ML20214G489

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Requests That Proprietary Addl Info in Support of Elimination of Postulated Pipe Rupture in Accumulator Line of South Texas Units 1 & 2, Be Withheld (Ref 10CFR2.790). Figures of Accumulator Loops 1,2 & 3 Encl
ML20214G489
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 05/07/1987
From: Wiesemann R
WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To: Murley T
Office of Nuclear Reactor Regulation
Shared Package
ML19292H294 List:
References
CAW-87-048, CAW-87-48, NUDOCS 8705270082
Download: ML20214G489 (10)
v • d • e


Text

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. U Westinghouse PowerSystems sex 355 Pittsburgh Pennsylvania 15230 0355 Electric Corporation May 7, 1987 CAW-87-048 Dr. Thomas Murley, Director Of fice 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 Accumulator Line of South Texas Units 1 & 2

Dear Dr. Murley:

The proprietary information for which withholding is being requested in the enclosed letter by Houston Lighting & Power Company is further identified.in

an af fidavit 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 required 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 & Power Company.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-87-048, and should be addressed to the undersigned.

Very t,u yours, o r A. Wies nn, Manager R gulatory & L gislative Affairs Enclosures cc: E. C. Shomaker, Esq.

Office of the General Council, NRC

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8705270082 870518

-PDR ADOCK 05000498-A PDR c

PROPRIETARY INFORMATION NOUCE TRANSHITTED HDDiITH ARE PROPRIETARY AND/0R NON-PR  !

D00JMENIS FURNISHE TO THE NRC IN CONNECTION WI l PLAhT SPECIFIC REVIEW AND APPROVAL.

IN ORDU 10 CONFORM 1D THE RIQUIRDENTS & 10CFR2.790 REGULATIONS CONCERNING THE PROTECTION W PROPRIE TO THE NRC, THE INFORMATION WHICH IS PROPRIETARY IN THE PROP CONTAING WITHIN BRACKEIS AND WHERE THE PROPRIETAR DE.ETED IN THE NON-PROPRIETARY VDSIONS IN.T THE BRACKEIS REMAIN INFORMATION THAT WAS CONTAINED WITHIN THE BRAC HAVING BES LE.ETE.

THE JUSTIFICATION FOR CLAIMING THE INFORMATION 3 DDIDNATED AS PROPRETARY IS INDICATED IN BD!H VER LEITERS (a) THROUGH (g) CONTAIND WITHIN PARENTEDES LOCATD AS IMMIDIATELT FDLLOWIh"i INE BRACKETS Sic.051NG EACH IT ~

IDENTIFED AS PROPRIETARY OR IN 1HE MARGINTHEE OPPOSUE SJ LCMD CASE LETTERS RUTR 10 THE TYPES OF INFORMAT N0lt3 IN CONFIDENCE IDEhTIFIED IN SECTIONS (4)(ii)(a) through (4)(ii)(g)

AFFIDAVIT ACCOMPAhTING THIS TRANS.SCTTAL PUR30AhT

j CAW-84-102

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AEEIRAY.LT.

l COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF ALLEGHENY:

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:

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i Joh D. McAdoo, Assistant Manager clear Safety Department i

Sworn to and subscribed before me this &! ,, day h .1984. a gh c:1 6

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I 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 an authorized to apply for its withholding on behalf of the Westinghouse Water Reactor Divisions.

(2) I am making this Affidavit in conformance udth 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 cf paragraph (b)(4) of Section 2.790 of the l Commission's regulations, the following is furnished for consideration by

., the Commission in determining whether the information sought to be

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withheld from'public disclosure should be withheld. ~

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

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CAW-84-102 under that system, infonnation is held in confidence if tt falls in one or more of several types, the release of which might res; ult in the loss rf an existing or potential competitive 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 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 b/ 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 I

similar product.

l (d) It reveals ' cost or price information, production capacities,

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

(e) It reveals aspects cf past, present, or future Westinghouse or customer funded development plans and programs of potential commercial 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 owner.

CAW-84-102 l

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There are sound policy reasons behind the Westinghouse system which include the following: "

(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors.

It is, therefore, udthheld 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 a competitive disadvantage by reducing his expenditure of resources at our expense.

1 (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 Westinghouse of a competitive advantage.

(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.

(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, i

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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-1048g,

" 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."

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

because it would simplify design and evaluation tasks without requiring a comensurate investment of time and effort.

Further the deponent sayeth not.

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Schematic Layout of Accumulator Line Loop 2 F i g u.c e. 2

4 Node 785H/TT9: Highest Load for 12 in. Pipe Node 80AE/800: Next Highest Load for 12 in. Pipe Ri 5 t^lW p +R 2 d

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-Schematic Layout of Accumulator Line Loop 3 Fig ure. 3

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