ML20083F263

Requests Withholding Proprietary Info Re Technical Bases for Eliminating Large Primary Loop Pipe Ruptures from Public Disclosure (Ref 10CFR2.790).Affidavit CAW-83-80 Encl

ML20083F263
Person / Time
Site:	Catawba
Issue date:	11/23/1983
From:	Wiesemann R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML19268E619	List: ML20083F254 ML20083F263 ML20083F276
References
CAW-83-106, NUDOCS 8312300226
Download: ML20083F263 (9)

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ATTACHMENT 1 Nuclear TechnologyDivision Westinghouse Water Reactor Electric Corporation Divisions Boxass PittsburghPennsylvanials230 November 23, 1983 CAW-83-106 l1r. ~ Harold R. Denton, Director Office of Nuclear Peactor Regulation U. S. Nuclear Regulatory Commission -

Washington, D. C. 20555 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

REFERENCE:

Duke Power Company letter to NRC dated November 1983 Decerber

Dear Mr. Denton:

The proprietary material for which withholding is being requested in the reference letter by Duke Power Company is further identified in an affidavit 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 para-graph (b)(4) of 10CFR Section 2.790 of the Comission's regulations.

The proprietary ma'terial for which withholding is being requested is of the same technical type as that proprietary material'previously submitted with application for withholding CAW-83-80. ,

Accordingly, this letter authori[Es tne utilization of the accompanying affidavit by Duke Power Company.

Correspondence with respect to t.he proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-83-106, and should be addressed to the undersigned.

Very truly yours, l Robert A. Wiesemann, Manager l /bek ,

Regulatory & Legislative Affairs l

l cc: E. C. Shomaker, Esq.

Office of the Executive Legal Director, NRC A

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Cr CAW-83-80 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally appeared John D. McAdco, 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, fr. formation, and belief:

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h D. McAdoo, Assidnt Manager l- ,

Nuclear Safety Department l

. Sworn to and subscribed before me this 24-M day o f a J ,. d.4 . 1983.

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'. CAW-83-80 (1) I am Assistant Manager, Nuclear Safety Department, in the Nuclear Techno-logy Division, of Westinghouse Electric Corporation and as such, I have been specifically delegated.the function of reviewing the proprietary information sought to be withheld from publ.ic disclosure in connection with nuclear power plant licensing or rule-making proceedings, and am authorized to apply for its withholding on behalf of the Westinghouse Water Reactor Divisions.

(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 Westinghouse Nuclear Energy Systems 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 foliosing is furnished for consideration by the Commission in determining whether the information sought to be with-held from public disclosyre-sh6uld be withheld.

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(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 1 Westinghouse and not customarily disclosed to the public. Westing-house 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 hole 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.

. CAW-83-80 Under that system, inforration 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 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 component, structure, tool, method, etc.), the application of which data secures a competitive cconomic advan-tage, e.g., by optimization or improved marketability.

(c) Its use by a competitor would reduce his expenditure of resour-i ces or improve his competitive position in the design, manufac-ture, shipment, installation, assurance of quality, or licensing a similar produc,t. -

(d) It reveals cost or price information, 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 conmiercial value to Westinghouse.

i (f) It contains patentable ideas, for which patent protection may be

! desirable.

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CAW-83-80 (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 behind the Westinghouse system which include the following:

(a) The use of 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.

(c) Use by our competitor wotfld put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense. ., . ,.. e -

(d) Each component of-proprietary information pertinent to a parti-cular 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 ifepriving Westinghouse of a competi-tive advantage.

(e) Unrestricted disclosure would jeopardize the position of promi-nonce of Westinghouse in the world market, and thereby give a market advantage to the competition in those countries.

- CAW-B3-80 l

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

(iii) The information is-beit.g 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 to the best of our knowledge and belief.

(v) The proprietary information sought to be withheld in this submittal is that which 1.s appropriately marked in " Technical Bases for

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Eliminating Large Primary Loop Pipe Ruptures as the Structural Design Bases for the South Texas Project," dated September 1983, prepared by S. A. Swamy and J. J. McInerney.

The subject information could mnly be duplicated by competitors if they were to invest time and effort equivalent to that invested by Westinghouseprovided,theyhavetherequisitetalentandexperience.

Public disclosure of ttiis information is likely to cause substantial l

harm to the competitive position of Westinghouse because it would

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l- simplify design and evaluation tasks without requiring a commensurate investment of time and effort. ,

Further the deponent sayeth not.

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ATTACHMENT 2-Impact of Elimination of Postulated Circumferential and Longitudinal Pipe Breaks in the RCS Primary Loop STRUCTURES, SYSTEMS, COMP 0NENTS, PROGRAMS CONSIDERED FOR IMPACT IMPACT Primary Loop Pipe Whip Restraints Deleted from Design

• Reactor Cavity / Primary Shield Wall / Reduction in pressurization loading Crane Wall /0perating Floor Steam Generator Sub-compartment No change RCS Component Supports / Heavy No change Component Supports Emergency Core Cooling Systems No change

-Containment Design No change RCS Pressure Boundary Leakage No change Detection Systems Environmental Qualification Program No change 4

• Due to small hot gaps, the hot leg pipe whip restraints currently receive relatively small loadings from postulated main steam pipe breaks. It has been shown that the Steam Generator column-supports are adequate to support the additional load in the absence of the hot leg pipe whip restraints.

Also, an analysis is being performed to show that the reactor coolant loop loadings from the main steam pipe breaks will be acceptable without the

' hot leg pipe whip restraints.

ATTACHMENT 3 Postulated RCS Primary Loop Pipe Breaks and Associated Pipe Whip Restraints Per' Unit Postulated Break Associated Whip Restraint Erection Status Locations Per Loop for Primary Loading Catawba Unit 2

1. Reactor vessel 1. Cold Leg Nozzle Break 1. Structure installed inlet nozzle Restraint (wagon wheel) without shims

2. Reactor vessel 2. Hot Leg Nozzle Break 2. Not installed outlet nozzle ' Restraint-(wagonwheel) 3.- Steam generator 3. Hot leg pipe whip 3. Structure installed inlet nozzle restraint without shims

4. 50 elbow in the 4. Hot leg pipe whip 4. Structure installed intrados(longitudinal restraint without shims slot)

5. Steam generator 5. 5. Structure installed outlet nozzle Crossover leg piperun restraint (vertical whip) with shims Crossover leg elbow Compression blocks' restraints installed without shimming

6. Reactor coolant pump 6. Crossover leg elbow 6. Compression block inlet nozzle (pump restraints installed without suction) shims

-- 7. Crossover leg closure 7. Crossover leg elbow 7. Compression blocks k weld restraints installed without shimming

8. . Reactor coolant pump 8. None outlet

' ATTACHMENT 4 Estimated Cost Savings / Operational Benefits for Elimination of Primary Loop Pipe Breaks on Catawba Unit 2 Category Cost Savings-(1983 rates) Operational Benefit

1. Elimination of RCS $0.6M - Pipe whip restraint -Substantial improvement pipe whip restraints installation cost

• in quality of ISI

$1.3ti - Occupational radiation -Substantial improvement exposure over Unit 2 in personnel access life results in dose reduction of 600 man-rem

- Simplifies plant design -Improved access for by elimination of po- operation and maintenance tential interferences with piping, hangers, -Reduced RCS heat loss to impulse tubing, etc. containment at whip restraint locations.

$0.1M - Eliminates additional hold points during -Reduced risk of unanti-initial heatup for pated pipe restraint for verifying pipe-restraint thermal growth and seismic clearances movement.

-Improvement in overall plantsafety(NUREG/CR-2136)

2. Simplification of . Pressurization loadings -Simplification of analyses analysis associated reduced on primary shield involving loadings due to with dynamic effects wall , crane wall, opera- future plant modifications, and loading conditions. ting floor, and-subcom-partment analys s.

TOTAL $2 Million 600 man-Rem (0f a ' total of 20 restraints, four have not been installt d. Shimming work has not been performed on any of the restraints.