ML20203A569

Requests That Proprietary Presentation Matl from Incomplete Rcca Insertion Resolution at Stp,Be Withheld from Public Disclosure,Per 10CFR2.790(b)(4)

ML20203A569
Person / Time
Site:	South Texas
Issue date:	01/25/1999
From:	Sepp H WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	Collins S NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20136E850	List: ML20203A569 NOC-AE-000422, Forwards Proprietary & non-proprietary Presentation Matl from 990126 Meeting Re Incomplete Rcca Insertion Resolution at Stp.Proprietary Info Withheld,Per 10CFR2.790(b)(4)
References
CAW-99-1317, NUDOCS 9902100034
Download: ML20203A569 (32)

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Westinghouse CommercialNuclear PO Box 355 Electric Corporation FuelDivision Pinsburgh Pennsy!vania 15230 0355 January 25,1999 CAW-99-1317 Document Control Desk US Nuclear Regulatory Commission Washington, DC 20555 Attention:

Samuel J. Collins, Director Office of Nuclear Reactor Regulation APPLICATION FOR WITIlllOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

Presentation Material from IRI Resolution Meeting (Proprietary)

Dear Mr. Collins:

The proprietary information for which withholding is being requested in the above-referenced report is further identified in AfTidavit CAW-99-1317 signed by the owner of the proprietary infonnation, Westinghouse Electric Company. 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 2.790 of the Commission's regulations.

Accordingly, this letter authorized the utilization of the accompanying Affidavit by South Texas Project Nuclear Operating Company.

)

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-99-1317, and should be addressed to the undersigned.

Very truly yours, II. A. Sepp, Manager Regulatory and Licensing Engineering Enclosures cc:

T. Carter, NIUUDISP (SE7)

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9902100034 990202 PDR ADOCK 050004 P

I Proprietary Information Notice Transmitted herewith are proprietary and/or non-proprietary versions of documents fumished to the NRC in connection with requests for generic and/or plant-specific review and approval, In order to conform to the requirements of 10 CFR 2.790 of the Commission's regulations conceming the protection of proprietary information so submitted to the NRC, the infonnation which is proprietary in the proprietary versions is contained within brackets, and where the proprietary infoimation 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 1

designated as proprietary is indicated in both versions by means oflower case letters (a) through (f) located i

as a superscript immediately following the brackets enclosing each item ofinformation 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) 1 of the affidavit accompanying this transmittal pursuant to 10 CFR 2.790(b)(1).

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Copyright Notice The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies for the infonnation contained in these reports which are necessary for its intemal 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, pemiit, order, or regulation subject to the requirements of 10 CFR 2.790 regarding restrictions on public disclosure to the i

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 these necessary for its intemal 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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I CAW-991317 l

t AFFIDAVIT '

COMMONWEALTII OF PENNSYLVANIA:

i ss COUNTY OF ALLEGIIENY:

j Before me, the undersigned authority, personally appeared IIenry A. Sepp, who, being by me duly swom according to law, deposes and says that he is authorized to execute this Amdavit on behalf of Westinghouse Electric Company (" Westinghouse") and that the averments of fact set forth in this Amdavit are l

true and correct to the best of his knowledge, information, and belief; d.

IIenry A. Sepp, Manager Regulatory And Licensing Engineering Sworn to and subscribed be me this A_fxg(. day-o' s_ve M

,1999.

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Notary Pubh;c L%u,V utatakwnnt ukser, s-s l

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- CAW-99-1317 (1)

I am Manager, Regulatory and Licensing Engineering, in the P O ar Services Division, of the Westinghouse Electric Company and as such, I have been specscally delegated the function of reviewing the proprietary information sought to be withheld from p;blic disclosure in connection with nuclear power plant licensing and miemaking proceedings, and am authorized to apply for its withholding on behalfof 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 Commission's regulations and in conjunctien 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 t

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 Commission's regulations, the following is fumished for consideration by the Commission in detennining 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 detennine 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 ifit 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 fmm 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.

I (c)

Its use by a competitor would reduce his expenditure of resources or improve his

I 1 CAW-99-1317 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 ofpotential commercial value to 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 seli products and senices 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.

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i (d)

Each component of proprietary information pertinent to a particelar 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.

}

" CAW-99-1317 (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.

(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 submitta! is that which is appropriately marked in " Presentation Material from IRI Resolution Meeting" (Proprietary), for information in support of South Texas Project Nuclear Operating Company's submittal to the Commission, transmitted via STP Nuclear Operating Company letter and Application for Withholding Proprietary Information from Public Disclosure, II. A. Sepp, Westinghouse, Manager Regulatory and Licensing Engineering to the attention of Samuel J. Collins, Director, Office of i

Nuclear Reactor Regulation. The proprietary information was provided by Westinghouse Electric Company, This infonnation is part of that which will enable Westinghouse to:

(a)

Improve fuel performance.

(b)

Assist its customer to obtain license.

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!! CAW-99-1317 f

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I-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 ofimproving fuel performance.

1 (b)

Westinghouse can use this information to further enhance their licensing position with their competitors.

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Public disclosure of this proprietary information is likely to cause substantial harm to the i

competitive position of Westinghouse because it would enhance the ability of competitors to i

provide similar licensing senices for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information I

' 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 effbrt and the expenditure of a I

considerable sum ofmoney.

l i-l In order for competitors of Westinghouse to duplicate this information, similar technical programs l

would have to be performed and a significant manpower effort,' having the requisite talent and experience, would have to be expended for developing the enclosed information.

j Farther the deponent sayeth not.

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NOC-AE-00422 Page 1 of 24 i

I ATTACHMENT 3 Presentation Material From Incomplete RCCA Insertion Resolution Meeting (Non-Proprietary) l I

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1 Incomplete RCCA Insertion l

Resolution at South Texas Units 1 & 2 l

I Presentation to the USNRC January 1999 L

4 Agenda tu

• XL Fuel Product Summary

• XL IRI Experience Summary

+ South Texas PIE Results

• Mechanical Analysis

- AMP Code - Span Bow Model

- FEM Analysis - Assembly Dashpot Bow Model

. South Texas Fuel Analysis

- XLIXLR & V5H l

- Improved Fuel Designs l

• IRI Susceptibility Thresholds 1

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14 Ft Fuel Product Summary A

= XL-Inconel Grids (10)

= XLR - same as XL but with removable top nozzles, debris filter bottom nozzles and high burnup capability XL-V5H - same as XLR but with low pressure a

drop Zirc mid-grids XL-V5H-P+ - same as XL-V5H but with ZlRLO

=

fuel cladding, grids, thimble tubes and Protective bottom grids

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XL RFA - same as V5H-P+ but with thicker thimble tubes, improved dashpot design and modified low pressure drop mid-grids

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14 Ft Fuel Product Summary

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XL Fuel Experience With IRI A

Max #

Burnup

$[,

Ran e Cause Plant Date gw9,u) her test)

South Texas 1 12/95-5/96 11 32-50 Double Dashpot GT-1/97-9/97 7

26-37 Excessive GT Bow South Texas 2 2/97 5

40-53 Double Dashpot GT-10/98 1

32 Excessive GT Bow DoelIV 6/96 5

29-33 Double Dashpot GT -

6/97 9

12-23 Excesel T& Assy EdF XL Plants 10/95-1/97 4-20 28-36 Double Dashpot GT-Excessive GT & Assy Excessive Assembly Tihange 3 4/98 4

l 12-15 15-20 Bo*

8/98 5

XL 1RI Experience at South Texas A

• IRlin 2 or 3 times burntfuel Lowest burnup threshold for IRI - 26000 MWD /MTU

• Stuck position is typically 6-12 steps from fully inserted

• Fuel assembly bow small to moderate

• RCCA drag is almost entirely in the dashpot spans l

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South Texas PIE Database to

• OriginalIRI Exam

-19 Fuel Assemblies examined (XLR)

Assy growth on all

• Drag on 14 Assembly bow on 4 August 1998 Fuel Exam j

- 19 Fuel Assemblies examined (XLR & V5H)

. Assy growth on 12

• Drag on 13

• Assembly bow on 16 (1 repeat assembly)

Key Findings from PIE Exams (Q

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Assembly Bow Measurement Results A

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Drag Measurement Results A

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D ag-Work Definition f

Drag Measurement Results to g

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Mechanical Analysis Overview IO

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1 tm>Wouse Paputwy Dans 3 Thimble tube distortion I4 Epan Bow &@

DashDol AS. 'mblV 1

Span Bow Only Bow Only Dashoot Assembly l

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Span Bow Model tu Span Bow Model(coneo)

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.1 Span Bow Model(conta)

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AMP Growth Predictions

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I Span Bow Model Application (Q

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was 10

Modeling Uncertainties A

Assembly Bow Modeling A

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Dashpot Assembly Bow Assessment IO Dashpot Assembly Bow Model A

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Model Application to South Texas I4 W PmPastWV Que 3 i

As-built Span Bow Distiibution (4

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Dashpot Assembly Bow Effect (Q

Dashpot Assembly Bow Effect tu h

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..s-a-<.-s-a Dashpot Assembly Bow Range IO

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Total Drag Work Results (4

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15

improved-Design implementation A

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. Approach for IRI mitigation

-Introduce already developed fuel i

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features to mitigate future Iris CO Lower holddown forces

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• IFMs Q.

• ZlRLO P-Grids N - Robust Fuel-Increase thimble tube g

strength for17x17 Fuel Design (U

Thicker thimbles

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• New dashpot design (XL only)

Fuel Improvements - Phase 1 A

. ZlRLO Skeleton P-grids / rods on bottom

. Loaded in ST Unit 1 - Fail 97 Same product Loaded into DOEL 4

- 1st cycle operation from 7/97-7/98

- Reduced bow and drag observed

- 2nd cycle currently in operation i

1 16

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Improved-Design implementation IO

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Drag Work Database t4

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improved-Design lmplementation A

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es Improved-Design implementation A

l tesorgheme Papsenwy Gass 3 18

Fuel Improvements - Phase 2 R

1

+ Thicker Guide Thimble

• New Dashpot Design

. Modified bottom grid and P-grid r

attachment New mid-Grid Design

. Optimized bulgejoint

. Loaded in ST Unit 2 - 10/98 Loaded in DOEL 4 - 7/98 XL Guide Thimble Design Comparison 8,C,

M 19

GT Strength Comparison R

1 Model Application to New Designs Ow

..g unawqpene Pupnetary Osas 3 20 j

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I Span Drag Predictions t

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Span Drag Predictions t4 e % =>

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Span Drag Predictions A

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w w us Assembly Bow Effect A

i Advanced designs are less j

susceptible to assembly bow

- Less growth due to ZlRLO thimble tubes (50% of Zr-4) (both designs)

)

- Less creep due to ZlRLO (80% of Zr-4) j (both designs)

- Stiffer thimble & dashpot spans due to thicker thimble tube and separate dashpot tube (Robust Design only)

~ % ->

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Total DragWork Results A

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. Qass 3 IRI Burnup Thresholds for XL Fuel

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i Susceptibility thresholds Assembly Average for XL, XLR and V5H fuel

""'"$$$*u"['

• should be unchanged Zr-4 ZlRLO V5H-P+ fuel threshold

+

"^

conservatively set as 30000 MWD /MTU V5H 25000 NA V5H-P+

NA 30000 No threshold needed for RFA NA

-57006 C the Robust Fuel Design up to the licensed lead rod burnup limit W Nueswy Ossa 3 i

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