ML20207R929

Requests Withholding of Proprietary Info Re Plant Demonstration Fuel Assemblies from Public Disclosure (Ref 10CFR2.790)

ML20207R929
Person / Time
Site:	North Anna
Issue date:	03/11/1987
From:	Wiesemann R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	Murley T Office of Nuclear Reactor Regulation
Shared Package
ML19292G937	List: ML20207R929 NRC-87-3208, Forwards Proprietary Info Re Plant Demonstration Fuel Assemblies.Encl Withheld (Ref 10CFR2.790)
References
AW-87-023, AW-87-23, NUDOCS 8703180314
Download: ML20207R929 (15)

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O Westinghouse PowerSystems s"nienis won'eaneaciogy Electric Corporation Box 355 Pittsburgh Pennsylvania 15230-0355 March 11, 1987 AW-87-023 Dr. Thomas Murley Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Comission Washington, DC 20555 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

Information on North Anna 1 Demonstration Fuel Assemblies (Proprietary)

Ref.: Westinghouse Letter No. NS-NRC-87-3208 Johnson to Rubenstein, dated March 11, 1987

Dear Mr. Murley:

This application for withholding is submitted by Westinghouse Electric Corporation (" Westinghouse") pursuant to the provisions of paragraph (b)

(1) of Section 2.790 of the Commission's regulations. It contains commercial strategic infomation proprietary to Westinghouse and customarily held in confidence.

The proprietary material for which withholding is being requested is of the same technical type as that proprietary material previously submitted with affidavit, AW-76-21, signed by the owner of the proprietary infonnation, Westinghouse Electric Corporation.

Accordingly, it is respectfully requested that the subject information which is proprietary to Westinghouse be withheld from public disclosure in acconiance with 10CFR Section 2.790 of the Commission's regulations.

Correspondence with respect to this application for withholding or the accompanying affidavit should reference AW-87-023 and should be addressed to the undersigned.

Ve ruly yours, '

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Robert . esemann, Manager Regulatory & Legislative Affairs _

cc: E. C. Shomaker, Esq.

Office of the General Council, NRC 4

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8703180314 870311 PDR ADOCK 05000338 p PDR.

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- AW-76-21 9'

AFFIDAVIT COMMONWEALTH 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, de-poses and says that he is authorized to execute this Affidavit on behalf

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of Westinghouse Electric Corporation (" Westinghouse") and that the aver-g.

? ments of fact set forth in this Affidavit are true 'and correct to the '

best of his knowledge, information, and belief:

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Robert A. Wiesemann, Manager Licensing Programs Sworn to and subsc,ribed before siie this j'/7 day

. of t /4W/ 1976.

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2- AW-76-21 (1) I am Manager Licensing Programs, in the Pressurized Water Reactor Systems 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 dis'-

closure in connection with nuclear power plant licensing or rule-making 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 10 CFR Section 2.790 of the Commission's regulations and in con-

< ; t- 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.

i (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 from public disclosure should be

i withheld.

(1) The information sought to be withheld from public disclosure

,,is owned and has been held in confidence b'y Westinghouse.

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AW-76-21 (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 information customarily held in confidence by it and, in 4 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.

t- Under that system, information is held in confidence if it

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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 competitors without license from Westinghouse consti-

- tutes a competitive economic advantage over other companies.

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. (b) It consists of supporting data, including test data,

.  ! relative to a process (or component, structure, tool, method,etc.),theapplicationofwhichdatasecuresa competitive economic advantage, e.g., by optimization or improved marketability.

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AW-76-21 (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 cap-i acities, budget levels, or commercial strategies of

- Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future West-7 g,

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 4 treated as proprietary by Westinghouse according to agreements with the owner.

There are sound policy reasons behind the Westinghouse

• system which include the following:

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l 3(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its com-petitors. It is, therefore, withheld from disclosure l f to protect the Westinghouse competitive position.

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, -$- . AW-76-21 (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 a competitive disadvantage by reducing his expenditure of resources at our expense.

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(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 t puzzle, thereby depriving Westinghouse of a competitive advantag2.

(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 development depends upon the success

. in obtaining and maintaining a competitive advantage.

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AW-76-21 (iii) The information is being transmitted to the Commission in ,,

confidence and, under the provisions of 10 CFR Section 2.790, it is to be received in con'fidence by the Comission.

(iv) The information is not available in public sources to the best of our knowledge and belief.

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

submittal is that which is appropriately marked in the at-

.. p tachment to Westinghouse letter number NS-CE-1100. Eiche1dinger ,

'i to Vassallo, dated June ll, 1976, concerning THINC II/THINC IV

code comparisons. The letter and attachment are being sub-l mitted in response to the NRC request at the May 28, 1976 NRC/ Westinghouse meeting.

, This inf6rmation enables Westinghouse to:

) (a) Justify the Westinghouse design correlations.

l j (b) Assist its customers to obtain licenses.

! ,f (c) Obtain preliminary design approvals.

1 f(d) Meet warranties.

l (e) Provide greater flexibility to customers assuring them of safe and reliable operation.

ls (f) Reduce plant and fuel costs.

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(g) Optimize performance while maintaining high level of l fuel integrity.

Further, the infomation gained from the THINC IV development -

program is of commercial value and is sold for considerable sums of money as follows:

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(a) Westinghouse sells the bie of this information to -

foreign licensees. -

.; t-(b) . Westinghouse uses the information to perfom and -

justify analyses which are sold to customers.

(c) Westinghouse sells testing services based upon the experience gained and the test equipment and methods

? develo, ped.

Public disclosure of this infomation concerning THINC II/

THINC IV code comparisons is likely to cause substantial ham to the competitive position of Westinghouse because l, competitors could utilize this information to assess and

,- , justify their own designs without comensurate expense.

The comparisons performed and their evaluation represent l

- a considerable amount of highly qualified development effort.

- *; This work was contingent upon a THINC IV development program f ,

i which has been underway during the past six years. Altogether, a substantial amount of money and effort has been expended d

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AW-76-21 I

, I by Westinghouse whlch could only be duplicated by a com- ,.

petitor if he were to invest similar sems of money and provided he had the appropriate talent available.

Further the deponent sayeth not.

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PROPRIETARY INFORMATION NOTICE p.

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i TRANSHITTD HDEWITH ARE PROPRIETARY AND/0R NON-PROPRIETARY TERSION k

D00JMENT3 PURNISHD TO ME NRC IN CONNECTION WITH REQUD13 FDR CD FLANT SPECIFIC REVIEW AND APPROVAL. '

IN CRDER 10 CONFORM TD DE REUIRDENTS E 10CF22.790 W THE COWIISSION'S RIDULATIONS CONCERNING HE PROTECTION W PROPRIETARY INFDRMATION

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70 THE NRC, THE INFORMATION WHICH IS PROPAIETARY IN ME PROPAIETARY VERSIONS IS i

CONTAING WIDiIN BRACKET 3 AND WHDE ME PROPRIETARY INFORMATION HAS BE *

$ t-11 + DELETE IN THE NON-PROPAZETARY VDSIONS GILY THE BRACKET 3 RDIAIN, BE .-

i INFORMATION 1 HAT WAS CONTAING WITHIN THE BRACKETS IN THE PROPAIE HAVIN3 BEIN DELETE. THE JUSTIFICATION POR II.AIMDG ME IWORMATION 30 DESIGNATED AS PROPRIETARY IS INDICATE IN BOIN'VDSIONS SY MANS, W LOWD CASE LETTERS (a) THROUGH (g) CONTAING WITHH PARENTHI3D LOCATED AS A EPDSCRIPT

IMMEDIATII.Y POLLOWING THE BRACKETS DMI.05ING EACH ITDI 0F INFORMATION B DENTIFIED AS PROPAIETARY OR IN ME HARGN OPPOSITE WOI INFORMATION. THD LGiB CASE LEITUS REFER 10 THE TYPD W INFORMATION WISTINGHOUSE CUSTO HOLDS IN CONFIDENCE DENTIFIED IN SECTIONS (4)(11)(a) through (4)(11)(g) 0F THE

. t Af71 DAVIT ACCOMPANYING THIS MAN 3MITTAL PUR5fANT 1010CFR2 790(b)(1).

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l CLADDING MATERIAL COMPOSITIONS L in ADVANCED ELEMENT ALLOY ZIRCALOY-4 -

_ +(a,c) ,;

SN, WT% 1.2-1.7 0.18-0.24 6

FE, WT% .

l CR, wT% 0.07-0.13

! FE+CR, WT% 0.28-0.37

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ZR, wr% BALANCE BALANCE

SUHMARY OF CLADDINC BEHAVIOR UNDER LOCA CONDITIONS The advanced zirconium base alloy was developed by making [

)* to the Zircaloy 4 composition to (a,c) l improve its corrosion performance.

The key aspects of cladding materials behavior which affect fuel a

performance during LOCA are high temperature metal water reaction

. kinetics and clad ballooning. The following discussion presents a l ~ t- comparison of the expected behavior of the advanced zirconium alloy with that of Zircaloy 4 HICH TEMPERATURE METAL VATER REACTION KINETICS The high temperature metal water reaction rates for Zircaloy 4 e

were reported by Cathcart I) .

[ )*( reported similar (a,c) reaction rates for Zircaloy 4, Zircaloy 2, [ )*. Both (a,c) o

'+ of these investigations show reaction rates less than those predicted by the Baker Just correlation which was adopted for LOCA modeling by the NRC. Since the advanced alloy is [

)* it is expected to (a,c) have similar high temperature metal water reaction kinetics and thus, have reaction rates less than those predicted by the Baker Just correlation.

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- , CLAD BALLOONING

[ )+I3) compares the high temperature strain behavior of (a c)

Zircaloy 4 [ )*. He found that [ )* is stronger (a,c) than Zircaloy 4 in both the alpha and beta phases but is weaker in the intermediate two phase region. For the [ )* alloy, the (a,c) two phase region begins at about 600C and ends about 900C. For Zircaloy 4, the corresponding temperatures are about 820C and

t- 950C. For the advanced alloy the temperatures are estimated to be r

[ ]*. (a.C)

The attached Figure shows the expected strain vs. temperature for Zircaloy 4 and [ )* heated at a rate of 25 C/see, replotted (a.c) from Reference 3. Also shown in the Figure is the estimated curve for the advanced alloy [

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.]*, The conclusion drawn from the Figure is that the strain (a,c) behavior of the advanced alloy will be very similar to that of 2ircaloy 4.

On the basis of the evaluation summarized above, the high temperature behavior of the advanced alloy is expected to be similar to that developed through the ECCS rulemaking proceedings and therefore, the proposed application for the insertion of two Lead Test Assemblies containing up to 48 advanced alloy clad fuel rods in North Anna Unit 1 is technically consistent with the appropriate regulations,

1 REFERENCES

1. Cathcart, J. V., et al, " Zirconium Metal Water oxidation Kinetics IV. Reaction Rate Studies" ORNL/NUREC 17. Oak Ridge National Laboratory,Jugust 1977.

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