ML11119A237
| ML11119A237 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/19/2011 |
| From: | Gresham J Westinghouse |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| LTR-NRC-11-19, WCAP-16260-P-A, Rev 1, AW-11-3142 | |
| Download: ML11119A237 (11) | |
Text
Westinghouse Electric Company
- Westinghouse Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (724) 720-0754 11555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852 LTR-NRC- 11-19 April 19, 2011
Subject:
SER Compliance with WCAP-16260-P-A, Revision 1, "The Spatially Corrected Inverse Count Rate (SCICR) Method for Subcritical Reactivity Measurement" (Proprietary/Non-Proprietary)
Enclosed are copies of the Proprietary/Non-Proprietary SER Compliance with WCAP-16260-P-A, Revision 1, "The Spatially Corrected Inverse Count Rate (SCICR) Method for Subcritical Reactivity Measurement."
Per SER Limitations and Conditions documented in the NRC's SER for WCAP-16260, Limitation and Condition # 2 specifies the following:
"2. Reactivity-sensitivity analyses must be conducted and submitted to the NRC staff for review/audit on a plant-specific basis to predetermine the masking effect (biases) so that they can be accounted for in SCICR applications to the plant."
The first application of this methodology for South Texas Unit 1 is planned for Cycle 17 and for South Texas Unit 2, Cycle 16. Enclosed are the reactivity-sensitivity analyses to determine the masking effect presented in the topical bound that of South Texas Units 1 and 2.
Also enclosed is:
- 1. One (1) copy of the Application for Withholding Proprietary Information from Public Disclosure, AW-1 1-3142 (Non-Proprietary), with Proprietary Information Notice and Copyright Notice.
- 2. One (1) copy of Affidavit (Non-Proprietary).
This submittal contains proprietary information of Westinghouse Electric Company LLC. In conformance with the requirements of 10 CFR Section 2.390, as amended, of the Commission's regulations, we are enclosing with this submittal an Application for Withholding Proprietary Information from Public Disclosure and an Affidavit. The affidavit sets forth the basis on which the information identified as proprietary may be withheld from public disclosure by the Commission.
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Page 2 of 2 LTR-NRC-1 1-19 Correspondence with respect to the application for withholding or the Westinghouse affidavit should reference AW-1 1-3142 and should be addressed to J. A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company LLC, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.
Very ly y J. A. Gresham, Manager Regulatory Compliance Enclosures cc: A. Mendiola, NRR A. Attard, NRR E. Lenning, NRR
Westinghouse Westinghouse Electric Company Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (724) 720-0754 11555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852 AW-1 1-3142 April 19, 2011 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
LTR-NRC-1 1-19 P-Enclosure, SER Compliance with WCAP-16260-P-A, Revision 1, "The Spatially Corrected Inverse Count Rate (SCICR) Method for Subcritical Reactivity Measurement" (Proprietary)
The Application for Withholding Proprietary Information from Public Disclosure is submitted by Westinghouse Electric Company LLC (Westinghouse), pursuant to the provisions of paragraph (b)(1) of Section 2.390 of the Commission's regulations. It contains commercial strategic information proprietary to Westinghouse and customarily held in confidence.
The proprietary material for which withholding is being requested is identified in the proprietary version of the subject report. In conformance with 10 CFR Section 2.390, Affidavit AW-1 1-3142 accompanies this Application for Withholding Proprietary Information from Public Disclosure, setting forth the basis on which the identified proprietary information may be withheld from public disclosure.
Accordingly, it is respectfully requested that the subject information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.
Correspondence with respect to this application for withholding or the accompanying affidavit should reference AW-1 1-3142 and should be addressed to J. A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company LLC, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.
Very truly yours, i.A Gresham, Manager Regulatory Compliance Enclosures
AW- 11-3142 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF BUTLER:
Before me, the undersigned authority, personally appeared J. A. Gresham, 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 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:
J. A. Gresham, Manager Regulatory Compliance Sworn. to and subscribed before me this 19th day of April 2011 Notary lPublic COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Renee Giampole, Notary Public Penn Township, Westmoreland County Ly Commission Expires September 25. 2013
2 AW-l 1-3142 (1) I am Manager, Regulatory Compliance, 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 Westinghouse.
(2) I 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 Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.
(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse 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 2.390 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 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
3 AW- 11-3142 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.
(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.
(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 by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.
4 AW- 11-3142 (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 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.
(iii) 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.
(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 LTR-NRC-1 1-19 P-Enclosure, "SER Compliance with WCAP-16260-P-A, Revision 1, 'The Spatially Corrected Inverse Count Rate (SCICR)
Method for Subcritical Reactivity Measurement' (Proprietary)," for submittal to the Commission, being transmitted by Westinghouse letter, LTR-NRC-I 1-19, and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is for NRC review/audit.
This information is part of that which will enable Westinghouse to:
(a) Demonstrate the applicability of the SCICR methodology for a specific plant.
5 AW- 11-3142 (b) Assist customers in implementing an improved measurement technique.
Fui'ther this information has substantial commercial value as follows:
(a) Westinghouse can use this methodology to further enhance their licensing position over their competitors.
(b) Assist customers to obtain license changes.
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 fuel design and 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 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 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.
PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.
In order to conform to the requirements of 10 CFR 2.390 of 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 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) 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 holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).
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 contained in these reports which are necessary for its internal use in connection with generic 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 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number 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 Washington, DC and in 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 proprietary.
Westinghouse Non-Proprietary Class 3 LTR-NRC-1 1-19 NP-Enclosure SER Compliance with WCAP-16260-P-A "The Spatially Corrected Inverse Count Rate (SCICR)
Method for Subcritical Reactivity Measurement" (Non-Proprietary)
Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, PA 16066
© 2011 Westinghouse Electric Company LLC All Rights Reserved.
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LTR-NRC-l 1-19 NP-Enclosure Reactivity-Sensitivity Analyses of SCICR Application at South Texas Units 1 and 2 The first application of the spatially corrected inverse count rate (SCICR) method for subcritical reactivity measurement is planned for initial application at Unit 1 of the South Texas plant. This method of reactivity measurement is described in the approved Westinghouse topical report (TR) WCAP-16260-P-A, Rev. 1. The final safety evaluation performed by the NRC staff (TAC No. MC3065) included the condition that reactivity-sensitivity analyses must be conducted and submitted to the NRC staff for review/audit on a plant-specific basis to predetermine any masking effect (biases) in the SCICR applications at each plant. For the purpose of this reactivity-sensitivity analysis, both South Texas units are considered "sister units," sharing common plant characteristics which would have an impact on this analysis. These common plant characteristics include ex-core detector design, general plant/reactor design affecting the detector response (or neutron transport from the core to the detector) during subcritical rod worth measurement, and RCCA bank design (absorber materials and bank definition).
The sensitivity calculations were performed in the same manner as described in Section 5.3 of WCAP- 16260-P-A, Rev. 1. The results of the core reactivity bias and control rod constant bias cases are presented below. These are equivalent to Tables 5-2 and 5-4 of WCAP-16260-P-A, Rev. 1.
South Texas Units 1 and 2 Quality of the SCICR Line Fit in the Simulated Cases With Core Reactivity and Control Rod Constants Biases (RMS = Root Mean Squared, pcm = 10-) a,c The reactivity-sensitivity results for South Texas Units 1 and 2 exhibit similar trends as those presented in WCAP-16260-P-A, Rev. 1 for the applicable plant/core type. Therefore, it is concluded that the sensitivity of the SCICR methodology to a core reactivity bias is very small or conservative and non-masking for South Texas Units 1 and 2. [ a~c 1
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