ML20235J492

Requests That Errata Sheet for Proprietary WCAP 11178,Rev 1 Be Withheld (Ref 10CFR2.790).Affidavit Encl

ML20235J492
Person / Time
Site:	Farley
Issue date:	06/23/1987
From:	Wiesemann R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	Murley T Office of Nuclear Reactor Regulation
Shared Package
ML19292H498	List: ML20235J455 ML20235J492
References
CAW-87-064, CAW-87-64, NUDOCS 8707150596
Download: ML20235J492 (9)

Text

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.- g1 ENCLOSURE 2 PowerSystems meesystenis sm oivise Westinghouse Electric Corporation 83 355-Pittsbutgh Pennsylvania 15230-0355 June 23, 1907 CAW-87-064 Dr. Thomas Murley, DLrector Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Comission Washington, D.C. 20555 APPLICATION FOR WITHHOLDING PROPRIETARY 70RMATION FROM PUBLIC DISCLOSURE I

Subject:

Transmittal of Errata Sheet for WCAP's 11178 Revision 1 (Proprietary) and 11179 Rev.1 (Non-Proprietary)

Dear Dr. Murley-The proprietary material for which withholding is being requested in the reference letter by Alabama Power Company is further 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 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 Comission's regulations.

The proprietary material for which withholding is being requested is of the same technical type as that proprietary material previously submitted as Affidavit AW-77-58.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Alabama Power Company.

Correspondence with respect to the proprietary aspects of the application for withholding or the ' Westinghouse affidavit should reference this letter, CAW-87-064 and should be addressed to the undersigned.

Very t uly yours,

@ eta.Whelmann, Manager i

/dar Rt atory &'1,egislative Affairs Enclosure (s)

E. C. Shomaker, Esq. -- '

cc:

Office of the General Council, NRC 8707150596 870710 l PDR ADDCK 05000348 P PDR

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PROPRIETARY INFORMATION NOTICE l TRANSMITTED HEREWITH ARE PROPRIETARY AND/OR NON-PROPRIETARY VERSI0tG OF DOCUMENTS {

FURNISHED TO THE NRC IN CONNECTION WITH REQUESTS FOR GENERIC AND/OR PLANT SPECIFIC REVIEW AND APPROVAL. )

l IN ORDER TO CONFORM TO THE REQUIREMENTS OF 10CFR2.790 0F THE COMMISSION'S REGULATIONS CONCERNING THE PROTECTION OF PROPRIETARY INFORMATION SO 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 RD4AIN, THE INFORMATION THAT WAS CONTAINED WITHIN THE BRACKETS IN THE PROPRIETARY VERSIONS HAVING BEEN DELETED. THE JUSTIFICATION FOR CLAIMING THE INFORMATION SO 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 LOWEP. CASE LETTERS REFER TO THE TYPES OF INFORMATION WESTINGHOUSE CUSTOMARILY HOLDS IN CONFIDENCE IDENTIFIED IN SECTIONS (4)(11)(a) THROUGH (4)(ii)(g) 0F THE AFFIDAVIT ACCOMPANYING THIS TRANSMITTAL PURSUANT TO 10CFR2.790(b)(1).

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AW-77-58 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally ' appeared Robert A. Wiesemann, 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:

.4bfM4 Robert A. Wiesemann, Manager Licensing Programs Sworn to and subscribed befo e me this day -

of 2,vle1977.

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,(1) I am Manager, Licensing Programs, in the Pressurized Water Reactor Systems Division, of Westinghouse Electric Corporation and as such, l

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 l 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 10 CFR Section 2.790 of the Commission'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 commercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.790 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the

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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. 1 (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 l

of information customarily held in confidence by it and, in

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' that connection, utilizes a system to determine when and l

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whether to hold certain-types of infonnation in confidence.

The application of that system and the substance of that q system constitutes Westinghouse policy and provides the .

rational basis required.

Under that system, information is held in confidence if it' i 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:

i (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 consti-tutes 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 optimization or improved marketability.

(c) Its use by a competitor would reduce his expenditure i

of resources or improve his competitive position in the l design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product.

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

budget levels, or commercial strategies of West.inghouse, l its customers or suppliers.

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,.'- , l (e) It reveals aspects of past, present, or future Westing-house or cus'tomer funded development plans and programs of potential commercial value to Westinghouse.

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

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

(iii) The information is being transmitted to the Commission in ]

confidence and, under the provisions of 10 CFR Section 2.790, it is to be received in confidence by the Commission.

(iv) The information is not available in public sources to the  :

best of our knowledge and belief. ,

(v) The proprietary information sought to be withheld in this

• 1 submittal is in the attachment to Westinghouse letter number NS-CE-1596, Eiche1dinger to Stuart, dated November 8,

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1977, concerning Westinghouse Steam Generator Programs.

The letter and attachment are being submitted in response to the request of the Commission and its October 25, 1977 memorandum, Stuart to Eisenhut concerning Westinghouse Steam Generator Programs.

Public disclosure of this information is likely to cause substantial harm to the competitive position of Westinghouse '

J as it would reveal the strategic. plans of Westinghouse regarding the nature .and direction of its development programs.

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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'21sclosure'.to protect the Westinghouse competitive position. . ,

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' I The (b) It is information which is; marketable.

. m.+ in many;~wys. m - u l extent to which such information is available to compet- {

itors diminishes the Westinghouse ability to sell products and services involving the. use of the information.

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(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 1 particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors  ;

acquire components of proprietary information, any one

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component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

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

Altogether, a substantial amount of money and effort has been and is being expended by Westinghouse in its development programs which could l

only be duplicated by a competitor if he were to invest similar sums of money and provided he had the appropriate talent available.

Further the deponent sayeth not.

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I 2.0 SLEEVING OBJECTIVES AND SLEEVING BOUNDARIES I

l 2.1 CBJECTIVES l

J. M. Farley Units 1 and 2 (ALA, APR) are Westinghouse-designed 3 1000 pressurized water reactors rated at 2660 MWt. The two units utilize a total of three vertical U-tube steam generators each. The steam generators are Westinghouse Model 51 Series containing heat transfer tubes with dimensions of j l .0.875 inch nominal 00 by 0.050 inch nominal wall thickness.

l The sleeving concept and design are based on observations to date that the tube degradation due to operating environmental attack has occurred near the  ;

l tubesheet areas of the tube bundle. The sleeve has been designed to span the degraded region in order to maintain these tubes in service. i i

The sleeving program has two primary objectives:  ;

1. To sleeve tubes in the region of known or potential tube degradation. '

2. To minimize the radiation exposure to all working personnel (ALARA) 2.2 SLEEVING BOUNDARIES i

Tubes to be sleeved will be selected by radial location, tooling access (due to channel head geometric constraints), and eddy current indication elevations 3 j

and size. An axial elevation tolerance of one inch wi!1 be employed to allow for any potential eddy current testing position indication inaccuracies and degradation growth. Tube location on the tubesheet face, sleeve length, tooling dimensions, and tooling access permitted by channelhead bowl geometry define the sleeving boundaries. Figure 2.2-1 shows an estimated radial sleeving bo,undary.for a ( JC sleeve as determined by a geometric radius computed from the channelhead surface-to-tubesheet primary face  !

clearance distance minus ths tooling clearance distance. (The actual "as i s l cowl geometry will be slightly different in certain areas.) This is the ,

sleeving boundary for a generic Westinghouse series 51 steam generator and ,

represents the maximum sleeving potential with a [ 3a .c.e 3),,yg, j y ;;u .,;: .

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3 Tubes within,the sleeving boundary that are degraded beyond the plugging limit but not within the axial restrictions of the ( Ja ,c.e sleeve or not j within the radial sleeving boundary will be. plugged. The actual sleevable i.

region may be modified based on tool length or other variables. .

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I The actual. tube plugging / sleeving map for each steam generator will be provided as part of the software deliverables at the conclusion of the i sleeving effort. 1 i

The specific tubes to be sleeved in each steam generator will be determined j based on the following parameters:

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1. No indications beyond an elevation spanned by the sleeve pressure boundary

.which are greater than the plugging limit, j

2. Concurrence on the eddy current analysis of the extent and location of the ]

degradation.

2.3 REPORT APPLICABILITY C

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35 D4/032487: 49 2-2 l

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