NOC-AE-05001836, Revised Response to Request for Additional Information Question 30 Regarding Correlations Used in Computer Codes
| ML050250195 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 01/20/2005 |
| From: | Jordan T South Texas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| D43.01, NOC-AE-05001836, STI: 31829551 | |
| Download: ML050250195 (14) | |
Text
Nuclear Operating Company South 7T=aqor/dEkctdc GaCaUnStaSbon PO. Sa 289 W edsitT=Z 7748 A January 20, 2005 NOC-AE-05001836
.10CFR50.90 File No. D43.01 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN-499 Revised Response to Request for Additional Information Question 30 Regarding Correlations Used in Computer Codes
Reference:
Letter, T. J. Jordan to NRC Document Control Desk, "Complete Response to Request for Additional Information Regarding a License Amendment Request for Approval of a Change in Analytical Methodology," dated November 30, 2004 (NOC-AE-04001819)
The referenced letter provided the complete responses to the NRC request for additional information regarding the use of a revised methodology described in WCAP-14882-S1-P for the loss of normal feedwater/loss of offsite power transient analysis. After reviewing the referenced letter, the NRC staff requested clarification of the response to Question 30. This letter provides the revised response, in which the revised information is annotated with a change bar. contains information proprietary to Westinghouse Electric Company LLC 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 NRC and addresses with specificity the considerations listed in 10CFR 2.390(b)(4). Accordingly, it is respectfully requested that the information be withheld from public disclosure. Attachment 2 provides a non-proprietary version of the revised response.
Correspondence with respect to the proprietary aspects of the application for withholding or the supporting Westinghouse affidavit should reference the Westinghouse authorization letter (CAW-05-1938) and should be addressed to J. A. Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.
There are no commitments in this letter.
'4X1i STI: 31829551
NOC-AE-05001836 Page 2 of 3 If there are any questions regarding the enclosed additional information, please contact John Conly at (361) 972-7336 or me at (361) 972-7902.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on January 20, 2005 Vice President Engineering & Technical Services jtc Attachments: 1. Revised Response to Request for Additional Information (Proprietary)
- 2. Revised Response to Request for Additional Information (Non-Proprietary)
- 3. Application for Withholding Proprietary Information from Public Disclosure
NOC-AE-05001836 Page 3 of 3 cc: without proprietary Attachment except **
(paper copy) (electronic copy)
Bruce S. Mallett A. H. Gutterman, Esquire Regional Administrator, Region IV Morgan, Lewis & Bockius LLP U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 David H. Jaffe **
Arlington, Texas 76011-8064 U. S. Nuclear Regulatory Commission C. M. Canady R. L. Balcom City of Austin Texas Genco, LP Electric Utility Department 721 Barton Springs Road C. A. Johnson Austin, TX 78704 AEP Texas Central Company Richard A. Ratliff C. Kirksey Bureau of Radiation Control City of Austin Texas Department of State Health Services 1100 West 49th Street Jon C. Wood Austin, TX 78756-3189 Cox Smith Matthews Jeffrey Cruz J. J. Nesrsta U. S. Nuclear Regulatory Commission R. K. Temple P. 0. Box 289, Mail Code: MN1 16 E. Alarcon Wadsworth, TX 77483 City Public Service
NOC-AE-05001836 ATTACHMENT 2 REVISED RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (NON-PROPRIETARY)
NOC-AE-05001836 Attachment 2 Page 1 of 2 Revised Response to Request for Additional Information (Non-Proprietary)
- 30. For analysis of feedwater line breaks using NOTRUMP, please discuss the models used to predict break flow and liquid entrainment from the broken steam generator. Justify that the models are conservative for determining the low level trip water mass to be input into RETRAN. Provide a comparison of the break flow rate predicted by NOTRUMP to that predicted by RETRAN.
Response
As part of the NOTRUMP-RETRAN iterations, comparisons were made between the break flows calculated by each code to ensure that the RETRAN flows are in agreement (or are conservative) with respect to the NOTRUMP flows through the point of reactor trip. The [ Ia c is used by both the NOTRUMP and RETRAN computer codes for break flow at saturated conditions. For subcooled conditions, NOTRUMP uses the [ ax and RETRAN uses the . aa
[
I a'c
NOC-AE-05001836 Attachment 2 Page 2 of 2 Figure 30-1 Comparison of the NOTRUMP Break Flow Rate to the RETRAN Break Flow Rate arc
NOC-AE-05001 836 ATTACHMENT 3 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Westin ho use Westinghouse Electric Company Nuclear Services P.O. Box 355 PittsburghPennsylvania 15230-0355 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 3744643 Document Control Desk Direct fax: (412) 3744011 Washington, DC 20555-0001 e-mail: greshaja@westinghouse.com Our ref. CAW-05-1938 January 6, 2005 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
"South Texas Unit I & 2, NOTRUMP/Thick Metal Mass Program: Revision I to Westinghouse Responses to NRC Requests for Additional Information (RAIs) on WCAP-14882-S I-P" (Proprietary)
The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-05-1938 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 addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.
Accordingly, this letter authorizes the utilization of the accompanying affidavit by STP Nuclear Operating Company.
Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-05-1938, and should be addressed to J. A. Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.
Very truly y urs, J. A. Gresham, Manager Regulatory Compliance and Plant Licensing Enclosures cc: B. Benney L. Feizollahi A BNFL Group company
CAW-05-1 938 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF ALLEGHENY:
Before me, the undersigned authority, personally appeared J. A. Gresham, 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:
,I-4.
- c' L 53 /2T~A _ -- _
6/ J. A. (Gresham, Manager Regulatory Compliance and Plant Licensing
'TARI 'IO' Sworn to and subscribed Notarial Seal before me this day Patricia L. Crown, Notary Public Monroeville Boro, Allegheny County of < I , 2005 My Commission Expires Feb. 7, 2005 Mernber,PennfsyiVtaniaASSOCation Ot Notanes aP Notary Public
2 CAW-05-1 938 (1) I am 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) I am 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) I have 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 (b)(4) 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-05-1938 (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 component
4 CAWV-05-1 938 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.
(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 "South Texas Unit I & 2, NOTRUMP/Thick Metal Mass Program: Revision I to Westinghouse Responses to NRC Requests for Additional Information (RAIs) on WCAP-14882-SI-P" (Proprietary) being transmitted by the STP Nuclear Operating Company letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted for use by Westinghouse for South Texas Project Units I & 2 is expected to be applicable for other licensee submittals in response to certain NRC requirements for justification of licensing new or updated methodologies.
This information is part of that which will enable Westinghouse to:
(a) Provide information in support of licensing new or updated methodologies.
(b) Provide plant specific calculations.
5 CAW 1938 (c) Provide licensing documentation support for customer submittals.
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 licensing documentation associated with licensing new or updated methodologies.
(b) Westinghouse can sell support and defense of the technology to its customers in the licensing process.
(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 the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar calculations, evaluations analysis, 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 NRC in connection with requests for generic and/or plant-specific review and approval.
In order to conform to the requirements of 10 CFR 2.390 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 (f) 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 10 CFR 2.390(b)(1).
COPYRIGHT NOTICE 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, 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 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, 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 was identified as proprietary.