ML20195F210

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Requests That Farley Nuclear Plant Proprietary Responses to NRC RAI Re W WCAP-14750, RCS Flow Verification Using Elbow Taps at W 3-Loop Pwrs, Be Withheld from Public Disclosure Per 10CFR2.790
ML20195F210
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 05/24/1999
From: Galembush J
WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20137T089 List:
References
CAW-99-1337, NUDOCS 9906140225
Download: ML20195F210 (17)
v • d • e


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l Westinghouse Electric Company Nuclear Services Division Eox 355 Pittsburgh, Pennsylvania 152304355 May 24,1999 CAW-99-1337 Document Control Desk i U.S. Nuc! car Regulatory Commission  ;

Washington, DC 20555 j Attention: Mr. Samuel J. Collins l l

APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE J

Subject:

Farley Nuclear Plant (Westinghouse Owners Group) Responses to NRC Request for Additional Information (RAIs #3) Related to WCAP-14750 "RCS Flow Verification Using Elbow Taps at Westinghouse 3-Loop PWRs," (Proprietary)

Dear Mr. Collins:

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-99-1337 signed by the owner of the proprietary information,

, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sett, fo;th 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 2.790 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Southern Nuclear Operating Company.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-99-1337, and should be addressed to the undersigned.

Very truly yours, Mh J. S. Galembush, Acting Manager Regulatory and Licensing Engineering Enclosures

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, . CAW-991337 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

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ss COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally appeared John S. Galembush, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this AfTidavit on behalf of Westinghouse Electric Company LLC, (" Westinghouse"), and that the averments of fact set forth in this .,

I Affidavit are true and correct to the best of his knowledge, information, and belief:

1 John S. Galembush, Acting Manager Regulatory and Licensing Engineering Sworn to and subscribed bef re me this/4/ day of N!114/ 1999

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CAW-99-1337 (1) I am Manager, Regulatory and Licensing Engineering, in the Nuclear Services Division, of the Westinghouse Electric Company LLC (" Westinghouse"), and as such, I have been specifically delegatei :he 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 Electric Company LLC.

(2) I am making this Affidavit in conformance with the provisions of 10CFR Section 2.790 of the Commission's 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 Electric Company LLC in designating information as a trade secret, privileged or as confidential commercial or financial infommtion.

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

I (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

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customarily disclosed to the public. Westinghouse has a rational basis for determining the types ofinformation 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.

    • i Under that system, information is held in confidence ifit faib in one or more of several types, the release of which might result in the loss of an existmg or potential competitive

,' advantage, as follows.

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r CAW-99-1337 (a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention ofits use by any of 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 j component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.

i (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 pre 3 rams of potential commercial value to Westinghousc.

(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 services involving the use of the information.

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' i CAW-99-1337 (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.

(c) Unrestricted disclosure would jer pardize 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 developrnent 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 10CFR 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 of our knowledge and belief.

1 (v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in "Farley Nuclear Plant (Westinghouse Orners Group) Responses to NRC Request for Additional Information (RAls #3) Related to WCAP-14750, "RCS Flow Verification Using Elbow Taps in Westinghouse 3-Loop PWRs," (Proprietary),"

May 1999 for Farley Units I and 2, being transmitted by Southern Nuclear Operating Company letter and Application for Withholding Proprietary Information from Public Disclosure, to the Docur.:ent Control Desk, Attention Mr. Samuel J. Collins. The proprietary information as submitted for use by Southern Nuclear Operating Company for the Farley Units I and 2 Nuclear Power Plants is expected to be applicable in other

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CAW-99-1337 e

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submittals in response to certain NRC requirements forjustification of use of RCS flow verification using elbow taps.

This information is part of that which will enable Westinghouse to:

(a) Provide elbow tap methodology foi baseline flows.

(b) Establish appropriate procedures for baseline calorimetric flow with elbow tap measurements.

(c) Assist the customer to obtain NRC approval.

Further this information has substantial commercial value as follows:

(a) Westinghouse plans to sell the use of similar information to its customers for l

purposes of meeting NRC requirements for licensing documentation.

(b) Westinghouse can sell support and defense of RCS verification methodology using elbow taps to its customers in the licensing process.

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 support documentation 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 pu--hasing 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.

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CAW-99-1337 In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, hasing the requisite talent and experience, would have to be expended for developing testing and analytical methods and performing tests.

Further the deponent sayeth not.

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. PROPRIETARY INFORMATION NOTICE l

i 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.

1 In order to conform to the requirements of 10 CFR 2.790 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 i that was contained within the brackets in the proprietary versions having been deleted). The l justification for claiming the information so designated as proprietary is indicated in both versions by - !

means of lower case letters (a) through (f) contained within parentheses located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.790(b)(1).

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COPYRIGIIT 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 2.790 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westiaghouse, 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.

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, , ATTACIIMENTIII ]

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SNC Response To NRC Request For AdditionalInformation On WCAP-14750, "RCS Flow Verification Using Elbow Taps At Westinghouse 3-Loop iPWRs,"

Joseph M. Farley Nuclear Plant Units 1 & 2 4

"Farley Nuclear Plant (Westinghouse Owners Group) Responses to NRC Request for Additional Information (RAI #3) Related to WCAP-14750, 'RCS Flow Verification Using Elbow Taps at V/cstinghouse 3-Loop PWRs,'" Westinghouse Non-Proprietary Class 3, Revision 0, May 24, 1999 l

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WESTINGHOUSE NON-PROPRIETARY CLASS 3 Farley Nuclear Plant (Westinghouse Owners Group) Responses to NRC Request for Additional Information (RAIs #3) Related to WCAP-14750

  • RCS Flow Verification Using Elbow Taps at Westinghouse 3-Loop PWRs" RAI #3, Question 1:

Provide the guidelines and/or methodology with appropriate criteria.

for defining how the baseline flow is established from one baseline cycle or the average of multiple cycles. The guidelines should also include (1) how the baseline cycle is chosen when it is determined that a Cycle 1 baseline flow is not available or that the Cycle 1 measurement does not meet the criteria for establishing the baseline flow, (2) how the number of additional cycles to be averaged is chosen, (3) the criteria for choosing the baseline cycle -flow or the average of the multiple cycle flows, and (4) why it is not necessary to pick the conservative result of the baseline cycle value and the average of the multiple cycles.

RAI #3, Response 1:

The procedure for defining baseline flow, previously presented in the paragraphs under Baseline Calorimetric Flow in Section 4.2 of

-WCAP-14750, has been revised to clarify the procedure. The revised procedure defines the acceptance criteria for.the calorimetric flow measurements used to define baseline calorimetric flow, and defines the basis for using either an average or a single measurement. The revised procedure is presented below. The revised procedure ensures that a conservative result is used; therefore, part (4) of this question no longer applies.

Baseline Calorimetric Flow (Revised Procedure)

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(End of Revised Procedure)

Section 6.1 of WCAP-14750 described the evaluation of calorimetric flows ~ for Farley Units 1 and 2, based on the original procedure.

When the revised procedure is applied, the evaluation is revised as described below. WCAP-14750 will be revised to reflect these changes.

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WESTINGHOUSE NON-PROPRIETARY CLASS 3 Farley Unit 1

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Farley Unit 2

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WESTINGHOUSE NON-PROPRIETARY CLASS 3 TABLE 1 - FARLEY UNIT 1 BASELINE FLOW DEVELOPMENT

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-Note: Applicable information in Section 6 and Appendix D of WCAP-14750 will be revised to reflect these changes.

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RAI #3, Quest' ion 2:

Section 6.3 of .. WCAP-14 750 discusses the evaluation of the Farley Units.1 and 2 elbow tap data. This section states that for Unit 2, the elbow tap baseline'is' based on the Cycle 5 measurement. Table 6-2 lists the Unit ' 2 calorimetric flows with the baseline flow obtained; from the average .of earlier cycles after hydraulic corrections to Cycle 1, and Table 6-4_ lists the elbow tap flow data normalized to Cycle 1. Explain how the Cycle 5 elbow tap op data was. normalized to Cycle 1.and why it is necessary to convert both the baseline Cycle 5 elbow tap op data and calorimetric flow data to Cycle 1, rather than maintaining both for Cycle 5.

RAI #3,' Response 2:

Table 6-4 compares the best estimate flow trend with the elbow tap flow trend for Units 1 and 2, to show that elbow tap measurements closely measure the predicted flow changes. Since Unit 2 elbow tap data was not available before Cycle E elbow tap and best estimate flows could not be compared in Cyc1cs 1 through 4. To obtain a meaningful comparison for the later cycles, the elbow tap flow was normalized to the best estimate flow of 98.64 percent in Cycle 5.

Elbow tep flows after Cycle 5, normally expressed as a percentage of the first measurement (Cycle 5 in this case, usually Cycle 1),

were multiplied by 0.9864 to normalize them to the best estimate flow. Therefore, the best estimate and elbow tap flow changes after Cycle 5- were presented with an equivalent basis and could be compared directly.

(Note that the same comparison would be obtained on Table 6-4 if best estimate flow had been normalized to 100 percent in Cycle 5 for comparison with the elbow tap flows normalized to 100 percent in Cycle 5.)

For convenience of the presentation, all flows were originally normalized to Cycle 1, based on the best estimate of the applicable hydraulics corrections. Since all flows used the same correction, the flow comparisons were consistent. As stated above for the revised procedure described in the response to Question 1, Cycle 5 would now_ be defined as the baseline cycle, and flows would be normalized to have the same percent flow in Cycle 5. This change would not affect the flow comparison shown on Figure 6-2.

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~RAI #3, Question 3:

Section_4.2 of WCAP-14750 describes the elbow tap flow measurement procedure.. For the most part, this procedure .is identified as

' proprietary. information. Since the time WCAP-14750 was submitted b'y Farley, 7another plant submittal ;was presented to the NRC which listed.similar information that was not marked as proprietary. As

-such,: .should ~ some orL all if the information in WCAP-14750 be

reclassified as non-proprietary? If not,lwhy?

RAI #3, Response 3:

In view of the inconsistency noted .by. the NRC, Westinghouse will reclassify as non-proprietary the information currently classified as proprietary in Section 4.2 in WCAP-14750. The revised procedure described in the response to Question 1, however, is new information. which has not yet been presented, and is being

. classified- as . proprietary. Other information in WCAP-14750 which .

was classified as proprietary will not be reclassified.

RAI.#3, Question'4:

WCAP-14750 Figure 4-1 indicates that four taps (including three low pressure taps and one common high pressure tap) are utilized for the RCS. loop flow transmitters. Table A-4 indicates that there are 2 " taps per loop". 'The Farley TS Bases 3/4.2.5 markups in Appendix C indicate that. indicated total flow rate ' is based on "Two elbow

-tap measurements" from each loop. Clarify how many taps. are

assumed in L the uncertainty analysis associated with the indicated

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i RCS total flow measurement and make appropriate modifications to i the term."two taps" for clarification. l RAI #3, Response 4:

The RCS flow . uncertainty calculations were. performed presuming two ,

out of three RCS flow channels per loop are available for averaging. TableL A-4 in WCAP-147E' will be modified to state

" Number of Channels per Loop." Add _.lonally, the Farley TS Bases 3/4.2.5 (first paragraph, last sentence) will be modified to state "The indicated total RCS flow rate is based on a measurement  !

. utilizing two indication channels per loop and an uncertainty of .

2.4% ' flow :(0.1% flow is included for feedwater venturi fouling) . " l The technical specification mark-ups provided as Attachment 1 in WCAP-14750will.perevisedtoreflectthischange.

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