ML20236R105

Discusses Request for Withholding Info from Public Disclosure Re WCAP-14932.Some Matl May Be Withheld in Accordance w/10CFR2.790(a)(4),but Certain Other Matl Should Be Released & Placed in PDR

ML20236R105
Person / Time
Site:	Summer
Issue date:	07/16/1998
From:	Padovan L NRC (Affiliation Not Assigned)
To:	Liparulo N WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
References
NUDOCS 9807210246
Download: ML20236R105 (5)

Text

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.. $n nn%. Nd p *a UNITED STATES g j NUCLEAR REGULATORY COMMISSION g WASHINGTON, D.c. '- anni

% * * * * * /j July 16,1998 Mr. N. J. Liparulo, Manager Equipment Design and Regulatory Engineering Nuclear Services Division Westinghouse Electric Corporation Post Office Box 355 -

Pittsburgh, PA 15230-0355

SUBJECT:

REQUEST FOR WITHHOLDING INFORMATION FROM PUBLIC DISCLOSURE, V. C. SUMMER NUCLEAR STATION

Dear Mr. Liparuto,

By your application dated July 25,1997, and affidavit executed by Henry A. Sepp on July 25, 1997, you submitted WCAP-14932. "Probabilistic and Economic Evaluation of Reactor Vessel Closure Head Penetration Integrity for Virgil C. Summer Nuclear Plant" to us, and requested that it be withheld from public disclosure pursuant to 10 CFR 2.790.

Some of your reasons for requesting our withholding of this information were 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 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, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.

(c) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

We have reviewed your application and all of the supporting information in accordance with the requirements of 10 CFR 2.790. We conclude that some of the material may be withheld in

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accordance with 10 CFR 2.790(a)(4), but that certain other material should be released and /

placed in the Public Document Room (PDR). The information that we do not believe includes distinguishing aspects, or would improve a competitor s economic advantage, and information that we do not believe constitutes trade secrets or proprietary commercialinformation is f

outlined in the Enclosure, 1]g in accordance with 10 CFR 2.790(c), we are notifying you that we will place the information in the PDR thirty (30) days from the date of this letter. If within thirty (30) days of this letter, you request withdrawal of these documents in accordance with 10 CFR 2.790(c), or provide additional reasons for the withholding of information not already expunged from the documents, we will consider your request in light of applicable statutes and regulations. We will then determine if we will withhold the documents from public disclosure or retum them to you.

9807210246 900716 PDR ADOCK 05000395 P PDR o e,me 4 3 prmtf

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i Withholding from public inspection shall not affect the right, if any, of persons properly and directly concerned to inspect the documents. If the need arises, we may send copies of this information to our consultants working in this area. We will, of course, ensure that the .

consultants have signed the appropriate agreements for handling proprietary information.

If the basis for withholding this information from public disclosure should change in the future, such that the information could then be made available for public inspection, you should promptly notify us. You should understand that we may have cause to review this determination in the future (e.g., if the scope of a Freedom of Information Act request includes your withheld information). In all review situations, if we make a determination adverse to the above, we will notify you in advance of any public disclosure.

Sincerely, Original signed by:

L. Mark Padovan, Project Manager Project Directorate 11-1 Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation Docket No. 50-395

Enclosure:

As stated cc w/ encl: See next page DISTRIBUTION:

Docket File PUBLIC PD 11-1 Reading File ACRS OGC JZwolinski JMedoff LPlisco, Ril 2OCUMENT NAME: G:\ SUMMER \ SUM 98602. PRO 7e recilve a copy of this document, indicate in the box: "C" = Copy without enclosures "E" = Cop 1 with enclosures *N" = No copy A OFFICE PM , 6 LA cn C EMCB:NRR IJ OGC lC-Acting PQ('

NAME MPadovan F% EDunnington ESullivan fM MPSiemiendN' $ PTKuoi lDATE 6/R98 6/#/98 6/2498 L) "7/ >/98 7/i (/98 OFFICIAL RECORD COPY

VIRGIL C. SUMMER NUCLEAR STATION cc:

Mr. R. J. White J. B. Knotts, Jr.. Esquire Nuclear Coordinator Winston & Strawn Law Firm S.C. Public Service Authority 1400 L Street N.W.

c/o Virgil C. Summer Nuclear Station Washington D.C. 20005-3502 Post Office Box 88. Mail Code 802 Jenkinsville, South Carolina 29065 Resident Inspector / Summer NPS c/o U.S. Nuclear Regulatory Commission Route 1. Box 64 Jenkinsville. South Carolina 29065 Regional Administrator. Region II U.S. Nuclear Regulatory Commission Atlanta Federal Center 61 Forsyth Street. SW. Suite 23T85 Atlanta, Georgia 30303 Chairman. Fairfield County Council Drawer 60 Winnsboro. South Carolina 29180 Mr. Virgil R. Autry Director of Radioactive Waste Management Bureau of Solid & Hazardous Waste Management Department of Health & Environmental Control 2600 Bull Street Columbia. South Carolina 29201 Mr. Robert M. Fowlkes. Manager Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station. Mail Code 303 Post Office Box 88 Jenkinsville. South Carolina 29065 Ms. April R. Rice. Manager Nuclear Licensing & Operating Experience South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station. Mail Code 830 Post Office Box 88 Jenkinsville. South Carolina 29065 Mr. Gary J. Taylor. Vice President Nuc' lear Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88 Jenkinsville. South Carolina .29065

3 Proprietary Finding On WCAP-14932, "Probabilistic and Economic Evaluation of Reactor Vessel Closure Head Penetration Integrity for Virgil C. Summer Nuclear Plant" l

We conclude that Table 4-3, Table 4-5, and Figure 4-2 in WCAP-14932, Revision 0, do not contain proprietary, or confidential commercial or financial information. Our basis for this determination is provided below.

You claim that the probability of failure values calculated for the V.C. Summer Nuclear Plant (VCSNP) vessel head penetration (VHP) nozzles (provided in Table 4-3, Table 4-5, and Figure 4-2 of Proprietary Class 2C Report WCAP-14932, Revision 0) are proprietary. This is inconsistent with you not identifying that the corresponding probability of failure values for D.C.

Cook 2, Almaraz 1, Ringhals 2, and North Anna 1 in Table 4-2 of WCAP-14901, Revision 0

• Background and Methodology for Evaluation of Reactor Vessel Closure Head Penetration Integrity for the Westinghouse Owners Group" are proprietary. Accordingly, we determine that your probability of failure values for the VHP nozzles at VCSNP (calculated using the VHPNPROF Monte Carlo Simulation Code) are non-proprietary. A more in-depth explanation follows.

On July 25,1997, you submitted Topical Report WCAP-14901, Revision 0, to us as one of the two generic responses to Generic Letter (GL) 97-01, " Degradation of Control Rod Drive Mechanism Nozzle and Other Vessel Closure Head Penetrations," for the utility members of Westinghouse Owners Group (WOG). You designated WCAP-14901, Revision 0, to be a Non-Pmprietary Class 3 document. Accordingly all text description, crack initiation and growth probability equations, input parameter data, and crack initiation and failure probability data in WCAP-14901, Revision 0, was non-proprietary.

On July 30,1997, the South Carolina Electric and Gas Company (SCE&G) submitted its 120-day GL-97-01 response to us. SCE&G informed us that it was participating in the WOG's program to assess the effects of age-related degradation on the structuralintegrity of pressurized water reactor VHP nozzles. SCE&G also indicated that Westinghouse Electric Corporation (WEC) had performed a VHP nozzle probabilistic safety assessment during design of VCSNP, and that the assessment results were provided in WEC Proprietary Class 2C Topical Report WCAP-14932, Revision 0. SCE&G included WCAP-14932, Revision 0, in its 120-day GL 97-01 response to us.

We have completed our initial review of all 120-day WOG member GL 97-01 responses, including non-proprietary WCAP-14901, Revision 0, and proprietary WCAP-14932, Revision 0.

Comparing WCAP-14932, Revision 0, with WCAP-14901, Revision 0, enabled us to arrive at the following conclusions:

1. WEC equations for calculating crack initiation times, crack growth rates, and the times to failure for assessing the VHP nozzles at both VCSNP and at other WOG member plants are non-proprietary equations since WEC uses the same calculation methods in both proprietary and non-proprietary reports. Therefore, none of the plant-specific parameter inputs to the equations for times to crack initiation, for adjusting for crack growth, or for calculating times to crack failure can be designated as being proprietary. We confirmed that none of the WOG member utilities (that have endorsed the methods and contents detailed in WCAP-14901, Revision 0) have indicated that the parameter inputs to the creck initiation, Enclosure

crack growth, and time to failure equations are proprietary. The VHPNPROF Monte Carlo Simulation Methods are based on these inputs. Our review of Proprietary Class 2C Report WCAP-14932, Revision 0, and Non-Proprietary Class 3C Report WCAP-14901, Revision 0, indicates that the VHPNPROF Monte Carlo Simulation was used to assess the VHP nozzles at both VCSNP and other WOG member plants.

2. You indicated on page 4-4 of non-proprietary WCAP-14901, Revision 0, that you had calculated the probability of failure values using the VHPNPROF Monte Carlo Simulation Methods for four nuclear plants where sufficient head penetration information and inspection results were available. You identified the plants, specified key input parameter values for the plants, and provided calculated plant failure probabilities in Table 4-2 of WCAP-14901, ,

Revision O. You did not designate in Table 4-2 that either the critical input parameter values or the probability failures calculated for the D.C. Cook 2, Almaraz 1, Ringhals 2, and North Anna 1 plants were proprietary. This contradicts you claiming that the corresponding VHPNPROF probability of failure values used for the assessment of the VCSNP VHP nozzles are proprietary.

Accordingly, we conclude that the information in Table 4-3, Table 4-5, and Figure 4-2 of WCAP -14932, Revision 0 sought to be withheld from public disclosure does not meet the requirements of 10 CFR 2.790.

.