ML20150E612
| ML20150E612 | |
| Person / Time | |
|---|---|
| Site: | 05000601 |
| Issue date: | 03/23/1988 |
| From: | Wiesemann R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19302D372 | List: |
| References | |
| AW-88-024, AW-88-24, NUDOCS 8804010133 | |
| Download: ML20150E612 (19) | |
Text
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t Westinghouse Power Systems p%'y]pp,g,m am Electric Corporation i
March 23, 1988 AW 88-024 i
Docket No. STN 50-601 Document Control Desk U.S. Nuclear Regulatory Comission Washington, D.C.
20555 Attention:
Lester Rubenstein, Director Standardization & Non-Power Reactor Project Directorate APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
Submittal of Amendment 2 to WAPWR RESAR-SP/90 PD4 Module 2, "Regulatory Conformance" 4
Reference:
Letter No. NS-NRC-88 3316, Johnson to Rubenstein dated March 23, l
1988 i
Dear Mr. Rubenstein:
The application for withholding is submitted by Westinghouse Electric f
Corporation ("Westinghouse") pursuant to the provisions of paragraph (b)(1) i and (d)(1) of Section 2.790 of the Comission's regulations.
It contains comercial strategic information proprietary to Westinghouse and customarily j
held in confidence.
The affidavit previously provided to justify withholding proprietary information in this matter was submitted as AW-82-57 with letter NS-NRC-87 3270 i
dated October 8,1987, and is equally applicable to this material, i
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j Accordingly, it is respectfully requested that the subject information which is proprietary to Westinghouse be withheld from public disclosure in accordance I
wit 110CFR Section 2.790 of the Comission's regulations.
Correspondence with respect to this application for withholding or the accompanying affidavit should reference AW 88 024 and should be addressed to j
the undersigned.
Very truly yours, I
l Q.
t Ou lijkAQiW4GL WMS/bek/00358 Robert A. Wiesemann, Manager
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l Enclosure (s)
Regulatory & Legislative Affairs j
cc:
E. C. Shomaker, Esq.
i Office of the General Council, NRC l
t 8804010133 880323 PDR ADOCK 05000601 O
PROPRIETARY INFORMATION NOTICE TRANSMITTED HEREWITH ARE PROPRIETARY AND/OR NON PROPRIETARY VERSIONS OF DOCUMENTS FURNISHED TO THE NRC IN CONNECTION WITH REQUESTS FOR GENERIC AND/0R PLANT SPECIFIC REVIEW AND APPROVAL.
IN ORDER TO CONFORM TO THE REQUIREMENTS OF 10CFR 2.790 0F THE COMMISSION'S REGULATIONS CONCERNING THE PROTECTION OF PROPRIETARY INFORMATION SO SUBMITTED TO THE NRC, THE INFORMATION WHICH IS PROPRIETARY IN THE PROPRIETARY VERSIONS IS l
CONTAINED WITHIN BRACKETS AND WHERE THE PROPRIETARY INFORMATION HAS BEEN DELETED IN THE NON PROPRIETARY VERSIONS ONLY THE BRACKETS REMAIN, THE INFORMATION THAT WAS CONTAINED WITHIN THE BRACKETS IN THE PROPRIETARY VERSIONS HAVING BEEN DELETED.
THE JUSTIFICATION FOR CLAIMING THE INFORMATION S0 DESIGNATED AS PROPRIETARY IS INDICATED IN BOTH VERSIONS BY MEANS OF LOWER CASE LETTERS (a) THROUGH (g) CONTAINED WITHIN PARENTHESES LOCATED AS A SUPERSCRIPT IMMEDIATELY FOLLOWING 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 TYPES OF INFORMATION WESTINGHOUSE CUSTOMARILY HOLDS IN CONFIDENCE IDENTIFIED IN SECTIONS (4)(ii)(a) THROUGH (4)(ii)(g) 0F THE AFFIDAVIT ACCOMPANYING THIS TRANSMITTAL PURSUANT TO 10CFR2.790(b)(1) and (d)(1).
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AW-82-57 AFFICAVIT COMMONWEALTH OF PENNSYLVANIA:
s8 COUNTY OF ALLEGHENY:
Before me, the undersigned authority, personally appeared John O. McAdoo, who, being by me duly sworn according to law, decosas and says that he is authori:ed to execute this Affidavit on behalf of Westinghouse Electric Corporation ("Westingneuse") and that the averments of fact set forth in this Affidavit are true and correct to the best,of his knowledge, infor.ation, and belief:
vm m C L -
. n D. McAcco, Assistan: Manager Nuclear Safety Cecartman:
Sworn to and suescribed before m this
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day of h h n )Vil1982.
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f.LL!L $$.
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Notary Public naunt su:nsu, m:tur Pusue
- cteenlut C430, Au!DI(47 COUWTT 31
- :MMl!!!C4 Q713Q EAICH !s,1386' momeer, Penmma.s Assmau89 e' "*"""
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. AW-82-57 (1) t am Assistant Manager, Nuclear Safety Cesartment, in the Nuclear Technology Division, of Westingnouse Electric Corporation and as such, I have been specifically delegated the function of reviewing the proprietary information sougnt to be dthheld from public dis-closure in connection witF nuclear. power plant licensing or rule-making proceedings, and am authori:ed to apply for its withnolding on behalf of the Westinghouse Water Reactor Divisions.
(2)
I am making this Affidavit in conformance with the provisions of 10CFR Section 2.790 of the Comission's regulations and in con-junction with the Westingneuse apolication for withholding ac-companying thir Affidavit.
(3)
I have personal knowledge of tne criteria and procacures utili:ed by Westinghouse Nuclear Energy _ Systems in designating information as a trade secret, privileged or as c:nfidential c:m.ercial or financial information.
(4)
Pursuant to the provisions of paragrapn (e)(4) of Section 2.770 of tne Comission's regulations, the following is furnisnee for consideration by the Comission in determining wnether the in-formation sougn: to be withneld fr:m ;ublic cisclosure snould :e withheld.
(,1 )
The infor-ation sought to be wittneld frem public disclosure is owned and nas been held in confidence by Westingneuse,
' AW-32-57 (ii)
The information is of a type customarily held in confidence i
by Westinghouse and not custemarily disclosed to the puolic.
Westinghouse has a rational bas'is for determining the types of information customarily held in confidence by it and, in that connection, utili:es a system to determine when and j
whether to hold certain types of information in confidence.
The application of that system and the substance of :na system constitutes Westinghouse policy and provides the rational basis required.
Under that system, information is held in confidence if it
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falls in one or more of seversi ty;es, the rtlease of wnich might result in the loss.of an existing or cotential cem-petitive advantage, as follows:
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(.4 )
The information reveals the distinguishing aspects of a process (or c:mponent, stru'cture, teol, me: nod, e::.)
l where prevention of its use by any of Westingneuse's c:mpetitors w'ithout license frem Westingnouse cdnsti-tutes a c mpetitive ; -icmic advantage ever etner j
c mpanies.
('b ).
It consists of succorting cata, including :est ca:a,
- r. elative to a pr: cess (or c:m:enent, structure
- ci, i
method, etc.), :ne acclication of wnien data secures a l
c:nnetitive ec:ncmic advantage, e.g., by opti'li:ation j
or imoroved marketability.
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! AW-32-57 l
t (c)
Its use by a ecmpetitor would reduce his ex:enditure of resources or improve his c:mpetitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.
(d)
It reveals cost or price infomation, production cap-acities, budget levels, or comercial strategies of Westingneuse, its customers or suppliers.
(el It reveals aspects of east, cresent, or future Wes:-
inghouse or cust:mer funded development :lans and pro-grams of potential comercial value to Westingneuse.
i (f). It contains patentable ideas, for which catent pro-taction may be desirsble.
(gl It is not the property of Westinghcuse, but mus: :e treated as proprietary by Westinghouse ac:ording to I
agreements with :ne owner.
1 There are scund policy reasons tenind tne Westingneuse system wnich include the following:
(a)
The use of such infomation by Westinghouse gives
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Westinghouse a ecmpetitive advantage over its ::m-
- etitors.
It is, therefore, witaneld frem cisclosure to protect the Westingneuse c:m etitive :esition.
-i-AW-82-57 l
i-(b)
It is information which is marketaole in many ways.
The extent to which such infomation is available to c0mpetitors diminishes the Westingneuse ability to sell products and services involving the use of the infomation.
9 (c)
Usa by our c mpetitor would put Westingneuse at a compttitive disadvantage by reducing his ex enditure i
of resources at our expense.
(d). Each component of preprietary information pertinent l
to a particular ccmcetitive advantage is :otentially j
as valuable as the total ccmcetitive advantage.
If j
ccmpetitors acquire c:mponents of proprietary infor-mation, any one c:mpsnent may be the key :: the entire pu::le, thereby depriving Westingneuse of a c:meetitive advantage.
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(e)
Unrestricted disclosure would jeccardi:e the positien j
of preminence of Westingneuse in the wrld market, and thereby give a market advantage to tne c:meetitien f
in those c:untries.
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(f). The Westingneuse capacity to invest corporate assets 1
in research and develoceent depends upon the sue:ess l
in obtaining and maintaining a c:meetitive advantage.
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. AW-82-57
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(iii)
The information'is being. transmitted to the Ccmmission in confidence and, under 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 available in public sources or available information has act been pre-viously employed.in the same original manner or method to the.best of cur knowledge and belief.
(vl The proprietary infor.r.ation sought to be withheld in this sub-mittal is that which is. appropriately marked in the "Westing-house Advanced Pressuri:ed Water Reactor (WAPWR) Licensing Control Occumer t."
This cocument identifies specific design features and improvements which the WAPWR will have in order to meet current reguTatory requirements.
In addition, it establishes the '4APWR position with respect to each require-ment.
Puolic disclosure of this infonnation is likely to cause suo-stantial harm to the comoetitive position of Westinghouse as it would reveal the description of the improved design features of the WAPWR; Westinghouse plans for future design, testing and analysis aimed at design verification; and demonstration of the design's capability to meet evolving NRC/ACRS safety goals.
All df this information is of comoetitive value because of the large amount of effort and money expended by Westingnouse over a period of several years in carrying out this :: articular
. AW-82 ~7 development program.
Further, it would enable c:mpetitors to use the informatien for commercial purposes and also to meet NRC requirements for liccnsing documentation, each without purchasing the right from Westingnouse to use the information.
Information regarding its development programs is valuable to
. Westinghouse because:
(a)
Information resulting from its development programs gives
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Westinghouse a competitive advantage over its competitors.
It is, therefore, withheld from disclosura to protect the Westinghouse competitive position.
(b)
It is information which is marketable in many ways.
The extent to which such infcrmation is available to competi-tors diminishes the Westingneuse ability to sell products and services involving the use of the information.
(c)
Use by our competitor would put Westingnouse at a ccm-petitive disadvantage by reducing his expenditure of resources at our expense.
(d)
Each component of proprietary information pertinent to a particular competitor advantage is potentially as valuable as the total ecmoetitive advantage.
If ccm-petitors acquire ccmconents of proprietary information, any one ccmconent may be the key to the entire ou::le thereby depriving Westingnouse of a ccmcetitive acvantage.
.. AW-82-57 (e)
The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.
Being an innovative concept, this information might not be discovered-by the competitors of Westingnouse independently.
To duplicate this information, competitors would first have to be similarly inspired and would then have to ex:end an effort similar to that of Westinghouse to develop the design.
Further the deponent sayeth not.
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WESTINGHOUSE CLASS 3 l
AMENDMENT 2 TO RESAR-SP/90 PDA MODULE 2 REGULATORY CONFORMANCE O
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O WAPWR-RC AMENDMENT 2 7567e:1d MARCH, 1988
AMENDMENT 2 TO RESAR-SP/90 PDA MODULE 2 REGULATORY CONFORMANCE Instruction Sheet 1
Place complete package behind Amendment 1 to Module 2,"
Regulatory Conformance."
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- e WAPWR-RC AMENDMENT 2 7567e
- 1d MARCH, 1988
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. p REQUEST FOR ADDITIONAL INFORMATION WESTINGHOUSE, RESAR-SP/90 410.1 In regards to Generic Issue A-29, "Nuclear Power Plant Design for the 0
Reduction of Vulnerability to Sabotage",
a.
provide a description of the RESAR-SP/90 design's features which inhibit sabotage, b,
provide a description of the RESAR-SP/90 design's capability to Oi mitigate sabotage,"
c.
provide a description of the RESAR-SP/90 design's capability to detect tampering to both electrical and mechanical components, d.
identify the criteria Westinghouse used to determine the adequacy of the RESAR-SP/90 design's capability to protect against postulated acts of sabotage and/or tampering, and e.
provide the schedule for submittal of (or if completed, the results of) the Westinghouse sabotage assessment for the RESAR-SP/90 design using the risk mode) indicated in Section 5.1 of Module 2.
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RESPONSE
For protection against internal sabotage, the general approach has a.
been to design vital systems with redundant, non-interconnected trains, and to locate these redundant trains into dedicated and separated safety areas.
It should be pointed out that this i;eneral approach was not only dictated by sabotage considerations; other events which could lead to common mode failure such as fire and flooding were of equal concern.
A more detailed listing of the vital equipment and their location has previously been provided in Attachment A, of Amendment 1 to RESAR-SP/90 PDA Mod % 2, "Regulatory Conformance."
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..c RC 410-1 AMENDMENT 2
,o67e:1d MARCH, 1988 I
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With regard to outsider sabotage, a defense-in-depth principle is utilized as follows:
o The first line of defense is the fence surrounding the nuclear power plant.
If a person (or persons) were to penetrate the plant fence, this would not automatically lead to access to vital areas, since the Nuclear Power Block contains [
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a,c o
Access to the Nuclear Power Block is only via (
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o Finally, personnel access from the (
) Again, security personnel would normally be expected a,c to be present in these locations, and this would thus constitute the third line-of-defense.
(
) provide a fourth line of defense by providing plant a,c security personnel with clear information as to the path of the saboteurs, b.
The capability to mitigate events resultina from sabotage is ultimately dependent on the [
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!O WAPWR-RC 410-2 AMENDMENT 2 7567e:1d MARCH, 1988
4 Three separate systems are able to perform the decay heat removal
'O function:
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4 a,c o
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a,c The dependence of the above systems on the various support systems I
is provided in Table 1.
O With regard to layout, the above systems are located in various areas of the plant, thereby further complicating the task of a
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potential saboteur.
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WAPWR-RC 410-3 AMENDMENT 2 7567e:1d MARCH, 1988
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] and are therefore protected to the same degree as the a,c primary systems.
In summary,
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incorporate a,c substantial redundancy and diversity, both in terms of system design and plant layout; it wculd appear to be an extremely difficult task for an inside saboteur to disable all these systems and components without being detected.
c.
Tampering to components is more of a concern in the case of
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a,c Key vital systems, which are normally in a standby mode, are:
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o a,c Measures to prevent tampering include:
1.
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Access to a,c O
these ro' oms would only be required for inspection and maintenance of the particular system and should be strictly controlled by the operator.
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WAPWR-RC 410-4 AMENDMENT 2 7567e:1d MARCH, 1988 l
2.
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) are key chain locked in the correct a,c position; this would be verified during periodic testing.
) are a,c similarly key chain locked in the correct position.
No other provisions (e.g.
remote position indication of manual O
valves) are presently included in the design; however, they could be added at the FDA stage without perturbing in any way the basic design presented at this PDA stage.
d.
There are no specific design criteria with regard to sabotage. As indicated above, there are general design criteria with regard to redundancy, diversity, separation, etc. which address a number of issues simultaneously, both in terms of in.ternal risks at well as l
external hazards.
V e.
Module 2,
"Regulatory Conformance" had stated that a sabotage assessment would be performed and "--- provided to utilities l
utilizing the WAPWR design for appropriate consideration in their physical protection plans." However, no commitment was made to provide staff with this study during the preliminary design stage.
Westinghouse did perform a preliminary study early in the design stage to evaluate the ability of one particular plant configuration to mitigate the consequences of the acts of saboteurs.
The process used a partial risk assessment approach to rate the plant systems as to their capability to mitigate the impact of successful acts.
The level of detail available for the final design for a plant specific applicant would allow more detailed
- analysis, and would provide a better understanding of the plant's overall ability to respond to sabotage attempts.
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WAPWR-RC 410-5 ARENDMENT 2 7567e:1d MARCH, 1988
The sabotage analysis methodology developed as the basis of this assessment will be fine tuned and expanded to consider final design detail (plant layout, detailed piping and valve locations, electrical cable routing, and etc.) for an assessment that will enable utilities to better plan their plant protection and security O
systems.
In the final
- analysis, the manner in which a utility controls access to their plants' vital systems during normal operation and off-normal situations, and the competency of their plant operations and security forces, will contribute equally as G
much as the design of plant safe shutdown systems in preventing possible saboteur acts and to mitigate the effects of same.
Based on the Probabilistic Safety Study in Module 16 and the preliminary sabotage assessment, Westinghouse has a
high confidence that the final WAPWR design will provide increased protection against radiological r91 ease from all adverse contributors to the safe shutdown capabilities of the plant including insider and outsider sabotage attempts.
4.10.2 In regard to 10CFR50.34(f)(1)(ii),
"Auxiliary Feedwater System Evaluation," provide the schedulc fer submittal (or if completed, the results of) the final secondary side safeguards system reliability analysis.
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RESPONSE
l in the WAPWR the emergency feedwater system (EFWS) and the startup O
feedwater system (SFWS) perform functions which are performed by the auxiliary feedwater system in a conventional Westinghouse nuclear power plant.
The EFWS is described in Subsections 10.'1.1.11 and 10.4.9 of RESAR-SP/90 PDA Module 6/8, "Secondary Side Safeguards System / Steam and Power Conversion," and the SFWS is described in Subsections 10.1.1.12 and 10.4.10 of that module.
The system reliability analyses for these systems is provided in Subsection 3.7, Volume 2 of RESAR-SP/90 PDA Module 16, "Prebabilistic Safety Study."
O WAPWR-RC 410-6 AMENDMENT 2 7567e:1d MARCH, 1988
TABLE 1 DECAY HEAT REMOVAL SUPPORT SYSTEMS DEPENDENCE 9
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(1) (
) is not connected to on-site power supplies, a,c e
WAPWR-RC 410-7 AMENDMENT 2 7567e:1d MARCH, 1988
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