ML20203C731
| ML20203C731 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 01/27/1999 |
| From: | Sepp H WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | Collins S NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20136F258 | List: |
| References | |
| CAW-99-1314, NUDOCS 9902120206 | |
| Download: ML20203C731 (18) | |
Text
_ -,
N 3
l Wesbnghouse Electric Company,.
Box 355 l
adivision of CBSCorporabon PittsburghPennsylvania 15230 4 355 January 27,1999 i
i CAW-99-1314 i
Document Control Desk i
~ U.S. Nuclear Regulatory Commission -
l Washington,DC 20555 i
Attention: Mr.SamuelJ. Collins l
l l
APPLICATION FOR WITHHOLDING PROPRIETARY I
INFORMATION FROM PUBLIC DISCLOSURE i
Subject " Responses to lhird Round NRC Request for Additional Information (RAls) on South Texas Project Elbow Tap Submittal"
)
Dear Mr. Collins:
i t
The proprietary information for which withholding is being requested in the above-referenced report is
)
l further identified in Affidavit CAW-99-1314 signed by the owner of the proprietary information, l
Westinghouse Electric Company, a division of CBS Corporation (" Westinghouse"). 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 (bX4) of 10 CFR Section 2.790 of the Commission's regulations.
Accordingly, this letter authorizes the utilization of the accompanying Aflidavit by South Texas Project Nuclear Operating Company.
Cormspondence with respect to the proprietary aspects of the. application for withholding or the Westinghouse affidavit should reference this letter, CAW-99-1314, and should be addressed to the undersigned.
l Very truly yours, H. A. Sepp, Manager Regulatory and Licensing Engineering Enclosures cc: T. Carter /NRC (SE7) 9902120206 990204 I
PDR ADOCK 05000498N P
PDR b 2130A-sA-l:l/21/99
--.a.-.
w v-
CAW-99-1314 r
AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
sS COUNTY OF ALLEGHENY:
i
)
l l
1 l
l Before me, the undersigned authority, personally appeared Henry 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, a division of CBS Corporation (" Westinghouse"), and that the l
averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, i
information, and belief:
i A
Henry A. S(epp, Ma/ / g/
nager l
Regulatory and Licensing Engineering Sworn to and subscribed befo e this A 7 day os M
1999
/ -
f
/ d h J E I:: k $ n
[
Notary Public
'#"'"A* A8*unon or q i
2782C4JA-l$90398
- - CAW-99-1314 l
l (1)
I am Manager, Regulatory and Licensing Engineering, in the Nuclear Services Division, of the 1
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 Commission's regulations and in conjunction with the Westinghouse application for withholding accompanying this Affidavit.
1 (3)
I have personal knowledge of the criteria and procedures utilized by the Westinghouse Energy Systems Business Unit 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 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 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 competitive advantage, as follows:
2131 A-J AS-2 Sil599
. _... _._. _ _. _ _.. _.. _ _.~. _._ _.
-___ _.. CAW-99-1314 (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 constitutes a l
competitive economic advantage over other companies.
i (b)
It consists of supporting data, including test data, relative to a process (or i
camponent, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved i
L marketabilitv.
i l.
(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.
l (d)
It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.
l 1
i l
i l
(e)
It reveals aspects of past, present, or future Westinghouse or customer funded I
development plans and programs of potential commercial value to i
1 l
(f)
It contains patentabic ideas, for which patent protection may be desirable.
Taere are sound policy reasons behind the Westinghouse system which include the following:
(a.-
The use of such information by Westinghouse gives Westinghouse a j
competitive advantage over its competitors. It is, therefore, withheld from l
l i
l disclosure to protect the Westinghouse competitive position.
1 1
(b)
It is information which is marketable in many ways. The extent to which such j
l information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.
i i
2131 A-JAS-3.Oll599
~
i 4-CAW-99-1314 l
l (c)
Use by our competitor would put West.N house at a competitive disadvantage -
by reducing his expenditure of resources at ccr 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, j
(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 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.
l (v)
The proprietary information sought to be withheld in this submittal is that which is appropriately marked in " Responses to Third Round NRC Request for Additional Information (RAls) on South Texas Project Elbow Tap Submittal" (Proprietary),
January,1999 for the South Texas Project transmitted by the South Texas Project i
l Nuclear Operating Company letter and Application for Withholding Proprietary
}
Information from Public Disclosure, to the Document Control Desk, Attention Mr.
Samuel J. Collins. The proprietary information as submitted for use the South Texas I
2131 A-JAS40ll599 I
l
_ _. _ _ _ _ _. _ _. _ _ _. _ _ _. _. _ _ _ _.. _. _ _. _. _. _ _ _ _. CAW-99-1314 Project Nuclear Operating Company for the South Texas Project Nuclear Power Plants is expected to be applicable its other licensee submittals in response to certain NRC requirements forjustification of use o RCS flow verification using elbow taps.
r This information is part of that which will enable Westinghouse to:
(a)
Provide elbow tap methodology.
)
(b)
Establish appropriate instrument uncertainties associated with elbow tap measurements.
l 1
J (c)
Assist the customer to obtain NRC approval.
i Further this information has substantial commercial value as follows-i (a)
Westinghouse plans to sell the use of similar information to its customers for purposes of meeting NRC requirements for licensing documentation.
(b)
Westinghouse can sell support and defense of the technology 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 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 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 effort and the expenditure of a considerable sum of money.
213tMAS 5211599 1
w
-~.
CAW-99-1314
)
In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be per'ormed and a significant manpower effort, having the requisite talent and expe:ience, would have to be expended for developing testing and analytical methods and performing tests.
Further the deponent sayeth not.
i j
l j
l l
l I
l l
l l
l l
201 AJAS4:0!!$99
i 1
ATTACHMENT 4 l
Response to Request for Additional Information (July 29,1998) 1 NON-PROPRIETARY i
4 4
4
l WESTINGHOUSE NON-PROPRIETARY CLASS 3
)
l RESPONSE TO THIRD ROUND NRC REQUEST FOR ADDITIONAL INFOR.MATION ON SOUTH TEXAS PROJECT ELBOW TAP SUBMITTAL January 1999 l
)
i i
I i
WESTINGHOUSE ELECIRIC COMPANY Nuclear Service Division P. O. Box 355 Pittsburgh, Pennsylvania 15230-0355
@ 1999 Westinghouse Electric Company 4
l l
t
RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION 1.
Section 3.4.2, Elbow Tap Flow Measurement Procedure, of Attachment 5 of the August 6, 1997, submittal defines the baseline elbow tap flow coefficient (B) and the future cycle elbow tap flow coefficient (K) as the elbow tap AP (inches water) multiplied by the cold leg water specific volume (v).
- a. The use of the terminology " flow coefficient" to define the AP measurement values is very j
coruusing because the elbow tap " flow coefficient" normally refers to the constant C in the elbow tap equation, O = C (AP)'", whereas AP is a variable as a function of volumetric flow
{
rate O. For example, in the September 18,1997, response to Questions 5 and 30 regarding the need to provide the values of correlation coefficients for each of the three elbow taps in each loop, it says that flow coefficients for each elbow tap measurement are not necessary. It j
is not clear whether the " flow coefficients" here refers to the term "AP x v" or the " correlation coefficient K" referred to in Question 30. Please clarify the confusion, and, if necessary, use I
an alternate terminology, other than flow coefficient, to define "AP x v."
Response 1a:
As shown in the publication "ASME Fluid Meters, Sixth Edition" the elbow tap volumetric flow equation includes a density term, i.e., O = C (AP/p)'", where AP (psi) is at the fluid temperature, and p corrects for the change in AP with temperature at a constant volumetric flow. The elbow tap d/p transmitters are calibrated in inches of water at ambient temperature, which is equivalent to AP at any temperature. Since the Elbow Tap Flow Measurement Procedure uses the elbow tap d/p transmitter output to define relative rather than absolute flow, inches of water is equivalent to psi. Converting the measurements to psi would not change the results. Both density (specific volume) and AP (inches, equivalent to psi at fluid temperature) are considered when determining volumetric flow.
The Elbow Tap Flow Measurement Procedure uses the term VAP (AP in inches of water) to characterize the relative flow performance at the beginning of a fuel cycle. The Procedure uses the terminology " flow coefficient" for this term, because the terms for a future cycle and the baseline cycle define the change in flow rather than an absolute flow. Since the Procedure clearly defines these terms, there will not be confusion in their application at the site.
The equation in the Procedure for calculating future cycle flow is FCF = BCF x ((v AP) / (vdAPe))'" = BCF x (K / B)i/2 where FCF = future cycle flow, BCF = baseline flow, K = future cycle flow coefficient, B =
baseline cycle flow coefficient, and (K / B)'" is the ratio of future cycle flow to baseline cycle flow. As stated above, AP is in inches of water. This equation is equivalent to the "ASME Fluid Meters" equation (O = C (vAP)'#) when one defines C = ( BCF / (v ape)'" ) where C o
represents the baseline cycle measurements. The Procedure equation is felt to be a better representation of the process.
Conceming the response to Questions 5 and 30, the " flow coefficient" is the term (vaP) which equals B for the baseline cycle or K for a future cycle. The terminology " flow coefficient" is considered to be appropriate for these terms, as stated above.
1
l i
f l
l
- b. The definition in Equations 1 and 2 (in Section 3.4.2 of the August 6,1997, submittal) that B (or K) = AP x v (where AP is in inches H,O, and B and K are in inches H,0*ft*/lb) is not Q
consistent with the basic elbow tap flow equation volumetric flow rate O = C x (AP)"2 Explain why B and K are defined as they are, and not as B (or K) = AP, a
Response 1b:
As explained in the response to question 1a, the terms B and K are consistent I
with the basic elbow tap flow equation, which is O = C (AP/p)"'.
I
- c. There appears to be an inconsistency in Table 3.6-2 (of the August 6,1997, submittal) in that
'he heading states, " Differential Pressures in inches of Water" whereas the footnote indicates that the Average Ap is in psj with the Flow Coefficient B in inches
- ft*/#. Clarify if the average i
Ap is 485.32 psi or 485.32 inches H20. Does this impact your response to item 1.b above?
l Response 1c:
The use of psiin the footnote was in error and will be corrected to inches H 0. The 2
calculations sppiit d the footnote values as inches H 0, so the error did not impact the results 2
and conclusions of the submittal.
f 2.
In the elbow tap flow measurement procedure in Section 3.4.2 (of the August 6,1997, l
submittal), the future cycle reactor coolant system (RCS) flow will be calculated from the baseline calorimetric measured RCS flow multiplied by the " ratio of future cycle flow," R, which i
is defined in Equation 3 to be the square root of the ratio the average AP (times specific volume) of all elbow taps from the future cycle to that of the baseline cycle, i.e. (K/B)*.
l
- a. Because of the variations in the elbow tap flow coetiicients (note that the flow coefficient here is C in the basic elbow tap equation, not B or K as defined in Equations 1 and 2 in Section j
3.4.2) and the Ap's for different elbow taps in the cold legs, what is the mathematical basis for the use of the average Ap of all elbow taps in defining the ratio of future cycle flow, R7 Q
i Provide the mathematical derivation to show correctness of *R" as defined in Section 3.4.2, using the average Ap of all elbow taps.
Response 2a:
The data presented in the response to question 2b (see below) notes insignificant differences between the NRC proposed average of the ratios versus the South Texas proposed ratio of the average. However, from the data presented, it can be concluded that the South Texas proposed ratio of the average calculates a smaller magnitude R than the NRC proposed average of the ratio and thus is the more conservative approach.
i
- b. As the flow coefficient (C) for each elbow tap i should remain constant, the volumetric flow ratio should be equal to the square root of the Ap ratio between two cycles, which should be anticipated to be the same for all elbow taps. Would it be more appropriate mathematically to use the average value of the flow ratios (i.e., square root of Ap ratio) of all e' bow taps to define the " ratio of future cycle flow", R7 If not, why not? (Note that the December 9,1997,
)
response to Question 11 showed that the difference between the total RCS flow based on a
individual elbow taps and flow based on the average elbow tap Ap is negligible (0.01%) based l
2 1
I
t on one cycle's data. But this is not mathematically demonstrated to be the case for all conditions.)
Response 2b:
Noted below are the South Texas Unit 1 and Unit 2 indicated transmitter Ap values for each cycle.
Transmitter Unit 1 Cycle 1 Cycle 2 Cycle 3 Cycle 4 Cycle 5 Cycle 6 Cycle 7 FT417 492.67 492.30 492.01 487.97 493.84 486.37 487.17 FT418 508.69 505.02 511.84 506.66 511.76 503.70 504.42 FT419 486.92 486.21 48927 482.00 486.99 478.85 478.95 FT427 457.20 458.74 464.07 461.54 459.94 459.53 462.22 FT428 502.08 496.02 503.45 497.54 483.69 495.65 503.99 FT429 492.59 493.09 49625 495.38 494.24 492.21 494.80 FT437 485.62 48328 481.38 483.50 488.10 478.21 479.96 FT438 520.65 512.51 513.94 507.30 520.57 506.37 504.61 FT439 496.31 488.47 496.31 48825 499.13 485.42 486.91 FT447 453.39 446.59 457.42 452.13 450.49 448.43 447.43 FT448 474.08 470.76 470.00 469.04 468.62 467.49 467.49 FT449 453.64 456.18 453.98 453.78 456.32 451.56 451.74 Average Delta-p 485.3200 482.4308 485.8267 482.0908 484.4742 479.4825 480.8075
+8.C R value individualTransmitter R values Average R value (R value)-(Average R value)
% Difference l
I t
3 l
...___mm l
Transmitter Unit 2 Cycle 1 Cycle 2 Cycle 3 Cycle'4 Cycle 5 Cycle 6 l
FT417 478.27 485.00 477.71 472.51 478.71 471.65 FT418 506.07 509.70 500.65 496.72 504.47 495.60 FT419 478.44 483.22 474.79 471.27 478.23 471.75 FT427 437.55 441.78 438.01 436.77 440.29 435.91 FT428 469.07 468.52 464.81 453.08 467.86 458.62 FT429 457.33 459.06 453.74 446.37 455.10 447.04 FT437 531.75 528.57 524.02 522.13 527.74 518.47 FT438 517.39 518.52 519.34 512.22 522.9 512.89 FT439 483.97 486.43 490.85 481.23 491.31 484.06 1
FT447 461.54 469.43 463.74 457.58 461.34 459.30 FT448 486.49 487.47 484.86 482.24 485.84 480.75 FT449 456.30 460.10 456.57 455.44 459.27 454.93 Average Delta p 480.3475 483.1567 479.0908 473.9633 481.0883 474.2475
+a e R value IndividualTransmitter R values l
l 1
Average R value (R value)-(Average R value)
% Difference
% Difference = [(R value) - (Average R value)][100y(R value)
)
As can be seen from the above data, the difference between the two techniques in the determination of the system R value is insignificant. All of the Unit 2 % differences and, with
)
two exceptions, the Unit 1 % differences are less than [
]*". The two Unit 1 exceptions are considered of little consequence. Therefore, it is concluded that the average of the ratios (as suggested by the above question) is equivalent to the ratio of the averages (the method presented in the South Texas submittal). It should be noted that in all cases the method presented in the South Texas submittal is conservative (smaller in magnitude) than that suggested by the NRC.
l l
4
i
- c. To provide a 95/95 probability / confidence of the value of R, would it be more appropriate to adjust the " future cycle flow ratio," R, by taking into to account the distribution of the Ap ratics i
among the elbow taps as the equation below? If not, why not?
R = R,- K(95,95,N) o
- where, R, = I R/N Ri = (ApdAp.)?, I = 1,2,....N (Note that Ap's are in inch of water. If Ap's are in psi, j
then it will be multiplied by the specific volume of water)
I N = total number of elbow taps = 3 x number of cold legs a = standard deviation of R,'s K(95,95,N) = factor for one-sided tolerance !imit for 95%
probability at 95% confidence level for a sample size of N.
K(95,95,12) = 2.736 K(95,95,9) = 3.031 Response 2c:
The basic presumption for use of the suggested approach is that allloops start with equal flow, experience equal mechanistic changes (equal impeller wear, equal steam generator tube plugging. equal steam generator tube sleeving, etc.) thus, the indicated Ap variation results from a random distribution of errors and uncertainties. However,[
l
]**#. As part of the Cycle 1 startup process, plants scale the individual RCS Flow channels to reflect 120 % flow at the i
indicated Ap values. Thus, the channels are normalized to reflect the same flow, [
]**#.
i 5
l r
l As an example please note the Cycle 1 Indicated Ap values of a Westinghouse three loop plant undergoing a Westinghouse performed RCS Flow normalization evaluation.
i Transmitter Ap (in WC)
+J c 1A 1B 1C 2A 2B 2C 3A l
3B 3C
+a.c 1
L As can be seen in the accompanying plot of [
l l
]**'*, where R equals the ratio of the l
average Ap values (South Texas approach) and R chan equals the average of the ratios of 1
l the Ap value; (NRC approach). The standard deviations for the individual R values for each j
j of these cy.
Tre:
i Cycle a
-...e
~
E F
G H
I J
K i
+8,C It is also suggested that application of a one-sided tolerance factor to the R values envelopes i
4 l
6
- ~ -.. - __,
l
{
T** Thus, it is concluded that application of the one-sided tolerance factor is not approprt.te in this calculation.
+AC l
l l
l l
7 l
i
-+----ww-a,
-e-.
w-----
- - - - +
w y
w y
i
- 3. Tables A-4 and A-5 of the August 6,1997, submittal provide the cold leg elbow tap flow l
uncertainty for ODPS/ Process computer and low flow reactor trip, respectively. Are the instrumentation uncertainty values sufficient to bound the uncertainties of the elbow tap measurement instrument, including the larger drift effects, due to absence of current l
norma lization of elbow tap measurement against the precision heat balance measurement at the l
beginning of each cycle? Provide corrected uncertainty values,if necessary, and the basis for the i
uncertainty values.
1 l
Response 3:
)
i
[
]"# Therefore,it is concluded that no changes to the uncertainties or final resultants are necessary for Tables A-4 and A-5.
l
\\
l 8
l i
l -
e 9
9 b
8 I
9 i
l 5
1 5
I Q
l
( )
2 1
8 g
m IJ 8
h E
i
~C 2
E 6
i a
o O
~
O d
1 8
0 m
S x
b 5
o i
1
- - _ _ _ _ _ _ _ _ _ _ _