ML20199H381
| ML20199H381 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 10/10/1997 |
| From: | Sepp H WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | Collins S NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML17339A053 | List: |
| References | |
| CAW-97-1172, NUDOCS 9711260101 | |
| Download: ML20199H381 (10) | |
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P Westifigheuse EftergySystems we*,s e souse Electric Corporation m 333 Pinsbutgh PennsyNania 15730 0355 October 10,1997 C AW-97-l 172 Document Control Desk U.S. Nuclear Regulatory Comtalssion Washington, DC 20555
- Attention: hir. Samuel J. Collins v
APPLICATION FOR WITilHOLDING PROPRIETARY INFORA1ATION FROh! PUllLIC DISCLOSURE
Subject:
WCAP 14732, "Probabilistic Analysis of Reduction in Turtiine Valve Test Frequency for
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Nuclear Plants with Westinghouse 1111296 Turbines with Steam Chests " Revision 1 (Proprietary) r
Dear hlr. Collins:
f The proprietary information for which withhc! ding is being requested in the above-referenced report is further identified in Af0 davit CAW-97-Il72 signed by ;he owner of the proprietary information, Westinghouse Electric Corporation. The affidavit, which accompanies this letter, sets forth the basis i
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 10 CFR Section 2.790 of the Commission's regulations.
. Accordingly, this letter authorizes the utilization of the accompanying Af6 davit by Virginia Power Company.
Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidasit should reference this letter, CAW 97-il72, and should be addressed to,a/
undersigned.
Very truly yours, H. A. Sepp, hianager Regulatory and Licensing Engineering Enclosures E
cc: Kevin flohrer/NRC (12H5)
- The missson of NSU it to Prwide our customers uith gent e, equipment and sernces i
that eet the standards o(excellence in the nuclear industry?
9711260101.971118 PDR ADOCK 05000338-P POR e
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i CAW-97-1172 AFFIDAVIT COMMONWEALTH OF PENNSYLANIA:
ss COUNTY OF ALLEGHENY:
Before me, the undersigned authority, personally appeared Henry A. Sepp, 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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7 v-y Henry A. Sepp, Manager Regulatory and Licensing Engineering Sworn to and subseribed before r this _/8 day of M
,1997 i '
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Janet A febw:ib Attry Pa4:
Monroevitic Byn A.n gi,ny gggg9 u n My Commason Esp.o3 p,y ;' E000 g
Notary Public m,.m. _,
-2 CAW-971172 (1)
I am Manager, Regulatory and Licensing Engineering, 'n the Nuclear Services Division, of the Westinghoue Electric Corporation and as such, I have been specifically delegated the function of reviewing the proprietary infbrmation sought to be withheld from public disclosure in connection with nuclear power plant licensing and < % making proceedings, and am authorized to apply for its withholding on behalf of the Westn.. house Energy Systems Business Unit.
(2)
I am making this Affidavit in conformance with the provisions of 10CFR Section 2.790 of the Commission's regulations and in conjunction with the Westinghouse application for withholding accompanying this Affidavit.
(3)
I have personal knowledge of the criteria and pocedures utilized by the Westinghouse Energy Systems Business Unit 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 regu'.;t ons, the following is furnished for consideration by the Commission in determining i
whether the information sought to be withheld from public disclosure should be withheld.
(i)
The information soucht to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.
l (ii)
The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the publie. Westinghouse has a rational basis for determining the types of information customarily behl in confidence by it and, in that connection, utilizes a system to determine when and whether to hold ee.tain types of information m confidence. The application 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 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 m e.u n w n
_ - - _ - - _ -. CAW 971172 Westinghouse's competitors without_ license from Westinghouse constitutes a competitive ecanomic advantage over other companies, (b)
It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, ete ), 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 of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.
I (d)
It revea s cost or price information, production capacities, budget levels, or t
commercial strategies of Westinghouse, its customers or suppliers.
(e)
It reveals aspects of 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.
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, withheld from disclosure to protect the Westinghouse competitive position.
I (b)
It is information which is marketable in many ways. The extent to which such j
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 Westiaghouse at a competitive disadvantage by reducing his expenditure ef resources at our exper.se.
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4-CAW-97-1172 (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 v/orld market, and thereby give a market advantage to the competliion of those countries.
i (f)
The Westing.iouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage, i
l (iii)
The information is being transmitted to the Commission in confidence and, under the j
provisions of 10CFR Section 2.790, it is to be received in confidence by the Commission.
(iv)
The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method 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 "Probahilistie Analysis of Reduction in Turbine Valve Test Frequency for Nuclear Plants with Westinghouse BB 296 Turbines with Steam Chests," WCAP-14732 (Proprietary), Revision I, June,1997 for North Anna Power Station Units I and 2, being transmitted by Virginia Power Company letter and i
Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk, Attention Samuel J. Collins. The proprietary information as submitted for use by Virginia Power Company tbr North Anna Units 1 and 2 is expected to be applicable in other licensee submittals in response to certain NRC requirements for justification of reducing turbine valve test frequer.cy.
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5 CAW 971172 This information is part of that which will enable Westinghouse to:
(a)
Provide documentation of the analyses and methods used in t e establishment h
of annual turbine overspeed missile ejection frequencies which serve as the technical basis for a reduction of turbine valve test frequency required per the plant technical speci0 cations.
(b)
Assist the customer in obtaining NRC acceptance for the necessary changes to the plant technical specifications, Further this information has substantial commerer value as follows:
(a)
Westinghouse plans to sell the use of similar information to its customers for purposes of adJressing turbine valve test frequency reduction and related issues.
(b)
Westinghouse can sell support and defense of the application of this methodology and other proposed programs, Publie disclosure of this proprietary information is likely to cause substantial harm to
- he competitive position of Westinghouse beer.use it would enhance the ability of competitors to provide similar turbir.e valve test frequency analyses and licensing defense servlees for comme.eial power reactors without commensurate expenses.
Also, public disclon re of the information would enanle others to use the information to meet N?C requirements for licensing documentation without purchasing the right to c:e the information, 4
The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.
In order for competitors of Westinghouse to duplicate this information, similar technical p~ grams would have to be performed and a signi6eant manpower effort, having the requisite talent and experience, would have to be expended for the me.auomm
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CAW 971172 development of turbine overspeed missile ejection analysis and its application to reducing turbine valve test frequency, Further the deponent sayeth not, i
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Copyright Notice The reports transmitted herewith each bear a Westinghouse copyright notice, The NRC is permitted to make the number of copies of the ;information evntained in these reports which are necessary for its internal use in connection with gerieric and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.790 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstandirig. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the r: umber of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washir.gton, DC and m local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as preorietary.
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Proprietary Infortiation Notice Transmit'eJ herewith are proprietary and/or non proprietary versior.s of documents furnished to the NRC in connection with requests for generic and/or p' ant specific review and approval.
In order to conform to the requirements of 10 CFR 2.','90 of the Commission's regulations concerning the protection of proprietary information so submitted.to the NRC, the information whic!: 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 so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) 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 rioids in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the altidavit accompanying this transmittal pursu: int to 10 CI'R 2.790(b)(1).
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ATTACHMENT 2 L-t 4
VIRGINIA ELECTRIC AND POWER COMPANY PROPOSED TECHNICAL SPECIFICATIONS CHANGES NORTH ANNA UNITS 1 AND 2 4
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