ML20012A307
| ML20012A307 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 02/26/1990 |
| From: | Wiesemann R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19293A180 | List: |
| References | |
| CAW-90-012, CAW-90-12, IEB-88-011, IEB-88-11, NUDOCS 9003090214 | |
| Download: ML20012A307 (15) | |
Text
5 Westinghouse Energy Systems ge4*ygg8njd Electric Corporation P s u?p rennstvm W3D 03%
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February 26, 1990 CAW-90-012 Document Control Desk U.S. Nuc1 car Regulatory Commission Washington, D.C.
20555 Attention: Dr. Thomas Murley APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC OlSCLOSURE
Subject:
Reconciliation of Fatigue Crack Growth Results for the South Texas Project Unit 1 Surge Line
Dear Dr. Murley:
The proprietary information for which withholding is being requested in the enclosed letter by Houston Lighting and Power Company is further identified in Affidavit CAW 88-129 signed by the owner of the pro)rietary information, Westinghouse Electric Corporation. The affidavit, w11ch accompanies 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 10CFR Section 2.790 of the Commission's regulations.
Accordingly, this letter authorizes the utilization of the accompt.nying.
affidavit by Houston Lighting and Power Company.
Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this 3
letter, CAW 90-012, and should be addressed to the undersigned.
I3 Very truly yours, I
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/RobertA.Wiesemann, Manager Regulatory & Legislative Affairs Enclor.ures cc:
K.- Holzle, Esq.
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Office of the General Counsel, NRC V. Wilson
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Nuclear Reactor Regulation
Pit 0PRIETARY INPOIMAT10N IRT13 TRAM 277D EDWW2fN ARE PROPRIETAM ANWOR IION-PROPRIETAM VERS 2 1DDper!S P1DtREBD 10 M 181C IN EERDBCT3CII WITN BBWESTS PCR SDIERIC AltWe PWMT 8PECIF20 REf35W AND APPRDr&L.
311 END 10 001EOM 10 THE REQUIMMDefS W McFRt.T90 W TE CDMIS$10N'S 3GDEAT20NS CDERM!llO 111E P8023C7101t & P90PETART tir0lMAT30lf 30 BRM277ED TO IKE SC, THE IsrclMAT30st atIm 28 790PRIETARY D Tilt PitRRIETW VERE 10llB IS CCIffA2XED U21NDI BRAMETS allD 20DtB TWE PROPR 2NFtpH4720ll RAS BEDi IRETED D Tilt IION-PPOPR2mRf VERE 109tB CBILY THE 3lRamETS RIMAIN, THE 2NP0fMATICet 127 WAS CONTAIED WITHIN Tilt BRACRETS IN THE PROPRIETARY VERSIONS Il&VING EDI IE127ED. TE.70BTIF2 CAT 10N PCR taA2 MING THE INFOROTION 80 EEB15&TD AS PPCPR1mRt IS INMCATD IN BOTH VER$100tB BY MEANS OF MMER CASE LETTERS (a) T200CH (g) CONTA%ED WITHIN PAREMESES LOCATO AS A SUPERSCRIPT 3MMATELY POLLMNG TE BRACEE78 ENCLaS3NG EACH ITEM CF IttPORMATION bello !!INTIF3ED AS PROPRIETARY OR THE MARDIN CPPQSITE 5001 INFORMATION. TESE MNER CASE LETTERS REFER 7 THE TYPES OF INF0fMAT10N WISTINCH:X5E 00370MARILY N0LIS IN CDNFIID2 2EEXTIFID IN SECT 10NS (4)(11)(a) THR0031 (4)(ii)(g) & THE AFF2 DAVIT ACCOMPAmNs tu28 TRANF. MAL PURSUANT TO 10CFR2.T90(b)(1).
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CAN-88-129 M
STATE OF CALIFORMIA:
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COUNTV 0F SAN FRANCISCDs Before me, the endersigned authority, personally appeared Acbert A. Wiessmana, who being by se duly sworn according to law, deposes and says that he is authettaed to esecute this Affidavit on behalf of Westinghouse IIectric Corporation ("Nestinghouse") ar.d that the aversents of fact set f6fth in this Affidavit are true and correct to tiis best of his knowledge, information, and belief:
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Robert A. Miesemann. Manager Regulatory and Legislative Affairs Sworn to and subscribed before me this f day of _Andv 198g.
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CAW 88 129 (3) I en hanager Regulatory and Legislative Affairs. 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 ga connection with auclear power plant Itcansing and rulemaking proceedings, and an authorized to apply for gis withholding on behalf of the Westinghouse Energy Systems. Nuclear Feel, and Power Generation Business Units.
(2) I as making this Affidavit in confomance with the provisions of 10CFR 5ection 2.790 of the Commission's regulations and in conjunction with the Westinghouse application hr withholding accompanying this Affidavit.
(3) I have personal knowledge of the criteria and procedures utilized by the Westinghouse Energy Systems, Nuclear Fuel, and Power Generation Business Units 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 2.7g0 of the Coenission's regulations, the following is furnished for consideration by the Cosatssion in determining whether the information' sought to be withheld from public disclosure should be withheld.
(1) The information sought to be withheld from public disclosne is owned and has been held in confidence by Westinghouse.
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3 CAW 88 Itg si (ii) The inforestion is of a type customarily held in confidence by l
Westinghouse and not costenartly disclosed to the public.
Westinghouse has a rational basis for determining the types of L
information castenarily held in confidence by it and, in that
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connection, st111:ss 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 L
constitutes Westinghouse policy and provides the rational basis
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required.
l l-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 l
l pracoss (or component, structure, tool, method, etc.) where prevention of its use by any of. Westinghouse's competitors without license from Westinghouse constitutes a competitive oconomic advantage over other companies.
i (b) It consists of supporting data, including test data, relative to a process (or component, structure, tool.
L' sethod, etc.), the application of which data secures a competitive economic advantage, e.g., by optiaitation or improved marketability.
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-CAW 88 129
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(c) Its use by a toepetitor would reduce bis expenditure of resources or taprove bis competitive position in the '
design, manufacture, shipment installation, assuranse of quality, or licensing a similar product.
1 (d) It reveals cost er price information, production H
sapacities, budget levels, or commercial strategies of Westinghouse, its costeners or, suppliers.
(e) It reveals aspects of past, present, or future Westinghouse or customer: funded development plans and programs of 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 tre 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.
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It is, therefore, withheld from disclosure to protect the
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Westinghouse competitive position.
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5 CAW 88 129 (b)- It is tafersatten dich is marketable in meer ways. The I
extent to d ich such information is available to competitors dietnishes the Westinghouse ability to' sell products t.W services involving the use of the information.
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(c) Use by our competitor would put Westinghouse at a q
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' competitive disadvantage by reducing his expenditure of _
resources at our expense.
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(d) Each component of proprietary information pertinent to a L
particular competitive advantage is potentially as valuable-
-as the total competitive advantage. If competitors acquire
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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 L
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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CAW 88 129 e
(iii)
The information is being transmitted to the Commission in confidence and, under the provisions of 10CFR Section 2.7p0, it is to'be received in confidence by the '
t Cennission.
(iv)
The infomation sought to be protected is not available in public sources or available information bas not been previously employed in the same original manner or method to the best of our knowledge and belief.
(v)-
The proprietary information sought to be withheld in this submittel is that which is appropriately marked in ' south Texas Units 1 and 2, Pressurizer Surge Line and Residual Heat Removal Line Stratification', WCAP 12067, (Proprietary),forSouthTexasProjectsUnits1and2 being transmitted by the Houston Lighting and Power Company (HL&P) letter and Application for Withholding Proprietary Information from Public Disclosure, H. A. Mc8venett, Manager. Operations Support Licensing HL&P, to NRC Document Control Desk, attention Dr. Thomas Murley, December,1988. The proprietary information as submitted for use by Houston Lighting and Power Company for the South
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Texas Project is expected to be applicable in other licensee submittals in response to certain NRC requirements for justification of the integrity of the pressurizer surge line for its design life under thermal stratification conditions.
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CAW 88 129 e
This infomation is part er that dich will enable Westinghouse to (a) provide documentation of the analyses and methodology used in the evaluation of the thermal stratification phenomenon.
(b) Establish revised design transients for the pressuriser surge 11ae based on plant monitoring data and Westinghouse test programs.
.(c) Demonstrate the structeral integrity of the pressurizer surge line for the 40 year design Itfe, and the acceptability of leak before break and fatigue track growth, under thermal stratification conditions.
(d) Demonstrate the low likelihood of stratification in the RHR lines, and the integrity of these lines in the event such-a condition did exist.
(e) Assist the customer in obtaining NRC approval.
Further this information has substantial ecamercial value as follows:
(a) Westinghouse plans to sell the use of stellar Information to its customers for purposes of demonstrating adequate design lifa for surge lines and RHR lines.
(b) Westinghouse can sell support and defense of the technology to its customers in the licensing process.
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public disclosure of this proprietary infomation is likely to cause substantial ham to tbs coepetflive position of Westinghouse because it would enhance the ability of competitors to provide similar analytical documentation and licensing defense services for comercial power teactors without comeensurate expenses. ilso, pubite disclosure of the information would enable others to use the infomation to meet NRC requirements for licensing documentation without purchasing the right to use the infomation, y
The development of the technology described in part by the L
information is the result of applying the results ef many L
years of experience in an intensive. Westinghouse effort and the expenditure of a considerable sum of money, l-o In order for competitors of Westinghouse to duplicate this c
information, similar technical programs would have to be performed and a significant sanpower effort, having the-requisite talent and experience, would have to be expended L
for. the development, verification, and licensing of adequate methods for evaluation of this phenomenon.
Further ties deponent sayeth not.
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ATTACHMENT 4 l-I 4
' COMPLETION OF IEB 88-11 3
I ACTIVITIES FOR STPEGS.
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-I COMPLETION OF.IEB 88-11 ACTIVITIES FOR STPEGS ATTACHMENT 4-U
,ST-HL-AE-3370 1
Page 1 of 3 ACTION SOURCE
'DUE DATE COMPLETION DATE REPORTED IN.
1.
Respond to NRC's Request for NRC's RAl and N/A 01/17/89 ST-HL-AE-2949 f Additional Information'(RAI).
SSER 6 2.
Visually examine (ASME Section IEB 88-11 first cold 01/09/89 ST-HL-AE-3016-XI, VT-3) the Unit 1 and 2 shutdown (Unit 2) pressurizer surge lines.
exceeding 7 02/02/89 3
days (Unit 1) 3.
Provide additional information 01/30/89, 01/31/89 N/A 02/09/89 ST-HL-AE-2987
.regarding the mean stress meetings HL6P with effects and use of the ASME NRC design fatigue curves.
4 Clarify leak rate calculations 01/30/89-02/02/89 N/A 02/15/89 ST-HL-AE-2992-for leak before break and meetings HL&P with justify the maximum differential NRC top-to-bottom pipe temperature, during a cooldown following a leak in the RCS.
5.
Remove pipe support HL5001 WCAP 12067 N/A 12/13/88 ST-HL-AE-3057' assumption.
(Unit 2) 02/17/89 (Unit 1) 6.
Demonstrate that the pressurizer
.IEB 88-11 12/19/89' 03/14/89 ST-HL-AE-3016 surge.line meets the applicable design codes and other FSAR and regulatory commitments for the licensed life of the plant.
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COMPLETION-OF~IEB 88-11 ACTIVITIES FOR STPEGS'
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ST-HL-AE-3370 Page 2 of 3 -
' ACTION' SOURCE DUE DATE cow 2LETION DATE REPORTED IN 7.
Revise' plant operating ST-HL-AE-2992 :
N/A.
,.05/31/89 N/A' procedures.to reinforce the need for prompt pressurization in the-event of a:nonisolable leak in the RCS.
8.
Confirm the existence of SSER 6 first cold 01/23/89 N/A' adequate clearance after removal-shutdown (Unit 2) of supporf HL5001.
after one 09/07/89
-heatup cycle (Unit 1)-
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- 9. - Monitor the Unit 1 surge line ST-HL-AE-3016 end of 10/89 ST-HL-AE-3284 through'the first refueling Unit 1, l
- outage, cycle 1
- 10. Revise operating procedures to internal N/A 11/15/89 ST-HL-AE-3284 i
prevent recurrence of system delta T > 320 F.
- 11. Plant specific data and o dier ST-HL-AE-3016 N/A 01/26/90 ST-HL-AE-3284 industry data will be reviewed to assure that the cycles and stratification temperatures as assumed in the analysis are conservative.
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m COMPLETION OF IEB 88-11 ACTIVITIES FOR STPEGS ATTACHMENT 4 ST-HL-AE-3370 -
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SOURCE p_1lE DATE.
COMPLETION DATE REPORTED IN
- 12. Update stress and fatigue IEB~88-11 12/19/90 02/28/90
'. ST-BL-AE-3370 analyses to ensure compliance with applicable code requirements.
- 13. IEB 88-11 results will be
'IEB 88-11 12/19/90 02/28/90 ST-HL-AE-3370 documented in'a final report.
- 14. Review opeoating records.for the internal.
N/A 02/28/90 ST-HL-AE-3370 time period. prior ~ to removal of support HL5001 to determine the stress effects.
- 15. Determine the effects of ST-HL-AE-3284 02/28/90 02/28/90 ST-HL-AE-3370 operation with the support in place ~on the surge line leak before break fatigue crack growth analysis.
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CORRESPONDENCE FROM lil4P TO'6RC TO ADDRESS Tile' PRESSURIZER SURGE LINE THERMAL STRATIFICATION ISSUE 1
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CORRESPONDENCE FROM HL&P TO NRC TO ADDRESS THE PRESSURIZER SURGE LINE THERMAL STRATIFICATION ISSUE LETTER DAIE SUBJ ECT.
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'ST HL-AE-2884 11/30/88 Pressurizer Surge Line and RHR Line Stratification Analysis P osentation to NRC, South Texas Project Unit 2 ST HL-AE-2894 12/06/88 Results of Analyses of Pressurizer Surge Line Stratification and RHR Suction Piping Stratification ST-hL AE-2900 12/09/88 Same as above ST llL-AE-2949 01/17/89-Additional Information in Support of the Evaluation for Thermal Stratification for the Pressurizer Surge Lines ST HL AE 2973 02/01/89 Evaluation of Thermal Stratification for 'the South Texas Units 1 and 2 Pressurizer-~ Surge Lines ST-HL-AE-2987 02/09/89 Clarification of'Mean Stress Effects and Use of ASME Fatigue ~ Curves in Analysis of the STP Pressurizer Surge Line ST-HL AE-2992 02/15/89 Additional Information in Support of the Evaluation for Thermal Stratification of the Pressurizer Surge Lines
~ST llL-AE-3016 03/14/89 Response to NRC Bulletin 88-11 " Pressurizer e
s Surge Line Thermal Stratification" ST HL-AE-3057 04/21'/89 Removal'of Pressurizer Surge Line Supports-S' ST-llL AE-3284 01/26/90 Additional Information Regarding Surge Line Stratification at.STP-(IEB 88-11)
ST-ilL AE-3370 02/28/90 Confirmation of Fatigue Crack Crowth Analysis and Completion of IEB 88-11 Activities 014~. N12 '
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