ML19310E611
| ML19310E611 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 01/15/1991 |
| From: | Dipiazza R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19310E612 | List: |
| References | |
| CAW-91-117, NUDOCS 9102150048 | |
| Download: ML19310E611 (11) | |
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l Westinghouse Energy Systems Bm 355 Electric Corporation numa nnnena 1523n35s r
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January 15, 1991 CAW-91-117
' Document Control Desk US Nuclear Regulatory Commission Washington, DC 20555 r
Attention: Dr. Thomas Murley, Director 4
APPLICATION FOR WITHHOLDING PROPRIETARY-INFORMATION FROM PUBLIC DISCLOSURE r
Subject:
Proprietary Report PFE-G22, "Sequoyah Nucle'ar Plant, Unit 2 Cycle 5 Restart Physics Test"
Dear Dr. Murley:
The proprietary information for which withholding is being' requested in the above-referenced letter is further identified in Affidavit CAW 91-117 signed by 1
the owner of the proprietary information, Westinghouse Electric. corporation.
l The affidavit, which ac-ompanies 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.
l Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Tennessee Valley Authority.
Correspondence with respect to the proprietary aspects of.the application for withholding or the Westinghouse affidavit should reference this letter, CAW-91-117, and should be addressed to the undersigned.
Very truly yours, l
O' R. P. DiPiazza, Ma Enclosures Operating Plant Licensing Support ec:
C. M. Holzle, Esq.
Office of the General Counsel, NRC 1
l V. Wilson (NRR)
(FOR GENERIC SUBMITTALS ONLY) i i
i
3 CAW-91-ll7 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
i ss COUNTY OF ALLEGHENY:
Before me, the undersigned authority, personally appeared Ronald P. DiPiazza, who, oeing 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:
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Ronald P. DiPiazza, M k r Operating Plant Licensing Support Sworn to and subscribed befo7,e me this /h day of I'//wt nu,1991.
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(culthtL kk'n14lu -
Notary Public tunwsad ppm G5trtA ttf3/O ll h $tY 0 A'
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l I CAW-91-117 7
1 (1) I am Manager, Operating Plant Licensing Support, in the Nuclear and Advanced Technology Division, 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.
(4) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.
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I CAW-91-117 l
l (ii) The information is of a type customarily held in confidence by l
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 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:
(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.
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. CAW-91-117 (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 4
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 Uestinghouse or.
customer funded development plans and programs ot' potential commercial value to Westinghouse.
(f)
It contains patentable ideas, for which patent protection 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.
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,1 withheld from disclosure to protect the Westinghouse competitive position.
i
. CAW-91-ll7 (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 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.
(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.
1 (f) The. Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.
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! CAW-91-177 I
(iii)
The information is being transmitted to the Commission in confidence and, under the provisions of 10CFR Section 2.790, it I
is to be received in confidence by the Commission.
i (iv)
The information sought to be protected-is not available in public j
sources or available information has not been previously employed l
in the same original manner or method to the best of our knowledge and belief.
l, (v)
The proprietary information sought to be withheld in this submittal is that which is appropriately marked in "Sequoyah _
Nuclear Plant, Unit 2 Cycle 5, Restart Physics Test Summary",
Report PFE-G22 (Proprietary), for Sequoyah Nuclear Plant, Unit 2, f
l being transmitted by the Tennessee Valley Authority (TVA) letter and Application for Withholding Proprietary Information from Public Disclosure, E. G. Wallace, TVA, to Document Control Desk, Attention Dr. Thomas Murley, January,1991. The proprietary i
information as submitted for use by Tennessee Valley Authority for Sequoyah Unit 2 is expected to be applicable in other licensee submittals in. response to certain NRC requirements for justification of. Restart Physics testing.
l Inis icformation is part'of that which will enable Westinghouse to:
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l CAW-91-117 t
(a)
Preclude competitors obtaining an indication of methodology comparison against plant measurements.
(b)
Preclude competitor from obtaining cycle specific design information based on advanced methodology.
(c) Assist the customer to obtain 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.
l (b) Westinghouse can sell support and defense.of the technology.
to its customers in the licensing process.
l 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 analytical documentation and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would L
enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.
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! CAW-91-117 i
I The development of the technology described in part by the j.
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.
I In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisito talent and experience, would have to be expended for system design,. analytical techniques and performing tests and evaluations.
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Further the deponent sayeth not.
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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.
f In order to conform to the requirements of 10 CFR 2.790 of the Commission's-I regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is i
contained within brackets, and where the proprietary information has been I
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 i
designated as proprietary is indicated in both versions by means of lower case i
letters (a) through (g) 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 informe ion.
These n
lower case letters refer to the types of information Westinghous
- ustomarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(g) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.790(b)(1).
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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-l 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, I
copyright protection not withstanding.
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 l
insufficient fo.- this purpose. The NRC is not authorized to make copies for I
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.
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Table 2.1 Sequoyah Unit 2, Cycle 5 Chronology of Startup Physics Tests' Test EAD i
Initial Criticality November 12, 1990 Boron Endpoint - ARO November 12, 1990 Isothermal Temperature Coefficient - ARO November 13, 1990 Bank D Worth - Dilution Method November'20,'1990 Rod Swap November 20, 1990 Flux Map at 30% Power November-27, 1990 Incore-Excore Calibration at 30% Power November.28, 1990-
/
Flux Map at 70% Power December 2, 1990 Flux Map at 100% Power December 8, 1990 i
9,
Table 2.2 Sequoyah Unit 2, Cycle 5 Significant Events Summary (Item numbers referenced on Figures 2.1 and 2.2) 1.
Reactor critical.
Low-power physics testi.1g in progress.
2.
Holding at 4 percent (N-44 at 4 percent).
3.
Initiated power increase to greater than 5 percent.
4.
Online.
U2C4 refueling outage ends.
5.
Reactor power level at 24 percent.
{
6.
Initiated increase to 30 percent reactor power.
7.
Unit 2 reactor power level now'30. percent.
8.
Holding at 30 percent power.
9.
Reactor trip / turbine trip on lok pressurizer pressure, entered Mode 3.
- 10. Initiated power increase to greaner:than 5~ percent.
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- 11. Reactor power level at 10 percent.'
Holding at 10 percent.
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because of various alarms received'due to ground somewhere in the system.
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- 12. Increasing power to 15 percent.'.
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- 13. Reactor power level at 15 percent.
- 14. Online.
Increasing power.
- 15. Reactor power level at 30 percent.
Holding at 30 percent power for performance of TI-2, " Calorimetric Calculation -
Units 0,1, and 2."
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- 16. SI-78 completed.
NIS adjusted upward in power to 32.4 percent.
- 17. Reactor power level at 32 percent, holding for 32 percent
' flux map.
- 18. Initiated increase to 35 percent reactor power.
- 19. Unit 2 at 35 percent reactor power as' indicated by delta T,
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PRM at 33 percent.
- 20. Began increasing power to 40 percent.
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- 22. Reactor power level at 50 percent and holding for SI-44,
" Axial Flux Difference - Units l'and 2," and SI-133,
" Quadrant Power Tilt Ratio - Units 1 and 2."
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- 23. Resumed Unit 2 power level increase from 51 percent.
- 24. Terminated power 1.evel increase because of No. 7 HDTP 5
discharge FCV-6-190 erratic cycling.
No. 3 HDTP LIC-6-106 is malfunctioning and will not control level.
WR initiated.
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- 25. Reactor power level at approximately 61 percent, 692 MWe, 2019 MWt.
- 26. Reactor power level at approximately 61 percent, 692 MWe, 2019 MWt and increasing.
- 27. Reactor power level at 75 percent highest delta T, 841 MWe, 2341 MWt.
- 28. Completed performance of SI-78, PRI reset to 71.5 percent i
indicated value.
Began unit load increase to 75 percent 1
l reactor power level.
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- 29. Initiated increase to 90 percent reactor power level.
- 30. Reactor power level at 80 percent NIS.
- 31. Reactor power level at 90 percent NIS,'91 percent delta T.
- 32. Began increase to'100 percent reactor power level.
- 33. Terminated power increase.
Loope 1-4 delta T is at 100
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i 3.0 Core Reload Summarv Af ter cotapletion of all prerequisitos, the cycle 4 core offload commenced on September 21, 1990.
The core offload was completed on September 23, 1990.
Figure 3.1 depicts the cycle 4 core configuration prior to the fuel shuffle.
The core configuration for cycle 5 is shown in Figure 3.2.
The neutron count rate was monitored throughout core load as a precaution to ensure that core loading proceeded as planned.
This monitoring was accomplished by utilizing the permanent excore source range detectors.
Neutron count rate was monitored at specified intervals for each detector.
Continuous plots of inverse count rate ratio were maintained to ensure an orderly and safe core loading.
Due to the grid strap damage identified during the fuel inspection, additional administrative controls were imposed on several fuel assemblies during core loading.
Upon completion of core reload, core verification was performed.
The fuel assemblies and inserts were independently verified to be in their correct location according to the unit 2, cycle 5 core loading pattern.
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