ML20147B285
| ML20147B285 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 12/16/1987 |
| From: | Wiesemann R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | Murley T Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML16223A662 | List: |
| References | |
| CAW-87-132, NUDOCS 8801150191 | |
| Download: ML20147B285 (10) | |
Text
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v Westinghouse Power Systems Nuclear TeWology Electric Corporation snten,s onusa Box 355 Pi!!sbu@ Pennsytvania 15230 0355 -
December 16, 1987 CAW-87-132 Dr. Thomas Murley, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 Application for Hithholding Proprietary Information from Public Disclosure RESPONSES TO NRC OUESTIONS REGARDING FAST RESPONSE.
NARR0H RANGE. THERM 0 HELL MOUNTED RTDs
Dear Dr. Murley:
The proprietary material for which withholding is being requested in the enclosed letter by the Houston Lighting & Power Company is further identified in an affidavit signed by the owner of the proprietary information, Westing-house 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 paragraph (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 CAH-85-044.
Accordingly, this letter authorizes the utilization of the accompanying affidavit by Houston Lighting & Powar Company.
Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this
- letter, CAH-87-132, and should be addressed to the undersigned.
Very truly yours, 91 B 90 W
g$il c6 0 PDR Rob rt A. Hiesemann, Manager P
gulatory & Legislative Affairs
/ daw Enclosure (s) cc:
E. C. Shomaker, Esq.
Office of the General Counsel, NRC
PROPRIETARY INFORMATION NOTICE TRANSHITTED HEREHITH ARE PROPRIETARY AND/0R NON-PROPRIETARY VERSIONS OF DOCUMENTS FURNISHED TO THE NRC IN CONNECTION HITH REQUESTS FOR GENERIC AND/0R PLANT SPECIFIC REVIEH AND APPROVAL.
IN ORDER TO CONFORM TO THE REQUIREMENTS OF 10CFR2.790 0F THE COMMISSION'S REGULATIONS CONCERNING THE PROTECTION OF PROPRIETARY INFORMATION SO SUBMITTED TO THE NRC, THE INFORMATION HHICH IS PROPRIETARY IN THE PROPRIETARY VERSIONS IS CONTAINED WITHIN BRACKETS AND WHERE THE PROPRIETARY INFORMATION HAS BEEN DELETED IN THE NON-PROPRIETARY VERSIONS ONLY THE BRACKETS REMAIN, THE INFORMA-TION THAT HAS CONTAINED HITHIN THE BRACKETS IN THE PROPRIETARY VERSIONS HAVING BEEN DELETED.
THE JUSTIFICATI0ll FOR CLAIMING THE INFORMATION S0 DESIGNATED AS PROPRIEIARY IS INDICATED IN BOTH VERSIONS BY MEANS OF LOWER CASE LETTERS (a)
THROUGH (g) CONTAINED HITHIN PARENTHESES LOCATED AS A SUPERSCRIPT IMMEDIATELY FOLL0HING THE BRACKETS ENCLOSING EACH ITEM OF INFORMATION BEING IDENTIFIED AS PROPRIETARY OR IN THE MARGIN OPPOSITE SUCH INFORMATION.
THESE LOHER CASE LETTERS REFER TO THE TYPES OF INFORMATION HESTINGHOUSE CUSTOMARILY HOLDS IN CONFIDENCE IDENTIFIED IN SECTIONS (4)(11)(a)
THROUGH (4)(ii)(g) 0F THE AFFIDAVIT ACCOMPANYING THIS TRANSMITTAL PURSUANT T0 10CFR2.790(b)(1).
AW-76-60 AFFIDAVIT C0!'N0HWEALTH OF PENNSYLVANIA:
ss C0l!NTY OF ALLEGHENY:
Before me, the undersigned authority, personally appeared Robert A. Wiesemann, who, being by me duly sworn according to law, de-poses and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Corporation ("Westinghouse") and that the aver-ments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:
bbl d)&!!W W Robert A. Wiesemann, Manager Licensing Programs Sworn to and subscribed before,methis/
day of.lfsndth 1976.
1 l
'((l&. b' M4r &
/
Notary Public,,.
l AW-76-60 (1) I am Manager, Licensing Programs, in the Pressurized Water Reactor Systems 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 dis-closure in connection with nuclear power plant licensing or rule-making proceedings, and am authorized to apply for its withholding on behalf of the Westinghouse Water Reactor Divisions.
(2)
I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.790 of the Commission's regulations and in con-junction with the Westinghouse application for withholding ac-companying this Affidavit.
(3)
I have personal knowledge of the criteria and procedures utilized by Westinghouse fluelear Energy Systems in designating iriformation 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 in-formation sought to be withheld from public disclosure should be withheld.
(1) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.
-3.
AW-76-60 (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 ap-plication 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 falle in enc er mere of several t'y.nas the release of which might result in the loss of an existing or potential com-petitive advantage, as follows:
(a) The 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 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, i
i k
+
AW-76-60 (c)
Its use by a competitor would reduce his expendihire 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 cap-acities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.
(e)
It reveals aspects of past, present, or future West-inghouse or customer funded-deve,lopment plans and pro-gre5 of potentici commercial valoa tn Westinghouse.
(f)
It contains patentable ideas, for which patent pro-tection may be desirable.
(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 Wtistirighouse system which include the following:
(a) The use of such information by Westinghouse gives l
Westinghouse a competitive ad/antage over its com-petitors.
It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.
\\
. AW-76-60 (b)
It is information which is marketable in many ways.
The extent to which such infermation is available to competitors diminishes the Westinghouse ability to sell produc' and services involving the use of the 4
information.
(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.
(d) Each compnnent of proprietary information pertinent tn a particular competitive advantage is potentially as valuable as the total competitive advantage.
If competitors acquire components of proprietary infor-mation, 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 in those countrics.
(f) The Westinghouse < capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.
1 i
Attechment'3 AH-70-60 i
(iii)
The information is being transmitted to,the Commission in confidence and, under the provisions of-10 CFR Section 2.790, it is to b'e received in confidence by the Commission.
(iv)
The information is not available in public sources to the best of our knowledge and belief.
(v)
The proprietary information sought to be withheld in this sub-mittal is that which is appropriately marked in the attach-ment to Westinghouse letter number NS-CE-1298, Eiche1dinger to Stolz, dated December 1,1976, concerning information relating to lOC revicw of UCAP oES7-9 and ucap RuR entitled. "Improved Thermal Design Procedure," defining the sensitivity of DNB ratio to various core parameters. The letter and attachment are being submitted in response to the NRC request at the October 29, 1970 NRC/ Westinghouse meeting.
This information enables Westinghouse to:
(a) Justify the Westinghouse design.
(b) Assist its customers to obtain licenses.
l (c) Meet warranties.
l (d) Provide greater operational flexibility to customers assuring them of safe and reliable operation.
(e) Justify increased power capability or operating margin for plants while assuring safe and reliable operation.
AW-76-60 (f) Optimize reactor design and performance while maintaining a high level of fuel integrity.
Further, the information gained from the improved thermal design procedure is of significant commercial value as follows:
(a) Westinghouse uses the information to perform and justify analyses which are sold to customers.
(b) Westinghouse sells analysis services based upon the experience gained and the methods developed.
Public disclosure of this information concerning design pro-cedures is likely to cause substantial harm to the competitive position of Westinghouse because competitors could ' utilize this information to assess and justify their own designs without commensurate expense.
The parametric analyses performed and their evaluation represent a considerable amount of highly qualified development effort.
This work was contingent upon a design method development pro-gram which has been underway during the past two years.
Altogether, a substantial amount of money and effort has been expended by Westinghouse which could only be duplicated by a competitor if he were to invest similar sums of money and pro-vided he had the appropriate talent availabic.
Further the deponent sayeth not.
J i
attachment 4 SI *1L AE 2460 Page 1 of 1 Additf.onal RTD Information Per the conversations between the NRC staff and HL&P on December 18, 1987, the following clarifying information is provided. Additionally, HL&P will provide the staff with test program results confirming the accuracy of the RTD temperature measurement.
1.
On page 8 of 9 of Attachment 1 to ST HL-AE-2409 dated November 12, 1987, no FSAR section is referenced for steamline rupture at power.
STP FSAR Section 15.1.5 discusses the effects of steamitne rupture.
For STP the 1
most limiting case is steamline rupture at zero power (ref. p.15.1-12).
In these analyses initial hot shutdown conditions are assumed at time zero (ref, p. 15.1 15) so the reactor is already in a tripped condition j
and RTD response time does not play a role in the conclusion for zero power steam line rupture, i
The analyses reperformed by Westinghouse for the steamline rupture at t
1 l
power, which include RTD time response effects, confirmed that the j
rupture at zero power is still the most limiting case for DNBR.
f 1
2.
Re WCAP-11701/2 Answer la:
STP Technical Specifications do not address the full power trip test.
This test is performed as pr.rt of the STP 1
initial test program and is described in procedure 1 PEP 04-ZY-0102, t
Determination of RCS hot leg RTD response time is specifically identified 4
as one purpose of the test.
e 3.
Re WCAP 11701/2 Answer 1b: As discussed in ST-HL AE-2429 dated December 1, 1987, the worst case margin in-the increased response time is approximately one second.
In most cases, a margin of two-three seconds is expected. As specified in the STP Technical Specification 4.3.1.2, functional response time is demonstrated once per 18 months.
t 4.
Re WCAP 11701/2 Answer 3c:
The normal periodic surveillance for i
operability is as specified in Tech Spec Table 4.3-1 for overtemperature
{
delta T and overpowcr delta T; i.e., channel calibration each refueling i
and a quarterly analog channel operational test. Also, the QDPS provides the operator with RTD outputs so that the operator can determine if one channel deviates excessively from the others, i
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l L1/NRC/ad l
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