ML20237D316

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Requests That W Response to NRC Ltrs Re Requests for Withholding Info Be Withheld from Public Disclosure,Per 10CFR2.790
ML20237D316
Person / Time
Site: 05200003
Issue date: 08/21/1998
From: Mcintyre B
WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To: Quay T
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20138K720 List:
References
AW-98-1282, NUDOCS 9808260020
Download: ML20237D316 (27)


Text

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. 1 Westingflouse Energy Systems Ba 355 Pinsburgh Pennsylvania 15230-0355 Electric Corporation l

r AW-98-1282 August 21,1998 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: MR. T. R. QUAY APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

SUBJECT:

RESPONSE TO NRC LETTERS CONCERNING REQUESTS FOR WITIIHOLDING INFORMATION

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 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-98-1282 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 l be withheld from public disclosure in accordance with 10CFR Section 2.790 of the Commission's regulations.

Correspondence with respect to this application for withholding or the accompanying affidavit should reference AW-98-1282 and should be addressed to the undersigned.

Very truly yours,

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6:~ A9' Brian A. McIntyre, Manage w

Advanced Plant Safety and Licensing jml cc: T. Carter, NRC - OWFN/MS SE7 9808260020 980821 .

PDR ADOCK 05200003 l A PDR i

. . . . - __________ __ i

COPYRIGHT NOTICE t

The repons transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to

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make the number of copies of the information contained in these reports which are necessary for its j internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, 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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l PROPRIETARY INFORMATION NOTICE l l 1

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 ofinformation Westinghouse customarily holds in confidence identified in Section (4)(ii)(a) thorough (4)(ii)(f) of the af'idavit accompanying this transmittal pursuant to 10 CFR2,790(b)(1).

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l-a AW-98-1282 AFFIDAVIT i COMMONWEALTli OF PENNSYLVANIA:

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j 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 l

Westinghouse Electric Company, a division of CBS Corporation (" Westinghouse"), and that the averments

! of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:

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Brian A. McIntyre, Manager Advanced Plant Safety and Licensing Sworn to and subscribed i before me this 2/ day l

of duo M0

,1998 7- .

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h Notary Public l

Notarial Seal Lorraine M. Piplica, Notary Public Monroeville Boro, Allegheny County My Commission Expires Dec. 14,1999

, Member, Pennsylvania Association of Notartes no4a wr

AW-98-1282 (1) I am Manager, Advanced Plant Safety And Licensing, in the Nuclear Plant Projects Division, of ,

i the Westinghouse Electric Company, a division of CBS Corporation (" Westinghouse"), and as l l

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 pint licensing and rulemaking proceedings, and am authorized to apply for its withholding on behalf of the Westinghouse Energy Systems Business Unit.

1 (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. 4 1

4 (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. l (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.

1 (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.

l Under that system, information is held in confidence ifit 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-98-1282 (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. l I

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 l the Westinghouse competitive position.

l L. (b) It is information which is marketable in many ways. The extent to which such information is availt.ble to competitors diminishes the Westinghouse ability to sell l . products and services involving the use of the information.

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AW-98-1282 4

(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 advantag- to the competition of those countries, y

(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.

(v) Enclosed is Letter DCP/NRCl429, (NSD-NRC-97-5772), August 21,1998, being transmitted by Westinghouse Electric Company (W), a division of CBS Corporation l

(" Westinghouse"), letter and Application for Wthholding Proprietary Information from Public Disclosure, Brian A. McIntyre (W), 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 cenification application and is expected to be applicable in other licensee submittals in response to certain NRC requirements forjustification oflicensing advanced nuclear power plant designs.

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AW-98-1282 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.

4 (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 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.

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AW-98-1282 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 WESTINGHOUSE DCP/NRCl429 AUGUST 21,1998 I

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C 0 V E R i 5 H E E

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T FAX To: Ralph Landry

Subject:

PRHR Heat Transfer Correlation Date: December 17,1996 Pages: 17, including this cover sheet.

COMMENTS Ralph, Attachv. is a draft copy of what we will be sending you on the above subject. If you get a chance to look at it, I'd appreciate any feedback you might have Wed. or Thurs. Will you be at ACRS meeting? If not, Larry indicated we might be get together after the meeting on level swell.

TharJa.

From N desk of.

Eart H. Novendstem Manager. Advanced att WER Plant Safety Anahms Wesunghouse PO Box 356 Pmsburgh, PA 15235 (412)374 4790 Far (412) 374-5744 l

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i The analysis of the PRHR test data (WCAP 12980, revision 2) has indicated that the heat transfer l

l correlations used for the PRHR, which were given in the original LOFTRAN Code Applicability j Document WCAP 14234 Appendix A, require modification. The table below summarizes the l i

original PRHR heat transfer correlations used and the new correlations to be used.

Table 1

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Region Original Heat Transfer New Heat Transfer Correlation Used Correlation -

Forced Convection inside of Petukhov Popov Dittus Boelter the PRHR tubes Narural Convection Heat Ecken Jackson McAdams l Transfer Outside of the PRHR l Tubes Boiling Heat Transfer Outside Exponent Type Based on Modified Rohsenow

( of the PRHR Tubes Phase 1 PRHR Data The forced convection heat transfer on the inside of the PRHR tubes will use the Dittus Boelter correlation. This correlation has been compared to the analyzed PRHR data as shown in Figure 9-3 from the revised PRHR test analysis report (WCAP 12980, revision 2). The generally more accepted Dittus Boelter single phase convective heat transfer correlation provides reasonable agreement with the PRHR data, particularly at higher Reynolds numbers. The comparisons presented in WCAP-12980 indicate that the Dittus-Boelter correlation is acceptable for calculating primary side PRHR heat transfer.

The natural convection heat transfer correlation used on the ouuide of the PRHR tubes, originally used in LOFTRAN, was the Eckert Jackson correlation. When comparisons of this correlation to the i PRHR test data were made (at the bottom of the tubes), this correlation was best estimate to slightly high relative to the data. The McAdams natural convection correlation was evaluated and found to give a better fit to the test data as seen in Figures 9-4 and 9-5 from WCAP-12980 Revision 2.

Therefore, LOFTRAN analyses will change from Eckert Jackson to McAdams for the natural convection heat transfer. It should be noted that for natural convection heat transfer in NOTRUMP and WCOBRA/ TRAC McAdams is used.

Based on the PRHR test data results presented in WCAP 12908 Revision 1, the boiling data was originally fitted to an equation where heat flux was an exponential function of AT using the following .

form:

g" = A ate where q,- = heat flux AT = wall temperature minus saturation temperature A&B= coefficients found from fits to Phase 1 PRHR test data The steady state data from Phase 1 and Phase 2 tests were used to fit a modification of the Rohsenow nuclease boiling correlation. The Rohsenow correlation was selected since the Rohsenow parameters l

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C are euy to calculate and do a good job of correlating nucleate boiling data and reflect the pressure dependency of the IRWST. The nominal fit to the PRHR data is shown in Figure 9-20 along with the upper and lower 95th percentile fits _ to the data. For the upper 95th percentile. this line is defined such that 95 percent of the data lie below this line. For the lower 95th percentile line,95 percent of the data lies above the line. In future LOFTRAN analyses, the nominal fit for the Rohsenow correlation will be used for nucleate boiling heat transfer.

Use of the nominal Rohsenow fit is consistent with the approach used for other heat transfer regimes in the PRHR and in general with heat transfer models used elsewhere in plant safety analyses. Use of nominal, rather than the upper or lower 95th percentile of the correlation, is appropriate since adequate conservatism in the safety analysis is maintained by using many other independent conservative input assumptions used in the safety analysis. The analyses use a bounding approach where many of the plant paramciers are assumed to be at the worst case upper or lower bound values.

De safety analyses assumes maximum uncertainties on initial conditions such as RCS flow. RCS temperature RCS pressure, pressurizer water volume and steam generator inventory. Uncenainties are also included in core neutron kinetics parameters, setpoints and actuation delays. For core decay heat, the ANS 1979 + 2 sigma model is used. For the PRHR model, uncertainties are it,cluded on PRHR volumes, surface areas, flow resistances, IRWST initial temperature and actuation time delays.

To quantify the sensitivity of the accident analyses to the uncertainty in the Rohsenow correlation, transients were run which used the upper 95 percentile line, the lower 95 percentile line and the  ;

nommal fit lines. A plant cooldown transient and a heatup transient which exercised the wide range i of conditions expected in the PRHR were chosen. The cooldown transient analyzed was the - 1 l' inadvertent operation of the PRHR while a power. Operation of the PRHR u power will result in l forced flow through ihe PRHR with high inlet temperatures. His transwm will have reimively high hem fluxes and a higher proportion of the PRHR tube bundle will be in nuclease boiling. His transient will show the representative maximum overall deviation in hem transfer due to the uncertainty in the Rohsenow boiling heat transfer correlation.

1 As a representative heatup transient, the loss of normal feedwuer evem was chosen. During this transient the PRHR is operated under forced flow conditions and under natural circulation flow conditions. During a loss of norreal feedwater and similar loss of steam generator heat sink transients, the PRHR provides the safety related means for long term core decay heat removal.

Figures I through 4 show the results of the inadvertent operation of the PRHR while a power analysis. Inadvertent operation of the PRHR at power causes an injection of relatively cold water into the reactor coolant system. This produces a reactivity insertion in the presence of a negative moderator temperature coef5cient. Since the fluid in the PRHR best exchanger is initially in equilibriusc with the IRWST tempermure, the initial flow out of the PRHR is significantly colder than the RCS fluid. FoGowing this initial insurge, the PRHR outles temperature increases and is limited by the cooling capacity of the PRHR. As shown in Figure 3, around 12 seconds there is a large peak in core power ese to the initial lasurge of cold fluid from the PRHR. AAer the original fluid in the PRHR fluid is purged, the temperature of the fluid exiting the PRHR increases and core power decreases to a value which is in equilibriurn with the heat removal rate of the steam generators and the PRHR. For this event the peak core power achieved and the mmimum DNBR are dependent on l the initial volume of cold fluid in the PRHR and are independent of the magnitude of the PRHR heat transfer. PRHR heat transfer capacity only affects the final equilibriurn power. As shown in Figure 1, with the RCPs running and the reactor at power conditions, the PRHR removes approximately 10% of rued plant power. De deviation in overall PRHR heat removal capacity due to the uncertainty in the Rohsenow nucleate boiling correlation is less than 10.7% of plant rued power.

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l Figures 5 through 8 show the results of a complete loss of normal feedwater analysis using the upper 95 percentile line, the lower 95 percentile line and the nominal fit lines for the Rohsenow correlation.

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' The PRHR total heat flux is shown in Figure 5. The reactor coolant pumps are running untiijust after 1000 seconds. While the RCPs are running, PRHR heat transfer is - 6 % of rated plant power.

After the reactor coolant pumps are tripped, PRHR heat transfer drops to - 1% of rated plant power.

During the period where pumps are running the, uncertainty in the boiling heat transfer coefficient causes a total deviation of less than 10.5 % of rated plant power. After the RCPs trip the difference

' in overall PRHR hear 8 transfer is negligible. From Figure 6, the deviation in peak pressurizer water 2

volume is +67 ft to -42 ft . The peak pressurizer water volume occurs in all of the three cases at least 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> after the start of the transient. Figure 7 shows that there is no increase in peak RCS pressure due to the correlation uncertainty.

The use of the nominal fit for the Rohsenow boiling correlation is consistent with the other heat transfer regime correlations used and other conservative assumptions used in the analysis bound the correlation uncertainty.

In conclusion the uncertainty in the boiling heat transfer correlation has small or negligible impact on the results of the accident analysis and no impact on the licensing basis conclusions of the accident analyses. Westinghouse believes the application of the correlations are sufficiently conservative to i

address the data scatter observed in the tests and intends to utilize nominal values of the PRHR heat transfer correlations for the final Chapter 15 SAR analyses.

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