ML20213G879

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Advises That Proprietary Westinghouse Document Entitled, Response to Questions on Changes Made to Wreflood Input in Large Break LOCA Analysis... Will Be Withheld from Public Disclosure (Ref 10CFR2.790(b)(5)),per Util 870408 Request
ML20213G879
Person / Time
Site: Prairie Island  Xcel Energy icon.png
Issue date: 05/06/1987
From: Diianni D
Office of Nuclear Reactor Regulation
To: Musolf D
NORTHERN STATES POWER CO.
References
NUDOCS 8705190004
Download: ML20213G879 (3)


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MAY 0 61987

. Docket Nos. 50-282 and 50-306 Mr. D. M. Musolf, Manager Nuclear Support Services Northern States Power Company 414 Nicollet Mall Midland Square, 4th Floor.

Minneapolis, Minnesota 55401

Dear Mr. Musolf:

SUBJECT:

REQUEST FOR WITHHOLDING INFORMATION FROM PUBLIC DISCLOSURE ,

By your letter dated April 8,1987 and Westinghouse Electric Corporation's affidavit dated April 20, 1977 you submitted a document entitled RESPONSE T0 QUESTIONS ON THE CHANGES MADE T0 THE WREFLOOD INPUT IN THE LARGE BREAK LOCA ANALYSIS FOR PRAIRIE ISLAND and requested it be withheld from public disclosure pursuant to 10 CFR 2.790.

Westinghouse Electric Corporation stated that the infonnation should 'be considered exempt from mandatory public disclosure for the following reasons:-

The information sought to be withheld consists of the. details of the Westinghouse flow path model, analytical rodeling techniques, testing programs, comparison of effects of modified initial gap pressure calcu-lation, pump speed calculations, continuous flow path quality. calculation, limiting pump speed factor, and discussion of results. -The release of.

this information would result in the following competitor benefits:

(1) It reduces or eliminates the amount of analysis, research and development work competitors would have to.do by providing specific data which by reverse engineering together with other infonnation, whether it be their own or that which is made o publicly available, enables competitors to derive the results of research and development work with a much smaller investment of-their own resources.

'(2) It enables competitors to learn details of our model, calcula - ~!

tions,.and testing programs. _!

-(3) It allows competitors to verify their own analytical techniques by using comparative testing arguments and with a much smaller i investment of resources.

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(4) It enables competitors to define and justify the scope and contents of their testing programs based on a comparison with an accepted program and thereby reduce their costs.

(5) It would provide competitors with the opportunity to develop a similar model on a time schedule which would allow them to counter Westinghouse in the marketplace.

A considerable amount of highly qualified development effort has been expended over a five year period in formulating the analytical models and computer programs used to assess emergency. core cooling system performance during a loss-of-coolant accident. The investment involved in test components, testing facilities, direct labor and computer costs amounts to approximately $3 million dollars. Some specific examples of this effort include testing of pump performance under single and two phase flow conditions, transient testing and analytical formulations for blowdown heat transfer, single and multi-rod dynamic evaluations, and associated code development and calculations of system effects as they influence emergency core cooling system performance during loss-of-cuolant accidents.

It should also be recognized that, in the course of these efforts, Westinghouse has generated additional information regarding emergency core cooling system design bases to improve our product and ultimately enhance our competitive position. Furthermore, it is felt that the extensive effort expended in obtaining comprehensive analytical and experimental information on system and component emergency core cooling system performance could directly affect cur sales performance with respect to the licensing service for which it is provided.

We believe there is a likelihood of substantial harm to the competitive position of Westinghouse if the information scught to be withheld is publicly disclosed, which could result in a minimum loss of approximately

$10,000,000 to $12,000,000 annuelly in potential reload fuel sales and reload emergency core cooling system analyses.

We have reviewed your submittal and the material based on the requirements and criteria of 10 CFR 2.790 and, on the basis of Westinghouse Electric Corporation's statements, have determined that the sutmitted information sought to be withheld contains trade secrets or proprietary commercial information.

Therefore, we have determined that the document entitled RESPONSE TO QUESTIONS ON THE CHANGES MADE TO THE WREFLOOD INFUT IN THE LARGE BREAK LOCA ANALYSIS FOR PRAIRIE ISLAND marked as proprietary, will be withheld from public disclosure pursuant to 10 CFR 2.790(b)(5) and Section 103(b) of the Atomic Energy Act of 1954, as amended.

Withholding from public inspection shall-not affect the right, if any, of persons properly and directly concerned to inspect the document. If the need arises, we may send copies of this information to our consultants working in  ;

this area. We will, of course, insure that the consultants have signed the appropriate agreements for handling proprietary infonnation.

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If the basis for withholding this information from public inspection should change in the future such that the information could then be made available for public inspection, you should promptly notify the NRC. You should also.

understand that the NRC may have cause to review this determination in the future, such as if the secpe of a Freedom of Information Act request includes your information. In all review situations, if the NRC needs additional infonnation from you or makes a determination adverse to the above, you will-be notified in advance of any public disclosure.

Sincerely, s ) \)

b V ' be Dominic C. Dilanni, Project Manager Project Directorate III-3 Division of Reactor Projects cc: See next page 1

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