NL-06-040, Additional Information Regarding Proposed Change to Indian Point 2 Technical Specifications for LBLOCA Analysis Methodology

Additional Information Regarding Proposed Change to Indian Point 2 Technical Specifications for LBLOCA Analysis Methodology

ML061080451
Person / Time
Site:	Indian Point
Issue date:	04/11/2006
From:	Dacimo F Entergy Nuclear Northeast
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-06-040, TAC MC8427
Download: ML061080451 (14)

Text

-4 Entergy Nuclear Northeast Indian Point Energy Centet

- _! a ,450 Broadway, GSI3 P.O. Box 249

-'E tergy Buchanan, NY 10511-024S Tel 914 734 6700 Fred Dacimo Site Vice President Administration April 11,2006 Re: Indian Point Unit 2 Docket 50-247 NL-06-040 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington. DC 20555-0001

SUBJECT:

Additional Information Regarding Proposed Change to Indian Point 2 Technical Specifications for LBLOCA Analysis Methodology (TAC MC11427)

REFERENCE:

1. Entergy letter NL-05-107 to NRC; "Proposed Change to Indian Point 2 Technical Specifications Regarding LBLOCA Analysis Methodology",

dated September 26, 2005.

Dear Sir or Madam:

Entergy Nuclear Operations, Inc (Entergy) requested, in Reference 1, NRC approval for use of the ASTRUM (Advanced Statistical Treatment of Uncertainties Method) methodology at Indian Point 2 for analysis of Large Break Loss of Coolant Accidents (LBLOCA). Entergy is submitting additional information regarding this request in response to a telephone call with NRC staff on March 6E, 2006.

The proprietary version of this response is provided in Attachment 1 and the non-proprietary version is provided in Attachment 2. The additional information provided in these attachments does nct change the conclusions of the No Significant Hazards Evaluation included in Reference 1.

As Attachment 1 contains information proprietary to Westinghouse Electric Company, it is supported by an affidavit signed by Westinghouse, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations. Accordingly, it is respectfully requested that the information that is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR 2.390 of the Commission's regulations. Westinghouse authorization letter dated March 15, 2006 (CAW-06-2113), with the accompanying affidavit, Proprietary Information Notice, and Copyright Notice are provided in Enclosure A.

• 4AmA

NL-06-040 Docket 50-247 Page 2 of 2 Correspondence with respect to the copyright on proprietary aspects of the items listed above or the supporting affidavit should reference CAW-06-2133 and should be addressed to B. F.

Maurer, Acting Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P. 0. Box 355, Pittsburgh, Pennsylvania 15230-0355.

There are no new commitments identified in this submittal. If you have any questions or require additional information, please contact Mr. Kevin Kingsley at (914) 734-6695.

I declare under penalty of perjury that the foregoing is true and correct. Executed on BAG S lyI Fred Dacimo Site Vice President Indian Point Energy Center cc:

Mr. JDhn P. Boska, Senior Project Manager, NRC NRR DORL Mr. Samuel J. Collins, Regional Administrator, NRC Region I NRC Resident Inspector's Office, Indian Point 2 Mr. Peter R. Smith, NYSERDA Mr. Paul Eddy, NYS Department of Public Service

ATTACHMENT 2 TO NL-06-040 ADDITIONAL INFORMATION FOR PROPOSED TECHNCIAL SPECIFICATION CHANGE REGARDING USE OF ASTRUM FOR LBLOCA ANALYSIS (NON-PROPRIETARY VERSION)

From Westinghouse Letter LTR-LIS-06-129, Rev 1, NP-Attachment, dated March 10, 2006 ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 DOCKET 50-247

I---

NL-06-040 Attachment 2 Docket 50-247 Page 1 of 3 Question 1:

Please confirm that Entergy and the LBLOCA analysis vendor have ongoing processes which assure that the input values and range of parameters for the Indian Point 2 LBLOCA analyses conservatively bound the values and ranges of those parameters for the as-operated Indian Point Unit 2 plant.

Response

Both Entergy Nuclear Operations, Inc and Westinghouse Electric Company (analysis vendor) have ongoing processes such that the values and ranges of the Best Estimate Large Break LOCA (BE-LELOCA) analysis inputs for peak cladding temperature and oxidation-sensitive parameters bound the values and ranges of the as-operated Indian Point 2 (IP2) plant for those parameters, in accordance with the approved methodology (WCAP-1 6009-P-A).

Question 2:

Please address slot breaks at the top and side of the Indian Point Unit 2 cold leg RCS pump discharge pipe.

Response

The break location was generically addressed during the development of the BE-LBLOCA methodology. Break type and size are specifically considered for the Indian Point Unit 2 ASTRUM LBLOCA transient calculations through sampling of both parameters. This analysis determined that the DECL.G break is limiting. The uncertainties related to break type and size were included in the Indian Point Unit 2 Best Estimate ASTRUM large break LOCA analysis.

For Small Break LOCA (SBLOCA) events, the effects of break location have been generically evaluated as part of the application of the NOTRUMP Evaluation Model (Reference 1). This document concluded that a break in the Reactor Coolant System (RCS) cold leg was limiting.

Additionally, the effects of break orientation were considered during the evaluation of Safety Injection in the Broken Loop and application of the COSI Condensation Model (Reference 2). This work concluded that a break oriented at the [ ]Iac of the RCS cold leg piping was limiting with respect to Peak Cladding Temperature (PCT).

While these references specifically address the short-term response to the LOCA break spectrum, the long-term effects associated with potential Reactor Coolant Pump (RCP) loop seal re-plugging core uncovery is addressed in the following.

A review of the analysis conditions associated with potential core uncovery due to loop seal re-plugging has previously been performed in Reference 3. Reference 3 documents the Westinghouse position with regards to the potential for Inadequate Core Cooling (ICC) scenarios following Large and Intermediate Break LOCAs as a result of loop seal re-plugging. Reference 3 concludes the following:

• The reactor coolant system response following a LOCA is a dynamic process and that the expected response in the long term is similar to the response that occurs in the short term.

NL-06-040 Attachment 2 Docket 50-247 Page 2 of 3 This short term response has been analyzed extensively through computer analysis and tests and is well documented.

Consideration of the physical mechanisms for liquid plugging of the pump suction leg U-bend piping following large and intermediate break LOCA at realistic decay heat levels precludes quasi steady-state inadequate core cooling conditions.

It is important to emphasize that the operator guidance provided in the Emergency Response Guidelines includes actions to be taken in the event of an indication of a challenge to adequate core cooling following a LOCA.

A review of the key contributors associated with long-term loop seal plugging core uncovery scenarios, under LOCA conditions, was performed as part of Reference 4 including a review of pertinent experimental data. a, c

NL-06-040 Attachrnent 2 Docket 50-247 Page 3 of 3 A review of the generic work performed in References 3 and 4, which includes discussions regarding the effectiveness of the prescribed post-LOCA recovery guidance provided in the Emergency Response Guidelines (ERGs), was performed for IP2. As a result of this review, it can be concluded that post-LOCA core uncovery scenarios resulting from loop seal re-plugging do not constitute a significant concern to IP2 plant safety.

References:

1. WCAP-11372-A, 'Westinghouse Small Break LOCA ECCS Evaluation Model Generic Study With the NOTRUMP Code", S. D. Rupprecht, et al., 1986.

2. WCAP-1 0081-NP Addendum 2, Revision 1, "Addendum to the Westinghouse Small Break ECCS Evaluation Model Using the NOTRUMP Code: Safety Injection into the Broken Loop and COSI Condensation Model", C. M. Thompson, et al., October 1995.

3. OG-87-37, "Westinghouse Owners Group (WOG) Post LOCA Long Term Cooling, Letter from Roger Newton (WOG) to Thomas Murley (NRC)", August 26, 1987.

4. NSD-NRC-97-5092, "Core Uncovery Due to Loop Seal Re-Plugging During Post-LOCA Recovery," Letter from N. J. Liparulo (W) to NRC, March, 1997.

ENCLOSURE A TO NL-06-040 Westinghouse authorization letter dated March 15, 2006 (CAW-06-2113),

with the accompanying Affidavit, Proprietary Information Notice, and Copyright Notice ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 DOCKET NO. 50-247

O Westinghouse Westinghouse Electric Compaly Nuclear Services P.O. Box 355 Pittsburgh, Pennsylvania 15230-0355 USA U.&. Nuclear Regulatory Commission Directtel: (412) 374-4419 Document Control Desk Direct fax: (412) 374-4011 Washington, DC 20555-0001 e-mail: maurerbfgwestinghouse.com Our ref: CAW-06-2113 March 15, 2006 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE Sutject: LTR-LIS-06-129, Rev. 1, P-Attachment, "Response to Indian Point 2 ASTRUM LOCA Slot Break RAI" (Proprietary)

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-06-2113 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and address s with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commissicn's regulations.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Entergy Nuclear Northeast.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-06-2113, and should be addressed to B. F. Maurer, Acting Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.

Very truly yours, B. F. Maurer, Acting Manager Regulatory Compliance and Plant Licensing Enclosures cc: B. Benney L. Feizollahi A BNFL Group company

CAW-06-21 13 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally appeared B. F. Maurer, 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 LLC (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:

B. F. Maurer, Acting Manager Regulatory Compliance and Plant Licensing Sworn to and subscribed before rme this /5 day of ) 2006 Notary Public Notarial Seal Sharon L Rou, Notary Publc Vlon oeville Boro. All egheny Co unty§ My Cmunrrssion Expires Januay 29.2007 Member, Pennsylvania Association Of Notaries

2 CAW-06-21 13 (I) I am Acting Manager, Regulatory Compliance and Plant Licensing, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), 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 rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

(2) 1am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse "Application for Withholding" accompanying this Affidavit.

(3) 1have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to the provisions of paragraph (bX4) 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 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:

(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.

3 CAW-06-2 113 (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.

(b) It is information that 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.

(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 componert may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

4 CAW-06-21 13 (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.

(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, 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) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in LTR-LIS-06-129, Rev. 1, P-Attachment, "Response to Indian Point 2 ASTRUM LOCA Slot Break RAI" (Proprietary), dated March 10, 2006, for the Indian Point Unit 2 Power Station, being transmitted by Entergy Nuclear Northeast letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse for Indian Point Unit 2 is expected to be applicable for other licensee submittals in response to certain NRC requirements forjustification of assumed cold leg break geometries.

This information is part of that which will enable Westinghouse to:

(a) Analyze cold leg break accident scenarios.

(b) Draw specific conclusions and results for individual plant applications.

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 analyzing various cold leg break geometries.

5 CAW-06-21 13 (b) Westinghouse can sell support and defense of analyses related to cold leg breek evaluations.

(c) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to 1he competitive position of Westinghouse because it would enhance the ability of competitors to provide similar LOCA analyses 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.

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.

Further the deponent sayeth not.

PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the N4RC in connection with requests for generic and/or plant-specific review and approval.

In order to conform to the requirements of 10 CFR 2.390 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 (I) 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 Sections (4)(ii)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to I0 CFR 2.390(b)(1).

COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted tD 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, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 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 pennitted 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, DC 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 wvas identified as proprietary.