ML20135B335

Requests That W Responses to RAI on AP600 Be Withheld from Public Disclosure,Per 10CFR2.790

ML20135B335
Person / Time
Site:	05200003
Issue date:	02/20/1997
From:	Mcintyre B WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	Quay T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20057G388	List: ML20135B335
References
AW-97-1079, NUDOCS 9703030011
Download: ML20135B335 (19)

Text

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Westinghouse Energy Systems Box 355 Pittsburgh Pennsylvania 15230-0355 L

Electric Corporation AW-97-1079 February 20,1997

, Document Control Desk i

U.S. Nuclear Regulatory Commission Washington, DC 20555 l

ATTENTION:

MR. T. R. QUAY APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE i

SUBJECT:

'VESTINGHOUSE RESPONSES TO NRC REQUESTS FOR ADDITIONAL INFORMATION ON THE AP600 l

Dear Mr. Quay:

i 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 l

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 i

version of the subject report. In conformance with 10CFR Section 2.790, Affidavit AW-97-1079 l

accompanies this application for withholding setting forth the basis on which the identified proprietary information may be withheld from public disclosure.

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l Accordingly, it is respectfully requested that 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, j

Correspondence with respect to this application for withholding or the accompanying affidavit should j

reference AW-97-1079 and should be addressed to the undersigned.

Very truly yours, Ga /6"'

Brian A. McIntyre, anager

. Advanced Plant Safety and Licensing Jml cc:

Kevin Bohrer NRC OWFN - MS 12E20 9703030011 970220 PDR ADOCK 05200003:

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AW-97-1079 I

AFFIDAVIT l

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COMMONWEALTH OF PENNSYLVANIA:

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' COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally appeared Brian A. McIntyre, 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 i

in this Affidavit are true and correct to the best of his knowledge, information, and belief:

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l Brian A. McIntyre, Manager Advanced Plant Safety and Licensing Sworn to and subscribed before me this A /# day l

of h2 A f11AA22-

,1997 F

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. Notary Public l'

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AW-97-1079 j.

l (1)-

I am Manager, Advanced Plant Safety And Licensing, in the Advanced Technology Business Area, of the Westinghouse Electric Corporation and as such, I have been specifically dele' gated 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 j

Energy Systems Business Unit.

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(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 4

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 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 furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure snould be withheld.

(i)

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

)

(ii)

The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse 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 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-97-1079 (a)

The aformation 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 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 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 capacNes, 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 desirable.

There m souno policy reasons behind the Westinghouse system which include the following:

(a)

The use of such information by Westingheuse gives Westinghouse a competitive advantage over N rompetitors. 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 i

sell products and services involving the use of the information.

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AW-97-1079 (c)

Use by our competitor 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 puzzle, 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 upon the success in obtaining and maintaining a competitive advantage.

j (iii)

The information 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.

l (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 NSD-NRC-97-4991, February 20,1997 being transmitted by Westinghouse Electric Corporation (E) letter and Application for Withholding Proprietary Information from Public Disclosure, Brian A. McIntyre (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 3088A

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AW-97-1079 justification of licensing advanced nuclear power plant designs.

This information is part of that which will enable Westinghouse to:

l (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.

1 (d)

Establish technical and licensing approaches for the AP600 that will ultimately j

result in a certified design.

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(e)

Assist customers in obtaining NRC approval for future plants.

Further this information has substantial commercial value as follows:

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(a)

Westirighouse 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 the technology to its customers in the licensing process.

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.

308tA

AW-97-1079 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 considerable sum of money.

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 be expended for developing analytical methods and receiving NRC approval for those methods.

l Further the deponent sayeth not.

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ATTACHMENT 2 PRHR SENSITIVITY ANALYSIS Westinghouse Non-Proprietary 7

2/20/97

"duced Heat Transfer in Upper Horuontal cf PM HX CN TA 95-2N III.3 Presentati:n to NRC The LONF an'd LOOP cases run in Sections III.1 and III.2 were used to prepare a presenta r

status of the investigation. The presentation is included on the following pages.

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.i LOFTRAN Sensitivity To Heat Transfer in PRHR Heat Exchanger SAR LOFTRAN Analyses Assume Full Heat Transfer Capability in All Sections of PRHR' C-Tube Heat Exchanger Heat Transfer Calculations include:

• Convection

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• Critical Heat Flux

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• Transition Boiling i

• Stable Film Boiling e

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Critical Heat Flux Not Exceeded in SAR Analyses I

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Non-LOCA Transients Used To Verify Adequate PRHR Cooling Os

• Loss Of Normal Feedwater (LONF) - Verify Margin to Pressurizer Overfill

• Loss of Offsite Power (LOOP) - Verify Margin to Pressurizer Overfill

• Feedline Break (FLB) - Verify RCS Does Not Saturate 6

• Inadvertent ECCS - Verify Margin to Pressurizer Overfill i

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r LOFTRAN Sensitivity To' Heat Transfer in PRHR Heat Exchanger Preliminary Analyses Performed To Determine Sensitivity To Heat Transfer in First Horizontal Section of PRHR C-Tube Heat Exchanger.

l Initial Scopirg Analyses Limited to LONF and LOOP f

= SAR FLB Analysis Shows Excessive Margin c2 l

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• SAR Inadvertent ECCS Cases Are Complex Scenarios

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- Impact Can Be Asw^,ed From LONF & LOOP Results bj V1

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LOFTRAN Sensitivity To Heat Transfer in PRHR Heat Exchanger Loss Of Normal Feedwater Cases:

Control Heat Transfer in First (Upper) Horizontal Section of C-Tubes

• Full Heat Transfer (SAR Case)

• No Heat Transfer O

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• Stable Film Boiling k

• Stable Film Boiling in Last 3/5 of First (Upper) Horizontal Section

• Stable Film Boiling For Forced Primary Flow (>99 lb/sec)

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Figure 1 Compares Pressurizer Water Volume For These Cases Figure 2 Compares PRHR Heat Flux For These Cases O

All Cases Maintain Significant Margin To Pressurizer Overfill t

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SAR LONF Rerun 2----No Heot Transfer in First Horizontal Section 3 -.-.- - S F B in First Horizoptol y---SF8 in lost 3/5th of First Horizontal 5---

SFB in First Horizontal for Flow > 99 lb/see 1600 --

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SAR LONF Rerun l

3----No Heot Transfer in First Horizontal Seetion 3----SFB in First Horizontal 9---SF8 in lost 3/5th of First Horizontal 3

SFB in First Horizontal for Flow > 99 lb/see 0.7E-01 m

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LOFTRAN Sensitivity To Heat Transfer in PRHR Heat Exchanger.

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Loss Of Offsite Power Cases:

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Control Heat Transfer in First (Upper) Horizontal Section of C-Tubes l

• Full Heat Transfer (SAR Case) i

• No Heat Transfer Q

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. Stable Film Boiling For Forced Flow (>99 lb/sec)

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i Figure 3 Compares Pressurizer Water Volume For These Cases N

i Figure 4 Compares PRHR Heat Flux For These Cases o

y All Cases Maintain Significant Margin To Pressurizer Overfill m

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1 SAR LOOP Rerun 3----

No Heat Tronsfer in First Horizontal Section 3 -.- -. S F 8 in First Horizontal for Flow > 99 lb/see 1600 m

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2._ - - - N o Heat Transfer in First Horizontal Section 3---SFB in First Horizontal for Flow > 99 lb/see 3E-01 m

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LOFTRAN Sensitivity To Heat Transfer in PRHR Heat Exchancer RESULTS

SUMMARY

Transients Analyzed Can Accommodate Severe Reduction in Heat Transfer Capability Of First Horizontal Section of PRHR C-Tube

• It is Expected That Same is True For FLB i

impact On inadvertent ECCS Analyses Can Be Assessed Based On LONF Results o

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• Heat Transfer Reduction During Full Flow g

- Results Would Be acceptable 6s' U1 I

• Heat Transfer Reduction in Limited Portion Of Section gl

- Depends On Reduction And Size Of Portion O

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• Unrestricted Heat Transfer Reduction

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- May Require Operator Action To Prevent Pressurizer Overfill m

- Significant Time For The Action Would Be Available 6

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LOFTRAN Sensitivity To Heat Transfer in PRHR Heat Exchanger i

CONCLUSION Current PRHR Design is Acceptable o2M P

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