ML20083P625
| ML20083P625 | |
| Person / Time | |
|---|---|
| Site: | 05200003 |
| Issue date: | 05/08/1995 |
| From: | Liparulo N WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | Quay T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19344C887 | List: |
| References | |
| AW-95-820, NUDOCS 9505240299 | |
| Download: ML20083P625 (12) | |
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Energy Systems Box 355 Electric Corporation Pittsburgh Pennsylvania 15230-0355 AW.95 820 May 8,1995.
1 Document Con' trol Desk U'.S. Nuclear Regulatory Commission Washington, D.C. 20555 A1TENTION:
MR. T. R. QU AY APPLICATION FOR WITilllOLDING PROPRIETARY L
INFORMATION FROM PUBLIC DISCLOSURE l
SUlHECT:
ADDITIONAL INFORMATION IN SUPPORT OF WESTINGliOUSE RESPONSE TO RAI 440.251 ON TiiE AP600 DESIGN
Dear Mr. Quay:
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 l
l version of the subject report. In conformance with 10CFR Section 2.790, Affidavit AW 95 820 accompanies this application for withholding setting forth the basis on which the identified proprietary l
1 information may be withheld from public disclosure.
1 Accordingly, it is respectfully requested that the subject information which is proprietary to I-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-95-820 and should be addressed to the undersigned.
l Very truly yours,
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N.. Liparuto, Manager Nuclear Safety Regulatory And Licensing Activities
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Kevin llohrer NRC 12115 j.
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AW-95-820 i
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COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF ALLEGIIENY:
l Before me, the undersigned authority, personally appeared James M. Brennan, who, being by i
me duty 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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\\cN_v h uuwt Ja M. Brennan, Manager Operating Plant Licensing Sworn to'and subscribed before me this
/d day of C
.1995
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Ay Notary Public i.
Notatte Seal Rose M.vu Paps,f PLtAo MonnxMW Doro,IGect County My Commet.'on Dpets 4,1996 Montar.PWWyauM*nof Nutansa 3,
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AW-95-820 (1)
I am Manager, Operating Plant Licensing, in the Nuclear 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 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 as a taade secret, privileged or as con 6dential commercial or financial information.
l (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.
1 (i)
The information sought to be withheld from public disclosure is owned and has been
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held in confidence by Westinghouse.
(ii)
The information is of a type customarily held in confidence by Westinghouse and not 1
customarily disclosed to the public. Westinghouse has a rational basis for determimng 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-95-820 1
(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 f
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 econcmic 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 capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.
(c)
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.
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-95-820 i
(c)
Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.
1 (d)
Each component of proprietary information pertinent to a particular j
competitive advantage is potentially as valuable as the total competitive I
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.
.t (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.
(iii)
The infornwion 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)
Enclosed is Letter NTD-NRC-95-4457, May 8,1995 being transmitted by Westinghouse Electric Corporation ()V) letter and Application,for Withholding -
Proprietary Information from Public Disclosure, N. J. Liparulo (W), to Mr. T. R. Quay, Office of NRR. The proprietary information as submitted for use by Westinghouse Electric Corporation is in response 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-95-820 f
This information is part of that which will enable Westinghouse to:
(a)
Demonstrate the design and safety of the AP600 Passive Safety Systems.
(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.
(e)
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 Nkt. requirements for advanced plant licenses.
(b)
Westinghouse can sell support and defense of the technology to its customers in the licensing process.
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 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 information.
The development of the technology described in part by the information is the result of '
f-applying the results of many years of experience in an intensive Westinghouse effort j
and the expenditure of a considerable sum of money.
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AW-95-820 -
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 taient and experience, would have to be expended for developing analytical methods and receiving NRC approval for those methods.
Further the deponent sayeth not, i
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Westinghouse' Proprietary Class 2C to Westinghouse Letter NTD-NRC-95-4457 1
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AP600 CHEMICAL AND VOLUME CONTROL SYSTEM
SUMMARY
OF CVS FLOW PATH RESISTANCES From To ActJ Tetel Additional Componenta Path Node Node Description Pipet.D.
K I Meelstance of Additional Grxteo if't.,01' (fUnom 2NSD Reeletance a
f! 1t t < From RCS Cold Leg to CVS Junction ! 3.624 i
2i 1 23 From CVS/RCS Tee Juncton to RNS ~ 2.52 4 Regeneratrve HX ME01 l
Connection on Regenwative Heat (Tube Side) j l
Exchanger Outlet i
l 3
23 3
From RNS Conneden on 2.624 Letdown HX ME02 j
Regenerative Heat Exchanger Outlet Aube Side) to Domineralizer inlet Header Tee Flow Meter FE001 4
3 4 From Domitieralizw Inlet Header Tee 2.624 Mixed Bed Domineralizer A i Through Mixed Bed Domineralizer A (MV01A) to Domineralizer Outlet Hoeder Tee 5
3 4
From Domineralizer inlet Hender Tee 2.624 Mixed Bed Domineralizw B i
Through Mixed Bed Dominwalizw B (MV018) to Domineraltzer Outlet Header Tee i
8 4
6 From Mixed Bed Domineralizer 2.624-Outlet Tee to Cation Bed Inlet I
f 7
6 7
From Cation Bed inlet Too Through 2.624 Cation Bed Domineralizer Colon Bed to Cation Bed Outlet Tee (MV02)
~ s 6
7 Caton Bypase From Cation Bed inlet 2.624l Tee to Cation Bed Outlet Too 2.624 l-p 7
8 From Cation Bed Outlet Tee to Reactor Coolant Futer inlet Tee f0 8
9 From Reactor Coolant firer inlet 2.624 RC Fater A Header Tee Through Reactor (MV03A)
Coolant Filler A to Reactor Coolant l
Fiber Outlet Header Tee If 8
9 From Reactor Coolant Filter inlet 2.824.
RC Filter B f
Hoeder Too Through Reactor (MV038)
Coolant Filter B to Reador Coolarti Fiber Outlet Header Tee f2 9
29 From Reactor Coolant FItw Outlet 2.824 Header Tee to WLS Letdown Connection f3 29 30 Letdown Line to the WLS 1.830' Letdown Ortftce f4 29 50 Purfication Line from WLS Letdown 2.624 Connection to Msdtoup Pump l
Connection i
78 60 14 From Makeup Pump Connection to 2.624~
Regenerative HX ME01 Regenerative Heat Eachan0er Shel (Shel Side)
SW Outlet Retum to RCS Flow Meter FE025 f6 14 18 From Regenerative Heat Eachanger 2.824 ShellSide Outlet to the RCS Auxsiary Pressurtzer Spray f7 18 20 From Auxiliary Prosaurtzer Spray 2.824 Connection to the PRHR Retum Tee t
Junction 18 20 17 From PRHR Return Tee Juncton to 8.750 the RCS Steam Generator i
ff 36 36 From the Boric Acid Tank to the 4.aas Flow Meter FT115 Three-Way Blondna Valve Diaphraam Valvo V112 1
From To Actual Twtal AMilonal Componenle i Path Node Node Desenption Pipe 1.0.
K Realstance of Additional
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(ft/com*2) * "A Reelstance 20 36 37 From Three Way Blending Valve to 4.026 the Makeup Pump Suction Header Tee Diaphragm Valve V150A 2f 37 36 From Makeup Pump Suction Header 4.026 i
Tee to Makeup Pump MP01 A l
Mindlow Retum Junction i
22} 38 45 From Makeup Pump MP01 A Mnflow 4.026 I
Retum to Makeup Pump MP01 A i
23 45 40 From Makeup Pump MP01 A to 2.624 Makeup Pump MP01 A Mindlow Inlet i
Junction I
j 24' 40 43 From Makeup Pump MP01 A Mindlow 1.689 Makeup Pump Mindlow Ordici Inlet to Makeup Pump MPot A Mindion l
i Onfee i
25 43 38 From Makeup Pump MP01 A Mindlow 1.939 Makeup Mindlow HX A Ortree to Makeup Pump MP01 A (ME 03A)
MinNiow Retum injection N
40 44 From Makeup Pump MP01 A Miruflow 2.624
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Innot to Makeup Pump Discharge HeaderTee 37 37 39 From Makeup Pump Sudion Header 4.020 Diaphreem Valve V1508 Tee to Makeup Pump MP018 Minflow Retum Jundion N
39 46 From Makeup Pump MP01B Mindlow 4.026 Retum to Makeup Pun;p MP018 N
46 41 From Makeup Pump MP01B to 2.624 Makeup Pump MP018 Minillow Inlet Jundian 30 41 42 From Makeup Pump MP01B Mwwflow 1.609 Makeup Pump MinNiow Ortfice inlet to Makeup Pump MP018 Minillom Orme.
37 42 39 From Makeup Pump MP01B Minillow 1.939 Makeup MinNiow HX B OrNtoe to Makeup Pump MP018 (ME 038)
Minflow Retum inledion 32 41 44 From Makeup Pump MP018 Miniflow 2.824 i
inlet to Makeup Pump Discharge HendeeTee 33 44 50 FromMakeup Pump Discharge 2.824 Flow Motor FT157 Header to Putfication Loop Retum Makeup Fret Jundion Tee (MY 04) 34 18 51 Aux. Spray Line From RCS 1.939 Prosaurtrer Spray Header Jundion Tee to RCS Preceuter Spray af
$1 52 Prosaurtzer Spray Line from Aux.
3.824 Spray Nozzle Sorav Connection to the Pr6Jourizer I
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5.5 5 --
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0 100 200 300 400 "
Flow - GPM Max shuice Head:
Minimum Decip Hmi:
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