ML20118A795
| ML20118A795 | |
| Person / Time | |
|---|---|
| Site: | 05200003 |
| Issue date: | 09/14/1992 |
| From: | Liparulo N WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20118A794 | List: |
| References | |
| AW-92-334, NUDOCS 9209280088 | |
| Download: ML20118A795 (11) | |
Text
.,l Westinghouse Energy Systems bm Electric Corporation h" * """ *
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AW-92 334 September 14,1992-Docuter' Control Des)
U.S. Nuclear Regulatory Comruission Washington, D.C. 20555 ATTENTION: DR. TilOMAS Ml'RLEY APPL.lCATION FOR WITHHOLDING PROPRIETARY INFORMNi10N FROM PUllLIC DISCLOSURE
.j SUIDECr: RESPONS5S TO NRC REQUESTS FOR ADDITIONAL INFORMATION RELATED TO TIIE AP600 DESIGN ixar Dr. Murley:
The application for withholding is submitted by Westinghouse Electric Corporation (" Westinghouse")
pursuant to the provisions of paras;raph (h)(1) of Section 2.790 of the Commission's regulations. It contains commercial stiategie information proprietary to Westinghouse and customarily held in conlidence.
The proprietary material for which withhciding is being requested is identified in the proprietary version of the subject tepart. In conformance with 10CFR Section 2.790, Affidavit AW-92 334 accompanies tha ap/.ication for withho' cling setting forth the basis on which the identified proprietary information may be withheld _ from public discimure.
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Accordingly, it is respectfully requested that the subject information which is proprietary to _ _ _
Westinghouse be withheld from peblic disclosure in accordance with 10CFR Section 2.790 of the Commission's regulations.
Correspondence with respect to this application far withholding or the accompanyinn affidavit should reference AW.92034 and should be addressed to the undersigned.
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Very truly youts, A.
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1 N. L( ;Ipanlio, Manager Nuclear Safety And Regulatory Activities n
Inja ec:
M. P. Siemien Office of the General Counsel, NRC L Darnett NRC (12115)
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9209280088 920914' PDR ADOCK 05200003 A
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' I col'YRIGilT NOTICE l
'Ib icpcris transmitted herewith exh bear a Westinghouse copyright notice. De NRC is permitted to make the number of copies of the infonna'iion con tained in these reports which are necessary for its internal use in connection with generic and plant specific reviews and approvals as well as the issuance, denial,.unendment, transfer, renewal, modificatior., suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirernents 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. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copics beyond those necessary for its internal use which are necessary in order to have one copy available for public ac. :- in the appropriate docket files in the public document room in Washington, D.C. and in loca? pur.
c,..nent nums as may be required by NRC regulations if the number of copies subrnitted k insaf ficient for this purpose. The NRC is not authorized to make copics for the persmal us.J..
mbers of the public who make use of the NRC public documem nioms. Copies maue by the NRC must include the copyright notice in all instances and the proprietary notice if the oiiginal was identified as proprietary.
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l'ItOPitlETAlW INI'OltMATION NOTICE Transmitted herewith are proprietary and/or non proprietary versions of 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 10CFR 2.790 of the commission's regulation concerning the protection t.f proprietary information so submitted to the NRC, the information which is proprietarv in the proprietary versions is contained within brackcu and where the proprietary information has been e eted in the non-proprietary aions on t' brackets re.aain, the information that was contained within brackets and where the proprietary informa n has been deleted in the non-proprietary versions on'., the lanckets remait., the information that was contained within the brackets in the proprietary venions having been deleted. The jestification for claiming the information so designated as proprietr'y a indicated in both versions by means of lower case letters (a) through (f) contained within parentheses located as a superscript immediately following the brackets enciesing each item of information being identified as 4
proprietary or in the margin oppxsite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Section (4)(ii)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10CFR2.790(b)(1).
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4 AW-92-334 A"FIDAVIT COMMONWEALT11 OF PENNSYINANIA:
ss COUNTY OF ALLEGIIENY:
Before me, the undersigned authority, perscnally appeared N;cholas J. Liparuto, who, being by me du'j sworn a cording to law, deposes and says that he is authorized to c::ecute tHs Affidavit on behalf of Westinghouse Electric Corporation ("V/estinghouse") and that the averments of fact set forth in this Affidavit are true and correct to the c.:st of his knowledge, information, and belief:
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g Nicholas J. Lipa)tulo, Manager N
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Nuclear Safety and Regulatory Activities Sworn to and subscribed I
/ 5 r L-day before me th.is of M,e-/~Cin/St-
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Notary Public MA' M PWa, tdotsy Rfje MY8WA EkycEr/remy County My Cor:YW9 Eores Dec u 19M hartw.hrasysiuAswxmc% p %-
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AW.92 334 (1)
I am Manager, Nuclear Safety and Regulatory Activities, in the Nuclear and Advanced Technology Division, of the Westinphouse 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
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rulemaking pn.ceedings, and am authorized to apply for its withholding on behalf of the V. stinghouse Energy Systems Business Unit.
(2)
I am making this Affidavit in conformance with the provisioas of 10CFR Section 2.790 of the Commissior's regulations and in conjunction with the Westinghouse application for i
withholding accompanying this Affidavit.
(3)
I have personal knowledge af the criteria and procedurer utili/cd b; Ge Westinghouse Energy Systems Business Ur t in designating information as a trade secret, privileged or as confidential comrnercial or financial information.
(4)
Pursuant to the provisions of paragraph (b)(4) of Section 2.790 ot' the Commission's regulations, the following is furnished for consideration by the Commission in determining whethcr the information sought to be withheld from public Jisclosure should be withiwld.
(i)
The information sought to be withheld from public disclosure is owned and har been held in confidence by Westinghouse.
(ii)
The information is of a type custornarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determiniag the types of information customarily held in confiduce by it and, in that connection, c
rtillies a system to determine when and whether in hold certain types of information in confidence. The application of that systern and the surstance of that system constitutes Wes.inghouse policy and provides the ratie u basis required.
Under that system, information is held in confidence if it falls in one or more of several type.., the release of which might result in the loss of an existmg or potential competitive advantage, as follows:
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AW.92 334 (a)
The information reveals the distinguishing aspects of r pme u (or component,=
structure, tool, method, etc.) where prevention of its me 9 any -.
' Westinghouse's competitors without license stom Westinghouse constitutes a competitive economic advantage over other companies.
(b)
It consists of supporting da'a, including test data, relative to (. process (or ccmponent, str cture, tool, methad, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved =
marketability.
(c)
Its use by a cor'petitor would reduce his expenditure of resources or improve 4
his cornpetitive position in the design, manufacture, shipment, installation, assunmce t' quality, or licensing a similar pmduct.
(d)
It revents cost or price information. production :apacitics, budget levels, or -
commercial strategies of Westinguouse, its customers or suppliers.
g) li reveals aspects of past, present, or f uture Westinghouse or customer funded development plerts and programs of potential commercial value to Westinghouse.
(f)
It contains patentable ideas, for which patent prctection may be dc:.irable.
There are ound policy reasons behind the Westin3 ouse system which include the h
following:
i; (a)
The use of such information by Westmghouse gives Westin thour l
competitive advantage over its competitors. It is, thw.-f.;re, wit? ' elo from l-disck>sure to protect ite Westinghouse competitive position.
(b)
It is information which is marketable in many ways. The extent to which such informntion is available to comperPors diminishes the Westinghouse ability to t
sell products and services involving the use of the information.
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AW 92-334
.(c)-
Use ny our competitor would put Westinghouse at a competitive disadvantage i
by reducing his expenditure of resources at our expense.
(d)
Each compment of proprietary information p:rtinent to a particular competitive advantage is potentiaily as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puule, thereby depriving Westinghouse of a competin've advantage.
(c)
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.
jii)
The information is being transmitted to the Commission in confidence and, under the j
provisions of 10CFR Section 2.790, it it 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 emplo, ed in the same original manner or method i
to the best of our knowledge and belief.
(v)
Enclosed is Letter ET-NRC-92-3722, September 19'12, being transmitted by l
Westinghouse Electric Corporation ($ letter and Application for Withholding Proprietary information from Public Disclosure, N. J. Liparulo (E, to Dr. Thomas l
Murley, Director, Office of NRR. ;he proprietary information as submitted for use by Westinghouse Electric Corporation is in response ta questions concerning the AP600 plant and the associated design certification application and is expected to be applicable in other licensee submittats in respmse to certain NRC requirements for justification of licensing advanced nuclear power plant designs.
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AW 92 334 -
This information is part of that vhich will enable Westinghouse to:
(a)
Den.unstrate the design and safety of the AP600 Passive Safety Systems, i
-(b) fistablish 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.
(c)
Assist customers in obtaining NRC approval for future plants.
Futther 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 NRC requirements for advanced plant licenses.
(b)
Westinghouse can sell support and defense of tiie technology to its customers in the licensing pmcess, Public disch)sure of this proprietary information is lik'ely to cause substantial harm to -
the coinpetitive position sf 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 corntnensurate expensesc Also, public diselnsure 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 of experience in an intensive Westinghouse effort and the expenditure of a considerabic sum of money.
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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 have to Le expended for developing analytical methods and receiving NRC approval for those methods.
Further the deponent sayeth not.
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i ET-fiRC-92-3722 N SRA-APSL-92-0 M4 ATTACHMENT This attachment contains 192 pages of AP600 desion information to be used in completing the specifications and conceptual design for the ROSA IV AP600 modif cations. It contains the fol'owing:
1)
Westinghouse COBRA / TRAC Steady State Loop Model 10 pages 2)
Saf eguards data including information on: IRWST, Passive Residual Heat 11 pages Removal Heat Exchanger Automatic Depressurization System Valve, ADS Sparger, Pressunzer, Reactor Coolant Pump, Core Makeup Tank, and Accumulator, 3)
Information for modelng the AP600 Passive Safety Systems, including TRAC 109 pages input summanes 4)
Reador Tnp S' nals 8 pages g
5)
Drawings of Pressurizer and Surge line details:
15 pages Primary Coolant Loop Outhne DWG PLO1 V2-001, Rev 3, Sh 1 of 7 Pnmary Coolant Loop Outline DWG PL01-V2-001, Rev 3. Sh 2 of 7 Pomary Coolant Loop Outhne DWG PLO1 V2-001, Rev 3. Sh 3 of 7 Pomary Coolant Loop Outline DWG PLO1-V2 001, Rev 3, Sh 4 of 7 Primary Coolant Loop Outhne DWG PL01-V2-001, Rev 3, Sh 5 of 7 Pnmary Coolant Loop Outline DWG PLO1-V2-001, Rev 3, Sh 6 of 7 Pnmary Coolant Loop Outhne DWG PL01 V2-001, Rev 3, Sh 7 of 7 AP 600 Pressurizer Outline.1300 Cu. Ft, DWG MV2041-001, Rev 1, Sh 1 of 2 AP-600 Fiessunzer Outline,1300 Co. Ft., DWG MV20-V1-001, Rev 1, Sh 2 of 2 Pressunzer General Arrangement and Details, MV20-V2 0W., f.ev 2, Sh 1 of 3 Pressunzer General Arrangement and Details, MV20-V2-001, Rev 2, Sh 2 of 3 Pressunzer General Arrangement and Details, MV20N2 001, Rev 2. Sh 3 of 3 Pressurizer Heater Assembly, MV20 V2-101, Rev 1, Sh 1 of 1 Retaining Basket. Dwg 395A 879 Detads of Lower and Upper Heater Support Plate Bracket, Ret No. 23 and 24 1
6)
Core Makeup Tank Drawings 2 pages Core Makeup Tank Outhne Dwg, ADPS245DMYXM001, Rev 1, Sh 1 of 1 Core Makeup Tank Assembfy Drawing, ADP5245DMYXM003, Rev. O. Sh 1 of 1 j
7; Pasr.ive Core Cooling System P&lD, Dwg 1874E76, AP600 Doc. PXS M6-001, 1 page Rev 4 8)
Reactor Vessel St Nozzle In'armation 2 paces l
1 AP600 St Drverter Skotch. D. Ekeroth,10391 l
Vessel Drawing M101-V2-101
e 9)
The following Avondale drawings / Study Sketch East Corrposite Below 12 pages Elevation 107' 2" Drawng No.1120-PLK-001 Rev B Drawing No 1120-PLK 002, Rev B Drawing No.1120 PLK 003, Rev B Drawing No.1120-PLK-004, Rev B Drawing No.1120-PLK-005, Rev B Drawing No.1123 PLK 001, Rev B Drawing No.1123 PLK 002, Rev B Drawing No.1124-PLK-001, Rev B Drawing No.1120-PLK-006, Rev B Drawing No.1120 PLK 007, Rev B Drawing No.1120-PLK-008, Rev B Drawing No.1124 PLK-002 Rev B
- 10) The following Avondale drawings / Study Sketch Passive RHR Supply &
9 pages Return. Pre surizer Letdown Piping to Spargers & Misc. Piping Drawing No. MO-129-127 Rev F. Sheet 1 Drawing No. MO-129127, Res F Sheet 2 Drawing No.1150-PLK-001 Drawing No.1100-PLK-803 Drawing No. MO-129-127, Rev F, Sheet 5 Drawing No. MO 129-127, Rev F. Sheet 6 Drawing No. MO 129127 Rev F, Sheet 7 Drawing No. MO-129127. Rev F, Sheet 8 Drawing No. MO 129-127, Rev F Sheet 9
- 11) General Arrangement Drawings 15 pagos General Arrangernent Plan at El. 66'-6",1010-P2-001, Rev. 3 Generai Arrangernent Plan at El. 82'-6*,1020 P2-001, Rev. 3 General Arrangement Plan at El. 96*-6",1020 P2-002, Rev. 3 General Arrangement Plan at El. 100'-0" & 107'-2",1030-P2-001 Rev. 3 Ger,eral Arrangement Plan at El 117'-6",1040-P2-001, Rev. 2 General Arrangernent Operating Deck El. 135'-3",1050-P2-001, Rev. 2 General Arrangement Root Plan El. 160'-6" & 153'-0",1060-P2 001, Rev. 2 General Arrangement Plan at El. 160'-6* & 180'-0",1070 F 2 001, Rev. 2 Genera! Arrangement Section A-A,1000-P2-901, Rev. 3 General Arrangement Section B 8,1000-P2 902, Rev. 2 General Arrangement Sections C-C & H-H,1000-P2-903, Rev. 2 General Arrangement Section G-G,1000-P2 904, Rev. 3 General Arrangement Section J-J.1000-P2 905 Rev. 3 General Arrangement Section K-K,1000-P2 906, Rev. 3 General Arrangement Sections D-D, E-E, F-F, N N,1000 P2 907, Rev. 2
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