ML20066L279

Forwards Proprietary WCAP-12855 & Nonproprietary WCAP-12856, Per NRC Bulletin 88-011, Pressurizer Surge Line Thermal Stratification. Proprietary Rept Withheld (Ref 10CFR2.790(b)(4))

ML20066L279
Person / Time
Site:	Farley
Issue date:	01/31/1991
From:	Hairston W ALABAMA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19312B425	List: ML20066L237 ML20066L252 ML20066L279 ML20066L317
References
NUDOCS 9102060385
Download: ML20066L279 (2)

Text

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Alabama Power Company 1

• 40 inverness Center Parkway Post Othce Box 1295 Ditmmgham. Alabama 35201 Telephone 205 868 5581 1

W. G. Hairston, lit - '

Senior Vee President Nuclear Orerations Magg3 gg the Golfhorn tdttitc systern I Docket No. 50-348 U. S. Nuclear Regulatory Commission i

ATTN: Document Control Desk Vashington, D. C. 20555 Gentlemen Joseph H. Farley Nuclear Plant -_ Unit 1 NRC Bulletin No. 88-11 Pressurizer surge Line Thermal Stratification

)

By let ter datbd March 3,1989, ' Alabama. Pover Company requested an alternate schedule-to that requested in Bulletin 88-11. A schedule of two years from receipt of the Bulletin was rquested to obtafn_the necessary additional monitoring. data. define thermal transients, perform all required analyses and update the stress and. fatigue analyses to ensure compliance with applicable code and regulatory requirements. The j requested schedule, though different from that stated in action 1.b of i Bulletin 88-11, was consistent with the requirement to. update the stress and fatigue analyses within two years as stated =in_ action 1.d of the Bulletin, j

-i Vestinghouse has performed a stress and fatigue analysis for Alabama Power Company of the Unit 1 pressurizer surge line including the effects of.

thermal stratification and striping. The results of'the analysis are contained in the enclosed VCAP from Vestinghouse. The existing surge line configurations for both units have been analyzed by this VCAP. The analysis indicates contact between the pipe and the pipe whip restraints on Unit 1. Even with this contact, the analysis has determined that Unit 1 pipe stress and the code fatigue cumulative usage factor are within the code allovables.

It is Alabama Pover Company's intent to develop-a' leak-before-break-(LBB) '

analysis for the Unit 1 surge line to allow the removal of the pipe whip restraints and _ thus eliminate the contact with the piping. The results of  ;

c that analysis vill be submitted to the NRC for approval in accordance with GDC 4 vithin the next three months. After NRC reviev and approval of-the LBB analysis, Alabama Power Company vill remove the postulated pipe rupture of the surge line fromithe design basis. . Alabama Power Company currently plans on removing _the whip restraints within two refueling outages _following LBB approval. ,

The results of this plant specific _ analysis on Unit lidemonstrates -

j acceptance to the requirements of the ASME Code Section III, including i

both stress limits and fatigue usage, for the: full' licensed life of the-L unit. The enclosed report coapletes the response to NRC Bulletin 8f 'O

j. for Farley Unit 1.

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l -l 9102060385 DR 910131 <

l: ADOCK 05000348 PDR

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U. S. Nuclear Regulatory commission-ATTH: Document Control Desk Page 2 3

Enclosures contain:  ;

1. VCAP-12855 - Structural Evaluation of-the Farley Units 1 and 2 i Pressurizer Surge Lines, Considering the Effects of Thermal-Stratification (Proprietary). j

2. VCAP-12856 - Structural Evaluation of=the Farley Units 1 and 2-Pressurizer Surge-Lines, Considering the Effects of Thermal Stratification (Non-Proprietary).-

Also enclosed are a Vestinghouse authorization letter, CAV-91-122, i

• accompanying affidavit, Proprietary Information Notice, and Copyright Notice.

As VCAP 12855 contains information proprietary to Vestinghouse Electric Corporation,-it is supported by an-affidavit signed by Westinghouse, the.

owner of the information. The aftidavit 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 Section 2.790 of the Commission's regulations..

Accordingly, it is respectfully requested that the information which is  ;

proprietary to Vestinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.790 of the Commission's.: regulations.

Correspondence with respect to the copyright-or proprietary, aspects of the items listed above or the supporting Vestinghouse Affidavit.should

/

reference CAV-91-122 and should be-addressed to R.-P. DiPiazza, Manager, Operating Plant Licensing Support, Vestinghouse Electric Corporation, P. O. Eox 355, Pittsburgh, Pennsylvania. 15230-0355. 1 The sr!<rmation provided herein is;true to_the best of my knowledge and bellet. If you have any questions, please' advise.

-Respectfully submitted, ALABAMA POWER COMPANY-

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VGH,III/JGSimaf2216 Enclosures

-SVORN TO AND SUBSCRIBED.BEFORE HE E

ct Mr. S. D. Ebneter

, 1991.

Mr. S. T. Hoffman THIS J /

• DAY 0F d u m y~ g th. G. Aaviell -

J7j6w) 7 l 4k)dl ~

( Not Public

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Westinghouse Energy Systems - jj,3Mg,,,,,,

Electric Corporation '

,g33 January-29, 1991- )

CAW 91-122=

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' Document Control Desk --

US Nuclear Regulatory Commission- l Washington, DC- 20555 -

Attention: Dr.~ Thomas Murley,-. Director

APPLICATION FOR WITHHOLDING. PROPRIETARY-INFORMATION FROM PUBLIC DISCLOSURE- 1.

Subject:

" Structural. Evaluation of the Farley Units 1 and' 2' Pressurizer _ Surge i Lines, Considering the Effects of Thermal Stratification" a (WCAP-12855)  !

Dear Dr. Murley:

-1 The proprietary information for which withholding is being.recuested in ithe; -

above-referenced letter;is_ furtheruidet:tified -in Affidavit; CAU91-122 signed.by-the owner of the proprietary information,, Westinghouse ElectricL Corporation, The-affidavit, whicn accompanies-this-. letter,' sets.forth the basis-on-which.the information jaay' be~ withhelt from public_ disclosure; by the ; Commission and addresses with specificity .the considerstions'-listed-in paragraph -(b)(4) of 10-

~

CFR Section 2.790 of~the Commission's regulations.- -

i Accordingly,_ this ~ letter authorizes -the utilization of- the' accompanying- -

l Affidavit by Alabama -Power Company. 1 l Correspondence-with respect to the proprietary aspects.of: the application for t withholding or the: Westinghouse. affidavit should reference this letter,

. CAW 91-122, and should be addressed to the undersigned.-

Veryotruly yours,

. . iPiazza, Manag 'r Enclosures- ing Plant Licensing Support '

cc: C. M. Holzle, Esq.

Office of the : General Counsel, NRC-l- .

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Proprietary'Information Notice.

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fransmitted herewith are proprietary and/or non proprietary; versions of j 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 '2.790 of. the Commission's -I regulations concerning the protection of proprietary information .so submitted  !

to the NRC, the information which_is proprietary in the' proprietary versions'is-  ;

contained within brackett and where the proprietary information has-been -  !

deleted in the non-proprietary versions, only the brackets _ remain 1(theJ information that-was contained.within the brackets intthe proprietary versions having been deleted). The justification for claiming,the information so1 designated as proprietary is indicated-in both versions-'by means of lower case letters (a) through (g) contained within parentheses located 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 Sections (4)(ii)(a).through (4)(ii)(g) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.790(b)(1)l..

J

' Copyright Notice The reports transmitted herewith eachLbear a Westinghouse copyright notice. q The NRC is permitted to make the number of copies of the information contained  ;

in these reports which are necessary for its internal use'in connection with generic end plant specific reviews- and approvals as well as: the issuance, denial, amendment, transfer,f renewal, modification, suspension,- revocation, or violation of:a license, permit,_ order, or regulation subject to the I 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. WithLrespectito,the non-proprietary- '

versions of these reports, the NRC .isl permitted _to _make the numberiof copies; beyond those necessary for its internal use-whichL are necessaryJin order to .

have one copy available for public viewing inLthe 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-public who.make 'use of the NRC public document rooms. Copies made by-the NRC must include the-copyright noticeiin all -instances and the . proprietary notice if theLoriginal was-identified as proprietary.

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l CAW-91-122 i

-AFFIDAVIT  ;

-COMMONWEALTH OF PENNSYLVANIA:

Ss COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally appeared -

Ronald-P DiPiazza, 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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~Q t Ronak iazza, Manager Operating Plant Licensing Support Sworn to ond subscribed before me this 36'k. day of %"sw ,1991.

V Cf W&'M. t] Eld a Notary Public -

NOTARi/UEAL LoRRAINE M. PlPLICA, NOTARY P'JBLic McNROEVLLEeORo. ALLEGHENYCoVNTY MYCCNM:SS:CN EXPiAES DEO 14.1W Mer.cer Penr4yivam AsM02'antitP.'ets

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= ~ CAW-91 122 T

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y (1) 1. am Manager, Operating Plant Licensing Support, 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 withh' eld- from-jeSlic disclosure in -

connection with nuclear power plant licensing and rulemaking proceedings, y and am authorized to apply for its' withholding on~ behalf.'of the Westinghouse Energy' Systems-Business Unit. i (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.

1 (3) I have personal knowledge' of the criteria and-procedures utilized -by.the-l Westinghouse Energy Systems Business Unit.in-designating information_as a trade secret, privileged or as confidential commercial or financial-information.

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(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 91-!22 1

I (1) I am Manager, Operating Plant Licensing Support, 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 in connection with nuclear power plant licensing and rulemaking proceedings, and am authorized to apply for its withholding on behalf of the Westinghc'4se 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 proceduresLutilized 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 _ regulations, the following is -furnished for1 consideration by' the Commission in determining whether the information' sought Lto_ 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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3- CAW-91-122.

d (ii) The information Lis of a type _ customarily heldLin . 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 bylit 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 1 required.

Under that system, information is hel'd in confidence if it falls in I one or more of-several types, the release-of wh'ich mightL;esultnin the  ;

, loss of-an existing or potential competitive advantage, as-follows:-

(a) The information reveals the distinguishing aspects.of~a process (or component, structure, tool, method,xetc.) where prevention of-

-its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over I other' companies.

(b) It consists of supporting data, including-Ltest-data, -relative to i a process (or component,. structurei . tool, method, etc.),1the application of which data secures;a_ competitive economic advantage, e.g., by optimization or improved marketability.-

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l CAW 91-122 (c) Its use by a competitor would reduce his expenditure of resources or imprese his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d) It reveals cost or price iriformation, production capacities, 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 br.

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 palicy 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.

. _ . - - . . . . . _ ~ - -

l CAW-91-122' i

(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' i expense.

(d) Each component of proprietary information pertinent'to a particular competitive advantageis potentially as- valuable as .j

-the total competitive advantage. If_ competitors acqui_re -

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 th'e position of l - 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.

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CAW-91-122 (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 inipublic-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 inichlis appropriately marked in " Structural Evaluation of the Farley Units 1 and 2 Pressurizer Surge Lines, Censidering the Effects of Thermal Stratification", _WCAPal2855, (Proprietary) foc Joseph M. Farley Units- 1 and_2, being transmitted by-the Alabama Power Company (APCo) -letter and-Application for Withholding Proprietary Information fromL Public Disclosure, Mr. W. G. Hairston 111, APCo, to_ Document _ Control Desk, to the Attention Dr. Thoma's Murley, January,1991. LThe proprietary information as submitted for use:by Alabama Pcwer Company for the -J. M. Farley Units 1- and- 2 is expected to be applicable in other licensee submittals in response 'to certain NRC requirements for pressurizer surge line structural.

evaluation's including thermal . stratification effects.

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7- CAW 91-122.

t This information is part. of that which will enable Westinghouse-to: j (a) Provide documentation of the-methods for1 structural

- evaluations.'of- pressurizer surgeHline. j (b) Establish applicable ' analytical . technologies. )

(c) Establish the transient-and temperature profiles.

(d) Establish the applicable codes -and standards which are to be: I applied.

(d) Assist the customer'to obtain NRC approval. -t

- Further this information has substantial commercial- value as. i follows:-

(a) Westinghouse plans to sell thetuse' of similar information to: a its: customers for purposes of meeting'NRC:requirementsLfor licensing documentation.

(b) Westinghouse can sell' support'.and defense,of th'e techno1cgyi-to its customers in-the licensing process,

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-l CAW-91 122 i

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 sleeving services 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 information.

The development of the technology described in' part by the information is the result of applying the results of many years J of experience in an intensive Westinghouse effort and the: i expenditure of a considerable sum of-money, .

In order for competitors of Westinghouse to duplicate this information, similar technical programs would-have .to-be performed and a significant manpower effort,--having the requisite talent and experience, would haa to be expended for developing testing and analytical methods and performing tests.

Further the deponent sayeth not.

_ _--_ _--_- _