ML20202H900
| ML20202H900 | |
| Person / Time | |
|---|---|
| Site: | 05200003 |
| Issue date: | 02/13/1998 |
| From: | Mcintyre B WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | Quay T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19317C869 | List: |
| References | |
| AW-98-1204, NUDOCS 9802230042 | |
| Download: ML20202H900 (17) | |
Text
{{#Wiki_filter:. 3;. Nestinghouse Energy Systeins Ba 355 Electric Corporation PintNgh Pemsylvania 15230-0355 AW-981204 February 13, 1998 Document Control Desk "U.S. Nuclear Regulatory Commission Washington, DC 20555 ATFENTION: MR. T. R. QUAY APPLICATION FOR WITilllOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE e SUlUECT: AP600 RESPONSE TO FSER OPEN ITEM 440.739R
Dear Mr. Quay:
The application for withholding is submitted by Westinghouse Electric Company, a division of CBS Corporation (" Westinghouse"), pursuant to the provisions of paragraph (b)(1) of Section 2.790 of the Commission's regulations. It contains 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 10CFR Section 2.790, Affidavit AW-98-1204 accompanies this application for withholding setting forth the basis on which the identified proprietary i 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 10CFR Section 2.790 of the Commission's regulations. Correspondence with respect to this application for withholding or the accompanying affidavit should reference AW-98-1204 and should be addressed to the undersigned. Very truly yours, 8:~A # Brian A. McIntyre, Manager Advanced Plant Safety and Licensing jml cc: Kevin Bohrer NRC OWFN - MS 12E20 ~ 9902230042 990213 PDR ADOCK OS200003 PDR E,.m.g
4 AW-98-1204 AFFIDAVIT COMMONWEALTil OF PENNSYLVANIA: ss I l COUNTY OF ALLEGilENY: l l Before me, the undersigned authority, personally appeared Brian A. McIntyre, 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, a civision of CBS Corporation ("Westinghou;e"), and that the avennents of fact set forth in this Affidavit are true and correct to the best of his knowledge,- infonnation, and belief: 0AYh r Brian A. McIntyre, Manager Advanced Plant Safety and Licensing Sworn to and subscribed before me this A 3 2. 4, day of ,1998 , ~ ~~~[ ,.,.f - ~~ ~ ~~ ~ l t _n u m, u n u ! um 7, / r GMil" pol i, -{ f L-y._ ,j / s ~ I /, p e.Nr.fe.ng,;w A4;u.s sit.J:E Notary Public wo..,e - a
AW 981204 (1) I am Manager, Advanced Plant Safety And Licensing, in the New Plant Projects Division, of ,the Westinghouse Electric Company, a division of CBS Corporation (" 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 rulemaking proceedings, and am authorized to apply for its withholding on behalf of the Westinghouse Energy Systems Business Unit. (2) I am making this Affidavit in conformance with the provisions of 10CFR Section 2.790 of the Commissic.n'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 Energy Systems ilusiness Unit in designating informatioa as a trade secret, privileged or as confidential commercial or financial information. (4) Pe~uant to the provisions of paragraph (b)(4) of Seccion 2.790 of the Commission's regutations, 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 nas a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required. Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows: %i64,vpf
AW-981204 (a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghoust. > competitors without license from Westinghouse constitutes a competidve economic advantage over other companies. (b) It consists of supporting data, including test data, r-Wye 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, chipment, installatimi, assurance of quality, or licensing a similar product. (d) It reveals cost or price information, production capacities, budget levels, or commercial crategies of Westinghouse, its customers or suppliers. (c) 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. There are sound policy reasons behind the Westina, house 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. un. nr
AW-98-1204 (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 vrJuable 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 compe:ition of those countries. (l) 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 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. (v) Enclosed is Letter DCP/NRCl256 (NSD-NRC-98-5570), February 13,1998, being transmitted by Westinghouse Electric Company @), a division of CBS Corporation (" Westinghouse"), letter and Application for Withholding Proprietary Information from Public Disclosure, Brian A. McIntyre (lV), to Mr. T. R. Quay, Office of NRR. The proprietary information as submitted for use by Westinghouse Electric Company is in response to questions concerning the AP600 plant and the associated design certification application and is expected to be applicable in other licensee submittals in response to certain NRC requirements fcr justification of licensing advanced nuclear power plant designs. %,..g 1 _J
AW-98-1204 This information is part of that which will enable Westinghouse to: (a) Demonstrate the design and safety of the AP600 Passive Safety Systems. (b) Establish applicable verification testing methods. (c) Design Advanced Nuclear Power Plants that meet NRC requirements. (d) Establish technical rrd licensing approaches for the AP600 that will ultimately result in a certified design. (c) Assist customers in obtaining NRC approval for future plants. Further this information has substantial e-~mercial value as follows: (a) Westinghouse plans to sell the use of similar information to its customers for purposes of meeting NRC requirements for advanced plant licenses. (b) Westinghouse can sell support and defense of the technology to its customers in the licensing process. 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 : ar advanced nuclear power designs and licensing defense services for commcreial 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. na..g
AW-98-1204 4 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 effon, having the requisite talent and experience, would have to be expended for developing analytical methods and receiving NRC approval for those methods. Further the deponent sayeth not. I ww.pr
ENCI.OSURE 2 TO DCP/NRCl256 NON-PROPRIETARY COPY OF FSER OPEN ITFM 440.739R I unsa sst
NRC FSER OPEN ITEM Questloh 440.739F tOITS. 6449) In the review of the approved methodology, Westinghouse provided a detailed evaluation of t compensating errors in WCOBRA/ TRAC as applied to three and four loop plants. In general, the staff considers that evaluation applicable to the AP600 analysis because of: (a) the similarity of the AP600 and three-and four loop plant _LBLOCA responses; (b) the AP600 specific assessments for DVI showed that WCOBRA/ TRAC gave conservative estimates of ECC bypass and core cooling; and (c) while AP600 has better Nowdown cooling than three and four loop plants, the global model run matrix ranges the calculated blowdown PCT and cooling, flowever, Westinghouse needs to supply data and/cr analysis to support the above arguments. Alternately, Westinghouse could clarify and justi'y how it addresses the issue of compensating errors in the AP600 LBLOCA b tes estimate methodology.
Response
Aa evaluation of the compensating errors in the WCOBRA/ TRAC best estimrae methodology as applied to the analysis of the AP600 large break LOCA transient is presented,a this response. Subsections sh, en correspond to the FSER 01 statement. (a) As identified in Reference 440.739F 1, the important phenomena for an AP600 large break LOCA transient (Reference 440.739F T) are similar to those for the three and four loop plant designs. In the initial seconds of the blowdown core cooling is provided by flow in the normal operation (positive) direction up through the fuel; the coic flow then changes direction,' and cooling is provided by downflow from the upper plenum toward the DECLG break during the remainder of blowdown. The - cladding temperature increases to a peak during the blowdowa, then decreases in both three and four-loop plant and AP600 analyses; the magnitude of the core flow determines the heat transfer present during the blowdown, and therefore the PCT transient. At the end of blowdown a second heatup begins; it continues until the core has been reflooded to an adequate level to provide the heat transfer necessary to terminate the cladding temperature increase. 'The AP600 exhibits its reflood PCT peak relatively early in the reflood phase of the large LOCA transient. This is similar to the performance observed in other WCOBRA/ TRAC analyses (such as the four-loop,17XI7 fuel plant reference transient shown in Figure 440.739F-1) in which the peak reflood PCT value occurs within the first 100 seconds of the DECLG break. Phenomena imponant to core cooling and to the cladding temperature response (break discharge coefficient, broken loop resistance, and condensation efficiency in the vessel downcomer) are considered in a global model matrix of cases, which is the same in both the three-and four loop plant and AP600 uncertainty methodologies. (b,c) For these items, Westinghouse has individually considered the existing 3 and 4-loop plant compensating error evaluations and assessed the similarity of AP600 behavior with the 3 and 4 loop plant evaluations: 440.739F-1 T Westinghouse s- .-.i-c~e, n.r - e n. 4
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NRC FSER OPEN ITEM Post-CllF'lleat Transfer: ORNL Tests t Section 4.2 of Reference 440.739F-1 prezents ECOBRA/ TRAC simulations of the ORNL high pressure f;1m boiling tests based on a minimum film boiling temperature (Tmin) of ( }". For AP600, the ORNL tests provide film boiling data in the appropriate range and constitute the basis for l post CllF blowdown heat transfer. De code prediction of the ORNL tests defines the AP600 I blowdevn heat transfer uncertainty distribution used in llOTSPOT. ECOBRA/ TRAC predicts the correct trends and magnitudes for the observed heat transfer, and it predicts heat transfer coefficients which agree well with the average data values (Reference 440.739F 1, Figure 4.2-1). ne vapor temperatures at the top of the bundle calculated by ECOBRA/ TRAC are compared with the data estimates in Reference 440.739F 3 in the 014674 response. He comparisons show that the code tends to underpredict the vapor superheat. Because the " experimental" vapor superheats are derived quantities (there were no vapor fraction or steam temperatutt measurements in the tests), there is considerable uncertainty in the values. He conclusion that can be reached is that ECOBRA/ TRAC accurately pre &is the location at which dryout occurs and superheated steam is found in these tests. Consistent with the good to low prediction of the vapor temperature, the predictions of heat transfer coefficients for these tests are good to slightly high. There is no evidence of compensating errors in these ECOBRA/ TRAC predictions. To be consistent with the 3 and 4-loop plant methodology, the lower bound [ ]"is used as the Tmin value during blowdown in the hot spot uncertainty calculation. His ensures that the hot spot will be prevented from rewetting for transients in which cladding temperature approaches best estimate values of Tmin. FLECliT Reflood Tests Cold temperature reflood tests were simulated in Reference 440.739F-1, Section 4.3, to assess the ECOBRA/ TRAC heat transfer mcdel for the ' cold" initial fuel temperatures associated with AP600 reflood heat transfer. De frequency distributions of the heat trans er multipliers obtained for the two r comparisons is Fhown in Figure 1 of the Reference 440.739F 3 response to OITS 4678. The multiplier range extends to a ( ]". ne base distribution was retair.ed in the AP600 mcthodology for conservatism, as discussed in Reference 440.739F-3. Therefore, the heat transfer coefficient values that contribute to the 95th percentile reflood PCT value are taken from the 3 and 4-loop plant distritution, and the compensating error evaluations relative to AP600 reflood heat transfer are covered by the Reference 440.739F-4 assessment of the FLECIIT test simulations. No further evaluation is needed for the AP600 application. 440.739F 2 3 Westingh0USS
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- %.jj NRC FSER OPEN ITEM i
SdTF Five SCTF tests were analyzed with ECOBRA/ TRAC to provide a separate assessment of the code E.at transfer models independent of the FLECllT Test simulations. Within the core itself, the reflood heat transfer behavior of the fuel rods is independent of the ECC injection location. Derefore, the SCTF core reflo(xi heat transfer evaluation of Reference 440.739F-4, as augmented in References 440.739F-5 and 6, also applies to the AP600 methodology; no evidence of compensating error was found in the evaluations of the SCTF simulations. ECC Bypass / Condensation: De Upper Plenum Test Facility (UlrrF)is a full-scale model of a PWR primary circuit that provides experimental data on multi dimensional flow in a PWR. Among the UFFF tests, phase A Run 272 and phase B Run 274 of Test 21 simulated ECC delivery to the vessel via the downcomer injection ports; other tests, including Test 6, were performed with cold leg injection of ECC water. Analyses of UPTF Tests 6 and 21 with ECOBRA/ TRAC are presented in the Reference 440.739F-7 RAll 238 response and are assessed in Reference 440.739F-4. These assessments [ ]" conclude that significant compensating errors do not exist in this area. He AP600 is equipped with direct vesselinjection. In the Reference 440.739F 8 response to RAI 440.348,[ ]" concludes that the code models the phenomena occurring during Test 21 well. It was concluded that the code provides a reasonable prediction of flooding in the vessel downcomer, with a tendency to underpredict the liquid penetration rate. Because the AP600 is equipped with direct vesselinjection, the downcomer region of the VESSEL component in the ECOBRA/ TRAC model is the important condensation location. He Reference 440.739F-4 assessment refers to the simulation of UlrrF Test 6 with four azimuthal channels.;.nd the simulation of UPTF Test 21 with six azimuthal channels. For Test 21, the downcomer injection test, .ECOBRA/ TRAC predicts the condensr/ ion phenomena occurring in the downcomer reasonably well, well enough that when six azimuthal ucces are modeled the onset of lower plenum water der.ry is predicted well. Bis evaluation of the Test 21 prediction supports the conclusion of Reference 440.739F-4 that no significant compensating errors exist in the ECC bypass / condensation modeling. Blowdown / Post Blowdown Thermal-1-lydraulics/Entrainment: LOFT Tests ne compensating error assessments presented in Reference 440.739F-4 and 5 for the LOFT Test L2-3 and LOFT Test L2-5 integral tests remain applicable to the AP600 methodology. The reference w weseneous. 44.7 9F-3
y tiij NRC FSER OPEN ITEM evaluations provide confidence that compensating errors do not exist n the LOFT facility test simulations. This evaluation also indicate 1 that relative Dows througl. the broken loop are an important contributor to unceisainty; this uncertainty is considered in the gicbal model run matrix performed for AP600 (Reference 440.739F-1. Table 4.5-1). CCTF Test 58 CCTF Test 58 is a grav' y xuood test with initial system pressure at 29 psia canducted at the CCTF Test Facility usin;, dire. v:ssel injection. To support the AP600 application. : was nm: ;ated with ECOBRA/ TRAC in Reference 440.739F-1. He PCT behavior of CCTF Run 58 is comparable with the CCTF Tests with which ECOBRA/ TRAC is compared in Reference 440.739F-9. A= 4 tme in those cold leg injection C'.'TF Test simulations (Runs 62, 63,64,67, and 75), ' - e vere overpredicted by the code at the 6,8, and 10 ft. core elevations. De averar ~ ~ an 58 is similar to that of the origina; tests (Reference 440.739F-1 Table 3.1-5) A' cont:rvative cladding temperature predictions obtained for CCTF Test 58 in ... the vapor temperature is being predicted reasonably. i .]". Ae was concluded for the CCTF Test 62 simulation, compensating errors are not significant in the Test 58 ECOBRAfrRAC simulation.
== Conclusions:== The assessments provided above augment those in Refe.ence 440.739F-5 in providing conGdence that no compensating errc.: exist which might serioedy compromise the ability of ECOBRAffRAC to 440.739F 4 3 W85tingh005d Th 7/
!i'P 'in NRC FSER OPEN ITEM M ?N pedict conditions during AP600 large break LOCA esents. The AP600-related additionalinformation herein is: During the ORNL steady-state film boi'ing test predictions, noncquilibdum vapor conditions are 1. predicted as has been observed experimentally. This provides confidence that an important component of the heat flux model, tl.e vapor heat sink, is predicted properly. While differer.ces exis' between the predicted and measured values, these differences are captured in the heat flux uncertainty which is applied in the overall uncertainty analysis. 2. He validation of the CCFL model by the simulation of UPfF Test 21, considering effects of condensation, demonstrates that compensating errors do not exist in the prediction of ECC bypass for the direct vessel injection geometry.
- 3. The detailed analysis of CCTF Test 58 indicates that the thennal hydran'
. pense of the core to h loop flow is proper, and not the result of a compensating error. He evaluation of compensating errors, which was previously performe6 in References 440.739F-4 through 6, has been extended to address AP600-specific modeling base. WCOBRAffRAC is shown to be acceptable for the best-estimate analysis of the AP600 large break uOCA event, as it is for 3-and 4-loop plant applications l
References:
3 440.739F-1 Hochreiter, L. E. et al, "WCOBRA/ TRAC Applicability to AP600 Large-Break Loss-of-Coolant Accident," WCAP-14171, Revision 1. Proprietary, October 1996. 440.739F-2 AP600 Standard Safety Anah sis Report. Revision 13, Subsecuan 15.6.5.4A, May 30, 1997. 440.739F-3 Letter from B. A. McIntyre, Westinghouse, to T. R. Quay, USNRC, NSD-NRC 5171, June 10,1997. 440.739F-4 Letter from N. J. Liparulo, Westinghouse, to R. C. Jones, Jr., USNRC, " Assessment of Compensating Errors in WCOBRAffRAC," NE-NRC-95-4586, November 3,1995. 440.739F-5 Letter from N. J. Liparulo, Westinghouse, tc USNRC Document Control Desk, " Docketing of Supplemental Information Related to WCAP-12945-P," NSD-NRC 4702, Attachment 1 April 30,1996. I W Westinghouse 410.739F-5 l l
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} 440.739F-s Letter from N. J. Liparulo, Westinghouse, to USNRC Document Control Desk, " Preliminary R:sponses to Requests for Additional Information Regarding WCAP-12945 P and the Revised Muhodology Report," NTD-NRC-95-4599, November 22,
- 1995, i
440.739F-7 Letter from N. J. Liparuto, Westinghouse, to USNRC Document Control Desk.. -Prelimine.ry Responses to Requests for Additional Information Regarding WCAP-12945-P," ifrD-NRC-95-4511 (Attachment 00), July 19,1995. 440.739F 8 Letter from B. A. McIntyre, Westinghouse, to T. R. Quay, USNRC, " Westinghouse Responses to NRC Requests for Additional Information on the AP600, NTD-NRC, l 4598 (DCP/NRC0423), November 17,1995. 440.739F 9 - Bajorek, S. M et al, " Code Qualification Document for Best Estimate LOCA Analysis, {' Volumes 1 through 5," WCAP-12945-P, Proprietary,1992 and 1993. I SSAR Revision: None h !~ P 44#'" W westinghouse
ijjii 'ljil NRC FSER OPEN ITEM i i 0 j' ^i o 4 W Westinghouse 440.739F-7 m-
NRC FSER OPEN ITdM JTlWil =$$'ih Ufd 2000 l W t. l 1500 I m u. L v c 6 j 1000 l o 1. u l-e c. E o. l f-- 500 e e i e e e i i 0 ,ie e 0 5'O 100 150 2$0 200 300 Time (S) FIGURE 440.739F.1: WCOBRAfrRAC Reference PCT Transient for an Operating Four Loop Plant [ Westinghouse 440.739F-7
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