ML20203D960

Requests That Proprietary AP600 Response to Request for Addl Info,Be Withheld (Ref 10CFR2.790)

ML20203D960
Person / Time
Site:	05200003
Issue date:	02/20/1998
From:	Sepp H WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	Quay T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19317C892	List: ML20203D960 NSD-NRC-98-5578, Forwards Proprietary Revised W Response to Request for Addl Info Item 440.580.Open Item Pertains to AP600 PRHR Osu Tar. Proprietary Response Withheld (Ref 10CFR2.790)
References
AW-98-1207, NUDOCS 9802260216
Download: ML20203D960 (12)

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Westinghouse Energy Systems g,3 5 m,m, Electric Corporation AW.98 1207 February 20,1998 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:

MR. T. R. QUAY APPLICATION FOR WITilllOLDING PROPRIETARY INFORMATION FROM PUllLIC DISCLOSURE SUlljECT:

AP600 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION

Dear Mr. Quay:

The application for withholding is submitted by Westinghouse Electric Company, a division of Cils Corporation (" Westinghouse"), 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.

The proprietary material for which withholding is being requested is identified in the proprietary version of the subject report. In conformance witn 10CFR Section 2.790, Affidavit AW 98-1207 accompanies this application for withholding setting Ibrth the basis on which the identified proprietary information may be withheld from public disclosure.

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.

Correspondence with respect to this application Ibr withholding or the accompanying affidavit should reference AW 981207 and should be addressed to the undersigned.

Very truly yours, ilenry A.. es,lManager Regulatory and Licensing Engineering jml ec:

Kevin 11ohrer NRC OWFN - MS 12E20 9802260216 900220-PDR ADOCK 05200003 A

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AW-98 1207 AEIDAVIT COMMONWl:Al/Ill Ol' l'l:NNSYINANI A:

ss Col 1NIY Ol' Al.l.l: Gill:NY:

liefore m;, the undersigned authority, personally appeared llenry A. Sepp, who, being by me duly sworn according 1: law, deposes and says that he is authorized to execute this Affidavit on behalf of West nghouse filectric Compiiny, e division of CllS Corporation (" Westinghouse"), and that the i

asennents of fiu:t set forth in this Auldavit are true and correct to the best of his knowledge, information, and belief:

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llenry A. Sepp, Manager y, itegulatory and 1.icensing 1:ngineering i

hworn to and subscribed before file this

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i AW.981207 (i)

I am Manager, Regulatory and 1.icensing Engineering, in the Nuclear Services Division, of the Westinghouse Electric Company, a division of CilS Corporation (" Westinghouse"), and as such, I have been specifically delegated the function of reviewing, the proprietary infortantion sought to be withheld from public disclosure in connection with nuclear power plan' licensing and rulemaking proceedings, and am authorired to apply for its withholding on behalf of the l

Westinghouse linergy Systems ilusiness Unit, k

(2)

I am making this A01 davit in conformance with the provisions of 10CFR Section 2.790 of the Commission's regulations and in conjunction with the Westinghouse application for whhholding accompanying this Af0 davit.

(3)

I have personal knowledge of the criteria and procedures utillr# ay the Westinghouse Energy Systems ilusiness Unit in designating information as a trade secret, privileged or as conudential commercial or unancial information.

L (4)

Pursuant to the provisions of paragraph (b)(4) of Section 2.790 of the Commission's regulations, the following i, furnished for coasideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i)

The information sought to be withheld from public disclosure is owned and has been held in con 0dence by Westinghouse.

(ii)

The information is of a type customarily held in confidence by Westinghouse and not i

customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in con 0dence by it and, in that connect:on, utillies a system to determine when and whether to hold certain types of information in confidence. 'the application of' hat system and the substance of that systein constitutes Westinghouse polley and provides the rational basis required.

Under that system, information is held in con 0dence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competiti e advamage, as follows:

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AW.981207 (a)

The infortnation 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 optimintion 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 capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(c)

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.

'lhere are sound policy reasons behind the Westinghouse system which include the following:

(a)

The use of such information by Westinghouse gives Westingho'ise a competitise advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

(b)

It is informatior, which is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information, wm.,r i

AW.981207 (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 cc

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advantage is potentially as valuable as the total competitive advaninge. 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.

(c)

Unrestricted disclosure would jeopardire the position of prominence of Westinghouse in the world rnarket, and thereby give a market a<lvantage to the i

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.

(iii)

't he information is being transmitted to the Commission in confidence and, under the provisions of 10CI R Section 2.790, it is to be received in con 0dence by the Commission.

(iv)

The information sought to be protected is not available in public scurces or available infonnation has not been previously employed in the same original manner or method to the best of our i.nowledge and belief.

(v) linclosed is Letter DCP/NRCl262 (NSibNRC 98 5578), l'ebruary 20,1998, being tiansmitted by Westinghouse Flectric Company (W), a division of Cils Corporation

(" Westinghouse"), letter and Application for Withholding Proprietary information from Public Disclosure, Brian A. McIntyre (W), tc Mr. T. R. Quay, Office of NRR. The proprietary information as submitted for use by Westinghouse Electric Company 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.lustification oflicensing advanced nuclear power plant designs, waw

I AW.981207

'ihis information is part of that which will enable Westinghouse to:

(a)

!!cmonstrate the design and safety of the AP600 Passive Safety Systerns.

(b)

!!s.ablish applicable verification testing methods.

(c)

Design Advanced Nuclear Power Plants that meet NI(C requirements.

(d) lhtabikh technical and licensing approaches for the AP600 that will ultimately result in a certified design.

t (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 NI(C requirements for advanced plant licenses.

(h)

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 powtr 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.

ma.,,

AW 981207 9

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 prograrns would have to be perfonned and a significant manpower effort, having the requisite talent and experience, would have to be expended for developing analytical tuethods and receiving NRC approval for those methods.

l'urther the depc.nent sayeth not.

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I:nclosure 2 to Westinghouse i etter DCI'/NRCl262 February 20,1998 460%DN

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NRC REQUEST FOR ADDITIONAL INFORMATION Question 440 Sk0 Re: OSU TAR (0115 3471) in Figurc $42 33 of the OSU TAR, curve "C" shows integrated PRHR heat removal. The cune peaks at around NGkOO i,econds, af ter which it begins to decrease. If this is an integrated cune, a decrease would seem to indicate heat tiansfer from the IRWST to the primary sptem, which does not seem to be physically plau Aible. Please esplain what this cune shows and the reason for its shape.

Response RAI 440.580 De integrated heat transfer from the PRllR presented in the TAR' was calculated inducctly by analysis of the resp (mse of the Guid in IRWST tank smce a direct measurement of the heat loss f rom the PRilR w as not available.

A heat balance on the IRWST was performed such that the energy from the PRi!R was equal to the change in energy m the IRWST or:

dU,, y Qenna=

di and the integrated heat transfer:

,Oranadt = (U - Uo),,wn -[Q nsndt As such, the plot presented in TAR Figure 5A2 33 and similar Agures in each of the other sections of the TAR is only vahd dunng the times prior to the release of mass from the IRWST(overdow and DVI How). Figure I shows a plot of the integrated PRilR energy along with plots of the oserdow and DVI Hows, it can be seen that the integrated PRilR energy starts to decrease when overdow from the IRWST starts.

De details of the PRHR operation do not have an impact on the overall energy balance of the splem since the energy stap within the control volume with the esception of eshaust from the system (after ADSl3 blowdown) that may be touted to the eshaust or the separator tanks. If the energy esiting the IRWST were included in the analpis; the equation becomes:

[Q4nsn t +[Q,,wn,,%,dt +[Q,ydt + [Q,,,. dt d

, Orana t = (U - Uo),,wn -

d WCAP 14292, Revision 1 AP600 Low Pressure Integral System Test at Oregon State University Final Test Analysis Report, September 1995 440.580 1 Rw.1 W w sunpouse

a NRC MOUEST POR ADDmONAL INFORMAtlON l'igure 440.5160-2 presents results of the above equation together with the calculational uncertainty of the tocasurements and calculations performed. The uncertainty in the flow rnessurements and material properties as a function of temperature wcre considered The resulting curve shows that PRilR heat removal essentially ceases after 2000 seconds. 'Ihe total uncertainty amounts to approsimately 2.6% of the nominal value.

SSAk Revision: NON!!

440.640 2-I MIM Rev.' 1

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