ML20207L765

Requests That Proprietary WCAP 11935, McGuire Unit 2 Evaluation for Tube Vibration Induced Fatigue, Be Withheld from Public Disclosure (Ref 10CFR2.790)

ML20207L765
Person / Time
Site:	Mcguire, McGuire, 05000000
Issue date:	08/30/1988
From:	Wiesemann R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	Murley T Office of Nuclear Reactor Regulation
Shared Package
ML19312B199	List: ML20207L752 ML20207L765 ML20207L778
References
CAW-88-093, CAW-88-93, NUDOCS 8810170432
Download: ML20207L765 (12)

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ATTACHMENT 1 .

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L.J August 30, 1988 Westingh0use Eties Systemt Fe*5 8r5'58 0'*$*

Electric Corporation sc1355 Pittscupfennsytvania 15230 0355 CAW-88-093 Dr. Tbcmas Murley, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Ccemission Washington, D.C. 20555 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

Transnittal of WCAPs Entitled "McGuire Unit 2 Evaluation For Tube Vibration Induced Fatigue"

Dear Dr. Murley:

Be proprietary informatiors for which withholding is being requested in the enclosed letter by Duke 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 %rth the bhsis on which the information may be 5:ithheld from public disclosure by the Ccanission and addresses

( with specificity the consideraticas listed in paragraph (b)(4) of 10CFR Section 2.790 of the Ccanission's regulations.

Be proprietary material for which withholding is being required is of the same technical type as that proprietary material previously submitted as Affidavit CAW-81-079 Accordingly, this letter authorizes the utilization of the accompanying affidavit by Duke Power Ccepany.

Correspordence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-88-093, and should be addressed to the undersigned.

Ve truly yours, Robert A. iesemann, 'ianager Regulatory & Legislative Affairs Enclosures cc: E. C. Shemaker, Esq.

Office of the General Counsel, NRC 8810170432 GG1006 PDR Q ADOCK 05000369 PDC

e PROPRIETARY INFORMATION FOTICE TRANSMITTED HEREWITH ARE PROPRIETARY AND/OR NCN-PROPRIETARY VERSIONS OF DOClNENTS FURNISHED TO 'DC NRC IN CONNECTION WITH REQUESTS FOR OENERIC A'iD/OR PLANI SPECIFIC REVIEW AND APPROVAL.

J IN ORLER TO CONFORM TO THE REQUIRLMENTS OF 10CFR2.790 0F WE CCPtiISSION'S REGULATIONL CONCERNING THE PROTECTION OF PROPRIETARY INMRMATION SO SUBMIITED 10 THE NRC, ' PIE INFORMATION WHICH IS PROPRIETARY IN THE PROPRIETARY VERSIONS IS COEAINED WITHIN BRACKETS AND WHERE THE PRCPRIETARY INMRMATION HAS BEEN DELETED IN THE NON-PROPRIETARY VERSIONS ONLY THE BRACKETS REMAIN, THE INFORMATION THAT WAS CONIAINED WITHIN THE BRACKETS IN THE PROPRIETARY VERSIONS HAVING BEDI DELETED. TIE JUSTIFICATION FOR CLAIMIM *nlE INFORMATION SO DESIGNATED AS PROPRIETARY IS INDICATED IN BOTH VERSIONS BY MEANS OF LOWER CASE LETIERS (a) THROUOH (g) CONTAINED WI'niIN PARDmiESES LDCATED AS A SUPERSCRIPT IMMEDIATELY NLIEWIm THE BRACKETS ENCWING EACH ITDi 0F INFORMATION BEING IIENTIFIED AS PROPRIETARY OR IN THE MARGIN OPPOSITE SUCH INMRMATION. THESE LOWER CASE LETTERS REFER TO 114E TYPES OF INERMATION WESTDGHOUSE CUSTCHARILY HOLDS IN CONFIDENCE IIENTIFIED IN SECTIONS (4)(11)(a) THROUGH (4)(ii)(g) 0F THE AFFIDAVIT ACCOMPANYDC THIS TRANSHIITAL PURSUANT TO 10CFR2.790(b)(1).

. CAW-81-79 n

AFFIDAVIT CO N NWEALTH 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 says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Corporation ("Westinghouse") and that the avennents of fact set forth in this Affidavit are true and correct to the best of his knowledge, infonnation, and belief:

eAnn>A Robert A. Wiesemann, Manager Regulatory and Legislative Affairs Sworn to and subscribed before me this a day of Dm./m 1981.

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.' . Notary [Publis..y' s...,.... .

CAW-81-79 4

(1) I an Manager, Regulatory and Legislative Affairs, in the Nuclear j Technology Division, of Westinghouse Electric Corporation and as such I have been specifically delegated the function of reviewing the proprietary infcrmation sought to be withheld from public dis- ,

closure in connection with nuclear power plant licensing or rule- l making proceedings, and am authorized to apply for its withholding on behalf of the Westinghouse Water Reactor Divisions. l (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 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 j consideration by the Commission in determining whether the in- j formation sought to be withheld frem 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.

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(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 deternining 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 application 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 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 l competitors without license from Westinghouse consti-tutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relativetoaprocess(orcomponent, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability. .

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(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, essurance of quality, or licensing a similar product. .

(d) It reveals cost or price infonnation, production cap-acities, budget levels, or comercial strategies of Westinghouse, its customers or suppliers.

l (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 wh'ch patent pro- '

taction may be desirable.

(g) It is not the property of Westingiouse, but must be treated as proprietary by Westingh'use according to agreements with the owner.

There are sound policy reasons behind the Westingnvu.; :;r+em 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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t (b) It is infonnation which is marketable in many ways.

The extent to which such infonnation is available to compt.titors diminishes the Westinghouse ability to sell ..roducts 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 infonnation pertinent to a particular competitive advantage is potentially as valuable as the total competitivi 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 disclos a would jeopardize the porition 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 a,id development depends upon the success in obtainins and maintaining a competitive advantage.

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(iii) The information is being transmitted to the Commission 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 not been pre-viously amployed in the same orf,ginal manner or method to the best of our knowledge and belief.

(v) The proprietary information sought to be withheld in this l

submittal is that *.hich is appropriately marked in "Steam Generator Tube Plugging Margin Analysis" for the Virgil C.

I Summer Nuclear Power Plant Unit No.1. WCAP-9912. Revi-sion 2 (Proprietary) being transmitted by South Carolina Electric and Gas Company letter Application for Withholding Proprietary Information from Public Disclosure Nichols to l Denton, November 1981. The proprietary information as sub-mitted for South Carolina , Electric and Gas Company, Virgil C.

Semmer Nuclear Station use is expected to be applicable in other licensee and applicant submittals in response to cer-tain NRC requirements for justif'l cation of the steam generator tube plugging margin. l This information is part of that which will enable Westing-house to:

(a) Provide documentation of the analyses, method and test-ing for determining plugging margin.

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. l CAW-81-79 (b) Establish the minimum wall thickness in compliance with Regulatory Guide 1.121.

(c) Establish ttc stress limits versus thinning of the remaining tube wall.

(d) Establish the maximum allowable leakage in support of the leak-before-break criteria.

(e) Assist the customer to obtain NRC approval.

Further this information has substantial comercial value as follows:

(a) Westinghouse plans to sell similar infonnation to its customers for purposes of meeting NRC requirements for licensing documentation.

(b) Westinghouse can sell support and defense of the tech-nology to its customers in the licensing process.

Public disclosure of this infonnation is likely to cause substantial hann to the competitive position of Westinghouse because it would enhance the ability of comp',titors to pro-vide similar analytical documentation and licensing defense services for comercial power reactors without comensurate expenses. Also, public disclosure of the infonnation would '

enable others to use the infonnation to meet NRC require-ments for licensing documentation without purchasing the right to use the infonnation.

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.. l CAW-81-79 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 e.xpenditure of a considerable sum of money.

In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the I requisite talent and experience, would have to be expended for system design software development.

Further the deponent sayeth not.

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4 A'ITAGMENT 2 M:Glire NLiclear Station Ehhanced Isakage hbnitoring Program Curt ently, McGlire Health Ehysics sanples and analyzes the Cbndensate Storage System Air Ejectors (CSAE's) once per week. 'Ihese results are then routed to the Chemistry group to calculate the primary to secondary leakrate. Chemistry then perfonns the calculation esing the CSAE Xe isotcpe with the highest activity. No netastables are used because of the short half-life.

If the leakrate is in the 25-50 gpd range, then the sanpling frequency for the CSAE's is increased to once per Cay. 'Ihe Station Chanist is innediately notified. The leakrate is then recalciated.

If the leakrate increases to 50-100 gpd, then CSAE sanpling is increased to onc.e every 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Again, the leakrate is recalculated.

If the leakrate is > 100 gpd, CSAE sanpling continues once every six hours, and Chemistry begins nonitoring (bndenser Evaluation System Radioactive Gaseous Effluent bbnitor DF-33 every 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Station managenent will determine if the leakrate is trending the curve in IRC R111etin 88-02, and appropriate action will be taken.

DF-33 is continuously monitored under another program by the Health Physics Grcup. 'Ihe current setpoints measured in counts / minute for EFF-33 are au follows:

Lhit I - DF-33* Lhit II - DF-33*

Background 600 Backgrcund 120 Trip 1 900 Trip 1 230 Trip 2 1800 Trip 2 350

• These nuasurenants are subject to changes depending on unit operation.

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. i ATTAC!NENT ?

Catawba Nuclear Staticn Ehhanced Ie.tkrate bbnitoring Program l

Currently, the Chtawba Nrlear Station Ihhanced Isakrate bbnitoring Program is defined by Station Directive 3.0.13. The leakrate calculation portion of this program is covered by Chemistry Guidel.ine 3.3.2 which is inpleented when Condenser Evaluation Systm Noble Gas Ictivity Monitor DF-33 reaches its trip 2 setpoint. Catawba Health Physics will sanple and analyze the Cbndensate i Storage Systs Air Ejectors (CSAE's) and Chemistry will then calculate the l primary to secondary leakrate. )

If the leakrate is <25 gpd, no further action is required. If the leakrate is in the 25-50 gpd range, the sanpling and leakrate calculation frequency is l once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.  !

l If the leakrate increases to the 50-100 gpd range, the CSAE sampling and leak rate calculation frequency is increased to once every six hours. Health ;

Physics will also trend DF-33 total gaseous activity, i 1

If the leakrate is 100-200 gpd, sanpling and leakrate calculaticos continue once every six trurs and DF-33 count rates are trended every 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. ,

If the leakrate is 200 gpd or greater, and the leakrate trend approximates the leakrate curve identified in NBC Bulletin 88-02, then Cperations is notified i to begin power reduction. If DE-33 is inoperable and the leakrate trend appraximates the leakrate curve identified in Nlt Bulletin 88-02, then  ;

Operations is notified to begin power reduction when the leakrate reaches 100 '

gpl.

If the leakrate trend does not approximate the curve identified in NIC ailletin 88-02, then deviations from this leakrate guideline may be authorized.

DF-33 provides continucus monitoring under arother station program. The current setpoints measured la counts / minute for EbF-33 are as follows:

thit 1 - DF 33* Unit II - DF - 3 3

• Backgrcund 140 Backgrcund 40 Trip 1 420 Trip 1 50 l Trip 2 600 Trip 2 75 l

• These measurments are subject to change depending cn Unit operation.

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