ML20101G008

Application for Withholding Info Re post-critical Testing (Ref 10CFR2.790)

ML20101G008
Person / Time
Site:	Wolf Creek
Issue date:	12/21/1984
From:	Wiesemann R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML19274C560	List: ML20101G006 ML20101G008
References
841212, CAW-84-111, NUDOCS 8412270394
Download: ML20101G008 (20)

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KMLNRC 84-235 Westinghouse WaterReactor 2x355 Electric Corporation Divisions R"*8 W'* *'30 December 12, 1984 CAW-84-111 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C.

20555 APPLICATION FOR WITHHof DING PROPRIETARY INFORMATION FROM PUBLIC DIS 10SURE

Subject:

Post Critical Testing

Reference:

Kansas Gas & Electric Cmpany letter to NRC dated December,1984

Dear Mr. Denton:

The proprietary material for which withholding is being requested in the reference letter by Kansas Gas & Electric Company is further identified in an affidavit signed by the owner of the proprietary infomation, Westinghouse Electric Corporation. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Comission and addresses with specificity the considerations listed in paragraph (b)(4) of 10CFR Section 2.790 of the Comission's regulations.

The proprietary material for which withholding is being required is of the same technical type as that proprietary material previously sutmitted with Application for Withholding AW-76-8.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Kansas Gas & Electric Cmpany.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-84-111, and should be addressed to the undersigned.

Very truly yours, Robert. Wiesema n, Manager Regulatory & Legislative Affairs

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Enclosure (s) cc: E. C. Shemaker, Esq.

.0ffice of the Executive Legal Director, NRC g2%foh A

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• .w AW-76-8 AFFIDAVIT

' COPMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally appeared Robert A. Wiesemann, who, being by me duly sworn according to law, de-poses and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Corporation (" Westinghouse") and that the aver-ments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:

Y b.

ftfd2ut Robert A. Wiesemann, Manager Licensing Programs Sworn to and subscribed beforeme.this/8' day of

[b/ 1976.

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/ Notary PublicI

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-(1) I am Manager, Licensing Programs, in the Pressurized Water Reactor Systems' Division, of Westinghouse Electric Corporation and as such, I have been specifically-delegated the function of reviewing the j

proprietary information sought to be withheld from public dis-L closure in connection with nuclear power plant licensing or rule-making proceedings, and am authorized to apply for its withholding on behalf of the Westinghouse Water Reactor Divisions.

(2)

I am making this Affidavit in conformance with the provisions of -

10 CFR Section 2.790 of the Commission's regulations and in con-junction with the Westinghouse application for withholding ac-companying this Affidavit.

4 I.

(3) I have personal knowledge of the criteria and procedures utilized -

by Westinghouse Nuclear Energy Systems in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to,the provisions of paragraph (b)(4) of Section 2.790 of the Conunission's regulations, the following is furnished for consideration by the Commission in determining whether the in-fonnation sought to be withheld from public disclosure should be withheld.

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

4

. AW-76-8 (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 com-petitive advantage, as follows:

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(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 consti-tutes a competitive economic advantage over other companies.

(b)

It consists of supporting data, including test data, relative to a process (or component, structure, tool, j.

method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization l

or improved marketability.

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, AW-76-8 (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 cap-acities ' budget levels, or comercial strategies of Westinghouse, its customers or suppliers.

(e).It' reveals aspects of past..present, or future West-

. inghouse or customer funded development plans and pro-grams of potential comercial value to Westinghouse.

(f) It contains patentable ideas, for which patent pro-taction may be desirable.

(g)

It is not the property of Westinghouse, but must be treated'as proprietary by Westinghouse according to agreements with the owner.

There are sound policy reasons behind the Westinghouse system which include the following:

(a) The use of such information by Westinghouse gives Westingh'ouse a competitive advantage over its com-petitors.

It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

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AW-76-8 l(b) -It is'information which is. marketable in many ways.

The! extent to which such infonnation 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 infonnation pertinent to a particular competitive advantage is potentially-

.as-valuable las-the total. competitive advantage.- If competitors acquire components of proprietary infor-mation, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

(e) U,nrestricted disclosure would jeopardize the position of prominence of Kestinghouse in the world market, and thereby give a market advantage to the competition in those countries.

(f) The Westinghouse capacity to invest corporate assets in rcsearch and developtrent depends upon the success in obtaining and maintaining a competitive advantage.

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6-AW-76-8 (iii).The information -is-being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.790, it is to be received in confidence by the Commission.

s (iv). Thelinformation is not available in public sources 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 the attach-ment to Westinghouse letter number NS-CE-1139, Eiche1dinger to Stolz, dated July 19, 1976, concerning supplemental infor-mation for use in the Augmented Startup and Cycle 1 Physics Program. - The -letter and attachment are being submitted as-part of the above mentioned program in response to concerns

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of the Advisory Committee on Reactor Safeguards with the new Westinghouse PWR's, which are rated at higher power densities than currently operating Westinghouse reactors.

This 1,nfonnaticn enables Westinghouse to:

(a) Justify the Westinghouse design correlations.

(b) Assist its customers to obtain licenses.

(c) Provide greater flexibility.to customers assuring them of safe reliable operation.

J (d) Optimize performance while maintaining a high level of fuel integrity.

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7-AW-76-8 (e). Justify operation at a. reduced peaking factor with a wider target band than normal.

(f) Justify full power operation and meet warranties.

Further, the information gained from the Augmented Startup and Cycle 1 Physics Program is of commercial value and is sold for considerable sums of money as follows:

(a) Westinghouse uses the information to perform and justify analyses which are sold to customers.

' (b) Westinghouse-uses the information to sell to its customers for the purpose of meeting NRC requirements for' full power licensing.

(c) Westinghouse could sell testing services based on the experience gained and the analytical methods developed using this information.

Public disclosure of this information concerning the Augmented Startup program is likely to cause substantial harm to the competitive position of Westinghouse by allowing its com-petitors to develop similar analysis methods and models at i

a much reduced cost.

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't AW-76-8 The analyses performed, their methods and evaluation repre-sent a considerable amount of highly qualified development effort, which has been underway for many years.

If a com-petitor were able to use the results of the analyses in the attached document, to normalize or verify their own

- methods or models, t' e development effort and monetary expen-

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.diture required to achieve an equivalent capability would be significantly reduced.

In total, a substantial amount of money and effort has been expended by Westinghouse which could only be duplicated by a competitor if he were to invest similar sums of money and provided he had the appro-priate talent available.

Further the deponent sayeth not. -

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. 'to-KMLNRC 84-235 Wolf Creek Low. Power and Power

' Ascension Test Results Review Program Position, C.8 of Regulatory Guide 1.68 Revision 2 dated August 1978, recommends that hcid. points. be _ established so that " relevant test results are evaluated and approved... prior to progressing with the power-ascension test phase."

(Emphasis added).

The Guide suggests-hold points be established for PWRs.likel Wolf Creek at approximately 25%,

.504, and 75%

power.

Appendix-C suggests that,.

for

. power-ascension procedures, controls be set up to

"(r) eview. the

-completed testing program at each-plateau, nerform preliminarv evaluations,... and obtain the required management approvals before ascending to the next power level..."

(Emphasis added).

Considering this guidance, KGEE has established initial test program controls;as-follows:

1.

Concerning the time frame for evaluating specific test results, Westinghouse determined those tests which-are related-. to safety / Technical Specification parameters, in contrast - to tests related 'to control system optimization and " historical-. tests."

A-table relating tests, power level of testing, and recommended power level threshold for evaluation was supplied by Westinghouse to KG&E.

The. table defines those parameters measured atLlower power. levels which are not-relevant when considering reactor safety until the plant exceeds the higher power level.

At the higher level, the results are relevant and management reviews and approvals must be obtained prior to exceeding that power level.

The table; Table II-1 of the Startup Test Program Reference

-Document, SNP-SU-3.1.1, from the SNUPPS NSSS Startup~ Manual; is

' attached and contains Westinghouse proprietary information.

The rationale for the recommendations made in Table II-1 derive from a need ; to verify ' the fundamental parameters..affecting NSSS core performance:

1) power distribution parameters F,3 Fan 3 quadrant power tilt

)

2) primary heat removal parameters, flow, L ATw 33 f

3) reactivityparameters,controlbankworth,dhyT)dghC, and the following transient characteristics:

1) reactor coolant' pump trip / flow.coastdown 2)

. normal load transients 3) large load.trans!ents/ plant trips l

1

i The-hot zero. power tests yield the basic core neutronic-performance: results.

.In order to vecify basic coa neutronic performance,athe required measurements are an all rods out flux:

mapwthewreactivity worth' of the fitst control bank, and-thes all-rods-out-plus-control-bank-in isothermal temperature coefficient.- These measurements are evaluated prior to proceeding to the<next testing plateau to-conform compliance.with applicable Technical Specifications.

From.these tests it is confirmed that' the powor-distribution parameters.

are within the. design constraints for-the plant.

Subsequent-power distribution-measurements c reveal-the offect of doppler and. xenon on - power

. distribution.

Theihot zero power tests also yield the moderator-W

' temperature + coefficient which is used to comply with the: Technical.

Specification on-moderator-temperature coefficient.

Measurements related ' to pseudo rod ejection have shown over. the-years-to yield data of -little significance when compared ; with.

design : margins..

Recently, twin unit stations' have succeeded in deleting these tests for the second unit with NRC concurrence..

Based on results from many Westinghouse plants, the tests can be properly evaluated in the time frame shown on Table II-1.

Again, reviews and approvals of test results will. be obtained.

priorrtoi: exceeding: power-levels where the results become-relevante 2.

To further amplify on-the power-ascension program, attached is a modified Table 3.8 of WCAP-7905, Revision 1.

'The modification consists of. updated information based on current testing methodology and Technical Specifications.

This WCAP has not yet been submitted for NRC review and approval.

The Table delineates

-the Westinghouse recommended " Minimum Test Requirements for Power

. Escalation."

It.is based on considerations described in Item 1.

above regarding the significance of test results to plant safety.

KGEE has endorsed the Westignhouse recommendations and established the following testing holdpoints of Table 3.8:

a)~

Initial criticality b)

Power escalation above 10%

c)

Power escalation above 50%

d)

Power escalation above 75%

e)

Power escalation above 90%

I Each acceptance

criteria, verification

activity, measurement,.

alignment, calibration, or check given in the Table has -been

' determined to be a relevant test result and must be satisfied and management approvals obtained prior to going above the noted holdpoint.

L 3.

Specific holdpoints, as required by Regulatory Guide 1.68, are established at approximately 25%, 50% and 75% power.

At these,

levels, oreliminarv-evaluations of test results not already

. covered:by Items 1. and 2. above will be performed and management approvals attained prior to ascent above the holdpoint.

TP.BLE II-l Test Resulta Evaluation' Schedule Exceptione Page 1 ef 2 Test Description 9"****

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Test Perfotmed at Test Resulte Required Number-Paragraph Before Exceeding Reactor Coolant System Plow Measurement 3 1.3 5.3.3 Not' Shutdown' 8'f*** 1818181 criticality Reactor Coolant System Plow Cosatdown t+a,c 3.1.3 5.3.10 Not Shutdown Low Power Nuclear Teete 3.1.4

.f5 RCCA Pseudo Ejection (NEP Case) 3.1.4 5,16 Imv Power g

RCCA Pseudo Ejection (NFP Case) 3.1.5 5.18 301 Se load Swins 3.1.5 5.19 30%

Power coefficient iSi 3.1.5 5.21 30%

m[z RCCA Pseudo Drop 3.1.6 E

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3.1.6 5.8.5 502 Rode tiep and Plant Tr1P 3.1.6 5.12 502

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I Test Description

-Reference Test se,sene,'

Page I of 2 p,"*' C'*fficient med at Test Results a g g w 3.1.6

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Pouer coefficient a,c l

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WESTINGHOUSE PROPRIETARY CLASS 3 TABLE 3.8 MININUM TEST REQUIRDENTS FOR poler ESCALATION (These Criteria Assume That All safety Related PreoPerational Tests Bave Been Performed datiefactorily)-

I.

PRIOR TO INITIAL CRITICALITY

+a,c

WESTINGH0USE PROPRIETARY CLASS 3 TE LE 3.8 (continued)

II. PRIOR TO POWER ESCALATION AB0VE 10%

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WESTINGHOUSE PROPRIETARY CLASS 3 TABLE 3.8 (continued)

IV. PRIOR TO POWER ESCAM TION ABOVE 751 ija,C w 9 0

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WESTINGHOUSE PROPRIETARY CLASS 3 TABLE 3.8 (continued) ui+a,, c O

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PRIOR TO POWER ESCA1ATION ABOVE 901

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, to KMLNRC 84-235 SNUPPS-WC 14.2.5

RTVIEW, EVALUATION, AND APPROVAL' OF TEST RESULTS Thevresponsibility+ fore review, evaluation, and recommenda-tione for.n approvalE of": test results from a all preoperational testsprests;with;theaJTG.- In.the caseSof all initial start-Jupstests,;it rests with the PSRC.

Following completion of a preoperational test, the respon-sibleu system startup engineer: wills assemble the test data packager <4for:.submittala ton the. memberswofL the. JTG, for evalua <

.tions: "Each testn data. package -willa be revieweds to ensuren

~ that-the ; test has been performed 61n accordance with the approvedrprocedure+ and that all: required data, checks, and signatures have been properly recorded and thate system

-performance meets the approved acceptance criteria.

Members of the JTG will review the-evaluation findings and recommend. corrective action to be taken to resolve any out-standing deficiencies.

If the deficiencies are not resolved to - the satisfaction of the JTG, then appropriate retesting may be required... If the evaluation indicates that deficien-cies ein thertest; method: are responsibler for unsatisfactory test results, the. test procedure willabe revised accordingly before ratesting is initiated.

The review and approval pro-cess for procedure revisions is carried out in the manner described-in Section 14.2.3.

Whenever an evaluation of test results indicates deficiencies in system performance, the JTG will refer the problem to the responsible engineering organization for evaluation.

If the test documentation and system performance are acceptable, the.JTG will recommend approval of the test by the Startup Manager and the Plant Manager.

Following each major phase of the initial startup test pro -

- grant, the-PSRC will verify that all required tests have been performed: and that the test results have been approved.

This verification will ensure that all required systems are operating properly and that testing for the next major phase l

will'be conducted in a safe and efficient manner.

This type of review will be performed to the extent required before major' initial startup test phases such fuel loa initial criticality, and power ascension During the power ascen-sion phase, revi s and approval of initial startup test procedure results will be completed for each of these pla-25 percent, 50 percent, and 75 percent, prior to teaus proceeding to the next plateau.

14.2.6 TEST RECORDS O

tcg.

Test procedures and test data relating to preoperational and initial startup testing will be retained in accordance with 4

I the measures described in Section 17.2.17.

Re 2

14.2-10a

n 4

. to KMLNRC 84-235 Wolf Creek-Low Power and Power Ascension Test Results Review' Program'-

Position. C.8 - of Regulatory Guide 'l'.68 Revision 2 dated August 1978, recommends that hold. points be established _ so that " relevant test results 'are evaluated. and. approved... prior to progressing with the power-ascension -test phase."

(Emphasis added).

The Guide suggests -

hold points be established for PWRs' like Wolf Creek at approximately 25%,

50%,

-and ;75%. power.

Appendix C'

. suggests- - that, for

. power-ascension. procedures, ' controls be set up to' '"(r)eview the completed-testing program at each

plateau, perform nreliminarv evaluations,.... and. obtain - the = required management approvals - before ascending to the next power level..."

(Emphasis-added).

Considering this guidance, KG&E has established initial test program-

. controls as follows:

1.

Concerning the time frame for. evaluating - specific test results, Westinghouse determined those tests which are' related to safety / Technical Specification parameters,.in contrast _ to tests relat.ed.to control system optimization and " historical tests."

A table relating tests, power. level of testing, and recommended power level threshold for evaluation.was supplied by Westinghouse to KG&E.

The table defines those parameters measured at lower power _ levels which are not relevant when considering reactor safety until the plant exceeds the higher power level.

At.the higher level, the results are relevant and management reviews and approvals must be obtained prior to exceeding that' power level.

The table; Table II-l of the Startup Test. Program Reference Document, SNP-SU-3.1.1, from the SNUPPS NSSS Startup Manual; is attached and contains' Westinghouse proprietary information.

The rationale for the recommendations made in Table' II-l derive from _a need to verify the fundamental parameters affecting NSSS core performance:

1) power distribution parameters F93 Fm quadrant power tilt 2) primary heat removal parameters, flow,' Tavg 3 Mew reactivityparameters,controlbankworth,'k[yT,khC 3) 8 and the following transient characteristics:

1) reactor coolant pump trip / flow coastdowr 2) normal load transients

-3) large. load transients / plant trips l

l I

L

The. hot zero power tests yield the basic core neutronic-performance results..

In order to verify basic core neutronic

_ performance, the required measurements are an all rods out -. flux map, the reactivity worth - of the first control bank, and the all-rods-out plus control-bank-in isothermal temperature coefficient.

These measurements are evaluated prior to proceeding to the next testing. plateau to conform compliance with applicable Technical Specifications.

From these tests it is confirmed that the ' power distribution parameters are within the design constraints for the plant.

Subsequent power distribution

[..

measurements reveal the effect of doppler and xenon on power distribution.

The hot zero power tests also yield the moderator temperature coefficient which is used'to comply with the Technical Specification on moderator temperature coefficient, i

-Mea'surements related to pseudo rod ejection have shown over the years to yield data of little significance when compared with design margins.

Recently, twin unit stations have succeeded in deleting these tests ~ for the second unit with NRC concurrence.

Based on results from many Westinghouse plants, the tests can be properly evaluated in the time frame shown on Table II-1.

Again, reviews and approvals of test results will be obtained

. prior to exceeding power levels where the results become relevant.

t i

2.

To further amplify on the power ascension program, attached is a modified Table 3.8 of WCAP-7905, Revision 1.

The modification consists of updated information based on current testing methodology and Technical Specifications.

This WCAP has not yet been submitted for NRC review and approval.

The Table delineates the Westinghouse recommended " Minimum Test Requirements for Power Escalation."

It is based on considerations described in Item 1.

above regarding the significance of test results to plant safety.

KG&E has endorsed the Westignhouse recommendations and established the following testing holdpoints of Table 3.8:

a)

Initial criticality b)

Power escalation above 10%

c)

Power escalation above 50%

d)

Power escalation above 75%

e)

Power escalation above 90%

Each acceptance

criteria, verification

activity, measurement, alignment, calibration, or check given in the Table has been determined to be a relevant test result and must be satisfied and management approvals obtained prior to going above the noted holdpoint.

3.

-Specific holdpoints, as required by Regulatory Guide 1.68, are established at approximately 25%, 50% and 75% power.

At these i

levels, oreliminarv evaluations of test results not already covered by Items 1. and 2. above will be performed and management approvals attained prior to ascent above the holdpoint.

-