ML20006B489
| ML20006B489 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 05/09/1988 |
| From: | Wiesemann R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | Murley T Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML100331190 | List: |
| References | |
| CAW-87-041, CAW-87-41, NUDOCS 9002020291 | |
| Download: ML20006B489 (10) | |
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t ATTACHMENT D-MATERIAL RELStING TO PROPRIETARY ASPECTS l
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CONSOLIDATED EDIS0N COMPANY OF NEW YORK, INC.
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' INDIAN POINT UNIT'NO. 2 DOCKET NO. 50-247
' JANUARY, 1990;
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1 Westinghouse Power Systerns gll,j,yber 1
Electric Corporation u
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- Pmsbutgh Pennsylvania 15230 0355 -
J l-j May 9, 1988 ChW-87-041 Mr. 'Dxanas Wrley,: Director
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office of Nuclear Reactor Regulation U.S. Nuclear Regulatory tweni== ion -
Washington,4D.C. 20555 APPLIch27W POR WI'D90GENG PR:PRIETh10f INPWMA2TW FBCM PUE*lC IEBCLOSURE
Subject:
WChP-11811." Indian Point Unit 2 'Daba Fatigue Evaluation"-
(Proprietary), and WChP-11812 " Indian' Point Unit 2 'habe i
Fatigue Evaluation" (RL-Lup.istary).
Dear nr. m riey,
1
'Ihe proprietary informatico for ei& withholding is'being requested in the enclosed letter by consolidated M% is further identified in~ an..
affidavit signed by the owner of the proprietary information, Westinghouse Electric hr.. tion.. 'Iha affidavit, ei&' mnies this letter, sets forth the basis on eid the informatics) any be withheld i
fran public disclosure by the rw=ni== ion and addresses with specificity.
J the considerations listed in peg..yss.(b)(4) of 10CER Section 2' 790 of-the h i== ion's regulations.:
'Ihm proprietary material for ei& withholding is being required is of j
the same technical type as that proprietary antarial' previously.
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sutanitted as Affidavit ChW-81-079.'
Accordingly, this letter authorizes the ut 414*ation.of the accxmpanying~
affidavit by cannolidated Edison.
L r.4Es with respect to the proprietary aspects of the ;
application for' withholding or the Westinghouse affidavit shouldl
.j reference this -letter, ChW-88-041,. and should be addressed to the undersigned.
y yours, x
A Regulatory & Iagislative Affairs g
._q cc:- E. C. Shcznakar, Esq.
Office of the Escacantive Imgal DiIstwx, NRC l
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PROPRIEIARY INIWMATICN NOTICE j
TRANSMITTED HERDCIH ARE PROPRIEIARY AND/OR NN-PROPRIEIARY VERSIONS OF DOCUMENDS FURNISHED 10 2HE NRC IN CONNECTICH WHH REQUNTS FOR GENERIC
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AND/CR PIANT SPECIFIC REVIEW AND APPROVAL.
IN ORIER TO CONFORM 70 7HE REQUIRDENIS OF 10CFR2.790 OF THE CDMISSION'S REGUIATIONS CONCERNING THE PRCTTECTION OF PROPRIETARY INPCRMATION SO SUIMIITED 70 2HE NRC, 2NE INIUMATION WHIm IS o
190PRIEIARY IN THE 190PRIEIARY VERSIONS IS CONIAINED WITHIN BRACKETS AND WHERE THE PROPRIEIARY INPMMATION HAS BEEN EEIETED IN 7EE
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NON-PROPRIEIARY VERSIONS ONLY THE BRACKEIS RD9JN, THE 4
INFWMATION THAT WAS CONTAINED WTIHIN THE. BRACKETS IN THE PROPRIETARY--
VERSICNS HAVING BEEN DEIETED. THE JUSTIFICATION FOR CIAIMING THE INFWMATION SO DESIGNATED AS PROPRIEIARY IS INDICATED IN BOIH VERSIONS BY MEANS OF IDWER CASE IETIERS (a) THROUGH (g) CCNTAIIED WIIHIN n
PARENIHESES IDCATED AS A SUPERSCRIPT DMEDIATELY POIIDWING THE MACKETS l
e DKIDSING EACH ITIM OF INPWMATION BEING IIENTIFIED AS PROPRIEIRRY OR IN THE MARGIN OPPCSITE SUG INPUWkTION. THESE IDWER CASE IETIERS REFER 70 THE TYPES OF INEMMATION WESTIN3CUSE WS7 WARILY HOIm IN CONFIIENCE IIENTIFIED IN SECTIONS (4)(11)(a) THROUGH (4)(ii)(g) OF THE AFFIDAVIT 1
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ACOMPANYING THIS TRANSMITIAL PURSUANT TO 10CPR2.790(b)(1).
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CAW-81-79 AFFIDAVIT y
C0m0NWEALTH OF PDOtSYLVANIA:
i ss COUNTY OF ALLEGHENY:'
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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-j behalf of Westinghouse Electric Corporation (" Westinghouse") and that l
the averments of fact set forth in this-Affidavit are true and correct to the best of his knowledge. infomation..and belief:
_h____//cAAM Robert A. Wiessmann Manager Regulatory and Legislative Affairs Sworn to and subscribed before me this a day of D w la_ 1981.
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r'.AhNotary Pub.ijk.[
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- CAW-81-79 9
(1) I am Hamager, Regulatory and Legislative Affairs, in the Nuclear
' Technology Division, of Westinghouse Electric Corporation and as such, I have been-specifically delegated the function of reviewing the proprietary information sought to be withheld from public dis-
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closure in connection with nuclear power plant licensing orl 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' F
10CFR Section 2.7g0 of the Coenission's regulations and in con-junction with the Westinghouse application for withholding ac -
j companying-this Affidavit.
y (3) I have personal knowledge of the criteria'and' procedures utilized by Westinghouse Nuclear Energy Systems.in designating ~informstion-as a trade secret,' privileged or as confidential connercial or
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financial information.
l Pursuant.to the provisions ef paragraph (b)(4) of.Section 2.7g0 i
(4) of the Connission's regulations, the:following is. furnished for consideration by.the Cosnission in determining whether.the in-fomation-soughtito be withheld from public disclosure should be I
withheld.
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1' (1)-Theinformationsought.to'bewithheldfrompublicdisclosure l~
is owned and has been held in confidence by Westinghouse.
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(ii) The infomation is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public.
Westinghouse has a rational basis for detemining the. types of infomation customarily held'in confidence by it and, in that connection, utilizes a system to~detemine when.and t
whether to hold certain types of.infomation in confidence.
l The application of that system and the substance of that-system constitutes Westinghouse policy and provides the-rational basis required..
f Under that system. infomation is held in confidenceLif 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 proces's (or component, structure.ctool.-method. etc.)
where prevention of its use by any of Westinghouse's'-
competitors without license from Westinghouse consti-l
- tutes a competitive economic advantage.over-other '
l companies.
(b)
Itconsistsofsupportingdata.includihg;testdata, relative to a process -(or component', structure.' tool.
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method. etc.). the application of which data secures n' t
l competitive economic advantage. e.g..'by optimization:
- or improved marketability.
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. CAW-81-7g (c) Its use by 'a competitor would reduce his expenditure.
of resources or improve his ccapetitive position in the design, annufacture, shipment. installation, assurance of_ quality, or licensing a steilar product.
(d) It reveals cost or price information, production cap-acities, budget levels, or. commercial strategies of
- Westinghouse. _its customers or suppliers.
(e) It reveals espects'of past, present. or future West-inghouse or customer funded development plans and pro-grans of potential commercial value to Westinghouse;--
(f) It contains patentable ideas, for which patent pro-
- j tection may be desirable.
(g) It is not the property of Westinghouse. but.aust be treated as proprietary by Westinghouse according toL agreements with the owner, j
There are sound policy reasons behind the Westinghouse' system which include the following:'
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- 1 (a) The use of such information by Westinghouse-gives 1
Westinghouse;a ccapetitive' advantage over'its ccm-petitors. It is. therefore, withheld Lfmm disclosure -
to protect the Westinghouse' competitive position.
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(b) It is inforsetion which is sarketable in many ways.
The extent to which such infomation is available to competitors _ diminishes the Westinghouse ability to.
sell. products and services; involving the use of the infomation.
(c) Use by our competitor would put Westinghouse a't a scapetitive disadvantage by reducing his expenditure of m sources'at our expense.
(d) Each component of proprietary infomation pertinent to a particular competitive advantage is potentially-
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as valuable as the total competitive advantage. LIf competitors-acquire components of proprietary infor-
.antion, any one component may be the key to the entirei puzzle, thereby depriving Westinghouse-of. a ecupetitivei advantage.
(e) Unrestricted disclosure would'jeopardiae the position-of prominence of Westinghouse in the world market.3 and thereby give a market advantage to.the competition in those countries.
(f) The Westinghouse capacity to invest corporate assets in msearch_and development depends upon the success in obtaining and maintaining a competitive advantage l
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(iii) The infomation is being transmitted to the Comission in confidence and. under the provisions of 10CFR Section 2.7g0.
L it is to be received in confidence by the. Commission.
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l (iv) The information sought to be protected is not available in public sources or available infomation has not been. pre-
,l l-viously employed in the same original manner or method to the best of our' knowledge and; belief.
4 (v) The proprietary information' sought to be withheld in this submittal is that which is appropriately marked in ' Steam Generator Tube tlugging Margin Analysis" for the Virgil C..
Sumer Nuclea'r Power plant Unit No.- 1. WCAp-9g12. Revi-i sion2.(Proprietary)beingtransmittedbySouthCarolina.
Electric and Gas Company letter Application for Withholding-j Proprietary Infomation from Public-Diselosure. Nichols ~to -
Denton November 1981. The proprietary infomation as sub-'
a sitted for South Carolina Flectric and Gas Company. Virgil C.
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Sumer Nuclear Station use is' expected to'be applicable in 3
other licensee and applicant submittals in response to'cer-tain NRC. requirements.for. jus'tification of the' steam generator tube plugging margin; 1-This infomation is part of that which w111' enable Westing-house to:
(a) Provide doceentation of the analyses, method'and test-ing for detemining plugging margin.
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CAW-81-79 (b)' Establish the minimum wall thickness in. compliance with Regulatory Guide 1.121..
(c) Establish the stress limits versus thinning of the remaining tube well.
(d) Establish the maximum allowable Isakage in support of the leak-befote-break criterie.
L (e) Assist the customer to obtain NRC approval.
Further this information has substantial commercial value:
as follows:.
(a) Westinghouse plans'to sell similar inforwation;to its customers for purposes of meeting NRC requirements forl licensing documentation.
- (b) Westinghouse can sell support and defense of the: tech--
nology to its customers in the licensing process.
Public disclosure of this information-is likely to;cause substantial harm to the competitive position ef Westinghouse'
- because it would enhance the ability of competitors:to. pro--
vide similar entlytical documentation and licensing defense.
services for commercial power mactors without commensurate expenses. Also public disslosure of the information would enable others to use the information to meet istC require-monts for licensing documentation without purchasing,tho right to use the information'.
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l The development of the technology described in part by the infomation is the result of applying the results of many yeam of experience in en. intensive Westinghouse effort -
.and the expenditure of a considerable ska of money.
1 In order for competitors of.6:estinghouse to duplicate this-1 information, steilar technical; programs would have to be performed and a significant aanpower' effort. having the-:
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j requisite talent and experience..would have to be expended-for system design software development.
Further the deponent'sayeth not.
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L Stephen 5. Srem '
I Woe Presulwu Consohdat4 Edison Company of New York, Inc.
Indian Poen! Stahon Arcadway & Beakley Avenue January 19,-1990 Bar.har an. NY 10511
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Ret Indian Point Unit No. 2
.I Docket No. 50-247 d
Document Control Desk US Nuclear Regulatory Commission Mail Station F1-137 Vashington, DC 20555 SUBJECT Request for Additional Information Regarding ImplementatJon'of Bulletiu 88-02~(TAC No. 67310) l This Actter is in response-to your request for additional information-regarding the implementation of Bulletin 88-02,. " Rapidly Fropagating Fatigue.
Cracks in Steam Generator Tubes.t' = The request was-transmitted by letter dated November 6,
1989.
Our original response to the' Bulletin was transmitted to yeu by letter dated March 25, 1988..You requested that ve:
provide the informacion within 60 days of your letter, which we received on November 20, 1989.
Accordingly, Attachment A to this letter contains our response to the additional information requested'under Item 1 (Enclosure 1 of your-letter).
In response to the additional information requested-~under Item 2,. enclosed as Attachment B and C respectively, ares.
One (1) copy of WCAP-11811,
" Indian Point Unit 2 Evaluation lfor Tube Vibration Induced Fatigue" (proprietary), May 1988.
One (1) copy of VCAP-11812,
" Indian' Point Unit 2 Evaluation for Tube Vibration Induced Fatigue" (non-proprietary), May 1988.
l Attachment' D is a Vestinghouse--authorization letter ~ (CAV-87-041), a proprietary-Information Notice, and an accompanying affidavit.
Since proprietary ellaims as to Attachment B are asserted by Westinghouse Electric Corporation.,
those -claims -are' supported by an affidavit signed ;by.
Westinghouss The affidavit. sets'forth the. basis on which -Vestinghouse l
claims that the information may be withheld from public disclosure by the' l-Commiselon, and addresses the considerations listed in' 10 CFR -Section l
2.790(b)(4).
Accordingly, it is respectfelly requested that' Attachment B, or. in the alternative such portions of Attachment B' as the Comr.ission determines to be protected by 10 CFR Section'2.790 as proprietary to-y Westinghouse, be withheld from public disclosure.ini accordance.vith the-l Commission's regulations.
Correspondence with respect to the proprietary l
aspects of the Application er, Withholding or the supporting Westinghouse 4
affidavit should refer to (CG-87-041)- and'should be addressed to R.A.
I Viesemann, Manager, Regulatory and Legiclative-Affairs, Vestinghouse L
Slectric Corporation, P.O. Box 255, Pittsburgh, Pennsylvania 15230, with a copy to the undersfgned.
PM 9002^ 1*se 9oog39
- d. PROP ONLH'%g O
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ton anoCx osooo247 PDC ggg
Should you or your staff have any questions regarding' this matter, please centact Mr. Charles V. Jackson, Manager, Nuclear Safety and Licensing.
Ve truly yours, l
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cct Mr. Villiam Russell i
Regional Administrator - Region I-US Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Donald S. Brinkman, Senior Project. Manager Project Directorate I-1 Division of Reactor Projects I/II US Nucl<ar Regulatory-Commission Mail Stop 14B-2 Vashington, DC 20555 i
Senior Resident Inspector US Nuclear Regulatory Commission
?0 Box-38 Buchanan, NY 10511 i
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