ML20005B500
| ML20005B500 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 06/13/1980 |
| From: | Anderson T WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | John Miller Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19277A024 | List: |
| References | |
| TASK-3.A.1.2, TASK-TM NS-TMA-2261, TAC-43091, TAC-46131, TAC-51292, TTAC-43091, NUDOCS 8107080303 | |
| Download: ML20005B500 (3) | |
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e Westinghouse Water Reactor Neeaneennoieg,omsion Electric Corporation Divisions go,333 PittsDurghPevsylvan 315233 June 13,1980 NS-TMA-2261 Mr. James R. Miller, Chief Special Projects Branch Division of Project Management U.S. Nuclear Regulatory Commission Phillips Building 7920 Norfolk Avenue Bethesda, Maryland 20014
Dear Mr. Miller:
Enclosed are:
1.
Forty (40) copias of WCAP-9725 (Proprietary).
2.
Twenty (20) copies of WCAP-9726 (Non-Proprietary).
Both reports are entitled, " Westinghouse Technical Support Complex."
Also enclosed are:
1.
One (1) copy of Application for Withholding Proprietary Information from public Disclosure, AW-80-32 (Non-Proprietary).
4 2.
One (1) copy of Affidavit, AW-80-32 (Non-Proprietary).
This report provides the functional and technical descriptions of the Westinghouse Technical Support Complex (TSC), that addresses certain re-quirements made by the NRC for improved in-plant procedures and pre-parations to cope with emergencies. The TSC design reflects the result of an intensive Westinghouse study of the plant from the perspective of the recommendations made by the NRC Lessons Learned Task Force following the TMI-2 incident.
The TSC contains a computer based data acquisition and display system which addresses the NRC requirements for a Safety Parameter Display System and Technical Support Center.
In addition, the TSC contains a Bypassed and Inoperable Status Indication System which addresses the retrofit of Regu-latory Guide 1.47.
Each of these systems draws from a common computerized data base with individual system CRT displays, human engineered for en-hanced effectiveness.
The same data base would be used to provide outputs for offsite data requirements such as the Emergency Operations Facility and Nuclear Data Link.
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Mr. James R. Miller June 13,1980 NS-TMA-2261 The following aspects of the Westinghouse design are highlighted for further NRC consideration:
1.
The systems comprisirig the TSC are not required for the safe shut-down of the plant.
They should be considered as operational aids, and as such, Westinghouse believes the advantages associated with a flexible compute
- based design are more important than providing a design that is lees useful, substantially more costly, or not available in the near-turm which could be seismically qualified.
Further, substantial cost and effort have been applied in providing qualified instrumentation on the plant control board to be utilized by the operator to bring the plant to a safe shutdown condition in the event of a seismic occurrence.
The Westinghouse design is thus not seismically qualified.
2.
Westinghouse believes that a fault tolera nt computer based archi-tecture with high reliability as a design goal is superior to a train oriented or single failure proof system.
The design documented in this report is being incorporated in the follow-ing plants and will be referenced in the utility submittals in response to certain NRC requirements resulting from the TMI-2 event:
1.
Sequoyah Units 1 and 2 2.
Watts Bar Units 1 and 2 3.
Donald C. Cook Units 1 and 2 4.
Virgii C. Summer 5.
Trojan This submittal contains proprietary information.
In conformance with the requirement of 10CFR Section 2.790, as amended, of the Commission's regulations, we are enclosing with this submittal an application for with-holding from public disclosure and an affidavit. The affidavit identi-fies the information sought to be withheld and sets forth the basis on which the information may be withheld from public disclosure by the Commission.
We expect that the non-proprietary version of this report, WCAP-9726, will be placed in the Public Document Room and identified as a Westing-house topical report.
Mr. James R. Miller June 13,1980 NS-TMA-2261 Correspondence with respect to the Westinghouse affidavit or application for withholding should reference AW-80-32 and be addressed to:
R. A. Wiesemann, Manager, Regulatory and Legislative Affairs, Westinghouse Electric Corporation, P.O. Box 355, Pittsburgh, Pennsylvania 15230.
Very truly yours, Q[/%kr
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/bek Enclosures cc:
R. J. Mattson S. S. Hanauer W. Minners
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se Pitts:g Pennsytvama 15223 June 13,1980 AW-80-32 Mr. James R. Miller, Chief Spe:ial Projects Branch Difision of Project Management U.S. Nuclear Regulatory Commission Phillips Building 7920 Norfolk Avenue Bethesda, Maryland 20014 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
SUBJECT:
WCAP-9725, " Westinghouse Technical Support Complex" (Proprietary)
REF: Westinghouse Letter No. NS " A-2251, Anderson to Miller, dated
. June 13,1980
Dear Mr. Miller:
This application for withholding is submitted by Westinghouse Electric 'Cor-paration (" 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 whicn is further identified in the affidavit acccmpanying this application.
The undersigned has reviewed the information sought to be withheld and is wthorized to apply for its withholding on behalf of Westinghouse, WRD, notification of which was sent to the Secretary of the Comission on April 19,1975.
The affidavit accompanying this application sets forth the basis on which the infor. attn may be withheld from public disclosure by the Commission and addresses w' ch specificity the considerations listed in paragraph (b)(4) of Section 2.730 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 bet withheld frem public disclosure in accordance with 10CFR Section 2.790 of the Commission's regulations.
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2-June 13,1980 Mr. James R. Miller AW-80-32
.I Correspondence with respect to this application for withholding or the accompanying affidavit should reference AW-80-32 and be addressed to the undersigned.
Very truly yours, q
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Robert A. Wiesemann, Manager Regulatory & Legislative Affairs
/bek Enclosure cc:
E. C. Shemaker, Esq.
Office of the Executive Legal Director, NRC 4
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l AW-80-32 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF ALLEGHENY:
Before me, the undersigned authority, personally appeared Robert A. Wiesemann, 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 avertents of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:
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u Robert A. !Oesemann, M3 nager Regulatory and Legislative Affairs l
Sworn to and subscribed befora me this < 3 day of c' e a 1980.
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(1)
I am Manager, Regulatory and Legislative Affairs, in.the Nuclear
'Techncicgy Division, of Westinghouse Electric Corporation and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld frem public dis-closure in connection with nuclear pcwer plant licensing or rule-making preceedings, and am authori:ed to accly for its withholding on benalf of the Westinghcuse Water React:r Divisiens.
(2)
I am making this Affidavit in conformance with the provisions of 10CF5 Secticn 2.790 of the Ccemission's regulations and in con-junction with the Westinghouse application for withholding ac-ccm anying this Affidavit.
(3)
I have personal knowledge of the criteria and precedures utili:ed by Westinghouse Nuclear Energy Systems in designating informaticn as a trade secret, privileged or as confidential cc merical or financial information.
(4) pursuant to the provisions of paragraph (b)(4) of Section 2.790 of the Ccamissien's regulations, the follcwing is furnished for consideraticn by t. e Cc= mission in determining whether the in-s font.ation sought to be withheld frcm public disclosure should be withheld.
(i)
The information scught to be withheld frcm public discicsure is cwned and has been held in confidence by Westinghcuse.
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I AN-80-32.
4 (ii)
The information is of a type custc=arily held in confidence by Westinghcuse and not custcmarily disclosed to the public.
Westinghcuse has a rational basis for determining the types of information custEmarily held in confidenc's by it and, in that connection, utili:es a system to determine wh,en and whether to hold certain types cf information in confidence.
The application of that system and the substance of that system constitutes Westingneuse policy and provides the
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rational basis required.
Under that system, informatien 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 cc.-
cetitive advantage, as follcws:
(a)
The information reveals the distinguishing ac;cets of
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a prccess (or ccmponent, structure, tool, metnod, etc.)
whers prevention of its use by any of Westinghouse's et 4petitors without license from Westinghouse consti-tutes a competitive econcmic advantage over other ccmpanies.
(b)
I't consists of supporting data, including test data, relative to a process (or ccmponent, structure, teol, method, etc.), the application of which data secures a ecmpetitive econcmic advantage, e.g., by optimization or improved marketability.
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_4, (c)
Its use by a compecitor would reduce his expenditure of resources or improve his' canpetitive pos'ition in the design, manufacture, shipment, installation, assurance,
of quality, or' licensing a similar product.
(d)
It reveals cos: or price information, prcduction cap-acities, budget levels, or ccamercial strategies of Westinghouse, its custcmers or suppliers.
(e)
It reveals aspects of past, present, or future West-inghouse or customer funded development plans and pro-grams of potential cdcrercial value to Westinghouse.
(f)
It contains patentable ideas, for which patent pro-
. tection 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 ecmpetitive advantage over its com-petitors.
It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.
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AW-80-32 5-(b)
It is infer =ation 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 cur competitor would put Westinghouse at a l
competitive disadvantage by reducing his expenditure of resources at our expense.
(d)
Each com;cnent of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage.
If competitors acquire components of proprietary infor-mation, any one component may be the key to the entire pu::le, thereby depriving Westinghouse of a ccmpetitive advantage.
(e)
Unrestricted disclosure wculd jeopardize the position of prcminence of Westinghcuse in the world market, and thereby give a market advantage to the competition in those countries.
(f) The Westinghouse capacity to inve:t corporate assets in research and development depends upon the success in obtaining and maintaining a~ competitive advantage.
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. AW-80-32 (iii) 'The information is being transmitted to the Commission in
. confidence and, under the provisions of 10CFR.Section 2.790, it is to be received in confidence by the Commission.
(iv) The information sought to be protected is not available in public sources to the best of our knowledge and belief.
(v) The proprietary information sought to be withheld in this sub-mittal is that which is appropriately marked in WCAP-9725,
" Westinghouse Technical Support Complex," (Proprietary),
being transmitted by Westinghouse letter No. NS-TMA-2251, Anderson to Miller, dated June 13, 1980. This report is 4
being submitted pursuant to the NRC's Topical Report Program for generic review by the Regulatory Staff cnd is expected to be referenced in several licensee and applicant submittals in response to certain NRC requirements resulting from the TMI-2 event.
This information is part of that which will enable Westing-house to:
(a) Apply for patent protection.
c (b)
Optimize control room operator and technical support personnel man-machine interface designs and criteria.
(c) Assist its customers to obtain NRC approval.
(d) Justify the design basis for the Technical Support Complex functions and inputs.
. AW-80-32 Further this information has substantial ccmercial value as follows: '
(a) Westinghouse plans to sell the system design and equip-
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ment described in part by the information.
(b) Westin'ghcuse plans to sell the use of the information to its customers for purposes of meeting NRC requirements for licensing documentation.
(c) bestinghouse can sell testing services based upon the experience gained and the tent equipment and methods Jevel =ed.
Public disclosure of this infomation is likely to cause
. substantial ham to t!.a competitive position of Westinghouse because (1) it would result in the loss of valuable patent rights; and (2} it' would enhan'ce the ability of competitors to design, manufacture, verify, and sell electrical equipment for commercial power reactors withcut comensurate expenses.
Also, public disclosure of the information would enable others' having the same c 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 infomation 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.
_ AW-80-32 In order for competitors of Westinghouse to duplicate this information, similar engineering programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended for system design software development.
Further the deponent sayeth not.
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