ML20084N918

Requests Withholding Proprietary WCAP-10546, Technical Bases for Eliminating Large Primary Loop Pipe Rupture as Structural Design Basis for Catawba Units 1 & 2 Per 10CFR2.790. Affidavit CAW-83-80 Encl

ML20084N918
Person / Time
Site:	Catawba
Issue date:	05/01/1984
From:	Wiesemann R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML19269A110	List: ML20084N899 ML20084N918 ML20084N929
References
CAW-84-39, NUDOCS 8405170285
Download: ML20084N918 (9)

Text

- ' e \

/

\

Attachm:nt.1

( /

Nuclear Technology Division Westinghouse Water Reactor Electric Corporation Divisions m3 PittsburghPennsylvanla15230 May 1, 1984 CAW-84-39 Mr. Harold R. Denton, Director Office of Nuclear Reactor 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 May 1984

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 Congnissions's regulations.

The proprietary material 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 authorizes the utilization of the accompanying affidavit by Duke Power Company.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-84-39, and should be addressed to the undersigned.

Ver truly yours, R. A. Wiesemann, Manager Regulatory & Legislative Affairs HFC/anj cc: E. C. Shomaker, Seq.

Office of the Executive Legal Director, NRC A

A M *ol mPDRa

CAW-82-80 AFFIDAVIT ,

I COMMONWEALTH OF PENNSYLVANIA: ,

ss COUNTY OF ALLEGHENY: .

I 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, information, and be11ef:

l v

\g,4.; w - [~

/ .

D. McAdoo, Assi'frant Manager Nuclear Safety Department Sworn to and subscribed before me this 26 M day of dpd...to , 1983.

N

..!;.'.',.*l

_ . *tSW'"*?$!$bu: Uc

... n .. 3. pum '

. . . . Im f

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 public 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 l

Water Reactor Divisions.

l (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

, l Westinghouse application for withholding accompanying..this Affidavit.

. t (3) I have personal knowledge of the criteria and procedures utilized by l Westinghouse Nuclear Energy Systems in designating information as a trade secret, privileged or as confidential commercial or financial information. l (4) Pursuant to the provisions of paragraph (b)(4) of Section 2.790 of the Commission's regulations, the fo1 Towing is furnished for consideration by l the Commission in determining whether the information sought to be with-  !

held from public disclosure should be withheid.  ;

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

I (ii) The information is of a type customarily held in confidence by l Westinghouse and not customarily disclosed to the public. Westing- l house has a rational basis for determining the types of information i customarily held in confidence by it and, in that connection, I utilizes a system to determine when and whether to hole certain types of information in confidence. The application of that system and the l substance of that system constitutes Westinghouse policy and provides the rational basis required.

s

CAW-83-80 Under that system, information is held in confidence if it falls in I one or more of several types, the release of which might result in  !

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

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

of its use by any of Westinghouse's competitors without ifcense ,

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 economic advan-tage, e.g., by optimization or improved marketability. '

l l

(c) Its use by a competitor would reduce his expenditure of resour-  !

ces or improve his competitive position in the design, manufac- l ture, shipment, installation, assurance of quality, or ifcensing l a similar product.  !

(d) It reveals cost or price information, production ' capacities, l 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 j desirable. -

~. .

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 sistem 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 ava'ilable to competitors diminishes

, the Westinghouse ability to sell products and services involving the use of the information. '

(c) Use by our competitor wod1d put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

(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 depriving Westinghouse of a competi-tive advantage.

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

t CAW-'83-80 (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 being transmitted to the Commission in confidence  !

and, under the provisions of 10CFR Section 2.790, it is to be l l

received in confidence by the Commission.  !

(iv) The information sought to be protected is not available in public l sources to the best of our knowledge and belief.

l

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

Eliminating Large Primary Loop Pipe Ruptures as the Structural Design l Bases for the South Texas Project," dated September 1983, prepared by  !

5. A. Swamy and J. J. McInerney. i The subject information could only be duplicated by ccmpetitors if they were to invest time and effort equivalent to that invested by (

Westinghouse provided they have the requisite talent and experience.  :

i Public disclosure of ttiis information is likely to cause substantial l harm to the competitive position of Westinghouse because it would l simplify design and evaluation tasks without requiring a commensurate I investment of time and effort. f i

Further the deponent sayeth not. '

i l

4 I

f o

.- i

?

ATTACHMENT 2 Impact of Elimination of Postulated Circunferential and Longitudinal Pipe Breaks in the RCS Primary Loop STRUCTURES, SYSTENG, COMP 0NENTS, PROGRAMS CONSIDERED FOR IMPACT IMPACT Primary Loop Pipe Whip Restraints- Deleted from Design Reactor Cavity /Frimary Shield Wall / Reduction in pressurization Crane Wall / Operating Floor loading Steam Generator Sub-compartment No change RCS Component Supports / Heavy No change Component Supports Emergency Core Cooling Systens No change Containment Design No change RCS Pressure Boundary Leakage No change Detection Systems Environmental Qualification Program No change i

k.

~i ATTACHMENT 3 Postulated RCS Primary Loop Pipe Breaks and Associated Pipe Whip Restraints Per Unit

~

Postulated Break Associated Whip Restraint Erection Status I

= Locations Per Loop for Primary Loading Catawba Unit 2  :

1.- Reactor vessel 1. Cold Leg Nozzle Break inlet nozzle

1. Structure installed Restraint (wagonwheel) without shims

}

2. Reactor vessel 2. Hot Lcg Nozzle Break outlet nozzle

2. Not installed Restiair.t (wagen wheel)

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 i

slot)

5. Steam generator' 5.

Crossover leg pipe

5. Structure installed toutle.t nozzle runwhip) restraint (vertical with shims Crossover leg elbow Compression blocks  ;

restraints installed without shimming  ;

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

7. Crossover leg closure 7. Crossover leg elbow 7. Compression blocks weld >

restraints installed without '

shimming

8. Reactor coolant pump 8. None outlet n

(

N .

g + -

ATTACHMENT 4 Estimated Cost Savings for Elimination of Primary Loop Pipe Breaks on Catawba Unit 2 Category Cost Savings (1983 Rates)

1. Elimination of RCS $0.6M - Pipe whip restraint p

pipe whip restraints installation cost *

$1.3M - Occupational radiation exposure over Unit 2 life

- Simplifies plant design by elimination of potential interferences with piping, hangers, impulse tubing, etc.

l $0.1M - Eliminates additional hold points during initial heatup for verifying pipe restraint clearances

~,

2. . Simplification of analysis - Pressurization loadings

. associated with dynamic reduced on primary shield effects and loading wall, crane wall, operating conditions, floor, and subcompartment-analyses.

TOTAL 52 Million

• 0f a total of 20 restraints, four have not been installed. Shinsning work has not'been performed on any of the restraints.

,_