ML20212A733

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Requests Withholding of Slides Used in Westinghouse 780321 Optimized Fuel Assembly Presentation to NRC from Public Disclosure Per 10CFR2.790
ML20212A733
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 03/21/1978
From: Wiesemann R
WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To: Stolz J
Office of Nuclear Reactor Regulation
Shared Package
ML19292F651 List:
References
AW-78-23, NUDOCS 8607290113
Download: ML20212A733 (11)
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Westinghouse Water Reactor sciass RNghPerrs/vania15230 Electric Corporation Divisions March 21, 1978

- AW-78-23 Mr. John F. Stolz, Chief Light Water Reactors Branch No.1 Division of Project Management Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

SUBJECT:

Copies of Slides Used in Westinghouse Optimized Fuel Assembly Presentation to NRC on March 21, 1978 REF: Westinghouse Letter No. NS-CE-1729, Eicheldinger to Stol'z,'

dated March 21, 1978

Dear Mr. Stolz:

This application for withholding is submitted by Westinghouse Electric

. Corporation (" Westinghouse") pursuant to the provision of paragraph (b)(1) of Section 2.790 of the Commission's regulations.

The undersigned has reviewed the information sought to be withheld and is authorized to apply for its withholding on behalf cc Wastinghouse, WRD, notification of which was sent to the Secretary of the Commission on April 19, 1976.

The affidavit accompanying this application 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 Section 2.790 of the Commission's regulations.

Accordingly, it is respectfully requested that the subject information l

, which is proprietary to Westinghouse be withheld from public disclosure l in accordance with 10 CFR Section 2.790 of the Commission's regulations.  ;

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AW-78-23 Mr. J. F. Stolz March 21, 1978 Correspondence with respect to this application for withholding or the accompanying affidavit should reference AW-78-23, and should be addressed to the undersigned. -

Very truly yours, Robert A. Wiesemann, Manager Licensing Programs cc: J. A. Cooke, Esq.

Office of the Executive Legal Director

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AW-78-23 .

AFFIDAVIT -

COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally appeared Robert A. '.iesemann, 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 l the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:

' ' $ lLlAMMin Robert A. Wiesemann, Manager Licensing Proti ams Sworn to and subscribed before,me this.do day -

of M46cd 1978.

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AW-78-23

(-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 reviewir[g the proprietary infomation sought to be withheld frem 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 Reacter Divisions.

(2) I am making this affidavit in conformance with the provisions of 10 CFR Section 2.790 of the Ccmmission's regulations and in con-junction with the Westinghouse application for withholding accompanying 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 ccmercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.790 of the Cocmission's regulations, the following is furnished for consideration by the Commission in detennining 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 confidence by Westinghouse.

l (ii) The informati6n is of a type customarily held in confidence I by Westinghouse and not customarily disclosed to the public.

Westinghouse has a rational basis for detemining the types of information custcmarily held in confidence by it a'nd, in that connection, utilizes a system to detemine when and l

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. . AW-78-23 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.

Criteria and Standards Utilized In determining whether information in a document or report is proprietary, the following criteria and standards are utilized by Westinghouse. Information is' proprietary if any one of the following are met:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.)

where prevention of its use by any.of Westiaghouse'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 op~timization 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, instaliation, assurance of quality, or licensing of a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or comercial strategies of Westipghouse, its customers or suppliers.

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AW-78-23 (e) It reveals aspects of past, present, or future Westing-house or customer funded development plans and programs of potential comercial value to Westinghouse. .

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

(g) It is not the property of Westinghouse, but must be treated as proprietary by Westinghouse according to agreements with the cwner.

(iii) The infor ation is being transmitted to the Cor.ission in confidence and, under the provisions of 10 CFR Section 2.790, it is to be received in confidence by the Commission.

(iv) The infomation 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 are the copies of slides utilized oy Westinghouse in its presentation to the fiRC at the March 21, 197,8 meeting concerning the Westinghouse optimized fuel as.iembly. The letter and the copies of slides are being submitted in pre-liminary form to the Conaission for review and cc=ent on the Westinghouse optimized fuel assembly in advance of a formal submittal for tiRC approval.

Public disclosure of this infomation is likely to cause substantial harm to the competitive position of Westinghouse as it would reveal the description of the approved design, the comparison of the improved design with the standard dpsign, the nature of the test's conducted, the test conditions, the test results and the conclusions of the testing program,

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AW-78-23 all of which is recognized by the Staff to be of competitive value and because of the large amount of effort and money expended by Westinghouse over a period of several years in

. carrying out this particular development program. Further, it would enable competitors to use the information for commercial .

purposes and also to meet NRC requirements for licensing documentation, each without purchasing the right from Westing- ,

house to use the information. ,

Information regarding its development programs is valuable to Westinghouse because:

(a) Information resulting from its development programs 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 compet-itors diminishes the Westinghouse ability to sell products and services involving the use of the u f'ormation.

(c) Use by our competitor would put Westinghouse at a com-petitive disadvantage by reducing his expenditure of resources at our expense.

(d) Each component of proprietary informaticn pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If com-petitors acquire components of proprietary information, any one ccmponent may be the key to the entire pbz:le, thereby depriving Westinghouse of a competitive advantage.

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AW-78-23 (e) The Westinghouse capacity to invest corporate assets in research and development depends upon the succest in

. obtaining and maintaining a competitive advantage. '

Being an innovative concept, this information might not be discovered by the competitors of Westinghouse independently. To duplicate this infor-

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mation, competitors would first have to be similarly inspired and would then have to expend an effort similar to that of Westinghouse to develop the design.

Further the deponent sayeth not.

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Supplemental Information Relative to l Momentary Fuel Assembly Liftoff i

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Attachment 2 ST-HL-AE-1711 File No.: G9.17, R15.1 Supplemental Information Relative to Momentary Fuel Assembly Liftoff The South Texas Project fuel assembly leaf spring is designed to prevent the fuel assembly from lifting off the lower core support plate during normal plant operation. This design criteria is met since the leaf spring force plus the fuel assembly weight is greater than the combination of the fuel assembly lift and buoyancy forces. Specific data which shows the nunarical values of each of these design forces and which demonstrates that the weight plus the spring forces exceeds the lift plus buoyancy force for cold and hot operating conditions is attached.

A turbine overspeed transient following loss of load may cause momentary fuel assembly liftoff if the lift and buoyancy forces should exceed the weight and spring force. Such liftoff is expected to be infrequent and the fuel assembly and core component hold down springs will accommodate the added deflection with no resultant damage to STP fuel assemblies or adjacent assemblies. This is supported by the following statements:

1. Grid-to-grid contact will be maintained.
2. The turbine overspeed will be infrequent and of a short duration,
3. The overspeed transient has the potential to affect only those assemblies in the core center region.

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4. Turbine overspeed calculations are based on worst case conditions.

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Ref: CAW-86-056 Supplemental Information Relative to Momentary Fuel Assembly Liftof f Specific Data - T6X Fuel Assembly Forces _ t Leaf Spring Fuel Assy. Lift Buoyancy Force Weicht Force Force Net

  • a,b,c Cold Conditions Hot Conditions Turbine Overspeed Units are pounds A plus (+) indicates a net downward force and a negative (-) indicates a net upward force.

Potential liftoff = net assembiv force (Dounds) total leaf spring rate (pounds per inch) a,c

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