ML20151Z912
| ML20151Z912 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 09/11/1998 |
| From: | Sepp H WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | Collins T NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20138L028 | List: |
| References | |
| AW-98-1279, NUDOCS 9809220171 | |
| Download: ML20151Z912 (21) | |
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l l Wesfinghouse Energy Systems Ba 355 l
- Electric Corporation Pittstugh Pennsylvania 15230-0355 j September 11,1998 AW 98-1279 U. S. Nuclear Regulatory Commission l ATTN
- Document Control Desk i Washington, DC 20555 -
Attention: T. E. Collins, Chief, Reactor Systems Branch !
Division of Systems Safety and Analysis l
Reference:
~ Letter from it A. Sepp to T. E. Collins, NSD-NRC-98-5786, dated September 11,1998 J
APPLICATION FOR WITilHOLDINO PROPRIETARY INFORMATION FROM PUBLIC DISCLOSUP.E ,
Subject:
North Anna Demonstration Assemblies Final Summary Report [ Proprietary]
Dear Mr. Collins:
i The application for withholding is submitted by Westinghouse Electric Corporation (" Westinghouse")
pursuant to the provisions of paragraph (b) (1) of Section 2.790 of the Commissioni regulations. It contaim 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 2.790, Affidavit AW-98-1279 accompanies this application for withholding, 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 2.790 of the Commissions regulations.
i Correspondence with respect to this application for withholding or the accompanying affidavit should reference AW-98-1279 and should be addressed to the undersigned.
Very truly yours, o
it A. Sepp, fanager Regulatory and Licensing Engineering
- oc: T, Carter, NRR/ DISP / (SE7) -
9909220171 990911 PDR ADOCK 05000338 '
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Proprietary information Notice Transmitted herewith are proprietary and non-proprietary versions of documents furnished to the NRC. In order to conform to the requirements of 10 CFR 2.790 of the Commissioni 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 l l the non-proprietary versions, only the brackets remain (the information that was contained within the l
brackets in the proprietary versions having been deleted). The justification for claiming the information so i
is designated as proprietary is indicated in both versions by means oflower case letters (a) through (f) located L
as a superscript immediately following the brackets enclosing each item of infonnation 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)(iivai through (4)(ii)(f) l of the affidavit accompanying this transmittal pursuant to 10 CFR 2.790(b)(1). l l l l
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l Copyright Notice l
l The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies for 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 2.790 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection not withstanding. 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 regulatbns if the number of copies submitted is insufTicient 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.
l
AW-98-1279
. . AFFIDAVIT COMMONWEALTIIOF PENNSYLVANIA:
ss COUNTY OF ALLEGilENY:
Before me, the undersigned authority, personally appeared llenry A. Sepp, 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 (" Westinghouse") and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, infonnation, and belief: l I
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IIenry A. Sepp, Manager Regulatory and Licensing Engineering Sworn to and subscribed before me this // day
.1998.
of _C,2 l
Y.M N- /
Notary Public l
M M %_% Notar 8% E'pW.y PubEch(([g
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AW-98-1279 l
(1) I am Manager, Regulatory and Licensing Engineering, in the Nuclear Services Division, of the Westinghouse Electric Company 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 rulemaking proceedings, and am authorized to apply for its withholding on behalf of the Westinghouse Energy Systems Business Units.
(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.790 of the Commissiont regulations and in conjunction with the Westinghouse application for withholding accompanying this Affidavit.
(3) I have personal knowledge of the criteria and procedures utilized by the Westinghouse Energy Systems Business Units 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 Commissioni regulations, the following is furnished for consideration by the Commission in determining whether the information j 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 ofinformation 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:
AW-98-1279 l (a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouseh 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 l 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 which is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and senices invohing the use of the information.
AW-98-1279 (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 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 conipetition 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 2.790, 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 ofour knowledge and belief.
(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in the letter," North Anna Demonstration Assemblies Final Summary Report", dated September 11,1998, for submittal to the Commission, being transmitted by Westinghouse Electric Company (W._) letter (NSD-NRC-98-5786) and Application for Withholding Proprietary Information from Public Disclosure, II. A. Sepp, W Manager Regulatory and Licensing Engineering to the attention of T. E. Collins, Chief, Reactor Systems Branch.
_ _ . _ > . _ . . _ . _ . = _ _ _ _ . _ . . . _ . _ _ _ . _ _ . . _ . _ . _ _ _ _ __-.__._._ __. . _ _ _
AW-98-1279 This information is part of that which will enable Westinghouse to:
(a) Support extended bumup programs and advanced fuel designs L
(b) Assist customers to obtain license 1
Further this information has substantial commercial value as follows:
-l (a) Westinghouse plans to sell the use'of similar information to its customers for i purposes ofdesigning reactor cores i (b) Westinghouse can use this information to further enhance their licensing position with their competitors l-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 licensing services for commercial power reactors without commensurate expenses. Also, public disclosure'of the information would enable, others to use the r
info'mation 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 i 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 perfonned and a significant manpower efTort, having the requisite talent and experience, would have to be expended for developing the enclosed information.
i . Further the deponent sayeth not.
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, Westlighuse Non-Proprietiry Class 3 i
l Excerpts from " Final Report on Post Irradiation Examinations of North Anna l -
Advanced Demonstration Assemblies"(Reference 22 of WCAP-10563-P) l l
6.2 Fuel Cladding Creep and Ovality Profilometry was performed on selected removable rods from North Anna demonstration assemblies AM1 and AM2 to determine the diametrical changes of fuel rods after irradiation. Profilometry data were also evaluated for localized fuel rod diametrical changes such as ovality and ridging. Ovality is defined as the azimuthal difference between the largest and smallest diameter at a given axial location on a rod.
+(a.c)
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For the full length rod profilometry measurements, each rod is scanned from the bottom to the top at two different orientations (0 and 45 degrees), resulting in four diameter measurements at 0,45,90 and 135 degrees along almost the entire length of the rods.
The top 1.25 inches of every rod was not scanned due to interference from the collet of the MFRHT. Each scan is approximately 150 inches long.
For the partial length rod profilometry measurements of the plenum region, each rod is scanned at two additional orientations along the upper portion of the rod. This results in a total of eight diameter measurements at 0,22,45,90,135,157,247 and 292 degrees along the uppermost section of the rod. Each scan is approximately 20 inches in length at the top of the rod. ,
For each LVDT, the data are taken digitally at [ ]+() increments along the entire scan length. Analysis and reduction of the digitized data included filtering the data to remove electronic noise, and averaging the data over [ ]+(*#) intervals.
l The detailed profilometry data are provided in the individual End of Cycle reports (References 2,3,8,9, and 12).
l The fuel rod creep data are presented in Tables 6-1 thrcagh 6-9 and Figures 6-2 through 6-6. Each table includes the assembly identification, the rod identification, the cladding
- type, and plenum spring type. [
}Ms.c)
Page1
Tables 6-1 through 6-3 summarize the burnup, the pre- and post irradiation diameters and the average creepdown of the rods for Cycles 7,8 and 10, respectively. The pre-irradiation diameter was measured on a number of rods. Where available, the measured
. pre-irradiation diameter was used, and for rods not measured, the rod nominal diameter of l [ ]"'#1 lwas used. The post-irradiation diameter has been [
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]+('#) at each elevation of other rods of the same material type was used.
The average creepdown in the high power region was calculated by first averaging the measured diameter over all the orientations measured and then applying the above equation. [
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+(a,b,c) 1 The fuel rod creep data are presented graphically in Figures 6-2 through 6-6, Figures 6-2 to 6-5 show the fuel rod axial creep profile for each cladding material type. Figure 6-2 shows the EOC-7 one cycle burnup rods, Figure 6-3 shows the EOC-8 two cycle rods, Figure 6-4 shows the EOC-10 two cycle rods and Figure 6-5 shows the EOC-10 three cycle rods. Figure 6-6 shows the average creep values in the high power region for l ' different cladding material types as a ftmetion of burnup. Each data point in Figure 6 denotes the average creep value for a single rod. These figures show that ZlRLO* rods exhibit slightly less creep than the improved Zr-4 and conventional Zr-4 rods after the first cycle ofirradiation. [
J +(a,b.c)
In addition to rod creep, rod ovality was detennined as an average over each one inch interval of elevation. Ovality is defined as the difference between the largest and smallest rod diameter measured at a given axial position (elevation).
Based on the full length profilometry data, the ovality data were evaluated for any values i greater than [ ' ]+('#) extending from the bottom of the rod i to the [ ]+(*#) elevation. The data above [ ]+(*#) were not evaluated because they are believed to be affected by the end plug and the collet of the fuel rod handling tool. The results are shown in Tables 6-4 through 6-6. None of the rods showed ovalities greater than [
}+(a,b,c)
Rod ovality in the plenum region was also evaluated from the plenum profilometry data.
The ovality values greater than [ ]+(* 6 *) in the plenum area are reported in Tables 6-
!' 7 through 6-9. The elevations covered by plenum profilometry [ ]'(* b *)
l are also covered by full length profilometry, so there is overlapping data at the higher elevations for rods examined by both techniques. It is noted that some rods had a different ovality as measured by plenum profilometry than as measured by full length Page 3
profilometry at the same elevation. These points are marked by the footnote (1) in Tables l 6-7 and 6-8. This difference could be partly attributed to the location of the probe on the I rod both in orientation and elevation (i.e. the starting point of the probe on the rod). It may be slightly different for each measurement since the plenum and full length profilometry were done separately. However, it is believed that the major reason for the ,
difference is due to a difference in the number of the azimuthal orientations selected for I each measurement. The diameter was measured at eight orientations in plenum profilometry and four orientations in full length profilometry. Because of this reason, it was judged that plenum profilometry provides more accurate ovality measurements on the top plenum region. Therefore, the rod ovality evaluation described below is based on the plenum profilometry data.
+(a.c)
None of the rods showed unexpectedly high ovalities. Table 6-10 compares the observed maximum ovality for each cladding material type at the end of each cycle. The table also 1 compares the ovality difference between the rods with and without a spring clip. As . I mentioned previously, the ovality values at elevations higher than [ ]+(* b ') were excluded from the data evaluation due to ' the influence of the end plug and the rod gripper. Although not enough data is available to make a conclusive comparison for each !
cladding material type, some possible trends can be seen. [
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Table 6-1 -
c Fuel Rod Profilometry Data End of Cycle 7 _ ;
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l Fuel Rod Profilometry Data ..:
End of Cycle 10 ' .
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Page 8
_ _ . _ _ _ - . _ _ _ ...__._o m _ __2_ . __ .__. . . ___._.__ _ _ _ _ _ .___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ .___m_.__.m_____ _____ __ ___.____s
Figure 6-2 -
l NORTH ANNA 1 EOC-7 PROFILOMETRY DATA -
Average Creepdown - One Cycle Burnup Rods - -
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. Figure e-a -
NORTH ANNA 1: 50C-8 PROFILOMETRY DATA -
Average Creepdown - Two Cycle Burnup Rods _
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Figure 6-4 .
NORTH ANNA 1-EOC-10 PROFILOMETRY DATA .
- Average Creepdown - Two Cycle Burnup Rods _
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99 Fjgure 6-5 .
NORTH ANNA 1.EOC-10 PROFILOMETRY DATA ..
verane Creepdown - Three Cycle Burnup Rods _
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s Figure 6-6 l NORTH ANNA 1 PFiDFILOMETRY DATA, ALL CYCLES ~
Average Creepdown in High Power Region _
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