ML20006E540

Requests Withholding of Proprietary WCAP-12495, Review of Flow Peaking & Tube Fatigue in Diablo Canyon Units 1 & 2 Steam Generator, from Public Disclosure

ML20006E540
Person / Time
Site:	Diablo Canyon
Issue date:	01/22/1990
From:	Wiesemann R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML16341F559	List: ML16341F558 ML20006E540 ML20006E544
References
CAW-90-005, CAW-90-5, NUDOCS 9002230529
Download: ML20006E540 (10)

Text

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' Westinghouse .

Energy Systems - Nuclear and Advanced '

Electric Corporation *" ' E' "8' " -

Box 355 -

Pittsburgh Pennsylvania 15230-0355 '

, Document Control Desk January 22, 1990 US Nuclear Regulatory Commission CAW-90-005 Washington, DC--20555 1 Attention: Dr. Thomas Murley:

APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

. WCAP-12495 (Proprietary) and WCAP-12496 (Non-Proprietary),

" Review of Flow Peaking and Tube Fatigue in Diablo Canyon Units 1 and 2 Steam Generators" r

Dear Dr. Murley:

The proprietary information for which withholding is being requested in the enclosed letter by Pacific Gas and Electric Company is furthar t

identified in an affidavit 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 y 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  ;

Affidavit CAW-88-106.

.Accordingly, .this letter authorizes the utilization of the accompanying affidavit by Pacific Gas and Electric Company.

Correspondence with respect to the proprietary aspects of the application >

• for withholding or the Westinghouse affidavit should reference this

• 1etter, CAW-90-005, and should be addressed to the undersigned.

Very truly yours, W MdQM o er '. esemann, anager Regulatory & Legislative Affairs -

Enclosures cc: K. Holzle, Esq.

Office of the General Counsel, NRC  ;

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< PROPRIETARY INFORMATION NOTICE a

[ TRANSMITTED HEREWITH ARE PROPRIETARY AND/0R NON-PROPRIETARY-VERSIONS OF  !

h DOCUMENTS FURNISHED TO THE NRC IN CONNECTION WITH REQUESTS FOR GENERIC U

AND/0R. PLANT SPECIFIC REVIEW AND APPROVAL.

~ IN ORDER TO CONFORM TO THE REQUIREMENTS OF 10CFR 2.790-0F THE COMMISSION'S L - REGULATIONS CONCERNING~THE. PROTECTION OF PROPRIETARY INFORMATION S0 l L . SUBMITTED TO THE NRC, THE INFORMATION'WHICH IS' PROPRIETARY IN THE PROPRIETARY VERSIONS IS CONTAINED WITHIN' BRACKETS AND WHERE TH'E l PROPRIETARY INFORMATION-HAS BEEN DELETED IN THE NON-PROPRIETARY VERSIONS ,

- ON THE BRACKETS REMAIN, THE INFORMATION:THAT WAS CONTAINED WITHIN BRACKETS

AND WHERE THE PROPRIETARY INFORMATION HAS BEEN DELETED IN THE- j

!? - NON-PROPRIETARY VERSIONS ONLY THE BRACKETS, REMAIN, THE INFORMATION.THAT y

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- WASfCONTAINED WITHIN THE- BRACKETS IN THE PROPRIETARY VERSIONS HAVING BEEN j

? - DELETED.. THE JUSTIFICATION FOR CLAIMING-THE INFORMATION S0 DESIGNATED AS.

i PROPRIETARY IS INDICATED IN BOTH VERSIONS BY MEANS OF' LOWER CASE LETTERS

/ (a) THROUGH (g) CONTAINED'WITHIN PARENTHESES LOCATED'AS A SUPERSCRIPT l

! m IMMEDIATELY FOLLOWING THE BRACKETS ENCLOSING EACH ITEM 0F INFORMATION l

. BEING IDENTIFIED AS PROPRIETARY OR IN THE MARGIN OPPOSITE SUCH l N

. INFORMATION. 'THESE LOWER CASE LETTERS REFER T0-THE~ TYPES OF INFORMATION j 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)(1).

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AFFIDAVIT q

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. COPMONWEALTH OF PENNSYLVANIA: .

ss-r COUNTY 0F ALLEGHENY:-

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Before me, the undersigned authority, personally. appeared Robert A. Wiesemann, who,i being'by me duly sworn according-to law,  !

' deposes'and says that hel1s: authorized to execute this Affidavit'on- 'f

= 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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Robert-A. Wiesemann -Manager._ .

Regulatory and -Legislative Affairs .

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Sworn to and subscribed 3

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~ Notary Public NOTARIAL st AL s LoRRAINE W PACA, NOTARY PUBLC V McNRo(VLLI Boro. ALLEGr4ENY COUNTY

& MYCOV.f/:s?cri EXPIRIs Dic 14.iM1 Membee Passpvens Assonemo'fWsu y1 *^?..

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2- CAW-88 106 (1) I am Manager, Regulatory and Legislative Affairs, in the Nuclear and Advanced Technology Division,:of the 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'and~ rulemaking proceedings, and am authorized to apply for its withholding on behalf of the Westinghouse Energy Systems, Nuclear Fuel, and Power Generation Business Units.

s (2) 1 am making this Affidavit in conformance with the provisions of 30CFR Section 2.7g0 of the Comission's regulations and in conjunction with the Westinghouse application for withholding accompanying this Affidavit.

. (3) 1- have personal knowledge of the criteria and procedures utilized by the Westinghouse Energy-' Systems, Nuclear Fuel, and Power Generation Business Units in designating information as a trade secret, privileged or as confidential comercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.7go of the Comission's regulations, the following is furnished for consideration by the Comission in determining whether the information sought to be withheld from public disclosure should be withheld.

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

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. (ii)' The infomation is of a type customarily held in confidence by

, Westinghouse and not customarily disclosed to the public. , ,

' Westinghouse:has a_ rational basis for detemining the types of l

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infomation customarily held in confidence by it and; in that ~

D connection, utilizes a system to detemine when and whether to L

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- 3 required.

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h . Under that system,- infomation is held. in confidence if it falls L in one or more of several types, the release of which might result in the loss of an existing or potentfal competitive ,

advantage,.as follows

.(a) The information reveals the' distinguishing aspects of a l 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, i 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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(c) .Its use by a competitor _ would reduce his expenditure of- t resources'or improve his' competitive position-in the design, manufacture, shipment, installation, assurance of  !

. quality, or licensing a similar product. -

• - (d) It1 reveals cost or price infomation', production capacities, budget levels, or commercial strategies of L Westinghouse, its customers or suppliers.

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L - (e) 'It reveals aspects of past, present, or future Westinghouse ,

H or customer funded development plans and programs-of 1

potential commercial value to Westinghouse. .;

(f) It contains patentable ideas', for which patent protection ]

may be desirable.  ;

(g){It~is'not-thepropertyofWestinghouse,butmustbetreated as proprietary by Westinghouse according to agreements with j the owner, q a

-i There are sound policy reasons behind the Westinghouse system L, which include the following: f (a) The use of such information by Westinghouse gives i

Westinghouse a competitive advantage over its competitors, It .is, therefore, withheld from disclosure to protect the i Westinghouse competitive position.

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, i (b) It is information which is marketatle 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. -I

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(c) Use by our competitor would put Westinghouse at a: 'I competitive disadvantage by reducing his expenditure of 7 L

] resources at our expense.- .

(d)= L Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable j

, 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 x give a market advantage:to the competition of.those 1

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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(iii) The infomation is being ' transmitted-to thi Commission in confidence and, under the provisions of 10CFR Section 2.790, it is to be received in confidence by the Commission.. 1 i

.(iv) The information sought to be protected is not available in I public sources or available information has not been-previously employed in the same original manner or method

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b .to the best of our knowledge and belief.

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~(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in;" San _!

Onofre Unit 1 Evaluation for Tube Vibration Induced  !

f atigue,"

F WCAP-11974 (Proprietary),.for San Onofre Nuclear h Generating Station Unit-No. 1, being transmitted by the'- -

Southern-California Edison Company (SCE) letter and 4 Application for Withholding Proprietary Information from 1 Public Disclosure, M. 0. Medford, SCE,- to J. B.' Martin, Region 5 Administrator November 10, 1988. 1he proprietary information as submitted for use by Southern California

' Electric Company for the San Onofre Unit No 1 is expected to be applicable .in other licensee submittals in response ,

to certain NRC requirements for justification of actions 'to ,

minimize the potential for rapidly propagating fatigue cracks causing a steam generator tube rupture.  !

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This information is part or that which will enable ,

Westinghouse to: ~ j i

(a) Provide documentation of the analyses,' methods, and

& testing.for reaching a conclusion relative'to ^he. 3 potential for denting induced fatigue degradation ^ at the top tube support plate.

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(b) Establish the tube stiffness, frequency, and ,

fluid elastic stability ratios by dynamic analysis of } .

various tubes.  !

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.(c) Establish the effects on fluid-elastic instability of columnwise~ variations in anti-vibration bar insertion

. depths. '

5(d) Establish the detailed flow conditions in the region:

of interest including flow velocities, densities. and _ ,

void fractions.

(e)'AssistthecustomertoobtainNRCapproval, y

Further this information has substantial commercial value y as follows:' .

(a) Westinghouse plans to sell the use of similar information to its customers for purposes of meeting NRC requirements for licensing documentation. >

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( 'I (b). Westinghouse can sell support.and-defense of the i w' . technology to its customers in the 1icensing process.

s Public disclosure of this proprietary information is likely- i to cause substantial ham to the competitive position of s

- Westinghouse because it would enhance' the ability'of.

competitors to provide similar analytical: documentation and; L

licensing' defense services for commercial power reactors I~ - witho'tu commensurate expenses. Also, public disclosure of the infomation would enable'others to' use the infomation  ;

to: meet NRC requirements for licensing documentation ,

without purchasing the.right to use the information.

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The development of the technology described in;part by the -

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.information-is the result of applying' the results of many u<

years of experience in an intensive Westinghouse' effort and.

[_ 'the expenditure of a considerable sum of money. '

In' order for competito'rs of Westinghouse to duplicate this en information. similar technical programs would have to'be  !

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perfomed and a significant' manpower effort, having the requisite talent and experience, would have to be expended 1 s

for developing testing and analytical methods and j.

performing. tests.

J Further the deponent sayeth not.

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