ML20148H233

Application for Withholding Proprietary Amend 1 to RESAR-SP/90 Pda Module 12, Waste Mgt, from Public Disclosure Per 10CFR2.790(b)(1)

ML20148H233
Person / Time
Site:	05000601
Issue date:	03/22/1988
From:	Wiesemann R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	Rubenstein L NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), Office of Nuclear Reactor Regulation
Shared Package
ML19302D362	List: ML20148H233 NRC-88-3315, Forwards Nonproprietary & Proprietary Info on Amend 1 to RESAR-SP/90 Pda Module 12, Waste Mgt & 880322 Application for Withholding Proprietary Info from Public Disclosure Per 10CFR2.790(b)(1)
References
AW-88-022, AW-88-22, NUDOCS 8803290358
Download: ML20148H233 (19)

Text

E ,

Nuclear Technology 0ivision Westinghouse Water Reactor Electric Corporation Divisions sox 355 PittsburghPennsylenla15230 March 22, 1988

' AW-88-022 Docket No. STN-50-601 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Lester Rubenstein, Director Standardization & Non-Power Reactor Project Directorate APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

Submittal of Amendment 1 to WAPWR RESAR-SP/90 PDA Module 12, "Waste Management"

Reference:

Letter No. NS-NRC-88-3315, Johnson to Rubenstein dated March 22, 1988

Dear Mr. Rubenstein:

The 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 information proprietary to Westinghouse and customarily held in confidence.

The i 'fidavit previously provided to justify withholding proprietary info nation in this matter was submitted as AW-82-57 with letter NS-NRC-85-3065 dates September 20, 1985, and is equally applicable to this material.

Accordingly, it is respectfully requested that the subject information which is proprietary to Westinghouse be withheld from public disclosure in accordance 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-88-022 and should be addressed to the undersigned.

Very truly yours, ,

f YL L (JLilllLHA -

WMS/bek/00338 Robert A. Wiesemann, Manager Enclosure (s) Regulatory & Legislative Affairs cc: E. C. Shomaker, Esq.

Office of the General Council, NRC 8803290358 880322 PDR ADOCK 05000601 DCD

PROPRIETARY INFORMATION NOTICE TRANSMITTED HEREWITH ARE PROPRIETARY AND/0R NON-PROPRIETARY VERSIONS OF ,

DOCUMENTS FURNISHED TO THE NRC IN CONNECTION WITH REQUESTS FOR GENERIC AND/0R PLANT SPECIFIC REVIEW AND APPROVAL.

IN ORDER TO CONFORM TO THE REQUIREMENTS OF 10CFR 2.790 0F THE COMMISSION'S REGULATIONS CONCERNING THE PROTECTION OF PROPRIETARY INFORMATION S0 SUBMITTED TO THE NRC, THE INFORMATION WHICH IS PROPRIETARY IN THE PROPRIETARY VERSIONS IS CONTAINED WITHIN BRACKETS AND WHERE THE PROPRIETARY INFORMATION HAS BEEN DELETED IN THE NON-PROPRIETARY VERSIONS ONLY THE BRACKETS REMAIN, THE INFORMATION THAT WAS CONTAINED WITHIN THE BRACKETS IN THE PROPRIETARY VERSIONS HAVING BEEN DELETED. THE JUSTIFICATION FOR CLAIMING THE INFORMATION S0 DESIGNATED AS PROPRIETARY IS INDICATED IN BOTH VERSIONS BY MEANS OF LOWER CASE LETTERS (a) THROUGH (g) CONTAINED WITHIN PARENTHESES LOCATED AS A SUPERSCRIPT IMMEDIATELY FOLLOWING THE BRACKETS ENCLOSING EACH ITEM OF INFORMATION BEING IDENTIFIED AS PROPRIETARY OR IN THE MARGIN OPPOSITE SUCH INFORMATION. THESE LOWER CASE LETTERS REFER TO THE TYPES OF INFORMATION WESTINGHOUSE CUSTOMARILY HOLDS IN CONFIDENCE IDENTIFIED IN SECTIONS (4)(ii)(a) THROUGH (4)(ii)(g) 0F THE AFFIDAVIT ACCOMPANYING THIS TRANSMITTAL PURSUANT TO 10CFR2.790(b)(I).

e AW-82-57 AFFIDAVIT COMMONWEALTri 0F PENNSYLVANIA:

ss COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally aopeared John D. McAdoo, who, being by me duly sworn according to law, deposes and says that he is aut!:orized to execute this Affidavit on behalf of Westinghouse Electric Corporation ("Westinghouse") and that the avements of fact set forth in this Affidavit are true and correct to the best.of his knowledge, infomation, and belief:

=w w C c -

. n D. McAcco, Assistant Manager Nuclear Safety Department l

Sworn to and subscribed

! before me this / day af bu m/V.Ll1982.

s

$.LLlLU /

Notary Public l

nuunt su:nsu. a:tAar resu:

UCNf9fflut :420. ALilCXDY OUM af 00MMissi:q DP1201AICH 1. ISW umw, Pennsymna Assoostion ef M*3*"

AW-82-57 (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 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 10CFR Section 2.790 of the Commission's regulations and in con-junction with the Westinghouse apolication 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 l

of the Commission's regulations, the following is furnished for consideration by the Commission in determining wnether the in-fonnation sought to be withheld from public disclosure should be withheld.

1 (1) The information sought to be withheld frem public disclosure is owned and has been held in confidence by Westingneuse.

l i

AW-82-57 (ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public.

Westinghouse has a rational bas'is 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 appifcatico 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 distinguisning as;:ects of a process (or component, stru'cture, tool, method, etc.)

where prevention of its use by any of Westingnouse's competitors w'ithout license from Westingneuse cdnsti-l tutes a competitive economic advantage over other companies.

l (bl. It consists of supporting data, including test data, relative to a proce:;s (or comconent, structure, tool, method, etc.), the application of which data secures a l

competitive econcmic advantage, e.g., by optimization or improved marketability.

l l

l

y AW-82-57 (c) Its use by a competitor would reduce his expenditure of retources 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-acities, budget levels, or ccmmercial strategies of Westinghouse, its custcmers or suppliers.

(el It reveals aspects of past, present, or future West-inghouse or customer funded development plans and pro-grams of potential commercial value to Westinghouse.

(f). It contains patentable ideas, for which patent pro-tection may be desirab.le.

(gl It is not the property of Westinghouse, but must be treated as proprietar;* by Westinghouse ac:ording to agreements with the owner.

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 com-petitors. It is, therefore, withheld from disclosure to protect the Westingnouse competitive position.

tr

. AW-82-57 (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) Usa by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

(d ). Each componern: of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If ecmpetitors acquire components of proprietary infor-ination, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a comoetitive advantage.

(e) Unrestricted disclosure would jeopardi:e the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition in those countries.

(fl The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

r

n 14 AW-82-57 (iii) The information is being transmitted to the Comission in confidence and, under the provisions of 10CFR Section 2.790, I

it is to be received in confidence by the Comission.

(.iv) The information sought to be protected is not available in public sources or available information has not been pre-viously employed in the same original manner o* method to the best of our knowledge and belief.

(v). The proprietary information sought to be withheld in this sub-mittal is that which is. appropriately marked in the "Westing-house Advanced Pressurized Water Reactor (WAPWR) Licensing Control Document." This document identifies specific design features and improvements which the WAPWR will have in order to meet current reguTatory requirements. In addition, it establishes the ' fAPWR position with respect to each require-ment.

Public disclosure of this information is likely to cause suo-stantial harm to the competitive position of Westinghouse as it would reveal the description of the improved design features of the WAPWR; Westinghouse plans for future design, testing and analysis aimed at design verification; and demonstration of the design's capability to meet evolving NRC/ACRS safety goals.

All 6f this information is of competitive value because of the large amount of effort and money expended by Westingneuse over

[ a period of several years in carrying out this particular l

l AW-82-57 1

I l

development program. Further, it would enable competitors to I l

use the information for commercial purposes and also.to meet  !

NRC requirements for licensing documentation, each without l purchasing the right from Westinghouse to use the information, i I

Information regarding its development programs is valuable to  !

. Westinghouse because:

l La) 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 competi-tors 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 com-petitive disadvantage by reducing his expenditure of resources at our expense.

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

l l

i l

I .

i e' ,

• 4 AW-82-57 (e) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

Being'an innovative concept, this information might not be discovered by the competitors of Westinghouse indeoendently.

To duplicate this information, 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.

h

- WESTINGHOUSE CLASS 3 AMENDMENT 1 TO RESAR-SP/90 PDA MODULE 12 WASTE MANAGEMENT l

l l

l l

i i

l i

I i

l l

l l

WAPWR-WM AMENDMENT 1 I

7514e:1d MARCH, 1988 ,

AMENDMENT 1 TO RESAR-SP/90 PDA MODULE 12-

^

WASTE MANAGEMEMT ,

, i L Instruction Sheet Replace current page 11.5-29 with revised page 11.5-29.

t j Replace current page 11.5-36 with revised page 11.5-36.  !

Replace current page 11.5-46 with revised page 11.5-46. -

! Place remainder of package behind Questions / Answers Tab in Module 12.

1 i

t i

!O i

1 i

t I

O i

i WAPWR-WM AMENDMENT 1 7514e: Id MARCH, 1988

REQUEST FOR ADDITIONAL INFORMATION ON RESAR-SP/90 PDA As a result of the review of Chapter 11.5 of the Westinghouse Advanced Pressurized Water Reactor (RESAR SP-90) FSAR by our

[]

V Radiation Protection Branch, we have several comments that should be addressed either in the preliminary design phase or in the final design phase.

Tables in the submission describe the characteristics of individual monitors but no diagrams were submitted fixing the J location of these monitors within the plant. General reference was made to several NRC Regulatory Guides and an ANSI Standard, but no mention was made of Technical Specifications (TS) for these effluent monitors for the eventual operation of this plant.- Characteristics proposed for these effluent monitors should be related to Technical Specifications presently in effect for Westinghouse plants. Inconsistencies noted include the lower limit of detection (LLD) of the radiciodine monitor PE-2 that is given in Table 11.5-2 as 1.0E-11 uti/cm', while the TS for Westinghouse plants such as Beaver Valley 2 require 1.0E-12. Similarly, radiogas monitor PE-28 for the Radwaste Building effluent is listed in Table 11.5-2 with an t.LD of 1.0E-8, although noble gas monitors for operating Westinghouse O plants have LLDs of 1.0E-6-in their TS, and some of the older plants have trouble meeting 1.0E-5. Further, tables of the August, 1985 submission state have (that) values for set points for the monitors will be provided later.

Specific location information regarding the effluent monitoring systems will also be required.

GENERAL WESTINGHOUSE COMMENT ON NRC LETTER:

In the NRC letter, the Radiation Protection Branch referred to their review of Chapter 11.5 of the Westinghouse Advanced Pressurized Water Reactor (RESAR-SP/90 PDA) as an FSAR review.

Since the current RESAR SP-90 Modules are being reviewed by the NRC for Preliminary Design Approval (PDA), some of the requested information is not required (for a PDA) and would be more appropriate for inclusion in a submittal for a Final Design Approval .'FDA) review.

O WAPWR-WM 1 AMENDMENT 1 7514e:1d MARCH, 1983

z Following ere the NRC comments from the 2/19/88 letter and the O- Westinghouse responses to those comments: (W has divided the RAI into six parts for ease of response and has assigned question numbers per the NRC project manager.)

471.15 NRC COMMENT:

Tables in the submission describe the characteristics of individual monitors but no diagrams were submitted fixing the location of these monitors within the plant.

O RESPONSE:

Monitor locations will be deferred to the FDA stage. Referring to the Standard Review Plan (NUREG-0800), Section 11.5, "Process and Effluent Radiological Monitoring Instrumentation and Sampling Systems," Item I.2.(b), "Location of Monitors and Direct Readout" is required (via the footnote) in the FSAR only.

471.16 NRC COYYENT:

General reference was made to several NRC Regulatory Guides.and an ANSI Standard, but no mention was made of Technical Specifications (TS) for these effluent monitors for the eventual operation of this plant. Characteristics proposed for these effluent monitors should be related to Technical Specifications presently in effect for Westinghouse plants.

t

RESPONSE

The characteristics proposed for these effluent monitors are Os compatible with the Technical Specifications presently in effect for Westinghouse plants and the most current revision to NUREG-0452, "Standard Technical Specifications for Westinghouse t Pressurized Water Reactors" will be used as the bases for the preparation of Technical Specifications for this plant.

However, this will be deferred to the FDA stage. This is consistent with SRP 11.5 (NUREG-0800) since item 111.2 of l

! WAPWR-WM 2 AMENDMENT 1

7514e

1d MARCH, 1988 I

Section 11.5 states, "ETSB reviews the technical specifications f3 U proposed by the applicant for process and effluent radiological monitoring and sampling at the OL stage."

471.17 NRC COMMENT:

The lower limit of detection (LLD) of the radiciodine monitor o PE-2 is given in Table 11.5-2 as 1.0E-11 uCi/cm' while the TS for Westinghouse plants such as Beaver Valley 2 require 1.0E-12.

RESPONSE

Owing to the lower background radiation levels in the laboratory versus typical plant locations, in which continuous monitors are located, a lower sensitivity or LLD is achievable for samples which are analyzed in the laboratory.

The purpose of the monitor in question (PE-2) is to continuously monitor iodine activity as it is discharged to the envircnment through the main plant vent (see RESAR-SP/90 PDA Section 11.5.2.3 and Figure 11.5-4). The radioiodine monitor referred to for Beaver Valley 2 (as well as the Westinghouse Standard Technical Specifications, NUREG-0452), however, is a charcoal collector which is analyzed in the laboratory, within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after changing, at least once per 7 days (see Beaver Valley Unit 2 or NUREG-0452 Technical Specification Section 3/4.11.2).

471.18 NRC COMMENT:

Similarly, radiogas monitor PE-28 for the radwaste building effluent is listed in Table 11.5-2 with an LLD of 1.0 E-8, although noble gas monitors for operating Westinghouse plants have LLDs of 1.0E-6 in their TS, and some of the older plants have trouble meeting 1.0E-5.

RESPONSE

l Westinghouse recognizes that an LLD of 1.0E-8 uCi/cm2 for radiogas detection is too low and also that there is no need for WAPWR-WM 3 AMENDMENT 1 7514e: 1d MARCH, 1988

the LLD for radiogas effluent from the radwaste building to be O any lower than that of other plant effluents. Therefore, the detectable range for radiogas monitor PE-28 has been changed to (5.0E-7 to 5.0E-2) in order to be consistent with other plant effluent radiogas monitors listed in Table 11.5-2 and be within O state-of-the-art LLD for Beta scintillation type detectors.

471.19 NRC COMMENT:

Further, tables of the August, 1985 submission state that values O for set points for the monitors will be provided later.

RESPONSE

The term "later" presented in RESAR-SP/90 PDA Tables 11.5-4 and 11.5-10 is to be interpreted as "to be provided in the FDA submittal" and has been revised on the applicable tables. This is consistent with SRP 11.5 (NUREG 0800) since Item I.2.(a),

. . . . alarm / trip setpoints . . . .

are required (via the footnote) in the FSAR only.

. 471.20 NRC COMMENT:

i Specific location information regarding the effluent monitoring systems will also be required.

RESPONSE

See response to NRC comment number 471.15 above.

O V

O O

WAPWR-WM 4 AMENDMENT 1 7514e:1d MARCH, 1988

' ~

O O O

~

O O O O -

TABLE 11.5-2 (SHEET 2 Of 4) 4 DETECTOR REQUIREMENTS FOR PROCESS AND EFFLUENT RADIATION MONITORS Radiation Detectable Detector Zone Range -

Monitor Location Type (MR/h) Major Isotopes (uCi/cm')

Cubicle Air Monitor -

PE-23 (particulate) Aux b1dg Beta 0.25-2.5 Co-58, Co-60, I-131, I-133, 1.0E-10 to 1.0E-5 scintillation Cs-134, Cs-137 PE-24 (radiogas) Aux b1dg Beta 0.25-2.5 Xe-133, Xe-135, Kr-85 5.0E-7 to 5.0E-2 scintillation Radwaste Building Effluent PE-26 (particulate) Radwaste Beta 0.25-2.5 I-131, I-133, Cs-134 CS-137, 1.0E-11 to 1.0E-6 b1dg scintillation 00-58, Co-60, Sr-90 PE-27 (iodine) Radwaste Gamma 0.25-2.5 I-131 1.0E-11 to 1.0E-6 b1dg scintillation PE-28 (radiogas) Radwaste Beta 0.25-2.5 Xe-133, Kr-85 5.0E-7 to 5.0E-2 1 b1dg scintillation Control Room Air Intake PE-30A, PE-30B Control room Thin walled < 0.25 Xe-133, Xe-135, Kr-85, I-131, 1.0E-6 to 1.0E-1 G-M tubes I-133, Co-58, Co-60 Gaseous Waste Processing System PE-31 Aux. b1dg G-M tubes 2.5-15 Xe-133, Xe-135, Kr-85 1.0E-1 to 1.0E+4 Gaseous Waste Processing System Effluent PE-38 Aux. b1dg G-M tube 0.25-2.5 Xe-133, Xe-135, Kr-85 1.0E-1 to 1.0E+4 i

WAPWR-WM 11.5-29 .WENOMENT 1 7514e-Id kARCH, 1988

1 E

9 9

TABLE 11.5-4 ALARM SETPOINTS FOR PROCESS AND EFFLUENT RADIATION MONITORS Initial Setpoints (uCi/cm )

8 Gas Monitors Intermediate High (Later)* (Later)

O PE-1 PE-2 (Later) (Later) 1 PE-3 (Later) (Later)

PE-10 (Later) (Later)

PE-11 (Later) (Later)

PE-12 (Later) (Later)

PE-13 (Later) (Later)

PE-14 (Later) (Later)

PE-23 (Later) (Later)

PE-24 (Later) (Later)

O PE-26 (Later) (Later)

PE-27 (Later) (Later)

PE-28 (Later) (Later)

PE-29 (Later) (Later)

PE-30A, B (Later) (Later)

PE-31 (Later) (Later) l PE-38 (Later) (Later) l PE-41A (Later) (Later)

PE-16 (Later) (Later)

O PE-17A and B (Later) (Later)

PE-18 (Later) (Later)

PE-19 (Later) (Later)

PE-20A and B (Later) (Later)

O PE-21 (Later) (Later)

PE-22 (Later) (Later)

PE-25 (Later) (Later)

PE-43 (Later) (Later)

O *To be provided in the FDA submittal. 1 WAPWR-WM1 11.5-36 AMENDMENT 1 7514e: 1d MARCH, 1988

TABLE 11.5-10 ALARM SETPOINTS FOR POST-ACCIDENT RADIATION MDNITORS Initial Setpoints (uCi/cm')

Monitor Intermediate High PE-44A NA, passive monitor ---

PE-44B NA, passive monitor ---

i 4

PE-44C (Later)* (Later) 1 i

! PE-45A (Later) (Later) l PE-45B (Later) (Later) l PE-45C (Later) (Later)

PE-45D (Later) (Later)

PE-33 NA, passive monitor ---

PE-34 NA, passive monitor ---

PE-15 (Later) (Later) 1

• To be provided in the FDA submittal.

O O

WAPWR-WM1 11.5-45 AMENDMENT 1 7514e:1d MARCH, 1988