ML20212A990
| ML20212A990 | |
| Person / Time | |
|---|---|
| Site: | 05200003 |
| Issue date: | 10/16/1997 |
| From: | Mcintyre B WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | Quay T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19313D009 | List: |
| References | |
| AW-97-1176, NUDOCS 9710270172 | |
| Download: ML20212A990 (11) | |
Text
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Westinghouse Energy Systems Bm 355 Electric Corporation
"""*$ P"""'" "23"355 AW-97-1176 October 16,1997 Document Control Desk U.S. Nudear Regulatory Commission Washington, DC 20555 ATFENTION:
MR. T. R. QUAY APPLICATION FOR WITilllOLDINO PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE SUBux.
RESPONSE TO REQUESTS FOR ADDITIONAL INFORMATION ON AP600 WCOBRAffRAC (RAI 440.728)
Dear Mr. Quay:
The application for withholding is submitted by Westinghouse Electric 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-97 Il76 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 Westinghouse be withheld from public disclosure in accordance with 10CFR Section 2.790 of the Coaimission's regulations.
Correspondence with respect to this application for withholding or the accompanying affidavit should reference AW-97-Il76 and should be addressed to the undersigned.
Very truly yours, A, ff
/
Brian A. McIntyre, Manager 4
Advanced Pl.mt Safety and Licensing jml ec:
Kevin Bohrer NRC OWFN - MS 12E20 9710270172 971016 PDR ADOCK 05200003 E
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AW 971176 AFFIDAVIT COMMONWEALTil OF PENNSYLVANIA:
ss COUNTY OF ALLEGilENY:
Ilefore me, the undersigned authority, personally appeared 13rian 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 Corporation (" Westinghouse") and that the avennents of fact set forth in this AITidavit are true and correct to the best of his knowledge, information, and belief:
A,
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13rian A. McIntyre, Mar.ager
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Advanced Plant Safety and Licensing Sworn to and subscribed before me is /~7 M day of [
,1997 l
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7 Notary Public ws. 4
AW 97 ll76
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(1) 1,am Manager, Advanced Plant Safety And Licensing,in the New Plant Projects Division, of the Westinghouse Electric Corporation t.nd as such, I have been specifically delegated the function of reviewing the proprietary infonnation 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.
(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 conndential commercial or financial infonnation.
(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 infonnation sought to be withheld from public tiisclosure should be withheld.
(i)
The infonnation sought to be withheld from pt.blic disclosure is owned and has been held in conHdence by Westinghouse.
]
(ii)
The information is of a type customarily held in con 0dence by Westinghouse and not l
customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in conGdence by it and, in that connection, utilizes a system to determine when and whether to 1.old certain types of informeSm in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis reqmred.
l Under that system, information is held i.' 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:
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AW.971176 (a)
The information reveals the distinguishing aspects of a process (os component, I
structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.
(b)
It consists of supporting data, including test data, relative to a process (or component, struc*,re, 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, 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 part, present, or future Westinghouse or customer funded development plana 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 tne 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 ir 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.
343 %a,rnf
i AW.97-1176 4
(c)
Use by our competitor would put Westinghouse at a competitive disadvantage a
by reducing his expenditure of resources at our expense.
(d)
Each component of proprietary informat%n 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 rnay be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.
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(c)
Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competitinn of those couatries.
(f)
The Westinghouse capac'ty 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 confideace and, under the provisions of 10CFR Section 2.790, it is to be received in confidence by the Commission.
(iv) ne information sought to be protected is not available in public sources or available information has not been previously employed in the unne or:ginal manner or e ethod to the best of our knowledge and belief.
s (v)
Enclosed is Letter DCP/NRC1085 (NSD-NRC-97 5381), October 16,1997, being transmitted by Westinghouse Electric Corporation @') letter and Application for Withholding Proprietary Information from Public Disclosure, Brian A. McIntyre @'),
to Mr. T. R. Quay, Office of NRR. The proprietary information as submitted for use by Westinghouse Electric Corporation is in response to questions concerning the AP600 plant and the associated design certification rpplication and is expec'ed to be applicable in other licensee submittats in response to certain NRC requirements for 34Ma tp l
AW.97.ll76 justification of licensing advanced nuclear power plant designs.
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 Myanced Nuclear Power Plants that meet NRC requirements.
(d)
Establish technical and licensing approaches for the AP600 that will ultimately result in a certified design.
(e)
Assist customers in obtair.ing NRC approval for future plants.
Further this information has substantist commercial value as follows:
(a)
Westinghouse plans to sell the use of similar information to its customers for puiposes of meeting NRC requirements for advanced plant licenses.
(bj Westinghouse can sell suppoi; 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 conaetitive position of Westinghouse beca>ise it would enhance the ability of competitors to provide i.imilar advanced nuclear power designs and licensi..g defeuse services for commercial power reactors witho st commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC l
iequirements for licensing documentation without purchasing the right to use the information.
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AW.97.l l 76 l
De development of the technology described in part by the information is the result of applying the result "many years of experience in an intensive Westinghouse elfort and the expenditure of a considerable sum of money, in order foi competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower efTort, 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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ATTACIIMENT 2 TO NRC/DCF1085 NON-PROPRIETARY VERSION OF RAI 440.728 4
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d NRC REQUEST FOR ADDITIONAL INFORMATION hk!'E RAI 440.728:
WCAP 14776 states that WCOBRA/ TRAC (LBLOCA version) and NOTRUMP will be used to specify the initial conditions (ICs) for the large and small break LOCAs respectively, followed by the analysis of the long term cooling (LTC, phase using WCOBRA/ TRAC (LTC version). However, there is no identification of the ICs resulting from a LBLOCA. Please complete the analysis with the presentation of the ICs resulting from a LBl.OCA and the qualification of WCOBRA/ TRAC to analyze the LTC for these ICs.
Response
The initial conditions of the LDLOCA LTC calculations reported in AP600 SSAR subsections 15.6.5.4C.3.2 and 3 are based upon the extended DECLG calculation performed using the ECOBRA/ TRAC large break LOCA model and reported in SSAR subsection 15.6.5.4C-1; Reference 440.728-1 justifies the use of the more detailed large break ECODRA/ TRAC nodalization for this portion of the transient. He validation of ECOBRA/ TRAC for long term cooling analyses of the AP600 in Reference 440.728 2 has shown that the predicted results are independent of the ICs assumed; rather, the results are determined by the boundary conditions of core power, IRWST and sumf water levels and temperatures, and steam generator secondary conditions which are specified.
As discussed in SSAR subsection 15.6.5.4C.2.1.A. the extended large break LOCA calculation bounds the ECCS performance at the beginning of IRWST injection, ne initial conditions for the ECOBRA/ TRAC LTC analysis of SSAR subsection 15.6.5.4C.'s.2 are as follows:
Reactor vessel downcomer/ lower plenum filled with liquid to the cold leg elevation and totally void above that elevation: liquid temperature equals 170F below the hot leg elevation,240F above there to the cold leg elevation Core - covered with a liquid mixture Upper plenum / upper head - 50% void fraction at saturation up to the hot leg elevation, totally void at higher elevations Hot legs, cold legs, surge line, pressurizer, RCPs - totally void Steam generators - totally void on the pnmary side in the SSAR subsection 15.6.5.4C,3,3 analysis, the above initial conditions are modified a follows consistent with the gutters operable scenario:
ne downcomer is filled with liquid to the top of the core active fuel The temperature of the liquid present in the downcomer equals 192F W8Silfigh00S8
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NRC REQUEST FOR ADDITIONAL. INFORMATION 4
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l The above values differ httle from the small break LOCA WCOBRAfrRAC SSAR analysis initial conditions.
Re reason that ICs for LBLOCA window mode analyses are similar to those of smaller break. es for AP600 LTC calcui.aions is because the actuation of the automatic depressuritation system (ADS) crr.tes large cpeniags which cause the thennal-hydraulic performance of all LOCA breaks to become similar in thr long term.
Furthermore, the LBLOCA ICs correspond well to the ICs with which WCOBRAfrRAC was qualified in the Reference 440.728-2 studies. The components initiated as totally void were modeled in that way m the Reference 440.728-2 case.malyses. Witnin the cases reported in that reference, the downcomer was initiated totally full to the cold leg elevation in the Section 2.1 analysis of Appendix A, and initiated at a level slightly above the core top elevation in the Section 5 analyses. The upper plenum was modeled at IC void fractions from 0.3 to 1.0 in various cases c' Reference 440.728 2, and the core was initially covered with liquid in all cases.
Recalling again that Reference 440.728-2 has established that the LTC performance is NOT dependent upon the WCOBRA/ TRAC initial conditions at the start of a window, the range of ICs associated with the AP600 LBLOCA SSAR transients has been suitably qualified by the Reference 440.728 2 timulations.
In the long term cooling phase of an AP600 LOCA event, the break effects are not among the more important phenomena of interest. As reflected in the LTC PIRT in Table 1 1 of Reference 440.728 2, break now is ranked as being of Medium imponance during IRWST injection and Low importance during sump injection. He injection parameters (DVI line pressure drop, sump /IRWST driving head) and the ADS path vent parameters (ADS Stage 4 flow, hot leg behavior) are the HIGH ranked parameters which dominate LTC transie..t flow behavior. He break conditions postulated are not of primary importance during the LTC phase.
Test SB21 at the Oregon State University test facility simulated a relatively large cold leg break during IRWST and sump injection. In comparing the test results of SB21 during the long term cooling phase with those of the other OSU tests, similar behavior is observed for the downcomer/ core masses and the DVI line injection from the available water source. A detailed examination of the trends among these parametet as a function of break size over the range of the OSU tests has been performed by comparing Test SB21 with SB23, the smallest size break test performed.
The Matrix Test 21 and Test 23 results (Reference 440.728 3) for the important mass and DVI inlet flow parameters were ccmpared at the times corresponding to (1) the end of IRWST injection and (2) once sump injection is established. At the end of IRWST injection during SB21 (9000-11000 seconds) the total DVI flow is approximately [
]"; at the comparable time of 15000-17000 seconds for SB23, the total DVI flow is also approximately [
}". He downcomer and core masses are also in good agreement between SB21 and SB*.3 Over these time periods, Test SB21 has [
]" in the dawncomer vs. [
]" for S323, and Test SB21 has [
]" in the core vs. [
)" (w SB23. Therefore, the largest and smallest breaks in the range of cold leg break tests performed show similar LTC IRWST phase performance.
Likewise, during the equilibrium sump injection (12000-14500 seconds in SB21,18000-20500 in SB23) the same independence from break size exists between the largest and smallest OSU loop break tests. De SB21 total DVI injection flow is approximately [
]"; in the SB23 comparable time span, the total DVI flow is approximately [
]" He downcomer and core masses are also in good agreement between SB21 and SB23 during these time per;ods: [
1" in the downcomer, [
]" in the core.
440.728 2 3 Westinghouse I
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NRb REQUEST FOR ADDITIONAL INFORMATION 1
ihlmiti:
1:;
Le close agreement between SB21 and SB23 results validates that LOCA break size.s not important relative to the most important long term coolir.g ECCS performance parameters.
In conclusion, it has been shown that the initial conditions hput to a window mode ECOBRAfrRAC analysis do not determine the outcome of the calculation; the boundary conditions specified determine the outcome. The Reference 440.728-2 simulation matris qealifies ECOBRAfrRAC for the long-term cooling analysis of any postulated LOCA break in the AP600, since by the time in the LOCA event that the LTC analyses are performed, large break LOCAs exhibit similar conditions and similar phenomena to the smaller break sires.
References:
440.728-1 Response to RAI 440.72(,, Westinghouse Electric Corporation, October 1997.
440.728-2 Garner, D. C. et. al., *ytCOBRA/ TRAC OSU Long-Term Cooling Final Validation Report,"
WCAP-14776 Revision 2 Proprietary, May 1997.
440.728 3 Andreychek. T. S. et. al., "AP600 Low-Pressure Integral Systems Test at Oregon State University Test Analysis Report," WCAP-14292, Proprietary, September 1995.
SSAR Revision: NONE t
e
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