ML20010F002

Forwards Responses to NRC Requesting Addl Info on NUREG-0737,Item II.F.2.3 Re Reactor Vessel Level Instrumentation Sys for Monitoring Inadequate Core Cooling. Response Withheld (Ref 10CFR2.790)

ML20010F002
Person / Time
Site:	Beaver Valley
Issue date:	09/02/1981
From:	Carey J DUQUESNE LIGHT CO.
To:	Varga S Office of Nuclear Reactor Regulation
Shared Package
ML19295G425	List: ML20010F002
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.2, TASK-TM TAC-45114, NUDOCS 8109090256
Download: ML20010F002 (2)

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September 2, 1981 Director of Nuclear Reactor Regulation United States Nticlear Regulatory Commission gM d)

Attn:

Mr. Steven A. Varga, Chief b(ijy [h(/

Operating Reactors Branch No. 1 0

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Reference:

Beaver Valley Power Station, Unit No. 1 d**-Q y [

Docket No. 50-334

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,g NUREG 0737; Item II.F.2.3; RVLIS

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4 Gentlemen:

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to Forwarded herewith is our response to your letter dated August 5, 1981, requesting additional information regarding the Reactor Vessel Level Instrumentation System for monitoring inadequate core cooling.

Please note that Attachment 2 contains proprietary information supplied by the Westinghouse Electric Co.poration.

This attachment is provided as supplemental proprietary information to the Summary Report, " Westinghouse Reactor Vessel Level Instrumentation System for Monitoring Inadequate Core Cooling", dar 2d December 1980, for which an application for the withholding of proprietary information from public discloeure has already been submitted.

Attached is this application and affidavit, signed by Westinghouse, which sets forth the basis on which the information may be withheld from public disclosure by the Commission and specifically addresses the considerations listed in paragraph (b) (4) of 10 CFR 2.790.

Accordingly, it is requested that information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR 2.790.

Correspondence relating to proprietary aspects of this application for withholding or the supporting Westinghouse affidavit should be addressed to R. A. Wiesmann, Manager, Regulatory and Legislative Affairs, Westinghouse Electric Corporation, P.O.

Box 355, Pittsburgh, Pennsylvania 15230.

Please note that items 9, 10, 12, and 20 have not been answered as further review of these items is required. A response will be submitted by September 30, 1981, which will provide the information requested for these four items.

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. Beaver-Valley Po;ier' Station,. Unit NO.1

--Docket No. 50-334 NUREG 0737;~ Item II;F.2.3; RVLIS

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Mr. D. A. Beckman,--Resident. Inspector.

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S.' Nuclear. Regulatory Commission

. Beaver Valley Power Station-

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Westinghouse Water P.Sactor 2 3

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December 23, 1980 CAW-80-76 Mr. Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Comission Phillips Building 7920 Norfolk Avenue Bethesda, Maryland 20014 ATTN: Lawrence E. Phillips Core Performance' Branch, DSI APPLICATION FOR WITu40LDING PROPRIETARY INFORMATION FROM PuBLIC DISCLOSURE _

SUBJECT:

Sumary Report, Westinghouse Reactor Vessel Level Instrumentation System for Monitoring Inadequate Core Cooling (Microprocessor System) f REF: NULF.G-0737 Part II.F.2, Instrumentation for Inadequate Core Coling i

Dear Mr. Eisenhut:

The proprietary material transmitted by the referenced letter supplements the proprietary material previously submitted concerning the Westinghouse development of ECCS models.

Pacher, the affidavit submitted to justify the material previously, submitted, AU-77-18, was approved by the Commission on October 28, 1977, and is equally applicable to this material.

Accordingly, withholding the subject infonnation 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.

3 Correspondence with respect to this application for withholding or the accompanying affidavit should reference CAW-80-76, and should be addressed to the undersigned.

i Very truly yours, b.Yh.

Robert b iesemann, Mansger

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E. C. Shomaker, Esq.

Office of the Executive Legal Director, NRC 4-

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AFFIDAVIT I,

COR*10:lWEALTH OF PEittlSYLVAtlIA:

I ss COUNTY OF ALLEGHEttY:

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Before me, the undersigned authority, personally appeared l

Robert A. Wiese; nann, who, being by me duly sworn according to law, de-poses and says that he is authorized to execute this Affidavit on behalf I

of Westinghouse Electric Corporation (" Westinghouse") and that the aver-ments of fact set forth in this Affidavit are true and correct to.the f:.

best of his knowledge, information, and belief:

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,so ub "$ /.f?!.Ul8%i' Robert A. Wiesemann, Manager l

Licensing Programs i

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l Sworn to and subscribed i

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AW-77-18 '

I an Manager, Licensing Programs, in the Pressurized Water Reaccor I

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Systems Division, of Westinghouse Electric Corporation and as such, E

I have been specifically delegated the function of reviewing the j

proprietary information sought to be withheld from public dis-closure in connection with nuclear power plant licensing or rule-making proceedings, and am c.uthorized to apply for its withholding on behalf of the Westinghouse Water Reactor Divisions.

i I am making, this Affidavit in conformance with the provisions of (2) 10 CFR Section 2.790 of the Cce.ission's regulations and in con-3 junction with the Westinghause application for withholding ac-i companying this Affidavit.

I have personal knowledge of the criteria and procedures utilized l

(3)

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. by Westinghour..."u*.r " :--. Systems in designating inforntion as a trade secret, privileged or as confidential comercial or financial information.

Pursuant to the provisions of paragraph (b)(4) of Section 2.790 (4) of the Commission's regulations, the following is furnished for consideration by the Ccmmission in determining whether the in-formation sought to be withheld from public disclosure should be '

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(i) The information sought to be withheld from public disclosure is cwned and has bden held in confidence by Westinghouse.

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n (ii) The information is of a type customarily held in confidence by I

Westinghouse and not customarily disclosed to the public.

Westinghouse has a rational basis for determining the types of

,f information customarily held in confidence by it and, in that connection, utill:es a system to determine'when and whether to hold cer:ain types of information in confidence.

The ap-plication nf that system and the substance of that system constitutes Westinghouse policy and provides the rational bas b required.

. Under that system, information is held in confidence if it 1

falls in ene or more of several types, the release of which might result in the loss of an existing or potential com-

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petitive advantage, as.,folle'.is:

(a) The information reveais the distinguishing aspects of a process (or component, structure, toel, method, etc.)

where preventicn of its use by any of Westinghouse's competitors without license from Westinghouse ccastitutes a competitive economic advantage over other companies.

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(*c) 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 optiinization or improved marketability.

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diture Its use by a competitor would ieduce his expen s

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of resources or improve his competitive pos (c) rance design, manufacture, shipment, installation,

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of quality, or itcensing a similar product.

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It reveals cost or price information, produc i

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act ties, hudoe' levels, or commercial strateg (d)

Westinghocie, its customers or suppliers.

7 West-It reveals aspects of past, present, or future inghouse er customer funded developm g..

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grams of potentiel comercial value to Wes It contains patentable ideas, for which pate r (~N

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tection may oe oesirable.

It is not the property of Westinghoun, b j

ding to treated as proprietary by Westinghouse accor l

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j agreements with the owner.

There are sound policy reasons behind the l

system which include the following:

The use of such information by Westingh Westinghouse a competitive advantage ov (a)

It is, therefore, withheld from disclosu ii petitors.

to protect.the Westinghouse competitive p

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It is information which is marketable in many ways.

t The extent to which such information is available to l

competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.

(c) Use by our competitor would put Westinghottse at a competitive disadvantage by reducing his expenditure of resources at our expense.

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(d)

Each ccaponent of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage.

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competitors acquire components of proprietary infor-mation, any one component may be the key to the entire

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puzzle, thereby depriving Westinghouse of a competitive advantage.

(e) Unrestricted disclosure would jeopardize; the position

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and thereby give a market advantage to the competition in 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.

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(iii)

The information is being transmitted to the Commission in l

confidence and, under the provistor.s of 10 CFR 3ection 2.790, 4

it is to be received in confidence by the Cc,r: mission.

(iv)

The information is not available in public sources to the best of our knowledge and belief.

(v)

The proprietary information sought to be withheld in this submittal is that which is attached to Westinghouse Letter Number NS-CE-1403, E1cheidinger tn Stolz, dated April 6, f

1977.

The letter and attachment are being stJuitted in support of the Westinghouse emergency core cooling system tealuation model.

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Public disclosure of the information sought to be withheld is likely to cause substantial harm to the ccmpetitive position of Westinghouse, taking into account the value of the information to Westinghouse, the amount of effort and money experided by Westinghouse in developing the information, and considering the ways in which the information could be i

acquired or duplicated by others.

Furtner the deponent sayeth not.

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s DUQUESNE LIGHT: COMPANY Nuclear Safety and Licensing Department Item 2.

Describe the location of ths level system displays in the control room with respect to other-plant instrument displays related to ICC monitoring, in particGlar, the. saturation meter display and the core exit thermocouple display.

RESPONSE.

2.

. The level system displays will be meunted left of center on the main control panel's Vertical Board Section-B, which also contains. the saturation meter display, pressurizer displays, and hot and cold leg temperature displays. Approximately 25 feet to the left of Vertical ~ Board Section-B, in the same control' room, are the core exit thermocouple displays.

l Item 3 Describe the provisions and procedures for on-line verification, calibration, and.

maintenance..

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RESPONSE

3.

On-line verification of the icvel system displays is achieved by crosschecking between redundant channels, or channels that have a relationship to each other j

during normal operation and b-,

observing reaction of the system in response to a test signal.

In addition, a comparison can be made alth the data obtained from-displays related to ICC monitoring; for example, the indicator on the saturation meter display.

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