ML20066C374

Requests That Topical Rept WCAP-12737 Be Withheld from Public Disclosure (Ref 10CFR2.790 (b)(4))

ML20066C374
Person / Time
Site:	Beaver Valley
Issue date:	10/26/1990
From:	Wiesemann R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19310D128	List: ML20066C373 ML20066C374 ML20066C377
References
CAW-90-083, CAW-90-83, NUDOCS 9101090498
Download: ML20066C374 (14)

Text

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D Westinghouse Energy Systems W rme

• '"N W Electric Corporation ten m h"e g frenNna42m Mt October 26. 1990 CAW 90 083 Document Control Desk US Nuclear Regulatory Commission Washington, DC 205$5 Attention: Dr. Thomas Murley, Director APPLICATION FOR WITHHOLDING PROPRIETARY JEQ3MATION FROM PUBLIC DISCLOSURL

Subject:

Transmittal of WCAP 12737

Dear Dr. Marley:

The proprietary information for which withholding is being requested in the above-referenced letter is further identified in Affidavit CAW 90 083 signed by the owner of the proprietary information, Westinghouse Electric Corporation.

The affidavit, which 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 10 CFR Section 2.790 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanying Af fidavit by Duquesne Light Company.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW 90-083, and should be addressed to the undersigned.

Very,truly yours,

)

0(U U.c Lct1U L cA RobertA.Wiesemann,Nanager Enclosures Regulatory & Legislative Affairs cc:

C. M. Holzle, Esq.

Office of the General Counsel, NRC 9101090498 910103,

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l CAW-90-083 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 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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Y' dbl &Afu(datl Robert A. Wiesemann, Manager Regulatory and legislative Affairs Sworn to and subscribed before me this 2 F day of /%fMut, 1990, cgf.wMt.rfm Notary Public tcur nit LORR AF.! M Fity A. N07/S,f pac l'O'J0!V;LLE 0,000 A;;E3NUM 002;TY My 00w 00:0N EYA;!;:E0 u mi Mo~,e osme :. k

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-- CAW 90 083 j

(1) I am Manager, Regulatory and Legislative Affairs, in the Nuclear and Advanced lechnology 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 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 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 es 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 regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

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

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i CAW 90 083 i

(ii) The information is of a type customarily held in confidence by 4

Westinghouse and not customarily disclosed to the public.

j Westinghouse has a rational basis for determining the. types of information customarily held in confidence by it and,-in that l

connection, utilizes a system to determine when and whether to hold l

certain types of information in confidence.

The application of that l

system and the substance of that system constitutes Westinghouce 1

I policy and provides the rational basis required.

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Under that system, information is held in confidence if it falls in 3

one or more of several types, the release of which might result in the i

loss of an existing or potential competitive advantage, astfollows:

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i (a)

The information reveals the distinguishing aspects of a process (or ccmponent, structure, tool, method,-etc.) where prevention of-f its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over i

other companies, j

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(b)

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 l

1 advantage, e.g., by optimization or improved marketability, 1

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l CAW 90 083 (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 capacities, budget levels, or commercial strategies of Westinghou:0, 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.

(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 behina 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, j

5-CAW-90 083 (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.

(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.

(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 countries.

(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

6-CAW 90 083 (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 or available information has 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 submittal is that which is appropriately marked in "LOFTTR2 Analysis for e Steam Generator Tube Rupture for Beaver Valley Unit 2", WCAP 12737, (Proprietary), for Beaver Valley Power Station Unit 2, being transmitted by the Duquesne Light Company (DLC) letter and Application for Withholding Proprietary Information from Public Disclosure, J. D. Sieber, Vice President, Nuclear Operations, DLC, to Public Document Room, attention Dr. Thomas Murley, November,1990. The proprietary information as submitted for use by Duquesne Light Company for the Beaver Valley Power Station Unit 2 is expected to be applicable in other licensing submittals in response to certain NRC requirements for justification of the design basis analysis for a steam generator tube rupture accident.

_ CAW-90-083 This information is part or that which will enable Westinghouse to:

(a) Provide documentation of the methods, assumptions, and analysis for a design basis steam generator tube rupture accident.

(b) Establish the margin to steam generator overfill for a design basis steam generator tube rupture.

(c)

Establish the offsite radiation doses for a design basis steam generator tube rupture.

(d) Assist the customer to obtain NRC approval.

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 licensing documentation.

(b) Westinghouse can sell support and defense of the technology to its customers in the licensing process,

c i-y 8-CAW-90 083 s

1 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 i

to provide similar analytical documentation and licensing defense services for commercial power reactors-without commensurate expenses.

Also, public disclosure of the information would l

enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information 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, in order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be i

performed and a significant manpower effort, having the requisite talent and experience, would have to be expended for developing i

analytical methods.

Further the deponent sayeth not.

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Copyright Notice The reports transmitted herewith eact, bear a Westinghouse copyright notice.

The NRC is permitted to make the ntmber of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, 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 l

have one copy available for public vietving in the appropriate docket files in the public document room in Washington, DC 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 copies for the personal use of members of the pubite 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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iI Proprietary 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.

j In order to conform to the requirements of 10 CFR 2.790 of the Commission's regulations concerning the protection of proprietary 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 on the brackets remain, the information that was 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 (g) contained within parentheses located as a superscript imediately 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 Sections (4)(ii)(a) through (4)(ii)(g) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.790(b)(1).

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KITAG MENT 2 Ecuirrwmt for Mitigation of a Li nsirn Basis Tube Rupture l

Description Mark Number Motive Power OA C3tegorv L31tainment Isolation Ehase A and Phase B N/A 1.

reset controls Safety Injection reset u;u'uuls N/A 1

i Steam Generator Blowdown isolation valves 2BDG* M/100A1, B1, C1, 101A1, Spring to close 1

and controls A2, B1, B2, C1, C2 Oniging Punps miniflow isolation valves 20G*M/275A, B, C anc 373 Electric Motor 1

and controls Auxiliary Pressurizer Spray valve arrl 20G*M/311 Electric Motor 1

controls Onrgirg Pump alternate miniflow isolation 20E*M/380A, B Electric Motor 1

valves and controls O urging /liigh Ilead Safety Injection pumps 20E*P21A, B, and C N/A 1

and controls Auxiliary Feedwater Pur:ps and Controls 2FhT*P23A, B N/A 1

Main Streamline isolation and bypass 2 MSS *M/101A, B, C, 102A, B, C Spring to close 1

valves and controls

'Iurbine Driven Auxiliary Feedrater Ptrp 2 MSS *SOV105A, B, C, D, E, F Solenoid 1

steam supply isolation valves and u.aiuvls I

i Pressurizer EORV block valves and controls 2RCS* M /535, 536, 537 Electric Motor 1

i Pressurizer EORVs and controls 2RCS*PCV455C, D, and 456 Solenoid-Pilot 1

Operated l

l Reactor Vessel liead Vent valves and 2RCS*SOV200A, B, and 201A, B Solenoid 1

controls

ATI70!MDTr 2 (cant')

F#Jiu,ent for Mitigation of a Ideensim Basis Tube Rupture t

Dm h ion Mark A-ter Motive Ibwer OA C3tecrary Main Steamline drains to Cordenser 2SIE*MI11]A1, A2, B1, B2, C1, Sprirg to Close 1

isolation valves ard mntrols C2 Residual Heat Release pipirn drains valves 2SDS*M1129A, B Spriry to Close 1

ard controls High Head Safety Injection cold leg 2 SIS *HCV868A, B Solenoid 1

throttlirg valve ard controls l

Charging /High Head Safety Injection pump 2 SIS

• M J867A, B Electric Motor 1

cold leg injection isolation valves ard controls Atmospheric Seam Durp ranual isolation 2SVS*23, 24, 25 Marmal 1

valves l

Residual Heat Release renual isolation 2SVS*27, 28, 29 Manual 1

valves j

Residual Heat Release valve ard controls 2SVS*HCV104 Electro /Hytiraulic 1

t Atnospheric Steam Dunp valve ard coni 2uls 2SVS*PC7101A, B, C Electro /Hytiraulic 1

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A1TA0! MENT 3 Instntmntation ard Egt;tlation Monitorn Ural for Licensirrr Ibsis Ebe Runtgre AC buses pwer irdication Annunciator A12-1C, " Auto Safety Injection Blocked" Annunciator A12-10, " Safety Injoction Signal" Core D:lt Thentoccuples (Plant Safety Monitoring System)

Digital Radiation Monitorirq consolo offsite pwer status iMication Reactor Coolant System subowling irdication (Plant Safoty Monitorirg System)

Air Fjoctor radiation rionitor (2 ARC-RQ100)

Steam Generator BloWdwn isol valves status indication (2l03*AOV100A1, B1, C1,101A1, A2, B1, B2, C1, C2)

Refueling Water Storage Tank outlet 1Golation valves position indication (20!S*lCV115B ard D)

Volumo control Tank outlet isolation valves position indication (20lS*ILV1150 and E)

Auxiliary Pressuriter Spray valve position indications (20!S*!OV311]

Omrgirg/Itigh fload Safety Injection pumps status irdication (20lS*P21A, B, and C)

Chartjing flow irdication (20!S-FI122A)

Auxiliary roodwater flow irdication (2fWE*TIl00A1, A2, B1, B2, C1, C2]

Foodwater flow regulatirq valves position irdication (2 INS *IrN478, 488, a'd 498)

Teodwater flow bypass valves position irdication (2WS*IW479, 489, ard 499]

Teodwater flow irdication (2WS*FI476, 486, 496, 477, 487, and 497)

Steam Generator Narrtu Rargo level indication (21HS*IJ474, 484, 494, 475, 405, 495, 476, 486, ard 496)

Main SteanLine isolation ard bypass valves sutus irdication (2 MSS *AOV101A, B, C,102A, B, C)

Steam Generator pressure irdicators (2 MSS *PI474, 484, 494, 475, 485, 495, 476, 486, ard 496)

Main Steamlino radiation monitors (2 MSS *RQ101A, B, C)

Turbino Driven Auxiliary Peodwater Pump steam supply isolation valvo status irdication (2 MSS *SOV105A, B, C, D, E, F)

Pressurizer level irdication (2RCS*LI459A, 460, and 461)

Pressurizer IORV block valves position irdication (2RCS*MJV535, 536, ard 537)

Pressurizer FORV position irdication (2RCS*IW455C, D, ard 456)

Reactor Coolant System wide rarge pressure indication (2RG*PI440 and 441)

Main Steamli!Y; drains to Cordenser status indication (2SDS*A0V111A1, A2, B1, B2, C1, C2)

Residual llcat Release piping drains status irdication (2SDG*AOV129A, B)

Steam Generator Blowdcun radiation monitor (2SSR-RQ100)

Residual llcat Release Valvo status indication (2SVS*llCV104)

Atmospheric Steam Dump valves status irdications (2SVS*PCV101A, B, C) l l

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