ML20116C820

Forwards Upper Plenum Injection LOCA Model Development & Affidavit for Withholding.Rept Withheld (Ref 10CFR2.790)

ML20116C820
Person / Time
Site:	Prairie Island
Issue date:	04/19/1985
From:	Musolf D NORTHERN STATES POWER CO.
To:	Office of Nuclear Reactor Regulation
Shared Package
ML19269B442	List: ML20116C820
References
TAC-57644, TAC-57645, NUDOCS 8504290172
Download: ML20116C820 (9)

Text

- e. _! ~

p Northem States Power Company 414 Ncollet Mall unneapoks nnnesda 05401 April 19,1985 " ' * "si23330 s e Director "

Office of Nuclear Reactor Regulation U S Nuclear Regulatory Commission Washington, DC 20555 PRAIRIE ISLAND NUCLEAR GENERATING PLANT Docket Nos. 50-282 License Nos. DPR-42 50-306 DPR-60 Upper Plenum Injection LOCA Model Development PROPRIETARY INFORMATION Attached is the PROPRIETARY Upper Plenum Injection LOCA Program Plan for Prairie Island. This plan contains information proprietary to Westinghouse Electric Company and we request that it be withheld from public disclosure.

This same plan was submitted to the NRC Staff in a letter dated March 11, 1985. However, the proprietary information in the plan was not identified in the March 11, 1985 submittal.

An affidavit of Robert Wiesemann is attached which states the basis for our request for exemption from public disclosure for this program plan. The l

i proprietary material in this program plan is identified by brackets. Each bracketed text is cross-referenced to section (4)(ii) of the affidavit.

Please call us if you have questions on this program plan.

l l 33  %

David Musolf Manager - Nuclear Su ort Services DMM/TMP/tp l c: Regional Administrator-III. NRC i

NRR Project Manager, NRC Resident Inspector, NRC G Charnoff E Shoemaker, NRC OELD @

P Attachments: Affidavit, UPI LOCA Program Plan

)1 0 ATTACHED PROGRAM PLAN CONTAINS 10 CFR 2.790 PROPRIETARY INFORMATION h

x _-- - -

• Northem States Power Company 414 Nicotiet Mall Minneapohs. Minnesota 55401 April 19,1985 Telemne ts121330-ssoo l

Director Office of Nuclear Reactor Regulation U S Nuclear Regulatory Commission Washington, DC 20555 l

PRAIRIE ISLAND NUCLEAR GENERATING PLANT Docket Nos. 50-282 License Nos. DPR-42 50-306 DPR-60 Upper Plenum Injection LOCA Model Development PROPRIETARY INFORMATION Attached is the PROPRIETARY Upper Plenum Injection LOCA Program Plan for Prairie Island. This plan contains information proprietary to Westinghouse Electric Company and we request that it be withheld from public disclosure.

This same plan was submitted to the NRC Staff in a letter dated March 11, 1985. However, the proprietary information in the plan was not identified in the March 11, 1985 submittal.

An affidavit of Robert Wiesemann is attached which states the basis for our request for exemption from public disclosure for this program plan. The proprietary material in this program plan is identified by brackets. Each bracketed text is cross-referenced to section (4)(ii) of the affidavit.

Please call us if you have questions on this program plan.

MNs David Musolf Manager - Nuclear Su ort Services DMM/TMP/tp c: Regional Administrator-III, NRC NRR Project Manager, NRC Resident Inspector, NRC G Charnoff @

E Shoemaker, NRC OELD D Attachments: Affidavit, UPI LOCA Program Plan ATTACilED PROGRAM PLAN CONTAINS 10 CFR 2.790 PROPRIETARY INFORMATION

3..:..@...,:.... ...y:.;n. u ,. , . ,,... . , ; ., .; .

. .. : .. . ..:. . ... ... ...,;, i.p O .;;.;u. v. ;. ... .) ',9;yp::wr> :.

- A!!-77-18 AFFI0AVIT COI'J:0;".-lEALTH OF PEin15YLVA!!IA: v. .

ss C0d!{TYOFALLEGHEllY: . . . .

Before me, the undersigned authority, personally appeared .

Robert A. Wiesemann, who, being by me duly sworn according to law, de- ,

poses and says that he is authorized to execute this Affidavit on behalf of West,inghouse Electric Corporation (" Westinghouse") and.that the aver-ments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief: ,

chi'-21 s a w w .

Robert A. ihese.mann, iianager Licensing Programs ,

1 l -

Sworn to and subscribed .

before me this / 0 day - -

,i 1

//f.'!d of 1977. .

/ -

-. ' /, n ,. -

~.,,

j

.d!//fU

> . ( :-((/O ,

s l [ llotary Public

.. ....s. . .;NE l

1 t

l. )

r-

? . 77, . . . , . . , , ...,,....... '

ih . ynn:;;l :.m S - > n;, . .

. .:....p n...:.na,:;:;G:m:.?,>p;Q;pl.;q:.g'c.'j:.p'.[,,f.;,::3.

,.y.5,;,::ip

• AW-77-18 (1) I am.1lanager, Licensing Programs, in the Pressurized Water Reactor

. Systems Division, of Westinghouse Electric Corporation and [s 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 P.eactor Divisions.

_ (2) I am making this Affidavit in conformance with the provisions of 10 CFR'Section 2.790 of the Corsaission's regulations and in con-

, junction with the kestinghouse application for withholding ac-companying this Affidavit. , ,

.(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse !!uclear Energy Systans in designating inforcation as a trade secret, privileged or as confidential commercial or financial infomation. ,

(4) Pursuant to the. provisions of paragraph (b)(4) of Section 2.790

~- of the Coraission's' regulations, the following is furnished for consideration by the Cc= mission in determining whether the in- ,

formation sought ,to be withheld from public disclosure should be '

I withheld. .

l l

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

e e

e S

b

, , 4

( t '

l 5'1 4: . .

. . . - . l. . . ,. . , . .. s s , , , 3 ., . . yp p,g;g m , u ,, . .

~3- N1-77-1 S

, (ii) The information is of a type customarily held in confihnce.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 -

in confidence. The ap-hold certain types of ir3 ormation f plication 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 di,stinguishing aspects of a ,

.- process (or component, structure, tool, method, etg.)

where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes

1. ~

.- a competitive economic advantage over other companies. ,

(b) It cons'ists of' supporting data, including test data, ,

l relative to a process (or component, structure, tool, method, etc.), the application of which data secures a ~ ~

e.'g.', by optimization or

, competitive economic advantage, improved marketability.

g I

e

.o i

o *

,4 .

o.

, ,%.'. , : tn:'. .... :, o.: ,...

':.'.. .: :':W

'.1 c.1 >$$' s-9//f '<! ... $' by:W,$.'.5;N I

, i,4(, '

AW-77-lG (c) Its use by a. competitor would reduce his expendiTube of resources 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 commercial strategies of .

Westinghouse, its customers or suppliers. -

It reveals aspects of past, present, or future West-(e)

.inghouse or customer funded development plans and pro '

grams of potential comnercial value to Westinghouse. -

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

(g) It is'not the property of Westinghouse, but must be . ,

treated as proprietary by Westinghouse according to agreeinents 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 disclosurc

- ~

to protect the Westinghouse competitive position.

J e

- g e

. 9

.o ..

, ,:,,,'.,,'. ,','; ,y:. , . y .y y, j; 9., .

.'. . .. . 0. ;,' > ;; :.:ll ,'.;

' , ;g, . ; "j-l.,,',} i,', ;.l.,.;f ;,* ', ',_ .

, ,s v ,;. ., . ,,.: ., , o AW-77-13

y. :. .

'(b) It is information yihich 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 competito: would put Hastinghouse at a

_.- . ' competitive disadvantage by reducing his expenditure

- of resources at our expense. -

. . , v,.~.

(d) Each component of proprietary information pertinent -

to a particular competitive advantage is potentially as valuable as the total' competitive advantage. If

.. ..m , ,

competitors acquire cocponents of, proprietary infor- -

mation, any one component may be the key to the entire .

~

puzzle, thereby depriving Westinghouse of a competit'ive

. advantage. .

t .

~

(e) Unres'tricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, ,

and the,reby 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.

g O .

l .. - ,

. g

C 1

.-. s .* ..t .

. . . . . . f. . .. . . . , , . s . . i u , , i . n.) 3 3 4j; r,. >.',.. 3 >> .

-G- ,

AW-77-18

,(iii) The infonnation is being transmitted to the Commissichtn -

confidence and, under the provisions of 10 CFR Section 2.790, l

.,- it is to be received in confidence by the Comission. l (iv) The infonnation is not available in public sources to the best of our knowledge and belief.

Th5 proprietary information sought to be withheld in this

, (v)

_ . submittal is that which is attached to Westinghouse Letter

- umber NS-CE-1403. Eiche1dinger to Stolz, dated April 6, 1977. The letter and attachment are being submitted in

' support of the Westinghouse emergency core cooling system -

evaluation model. , ,

~

Public disclosurc of the information sought to be withheld is likely to cause substantial harm to the competitive

~ '

. position of Westinghouse, taking into account the value of -

. 'the information to Westinghouse, the amount of effort and ,

money expended by Westinghouse in developing the inforr.ation, ,

and considering the ways in which the information could be -

. acquired or duplicated by others.

Further the deponent sayeth not. . .

S .

l

.e

~

s r PROPRIETARY INFORMATION NOTICE t

TRANSMITTED HSEWITH ARE PROPRIETARY AND/OR NON-PROPRIETARY VERSIONS OF D0QJMENTS FURNISHED TO THE NRC IN CONNECTION WITH REQUESTS FDR GENERIC AND PLANT SPECIFIC REVIEW AND APPROVAL.

IN ORDER 10 CONFORM TO THE RQUIREMENTS OF 10CFR2.790 0F THE COMMISSION'S REGULATIONS CONCERNING THE PROTECTION 7 PROPRIETARY INFORMATION SO SUBMITT TO THE NRC, THE INFORMATION WHICH IS PROPRIETARY IN THE PROPRIETARY VERSIONS IS CONTAINED WITHIN BRACKETS AND WHEE THE PROPRIETARY INFORMATION HAS BEEN DELETED IN THE NON-PROPRIETARY VERSIONS ONLY THE BRACKETS REMAIN, THE INFORMATION 1 HAT WAS CONTAINED WITHIN THE BRACKETS IN THE PROPRIETARY VERSIO HAVING BEDI DEI.ETED. THE JUSTIFICATION FOR 1 AIMING 1HE INFORMATION SO DESIGNATED AS PROPRIETARY IS INDICATED IN BOTH VDSIONS BY MEANS OF LOWS CASE LETTERS (a) THROUGH (g) CONTAINED WITHIN PAREN1HESES LOCATED AS A SUPERSCRIPT IMMEDIATEY FOLLOWING THE BRACKETS DQ.0 SING EACH ITEM OF INFORMATION BEING IDENTIFIED AS PROPRIETARY OR IN THE MARGIN OPPOSITE SUQi INFORMATION. THEEE LOWS CASE LEITERS REFER 10 'adE TYPES & INFORMATION WESTINGHOUSE CUS10MARILY HOLDS IN CONFIDENCE IDENTIFIED IN SECTIONS (4)(ii)(a) through (4)(ii)(g) 0F THE AFFIDAVIT ACCOMPANYING THIS TRANSMITTAL PURSUANT 1010CFR2.790(b)(1).

_ _ , _ _ _ _ . . . -, - - - -