CNL-20-063, Supplement to License Amendment Request for Measurement Uncertainty Recapture Power Uprate (WBN-TS-19-06)

Supplement to License Amendment Request for Measurement Uncertainty Recapture Power Uprate (WBN-TS-19-06)

ML20210M034
Person / Time
Site:	Watts Bar
Issue date:	07/27/2020
From:	Jim Barstow Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML20210M033	List: CNL-20-063, Supplement to License Amendment Request for Measurement Uncertainty Recapture Power Uprate (WBN-TS-19-06)
References
CNL-20-063, EPID L-2019-LLS-0000
Download: ML20210M034 (34)

Text

Proprietary Information Withhold Under 10 CFR § 2.390 This letter is decontrolled when separated from Enclosures 1 and 3

[I!fil Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-20-063 July 27, 2020 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Watts Bar Nuclear Plant, Unit 2 Facility Operating License No. NPF-96 NRC Docket No. 50-391

Subject:

Supplement to License Amendment Request for Measurement Uncertainty Recapture Power Uprate (WBN-TS-19-06)

(EPID L-2019-LLS-0000)

References:

1. TVA Letter to NRC, CNL-19-082, License Amendment Request for Measurement Uncertainty Recapture Power Uprate (WBN-TS-19-06),

dated October 10, 2019 (ML19283G117)

2. TVA Letter to NRC, CNL-20-030, Response to Request for Additional Information to License Amendment Request for Measurement Uncertainty Recapture Power Uprate (WBN-TS-19-06)

(EPID L-2019-LLS-0000), dated April 29, 2020 (ML20120A582)

In Reference 1, Tennessee Valley Authority (TVA) submitted a request for an amendment to Facility Operating License No. NPF-96 for the Watts Bar Nuclear Plant (WBN), Unit 2. The proposed license amendment request (LAR) would increase the WBN, Unit 2 authorized core power level from 3411 megawatts thermal (MWt) to 3459 MWt (i.e., an increase of approximately 1.4 percent (%) Rated Thermal Power), based on the use of the Caldon1 Leading Edge Flow Meter (LEFM1) CheckPlus System.

In Reference 2, TVA responded to a Nuclear Regulatory Commission (NRC) request for additional Information (RAI). Following submittal of Reference 2, the NRC identified information in Enclosures 1 and 2 to Reference 1 that was marked as non-proprietary that appeared to be based on proprietary information in Cameron Engineering Report ER-734P, Revision 2 (Enclosure 5 to Reference 1), and Westinghouse WCAP-18419-P, Revision 1 (Enclosure 6 to Reference 1). Specifically, in Table I.1.E-1 of Enclosure 2 to Reference 1, 1 Caldon, Inc. is now part of the Measurement Systems Division of Cameron International Corporation (Cameron). Caldon and LEFM are registered trademarks of Cameron.

Proprietary Information Withhold Under 10 CFR § 2.390 This letter is decontrolled when separated from Enclosures 1 and 3

Proprietary Information Withhold Under 10 CFR § 2.390 This letter is decontrolled when separated from Enclosures 1 and 3 U.S. Nuclear Regulatory Commission CNL-20-063 Page 2 July 27, 2020 the total thermal power uncertainty of 0.6% rated thermal power (RTP) referred to WCAP-18419-P. However, in Section 3.1.1 and Table 3 of WCAP-18419-P, the value of 0.6% RTP was marked as proprietary. Westinghouse has subsequently determined that the value of 0.6% RTP should not have been marked as proprietary. Enclosures 1 and 2 provide revised pages of WCAP-18419-P, Revision 1, and WCAP-18419-NP, Revision 1, respectively, reflecting that the total uncertainty value of 0.6% RTP is not considered proprietary. Enclosures 1 and 2 supersede the corresponding pages in Enclosures 6 and 10 to Reference 1.

Additionally, Section 3.1, Leading Edge Flow Meter Checkplus System Description, in to Reference 1, contained a discussion of the NORMAL and MAINTENANCE modes of the Leading Edge Flow Meter CheckPlus System . The information in Section 3.1 to Enclosure 1 to Reference 1 was based on similar information in footnotes 1 and 2 to Section 1.0 of Cameron Engineering Report ER-734P, Revision 2, which were marked as proprietary. Cameron has subsequently determined that footnotes 1 and 2 to Section 1.0 of Cameron Engineering Report ER-734P, Revision 2, should not have been marked as proprietary. Enclosures 3 and 4 provide Revisions 3 to ER-734P and ER-734NP, respectively, reflecting that footnotes 1 and 2 to Section 1.0 are not considered proprietary.

Enclosures 3 and 4 supersede the corresponding reports in Enclosures 5 and 9 to Reference 1.

The incorrect proprietary markings have been entered into the TVA corrective action program and TVA has determined that the remaining information in Enclosures 1, 2, 5, and 6 to Reference 1 are properly marked.

The proprietary information in Enclosure 1 is supported by the affidavit (CAW-19-4927) in to Reference 1, which sets forth the basis on which the information should be withheld from public disclosure by the NRC and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390. Accordingly, TVA requests that the information, which is proprietary to Westinghouse, be withheld from public disclosure in accordance with 10 CFR 2.390. Correspondence with respect to the copyright or proprietary aspects of the technical support document or the supporting Westinghouse affidavit should reference CAW-19-4927 and should be addressed to Zachary Harper, Manager Licensing Engineering, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 3, Suite 310, Cranberry Township, Pennsylvania 16066.

The proprietary information in Enclosure 3 is supported by an affidavit (Enclosure 5) signed by Cameron, the owner of the information, which sets forth the basis on which the information should be withheld from public disclosure by the NRC and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390. Accordingly, TVA requests that the information, which is proprietary to Cameron, be withheld from public disclosure in accordance with 10 CFR 2.390. Correspondence with respect to the copyright Proprietary Information Withhold Under 10 CFR § 2.390 This letter is decontrolled when separated from Enclosures 1 and 3

Proprietary Information Withhold Under 10 CFR § 2.390 This letter is decontrolled when separated from Enclosures 1 and 3 U.S. Nuclear Regulatory Commission CNL-20-063 Page 3 July 27, 2020 or proprietary aspects of the technical information listed above or the supporting Cameron affidavit should reference Cameron letter CAW 20-07 and should be addressed to Joanna Phillips, Nuclear Sales Manager, Caldon Ultrasonics Technology Center, Cameron, 1000 McClaren Woods Drive, Coraopolis, Pennsylvania 15216.

This letter does not change the conclusions, the no significant hazards consideration, nor the environmental considerations contained in Reference 1. Additionally, in accordance with 10 CFR 50.91(b)(1), TVA is sending a copy of this letter and the enclosures to the Tennessee Department of Environment and Conservation.

There are no new regulatory commitments associated with this submittal. Please address any questions regarding this request to Gordon R. Williams, Senior Manager, Fleet Licensing (Acting) at (423) 751-2687.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this 27th day of July 2020.

Respectfully, James Barstow Vice President, Nuclear Regulatory Affairs & Support Services

Enclosures:

1. Revised Pages from WCAP-18419-P (Proprietary)

2. Revised Pages from WCAP-18419-NP (Non-Proprietary)

3. Cameron Engineering Report ER-734P, Revision 3 (Proprietary)

4. Cameron Engineering Report ER-734NP, Revision 3 (Non-Proprietary)

5. Cameron Affidavit CAW 20-07 cc (Enclosures):

NRC Regional Administrator - Region II NRC Senior Resident Inspector - Watts Bar Nuclear Plant NRC Project Manager - Watts Bar Nuclear Plant Director, Division of Radiological Health - Tennessee State Department of Environment and Conservation Proprietary Information Withhold Under 10 CFR § 2.390 This letter is decontrolled when separated from Enclosures 1 and 3

Proprietary Information Withhold Under 10 CFR § 2.390 Enclosure 1 Revised Pages from WCAP-18419-P (Proprietary)

CNL-20-063 Proprietary Information Withhold Under 10 CFR § 2.390

Enclosure 2 Revised Pages from WCAP-18419-NP (Non-Proprietary)

CNL-20-063

Westinghouse Non-Proprietary Class 3 WCAP-18419-NP, Revision 1 Errata Pages 2 pages

©2020 Westinghouse Electric Company LLC All Rights Reserved

Westin¢iouse Non-Proprietary Class 3 6

3. C\STRu ~IE~TATIO~ Ll\"CERTAThTIES Th.is section contains a discussion of the Daily Power Calorimetric uncertainty function.

3.1 11\""TEGR.ATED CO~IPl7TER SYSilY (ICS) POWER 1II.ASURE)IE~T l ~CERT.~ n

• 3.1.1 l7sing Leading Edge f low )feter (LEf)I) Installed infeedwater Header The normal way that the daily calorimetric power measurement will be performed is by the Integrated Computer System and using the data supplied by the Leading Edge Flow Meter (I.EFM). The LE.f),[,

iru.talled in the feedwater header gives a system measurement of the feedwater (as opposed to a loop feedwater measurement); therefore no loop feedwater tempering flows are considered. The feedwater temperature is also measw-ed by the LEFM thus no uncertainties are associated with feedwater temperature. The overall uncertainty of the LEFM is gi\*en as 0.48% flow.

Tables 1. 2, and 3 show the results of the uncertainty calculations and the sensitivities using the LEFM, while Table 4 shows the instrumentation arrangement using the LEF.vl.

Using the power uncertainty values noted on Table 3 , the 4 loop uncertawty (with bias \*alues) equation is as follo,vs:

[ r Based on four (4) loops and the instrument uncertainties for the four parameters. the uncertainty for the secondary s.ide power calorimetric measurement is:

1. of loops Power Uncenainty (% Rated Thermal Power (RTP))

4  ::!:0.6 WCAP-18419-1'-P. Revision 1 August 2019

Westinghouse Non-Proprietary Class 3 9 Table 3 Integrated Computer System Power :\1easurement l'ncenainties (Using L EF-\I on f eedwater H ead er) f our Loop Operation Component Instrument Uncertainty Pov.rer Uncertainty

(% Power)

Feedwatt-r Flow (Header)

LEFM &.C Feedwater Density Temperature Pressure Feedwater Enthalpy Temperature (Main)

Pressure (Main)

Steam Enthalpy Pressure Moisture Net Pump Heat Addition Steam Generator Blowdowu Flow Orifice (Flow Codlicient)

Thermal Expansion Coefficient Temperature Material Density Prt>Ssure 6P Steam Generator Blowdown Enthalpy Pressure Bias Values Power Bias Total Value 4 Loop Uncertainty (random)  :!:: 0.6

• . ** Indicate seis of depe.ndent parameters

• 0 Effe.<:ts a.re included m the feedwall!r ~ow llllCe1t1mly pro,i.ded by Caldon WCAP-1&419-1'-P. Revision 1 August 2019

Proprietary Information Withhold Under 10 CFR § 2.390 Enclosure 3 Cameron Engineering Report ER-734P, Revision 3 (Proprietary)

CNL-20-063 Proprietary Information Withhold Under 10 CFR § 2.390

Enclosure 4 Cameron Engineering Report ER-734NP, Revision 3 (Non-Proprietary)

CNL-20-063

noch.,,*cll Autcmat , o n + Schl u mbe r ger Page 1 Caldon Ultrasonics Engineering Report: ER-734NP Rev. 3 BOUNDING UNCERTAINTY ANALYSIS FOR THERMAL POWER DETERMINATl 0N AT WATTS 1 BAR UNIT 2 USING THE LEFM + SYSTEM Prepared by: Joanna Phillips Reviewed by: Jonathan Lent t!cX Reviewed for Proprietary Content by: Joanna Phillips~J!

July 2020 ER-734NP Rev 3 Prepared by: JMP Reviewed by: JJL

sensia Rockwell Automation+ Schlumberger Page 2 All Rights Reserved.

Printed in the United States of America.

Engineering Report No. ER-734NP Rev. 3 July 2020 ER-734NP Rev 3 Prepared by: JMP Reviewed by: JJL

sensia Rockwell Automation+ Schlumberger Page 3 Engineering Report: ER-734NP Rev. 3 BOUNDING UNCERTAINTY ANALYSIS FOR THERMAL POWER DETERMINATION AT WATTS BAR UNIT 2 USING THE LEFM%+

SYSTEM Table of Contents

1.0 INTRODUCTION

2.0

SUMMARY

3.0 APPROACH 4.0 OVERVIEW

5.0 REFERENCES

6.0 APPENDICES A Information Supporting Uncertainty in LEFM + Flow and Temperature Measurements A.1 LEFM + Inputs A.2 LEFM + Uncertainty Items/Calculations A.3 LEFM + Meter Factor Calculation and Accuracy Assessment Trade A.4 [Uncertainty in Time of Flight Measurement] Secret &

Confidential A.5 [Uncertainty in Tau, Non-Fluid Delay] Commercial B Total Thermal Power and Mass Flow Uncertainties using the LEFM%+ Information System ER-734NP Rev 3 Prepared by: JMP Reviewed by: JJL

sensia Rockwell Automation+ Schlumberger Page 4

1.0 INTRODUCTION

The LEFM% and LEFM%+1 are advanced ultrasonic systems that accurately determine the volume flow and temperature of feedwater in nuclear power plants. Using a feedwater pressure signal input to the LEFM% and LEFM%+: mass flow can be determined and, along with the temperature output are used along with plant data to compute reactor core thermal power. The technology underlying the LEFM% ultrasonic instruments and the factors affecting their performance are described in a topical report, Reference 1, and a supplement to this topical report, Reference 2.

The LEFM%+, which is made of two LEFM% subsystems, is described in another supplement to the topical report, Reference 3. The exact amount of the uprate allowable under a revision to 10CFR50 Appendix K depends not only on the accuracy of the LEFM%+ instrument, but also on the uncertainties in other inputs to the thermal power calculation.

Trade It is the purpose of this document to provide an analysis of the uncertainty contribution of the Secret &

LEFM%+ System [in its normal operation as well as when operating in its maintenance mode2] to Confidential Commercial the overall mass flow and thermal power uncertainty of Watts Bar Unit 2 (Appendix B). Information The uncertainties in mass flow and feedwater temperature are also used in the calculation of the overall thermal power uncertainty (Appendix B). [It should be noted that a special procedure is Trade required for combining the mass flow uncertainty and the uncertainty in feedwater enthalpy due to Secret &

Confidential temperature. This is necessary because some elements of the temperature uncertainty are Commercial systematically related to elements of the mass flow uncertainty and others are not.] A detailed Information discussion of the methodology for combining these terms is described in Reference 3.

This analysis is a bounding analysis for Watts Bar Unit 2. [This revision utilizes actual dimensions for the spool piece and nominal values for full power mass flow, final feed temperature, and steam Trade conditions. Actual values for the uncertainties in length measurements, time measurements, and Secret &

Confidential calibration coefficients (meter factor) are employed. The commissioning tests for the LEFM%+ Commercial have confirmed that the time measurement uncertainties are within the bounding values used in the Information analysis.]

1 The LEFM%+ is composed of the average flow of two independent LEFM% subsystems. There are four acoustic paths in an LEFM% summing to eight paths in the LEFM%+.

2 Maintenance Mode refers to the state when any LEFM%+ meter has only one of its two LEFM% subsystems fully operational, dWeg^f[`Y [` fZSf _WfWdpe Ua_bgf[`Y X^ai Xda_ \gef fZW dW_S[`[`Y Xg^^k abWdSf[a`S^ C>?D% subsystem.

ER-734NP Rev 3 Prepared by: JMP Reviewed by: JJL

sensia Rockwell Automation+ Schlumberger Page 5 2.0

SUMMARY

For Watts Bar Unit 2, Revision 3 results are as follows:

1. The mass flow uncertainty approach is documented in Reference 3. The uncertainty in the LEFM%'pe _See X^ai aX XWWViSfWd [e Se Xa^^aie6

% Fully Functional LEFM%+ system mass flow uncertainty is [, 0.32%]

% Maintenance Mode LEFM%+ system mass flow uncertainty is [, 0.47%.] Trade Secret &

[Note: The LEFM%+ system is in maintenance mode when only one of the two LEFM%+ Confidential Commercial subsystems is fully functional, i.e., LEFM%+ System is operating as a LEFM% System. The Information uncertainty of the LEFM%+ when in maintenance mode may be re-evaluated and will likely be reduced after site specific hydraulic experience has been taken into account.]

2. The uncertainty in the LEFM%+ feedwater temperature is as follows:

Trade Secret &

% Fully Functional LEFM%+ system temperature uncertainty is [,0.58°F] Confidential Commercial

% Maintenance Mode LEFM%+ system the uncertainty is [,0.61°F] Information

3. The total thermal power uncertainty approach is documented in Reference 3 and Appendix B of this document. The total uncertainty in the determination of thermal power uses the LEFM%+ system parameters and plant specific parameters, i.e., heat gain/losses, etc. and is as follows:

% Thermal power uncertainty using a Fully Functional LEFM%+ system is , 0.42%

% Thermal power uncertainty using a Maintenance Mode LEFM%+ system is [,0.55%] Trade Secret &

[Note: Because some elements of the temperature uncertainty are systematic, the total power Confidential Commercial uncertainty due to the LEFM%+ is not the root sum squares of the uncertainties due to items 1 Information and 2 above.]

ER-734NP Rev 3 Prepared by: JMP Reviewed by: JJL

sensia Page 6 Rockwell Automation+ Schlumberger 3.0 APPROACH All errors and biases are calculated and combined according to the procedures defined in Reference 4 in order to determine the 95% confidence and probability value. The approach to determine the uncertainty, consistent with determining set points, is to combine the random and bias terms by the means of the RSS approach provided that all the terms are independent, zero-centered and normally distributed.

Reference 4 defines the contributions of individual error elements through the use of sensitivity coefficients defined as follows:

A calculated variable P is determined by algorithm f, from measured variables X, Y, and Z.

P = f (X, Y, Z)

The error, or uncertainty in P, dP, is given by:

dP = of I dX + of I dY + of I dZ

&.'"yz oYxz 8Zxr As noted above, P is the determined variable--in this case, reactor power or mass flow-- which is calculated via measured variables X, Y, and Z using an algorithm f (X, Y, Z). The uncertainty or error in P, dP, is determined on a per unit basis as follows:

dP P

= {x of I P&.'"rz

}dx +{Y X

ofl PoYxz

}dY Y

+{z ofl }dz P8Zxr Z where the terms in brackets are referred to as the sensitivity coefficients.

If the errors or biases in individual elements (dX/X, dY/Y, and dZ/Z in the above equation) are all caused by a common (systematic) boundary condition (for example ambient temperature) the total error dP/P is found by summing the three terms in the above equation. If, as is more often the case, the errors in X, Y, and Z are independent of each other, then Reference 4 recommends and probability theory requires that the total uncertainty be determined by the root sum square as follows (for 95% confidence and probability):

2 2 2 YZ XZ XY Obviously, if some errors in individual elements are caused by a combination of boundary conditions, some independent and some related (i.e., systematic) then a combination of the two procedures is appropriate.

ER-734NP Rev 3 Prepared by: JMP Reviewed by: JJL

sensia Rockwell Automation+ Schlumberger Page 7 4.0 OVERVIEW The analyses that support the calculation of LEFM%+ uncertainties are contained in the appendices to this document. The function of each appendix is outlined below.

Appendix A.1, LEFM + Inputs This appendix tabulates dimensional and other inputs to the LEFM%+. The spreadsheet Trade calculates other key dimensions and factors from these inputs [(e.g., the face-to-face Secret &

Confidential distance between pairs of transducer assemblies)], which is used by the LEFM%+ for the Commercial computation of mass flow and temperature. Information Appendix A.2, LEFM + Uncertainty Items Calculations This appendix calculates the uncertainties in mass flow and temperature as computed by the LEFM%+ using the methodology described in Appendix E of Reference 1 and Appendix A of Reference 33, with uncertainties in the elements of these measurements bounded as described in both references4. The spreadsheet calculations draw on the data of Appendix A.1 for dimensional information. It draws from Appendix A.4 [for the Trade uncertainties in time of flight measurements which affect 'fpe( ]Wk W^W_W`fe [` fZW Secret &

Confidential computation of fluid velocity and volumetric flow]. It draws from Appendix A.5 [for the Commercial uncertainties in Tau, Non-Fluid Delay S`V _WSegdW_W`fe aX bg^eW fdS`e[f f[_We %fpe&]. Information These uncertainties are an important factor in establishing the overall uncertainty of the LEFM%+.

This appendix utilizes the results of the calibration testing for the plant spool piece(s) for the uncertainty in the profile factor (calibration coefficient). The engineering reports for the spool piece calibration tests are referenced in Appendix A.3 to this report.

3 Reference 3 (ER 157P-A) develops the uncertainties for the LEFM%+ system. Because this system uses two measurement planes, the structure of its uncertainties differs somewhat that of an LEFM%.

4 Reference 3 (ER 157P-A) revised some of the time measurement uncertainty bounds. The revised bounds are a conservative projection of actual performance of the LEFM hardware. ER 80P used bounds that were based on a conservative projection of theoretical performance.

ER-734NP Rev 3 Prepared by: JMP Reviewed by: JJL

sensia Rockwell Automation+ Schlumberger Page 8 Appendix A.3, Meter Factor (Calibration) Uncertainties Included with Revision 1 only b N/A for Revision 0 As noted above, the calibration test report for the spool piece(s) establishes the overall uncertainty in the meter factor of the LEFM%+. [The elements of the meter factor uncertainty include the uncertainty of the calibration facility itself, the observational Trade (statistical) uncertainty of the test, uncertainties associated with extrapolating test results to Secret &

plant conditions, etc. The time measurement uncertainties in the LEFM%+ electronics Confidential Commercial used for the calibration test are also elements in establishing the uncertainty in profile Information factor. These time measurement uncertainties are documented in Appendix A.3 for actual test conditions.]

[One aspect of the meter factor uncertainty that must be determined in the field is the LEFM% plane to plane variability. As discussed in the calibration report, the LEFM%+

Trade flow measurement by design cancels all cross velocities; however, when in maintenance Secret &

mode (LEFM% mode), the meter factor uncertainty also must consider additional Confidential Commercial uncertainties due to uncancelled cross velocities. The established approach is to monitor Information the variations in plane balance in each loop over a long period of time (typically, 1 to 2 years) and compute bounding ranges of these variations based on plant data, versus modelling data].

Appendix A.4, [Uncertainty in Time of Flight Measurement]

This appendix calculates the [uncertainties in time measurements that affect 'fpe( ]Wk Trade elements in the computation of fluid velocity and volumetric flow.] Secret &

Confidential Commercial Appendix A.5, [Uncertainty in Tau, Non Fluid Delay] Information This appendix calculates the [g`UWdfS[`f[We [` fZW _WSegdW_W`fe aX bg^eW fdS`e[f f[_We %fpe&

as well as the uncertainties in non-fluid delays (+pe&.]

Appendix B, Total Thermal Power Uncertainty due to the LEFM +

The total thermal power uncertainty due to the LEFM%+ is calculated in this appendix, using the results of Appendix A.2, A.4 and A.5. Plant supplied steam conditions (which enter into the computation of errors due to feedwater temperature) are used for this computation. This appendix also computes the fraction of the uncertainty in feedwater temperature that is systematically related to the mass flow uncertainty.

ER-734NP Rev 3 Prepared by: JMP Reviewed by: JJL

sE!nsia Page 9 Rockwell Automation + Schlumberger

5.0 REFERENCES

1) Cameron Topical Report ER-4,G( n@_bdah[`Y JZWd_S^ GaiWd 9UUgdSUk S`V G^S`f ISXWfk MZ[^W @`UdWSe[`Y FbWdSf[`Y GaiWd CWhW^ Ke[`Y fZW C>?D <ZWU] IkefW_o( HWh. 0

2) Cameron Engineering Report ER--2,G( nIgbb^W_W`f fa Jab[US^ HWbadf >H 4,G6 ;Se[e Xad a Power Uprate i[fZ fZW C>?D IkefW_o( DSk .,,,

3) Cameron Engineering Report ER-157(P-A)( nIgbb^W_W`f fa Cameron Topical Report ER-4,G6 ;Se[e Xad GaiWd KbdSfWe i[fZ S` C>?D <ZWU] ad S` C>?D <ZWU]G^geo( VSfWV May 2008, Revision 8 and Revision 8 Errata

4) ASME PTC 19.1-1985, Measurement Uncertainty ER-734NP Rev 3 Prepared by: JMP Reviewed by: JJL

sensia Page 10 Rockwell Automation+ Schlumberger Appendix A Appendix A.1, LEFM+ Inputs Appendix A.2, LEFM+ Uncertainty Items/Calculations Appendix A.3, Meter Factor Calculation and Accuracy Assessment Trade Appendix A.4, [Uncertainty in Time of Flight Measurement] Secret &

Confidential Appendix A.5, [Uncertainty in Tau, Non-Fluid Delay] Commercial Information ER-734NP Rev 3 Prepared by: JMP Reviewed by: JJL

sensia Rockwell Automation+ Schlumberger Page 11 Appendix A.1 LEFM + Inputs No attachment to follow, as Appendix is Proprietary in its Entirety ER-734NP Rev 3 Prepared by: JMP Reviewed by: JJL

sensia Rockwell Automation+ Schlumberger Page 12 Appendix A.2 LEFM + Uncertainty Items/Calculations No attachment to follow, as Appendix is Proprietary in its Entirety ER-734NP Rev 3 Prepared by: JMP Reviewed by: JJL

sensia Page 13 Rockwell Automation+ Schlumberger Appendix A.3 LEFM + Meter Factor Calculation and Accuracy Assessment Reference Caldon Engineering Report ER-3/. HWh ,( nDWfWd ?SUfad <S^Ug^Sf[a` S`V 9UUgdSUk 9eeWee_W`f Xad JW``WeeWW LS^^Wk 9gfZad[fk( MSffe ;Sd EgU^WSd GaiWd G^S`f K`[f .o( =WUW_TWd .,,4 ER-734NP Rev 3 Prepared by: JMP Reviewed by: JJL

sensia Rockwell Automation + Schlumberger Page 14 Appendix A.4 Trade Secret &

Confidential

[Uncertainty in Time of Flight Measurement] Commercial Information No attachment to follow, as Appendix is Proprietary in its Entirety ER-734NP Rev 3 Prepared by: JMP Reviewed by: JJL

sensia Rockwell Automation + Schlumberger Page 15 Appendix A.5 Trade Secret &

[Uncertainty in Tau, Non Fluid Delay] Confidential Commercial Information No attachment to follow, as Appendix is Proprietary in its Entirety ER-734NP Rev 3 Prepared by: JMP Reviewed by: JJL

sensia Page 16 Rockwell Automation+ Schlumberger Appendix B Total Thermal Power and Mass Flow Uncertainty using the LEFM%+ System No attachment to follow, as Appendix is Proprietary in its Entirety ER-734NP Rev. 2 Prepared by: JMP Reviewed by: JJL

Enclosure 5 Cameron Affidavit CAW 20-07 CNL-20-063

sensia Cameron Technologies US LLC July 8, 2020 CAW 20-07 Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

Cameron Engineering Report ER- 734 Rev 3 "Bounding Uncertainty Analysis for Thermal Power Determination at Watts Bar Unit 2 Using the LEFM.., + System" Gentlemen:

This application for withholding is submitted by Cameron Technologies US, LLC, a Delaware limited liability company (herein called "Cameron") pursuant to the provisions of paragraph (b )(1) of Section 2.390 of the Commission's regulations. It contains trade secrets and/or commercial information proprietary to Cameron and customarily held in confidence.

The proprietary information for which withholding is being requested is identified in the subject submittal. In conformance with 10 CFR Section 2.390, Affidavit CAW 20-07 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 Cameron, be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.

Correspondence with respect to this application for withholding or the accompanying affidavit should reference CAW 20-07 and should be addressed to the undersigned.

Very truly yours,

- ~

~ !lips Nuclear Sales Manager Enclosures (Only upon separation of the enclosed confidential material should this letter and affidavit be released.)

1

July 8, 2020 CAW 20-07 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally appeared Joanna Phillips, who, being by me duly sworn according to law, deposes and says that she is authorized to execute this Affidavit on behalf of Cameron Technologies US, LLC, a Delaware limited liability company (herein called "Cameron"), and that the averments of fact set forth in this Affidavit are true and correct to the best of her knowledge, information, and belief:

na Phillips uclear Sales Manager Signed and sworn to before me this 1>:\b day of J

~

=

Notary Public 2020 A.QQAAM Commonwealth of Pennsylvania - Notary Seal Frances A. Lewis. Notary Public Allegheny County My commission expires November 25, 2022 Commission number 1287160 Member. Pennsylvania Association of Notaries 1

July 8, 2020 CAW 20-07

1. I am the Nuclear Sales Manager for Cameron Technologies US, LLC, 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 Cameron.

2. I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Cameron application for withholding accompanying this Affidavit.

3. I have personal knowledge of the criteria and procedures utilized by Cameron in designating information as a trade secret, privileged or as confidential commercial or financial information.

4. Cameron requests that the information identified in paragraph S(v) below be withheld from the public on the following bases:

Trade secrets and commercial information obtained from a person and privileged or confidential The material and information provided herewith is so designated by Cameron, in accordance with those criteria and procedures, for the reasons set forth below.

5. Pursuant to the provisions of paragraph (b) (4) of Section 2.390 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 Cameron.

(ii) The information is of a type customarily held in confidence by Cameron and not customarily disclosed to the public. Cameron has a rational basis for determining the types of information customarily held in confidence by it and, in that connection utilizes a 2

July 8, 2020 CAW 20-07 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 Cameron policy and provides the rational basis required. Furthermore, the information is submitted voluntarily and need not rely on the evaluation of any rational basis.

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 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 Cameron's competitors without license from Cameron 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, and assurance of quality, or licensing a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Cameron, its customer or suppliers.

(e) It reveals aspects of past, present or future Cameron or customer funded development plans and programs of potential customer value to Cameron.

(f) It contains patentable ideas, for which patent protection may be desirable.

The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (a), (b) and (c), above.

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July 8, 2020 CAW 20-07 There are sound policy reasons behind the Cameron system, which include the following:

(a) The use of such information by Cameron gives Cameron a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Cameron competitive position.

(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Cameron ability to sell products or services involving the use of the information.

(c) Use by our competitor would put Cameron 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 Cameron of a competitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence of Cameron in the world market, and thereby give a market advantage to the competition of those countries.

(f) The Cameron 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 §§ 2. 390, it is to be received in confidence by the Commission.

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July 8, 2020 CAW 20-07 (iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same manner or method to the best of our knowledge and belief.

(v) The proprietary information sought to be withheld is the submittal titled:

Subject:

Cameron Engineering Report ER- 734 Rev 3 "Bounding Uncertainty Analysis for Thermal Power Determination at Watts Bar Unit 2 Using the LEFM..; + System"

• Table of Contents page contains partial proprietary information

• Pages 4, 5, 7, and 8 contain partial proprietary information

• Appendix A, A.4 and A.5 cover pages contain partial proprietary information

• Appendices A.1 , A.2, A.4, A.5 and Bare proprietary in their entirety It is designated therein in accordance with 10 CFR §§ 2.390(b)(l)(i)(A,B), with the reason(s) for confidential treatment noted in the submittal and further described in this affidavit. This information is voluntarily submitted for use by the NRC Staff in their review of the accuracy assessment of the proposed methodology for the LEFM CheckPlus System used by Watts Bar Unit 2 for flow measurement at the licensed reactor thermal power level of 3459 MWt.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Cameron because it would enhance the ability of competitors to provide similar flow and temperature measurement systems 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 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 Cameron effort and the expenditure of a considerable sum of money.

In order for competitors of Cameron to duplicate this information, similar products would have to be developed, similar technical programs would have to be performed, and a significant 5

July 8, 2020 CAW 20-07 manpower effort, 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.

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