ML14353A027
| ML14353A027 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 12/15/2014 |
| From: | Henderson K Duke Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML14353A024 | List: |
| References | |
| CNS-14-131, TAC MF4526, TAC MF4527 | |
| Download: ML14353A027 (25) | |
Text
tENERGY.
Kelvin Henderson Vice President Catawba Nuclear Station Duke Energy CNOIVP 1 4800 Concord Road York, SC 29745 o: 803.701.4251 f: 803.701.3221 CNS-14-131 December 15, 2014 10 CFR 50.90 U. S. Nuclear Regulatory Commission (NRC)
Attention: Document Control Desk Washington, D. C. 20555-0001
Subject:
References:
Duke Energy Carolinas, LLC (Duke Energy)
Catawba Nuclear Station, Units 1 and 2 Docket Numbers 50-413 and 50-414 License Amendment Request (LAR) for Measurement Uncertainty Recapture (MUR) Power Uprate Response to NRC Requests for Additional Information (RAls)
(TAC Nos. MF4526 and MF4527)
- 1. Letters from Duke Energy to NRC, dated June 23, 2014 (ADAMS Accession Number ML14176A109) and August 26, 2014 (ADAMS Accession Number ML14245A059)
- 2. Letter from NRC to Duke Energy, dated November 4, 2014 (ADAMS Accession Number ML14303A279)
The Reference 1 letters submitted and supplemented a LAR for the Renewed Facility Operating Licenses (FOLs) for Catawba Nuclear Station (CNS) Units 1 and 2 NPF-35 and NPF-52 and the subject Technical Specifications (TS) to support a MUR power uprate for Catawba Unit 1. The Reference 2 letter transmitted a set of RAI questions from the NRC associated with the LAR.
The purpose of this letter is to formally respond to this set of RAls. The attachment to this letter constitutes Duke Energy's response to these RAls. The format of the attachment is to re-state each RAI question, followed by its associated response.
With respect to the response to Division of Safety Systems, Reactor Systems Branch (SRXB) -
RAI 5, the response consists of Westinghouse letter DPC-05-14, Revision 0, Attachment, "Mini-Uprate (Appendix K Uprate) Evaluation of the Best-Estimate Large Break Loss of Coolant Accident for the McGuire Unit 1 and 2 and Catawba Unit 1 and 2 Nuclear Plants", which is considered to be proprietary information by Westinghouse. This response is supported by Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-14-4057, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice. As this response 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
,4O /
www.duke-energy.com
U. S. Nuclear Regulatory Commission December 15, 2014 PaQe 2 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. Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse Affidavit should reference CAW-14-4057 and should be addressed to James A.
Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 3 Suite 310, Cranberry Township, Pennsylvania 16066.
The conclusions of the original Regulatory Evaluation and Environmental Consideration are unaffected as a result of this RAI response.
There are no regulatory commitments contained in this letter or its attachment.
Pursuant to 10 CFR 50.91, a copy of the non-proprietary portions of this amendment request supplement is being sent to the designated official of the State of South Carolina.
Inquiries on this matter should be directed to L. J. Rudy of Catawba Regulatory Affairs at (803) 701-3084.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on December 15, 2014.
Very truly yours, Kelvin Henderson Vice President, Catawba Nuclear Station LJR/s Attachment
U. S. Nuclear Regulatory Commission December 15, 2014 Page 3 xc (with attachment):
V. M. McCree Regional Administrator U.S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave. NE, Suite 1200 Atlanta, Georgia 30303-1257 G. A. Hutto, III, NRC Senior Resident Inspector Catawba Nuclear Station G. E. Miller Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 8 G9A 11555 Rockville Pike Rockville, Maryland 20852-2738 (non-proprietary portions only)
S. E. Jenkins, Manager Radioactive & Infectious Waste Management Division of Waste Management South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201
Attachment Response to NRC Requests for Additional Information (RAIs)
Attachment Page REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST TO SUPPORT THE MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE DUKE ENERGY CAROLINAS, LLC CATAWBA NUCLEAR STATION, UNITS 1 AND 2 DOCKET NOS. 50-413 AND 50-414 TAC NOS. MF4328 AND MF4329 By letter dated June 23, 2014, Duke Energy Carolinas, LLC, the licensee for Catawba Nuclear Station, Units 1 and 2 (Catawba), requested a measurement uncertainty recapture (MUR) power uprate (Agencywide Documents Access and Management System (ADAMS) Accession No. ML1 4176 Al 09). The proposed revision would increase the Catawba, Unit 1, authorized core power level from 3411 megawatts thermal (MWt) to 3469 MWt, an increase of 1.7 percent rated thermal power (RTP).
Based on the review of the amendment request, the NRC staff has determined that additional information is required regarding the MUR power uprate Division of Safety Systems, Reactor Systems Branch (SRXB) - RAI 1 Cameron Measurement Systems, ML205, Revision 0, "Methodology for Calculating the Weighted Average of Several Measurements, Each Having an Estimated Uncertainty, to Minimize the Uncertainty of the Results," (ADAMS Accession No. ML12075A212) provides guidance for assessing long-term operational feedwater flow rate calibration of chordal leading edge flow meters (LEFMs) by comparison to other plant parameters. The Cameron methodology takes the estimated uncertainty of each plant parameter into consideration and states that, "If an unaccounted bias in the LEFM is to be detected by best estimate trending, it is desirable to start the trend at the commissioning of the LEFM." Please discuss how ML205 will be implemented as part of procedures associated with the MUR uprate.
Duke Energy Response:
Cameron document ML205 describes a methodology for identifying drift in baseline differences (biases) between independent parameters with a known relationship to feedwater mass flow rate. The ML205 method calculates a best-estimate feedwater mass flow rate by summing weighted diverse measurements. The difference between each diverse measurement and the best-estimate is then trended.
Catawba's intention is to directly trend different measurements of plant power. This is considered to be equivalent to the ML205 method and allows direct comparison with additional diverse parameters (e.g., reactor coolant system delta-T and megawatt indicators). Also, comparison trending between venturi delta-P flow measurements and Attachment Page LEFM flow measurements will also be performed. Trend monitoring is not required to validate the LEFM calorimetric uncertainty; however, it is a prudent step that will be taken to further reduce the unlikely possibility of an overpower event.
SRXB - RAI 2 Caldon Customer Information Bulletin, CIB1 19, Revision 0, "Checklist Confirming the LEFM4/
and LEFM/+ Systems are Operating Within Design Basis," (ADAMS Accession No. ML12075A211) provides for on-line monitoring of the inputs to the CheckPlus feedwater flow computation. In Table 3, Field Verification of Input Uncertainties, under Category Dimensions, an unstated assumption appears to be made that corrosion products are never removed in the short-term during operation. Please confirm that CIB1 19, Revision 0, will be followed while addressing the identified observation.
Duke Energy Response:
CameronlCaldon document Customer Information Bulletin CIB 119, Revision 0 identifies those parameters that must be monitored over time to ensure that the LEFM is operating within the bounds of its uncertainty analysis. Recent versions of the LEFM system (including the Catawba Unit I LEFM model) are designed to continuously self-monitor most of the parameters and conditions that require field verification. For the Catawba Unit I version of the LEFM Check Plus system, Table 3 of CIB 119 identifies two parameters that require manual trending/adjustment as follows:
- Periodic measurement of wall thickness using an ultrasonic thickness gauge, and
- Periodic calibration of the feedwater pressure transmitters As part of the LEFM modification, the following changes to the plant's preventative maintenance program have been initiated to address the above:
- 1.
The wall thickness of the LEFM spools will be measured using an ultrasonic thickness gauge (or equivalent instrument) once every refueling cycle to validate any change in internal diameter remains within the budgeted allowance of 0.015 inch documented within Cameron Engineering Report ER-996, Revision 1; and
- 2.
The LEFM feedwater pressure transmitters will be calibrated every two years to validate the pressure measurement total uncertainty remains within the budgeted allowance of 15 psi documented within Cameron Engineering Report ER-996, Revision 1.
SRXB - RAI 3 Section III of the application contains the accidents and transients for the existing analyses of record that do not bound plant operation at the proposed uprated power level. The loss-of-coolant accidents (LOCAs) are reviewed for the impact of the MUR power uprate under this section. The licensee states the following that, "Based on power levels assumed in current best-estimate large-break LOCA analyses (101 percent of 3411 MWt plus 1 percent uncertainty), it has been determined that the peak clad temperature (PCT) analysis is not bounded by the uprate. However, there is a PCT analysis performed at a best-estimate power of 101.7 percent of 3411 MWt with 0.3 percent uncertainty that will be included in the updated Attachment Page final safety analysis report (UFSAR) once the NRC approves the MUR LAR [license amendment resquest]." Please clarify if the methodology used for the PCT analysis for the MUR, that would be included in the UFSAR, is the same as the current unbounded PCT analysis.
Duke Energy Response:
The response to this question is combined with the response to the following question.
SRXB - RAI 4 The best-estimate power levels used in the new PCT analysis are 101.7 percent of 3411 MWt with 0.3 percent uncertainty compared to the unbounded analysis power levels of 101 percent of 3411 MWt plus 1 percent uncertainty. Please provide a justification for why these best-estimate power levels of 101.7 percent of 3411 MWt with 0.3 percent uncertainty is appropriate for the new PCT analysis compared to 101 percent MWt of 3411 MWt plus 1 percent uncertainty.
Duke Energy Response:
Westinghouse has performed an evaluation for impacts to the Catawba Large Break LOCA analysis, considering an MUR uprate to 101.7% of 3411 MWt. The assessment re-performs the Monte Carlo uncertainty analysis to quantify peak cladding temperature for the MUR, by increasing peaking factors FAH and FQ which would correspond to the MUR rated thermal power, and reducing the assumed power uncertainty to 0.3% from 1.0%.
Use of the Monte Carlo approach (via the MONTEC calculation) is consistent with the CQD Best-Estimate LOCA methodology (WCAP-12945-P-A), which is the Large Break LOCA evaluation methodology used in Catawba's current licensing basis.
SRXB - RAI 5 Please provide the PCT analysis performed at a best-estimate power of 101.7 percent of 3411 MWt with 0.3 percent uncertainty to confirm the accident and transient bounding for plant operation at the proposed uprated power level.
Duke Energy Response:
The Westinghouse proprietary information which constitutes the response to this RAI is located immediately following the response to ESGB RAI 2.
SRXB - RAI 6 Please provide WCAP-16980316083 1-NP, Revision 1, "Benchmark Testing of the FERRET Code for Least Squares Evaluation of Light Water Reactor Dosimetry," April 2013.
1 During the RAI clarification call on October 22, 2014, the licensee stated that the correct document number for the Topical Report referenced is WCAP-1 6083-NP, Revision 1. The NRC staff had incorrectly identified it as WCAP-1 6803-NP, Revision 1.
Attachment Page Duke Energy Response:
WCAP-16083 is available as non-proprietary and is attached. The NRC request listed the WCAP number as 16803 which was the incorrect number for this document. It should be WCAP-16083-NP, Revision 1, dated April 2013.
SRXB - RAI 7 The NRC staff is not aware of any benchmarking that qualifies RAPTOR-M3G for Catawba.
Please provide plant-specific benchmarking for Catawba.
Duke Energy Response:
This information (dosimetry comparisons for Catawba 1 with RAPTOR) is contained in WCAP-17669-NP, Revision 0, Appendix C. A non-proprietary version of this document is attached.
Division of Safety Systems, Containment and Ventilation Branch (SCVB) RAI I Pleas~e verify that the control area ventilation system, the auxiliary building ventilation systemn and the diesel building Ventilation system remain bounded for the design basis (102 Percent o 3111 MAW) for the MUR power uprate con)ditions.2 Division of Risk Assessment, Fire Protection Branch (AFPB) RAI 1, "Summary of RIS [Regulatory Issue Summary] 2002-03 Requested Information,"
to LAR, Section 46, "Safe Shutdown Fire," states that, "...The CNS Fire Protection System is utilized for certain non-fire protection purposes. During a B.5.b event, all AC power is lost and portable pumps are used to charge the underground fire protection system header. Catawba uses the underground fire protection system header to distribute water to meet B.5.b strategies including makeup to the spent fuel pool, the refueling water storage tank, and steam generators as well as fire suppression and Containment flooding. Operations emergency procedures for loss of feedwater provide an option to use water from the fire protection system header to make up to the steam generators..."
It is unclear to the NRC staff whether other uses of fire water for non-fire protection purposes at Catawba, Units 1 and 2, will impact the need to meet the fire protection system design demands. The NRC staff requests the licensee to discuss any changes to non-fire suppression use of fire protection water as a result of the MUR and how this change will impact the need to meet the fire protection system design demands or confirm that these uses remain unchanged as a result of the MUR.
2 During the RAI clarification call on October 22, 2014, the licensee stated that the information being sought in SCVB RAI 1 could be found on page E2-83 of the licensee's June 23, 2014 submittal. The NRC staff agreed that the information is contained in the submittal and that this RAI is no longer necessary.
Attachment Page Duke Energy Response:
Catawba's current licensing basis for fire protection is NUREG- 0800, Section 9.5.1. On September 25, 2013, Duke Energy submitted a License Amendment Request (LAR)
(ML13276A503) to adopt NFPA 805 as the fire protection licensing basis for Catawba.
This LAR was accepted for review by the NRC on January 15, 2014 (ML14010A461). An evaluation of fire protection systems concluded that they were not adversely affected by the MUR power uprate since supporting calculations were performed at 102% of 3411 MWt (3479 MWt).
As discussed in the Catawba MUR LAR (ML14176A109), Enclosure 2, Section 46, Safe Shutdown Fire, the Catawba Fire Protection System is utilized for certain non-fire protection uses as well as for fire suppression. These non-fire protection uses of fire water were reviewed and found not to be impacted by the MUR power uprate.
Division of Engineering, Mechanical and Civil Engineering Branch (EMCB) RAI 1 The primary system critical parameters listed in Table IV-1 (Page E2-44) of CATAWBA LAR are not consistent with the parameters listed in the FSAR [final safety analysis report], Revision 15 as shown below:
Table IV-1 of LAR Table 5-1 of FSAR Revision15 Reactor flow (E+06 Ibm/hr) 147.8 145.3 T hot (OF) 614.4 613.9 T cold (OF) 555.8 556.3 Steam temperature (OF) 548.73 547 Steam pressure (psia) 1021 1020 Please clarify the differences.
Duke Energy Response:
By letter dated September 30, 1994, Duke Energy submitted a License Amendment Request (LAR) in support of the planned replacement of the Catawba Unit 1 steam generators. Attached to that submittal was a Replacement Steam Generator (RSG)
Topical Report. Table 2.1-1 of that report included design parameters for the RSGs.
These included:
Attachment Page Primary Side Design Pressure 2500 psia Secondary Side Design Pressure 1200 psia Primary Side Design Temperature 650°F Secondary Side Design 600°F Temperature Primary Side Operating pressure 2250 psia Steam Outlet Pressure 1020 psia Feedwater Temperature at Full 440°F Power Steam Flow at Full Power per RSG 3.78 E+06 Ibm/hr None of these parameters represented a change from the original steam generators. The NRC issued Amendment 151 (ML013090245) on August 29, 1996, approving the Catawba Unit 1 steam generator replacement.
By letter dated December 18, 1996, Duke Energy submitted a Startup Report for Catawba Unit I Cycle 10. The report provided data for the initial operation of the RSGs. Among parameters reported at a power level of 99.53% during the Unit Load Steady State Test were:
Loop A Loop B Loop C Loop D T-hot (OF) 613.8 609.6 613.9 612.9 T-ave (OF) 584.7 581.9 583.7 583.9 T-cold (°F) 553.7 553.5 552.9 554.3 As can be seen from the Startup Report data, there is variability between loops even though T-ave is controlled at 585.1OF at full power. This difference is due in part to differences in core output per quadrant, differences in loop flow, and differences in steam generator heat transfer. The above values are typical of current operating conditions.
The Startup Report also provided main steam pressure for each RSG at increasing power levels:
Attachment Page Power (%)
RSG A (psig)
RSG B (psig)
RSG C (psig)
RSG D (psig) 15.58 1055.5 1051.8 1065.8 1063.1 30.66 1022.0 1017.9 1032.0 1029.7 50.36 1004.2 999.9 1014.0 1011.7 71.03 980.5 976.1 990.2 988.2 99.53 975.7 971.1 985.6 983.9 The main steam data demonstrated once again that each steam generator operates at slightly different conditions and that main steam pressure decreases as the power level increases.
One significant change that resulted from replacement of the steam generators was a step increase in reactor coolant system flow due to the change from heavily plugged steam generators to steam generators with no or few tubes plugged. Reactor coolant system flow has changed over subsequent cycles due to fuel changes, buildup/release of crud from the fuel and steam generator tubes, and maintenance activities such as replacement of a reactor coolant pump. These changes in flow result in changes in reactor coolant system loop parameters.
The RSG vendor provided a set of predicted reactor coolant system operating parameters that were used to update UFSAR Table 5-1 following steam generator replacement.
In 2002, Duke Energy initiated studies for an end of cycle T-ave reduction coastdown for Catawba Unit 1. These studies assumed a slightly higher reactor coolant system flow than used in previous analyses (147.8 E+6 Ibm/hr vs. 145.3 E+6 Ibm/hr). In preparation for the McGuire and Catawba MUR power uprate LARs, a number of model runs were performed to bound unit operation for 102% power (3479 MWt) and the T-ave reduction.
These analyses varied T-ave, steam generator tube plugging, and steam generator fouling. As steam generator tube plugging increases from 0% at beginning of life to 10%
at end of life, reactor coolant system flow decreases, which in turn changes T-hot and T-cold. The analyses most representative of current plant operation were used as the base case 100% power (3411 MWt) starting point and were extrapolated to 102% power (3479 MWt) predictions.
The following is a listing of reactor coolant system parameters that are predicted to change at MUR conditions. Reactor coolant system pressure and T-ave are included for completeness but do not change at MUR conditions. Values provided are at a bounding power level of 102% (3479 MWt). Relevant design limitations are also provided. All parameters remain bounded at MUR conditions. UFSAR Chapter 15 analyses were previously addressed in the LAR.
Attachment Page Parameter Current Uprate Limit Reactor power (MWt) 3411 3479 Limited by Facility Operating License Reactor coolant 2250 2250 5 2500 - system design pressure (Note 1) system pressure (psia)
> 2230.5 - Core Operating Limits Report Table 4 (Note 2)
T-hot (°F) 614.4 614.9 5 650 - system design temperature (Note 3) 5 616 - structural analysis
> 603.27 - structural analysis T-cold (°F) 555.8 555.3 5 650 - system design temperature (Note 3) 5 556.5 - structural analysis
>_ 541.61 - structural analysis T-ave (°F) 585.1 585.1 5 587.7 - Core Operating Limits Report Table 4 (Note 2)
Steam temperature 548.73 548.69 5 600 - system design temperature (Note (OF) 4)
Steam pressure (psia) 1021 1020.7 5 1200 - system design pressure (Note 4)
> 884.5 - structural analysis Steam flow (E+06 15.1 15.5 5 16.85 - limited by safety valve relief lb/hr) capacity Feedwater 440 442 5 500 - system design temperature (Note temperature (OF) 5)
Total reactor coolant 390,000 391,000
> 388,000 - Core Operating Limits Report system flow (gpm)
Table 4 (Note 2) and Technical Specification 3.4.1
<5 420,000 - mechanical design flow Notes:
- 1.
UFSAR Figure 5-1
- 2.
Catawba Unit I Core Operating Limits Report for Cycle 22, Rev. 1, April 2014 (ML14169A331 and ML14169A493)
- 3.
UFSAR Figure 5-1
- 4. UFSAR Section 10.3.2 and Figure 10-5
- 5.
UFSAR Figure 10.27 Attachment Page Regulatory Guide 1.70, Rev. 3, Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants, LWR Edition, Section 5.1, did not request a table of expected reactor coolant system operating parameters. The NRC did not rely on UFSAR Table'5-1 parameters in the Catawba SER, NUREG-0954.
UFSAR Table 5-1 was previously updated following steam generator replacement. As discussed above, changes in reactor coolant system flow day-to-day and cycle-to-cycle impact the loop parameters. Since Table 5-1 represents nominal, best-estimate values, it wasn't deemed necessary to update the table for small changes in parameters. Table 5-1 will be updated to bounding 102% power (3479 MWt) values in the next UFSAR update following approval of the MUR LAR. As shown above, loop parameters remain bounded at MUR conditions.
Division of Engineering, Steam Generator and Chemical Engineering Branch (ESGB)
RAI 1
Confirm that the steam generator plugging limit is still appropriate for the proposed MUR Power Uprate conditions, given the guidance in Regulatory Guide 1.121.
Duke Energy Response:
The Catawba Unit 1 Steam Generator Condition Monitoring and Operational Assessment conducted under the Steam Generator Program, in compliance with Regulatory Guide 1.121, has demonstrated that the steam generators meet the tube integrity performance criteria and that the criteria will be met throughout the next inspection interval at the expected MUR uprate conditions. At MUR uprate conditions, a tube with 40% loss of nominal wall thickness uniformly around the secondary side meets the acceptance criteria of Regulatory Guide 1.121.
ESGB RAI 2 Page E2-67 of Enclosure 2 of the LAR provides the predicted wear rates for run definition
'HS4/D-1s t Stg Drain' with component name 1 HS817E-T196. The information in the table for this component indicates that the post-MUR predicted thickness value is -0.048 inches. Further, the ratio of pre-MUR measured thickness to predicted thickness is -5.13. Please clarify what these values represent and the significance of them being negative numbers.
Duke Energy Response:
The subject component (1HS817E-T196) has been historically difficult to predict and the results of the model should be used with caution. The quality of these lines will increase by approximately 10% post-MUR to around 0.99. This will greatly decrease wear rates in the line due to the high quality of steam. There would not be a major decrease in wall thickness in this pipe when the quality is that high, and therefore, this shows an inaccuracy within the model. Also, this component is not expected to greatly wear based on knowledge of the system and the steam qualities. The negative number in the report doesn't hold any significance in the model and the results for scavenging steam should be used for relative ranking only. This specific component will continue to be inspected Attachment Page as part of the Flow Accelerated Corrosion (FAC) Program and is anticipated to have very low wear rates due to the 0.99 steam quality that the lines will have post-MUR.
Attachment Page Westinghouse Proprietary Class 2 OWestinghouse Mr. Michael Alfonso (Michael.alfonso(Rduke-energy.com)
Duke Energy-Catawba Station 4800 Concord Rd York, SC 29745 Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA Direct tel: 412-374-5651 Direct fax: 724-940-8553 e-mail: beddindc@westinghouse.com Westinghouse S.O.:
90737 Our ref: DPC-14-42 November 26, 2014 DUKE ENERGY CATAWBA NUCLEAR UNIT 1 RAI'S AFFIDAVIT SUBMITTAL
Reference:
Westinghouse Letter, DPC-05-14, Revision 0, "Mini-Uprate (Appendix K Uprate) Evaluation of the Best-Estimate Large Break Loss of Coolant Accident for the McGuire Unit 1 and 2 and Catawba Unit I and 2 Nuclear Plants" Dear Mr. Alfonso; Please find the attached Westinghouse Affidavit CAW-14-4057. This transmittal includes information that is Proprietary to Westinghouse. Please treat this information in accordance with the terms and conditions of the Master Equipment, Parts and Services Agreement between Duke Power, a Division of Duke Energy Corporation and Westinghouse Electric Company LLC, dated August 5, 2005, as amended.
If you have any questions or additional comments concerning this subject, please do not hesitate to contact me or John Victor at 412-374-2532.
Sincerely, WESTINGHOUSE ELECTRIC COMPANY LLC Customer Account Engineer Richard J. DranuskyJbr Daniel Beddingfield Customer Account Manager Attachment This document is the property of and contains Proprietaty Itformation owned by Westinghouse Electric Company LLC and/or its subcontractors and suppliers. It is transmitted to you in conifidence and trust, and you agree to treat this document in strict accordance with the terms and conditions of the agreement under which it was provided to you.
C 2014 Westinghouse Electric Company LLC All Rights Reserved Electronically Approved Records are Authenticated in the Electronic Document Management System
cc:
Peter Harden Richard Dranusky Dan Beddingfield Amy Colussy John Victor Megan O'Keefe Amy Freed Westinghouse Westinghouse Westinghouse Westinghouse Westinghouse Westinghouse Westinghouse Electronically Approved Records are Authenticated in the Electronic Document Management System
Westinghouse Electric Company Engineering, Equipment and Major Projects 1000 Westinghouse Drive, Building 3 Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (724) 940-8560 11555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852 Proj letter: DPC-14-42 CAW-14-4057 November 24, 2014 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
DPC-05-14, Revision 0, Attachment, "Mini-Uprate (Appendix K Uprate) Evaluation of the Best-Estimate Large Break Loss of Coolant Accident for the McGuire Unit I and 2 and Catawba Unit 1 and 2 Nuclear Plants" (Proprietary)
The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-14-4057 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. 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.
The subject document was prepared and classified as Westinghouse Proprietary Class 2. Westinghouse requests that the document be considered proprietary in its entirety. As such, a non-proprietary version will not be issued.
Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Duke Energy.
Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse Affidavit should reference CAW-14-4057, and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building.3 Suite 310, Cranberry Township, Pennsylvania 16066.
Very truly yours,
- IGresha, Manager Regulatory Compliance Enclosures
fWestinghouse Westinghouse Electric Company Nuclear Services P.O. Box 355 Pittsburgh, Pennsylvania 15230-0355 USA Mr. Robert Harvey Duke Power Company P. 0. Box 1006 Charlotte, NC 28201-1006 Direct tel: 412-374-5651 Direct fax: 412-374-3451 e-mail: beddindc@westinghouse.com Westinghouse S.O.: 20590 Customer P.O.: N/A Our ref DPC-05-14 March 15, 2005 DUKE POWER COMPANY Appendix K Uprate Evaluation of the Best Estimate Larme Break LOCA for McGuire 1&2 and Catawba 1&2
Dear Mr. Harvey:
Westinghouse has completed the Mini-Uprate (Appendix K Uprate) Evaluation of the Best-Estimate Large Break Loss of Coolant Accident for the McGuire Units 1&2 and Catawba Units 1 &2 nuclear plants. The evaluation supports an increased nominal core power and decreased core power uncertainty for the LB BELOCA analyses for these units. The 19 page evaluation is attached to this letter.
This completes the scope of work defined in the December 2, 2004 letter from Mr. Paul Bailey (Duke Energy) to Mr. Pete Harden (Westinghouse) titled "Westinghouse Offer for BELOCA Mini-Uprate Evaluation for McGuire Units 1&2 and Catawba 1&2 and Optional Scope".
This work was performed under the McGuire and Catawba fuel fabrication contract.
Westinghouse appreciates the opportunity to perform this work for your plants. If there are any questions concerning this evaluation, please contact Mr. Jeff Kobelak at 412-374-4043 or me at 412-374-5651.
Sincerely, WESTINGHOUSE ELECTRIC COMPANY LLC Daniel Beddingfield Customer Project Manager Attachment Official record electronically approved in EDMS 2000 A BNFL Group company
Page 2 of 2 Our ref: DPC-05-14 March 15, 2005 cc: M. Seagle Pete Harden Jeff Kobelak Matthew Cerrone Linda Pressley Duke ECO5P Westinghouse Charlotte Westinghouse Westinghouse Westinghouse Official record electronically approved in EDMS 2000 A BNFL Group company
CAW-14-4057 November 24, 2014 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF BUTLER:
I, James A. Gresham, am 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 my knowledge, information, and belief.
Ames A. Gresham, Manager Regulatory Compliance
2 CAW-1 4-4057 (1) 1 am Manager, 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) 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 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 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 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, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.
3 CAW-14-4057 (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.
(d)
Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If
4 CAW-14-4057 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 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 in this submittal is that which is appropriately marked in DPC-05-14, Revision 0, Attachment, "Mini-Uprate (Appendix K Uprate) Evaluation of the Best-Estimate Large Break Loss of Coolant Accident for the McGuire Unit 1 and 2 and Catawba Unit 1 and 2 Nuclear Plants" (Proprietary), for submittal to the Commission, being transmitted by Duke 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 the results of, and method for, the evaluation of a mini-uprate for McGuire Unit I and 2 and Catawba Unit 1 and 2, and may be used only for that purpose.
(a)
This information is part of that which will enable Westinghouse to:
(i)
Provide input to Duke Energy to provide to the U.S. Nuclear Regulatory Commission regarding the mini-uprate evaluation.
5 CAW-14-4057 (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 addressing the U.S. Nuclear Regulatory Commission Request for Additional Information.
(ii)
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 calculation 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 is proprietary version of a document furnished to the NRC and is associated with the results of, and method for, the evaluation of a mini-uprate for McGuire Unit I and 2 and Catawba Unit I and 2, and may be used only for that purpose. The document is to be considered proprietary in its entirety.
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 magin 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.