ML20206S415

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Requests Withholding of Proprietary WCAP-11256, Addl Info in Support of Elimination of Postulated Pipe Ruptures in Pressurizer Surge Lines of South Texas Project Units 1 & 2, from Public Disclosure Per 10CFR2.790.W/affidavit
ML20206S415
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 08/20/1986
From: Wiesemann R
WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To: Harold Denton
Office of Nuclear Reactor Regulation
Shared Package
ML19292F908 List:
References
CAW-86-068, CAW-86-68, NUDOCS 8609220210
Download: ML20206S415 (9)
v • d • e


Text

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a ni C5l TNT.xs ST bAb /737 PAGE / Of ,*

Westinghouse PowerSystems Ba 355 Pittsbu@ Pennsylvania 15230-0355 Electric Corporation August 20, 1986 CAW-86-068

. Mr. Harold R. Denton, Directer 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 in Support of the Elimination of Postulated Pipe Ruptures in the Pressurizer Surge Line of STP Units 1 and 2

Reference:

Houston Lighting and Power Company Letter to NRC dated September 1986

Dear Mr. Denton:

The proprietary material for which withholding is being requested in the reference letter by Houston Lighting and Power 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 requested is of the same technical type as that proprietary material previously submitted as Af fidavit CAW-84-102.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Houston Lighting and Power Company.

Correspondence with respect to the proprietary aspects of the application for i withholding or the Westinghouse affidavit should reference this letter, CAW-86-068, and should be addressed to the undersigned.

t Ve truly yours, (84biGZW

) Robert A. Wiesemann, Manager j _, Regulatory & Legislative Affairs _

Enclosure (s)

E. C. Shoraaker, Esq.

cc:

Office of the Executive Legal Director, NRC

' 8609220210 860915 PDR ADOCK 05000498 A PDR .,

l- ,

t I ATTACHMENL /.6 l ST HL AE M7 Attachment PAGE 4. OF 9

, (Insert to Houston Lighting and Power Company i Letter for Transmittal to the 'NRC)

^

Enclosed are-l .

1. 5 copies of WCAP-11256, " Additional Information in Support of the
Elimination of Postulated Pipe Ruptures in the Pressurizer Surge Lines of I

the STP Units 1 and 2," Westinghouse Proprietary Class 2, August 1986.

2. 5 copies of WCAP-11257, " Additional Information in Support of the '

Elimination of Postulated Pipe Rupturessin the Pressurizer Surge Lines of the STP Units 1 and 2," Westinghouse Non-Proprietary Class 3, August 1986, i

Also enclosed is a Westinghouse authorization letter, (CAW-86-068),

i Proprietary Information Notice, and accompanying af fidavit.

THE FOLLOWING PARAGRAPHS SHOULO BE INCLUDED IN YOUR LETTER TO THE NRC:

. As items (1) and (3) contain information proprietary to Westinghouse Electric i- Corporation, they are supported by an af fidavit signed by Westinghouse, the owner of the information. The affidavit sets forth the basis on which the j information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.790 of the Commission's regulations.

Accordingly, it is respectfully requested that the 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 i

respect to the proprietary aspects of the Application for Withholding or the

! supporting Westinghouse affidavit should reference (CAW-86-068) and should be

{ addressed to R. A. Wiesemann, Manager, Regulatory and Legislative Affairs, l Westinghouse Electric Corporation, P.O. Box 355, Pittsburgh, Pennsylvania l 15230.

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i 1338n:19/HFC/8-86

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. ATTACHMENT /o ST HL-AE /7J7 l

, PAGEJ OF f DRAFT LETTER FOR HL&P September 1986 kr. N. Prasad Kadambi, Project Manager PWR Project Directorate #5 Division of PWR Licensing-A U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

South Texas Project Units 1 and 2 Alternative Pipe Break Criteria - Additional Information In your letter dated July 10, 1986, you requested additional information in support of our requests for exemptions to the requirements of 10CFR50, Appendix A, General Design Criteria-4 for the treatment of pressurizer surge line pipe breaks (Docket Numbers 50-498 and 50-499). Your request was in the form of an attachment to your letter which itemized your concerns. Please find our response to each item.

While some of the responses provide requested information, others deal with technical issues. For the latter case, we feel we have addressed the items usirig state-of-the-art methodologies and have incorporated adequate conservatisms to assure that the requests for exemption are justified. We shall be most happy to meet with you in order to facilitate your review.

Should you have any questions on our responses or additional concerns prior to a meeting, please advise us so that we can be adequately prepared to address them at the meeting.

Sincerely yours, Attachaent 1338n:20/HFC/8-86

_ _ _ _ _ _ _ _ _ _ _ _ _ _ J

ATTACHMENT / 4.

ST HL AE /137 PAGE 9 OF 7 i.

PROPRIETARY INFORMATION NOTICE I TRANSMITTED HDEWITH ARE PROPRIETARY AND/OR NON-PR DOCUMENIS FURNISHE TO THE NRC IN CONNECTION WIT PLANT SPECIFIC REVIEW AND APPROVAL.

(A 3 ORDER 10 CONFORM 10 THE REQUIREMENT 3 CF 10CFR2 REULATIONS CONCERNDG 1HE PROTECTION & PROPRIETA 101HE NRC, THE INFORETION WHICH IS PROPRIETARY IN THE PROPRIE CONTAINE WITRIN BRACKETS AND WHDE THE PROPRIETAR

  • DEI.ETED .IN THE NON-PROPRIETARY VERSIONS GLY THE BRACKETS RDIA -

INFORETION 1 HAT WAS CONTAING WITHIN 1HE BRACKET HAVING BED DII.ETE.

THE JUSTIFICATION FOR (2 AIMING THE INFORMATION 30

{ J DESIDNATED AS PROPRIETARY IS INDICATE IN BDIH VERSI

{ ,

LEITERS (a) THROUGH (g) CONTAING WITHIN PAREN1HDES LOCATED AS IKEDIATII.Y FtX.10 WING THE BRACKETS DCI.05ING EACH ITIM DENTIFIED AS PROPRIETARY OR IN 1HE MARGINTHESE OPPOSITE SU LCED CASE LETTERS PEFER 10 THE TYPES OF INFORMATIO H02S IN CONFIDENCE IDENTIFIED IN SECTIONS (4)(ii)(a) t.hrough (4)(ii)(g AFFIDAVIT ACCOMPAh7ING THIS TRANSMITTAL nlRSUAhT 1D C

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ATTACHMENT / o ST HL AE. /737 PAGE r OF 7 CAW-84-102 i

AFFIDAVIT COMM0hWEALTH OF PENNSYLVANIA:

ss COUNTY OF ALLE6HENY:

i Before me, the undersigned authority, personally appeared John D. McAdoo,

~

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

w& ' : _

Joh D. McAdoo, Assistant Manager clear Safety Department i

Sworn to and subscribed before me this Al__ day p

s y j.f b M .1984.

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h. yli. h, 6 -

, Notary Public i

LORAAINt M. PlPliCA. N0?ACY PUBilt

NONR0tYlttt 80RO. AlttCH!>Y C0!'NTY WY COMMis$l0N IIPitts Cic 14.1987 Member. Pennsylvania Association of notaries 6

ATTACHMENT / e-

' ST HL AE n>7

, PAGE 4'OF 7 CAW-84-102 (1) I am Assistant Manager, Nuclear Safety Department, in the Nuclear Technology 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 disclosure in connection with nuclear power plant licensing or rulemaking 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 10CFR Section 2.790 of the Commission's regulations and in conjunction with the Westinghouse application for withholding accompany 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 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 should be withheld.

(1) 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 l

information customarily held in confidence by it and, in that i . connection, utilizes a system to determine when and whether to i hold certain types of information in confidence.

i The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.

HFC/0162n/11-20-84

. ATTACHMENT /4 ST-HL AE 1737

, PAGE 7 OF f _

CAW-84-102 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:

l

, (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

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.

!- It reveals cost or price information, production capacities, (d)

budget levels, or connercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded develcpment plans and programs of potential connercial value to Westinghouse.

, (f) It contains patentable ideas, for which patent protection may be desirable.

l (g) It is not the property of Westinghouse, but must be treated as

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l proprietary by Westinghouse according to agreements with the owner.

i

HFC/0162n/11-70-84

ATTACHMENT A

., ST HL AE /7J7

... PAGE d' 0F f

,, CAW-84-102 l

There are sound policy reasons behind the Westinghouse system  !

which include the following: i (a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors.

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 sell products and services involving the use of the information.

(c) Use by our competitor would put Westinghouse at 3 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 j Westinghouse of a competitive advantage.

l (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 i research and development depends upon the success in l obtaining and maintaining a competitive advantage.

(iii) The information is being transmitted to the Connission in confidence and, under the provisions of 10CFR Section 2.790, it is to be received in confidence by the Connission.

f l

HFC/0162n/11-20-84

  • ATTACHMENT / *-

ST HL-AE- /%57 PAGE S OF 9 CAW-84-102 (iv) The information 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 in WCAP-10489,

" Technical Bases for Eliminating Pressurizer Surge line Ruptures as the Structural Design Bases for South Texas Project," dated February 1984, and " Additional Information - South Texas Surge

Line."

t The subject information could only be duplicated by competitors if they were to invest time and effort equivalent to that invested by _

i Westinghouse provided that they have the requisite talent and experience.

Public disclosure of this information is likely to cause substantial harm to the competitive position of Westinghouse because it would simplify design and evaluation tasks without

requiring a commensurate investment of time and effort.

! Further the deponent sayeth not.

i i i e

o Q162n/11-20-B4

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