ML20118B025
| ML20118B025 | |
| 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 | |
| ML20012G129 | List: |
| References | |
| AW-92-357, NUDOCS 9209290258 | |
| Download: ML20118B025 (10) | |
Text
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t Westinghouse Energy Systems B^e 3n Electric Corporation
"** N*" W33 03M AW-92-357 Septembc. 14,1992 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTENTION: DR. THOMAS MURLEY APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
SUBJECT:
RESPOI;3ES TO NRC REQUESTS FOR ADDITIONALINFORMATION RELKMD TO SPES2 TEST FACILFFY
Dear Dr. Murley:
The application for withholding is submitted by Westinghouse Electric Corporation CWestinghouse")
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.
'Da. p.oprietary material for which withholding is being requested is identified in the proprietary version of the rubject report. In conformance with 10CFR Sect on 2.790, Affidavit AW-92-357 accompanies this i
application for withholding setting forth ;he basis on which the identified proprietary information may be withheld from public disclosure.
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Accordingly, it is respectfully requestet' iat the subject information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10CFR Section 2.790 of the Commission's
. regulations.
i Correspondence witia respect to this application for withholding or the accompany:ng affidavit should l
reference AW-92-357 and should be addressed to the undersigned.
l Very truly yours.
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N. J. L trulo, Manager I
Nuclear Safety And Regulatory Activities
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M. P. Siemien Gffice of the General C unsel, NRC L Barnett NP.C (12H5) 0576A 9209290258 920914
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l COPYRIGIIT NOTICE The reports trat.nitted herewith each bear a Westinghouse copyright notice. The NRC is perm.rted to l
make the nurnber of copies of the information contained in these report < which are necessary for its internal use in connection with geactic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, tenev al, n
..eation, suspension, revocation, or violation of a license, perrnit, order. or regulation subject to the requirements of 10 CFR 2.790 regarding rcstrictions on public disclo3ure 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 copies beyond those nect.ssary for its internal use which are necessary in order to have one copy available for public viewing in the apprag;;.t: docket files in the public document rmm in Washington, D.C. and in local public Axument noms as may be reqcited by NRC regulations if the number of copies submitted is insufGeient for this purpose. The NRC is not authorized i
to mak; copies for the personal use of rnembers of the puNic who make use of the NRC public document Copies made by the NRC nust include the copyrigbt notice in ali instances and the proprietary rooms.
i notice if the original was identifi'd as proprietary.
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PROPRilfrAltY IN1'OllMATION NOTICE i
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l Transmitted herewith are proprietary and/or non-proprietary versicas of docu nents furnished to the NRC m cont.ection v sth requests for generic and/or plant specific review and app. oval.
I in order to conform to the requirements of 10CFR 2.790 of the commission's regulation concerning the protection of proprietary nformation so submitted to the NRC, the infermation which is propr etary in the i
i proprietary versions is contained within brackets ned where the proprietary infctmation has been deleted in the non-proprietary versions on the brackets remain, the information that was contained within brackets and whcre the proprietary information has been dJeted in the non proprietary versions only the brackets remain, the information that was contained wittic the brackets in the proprietary versions h; ing been l~
deleted. The justification for claiming the information so designated as prop ictary is indicatcJ in both versions by means of lower caw letters (a) through (f) contained within parenthescs located as a l
superscript immediately followir the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the type,s of information Westinghouse customarily holda in confidence identified in Section (4)(ii)(a) through (4)(ii)(f) l of the affidavit accompanying this transmittal pursuant to 10CFR2.790(b)(1).
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t AW-92-357 AFFIDAVIT COMMONWEALTil OF PENNSYINANIA:
ss COUNTY OF ALLEGilENY:
t Defore me, the undersigned authority, per..ane!!y appcared Nicholas J. Ligurulo, who, being by me duly sworn according to law, deposes and uys that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Corporation (" Westinghouse") and that the avermenis of fact set forth it, this Affidavit are uue and correct to the best of his knowledge, information, and belief:
N\\ % %F + L Nicholas J. Liparuto, Manager Nuclear Safety a.d Regulatory Activities Sworn to and subscribed l
before me this
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. AW-92-357.
i (1)
I am Manager, Nuclear Safety and Regulatury Activitics, in the Nuclear and Advanced Technology Division, of the Westinghouse Electric Corporation and as such, I have been specifically
- legated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with auclear ;ower 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 ' CfM Section 2.790 of the.
Cornmission's regulations and in conjunction with the Westinghon...p;aation for withholding accompanying this Affidavit.
l (3)
I have personal knowledge of the criteria and procedures utilized by the Westinghouse Energy Systems Business Unit 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 following is furrished for consideration by the Commission in determining whether the: information sought to be withheld from public disclosure should be withheld.
(i)
The information sought to be withhe8J fro,n public disclosure is owned anu has been held in confidence by Westinghousc.
l (ii)
The information is of a type customarily held in con 0dence by Westinghouse and not customarily disclor.ed to the public. Wes'inghouse has a rational basis foi determining the types of information customarily held in confidence by it and, in that es..:nection, utili/cs 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 coristitntes Westinghouse policy and provides the rational basis required.
Under that system, information is held in confidence if it falls in one or more r,"
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-92 357 9
R (a) ne 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 companics.
(b)
It consists of supporting data, including test data, relative to a process (or i
componcet, structure, tool, methtx1, etc.), the application of which data secures a competitive economic advantage, e.g., by optimitation or improved marketability.
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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 pnx!uct.
(d)
It reveals cost or price information, production capacities, budget levels, or commercial strategics of Westinghouse, its customers or supplicts.
(c)
It reveals aspects of past, present, or future Westinghouss or customer funded -
i 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 Weuinghouse system which incitdc the following:
(a)
The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. If is, therefore,' withheld from disclosure to protect the Westinghouse competitive position.
It is information which is marketable in niany ways. The extent to wnich such (b) information is available to comptitors diminishes the Westinghouse ability to
. Il products and services involving the use of "ic information.
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(c)
Use by our conepetitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.
(d)
Each component of proprietary information pertinent to a particular 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 puule, thereby depriving Westinghouse of a competitive advantage.
(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 epon the success in obtaining and maintaining a competitive advantage.
(iii)
The information is being transmitted to the Commission in confidence and, undet 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 availabic 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 ET-NRC-92-3749, September 1992, being transmitted by Westinghouse Electric Corporation @ letter and Application for Withholding Proprietary Informat.cn from Public Disclosure, N. J. Liparuto @, to Dr. Thomas Murley, Director, Office of NRR. The proprietary information as submitted for use by.
Westinghouse Electric Corporation is in response to questions conecrning the AP600 plant and the nssociated design certification application and is expected to be applict.ble in other licensee submittals in response to certain NRC requirements _for justification of licensing advanced nuclea power plant designs.
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AW 02 357 This information is part of that which will enable Westinghouse to:
(a)
Demonstrate the desigt: and safety of the AP600 Passive Safety Systems.
(b)
Establish 9pplicable verification testing melhorts.
(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.
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 NRC requirements for advanced plant licenses.
(b)
Westinghouse c n sell support and defans:: of the technology to its customers in the licensing process.
Public disclosure of this proprietary information is likely to cause sut>stantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similai advanced nuclear power designs and iic< ;ing defense services for commercial power reactors without commensurate expenses. Also, public dischwure of the information would enable others to use the information to meet NRC requirements for licensing Jocumentation without purchasing the right to use the information.
The development of the teeMogy described in part by the information is the result of -
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applying the results of many years of experit. ace in an intensive Westinghouse effort and the expenditure of a considerable sum of money.
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In order for competitors of Westinghouse to duplicate this infoimation, similar technical programs would have to be performed and a significant maapower effort, having the requisite talcat and experience, would tsve to be expended for develo;d:g analytical method 3 and receiving NRC pproval for those methods.
Further the deponent sayeth not.
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RESPONSES TO NRC OUESTIONS ON WCAP-13277 QUESTION:
1.
The modifications to SPES as described in WCAP-13277 do not represent the most recent version of the AP600 design. How will design changes made after preparatien of the report be incorporated? Among the specific components of concern are the pressurizer surge line and the steam generators.
RESPONSE.
The latest AP600 design changes have been provided to SEIT for incorporation into the modified SPES-2 ( AP600) representation. The pressurizer surge line changes will also be g
included in the design changes. We are currently performing the scaling analysis on this particular line to develop the geometry and size for the SPES-2 facility. With regard to the generators, while the AP600 design has changed to the Delta 75 model, the SPES generators more acewately represent a Model F U-tube generator. These generators will not be changed for the SPES-2 (AP600) simulation. Since the purpose of the experiments is to validate system codes at high pressure for PWR's with AP600 passive safety systems, the model F generator is sufficienth representative of the AP600 such that they do not have to be altered.
QUESTION:
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2.
The report describes the primary system layout as having a single cold and a single hot leg for each loop. Information received as a result of the recent visit by an NRC staff member to SIET indicates that this configuration has been modified. There is also no information in the WCAP regarding the SPES-2 down omer design, which has also apparently been changed. What will be the primary systet i configursion, and how closely will it resemble the AP600 layout' Also in this regaa.1, how will the simulated CMTs be incorporated into SPES-2?
RESPONSE
The loop configuratior. which will be used for the SPES-2 (AP600) is shown in Figure 1 which includes a ringle pump attache i 10 the outlet plenum of he steam generator by a single pipe. The flow will split after the pump into two cold legs per loop which end at an annular downcom-which surrounds the upper imheated portion of the rod bundle. The upper portion of the dc wneomer is an annulus as shown in Figure 2 with all four cold legs entering. There will be flov affles between the cold legs and the DVI injection locations to simulate the hot leg blockage and to obtain proper circumferential flow AP. The flow from the bottom of the annular downcomer will flow into a pipe which is parallel but separate from the heater rod bundle. The downcomer pipe connects to the simulated lower plenum below the heated portion of the rod bundle ol15XMILll W M )
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