ML14055A045

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Response to Request for Additional Information Re License Amendment Request on Revising Section 3.6.5 of the Technical Specifications, Containment Air Temperature.
ML14055A045
Person / Time
Site: Ginna Constellation icon.png
Issue date: 01/22/2014
From: Joseph Pacher
Constellation Energy Nuclear Group, EDF Group, Ginna
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML14055A052 List:
References
LTR-LIS-13-492, Rev 1
Download: ML14055A045 (16)


Text

.0 ob PROPRIETARY INFORMATION - WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 Joseph E. Pacher Office: 585-771-5200 Site Vice President Fax: 585-771-3943 Email: Joseph.Pacher@cenglIc.com CENG.

a joint venture of 0f Const*ell*on eDF January 22, 2014 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION: Document Control Desk

SUBJECT:

R.E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR- 18 Docket No. 50-244 Response to Request for Additional Information regarding License Amendment Request on Revising Section 3.6.5 of the Technical Specifications, "Containment Air Temperature"

REFERENCES:

(a) Letter from J.E. Pacher (REG) to NRC Document Control Desk, 'License Amendment Request, Revise Section 3.6.5 of the Technical Specifications, "Containment Air Temperature,"' dated February 28, 2013 (ML13067A328)

(b) E-mail from M.C. Thadani (NRC) to T. Harding, Jr. (REG), "Ginna LAR for Containment Air Temperature RAI (TAC MF0900)," dated December 11, 2013 (ML13345A953)

By Reference (a), R.E. Ginna Nuclear Power Plant (REG) submitted a License Amendment Request to revise Section 3.6.5 of the Technical Specifications, "Contaimnent Air Temperature," to increase the allowable contaimnent average air temperature from 120°F to 125°F.

By Reference (b), the U.S. Nuclear Regulatory Commission (NRC) requested additional information from REG to complete its review.

The response to Reference (b) is provided in Attachment (1A). A redacted, non-proprietary version of Attachment (IA) is provided in Attachment (1). Attachment (2) is the Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-14-3882 accompanying Affidavit, Proprietary Information Notice, and Copyright Notice.

R.E. Ginna Nuclear Power Plant, LLC 1503 Lake Road, Ontario, New York 14519-9364 ATTACHMENT 1A CONTAINS PROPRIETARY INFORMATION. WHEN SEPARATED FROM ATTACHMENT 1A, THIS DOCUMENT IS DECONTROLLED.

Document Control Desk January 22, 2014 Page 2 As Attachment (IA) contains information proprietary to Westinghouse Electric Company LLC, it is supported by an Affidavit signed by Westinghouse, the owner of the information. The Affidavit 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 Section 2.390 of the Commission's regulations.

Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.

Should you have any other questions regarding this submittal, please contact Thomas Harding at 585-771-5219.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this _ day of 2014.

Siely, JEP/JPO Attachments: (1) Response to Question in Request for Additional Information (Non-Proprietary Version) (5 Pages).

(I A) Response to Question in Request for Additional Information (Proprietary Version) (5 Pages)

(2) 10 CFR 2.390 Affidavit of Westinghouse - CAW-14-3882 (7 Pages) cc: NRC Regional Administrator, Region I NRC Project Manager, Ginna NRC Senior Resident Inspector

ATTACHMENT (1)

RESPONSE TO QUESTION IN REQUEST FOR ADDITIONAL INFORMATION (NON-PROPRIETARY VERSION)

R.E. Ginna Nuclear Power Plant, LLC January 22, 2014

Westinghouse Non-Proprietary Class 3 LTR-LIS-13-492, Revision 1 NP-Attachment Response to Follow-Up NRC RAI Regarding the R.E. Ginna BE LBLOCA Evaluation of Elevated Initial Containment and Accumulator Temperature, NP-Attachment (5 pages including this cover page)

Westinghouse Electric Company LLC 1000 Westinghouse Drive Cranberry Township, PA 16066

©2014 Westinghouse Electric Company LLC All Rights Reserved NP-1

Westinghouse Non-Proprietary Class 3 LTR-LIS-13-492, Revision 1 NP-Attachment

Background

This letter provides the response to the follow-up Nuclear Regulatory Commission (NRC)

Request for Additional Information (RAI) related to the R.E. Ginna Best Estimate Large Break Loss-of-Coolant Accident (BE LBLOCA) evaluation of elevated initial containment and accumulator temperature (see Reference 1). The RAI is provided below.

By letter dated February28, 2013 (ADAMS Accession Number ML13067A328), R.E. Ginna Nuclear Power Plant, LLC, the licensee for R.E. Ginna Nuclear Power Plant submitted a License Amendment Request (LAR) to revise Technical Specifications 3.6.5, "Containment Air Temperature." The revision would increase the allowable containment air temperature from 1201F to 1251F. A RAI was issued by the NRC staff Branch on September 24, 2013.

The licensee Provided its response to RAI on November 11, 2013 (ADAMS Accession No. ML13323A080), which supplements the LAR.

Title 10 of the Code of FederalRegulation (10 CFR) Section 50.46(a)(1)(i) states "Comparisonsto applicable experimental data must be made and uncertainties in the analysis method and inputs must be identified and assessed so that the uncertainty in the calculated results can be estimated."

The licensee uses the NRC-approved Automated Statistical Treatment of Uncertainty Method (ASTRUM), documented in WCAP-16009-NP-A (ADAMS Accession Nos.

ML050910157, ML050910159, and ML050910161), to evaluate Emergency Core Cooling System (ECCS) performance. ASTRUM relies on an approachbased on order statistics, in which a set number of cases with randomly varied initial conditions are analyzed using the WCOBRA/TRAC (WC/I) reactor system analysis code. (The initial conditions are also referred to as inputs.) The number of cases is chosen so that the highest predicted Peak Cladding Temperature (PCT) within the case set becomes a predictor of the 95/95 upper tolerance limit for the PCT associated with a hypothetical population of Loss of Coolant Accident (LOCA) scenarios. This result is used to show compliance with the 10 CFR 50.46(b)(1) acceptance criterion concerning PCT.

In the supplement dated November 11, 2013 it was shown that a subset of the original 124 ASTRUM cases was chosen to be re-executed as a result of an error in the evaluation model relating to thermal conductivity degradation (TCD). For TCD, the subset of cases was chosen based on those original cases where TCD would have the greatest potential to affect initial stored energy in the fuel. To evaluate the proposed increase in containment air temperature, a smaller subset of cases from the TCD subset was chosen to be re-executed.

The smaller subset was chosen based on the highest peak cladding temperature (PCT) cases from the TCD subset. It is not clear to the NRC how the smaller subset accounted for those cases within the original run set, where an increase in containment air temperature could introduce additional uncertainty in the inputs, and compromise the requisite, per 10 CFR 50.46(a)(i), "high level of probability"that the acceptance criteria contained in 10 CFR 50.46(b) would not be exceeded.

Please review the randomly varied evaluation model inputs, for which an increase in containment air temperature could introduce additional uncertainty (i.e., inputs that are affected by an increase in containment air temperature). Please demonstrate that the NP-2

Westinghouse Non-Proprietary Class 3 LTR-LIS-13-492, Revision 1 NP-Attachment evaluation model and the results continue to account for the potentially increased uncertainty, such that the ECCS evaluation results continue to demonstrate that there is a high level of probability that the acceptance criteria set forth in 10 CFR 50.46(b) would not be exceeded.

Reference

1. E-mail from Mohan C. Thadani (NRC) to Thomas Harding, Jr. (R.E. Ginna Nuclear Power Plant), "Ginna LAR for Containment Air Temperature RAI (TAC MFO900)," December 11, 2013. (available in NRC ADAMS database - Accession Number: ML13345A953)

NP-3

Westinghouse Non-Proprietary Class 3 LTR-LIS-13-492, Revision 1 NP-Attachment Response to RAI:

[

]a,c The application of the approved statistical methodology applies a random number generator that returns a value between 0 and 1 [

]a.c (see Section 11 of Reference 1).

]a,c Since the explicit modeling of fuel pellet TCD resulted in a significant PCT impact on the R.E.

Ginna AOR, the [ ]axc that explicitly accounted for fuel pellet TCD was used as the starting point for the evaluation of the elevated containment air temperature (Reference 2). The top 10 cases, as ranked by maximum PCT, from the I ]axc that explicitly accounted for fuel pellet TCD were chosen for re-execution to evaluate the elevated accumulator temperature. This subset included all results within 250'F of the limiting TCD result. This evaluation resulted in an estimate of effect of +75°F.

While some cases not included in the evaluation of the elevated containment air temperature may be impacted by the increase in accumulator temperature, the effect would not be expected to be much higher than the overall estimate of effect of 75°F, leaving significant margin to the limiting result from Reference 2 (-250'F). As such, explicit consideration of additional cases would not result in a change to the limiting results calculated in the evaluation of the elevated accumulator temperature.

The evaluation of the elevated containment air temperature accounted for the change in the evaluation model inputs consistent with the approved ASTRUM methodology, and explicit consideration of additional cases will not change the estimated effect. Therefore, there is a high level of confidence that the maximum PCT, MLO and CWO results from all 124 uncertainty cases have been captured, and the effect of the elevated accumulator temperature was estimated pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 50.46(a)(3)(i).

References

1. WCAP-16009-P-A, "Realistic Large-Break LOCA Evaluation Methodology Using the Automated Statistical Treatment Of Uncertainty Method (ASTRUM)," January 2005.
2. Letter from Joseph E. Pacher (R.E. Ginna Nuclear Power Plant) to Document Control Desk (NRC), "License Amendment Request, Revise Section 3.6.5 of the Technical Specifications,

'Containment Air Temperature'," February 28, 2013. (available in NRC ADAMS database -

Accession Number: ML13067A328)

NP-4

Westinghouse Non-Proprietary Class 3 LTR-LIS-13-492, Revision 1 NP-Attachment ac Figure 1 - Accumulator Temperature vs. Random Number for R.E. Ginna Analysis-of-Record and Evaluation of Elevated Accumulator Temperature NP-5

ATTACHMENT (2) 10 CFR 2.390 AFFIDAVIT OF WESTINGHOUSE - CAW-14-3882 R.E. Ginna Nuclear Power Plant, LLC January 22, 2014

CAW-14-3882 AFFIDAVIT COMMONWEAL.,TH OF PENNSYLVANIA:

ss COUNTY OF BUTLER:

Before me, the undersigned authority, personally appeared James 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 avennents of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:

Jes A. Gresham, Manager Regulatory Compliance Sworn to and subscribed before me this 9th day of January 2014 Notary Public COMMONWEALTH OF PENNSYLVANIA I Notarial Seal Anne M.Stegman, Notary Public Unity Twp., Westmoreland County My Commission Expires Aug. 7, 2016 MEMBER,PENNSYLVANIA ASSOCIATION Of NOTARIES

2 CAW-14-3882 (1) 1am Manager., Regulatory Compliance, in Engineering, Equipment and Major Projects, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary inforiration 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) 1am 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) 1 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 informnation.

(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 CAW-14-3882 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.

(iii) 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 CAW-14-3882 (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.

(iv) The infonnation 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 in this submittal is that which is appropriately marked in "Suggested Response to Follow-Up NRC RAls Regarding the R.E. Ginna BE LBLOCA Evaluation of Elevated Initial Containment and Accumulator Temperature, P-Attachment" (Proprietary) for submittal to the Commission, being transmitted by Constellation Energy letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with NRC approval of a revision to Technical Specification 3.6.5, and may be used only for that purpose.

5 CAW-14-3882 (a) This information is part of that which will enable Westinghouse to:

(i) Provide input to Constellation Energy to provide to the U. S. Nuclear Regulatory Commission in response to NRC Request for Additional Information Regarding Amendment to Revise Technical Specification 3.6.5.

(ii) Provide licensing support for customer submittal.

(b) Further this information has substantial commercial value as follows:

(i) Westinghouse plans to sell the use of the information to its customers for the purpose of obtaining license changes for a Westinghouse pressurized water reactor (PWR).

(ii) Westinghouse can sell support and defense of the technology to its customer in the licensing process.

(iii) The informnation 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 technical evaluation justifications and licensing defense services for conmmercial power reactors without commensurate expenses. Also, public disclosure of the informnation 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.

6 CAW-14-3882 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 infonnation 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 infonnation. 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 pennitted 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.