ML20059C507
| ML20059C507 | |
| Person / Time | |
|---|---|
| Site: | 05200003 |
| Issue date: | 10/27/1993 |
| From: | Liparulo N WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | Borchardt R NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19311B152 | List: |
| References | |
| AW-93-540, NUDOCS 9311010177 | |
| Download: ML20059C507 (10) | |
Text
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q Westinghouse Energy Systems Ba 355 Electfic Corporation Pittsburgh Pennryivanta 15230 0355 i
AW-93-540 October 27,1993 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTENTION:
MR. R. W. BORCHARDT APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
SUBJECT:
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE AP600 DESlON DATED APR]L 2,1993 (REVISED RESPONSE)
Dear Mr. Borchardt:
The application for withholding is submitted by Westinghouse Electric Corporation (" Westinghouse")
pursuant to the provisions of paragraph (b)(1) of Section 2.790 of the Commission's regulations. It contains commercial strategic information proprietary to Westinghouse and customarily held in confidence.
The proprietary material for which withholding is being requested is identified in the proprietary version of the subject report. In conformance with 10CFR Section 2.790, Affidavit AW-93-540 accompanics this application for withholding setting forth the basis on which the identified proprietary information may be withheld from public disclosure.
Accordingly, it is respectfully requested that the subject information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10CFR Section 2.790 of the Commission's regulations.
Correspondence with respect to this application for withholding or the accompanying affidavit should reference AW-93-540 and should be addressed to the undersigned Very truly yours, hh A
N. J. Liparuto, Manager Nuclear Safety And Regulatory Activities
/nja ec:
Kevin Bohrer NRC 12H5 9311010177 931027
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Enclosure to Westinghouse Letter I?P NRC-93 4001 Table i Figure 1:
Pressurizer Safety and Automatic Depressurization System (PSADS) Piping lower Tier Isometric Figure 2:
PSADS Piping Upper Tier Isometric Figure 3:
PSAD3 Lower Riser Isometric Figure 4:
PSADS Upper Riser isometric Figure 5:
Pressurizer Riser Piping - Elevation Figure 6:
PSADS Piping 3D Sketch Figure 7:
PSADS Piping and Module Plan View Figure 8:
PSADS Piping and Module Interface Section A-A Figure 9:
PSADS Piping Plan View Figure 10: PSADS Piping Section A-A Figure 11: PSADS Piping Section K-K Figure 12: Core Make-up Tank (CMT) Pressure Balance Piping Plan View Figure 13: CMT Pressure Balance Piping Section View I Figure 14: CMT Pressure Balance Piping Section View 2 Figure 15: Pressurizer Spray 1.ine Section View Figure 16: Pressuri7er Spray Line Plan View 1 Figure 17: Pressurizer Spray Line Plan View 2 Figure 18: Pressurizer Spray Line Plan View 3 Figure 19: Pressurizer Spray Line Plan View 4 Figure 20: Pressurizer Spray Line Plan View 5 Figure 21: IRWST Discharge Piping Plan View 1 Figure 22: IRWST Discharge Piping Plan View 2 Figure 23: IRWST Discharge Piping Section A-A Figure 24: IRWST Discharge Piping Section B-B Figure 25: IRWST Discharge Piping Section C-C Figure 26: IRWST Discharge Piping Section D-D The ADS piping from the pressurizer to the valves of the first three stages, and downstream of the valves to the IRWST is shown in Figures 1-11. Figures 6-11 are provided only to help visualire this ADS piping module. The dimensions on Figures 1-5 represent the latest routing and should be used over the dimensions provided in Figures 6-11. The IRWST discharge piping is shown in Figures 21-
- 26. The pressure balance line piping from the cold leg to the CMT, and pressurizer to the CMT is shown in Figures 12-14. The 3" pressure balance line connections to the 14-inch pressurizer headers are shown in Figures 3,4,7 and 9. These must be used in addition to Figures 12-14 to establish the -
balance line routing. The pressurizer spray line piping is shown in Figures 15-20.
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COPYRIGIIT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copics of the information contained in these reports which are necessary for its internal use in connection with generic and p' ant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, pennit, 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, 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, D.C. and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. The NRC is not authorized to make copics for 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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PROPR11CTARY 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.
In order to conform to the requirements of 10 CFR 2.7(X) of the Commission's regulations concerning the protection of proprictary information so submitted to the NRC, the information which is -
proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been 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 designated as proprietary is indicated in both versions by means of lower case letters (a) through (i) contained within parentheses h>cated as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Section (4)(li)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR2.790(b)(1).
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AW-93-540 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF ALLEGHENY:
Before me, the undersigned authority, personally appeared Brian A. McIntyre, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on bchalf 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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Brian A. McIntyre, Manager Advanced Plant Safety & Licensmg j
i Sworn to and subscribed i
before m this _ 87 day of 4Md
.1993
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. AW-93 540 (1)-
I am Manager, Advanced Plant Safety and Licensing,in the Nuclear and Advanced Technology Divisions, of the Westinghouse Electric Corporation and as such, I have been specifically delegated the function of reviewing the proprietary information sought to bc 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 j
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 l
regulations, the following is furnished for consideration by the Commission in determimng 1
whether the information sought to be withheld from public disclosure should be withheld.
l (i)
The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.
(ii)
The information is of a type customarily held in confidence by 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:
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AW-93-540 -
(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 comp (ment, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved.
marketability.
(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 similar product.
(d)
It reveals cost or price information, production capacitics, budget levels, or commercial strategies of Westinghouse, its customers 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.
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t 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, withheld from disclosure to protect the Westinghouse competitive position.
(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.
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AW-93-540 (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.
l (c)
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.
(f)
The Westinghouse capacity to invest corporate assets in research and development depends upm the success in obtaining and maintaining a competitive advantage.
(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 l
Commission.
(iv)
The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.
(v)
Enclosed is Letter ET-NRC-93-4001, October 27,1993, being transmitted by Westinghouse Electric Corporation (W) letter and Application for Withholding Proprietary Information from Public Disclosure, N. J. Liparulo (W), to Mr. R. W. Ikirchardt, Office of NRR. The proprietary information as submitted for use by Westinghouse Electric Ccrporation is in ressmse to questions concerning the AP600 plant and the associated design certification application and is expected to be applicable in other licensee submittals in response to certain NRC requirements for justification of licensing advanced nuclear power plant designs.
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AW-93-540 2
This information is part of that which will enable Westinghouse to:
1 (a)
Demonstrate the design and safety of the AP600 Passive Safety Systems.
f (b)
Establish applicable verification testing methods.
(c)
Design Advanced Nuclear Power Plants that meet NRC requirements, (d)
Establish technical and licensing approaches for the AP600 that will ultimately result in a certified design.
(c)
Assist customers in obtaining NRC approval for future plants.
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 advanced plant licenses.
l (b)
Westinghouse can sell support and defense of the technology to its customers '
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in the licensing process.
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 advanced nuclear power designs and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the
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information.
i The development of the technology described in part by the information is the result of i
applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money, j
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AW.93-540 In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, -
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having the requisite talent and experience, would have to be expended for developing analytical methods and receiving NRC approval for those methods.
Further the deponent sayeth not.
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