ML20198J512
| ML20198J512 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 05/06/1986 |
| From: | Wiesemann R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19292F340 | List: |
| References | |
| AW-80-66, CAW-86-039, CAW-86-39, NUDOCS 8606030134 | |
| Download: ML20198J512 (12) | |
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Westinghouse Water Reactor NudearTechnology hsion Electric Corporation Divisions PittsburghPennsyNania 15230 May 6, 1986 CAW-86-039 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.
20555 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
Additional Information on SER Confirmatory Issue 032
Reference:
DMW-D-5487
Dear Mr. Denton:
The proprietary material for which withholding is being requested in the reference letter by Duquesne Light Company is further identified in an affidavit signed by the owner of the proprietary information, Westinghouse 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 required is of the same technical type as that proprietary material previously submitted with Application for Withholding AW-80-066.
Accordingly, this letter authorizes the utilization of the accompanying affidavit by Duquesne Light Company.
Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-86-039, and should be addressed to the undersigned.
Very truly yours, Robert A. Wiesemann, Manager Regulatory & Legislative Affairs Enclosure (s)/1253n cc:
E. C. Shomaker, Esq.
Office of the Executive Legal Director, NRC 8606030134 860528 PDR ADOCK 0500 2
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PROPRIETARY INFORMATION NOTICE TRANSMITTED HDEWITH ARE PROPRIETARY AND/OR NON-PROPRIETARY DoQjMENTS FURNISHED TD THE NRC IN CONNECTION WITH RIQUDTS FDR GDERIC A PLAhT SPECIFIC RDIEW AND APPROVAL.
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IN ORDER 10 CONFORM TD THE RIQUIREMENTS W 10CFR2.790 CF THE C RIDULATIONS CONCERNING THE PROTECTION & PROPRIETARY INFORM 701HE NRC, THE INFORMATION WHICH IS PROPRIETARY IN THE PROPRIETARY VERSIO CONTAIND WITHIN BRACKET 3 AND WHERE THE PROPRIETARY INFORMAT DELETED IN THE NON-PROPRIETARY VERSIONS GG.Y THE BRACKETS REMAIN, THE INFORMATION THAT WAS (2NTAINED WITHIN THE BRACKETS IN THE P HAVING BEIN DII.ETED. THE JUSTIFICATION FOR CLAIMING 1HE INFORMAT DESIDNATED AS PROPRIETARY IS INDICATED IN BOTH VERSIONS BY
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LEITERS (a) THROUGH (g) CONTAINED WITHIN PARENTHDES LOCATED AS A SUPERSC IMMEDIATILY FOLLOWING THE BRACKETS S'CI.QSING EACH ITEM OF INFO IDENTIFIED AS PROPRIETARY OR IN THE MARGIN OPPOSITE SUCH INFORMA 1HISE LOWS CASE LEITERS REFER 10 THE TYPES OF INFORMATION WESTINGH HCLDS IN CONFIDENCE IDEhTIFIED IN SECTIONS (4)(ii)(a) through (4)(ii)(g) 0F THE AF7IDAVIT ACCOMPAhTING THIS TRANSMITTAL PURSUAhT 1010CFR2.790(
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AW-80-66 3
4 AFFIDAVIT C0tiMONilEALTH OF PENNSYLVANIA:
ss COUNTY OF ALLEGHENY:
Before me, the undersigned authority, personally appeared Robert A. Wiesemann, who, being by me duly sworn according to law, deposes and s2ys that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Corporation (" Westinghouse") and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:
Mibt4&fi Robert A. Wiesemann, Manager Regulatory and Legislative Affairs Sworn to and subscribed before me this/p__ day
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'I AW-80-66 (1)
I am Manager, Regulatory and Legislative Affairs, in the Nuclear Technology Division, of Westinghouse Electric Corporatiin a'nd 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
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on behalf of the Westinghouse Water Reactor Divisions.
- Further, Westinghouse is authorized by the Feedwater Line Cracking Owners Group to obtain from NRC protection of proprietary information in-connection with their activities in accordance with the procedures employed by Westinghouse.
(2)
I am making this Affidavit in conformance with the provisions of 10CFR 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 Nuclear Energy Systems in designating information as a trade secret, privileged or as confidential commerical 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 frem public disclosure should be withheld.-
l-(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.
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. AW-80-66 f
(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to tfie 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 detennine 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, infonnation 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 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
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competitors without license from Westinghouse consti-tutes 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.
f-
. AW-80-66 (c)
Its use by a competitor would reduce his expen_diture 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 development plans and pro-grams of potential comercial value to 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 Westinghouse system which include the following:
(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its com-petitors.
It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.
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' ' ' AW-80-66 (b)
It is information which is marketable in many ways.
The extent to which such information is availble'to a
competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.
(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 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 countries.
(f) The Westinghouse capacity to invest corporate assets in research and develognent depends upon the success in obtaining and maintaining a competitive advantage.
.' AW-80-66 (iii) The information is being transmitted to the Commis,sion in confidence and, under the provisions of 10CFR Section 2.790, it is to be received in confidence by the Commission.
(iv) The infonnation sought to be protected is not available in public sources to the best of our knowledge and belief.
(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked WCAP-9693,
" Investigation of Feedwater Line Cracking in Pressurized Water Reactor Plants." This report has been prepared for and is being submitted to the Staff at the request of the Feedwater Line Cracking Owners Group. This report describes various analytical, modeling and equipment modification details applying to owner's group members' facilities.
This information is part of that which will enable Westing-house and the Feedwater Line Cracking Owners Group to:
(a) Assist its members and future customers to obtain NRC approval of repairs.
(b) Justify the design basis for the feedwater line modi-fications and installation methods.
Further, this information has substantial comercial value as follows:
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7-AW-80-66 (a)' Feedwater Line Cracking Owners Group and/or Westinghouse i-plans to sell the analytical techniques and equipment modifications described in part by the information.
(b) Feedwater Line Cracking Owners Group and/or Westinghouse can sell repair services based upon the experience gained and the installation equipment and methods developed.
Public disclosure of this information is likely to cause substantial harm to the competitive position of Westing-house because (1) it would result in the loss of valuable patent rights, and (2) it would enhance the ability of competitors to design, manufacture, verify and sell steam
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generator repair techniques for commercial power reactors without commensurate expenses.
The development of the methods and equipment described in part by the information is the result of a'pplying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.
In order for those who are not members of the Owners Group or are competitors of Westinghouse to duplicate this infor-mation, similar engineering programs would have to be per-formed and a significant manpower effort, having the requisite talent and experience, would have to be expended for steam generator repair techniques.
Further the deponent sayeth not.
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^I AIIHTICNAL INPWMATICH W
BVPS-2 SER CWFIRMAIGE ISSUE 032 May 6, 1986 i
e NESTINGEUSE EIECIRIC CERPGUCICN NUCIEAR ENERGY SYSIBG P.O. BOX 355
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PITISREGH, PENNSYIFANIA 15230 Ref: (1) BVPS-2 SIR (2) Teleotn en November 11, 1985 : F. Burrows - NRC l
K. Tztecler, R. Fadin - D[c J. Mesmaringer, B. Council, K. Gaydos, B. Hall - N (3) Teleccm cut February 13, 1986 : F. Burrows, A. Gilbert - NRC R. Fadin - D[c J. Mesmaringer, B. Cbuncil, T. Blackburn, B. Hall - N d
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'Iha analysis of the Feedheter Malfunctica Event for Beaver Valley Unit 2 presented in Sectica 15.1.2 of the BVPS-2 PSAR====== that cme FCV is inadvertently opened. '!his analysis was perfewmad using assumptions eich bound an event ears two ar acts PtNs are opened. 'Ihese assumpticms include:
1.
[.]a,c mixing of RCS fluid in the core inlet plenum is i
censarvatively ammaned.
Reactivity f
- k is ocnservatively {**
2.
3 3.
Main faschatar f1w to the affected stamm generator is increased to the =mvi== amount idlich can be sustained by the feedwat2r system.
'Ihm failing open of ena FCV results in an asynnestric cooldown event. 'Ihe first two -
- 2 i=-i nav4=ima the iM of this asyaumstry by navimiring the resulting reactivity insertion. A more uniform rmldrwrt would result if two or more 7tNs were opened and as suds the resulting reactivity insertion would be acre uniformly dispersed over the acre. For the same total increase in feechatar fim, the case of cme FtN cpening bounds, in terms of reactivity insertien, the cases ears two ce more FCVs open.
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'Ihm FSAR analysis anstamos an increase in feechatar f1w to 160% of ncminal to the affected loop for the full power case. 'Ihis increase in feedwater flw is based p the nav4== total as-built delivery capability of the i
Main Feedwater System with all three FCVIs wide open. As a result, if two l
or acro FCVs fail open, the total increase in flw (i.e., man of all loop i
i flows) would be equal to ce less then that asstamed in the PSAR fce ens loop l
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to fail open. '!he -- -- ^ ir=1 of ena FCV failing open results in a concentration of flw to one loop which in ocnjunctice with the conservative mixing and reactivity faadhack - -.2 ir=1s diaramad above results in a conservative reactivity addition. As a result, the PSAR analysis assuming that one FCV cpens bounds the case tore a single failure causes one or acta PtNs to open.
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4 The FSAR zero power analysis assumes an increase in feedwater flow of 170%
of nominal to the affected loop.
This is the maximum flowrate which can be delivered to one stean generator at zero power. The maximum total as-built delivery capability of the Main Feedwater Systen with all three FCVs open at zero power is 75% of nominal (plant total).
Analysis was performed of this zero power symmetric three loop event, using FSAR methodology, but with reactivity feedback [
]ac This case was shown to be less limiting than the case currently presented in the FSAR.
Additionally, a most conservative combination of initiating events was analyzed at zero power.
For this case, the above mixing and reactivity feedback assunptions were made, while feedwater flow was assumed to increase to only(75% ofone loop at the magnitude of the plant total increase in feedwater flow naninal pl ant total, 225% of nominal loop flow; this flowrate is higher than the expected maximum possible feedwater flow capability from a single loop).
The results of this very conservative analysis, though more limiting than that of the current FSAR analysis, renain within the acceptance criteria.
The analysis of the feedwater malfunction event presented in Section 15.1.2 of the Beaver Valley Unit 2 FSAR assunes that one Feedwater Control Valve f ails open.
In the analysis, conservative asumptions are used with respect to RCS mixing, ructivity feedback and feedwater flow which result in an event which is more limiting than a case where two or more FCVs fail open.