ML060670205

Request for Additional Information Regarding Measurement Uncertainty Recapture Power Uprate

ML060670205
Person / Time
Site:	Calvert Cliffs
Issue date:	03/06/2006
From:	Spina J Calvert Cliffs, Constellation Energy Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MC6210, TAC MC6211
Download: ML060670205 (23)

Text

James A. Spina Vice President Calvert Cliffs Nuclear Power Plant, Inc.

1650 Calvert Cliffs Parkway Lusby, Maryland 20657 410.495.4455 410.495.3500 Fax Constellation Energy Generation Group March 6, 2006 U. S. Nuclear Regulatcry Commission Washington, DC 20555 ATTENTION:

SUBJECT:

Document Control Desk Calvert Cliffs Nuclear Power Plant Unit Nos. I & 2; Docket Nos. 50-317 & 50-318 Request for Additional Information Regarding Measurement Uncertainty Recapture Power Uprate (TAC Nos. MC6210 and MC62 11)

REFERENCES:

(a)

Letter from P. D. Milano (NRC) to J. A. Spina (CCNPP), dated January 19,

2006, Request for Additional Information Regarding Measurement Uncertainty Recapture Power Uprate (TAC Nos. MC6210 and MC621 1)

(b)

Letter from K. J. Nietmann (CCNPP) to Document Control Desk (NRC),

dated January 31, 2005, License Amendment Request:

Appendix K Measurement Uncertainty Recapture - Power Uprate Request The Nuclear Regulatory Commission (NRC) has requested (Reference a) additional information regarding our measurement uncertainty recapture license amendment request (Reference b).

The information requested is contained in the attached response. Some of the information contained in the attached responses is proprietary. Accordingly, it is requested that the proprietary information contained in Attachment (I) be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390 and that this material be appropriately controlled. The reasons for the classification of this material as proprietary are delineated in the affidavit provided in Attachment (2). The non-proprietary version of the response is provided in Attachment (3).

Af~1

Document Control Desk March 6, 2006 Page 2 Should you have questions regarding this matter, please contact Mr. L. S. Larragoite at (410) 4954922.

Very truly yours, STATE OF MARYLAND COUNTY OF CALVERT

TO WIT:

1, James A. Spina, being duly sworn, state that I am Vice President - Calvert Cliffs Nuclear Power Plant, Inc. (CCNPP), and that I am duly authorized to execute and file this License Amendment Request on behalf of CCNPP. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon informatio:l provided by other CCNPP employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to be reliable.

Subscribed and sworn before me, a Notary Public in and for the State of Maryland and County of 5f athis L dayof

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,2006.

WITNESS -my Hand and Notarial Seal:

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My Commission Expires:

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Notary Pubie Date' JAS/PSF/bjd

Attachment:

(1)

Proprietary -- Request for Additional Information Regarding Measurement Uncertainty Recapture Power Uprate (2)

Westinghouse Proprietary Affidavit (3)

Non-Proprietary -- Request for Additional Information Regarding Measurement Uncertainty Recapture Power Uprate cc:

P. D. Milano, NRC S. J. Collins, NRC Resident Inspector, NRC R. 1. McLean, DNR

ATTACHMENT (3)

NON-PROPRIETARY -

REQUEST FOR ADDITIONAL INFORMATION REGARDING MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE Calvert Cliffs Nuclear Power Plant, Inc.

March 6, 2006

ATTACHMENT (3)

NON-PROPRIETARY - REQUEST FOR ADDITIONAL INFORMATION REGARDING MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE NRC RAT Question 1 In Licensee Event Report 2005-003-01, dated December 15, 2005, the licensee described its actions to determine the root cause of non-conservative flow correction factors determined during chemical tracer testing for main feedwaterflow.

Provide a summary description of the followvup tracer testing and the computational fluid dynamics (CFD) analyses that have been accomplished and the findings of each analysis and test. In the case of the followup testing, provide the unrecalibrated 4AM G-indicated flow rates for each of the installed instruments (Crossflow and/or X-Beam), the flow rates determined using tracer testing, and flowv rates from the venturis obtained duringfollowup testing.

CCNPP Response Calvert Cliff Units I and 2 are two loop Combustion Engineering (CE) Pressurized Water Reactor (PWR)

Nuclear Steam Supply System (NSSS) design plants.

Unit 1's feedwater loops are designated as Loops 11 and 12, while Unit 2's loops are designated as Loops 21 and 22. Each of the loops includes a control valve, a run of pipe with several elbows and a Mitsubishi style flow straightener. CROSSFLOW meters were mounted on each of the loops approximately 11 pipe diameters downstream of the flow straighteners, but upstream of the venturi. On Loop 12, a second meter was mounted upstream of the flow straightener. At the time, this meter was believed to meet the requirements of the CROSSFLOW topical report (i.e., CENPD-397-P-A, Rev. I) for a standard installation, where the flow was assumed to be stable and fully developed; because the meter was mounted more than 15 pipe diameters downstream of a standard 900 elbow. The plan was to use the Loop 12 upstream meter to calibrate the meter downstream of the flow straightener on Loop 12. It was then demonstrated through cold laboratory tests that the Loop 12 downstream meter calibration could be also used for the remaining three meters on Loops II, 21 and 22.

As part of the commissioning process for a measurement uncertainty recapture (MUR) power uprate, it was decided to confirm the performance of the CROSSFLOW meters using a non-radioactive chemical tracer test. This test was not performed to calibrate the CROSSFLOW meters. Rather, the objective of this test was to compare the ratio of the tracer flow to the venturi flow, measured over approximately 200 seconds, to the ratio of the CROSSFLOW meter flow to venturi flow, measured over at approximately 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. Approximately 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of data are required to ensure that the measurement of flow using the CROSSFLOW meters satisfies the requirements of the uncertainty calculations. Since the duration of the tracer is only 200 seconds, the results of the tracer cannot be compared directly to CROSSFLOW results. However, assuming that the venturi and CROSSFLOW performance do not vary significantly at constant power, the ratio of the tracer flow to the venturi flow should be similar to the ratio of the CROSSFLOW measured flow to venturi flow.

Five hours of CROSSFLOW data was not available for the Loop 12 meter located downstream of the flow straightener, because it was not being used for power recovery, and was not going to be used for the proposed Appendix K uprate. Five hours of data are also not available for the CROSSFLOW X-Beam meters which were temporarily installed to investigate power dependency of the meters downstream of the flow straighteners.

Table I compares the tracer measurements (taken at the 100% power level) with the corresponding venturi readings. The venturi flow is the uncorrected flow (not corrected by the CROSSFLOW meter).

-I-

ATTACHMENT (3)

NON-PROPRIETARY - REQUEST FOR ADDITIONAL INFORMATION REGARDING MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE Table 1 Comparison of Tracer with Venturis Loop Tracer Venturi Difference (klbm/hr)

(klbm/hr)

(%)

11 5998.9 6011.7

-0.213 12 5964.3 5990.5

-0.439 21 6060.2 6038.3 0.361 22 5991.1 5977.0 0.235 It can be seen from this data that all the tracer measurements compare favorably with the venturi readings.

It should also be noted that the tracer tests for Loops 11 and 12 are lower than the venturis. This is consistent with plant operating experience that had indicated that the Unit I venturis were fouled, resulting in an approximately 0.6% loss in generation. If the effects of fouling were removed from the Unit I data, the relative difference between tracer flow and venturi flow would have been similar for both units (tracer flow approximately 0.3% greater than venturi flow).

Table 2 is a summary of CROSSFLOW data, averaged over approximately 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, obtained prior to and following the tracer test. As requested, the venturi flow data has not been corrected by the CROSSFLOW meter. Also, the calibration factor determined from the relationship between the Loop 12 upstream meter and Loop 12 downstream meter has been removed from the Loop 11, 21, and 22 CROSSFLOW data to supply unrecalibrated flow rates.

Only the meters that were continuously run to monitor venturi performance are included in the table. Data obtained from the X-Beam and Loop 12 downstream meters were limited to approximately one hour before and after the tracer test. Since 5 or more hours of data are required to obtain a satisfactory CROSSFLOW reading that is within the statistical uncertainty of the quality assured calculation, data for these meters has not been included.

Table 2 Pre-Test and Post-Test 5 Hour CROSSFLOW Data Pre-test Pre-test Pre-test Post-test Post-test Post-test Loop Venturi CROSSFLOW/

CROSSFLOW/

Venturi CROSSFLOW/

CROSSFLOW/

(klbm/hr)

(klbm/hr)

Venturi Ratio (klbm/hr)

(klbm/hr)

Venturi Ratio 11 6000.2 6025.9 1.0043 5993.9 6016.2 1.0037 12*

5959.8 5822.2 0.9769 5951.5 5816.4 0.9773 21 6050.3 6043.3 0.9988 6049.6 6040 0.9984 22 5976.4 5995.1 1.0031 5974.8 5999.1 1.0041

• Upstream Meter As shown in Table 2, the pre-test and post-test ratios of CROSSFLOW to Venturi flow are similar, consistent with the assumptions for CROSSFLOW performance.

Table 3 is a comparison of the ratio of tracer to the venturi flow (from Table 1) to the ratio of CROSSFLOW to venturi flow (from Table 2). The average of the pre and post test data from Table 2 is presented in Table 3.

ATTACHMENT (3)

NON-PROPRIETARY - REQUEST FOR ADDITIONAL INFORMATION REGARDING MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE Table 3 Comparison of Tracer to CROSSFLOW CROSSFLOW/

Tracer/

Difference Loop Venturi Ratio Venturi Ratio

(%)

11 1.0040 0.9979 0.61%

12 0.9771

• 0.9956

-1.89%

21 0.9986 1

1.0036

-0.50%

22 1.0036 1.0024 0.12%

• Ulpstream Meter As shown in Table 3, the Loop 12 upstream meter, used to calibrate the Loop 12 meter downstream of the flow straightener, has the largest difference from the tracer results. Therefore, the assumption that the flow at that location was both stable and developed was incorrect. Also, the wide variation in the results indicates that the Loop 12 calibration could not be used for the remaining three loops, contrary to the results from the cold laboratory testing.

For information only, the CROSSFLOW data obtained during the tracer test for all meter locations is presented in Table 4. The data is averaged over only approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and does not meet the criteria established in the uncertainty calculations. Therefore, this information cannot be used to make any meaningful conclusions regarding CROSSFLOW performance. Furthermore, the X-Beams are located downstream of a machined taper in the feedwater pipe. Hence, it would not be expected that the standard (I-beam) meters and X-Beam meters would read the same.

Table 4 Summary of Data for All CROSSFLOW Meters Venturi I-beam X-Beam X-Beam Loop (klbm/hr)

(klbm/hr)

(klbmPhr)

(klabmhr) 11 5996.7 6044.4 6084.6 6078.5 12 5962.1 5949.2 5994.7 5979.2 12 Upstream 5962.1 5841.3 21 6054.9 6051.2 22 5979.8 6014.7 Based on the tracer test results, it was decided to perform a Computational Fluid Dynamics (CFD) analysis of the piping upstream of the Mitsubishi flow straightener on Loop 12 in order to get a qualitative picture of what was happening to the flow field in the piping system. It was decided to model the piping up to the main feedwater control valve and to simulate the control valve by using an 8 inch pipe to represent the jetting action of the feedwater exiting the cage of the valve into the approximately 14 inch (inner diameter) feedwater pipe. For control purposes, a second model was also developed with the same piping configuration, but without the 8 inch control valve pipe simulation.

Figures I and 2 show the two CFD piping configurations with and without the 8 inch pipe. Figures 3 and 4 show the differences in swirl that are generated in the pipe due to the jetting action of the control valve and Figures 5 and 6 show the velocity profiles at the location in the feedwater pipe where the CROSSFLOW meter is located.

ATTACHMENT (3)

NON-PROPRIETARY - REQUEST FOR ADDITIONAL INFORMATION REGARDING MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE Figure 1: Loop 12 Piping Layout Upstream of the Mitsubishi Flow Straightener with the Main Feedwater Control Valve Simulated Figure 2: Loop 12 Piping Layout Upstream of the Mitsubishi Flow Straightener without the Main Feedwater Control Valve Simulated 00/

ATTACHMENT (3)

NON-PROPRIETARY - REQUEST FOR ADDITIONAL INFORMATION REGARDING MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE Velocity (Streamline 1)

I 1.873e+01

-1.421e+01I

( I X4$

yjX

- 9.679e+00

- 5.151e+00 16 241e-01

[rm 5-11 l

Figure 3: Loop 12 Swirl with the Main Feedwater Control Valve Simulated ClIX' z

Figure 4: Loop 12 Swirl without the Main Feedwater Control Valve Simulated COZi

ATTACHMENT (3)

NON-PROPRIETARY - REQUEST FOR ADDITIONAL INFORMATION REGARDING MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE Axial Velocity Profil, at CROSSFLOW meter Location e'

I1 400

- Line 0 Degree

- Line 45 Degree

- Line 90 Degree

- Line 135 Degree Figure 5: Loop 12 Velocity Profile at the Location of the CROSSFLOW meter with the Main Feedwater Control Valve Simulated Axial Velocity Profile at CROSSFLOW motor Location 7 - -

4 - - -----------------

0 50 100 150 o200 50 300 350 400 Chart Count Line 0 Degree

- Line 45 Degree - Line 90 Degree Line 135 Degree Figure 6: Loop 12 Velocity Profile at the Location of the CROSSFLOW meter without the Main Feedwater Control Valve Simulated Figure 3 shows that a very strong swirling action is created when the jetting action of the main feedwater control valve is included in the simulation, while Figure 4 shows that swirling action is essentially eliminated if the simulated valve is not present. Figure 4 is the type of response that would have been expected in the pipe due to the fact that the two out-of-plane elbows are almost 10 pipe diameters apart. (-.OTY

ATTACHMENT (3)

NON-PROPRIETARY - REQUEST FOR ADDITIONAL INFORMATION REGARDING MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE Under these conditions, the velocity profile has a chance to reestablish itself prior to entering the second elbow, hence the effects of swirl was expected to have been mitigated. However, the CFD analysis shows that when the jetting action of the control valve is included, the flow profile cannot recover within the 10 pipe diameters, so Ihe interaction with the second elbow causes a strong swirling action that had not been anticipated.

Figures 5 and 6 show the velocity profile at different orientations about the pipe where the CROSSFLOW meter is located, with 0 representing the vertical plane and 90 the horizontal plane. Since the meter is mounted in the plane of the upstream elbow, it sees the velocity profile in the horizontal plane, which is shown as green.

It is clear from Figures 5 and 6 that the velocity profiles are significantly different when the effects of the control valve are included in the simulation. The profile moves from the traditional parabolic shape to a concave shape. The swirl then causes the eddies nearer the wall that pass through the upstream ultrasonic beam to be rotated out of the downstream ultrasonic beam so that the meter tends to track the eddies in the central part of the profile, where the fluid is moving slower. This in turn causes the meter readings to be biased low, which is consistent with the conclusion of the tracer test.

NRC RAT Question 2 Provide a description of the tracer testing procedures to be used to support in-situ calibration of the Crossflow System. Include a discussion of (a) how the tracer testing is traceable to National standards, (b) the controls in place to assure the procedures are properly conducted, (c) the accuracy of the tracer testing, and (d) how the uncertainties associated with the tracer testing are factored into the overall uncertainty of the Crossflowv system accuracy.

CCNPP Response Although there are multiple parts to this question, the best way to address them is to incorporate the response into a general presentation on the subject of tracer testing, starting with the theory and test equipment followed by the steps in the test procedure and then the chemical analysis and finally the incorporation of the results of the tracer test into the CROSSFLOW system accuracy.

The tracer test measures the flow in a pipe based on the principle of conservation of mass, which states that the concentration of the tracer times its rate of injection must be equal to the concentration in the feedwater line times the feedwater flow rate. The only term in this equation that is not known is the feedwater flow rate. In practice, the conservation of mass equation is usually rearranged so that the feedwater flow rate is set equal to the injection rate of the tracer times the dilution ratio, where the dilution ratio is defined as the ratio of the concentration of the tracer being injected into the pipe divided by the concentration of the feedwater samples.

The concept of measuring the feedwater flow with a tracer is rather simple, however in order to achieve an accurate measurement, the injection, mixing and chemical analyses must be performed in a very precise and controlled manner. When performed properly, flow measurements with accuracies between 0.2% and 0.4% with a 95% confidence interval can be achieved. However, the actual accuracy of each feedwater flow measurement is determined based on the specific uncertainty of the injection rate and the chemical analysis. For example, the uncertainty of the test can be increased if the feedwater flow is not stable during the test, since the oscillations in the flow will cause the concentrations of the feedwater sample to increase and decrease, which results in a higher standard deviation.

ATTACHMENT (3)

NON-PROPRIETARY - REQUEST FOR ADDITIONAL INFORMATION REGARDING MEASUREMENT UNCERTAINTY RECAPTURE POWER UJPRATE When performing a chemical tracer measurement, injection and sampling points must first be selected that prevent the loss of tracer, while assuring complete mixing. The loss of tracer is minimized by avoiding flow branches prior to achieving complete mixing, plus large surface area such as feedwater heaters, where the larg. surface increases the chance of the tracer plating out on the surface. It should be noted that if tracer is lost, the flow measurement is biased high, so from an overpower perspective the lost of tracer is conservative. Complete mixing can be assured when the injection and sample points are at least 250 pipe diameters apart. This criteria is based on testing performed in England, see Reference 1.

For the Calvert Cliffs iracer test both of these requirements are met. The tracer is injected just upstream of the main feedwater control valves and samples are pulled downstream. There is only one branch line; the feedwater control valve bypass line which reenters the main feedwater line several pipe diameters downstream of the main control valve. Normally, this could result in a slight loss of tracer, biasing the results conservatively high. However, because of the relatively large pressure drop across the control valve, the equivalent mixing distance in just passing through the valve is over 2000 pipe diameters.

Hence, a significant amount of mixing has already occurred upstream of the bypass line, minimizing the error. Given that the mixing created by the valve and even further mixing by the Mitsubishi style flow straighteners, the mixing requirements are easily met. Moreover, the injection and sampling points are all downstream of the last high pressure feedwater heater, so surface areas are not a concern.

During the actual tracer test, injection and sample carts are connected to the feedwater system.

Once the injection and sample carts are connected to the feedwater system, the metering pump is calibrated using a balance that has been calibrated on-site with weights that are traceable to the National Institute of Standard and Technology (NIST).

ATTACHMENT (3)

NON-PROPRIETARY - REQUEST FOR ADDITIONAL INFORMATION REGARDING MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE After the transfer from the drain to the feedwater system has been completed, an inspection of all connections between the discharge of the pump and the connection to the feedwater system are checked for leaks.

Once it is confirmed that there are no leaks, Operations is alerted that the tracer injection will begin.

The analysis is performed by laboratory personnel, who have been trained specifically for this type of analysis. Their skills include the preparation of the standards, the operation of the Atomic Absorption instrument plus the entry of the data into a spreadsheet and the quality control of all aspects of the job.

When the samples arrive at the laboratory, the background and sample bottles are unpacked. Since each background and sample bottle has a unique ID number that is recorded at the time of each test, there is no question about which set of samples goes with which loop.

ATTACHMENT (3)

NON-PROPRIETARY - REQUEST FOR ADDITIONAL INFORMATION REGARDING MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE ATTACHMENT (3)

NON-PROPRIETARY - REQUEST FOR ADDITIONAL INFORMATION REGARDING MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE As noted earlier, the uncertainty of the tracer test is dependent on the stability of the feedwater during the tests, the stability of the Atomic Absorption equipment and the repeatability of the pump at the time of the test.

Hence, it is not possible to state a specific number, however, based on past experience the uncertainty is normally in the range of 0.2 to 0.4%.

References

1.

C.G. Clayton, A.M. Ball, and R. Spackman, "Dispersion and Mixing During Turbulent Flow of Water in a Circular Pipe," Isotope Research Division, Wantage Research Laboratory, Wantage, Birkshire, 1968 NRC RAT Question 3 Provide a description of any periodic testing to be performed that will verify that the CROSSFLOW systems remains calibrated over the range of operating conditions and changes in flow that may occur over time due to degradation of, modification to, and/or operational changes in the main feedwtater system.

CCNPP Response As with any plant system, there are many levels of checks and cross-checks built into the CROSSFLOW system and its operation that assures its safe operation.

There are two key issues that must be addressed:

1) Has the meter been calibrated correctly?

2) How do you know that the calibration has not been compromised during operation?

ATTACHMENT (3)

NON-PROPRIETARY - REQUEST FOR ADDITIONAL INFORMATION REGARDING MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE The meter can be calibrated and then verified by a comparison with another diverse method of flow measurement.

In the case of Calvert Cliffs a chemical tracer test is being used to calibrate the CROSSFLOW meter.

Once each meter has been calibrated correctly using the chemical tracer and its uncertainty has been established, it is an absolute requirement that the uncertainty of the meter remain within the operating limits established by the quality assured uncertainty calculation.

Experience at Calvert Cliffs has demonstrated that the meters downstream of the Mitsubishi style flow straighteners are repeatable, as shown in Tables 5 and 6. Table 5 shows the Loop 11 data for the meter located downstream of the Mitsubishi flow. Data is not available for the Loop 12 meter downstream of the straightener since it was not used for venturi correction prior to performance of the initial tracer test. The Table 6 data covers a span of time from when the meter was first placed in operation to the time when it was taken out of service, a period of over 2 years. The Table 5 data includes the time period from when the meters were first placed in service to point in time when the feedwater venturi was first observed to foul in April of 2005, a period of one year 9 months. Fouling was corroborated by a corresponding drop in 15' stage pressure and reduction in the difference between reactor coolant system hot and cold leg temperatures.

It is clear from this dal:a, that although the meters are all located in regions where the flow is not stable, they are capable of maintaining a precise calibration.

Table S Stability of Vent iri Correction Factor Over Time Table 6 Stability of Venturi Correction Factor Over Time DATE Venturi Correcton Factor Loop II 7/2l/03 1.0022 7/31/03 1.0027 9,3/03 1.0017 10/6/03 1.0019 11/5/03 1.0020 12/8/03 1.0017 1/12/04 1.0028 2/17/04 1.0035 3/18/04 1.0032 5/14/04 1.0041 6/16/04 1.0035 7/18/04 1.0044 8/8/04 1.0046 8/29/04 1.0028 10/4/04 1.0024 11/5/04 1.0018 12/7/04 1.0033 1/10/05 1.0025 2/10/05 1.0020 3/15/05 1.0037 4/705 1.0027 Average Correction Factr 1.0028 Relative Standard Deviation (%)

0.0886 DATE Venturi Correcton Factor Loop 21 Loop 22 7/8/03 0.9904 0.9938 7/16/03 0.9902 0.9931 8/20/03 0.9902 0.9942 9/23/03 0.9907 0.9941 10/27/03 0.9915 0.9944 11/25/03 0.9901 0.9940 12/31/03 0.9903 0.9939 1/31/04 0.9893 0.9931 3/3/04 0.9901 0.9935 4/5/04 0.9895 0.9929 5/704 0.9897 0.9928 6/8/04 0.9898 0.9924 7/12/04 0.9907 0.9935 8/9/04 0.9904 0.9935 9/8/04 0.9902 0.9933 9/28/04 0.9906 0.9948 11/1/04 0.9910 0.9942 12/1/04 0.9909 0.9940 1/3/05 0.9900 0.9937 2/2105 0.9908 0.9939 3/18/05 0.9889 0.9943 4,18/05 0.9889 0.9930 5/19/05 0.9899 0.9935 6/20/05 0.9894 0.9945 7/22/05 0.9898 0.9948 8/24/05 0.9902 0.9949 Average Correction Factor 0.9901 0.9938 Relative Standard Deviation (%)

0.0642 0.0658 The system provides several critical alarms to identify potential problems with the CROSSFLOW system.

These are summarized in Table 4-1 of WCAP-16437-P, "CROSSFLOW Ultrasonic Flow Meter User Guidelines" prepared by the Westinghouse Owners Group (WOG) CROSSFLOW Task Force (CTF).

ATTACHMENT (3)

NON-PROPRIETARY - REQUEST FOR ADDITIONAL INFORMATION REGARDING MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE These alarms assure that the CROSSFLOW system will continue to operate within the limits established by the quality assured calculation. Table 7 is a summary of key alarms presented in the guidelines.

Table 7 - UFM Critical Alarms Alarm Name Comment Flow is less than limit. CROSSFLOW could not reliably FlowLessThanLimit measure flow if it is less than limit. The correction factors while the flow is less than limit, would be marked as BAD.

CfLongE~ufferLow Number of points with good quality in the Long Buffer is Cf~onE~uffr~owlow.

CfShortElufferLow Number of points with good quality in the Short Buffer is

________________________low.

Uncertainty for the Long Buffer is not met. The CfLongUiicertainty uncertainty limit is based on QA calc.

CfShortUncertainty Uncertainty for the Short Buffer is not met.

C, is out of range limits. If C, is below the lower range CfOutOffLimit limit it could lead to non-conservative reactor power calculations if the condition was caused by a fault.

Sudden change in C, (e.g. sudden defouling). Addition CfSuddenChange of reactivity, i.e., boron dilution, could lead to over power conditions.

SCUNeedsCalibration SCU needs calibration. SCU self-test has failed.

CfShort Buffer contains less than CfPercentGoodFw of CfShortEufferLow Good Quality Cfi.

This is typical under steady state conditions. If the cause of this alarm persists, it could eventually lead to a bad Ct.

ATTACHMENT (3)

NON-PROPRIETARY - REQUEST FOR ADDITIONAL INFORMATION REGARDING MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE ATTACHMENT (2)

WESTINGHOUSE PROPRIETARY AFFIDAVIT Calvert Cliffs Nuclear Power Plant, Inc.

March 6, 2006

e Westinghouse Westinghouse Electric Company Nuclear Services P. 0. Box 355 Pittsburgh, Pennsylvania 15230-0355 USA U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Direct tel: 412-374-4643 Directfax: 412-374-4211 e-mail: greshaja@vestinghouse.com Our ref: CAW-06-2111 March 2, 2006 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Reference:

CCNPI :Letter, "Request for Additional Information Re: Measurement Uncertainty Recapture Power Uprate", dated March 3, 2006 The proprietary info;rmation for wvhich withholding is being requested is contained in the above referenced Calvert Cliffs Nuclear Power Plant, Inc. (CCNPPI) letter in proprietary Attachment (1), "Proprietary Response to Request for Additional Information on the Measurement Uncertainty Recapture Power Uprate", as identified in Affidavit CAW-06-2 III signed by the owner of the proprietary information, Westinghouse Electric Company LLC (Westinghouse). 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 10 CFR Section 2.390 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Calvert Cliffs Nuclear Power Plant, Inc.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-06-21 11, and should be addressed to J. A. Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.

Very truly yours, Manager Regulatory Compliance and Plant Licensing

Enclosure:

As stated A BNFL Group Company

CAW-06-21 1 1 Page I AFFIDAVIT STATE OF CONNECTICUT

)

) ss: WINDSOR, CT COUNTY OF HARTFORD

)

Before me, the undersigned authority, personally appeared Ian C. Rickard, who, being by me duly sworn according to law, deposes and says that lie is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC ("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:

Ian Licensing Project Manager Systems and Safety Analysis, Nuclear Services Westinghouse Electric Company, LLC Sworn to and subscribed before me this 2nd day of March 201)6.

My commission expires S-3/JOY

CAW-06-21 11 Page2 (1) 1, lan C. Rickarci, depose and say that I am the Licensing Project Manager, Systems and Safety Analysis, in Nuclear Services, Westinghouse Electric Company LLC ("Westinghouse"), 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 rule making proceedings, and am authorized to apply for its withholding on behalf of the Westinghouse Electric Company LLC.

(2) 1 am making this; Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse application for wvithholding accompanying this Affidavit.

(3) 1 have personal knowledge of the criteria and procedures utilized by the Westinghouse Electric Company LLC 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 10 CFR Section 2.390 of the Commission's regulations, the Following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i)

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

(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 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 application of that system and the substance of that system constitute Westinghouse policy and provide 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, strucl ure, tool, method, etc.) wvihere 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, 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 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 capacities, budget levels, or 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.

CAW-06-2 1 1 1 Page 3 CAW-06-21 11 Page 3 (f)

It contains patentable ideas, for which patent protection may be desirable.

(iii) There are sound policy reasons behind the Westinghouse system for classification of proprietary information, 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.

(b)

It is information that 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 of this information by our competitors would put Westinghouse at a competitive disadvantage by reducing their expenditure of resources at our expense.

(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 of this information would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of 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.

(iv) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390; it is to be received in confidence by the Commission.

(v) 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.

(vi) The proprietary information sought to be withheld by this submittal is that which is contained in proprietary Attachment (I), "Proprietary Response to Request for Additional Information on the Measurement Uncertainty Recapture Power Uprate", transmitted by Calvert Clilffs Nuclear Power Plant, Inc. letter, " Request for Additional Information Re:

Measurement Uncertainty Recapture Power Uprate ", dated March 3, 2006, for submittal tc the Commission, being transmitted herewith and Application for Withholding Proprietary Information from Public Disclosure, to the NRC Document Control Desk. The proprietary information as submitted for use by Westinghouse is expected to be applicable in other licensee submittals in response to certain NRC requirements forjustification of the application of the CROSSFLOW Ultrasonic Flow Measurement System performance within its approved accuracy limit.

This information is part of that which will enable Westinghouse to:

(a) Validate CROSSFLOW Ultrasonic Flow Measurement System performance.

CAW-06-2 1 1 1 Page 4 CAW-06-21 11 Page 4 (b) Support licensees in implementing the CROSSFLOW Ultrasonic Flow Measurement System within its approved accuracy limit.

Further this information has substantial commercial value as follows:

(a)

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

(b)

Westinghouse can sell support and defense of the CROSSFLOW Ultrasonic Flow Measurement System performance within its approved accuracy limit.

(c)

The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar advanced nuclear power plant designs and to provide licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The developmert 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 programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.

Further the deponent sayeth not.