ML20087G322

Application for Withholding Proprietary Rept WCAP-10487, Technical Basis for Eliminating Pressurizer Surge Line Ruptures as Structural Design Basis

ML20087G322
Person / Time
Site:	Catawba
Issue date:	02/15/1984
From:	Wiesemann R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML19292D068	List: ML20087G310 ML20087G322 ML20087G335
References
CAW-84-13, NUDOCS 8403190399
Download: ML20087G322 (9)

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Attachment 1 t

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1 Water Reactor Nucksiechebgy0ivish l Wesdn$ouse Bectric Corporation ' Divisions ~ m ass i PmsburghPennsylvanials230  :

February 15, 1984 .

CAW-84-13 s_ m Mr. Harold'R'. Denton, Director

.0ffice of Nuclear Reactor Regulation 1U. S. Nuc* ear, Regulatory Commission

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

REFERENCE:

Duke Power Company letter to NRC dated February 1984 I

Dear Mr. Denton:

1The proprietary material for which withholding .is being requested in the l reference letter by Duke Power Company.is further identified in an affidavit  !

signed by the owner of the proprietary infonnation, 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 Comission'and addresses with specificity the considerations listed in para-

graph

(b)(4) of,10CFR Section 2.790 of the Commission'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.

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Accordingly, this letter authorizes the utilization of the accompanying

affidavit by Duke Power Company.

Correspondence with respect to the proprietary aspects-of_ the application

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' for withholding ~or the Westinghouse affidavit should reference this letter, CAW-84-13,.and should be addressed to the undersigned.

f Very truly yours, Robert A. Wiesemann, Manager ,

, /bek~ Regulatory & Legislative Affairs ,

7; 'cc: E. C.-Shomaker, Esq. -

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Office of the Executive Legal Director, NRC -

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CAW-63-20

. AFFIDAVIT i

COMMON'nALTH OF PENNSYLVANIA:

ss COUNTY OF ALLEGHENY:

.i Before me, the undersigned authority, personally appeared John D. McAdoo, who, being by me duly sworn according to ~ 1aw, deposes and says that he is authorized to execute this Affidavi.t 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 Jeffef:

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• D.McAdoo,AssidntManager Nuclear Safety Department i

Sworn to and subscribed before me this M 5 day of 1,t.. w 1ees.

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CAW-83-80 (1) I am Assistant Manager, Nuclear Safety Department, in the Nuclear Technc-logy Division, of Westinghouse Electric Corporation and as sucn, 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 j j authorized to apply for its withholding on behalf of the Westinghouse l Water Reactor Divisions.

.(2) I as making this Affidavit in coriformance with the provisions of 10CFR Section 2.790 of the Commission's regulations and in can, junction with the Westinghouse application for withholding accompanying this Affidavit.

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(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.

l _ (4) Pursuant to the provisions of paragraph (b)(4) of Section 2.790 of the l Commission'sregulations,thefeitosingisfurnishedforconsiderationby

the Commission in determining whether the information sought to be with-i held from public disclosure should be withheid.

(1) The information sought to be withheld from public disclosure is owned

! and has been held in confidence by Westinghouse.

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

substance of that system constitutes Westinghouse policy and'provides the rational basis required.

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. CAW-83-80 Under that system, information is held in confidence if it falls in one or more of several types, the release of whi.ch might result in the loss of an existing or potential competitive advantage, as followi::

(a) The information reveals the distinguishing aspects of a process (or comp'onent, 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 suppcrting 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.

( (c) Its use by a competitof would reduce his expenditure of resour-l- ces or improve his competitive position in the design, manufac-l ture, shipment, installation, assurance of quality, or 11cansing a similar product.

(d) It reveals cost or prica information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers. .

L (e) It reveals aspects of past, present, or fu'ture Westinghouse or customer funded development plans and programs of potential coanercial value to Westinghouse.

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

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CAW-83-80 l

(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 $estinghouse ability to sell products and services involving the use of the information. '

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

4 (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 jeopardize the position of promi-nonce of Westinghouse in the world market, and thereby give a market advantage to the competition in those, countries.

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, CAW-83-80 (f) The Westinghcuse 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 received in confidence by the Comission.

(iv) . The information sought to be protec, 's not available in public

-sources to the best 6f our knowledge anu belief.

(v) The proprietary information sought to be withheld in this submittal is th::t which is appropriately marked in " Technical Bases for Eliminating Large Primary Loop Pipe Ruptures as the Structural Design 3ases for the South Texas Pr-oject,' dated September 1983, prepared by S. A. Swamy and J. J. McInerney.

The subject information could only be duplicated by competitors if they were to invert time and effort equivalent to that invested by Westinghouse provided they have the requisite talent and experience.

Public disclosure of this information is likely to cause substantial harm to the competitive position of Westinghouse because it would simplify design and evaluation tasks without requiring a comensurate 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 L

in the Pressurizer Surge Lines Structures, Systems, Components.

Programs Considered for Impact Impact Pressurizer Surge Line Pipe Whip Deleted from Design Restraints and Jet-Barriers Primary Shield Wall / Crane Wall / Reduction in pressurization loading Operating Floor RCS Pressure Boundary Leakage No change Detection Systems Environmental-Qualification Program No change n.

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Attachment 3 Postulated Pressurizer Surge Line Pipe Breaks and Associated Rupture Devices Erection Status Postulated Break Location Devices Associated with Break

• Catawba Unit 2

1. Terminal end at 21 pipe whip restraints Not installed Pressurizer Nozzle

2. Terminal end at 21 pipe whip restraints Not installed hot leg connection and 2 jet deflectors

3. Intermediate break 21 pipe whip restraints Not installed at Node 2AA

- 4. Intermediate break 21 pipe whip restraints Not installed at Nodes 9B, 9ABA,.& and 1 jet deflector 9AB

• All 21 Pressurizer Surge Line pipe whip restraints are loaded by each of this line's breaks. Thus, the total number of devices being deleted is 21 pipe whip restraints and 3 jet deflectors.

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Attachment 4

,' Summary of Benefits from the Elimination of Pressurizer Surge Line Pipe Breaks on Catawba Nuclear Station. Unit 2 Category Benefit

-1. Design, material and erection costs $1.1 million*

associated with 24 rupture devices.

2. Plant design Simplifies overall plant design by elimination of potential inter-ferences with piping, hangers, impulse tubing, etc.

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3. Relief of congestion, improving 216 man-rem reduction in radiation access for operation and maintenance. exposure over life of Unit 2

($595,000)

4. Reduction' in piping heat loss at ' Not quantitatively assessed.

whip restraint locations.- Insulation can be installed on piping at current locations of Pressurizer Surge Line pipe whip restraints.

5. Improvement in overall plant Improvement in ISI quality.

safety (NUREG/CR-2136). Elimination of potential for restricted thermal or seismic movement.

• Current (1984) dollars.

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