ML20237D268

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Requests That Proprietary Informal Correspondence Be Withheld from Public Disclosure,Per 10CFR2.790
ML20237D268
Person / Time
Site: 05200003
Issue date: 08/18/1998
From: Mcintyre B
WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To: Quay T
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20138K709 List:
References
AW-98-1276, NUDOCS 9808250283
Download: ML20237D268 (19)
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Text

_ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ ___ _ - _ _ _ _ _ _ _ _ _ . - _ _ - _ _ _ _ _ _ _ _ .

- (V- s o Westinghouse Energy Systems Ba 355 Pittsburgh Pennsylvania 15230-0355 l Electric Corporation .

AW-98-1276 August 18,1998 Document Control Desk l U.S. Nuclear Regulatory Commission Washington, DC 20555 ,

l ATTENTION: MR. T. R. QUAY APPLICATION FOR WITHiiOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

SUBJECT:

PROPRIETARY INFORMAL CORRESPONDENCE

Dear Mr. Quay:

.The application for withholding is submitted by Westinghouse Electric Company, a division of CBS Corporation (" Westinghouse"), pursuant to the provisions of paragraph (b)(1) of Section 2.790 of the 1 Commission's regulations. It contains commercial strategic information proprietary to Westinghouse l 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-98-1276 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 1 Commission's regulations.

Correspondence with respect to this application for withholding or the accompanying affidavit should reference AW-98-1276 and should be addressed to the undersigned.

Very truly yours, M

Brian A. McIntyre, Manager Advanced Plant Safety and Licensing

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cc: T. Carter, NRC - OWFN/MS SE7 9000250283 980818 PDR ADOCK 05200003~

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4 COPYRIGHT NOTICE I

The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocatian, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.790 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal 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, D.C. 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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PROPRIETARY INFORMATION NOTICE l

Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished 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 concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information 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 designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) contained within parentheses located as a superscript immediately following the brackets enclosing each item of information 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 Section (4)(iiXa) thorough (4Xii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR2.790(b)(1).

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AW-98-1276 AFFIDAVIT COMMONWEALTli OF PENNSYLVANIA:

ss COUNTY OF ALLEGIIENY:

Before me, the undersigned authority, personally appeared Brian 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 Company, a division of CBS Corporation (" Westinghouse"), and that the averments of fact set forth la this Affidavit are true and correct to the best of his knowledge, information, and belief:

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- 7 Brian A. McIntyre, Manager Advanced Plant Safety and Licensing  ;

Sworn to and subscribed j

before me this /8.{lA. day i of //14<A.4d' _ 1998 0

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Notarial Seal Lorrahe M. Piplica. Notcry Public I i-Monroevlhe Boro, Allegheny County 3m, y My Commission Expires Dec.14,1999 Member, Pennsylvania Association of Notartes i

l AW-98-1276 l (1) ' I am Manager, Advanced Plant Safety And Licensing, in the Nuclear Plant Projects Division, of the Westinghouse Electric Company, a division of CBS Corporation (" Westinghouse"), and ta 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 l behalf of the Westinghouse Energy Systems Business Unit.

l (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 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:

1

AW-98-1276 (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) 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 past, present, or future Westinghouse or customer funded development plans 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 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.

l (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 sell products and services involving the use of the information.

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AW-98-1276 (c) Use by our competitor would put Westinghouse 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 Westinghouse of a competitive advantage.

(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.

i' (iii) The information is being transmitted to the Commission in confidence and, under the L 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.

(v) Enclosed is Letter DCP/NRC0793, Revision 1,(NSD-NRC-97-5046), August 18,1998, being transmitted by Westinghouse Electric Company (_W), a division of CBS Corporation (" Westinghouse"), letter and Application for Wthholding 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 Company is in response to questions concerning the AP600 plant and the associated design certification application and is expected to be applicable in other licensee submittals in response to certain NRC requirements for justification of )

licensing advanced nuclear power plant designs.

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_ _ _ _ _ _ _ _ _ _ = _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ . _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ - _ - _ - _ _ _ _ _ _ - _

AW-98-1276

, , 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 Advanced 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 obtaining NRC approval for future plants.

Further this information has substantial commercial value as follows:

(a) Westinghouse plans to sell the use of similar information to its customers for purposes of meeting NRC requirements for advanced plant licenses.

(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 advanced nuclear power designs and licensing defense  !

I 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 j information.

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AW-98-1276 -

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, in order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant 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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ENCLOSURE 2 TO DCP/NRC0793 (NSD-NRC-97-5046) (ReVisioo il NON-PROPRIETARY VERSION OF INFORMAL CORRESPONDENCE l

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COVER FAX l SHEET To: , Bill Huffman/L. Lois(NRC), Cliff Fineman(INEL), L. Hochreiter(PSU)

Subject:

Text to close WCOBRAfrRAC CAD Discussion Items Date: March 21,1997 Pages: 9 , including this cover sheet.

COMMENTS:

Attached are responses, in accordance with the rankings you provided, to close some of the HIGH-ranked outstanding discussion items: Ic, Id,10a,10b, and 10d from the initial set, and item 4 from the follow-on set provided on February 26,1997. Comments about the attachment may be directed to the undersigned. In the next few weeks, responses will be provided to close the remaining discussion items.

N/

cc: B. Rahf B. McInty or informal NRC correspondence file). E. Novendstern l

$-P 3-o From the desk of..,

Robert Kemper Advanced and WER Plant Safety Analysts Wesunghouse Po Box 355 Pittsburgh. PA 15235 (412)374 4579 Fax: (412) 374 4011 l

g*g" Gg e n s o yon e . .- -- -- ...-. - ,

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. lo er in reflood for the AP600 relative to. 3-/4-loop Diants'but' l did not discuss thy. Clarify the reascn for the lower AP600 i

. ranking, if the reason (s) is(are) stollar to that discussed in i

.* part a, provide the same type of inforination requested in parts a l and b.

Enclosure 1

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, 1.c. The AP600 PIRT shows a lower ranking f or downcomer entrainment because it is less important during reflood for AP600 large break j

LCCA events than it is for 3/4-loop plants. Two phenomena which I

can lead to liquid entrainment (and deentrainment) in 3 / 4-1ce; i

plants do not apply to AP600. First, the direct vessel injecticn I of accumulator water and the very large accumulators with which the AP600 is equipped mean that no downcomer boiling occurs in AP6:0 during the time of interest for the calculation of peak cladding temperature. Furthermore, the elevation of the DVI nozzle entrance into the AP600 downcomer is about two feet below the bottom cold leg nozzle elevation, and during the PCT transient the downcomer 1

l liquid level does not advance above the DVI nozzle elevation to any  !

significant extent. Therefore, the safety injection water is net subject to surface 'ntralnment into any high velocity steam which might be progressing from the intact loop cold legs across the downcomer to the break.

The attached figure plots the entrained liquid flow predicted between cells in COBRA downcomer channel #56, which is connected to the broken cold leg, during the AP600 WCOBRA/ TRAC CD=0.3 O EC *.G analysis presented in Chapter 2 of WCAP-14171, Revision 1. FEM (56,1) is the entrained droplet flow into the channel's lower cell f rom the channel below, and FEM (56,3) is the entrained droplet flcw l out of the channel upper cell, which is connected to the broken i cold leg, into the channel above. FEM (56,2) is the flow between the two cells of channel 56. The figure illustrates that although

' as much as 3000 lbm/sec of entrained liquid flows into the cell connected to the break during blowdown, there is almost no entrained liquid entering into that downcomer cell from adjacent cells to proceed ort the break during reflood. For the reasons specified above, downcomer entrainment during reflood is not as important during reflood for AP600 as it is for 3/4 loop plants.

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I AP600 BELOCA CAD CASE 0: MERGE OF NSAPLOT FILE u20 FEM 56

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,/ %o core dUring hm-u cuemeuuu v um Wm Me upper plenua to ow reversal in blowdown. During the flo:

I, reversal, Westinghouse argued that all thr, upper head unter flows to the drop upperthe between plenum and then upper plenua to the and the core due to the large pressur break.

However the flow path to the for upper break head through the hot leg is another water. poss,ble i route To clarify the flow split from the u plenum to the core versus the oper plenum to the hot legs,pper i

provide plots of the flows at the intact and broken loop hot leg junctions RefOence 1. for comparison to the top of the core flows provided in Clarify how the hot leg flows support Westinghouse's position on the flow to the core or provide additional information to clarify Westinghouse's understanding of the flow split and how l i

any uncertainty uncertainty in the calculation is accounted for in the AP600 analysis.

the May 17, 1996, letter. This is a followup to Discussion item Sb in \I 1.d.

The attached figures depict the flow in the two hot legs at the vessel junction during the AP600 blowdown. Early on, within the first second leg reverses and following proceeds the intobreak, ficw in the intact locp hot the vessel. For the remainder of the leg 35 second flows into blowdown, the vessel.any liquid flowing ir,the intact loop hot transient, During the initial seconds of the the influx of liquid from the intact loop hot leg (Figure large flow1) into that the upper plenum in its entirety contributes to the leg (Figure 2). is feeding the break through the broken locp hot In the five to six second time frame, a portion of the influx f rom the broken loop hot leg enters the core as dcwnfIcw into the peripheral or guide tube fuel assemblies (WCAP-14171, Revision 1, Figures 2.2-34 and 2.2-3 6) . Shortly af ter six seconds, all the intact loop hot leg flow into the vessel once again flows through the upper plenum and out the broken Icop hot leg. Beyond 12 seconds, the liquid flow from the intact loop hot leg is in pare predicted to enter the core, and in part proceeds out the broken loop hot leg as liquid and/or er. trained droplets.

This pattern continues until the liquid flow in each of the hot legs diminishes to a small value approximately 18 seconds into the transient.

Note the discussion on page 2-8 does not state that ALL the upper head fluid draining into the upper plenum proceeds into the core.

Some of this upper head fluid also becomes part of the liquid and entrained droplets leaving the upper plenum out through the broken loop hot leg in the 6-12 second time f rame. Overall, approximately one-third of the upper head fluid draining into the upper plenum during this time interval exits through the broken loop hot leg.

The possible uncertainty associated with the upper plenum flow split is addressed in two ways. First, a sensitivity case is being <

performed to identify the worst break location relative to the i pressurizer, and the limiting location will be the basis for the SSAR spectrum. Second, the variation of the CD and KN parameters j

' in the global model matrix being performed for the AP600 SSAR will impact the flow split of liquid from the upper plenum. Together,  !

these studies address uncertainty in the upper plenum flow split by i varying the loop parameters which determine the relative flow {

j. between the core and the hot legs.

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AP600 LBLOCA RC/T CAO CASE 0 DECLC. C0=0.8. Imin=800F. WITH PXS Figure id,-j ; vessel Uppper Plenum to Hot Legs Flows A Flows - Slowdoen WLM 59 2 0 GAP L10 FLOW RATE WEu 59 2 0 CAP ENT FLOW RATE

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conditions,~but in the eniconcludef f. hit oriijInai~unierhinty distribution cas better and more conservative because the new

. distribution had less scatter than the original distribution.

Justify this conclusion because the original distribution allows for larger multipliers and a larger average multiplier than the one developed in Section 4.2.

. 'b. Clarify what Westinghouse means in Section 4.2 by the original

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distribution because distributions from the RNR, Reference 2, and the final 3-/4-loop plant distribution from Reference 6 are referenced.

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c. For the comparisons provided in Section 4.2, Westinghouse found WCOBRA/ TRAC overpredicted the ORNL heat transfer data used as the database. In Reference 6, however, Westinghouse found that  !

WCOBRA/ TRAC underpredicted the same data. Clarify whether the overprediction or the underprediction of the ORNL data is correct, ,

and clarify the reason (s) for the different results in Section 4.2 versus Reference 6.

! d. Because Reference 6 contains the final blowdown cooling heat transfer dis',aibution for 3-/4-loop plants, justify why that ,

distribution was not used in Figure 4.2-1.

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10.a. The AP600 blowdown cooling heat transfer multipliers

, distribution has been established via the direct comparisen of l WCOBRA/ TRAC results with the ORNL high pressure Dispersed Flow Film Boiling heat transfer test data. As presented in WCAP '.4171, Revision 1, this new distribution is valid in the AP600-specific blowdown cooling range and is obtained using a conserva:ive value )

l of Tmin. For the AP600 SSAR matrix of cases, the HOTSPOT computer code has been revised to incorporate this new blewdown cooling heat transfer distribution. The cumulative distribution for AP600 analysis is presented as Figure 4.2-2 in WCAP-14171, Revision 1.

10.b,d. The distribution labelled as 'RMR' on Figure 4.2-2 is exactly that, the blowdown cooling heat transfer distribution presented in Reference 10-1. It is shown for illustrative purposes only. The final, approved blowdown cooling heat transfer distribution for 3/4 loop plants is based on Figure 36 of Reference 10-2; it is depicted as a cumulative f requency distribution in the attachment.

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References:

1. 0 - 1. NTD-NRC-95-4575, Letter from N. J. Liparulo (W) to R. C.

l Jones, Jr. (USNRC), " Revisions to Westinghouse Best-Estimate Uncertainty Report,' October 13, 1995.

, 10-2. NTD-NRC-96-4672, Letter from N. J. Liparulo (W) to R. C.

Jones, Jr. (USNRC), " Resolution of Issues Related to Review of

, WCAP- 12945-P," March 25, 1996.

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Blowdown Cooling HIC Multiplier Distribution DistributionBasedon18JScaledC1and235ORNLDatopoints/4 1

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in its AP600 analyse.s? . . . . . . .

b.

Are all AP600 design changes (relative to three- and four loop plants) that are important to LBlotA addressed through code i (forclarif is, example, direct vessel injection and the accumulators)? That M07A.Rev.y that Westinghouse

), to analyze AP600. did not need to modtfy WC08RA/ TR The approved version of WCOBRA/ TRAC, WCOBRA/ TRAC MOD 7A Revision 1, is modified slightly for the AP600 SSAR large break LOCA analyses solely to f acilitate AP600-specific passive safety system modeling.

All of the WCOBRA/ TRAC updates introduced to model AP600 features are described break LOCA in WCAP-14776; those which are employed in the large best-estimate analyses are described belcw convenience. for

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