ML17331A682
| ML17331A682 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 03/31/1981 |
| From: | Hunter R INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.2, TASK-TM AEP:NRC:0398D, AEP:NRC:398D, NUDOCS 8104060551 | |
| Download: ML17331A682 (14) | |
Text
REGULATOR INFORMATION. DISTRIBUTION S
EM (RIDS)
ACCESSION NBR;8104060551 DOC ~ DATE! 81/03/31 NOTARIZED: YKS DOCKET FACIL:5 onal d C+
Cook Nuclear Power Pl antr Unf t 1r Indi ana L
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ARE-AUTHOR AFFILIATION HUNTERrR ~ ST Indiana L Mfchfgan Electric Co, RECIP ~NAME'ECIPIENT AFFILIATION DENTONEH ~ RE Offf ce of Nuc 1 ear Reactor Regul atf one Df r actor SUBJECT!. For wards info fn response to NUREG 0737r Item II~ P 2
r e r eactor. vessel level instrumentation sys,Util 801223 proprietary r ept appl fes to facf1 f ties,Application for wfthholdfng proprietary fnfo L affidavit encl.
DISTRIBUTION CODE:
ROOSE COPIES RECEIVED:LTR J ENCL J, SIZE:jg TITLE'. Response to NUREG 0737/NUREG>>0660 TMI Action Plan Rgmts'OL's)
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INDIANA L MICHIGAN ELECTRIC COMPANY P. O.
BOX 18 BOWLING GREEN STATION NEW YORK, N. Y. 10004 March 31, 1981 AEP:NRC:0398D Donald C.
Cook Nuclear Plant Unit Nos.
1 8
2 Docket Nos.
50-315 and 50-316 License Nos.
DPR-58 and DPR-74 NUREG-0737, ITEM II F.2 REACTOR VESSEL LEVEL INSTRUMENTATION SYSTEM Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission,.
Washington, D.
C.
20555
Dear Mr. Denton:
1'~ I
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~
The enclosed information is being submitted to you in response to Item II F.2 of NUREG-0737 (Instrumentation for Inadequate Core Cooling) and in accordance with the commitments made in our letters of January 8,
1981 (AEP:NRC:0398) and March 6, 1981 (AEP:NRC:0398E).
Westinghouse has submitted to the NRC via letter No.
NS-TMA-2357 dated December 23, 1980 proprietary and non-proprietary copies of a report
- entitled, "Summary Report, Westinghouse Reactor Vessel Level Instrumentation System for Monitoring Inadequate Core Cooling (7300 System),
- December, 1980."
Except for the few differences discussed in Attachment 1 to this letter, the subject report can be considered as applicable to the Donald C.
Cook Nuclear Plant.
As this report contains information proprietary to Westinghouse Electric Corporation, Attachment 2 to this letter contains an application for withholding proprietary information from public disclosure and an affidavit signed by Westinghouse.
The affidavit sets forth the basis on which the in-formation 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.
Mr. Harold R ~ Denton AEP:NRC:0398D Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.790 of the Commission's regulations.
Correspondence with respect to the proprietary aspects of this application for withholding or the supporting Westinghouse affidavit should reference CAW-80-75 and should be addressed to R. A. Wiesemann,
- Manager, Regulatory and Legislative Affairs, Westinghouse Electric Corporation, P. 0.
Box 355, Pittsburgh, Pennsylvania 15230.
Very truly yours, ii.
'S.'Hunter Vice President cc:
John E. Dolan (w/o attachment)
R.
C. Callen (w/o attachment)
G. Charnoff (w/o attachment)
R.
W. Jurgensen (w/o attachment)
D. V. Shaller Bridgman NRC Resident Inspector at Cook Plant - Bridgman
ATTACHMENT 1 TO AEP:NRC:0398D The following lists our exceptions to the Westinghouse report entitled, "Summary Report, Westinghouse Reactor Vessel Level Instrumentation System for Monitoring Inadequate Core Cooling (7300 System),
- December, 1980 (Proprietary)" in order that it be applicable to the Donald C.
Cook Nuclear Plant:
1.
The last sentence of Item f on pages 3-2 under Section 3.0 entitled
" ICC Instrumentation Identification" should be deleted.
2.
Table 3.1 entitled
" Information Required On The Core Subcooling Monitor" on pages 3-3 and 3-4 should be deleted.
Relevant information pertaining to these two deletions is contained in our letters identified as AEP:NRC:00253B dated December 19,
- 1979, AEP:NRC:00346 dated January 30,
- 1980, and AEP:NRC:00334B dated March 10, 1980.
3.
The paragraphs entitled "Vessel Liquid Density Calculation",
"Vessel Vapor Phase Density Calculation",
"Vessel Level Calculation and Pump Flow d/p Calculation" on pages 4-7 and 4-8 are currently being revised by Westinghouse with respect to RCS hot leg RTD temperature inputs.
Westinghouse will address this information directly to the NRC.
ATTACHMENT 2 TO AEP:NRC 0398D APPLICATION AND AFFIDAVIT FOR WITHHOLDING OF PROPRIETARY INFORtQTION
Westinghouse Electric Corporation Water Reactor Divisions Nuclear Technology Oivision Sox 355 Pittsburgh Pennsylvania 15230 December 23, 1980 CAW-80-75 Mr. Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Phillips Building 7920 Norfolk Avenue
- Bethesda, Maryland 20014 ATTN:
Lawrence E. Phillips Core Performance
- Branch, DSI
- APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
SUBJECT:
Summary Report, Westinghouse Reactor Vessel Level Instrumentation System for Monitoring Inadequate Core Cooling (7300 System),
December 1980 REF:
NUREG-0737 Part II.F.2, Instrumentation for Inadequate Core Cooling
Dear Mr. Eisenhut:
The proprietary material transmitted by the referenced letter supplements the proprietary material previously submitted concerning the Westinghouse development of ECCS models.
Further, the affidavit submitted to justify the material previously submitted, AW-77-18, was approved by the Commission on October 28, 1977, and is equally applicable to this material.
Accordingly, withholding the subject information from public disclosure is requested in accordance with the previously submitted affidavit and appli-cation for withholding, AW-77-18, dated April 6, 1977, a copy of which is attached.
Correspondence with respect to -this application for withholding or the accompanying affidavit should reference CAW-80-75, and should be addressed to the undersigned.
Very truly yours,
/bek Attachment Robert Ai
- iesemann, Manager Regulatory 5 Legislative Affairs cc:
E.
C. Shomaker, Esq.
Office,of the Executive L'egal Director, NRC'
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97 AM-77-18 1
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t AFFIDAVIT CQt'li'>OH'lEA TH QF PE['(tlSYL AilIA:
COUNTY OF ALLEGHENY:
ss Before me, the undersigned authority, personally appeared Robert-A. >li'esemann, who, being by me duly sworn according to law, de-poses and says that he is authorized to execute this Affidavit on behalf of Mestinghouse Electric Corporation
("Westinghouse")
and that the aver-ments of fact set forth in this Affidavit are true and correct to.the best of hi s knowl edge, informati on, and bel ief:
Robert A. 'yliesemann, i",an ger Licensing Programs Sworn to and subscribed before me this rJ 0 day 7 ~i r 1977.
/
A..:i"y!~.:
ri!S'e'~
( Notary Public a ~3lC Ail-77-18 (1)
I am Manager, Licensing Programs, in the Pressurized Water Reactor Systems Division, of Westinghouse Electric Corporation and as such, I have been specifically delegated the function of reviewing the I
proprietary information sought to be 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 Westinghouse Water Reactor 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 l/estinghouse application for withholding ac-companying this Affidavit.
(3)
I have personal knowledge of the criteria and procedures utilized
. 'by Westinghou".",
lu.-.'..".- -"..";---".Systems in designating inforration 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 in-formation sought to be withheld from public disclosure should be withhel d.
(i)
The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.
&3 AH-77-18 (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 confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence.
The ap-plication of that system and the substance of that system constitutes Mestingnouse 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 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'ompetitive economic advantage, e.g.,
by optimization or improved marketability.
AH-77-18 (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 cap-
- acities, budget levels, or commercial st1 ategies of Westinghouse, its customers or suppliers.
(e) It reveals aspects of past,
- present, or future West-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 oe aesirable.
(g) It is not the property of Westinghouse, but must be treated as proprietary by Westinghouse according to agreements with the owner.
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 com-petitors.
It is, therefore, withheld from disclosure to protect. the Hestinghouse competitive position.
AH-77-1S (b) It is information which is marketable in many ways.
The extent to which such information is available to competitors diminishes the flestinghouse ability to sell products and services involving the use of the information' (c)
Use by our competitor would put l estinghouse at a
competitive disadvantage by reducing his expenditure of resources at our expense.
I'd)
Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage.
If competitors acouire components of proprietary infor-
- mation, any one co'mponent may be the key to the entire
- puzzle, thereby depriving 'lestinghouse of a competitive advantage.
(e)
Unrestricted disclosure would jeopardize the position of prominence of Mestinghouse in the world market, and thereby give a market ad.'antage to the competition in those countries.
(f)
The klestinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.
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Nl ) b (iii)
The information is being transmitted to the ommission in confidence
- and, under the provisions of 10 C"i2 5 ction 2.790, it is to be received in confidence by the Cor::.;-.ission.
(iv)
The information is not available in public sources to the best of our knowledge and b lief.
(v)
The proprietary information sought to be withheld in this submittal is that which is attached to hesiii:,house Letter Number HS-CE-1403, Eicheldinger to Stolz, date: April 6, 1977.
The letter and attachment are being s.:h'..itt d in support of the kestinghouse emergency core cooling system evaluation model.
Public disclosure of the information sought
+o be witbh
'1d is likely to cause substantial harm to the corn; titive position of Westinghouse, taking into account he value of the information. to llestinghouse, the amount o" effort and money expended by tlestinghouse in developing the information, and considering the ways in which the information could be acquired or duplicated by others.
Further the deponent sayeth not.
0 0'