NSD-NRC-98-5741, Responds to NRC Re Request for Withholding Info in Design Certification Application for AP600,submitted on 920626.Encl to Ltr Dispositions Each of Nine Specific Items

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Responds to NRC Re Request for Withholding Info in Design Certification Application for AP600,submitted on 920626.Encl to Ltr Dispositions Each of Nine Specific Items
ML20236T468
Person / Time
Site: 05200003
Issue date: 07/22/1998
From: Mcintyre B
WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To: Quay T
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NSD-NRC-98-5741, NUDOCS 9807280203
Download: ML20236T468 (6)


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o, Lstinghouse Energy Systems Ba 355 Pittsburg. 'ennsyhania 15230-0355 Electric Corporation DCP/NRC1400 NSD-NRC-98-5741 Docket No.: 52-003 July 22,1998 Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: T. R. QUAY -

SUBJECT:

RESPONSE TO NRC LETfER OF AUGUST 23,1995, " REQUEST FOR WITHHOLDING INFORMATION IN THE DESIGN CERTIFICATION APPLICATION FOR THE AP600"

Reference:

Letter, Quay to Liparulo, " Request for withholding of information in the design certification application for the AP600," August 23,1995.

Dear Mr. Quay:

The application for design certification of the AP600 submitted on June 26,1992, consisting of the AP600 Standard Safety Analysis Report (SSAR) and Probabilistic Risk A:;sessment (PRA), was submitted with an application for withholding for certain proprietary information and the required affidavit. When the AP600 was submitted to the NRC for review in 1992, there was little information publicly available concerning the details of 2he AP600 or any other passive plant design. The AP600 SSAR and PRA provided to the NRC as a part of the design certification application were therefore the first and most complete set of detailed technical information that were released outside of f

Westinghouse. ]

. The AP600 is the first nuclear plant design with passive features that has progressed beyond the concept stage. Westinghouse incurred considerable expense in performing detailed engineering calculations as well as performing an extensive experimental verification program to confirm the performance of the unique passive features of the AP600 nuclear plant design. The information in these detailed engineering calculations and experimental verification program are thus proprietary to

[g() t Westinghouse. It therefore met the requirements of 10 CFR 2.790 (b)(4) in that it was held in confidence by Westinghouse, being a new and unique design the information was the type of information customarily held in sonfidence by Westinghouse, was transmitted to the Commission in confidence, was not availabic in public sources and public disclowre of the mformation was likely to i cause substantive harm tc ine competitive position of Westinghouse Elcaric Company.

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DCP/NRCl400

, NSD-NRC-98-5741 ' July 22,1998 )

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The reference indicated that the staff agreed the information in the SSAR and PRA designated as proprietary and, other than information identified in certain speci0c sections, did contain trade secrets or proprietary information and would be withheld pursuant to 10 CFR 2.790(b)(5) and section 103(b) of the Atomic Energy Act of 1954, as amended. The reference identified specific sections of the SSAR and PRA, however, that "... the staff believes contain information that is not of the type which l is customarily held in confidence by the owner, or has already been released to the public in some i form, or both." While certain information of similar nature might be considered nonproprietary in the I context of certain operating plants or other reactor designs, such information as utilized in connection with the AP600 design certification application does not exist outside of the Westinghouse offices except for the AP600 design certification application and is therefore considered proprietary.

The reference requested " ... that Westinghouse reevaluate the SSAR and PRA materit.ls to be sure that the materials that it is requesting be withheld from public disclosure meet the criteria set forth in 10 CFR 2.790 (b)(4)" and to " ... consider how this information will be included in the design certification rule."

l In response to this staff request, Westinghouse reviewed the AP600 Standard Safay Analysis Report and the AP600 Probabilistic Risk Assessment report and removed all proprietary information from those documents. This positions Westinghouse to provide the AP600 Design Control Document which will form the basis for the AP600 design certification rule.

With respect to the specific items listed in the reference related to Revisions 0 through 4 of the SSAR and Revisions 0 through 5 of the PRA, the attachment to this letter dispositions each of the nine specific items.

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G:~fr Brian A. McIntyre, Manager &

Advanced Plant Safety and Licensing jml Attachment cc: J. W. Roe - NRC/NRR/DRPM (w/ Attachment)

H. A. Sepp - Westinghouse (w/o Attachment) i i

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.e ATTACHMENT TO DCP/NRCl400 1[' SSAR Chapter 1 - General Arrangement Drawings

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The General Arrangement drawings in Revision 0 of the SSAR were the detailed construction drawings developed as a part of the detailed engineering activities of the AP600. As such, these drawings contained significantly more information than the simplified drawings that traditionally appeared in safety analysis reports. In addition, the proper operation of the passive plant is dependent on certain details of the plant layout that are described in detail in these drawings.

The reference indicated the NRC agreed that some, but not all, of the information contained on these drawings was proprietary. Simplified nonproprietary General Arrangement drawings were developed and included in the SSAR in Revision 7.

Westinghouse still considers the drawings provided in Revisions 0 through 6 of the SSAR to contain proprietary information for the reasons stated in the cover letter.

2. SSAR Appendix 3B Westinghouse agrees that the stress / strain curves for 316 stainless steel are not proprietary. This was information removed from the SSAR in Revision 7.
3. SSAR Chapters 5,6,9, and 11 - Piping and Instrumentation drawings for certain systems The Piping and Instrumentation drawings in Revision 0 of the SSAR were the detailed construction drawings developed as a part of the detailed engineering activities of the AP600. As such, these drawings contained significantly more information than the simplified drawings that traditionally appeared ii safety analysis reports. In addition, the proper operation of the passive plant is depe .:nt on certain details of the plant arrangement and layout that are described in detail in these drawings.

Simplified nonproprietary P&lDs were developed for these certain systems and included in the SSAR in Revisions 7,8 and 9. a Westinghouse still considers the drawings provided in Revisions 0 through 6 of the 5SAR to contain proprietary i . formation for the reasons stated in the cover letter.

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4. SSAR Chapter 9 - Table 9.2.2 2 The-information in Table 9.2.2-2, " Component Cooling Water System Flows and Heat l Loads" was based on detailed component sizing calculations. )

l 1 The reference indicated the NRC agreed that some, but not all, of the information l contained in this table was proprietary. A simplified nonproprietary version of Table i

9.2.2-2 was developed and included in the SSAR in Revision 9.

Westinghouse still considers the information included in Revisions 0 through 6 of the -

SSAR to be proprietary for the reasons stated in the cover letter.

5. SSAR Chapter 10 - Figures 10.1-1 and 10.2-1 These figures, heat balance and turbine generator outline drawing, that were contained  :

J in Chapter 10 of Revision 0 of the SSAR no longer reflect the design or are considered to be proprietary by Westinghouse.

The current revision of the SSAR includes this information in a nonproprietary form.

l l 6. SSAR Chapter 15 - Appendices ISB,15C, and ISD These appendices contain details of the methodology used in the LOCA and transient ,

analyses. The reference indicated the NRC agreed that some, but not all, of the information contained in these appendices was proprietary. This information was  ;

l. subsequently moved to WCAP-14601, "AP600 Accident Analyses - Evaluation  ;

Models" and removed from Revision 6 of the SSAR. A nonproprietary version of this report was provided to the NRC. Nonproprietary general descriptions of the safety I analysis computer codes are provided in the SSAR.

L Westinghouse still considers the detailed information provided in Revisions 0 through 5 of the SSAR to be proprietary for the reasons stated in the cover letter and the letter ,

l transmitting WCAP-14601 to the NRC.

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1 7, SSAR Chapter 18 - Specific tables and sections j Chapter 18 has been entirely reformatted since Revision 4 of the SSAR was submitted

, , as a result of Westinghouse significantly changing the approach being taken to human factors as a part of design certification. As a result, the information in Revision 4 of the SSAR is essentially no longer applicable to the AP600 design certification process.

Except as noted below, the information contained in Revisions 0 through 8 of the SSAR is not a part of the design certification review and it is requested the infonnation be withdrawn:

Subsection 18.9.8.1 - Development of emergency operating procedures l The information contained in Revisions 0 through 4 of the SSAR is nonproprietary.

Tables 18.9.8-1 through 18.9.8 Emergency response guidelines 1

The information contained in Revisions 0 through 4 of the SSAR is j nonproprietary. As noted in the reference, nonproprietary ERGS had already been provided to the staff.

8. PRA Chapter 22 - Figures 22-1 and 22-2 are proprietary in PRA but nonproprietary in SSAR The two figures mentioned, one line diagrams for the Class IE DC system and the j Class IE UPS were provided as proprietary in Revision 0 of the SSAR. In Revision 3 l of the SSAR, simplified versions of these two figures were provided as nonproprietary, j These nonproprietary figures were provided in Revision 7 of the PRA. l l

Westinghouse still considers the information included in Revisions 0 through 2 of the i SSAR and Revisions 0 through 6 of the PRA to be proprietary for the reasons stated i in the cover letter.  ;

9. PRA Chapter 48 - Location of Hydrogen igniters.

When the AP600 was submitted to the NRC for review in 1992, there was little '

information publicly available concerning the details of the AP600 or any other passive plant design. The AP600 SSAR and PRA provided to the NRC as a part of the design certification application were therefore the first and most complete set of l

detailed technical information that were released outside of Westinghouse.

The AP600 is the first nuclear plant design with passive features that has progressed beyond the concept stage. Westinghouse incurred considerable expense in performing 1

detailed engineering calculations as well as performing an extensive experimental

( verification program to confirm the performance of the unique passive features of the AP600 nuclear plant design. The information in these detailed engineering l-calculations and experimental verification program are thus proprietary to 2m w 3 l

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i was the type of information customarily held in confidence by Westinghou.;e, was i transmitted to the Commission in confidence, was not available in public sources and puWic disclosure of the information was likely to cause substantive harm to the competitive position of Westinghouse Electric Company.

The staff noted that the location of the hydrogen ignitors was nonproprietary for the

. ABB/CE System 80+ design. The fact that ABB-CE chose to make this type of information nonproprietary for the System 80+ design is not relevant to making a q proprietary determination for information which was developed by Westinghouse for i the AP600.

The locatiori of the hydrogen ignitors was rem.aved from the PRA report and moved to Revision 11 of the SSAR as nonproprietary information. The information that was contained in Chapter 48 of Revision 0 of the PRA report concerning the location of 1 the hydrogen ignitors no longer reflects the plant design or considered to be proprietary by Westinghouse. -

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