(d) ML17265A7271999-07-30030 July 1999 Forwards 10CFR21 Interim Rept Per Reporting of Defects & Noncompliance,Section 21 (a) (2).Interim Rept Prepared Because Evaluation Cannot Be Completed within 60 Days from Discovery of Deviation or Failure to Comply ML17265A7151999-07-23023 July 1999 Forwards LER 99-007-01 Re Personnel Error Which Caused Two Channels to Be in Tripped Condition,Resulting in Reactor Trip.Further Investigation of Event Identified Addl Corrective Actions ML17265A7061999-07-22022 July 1999 Forwards LER 98-003-02,re Actuations of CR Emergency Air Treatment Sys.All Creats Actuations,Including Those Originally Believed to Be Valid Actuations,Were,In Fact Invalid Actuations ML17265A7191999-07-21021 July 1999 Forwards Ginna Station ISI Rept for Refueling Outage Conducted in 1999 ML17265A7141999-07-21021 July 1999 Withdraws Relief Request 35 for Plant Inservice Insp Program Section XI Requirements,Submitted on 980806.Licensee Plans to Resubmit Relief Request,Which Includes Addl Level of Detail,In Near Future ML17265A7041999-07-16016 July 1999 Submits Info Re Specific Licensing Actions Which May Be Expected to Generate Complex Reviews,In Response to Administrative Ltr 99-02,dtd 990603 ML17265A6911999-06-30030 June 1999 Responds to NRC Request for Info Re Y2K Readiness at Nuclear Power Plants.Gl 98-01 Requested Response on Status of Facility Y2K Readiness by 990701.Readiness Disclosure Attached ML17265A6871999-06-22022 June 1999 Forwards Response to RAI Made During 990225 Telcon Re GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves. Calculation Encl. Encl ML17265A6841999-06-21021 June 1999 Informs That Util Wishes to Amend Extend of Alternate Exams Provided for Relief Request Re ISI Program ASME Section XI Require Exams for First 10-Yr Interval for Containment ML17265A6741999-06-15015 June 1999 Submits Annual ECCS Rept IAW 10CFR50.46(a)(3)(ii) Requirements.No Changes Have Been Made to Large Break LOCA PCT & Small Break LOCA PCT ML17265A6751999-06-11011 June 1999 Responds to NRC RAI Re Licensee GL 96-05 Program.Encl Info Verifies That Util Is Implementing Provisions of JOG Program on MOV Periodic Verification ML17309A6551999-06-0707 June 1999 Responds to NRC 990310 RAI Re Verification of Seismic Adequacy of Mechanical & Electrical Equipment ML17265A6671999-06-0101 June 1999 Requests Approval of Ginna QA Program for Radioactive Matl Packages,Form 311,approval Number 0019.Ginna QA Program for Station Operation, Was Most Recently Submitted to NRC by Ltr Dtd 981221 & Supplemented on 990301 ML17265A6641999-05-25025 May 1999 Forwards Addl Info on Use of GIP Method a for Re Ginna Nuclear Power Plant.Copy of Re Ginna Station USI A-46 Outlier Resolution Table as Requested ML17265A6611999-05-24024 May 1999 Forwards LER 99-007-00 Re Personnel Error Which Caused Two Channels to Be in Tripped Condition,Resulting in Rt.Util Is Planning to Submit Suppl to LER by 990730 ML20206U0921999-05-13013 May 1999 Forwards Four Copies of Rev R to Gnpp Security Plan,Per Provisions of 10CFR50.54(p).Rev Clarifies Armed Response Team Assignments & Does Not Degrade Physical Security Effectiveness.Rev Withheld,Per 10CFR73.21 ML17265A6461999-05-12012 May 1999 Forwards 1998 Annual Radioactive Effluent Release Rept & 1998 Annual Radiological Environ Operating Rept, for Re Ginna NPP ML17265A6411999-05-12012 May 1999 Forwards LER 99-004-00 IAW 10CFR50.73 & 10CFR21.Further Assessment Will Be Provided in Suppl to LER by 990630 ML20206E7221999-04-29029 April 1999 Forwards Four Copies of Rev Q to Re Ginna Nuclear Power Plant Security Plan,Per 10CFR50.54(p).Changes Do Not Degrade Physical Security Effectiveness.Encl Withheld,Per 10CFR73.21 ML20206H6911999-04-22022 April 1999 Forwards Info Requested During Informal Telcon on 980408 Concerning Upcoming Osre at Ginna Station.Info Requested Listed.Without Encls ML17265A6271999-04-19019 April 1999 Forwards Rev 0 & Rev 1 to Colr,Cycle 28 for Re Ginna NPP, Per TS 5.6.5 ML17309A6501999-04-14014 April 1999 Forwards Revised Ginna Station EOPs & Procedures Index ML17265A6121999-03-29029 March 1999 Forwards Rept on Status of Decommissioning Funding for Re Ginna Npp,For Which Rg&E Is Sole Owner,Per 10CFR50.75. Data Presented Herein,Current as of 981231 ML17265A6041999-03-24024 March 1999 Forwards LER 99-001-00,IAW 10CFR50.73(a)(2)(ii)(B) & 10CFR21.Addl Analyses Are Being Performed to Support Future Cycle Operation & Supplemental LER Is Scheduled to Be Submitted by 990618 ML17265A5641999-03-0101 March 1999 Forwards Response to NRC 990217 RAI Concerning Changes to QA Program for Re Ginna Station Operation.Rg&E Is Modifying Changes Requested in 981221 Submittal.Modified QA Program,Encl ML17265A5671999-03-0101 March 1999 Forwards Application for Amend to License DPR-18,to Revise TSs Battery Cell Parameters Limit for Specific Gravity (SR 3.8.6.3 & SR 3.8.6.6).Supporting Tss,Encl ML17265A5551999-02-25025 February 1999 Informs That Util Is in Process of Revising fitness-for-duty Program,Developed in Accordance with 10CFR26.Util Will Continue to Use Dept of Health & Human Svcs Certified Test Facility for Majority of Tests During Yr ML17265A5561999-02-22022 February 1999 Forwards FFD Performance Data Rept for Six Months Ending 981231,per 10CFR26.71(d) ML17265A5451999-02-12012 February 1999 Forwards Simulator Four Year Certification Rept,Per 10CFR55.45(b)(5)(ii) ML17309A6491999-02-12012 February 1999 Forwards Ginna Station EOPs ML17265A5431999-02-0909 February 1999 Supplements 980806 Relief Request with Attached Table.Util Third 10-Yr ISI of Reactor Vessel Being Performed During 1999 Refueling Outage,Beginning on 990301 ML17265A5361999-02-0202 February 1999 Forwards Response to NRC 981203 RAI Re Resolution of Unresolved Safety Issue USI A-46.Util Does Not Agree with NRCs Interpretation.Detailed Bases,Encl ML17311A0691999-01-25025 January 1999 Forwards Revs to Ginna Station Emergency Plan Implementing Procedures (Epips).Previous Rev Had Incorrect Effective Date ML17311A0671999-01-14014 January 1999 Forwards Revised Emergency Operating Procedures for Re Ginna NPP ML17265A5131999-01-12012 January 1999 Forwards Revised Cover Page for Ginna Station Technical Requirements Manual (Trm), Rev 7,correcting Error in Effective Date ML17265A5111999-01-11011 January 1999 Requests Relief Per 10CFR50.55a(a)(3)(ii) from Certain Requirements of Section XI of ASME Bp&V Code for ISI Program.Relief Requests 37,38 & 39 Encl ML17265A5101999-01-11011 January 1999 Requests Relief Per to 10CFR50.55a(a)(3)(ii) from Certain Requirements of Section XI of ASME B&PV Code for ISI Program.Relief Request 40 Encl 1999-09-30
[Table view] |
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Westinghouse Energy Systems Box 355 Pinsburgh Pennsylvania 15230 0355 Electric Corporation March 31, 1993 CAW-93-436 Document Control Desk US Nuclear Regulatory Commission Washington, DC 20555 Attention: Dr. Thomas Murley, Director APPLICATION FOR WITHHOLDINGPROPRIETARY INFORMATIONFROM PUBLI DISCLOSURE
Subject:
"Responses to NRC Questions Regarding the Boron Concentration Reduction Program" at the R. E. Ginna Station
Dear Dr. Murley:
The proprietary information for which withholding is being requested in the above-referenced letter is further identified in Affidavit CAW-93-436 signed by the owner of the proprietary information, Westinghouse Electric Corporation. The affidavit, which accompanies this letter, 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 10 CFR Section 2.790 of the Commission's regulations.
Accordingly, this letter authorizes the utilization of the accompanying Affidavitby Rochester Gas and Electric Corporation.
Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-93%36, and should be addressed to the undersigned.
Very truly yours, N. J. Lip an ager Nuclear Safety & Regulatory Activities TJKitchen/cld cc: Kevin Bohrer/NRC (12H5) 930414019Z 'F30408 PDR ADOCK 05000244 P PDR
CAW-93-436 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF ALLEGHENY:
Before me, the undersigned authority, personally appeared Henry A. Sepp, 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:
Henry A. Sepp, Manager Strategic Licensing Issues Sworn to and subscribed before me this ~~ dey of , 1993 Notary Public
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CA W-93-436 (1) I am Manager, Strategic Licensing Issues, in the Nuclear and Advanced Technology Divisions, of the 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 rulemaking proceedings, and am authorized to apply for its withholding on behalf of the Westinghouse Energy Systems Business Unit.
(2) I am making this Affidavit in conformance with the provisions of 10CFR 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 the Westinghouse Energy Systems Business Unit in designating information 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 consideration 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 public. Westinghouse has a rational basis for determining the types of information customarily held in contidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. 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 competitive advantage, as follows:
073 I C-YJK.2:CU l 93
CAW-93-436 (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 constitutes 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 capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.
(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.
(f) "It contains patentable ideas, for which patent protection may be desirable.
There are sound policy reasons behind the Westinghouse system which include the following:
(a) The use of such information by Westinghouse gives Westinghouse 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.
073 IC-TJK-3:033193
CA W-93-436 (c) Use by our competitor would put Westinghouse at a competitive 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 competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.
1 (e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of 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 contidence and, under the provisions of 10CFR Section 2.790, it is to be received in contidence by the Commission.
(iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method 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 responses to the NRC regarding questions regarding the boron concentration reduction program, March 31 1993 for the R. E. Ginna Station being transmitted by the Rochester Gas and Electric Company (RGE) letter and Application for Withholding Proprietary Information from Public Disclosure, to Document Control Desk, Attention Dr. Thomas Murley. The proprietary information as submitted for use by the Rochester Gas and Electric Company for the R. E. Ginna Station is expected to be applicable in other licensee submittals in response to certain NRC requirements for justification of Boron Reduction Programs.
073iC-YJKA:033193
CA W-93-436 This information is part of that which will enable Westinghouse to:
(a) Provide documentation of the methods used for implementing boron reduction programs.
(b) Establish the applicable analytical technologies.
(c) Assist the customer in obtaining NRC approval.
Further this information has substantial commercial value as follows:
(a) Westinghouse plans to sell the use of similar information to its customers for purposes of meeting NRC requirements for licensing documentation.
(b) Westinghouse can sell support and defense of the technology to its customers in the licensing process.
Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar methodologies and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.
The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.
In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, OD I C-YJK.S:033193
CAW-93-436 having the requisite talent and experience, would have to be expended for developing analytical methods.
Further the deponent sayeth not.
Proprietary Information Notice Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval ~
In order to conform to the requirements of 10 CFR 2.790 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) contained within parentheses located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.790(b)(1).
CLD269: TJIGN0193
Copyright Notice The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.790 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection'notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document
'room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. The NRC is not authorized to make copies for the personal use of members of the public who make use of the NRC public document rooms.
Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.
CLD269: YJIGN01 93
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Westinghouse Class 3 Responses to NRC Questions Regarding the Boron Concentration Reduction Program Westinghouse Electric Corporation Engineering Technology Division P.O. Box 355 Pittsburgh, PA 152304355 o 1993 Westinghouse Electric Corporation, All Rights Reserved
Westinghouse Class 3 Summary of Conservatisms Removed from the R. E. Ginna 1985 Steamline Break Analysis I~ntr ducti n - The R. E. Ginna Steamiine Break analyses to support a reduction in the BAST boron concentration included several assumptions that were different than those made in the 1985 analyses.
These refined assumptions resulted from a closer working relationship between Westinghouse and Rochester Gas & Electric and a better understanding of the transient by both organizations.
Following is a summary of these revised assumptions that account for the differences in the final results of the 1985 and 1992 analyses.
Off- i e wer il ili - One of the overly conservative assumptions that was made in the 1985 analysis is with respect to the availability of off-site power. [
la,b.c Rea ivi F k efficien - A second methodology enhancement was made in the assumed reactivity feedback coefficients. LOFTRAN utilizes a point kinetics model, which uses reactivity feedback coefficients to calculate the kinetics conditions in the core. Steamline break transients initialized at hot zero power assume rodded reactivity feedback coefficients with an allowance for the most reactive Rod Cluster Control Assembly (RCCA) stuck in its fully withdrawn position. Steamline break transients initiated with the reactor at power typically assume End&f-Life (EOL) reactivity coefficients calculated assuming that all RCCAs are fully withdrawn which is the case with the.1985 analyses. For these analyses,[
Westinghouse Class 3 Main Feedwater Flow Rates -[
The final 1992 analyses resulted in less main feedwater flow delivered to the faulted steam generator prior to feedline isolation than was assumed in the 1985 analyses.
Auxiliary Feedwater Flow Rate -[
a,b,o
Westinghouse Class 3 Initial t m ener r Wa er Level - The uncertainty assumed on the steam generator water level when calculating the initial steam generator mass was reduced from 5% NRS to 3.5% NRS. This has the greatest impact on cases initiated at part power.
Steamline Check Valves -[
]s,b,o Safe In'ecti n Fl w Rates - The Safety Injection flow rates assumed in the 1992 analyses are slightly higher than those assumed in the 1985 analyses. This has a small effect since the purpose of the analysis was to reduce the boron concentration in the Safety Injection. The lower the SI boron concentration, the smaller the impact of changes in SI flow rates.
Mi ell n n inm n M 1 lm r v men - Since the 1985 analysis, improvements to the values of initial conditions and various containment heat removal systems have been supported by RG&E and have been taken credit for in the containment response model.
There have been significant improvements to the containment spray system. Spray flow per pump was increased from 1200 GPM to 1300 GPM per pump. Because two spray pumps are available for cases without a containment failure, the total spray flow increase was 200 GPM for these cases. The sprays become functional earlier in the boron reduction than the 1985 analysis due to a reduction in both the setpoint and delays. The sum of the spray setpoint plus pressure uncertainties has been decreased from 33.5 psig to 32.5 psig. The delay time from when the spray setpoint is reached to full operation of the sprays has been reduced from 35.5 seconds to 27.3 second with two spray pumps and 28.5 seconds with one spray pump.
Heat sinks. inside containment and the thermal physical properties of steel and concrete have been revised to be more complete and accurate, and therefore offer more heat removal than the heat sinks used in 1985. The properties of stainless steel have been included in the 1992 model. The previous analysis substituted carbon steel properties for stainless steel items.
In the 1992 analysis, the fan coolers were initiated on a safety injection signal when a safety injection signal was reached before the Containment High Pressure signal. This offered a small benefit for only the upstream double ended rupture cases, where the safety injection signal is reached less, than a second before the Containment High Pressure signal.
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