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#REDIRECT [[W3F1-2018-0031, Supplemental Information Supporting the License Amendment Request Regarding Use of the Tranflow Code for Determining the Pressure Drops Across the Steam Generator Secondary Side Internal Components]]
| number = ML18169A275
| issue date = 06/13/2018
| title = Waterford, Unit 3, Supplemental Information Supporting the License Amendment Request Regarding Use of the Tranflow Code for Determining the Pressure Drops Across the Steam Generator Secondary Side Internal Components
| author name = Dinelli J C
| author affiliation = Entergy Operations, Inc
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000382
| license number = NPF-038
| contact person =
| case reference number = W3F1-2018-0031
| package number = ML18169A274
| document type = Letter, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 166
}}
 
=Text=
{{#Wiki_filter:W3F1-2018-0031 Page 3 of 4 There are no new regulatory commitments contained in this supplement.
If you have any questions or require additional information, please contact John Jarrell , Regulatory Assurance Manager, at 504-739-6685.
I declare under penalty of perjury that the foregoing is true and correct. Executed on June 13, 2018. Supplement to Proposed Licensing Basis Change. This includes the following 6 attachments:
: 1. Westinghouse Letter LTR-SGMP-18-20 NP-Attachment, "Responses to Waterford Unit 3 TRANFLOW License Amendment Request Non-Accept Sufficiency Items," Rev. 1, June 13, 2018. (21 pages) 2. Letter CAW-18-4763, Affidavit for LTR-SGMP-18-20 P-Attachment, Application for Withholding Proprietary Information from Public Disclosure, June 13, 2018. (7 pages) 3. PROPRIETARY -Westinghouse Letter LTR-SGMP-18-20 Attachment, "Responses to Waterford Unit 3 TRANFLOW License Amendment Request Non-Accept Sufficiency Items," Rev. 1, June 13, 2018. (21 pages) 4. Westinghouse Letter L TR-SGMP-17-107 NP-Attachment, "Acceptability of the TRANFLOW Computer Code for Steam Line Break Internal Pressure Loads for the Waterford Unit 3 Replacement Steam Generators," Rev. 0, February 21, 2018. (118 pages) 5. Letter CAW-18-4712, Affidavit for LTR-SGMP-17-107 Attachment, Application for Withholding Proprietary Information from Public Disclosure, February 26, 2018. (7 pages) 6. PROPRIETARY -Westinghouse Letter LTR-SGMP-17-107 Attachment, "Acceptability of the TRANFLOW Computer Code for Steam Line Break Internal Pressure Loads for the Waterford Unit 3 Replacement Steam Generators," Rev. 0, February 21, 2018. (118 pages)
W3F1-2018-0031 Page 4 of 4  W/ Attachments 3 & 6 cc: Mr. Kriss Kennedy, Regional Administrator U.S. NRC, Region IV RidsRgn4MailCenter@nrc.gov U.S. NRC Project Manager for Waterford 3 April.Pulvirenti@nrc.gov U.S. NRC Senior Resident Inspector for Waterford 3 Frances.Ramirez@nrc.gov Chris.Speer@nrc.gov W/O Attachments 3 & 6 cc: Louisiana Department of Environmental Quality Office of Environmental Compliance Surveillance Division Ji.Wiley@LA.gov
 
Westinghouse Non-Proprietary Class 3 LTR-SGMP-18-20 NP-Attachment, Rev. 1  Page 1 of 21  Westinghouse Electric Company Responses to Waterford Unit 3 TR ANFLOW License Amendment Request Non-Accept Sufficiency Items June 13, 2018 Author: Electronically Approved*
Gary W. Whiteman Plant Licensing and Engineering Author: Electronically Approved*
Jivan G. Thakkar Steam Generator Ma nagement Programs Verifier:
Electronically Approved* David A. Rubolino Steam Generator Ma nagement Programs Approved:
Electronically Approved*
David P. Lytle, Manager Steam Generator Ma nagement Programs
 
© 2018 Westinghouse Electric Company LLC All Rights Reserved
*Electronically approved records are authenticated in the electronic document management system.
Westinghouse Non-Proprietary Class 3 LTR-SGMP-18-20 NP-Attachment, Rev. 1  Page 2 of 21 I.Introduction By letter dated April 12, 2018 (Agencywide Documents Access and Management System [ADAMS] Accession No. ML18106A074), Entergy Operations, Inc. submitted a request for U.S. Nuclear Regulatory Commission (NRC) review and approval of the use of the TRANFLOW code to determine the pressure drops across main steam generator secondary side internal components for the plant for Waterford Steam Electric Station, Unit 3. The NRC staff has evaluated the licensee's submittal relative to the acceptance review criteria provided in subsection 3.1.2 of LIC-109, Revision 2. The NRC staff concluded that:
a)The request used an NRC-approved topical report outside of the limitations imposed by the NRC staff without adequate justification, and b)The licensee did not provide sufficient information for the NRC staff to complete its detailed technical review (Reference 1). As a result, supplemental information (i.e., responses to sufficiency items) was requested and must be provided to the NRC staff by June 13, 2018. Individual responses to each sufficiency item identified in Reference 1 are provided below except additional details on the code-to-code benchmarking discussed in Section 3.1 of the submittal and a discussion whether the experimental validation performed for the TRANFLO topical report is relevant to the blowdown loads calculation. This supplemental information is provided in Reference 2. Sufficiency Item No. 1 - Provision of Additional Details on Benchmarking of TRANFLO(W)  The supplemental information requested by the NRC staff for benchmarking the TRANFLOW Code is:
* Additional details on the code-to-code benchmarks discussed in Section 3.1 of the submittal, including for each benchmark: Discussion of the event modeled Comparison of input parameters and nodalizations  Discussion of how the benchmark analysis is relevant for determining blowdown loads Response: Additional details on the code-to-code benchmarks discussed in Section 3.1 of the submittal are included in Reference 2.
Four code-to-code benchmark comparisons to TRANFLOW are discussed in Section 3.1 of the submittal: RELAP5, CEFLASH-4A/4B, NOTRUMP and CATHARE 2. Of these comparisons, only the RELAP5 and CEFLASH-4A/4B are relevant for determining blowdown loads. Additional details on the comparison of the TRANFLOW code and the NRC approved RELAP5 code steam generator simulations can be found in Section 3.1 of Appendix A of Westinghouse Non-Proprietary Class 3 LTR-SGMP-18-20 NP-Attachment, Rev. 1  Page 3 of 21 Reference 2. Tube support plate loadings for a small steam line break starting from hot standby for a Model 51 feedwater ring type steam generator are discussed.
Validation of the TRANFLOW code versus the CEFLASH-4B code can be found in Section 3.2 of Appendix A of Reference 2. A comparison of the peak pressure load results during a postulated feedwater line break is provided. Definitions of the TRANFLOW nodes are presented and corresponding nodal locations within the TRANFLOW and CEFLASH-4B models are identified. The TRANFLOW code is compared to NOTRUMP code in Section 3.5 of Appendix A of Reference 2. Comparisons of water level (narrow range span) and steam pressure responses are shown during a loss-of-normal-feedwater (LONF) flow transient. This comparison demonstrates that TRANFLOW is fully capable of replicating the physics of water level behavior during a LONF transient. A qualitative comparison of dynamic stability characteristics of steam generators installed at the Cruas Nuclear Power Facility subjected to va rious levels of tube support plate blockage between the TRANFLOW code and the CATHARE 2 computer code is provided in Section 3.4 of Appendix A of Reference 2. The work presented in this study shows that the CATHARE 2 and TRANFLOW code yield similar results, verifying that TRANFLOW correctly transmits dynamic phenomena and is qualified to simulate dynamic stability responses.
* A discussion concerning whether the experimental validation performed in the TRANFLO topical report is relevant to the blowdown loads calculation. If the validation performed in the topical report is relevant, the justification should describe how. If the validation performed in the topical report is not relevant, a comparison of the code to appropriate experiments should be provided and the results discussed and justified to be conservative.
Response: An accurate prediction of mass and energy release from a vessel means that TRANFLO properly calculates local thermal-hydraulics in various nodes (i.e., elemental control volumes and flow connector). The experimental validation performed in the TRANFLO topical report is directly relevant to the blowdown loads calculation. Qualification of code capability was obtained by numerous predictions of experimental blowdown. TRANFLO has been used to predict the secondary side pressures and mass flow rates during vessel blowdown transients. Details of the blowdown test results are discussed in Section 3.3, Qualification of TRANFLOW vs. Tests, of Reference 2. The TRANFLOW computer code has been extensively verified and validated by comparison with other NRC-approved transient analysis codes: RELAP5, TRACE, NOTRUMP, and Westinghouse Non-Proprietary Class 3 LTR-SGMP-18-20 NP-Attachment, Rev. 1  Page 4 of 21 CEFLASH-4B. Also, as documented in Reference 2, TRANFLOW has been used to predict the secondary side pressures and mass flow rates during vessel blowdown transients. Reference 2 also includes comparisons between the TRANFLOW calculated values and experiments B53B done at Battelle Northwest, experiments 7, 12, and 14 done at Frankfurt/Main, and several blowdown tests conducted by CISE as part of the CIRENE-3 program. The results obtained from the tests show reasonably good agreement with TRANFLOW calculations. The code has been reviewed and approved by the NRC. The NRC's review of the TRANFLO code (TRANFLOW is the workstation version of the TRANFLO), included in Section B of Reference 6 (WCAP-8821-P-A), states that:
1.In general, TRANFLO was observed to follow the test data from a number of small blowdown tests (page 7 of Reference 6).
2.Steam generator blowdown simulations were also performed by the NRC using the RELAP-4 (MOD-5) code and a modified vers ion of the COMPARE code. In both the RELAP and COMPARE analyses, the entrainm ent predicted for full double-ended break was in general agreement with the predictions of the TRANFLO code (page 8 of Reference 6).
3.TRANFLO uses the Moody slip correlation to predict break flow (page 10 of Reference 6). For a large break the results demonstrated that the use of Moody correlation leads to larger flows early in the transient. It is, therefore, concluded that the use of the Moody flow model is satisfactory (page 11 of Reference 6).
4.TRANFLO-MARVEL method is conservative for calculating mass energy release following a main steam line break (page 19 of Reference 6). Note that the focus of the NRC staff was evaluation of the mass and energy release into a reactor primary containment in the event of a main steam line break. Based on the favorable comparison of the TRANFLO/TRANFLOW code calculations with other NRC-approved codes and data from several blowdown tests, it is logical to conclude that the TRANFLOW code solves the conservation of mass, momentum and energy equations for the SG transients correctly and has a built in conservative bias. Further details about the acceptability of the TRANFLOW computer code for SG analysis are documented in LTR-SGMP-17-107 (Reference 2).
* A discussion detailing any differences between the NRC-approved version of TRANFLO and the TRANFLOW code used in the calculation.
 
Westinghouse Non-Proprietary Class 3 LTR-SGMP-18-20 NP-Attachment, Rev. 1  Page 5 of 21  Response: A discussion detailing any differences between the NRC-approved version of TRANFLO and the TRANFLOW code follows. TRANFLOW Version 3.0 and 3.2 were used in the analysis of the Waterford Unit 3 RSGs. The Original Version (April 1974) The original homogeneous model predicts mass flow rate, pressure, pressure drop, fluid temperature, steam quality, and void fraction.
The code document includes results of TRANFLO calculations for a 51 Series steam generator subject to water and steam blowdown due to a SLB event. The document also presents code verification using blowdown test data from pressurized vessels. Westinghouse documented this version in detail in September of 1976, including code verification using vessel blowdown data (Reference 6). The Drift-Flux Version (November 1980) This version implements a drift-flux model to better simulate relative flow velocity between water and steam (Reference 3). For example, it allows a realistic simulation of counter-current flow of steam and water. It required modification of the mass, momentum, and energy equations of the two-phase flow. A capability is provided for monitoring calculated variables for convenient examination of results. TRANFLO Version 1.0 (November 1991) This version accepts transient data of parameters as direct inputs, rather than supplying input subroutines, as used in the drift-flux version (Reference 3). It also improves printouts and plots. This version maintains the drift-flux model, and includes the addition of thermal conductivity of Alloy 690 tubing. TRANFLO Version 2.0 (January 1993) This version provides as an option for two inlets of feedwater flow into the steam generator (Reference 3). It involves minor changes to a subroutine for specifying feedwater flow. This version is used for separate inlets of simultaneous flow from the main and auxiliary feedwater nozzle. TRANFLOW Version 3.0 (March 2008) TRANFLOW is a computer code used to compute the thermal and hydraulic response of steam generators during various design transients in support of the structural qualification of steam generators. This Version 3.0 is developed and configured for the HP-UNIX operating Westinghouse Non-Proprietary Class 3 LTR-SGMP-18-20 NP-Attachment, Rev. 1  Page 6 of 21 system and has been verified to execute on HP platforms running the HP-UX 11.0 version of the operating systems (Reference 7). TRANFLOW Version 3.2 (October 2011)
Version 3.2 is developed and configured for the Linux operating system and has been verified to execute on the GNU/Linux 2.6 platforms (Reference 30).
This version is functionally identical to TRANFLOW Version 3.0.
Sufficiency Item No. 2 - Discussion of Waterford 3 Plant-Specific SG Blowdown Load Analysis The supplemental information requested by the NRC staff for discussion of the Waterford Unit 3 plant specific steam generator blowdown analysis is:
* A detailed discussion of the nodalization used in the steam generator secondary side, steam generator U-tubes, and any components modeled on the primary side of the reactor coolant system that were found to be important to the transient response Response: Information from Reference 4 (CN-NCE-08-44, Revision 1) The Waterford TRANFLOW model is composed of a network of nodes and connectors that represent the secondary side fluid, tube metal heat transfer, steam generator shell metal heat transfer, tube plate metal heat transfer, and primary coolant. Figures 1 through 3 show the secondary side fluid node / connectors, primary coolant nodes and tube metal heat connectors, and shell metal nodes and connectors. The computational model consists of the following elements:
* Eighteen fluid nodes (#1 - 18) which represent the primary side water volumes. Primary side volumes are characterized in TRANFLOW as constant pressure nodes with nodal temperatures determined from the energy equation.
* Nineteen fluid node connectors (#1 - 19) between primary side nodes. Fluid connector number one represents the inlet connector on the hot-leg side; fluid connector number nineteen represents the outlet connector on the cold-leg side. Primary side flow paths are designated in TRANFLOW as boundary connectors wherein all connector parameters (e.g.,
mass flow rate) remain constant throughout the transient simulation. For boundary connectors, the momentum equation is not solved; hence, pressure drops are not computed.
* Twenty-one fluid nodes (#19 - 39) which represent the secondary side steam and water volumes. Twenty-one control volumes are used to represent the secondary side of the steam generator. Control volumes nineteen through thirty characterize the entire tube bundle region contained Westinghouse Non-Proprietary Class 3 LTR-SGMP-18-20 NP-Attachment, Rev. 1  Page 7 of 21 within the wrapper section between the lower deck plate and top surface of the tubesheet. The volume between tube support plates is generally represented by a single control volume, thus providing sufficient detail for accurate assessment of pressure drops across each TSP during faulted and operational design transients. Control volumes thirty-one and thirty-two correspond to the primary riser pipe. Control volume thirty-three represents the upper shell region outside the primary separators between the lower deck and mid deck plates. The steam generator downcomer is represented by three control volumes (thirty-four through thirty-six) extending from the top of the tubesheet to the lower deck plate. Control volumes thirty-seven, thirty-eight, and thirty-nine represent the upper shell region above the mid deck plate.
* Thirty fluid node connectors (#20 - 49) between secondary side nodes. Main feedwater coolant is introduced into the steam generator upper shell via fluid connectors forty-seven and forty-eight. These flow connectors represent boundary flow paths in which feedwater temperature and mass flow rate are specified as functions of time. Since spray tubes are uniformly placed along the top surface of the feedwater distribution ring, main feedwater flow is symmetrically introduced into the upper shell. Consequently, the feedwater flow split going into the hot leg (connector forty-seven) and cold leg (connector forty-eight) of the steam generator is fifty-fifty. Steam exits the steam generator outlet nozzle via fluid connector forty-nine.
* Eighteen metal nodes (#1 - 18) which represent the steam generator tube metal.
* Ten metal nodes (#19 - 28) which represent the steam generator shell metal. Metal nodes in the steam generator lower shell, transition cone, and portions of the upper shell (below lower deck plate elevation), are divided into two slabs. For inner slabs adjacent to fluid nodes, a half-inch wall layer thickness is assumed. This representation of the steam generator shell is intended to better characterize heat transfer to the steam generator downcomer region during cold auxiliary feedwater addition.
* Four metal nodes (#29 - 32) which represent the tubesheet metal adjacent to secondary fluid. These metal nodes are further subdivided into smaller nodes (#33 - 52). For clarity the subdivided nodes are not shown.
* Fifty-two heat connectors which represent heat transfer links between primary side fluid volume and tube metal, between secondary side fluid volume and tube metal, between steam generator shell and secondary side fluid volume, and between secondary side fluid volume and the top of the tubesheet. As indicated in Figures 1 and 2, the fluid node numbering sequence begins on the primary side of the tube bundle (System 1) and then proceeds on the secondary side just above the tubesheet (System 2). This scheme is applicable to non-break as well as ma in steam line break / feedwater line break simulations. For pipe breaks, fluid node number forty (the last node in the TRANFLOW model) is added and adjustments are made to the appropriate flow connector (either the steam or the feedwater connector depending on which simulation is under evaluation). This numbering scheme eliminates the need to have separate TRANFLOW models for non-break and secondary pipe break transients.
Westinghouse Non-Proprietary Class 3 LTR-SGMP-18-20 NP-Attachment, Rev. 1  Page 8 of 21
 
Figure 1 TRANFLOW Model - Steam Generator Secondary Side Fluid Nodes/Connectors a,c,e Westinghouse Non-Proprietary Class 3 LTR-SGMP-18-20 NP-Attachment, Rev. 1  Page 9 of 21
 
Figure 2 TRANFLOW Model - Primary Coolant Fluid Nodes, Tube/Tubesheet Metal Nodes and Heat Connectors a,c,e Westinghouse Non-Proprietary Class 3 LTR-SGMP-18-20 NP-Attachment, Rev. 1  Page 10 of 21
 
Figure 3 TRANFLOW Model - Steam Generator Shell Metal Nodes, Fluid Nodes, and Heat Connectors (Non-Steam Line Break) a,c,e Westinghouse Non-Proprietary Class 3 LTR-SGMP-18-20 NP-Attachment, Rev. 1  Page 11 of 21
* A discussion of the form loss coefficients applied in the calculation and the basis by which they were developed.
 
Response: The form loss coefficient, in a TRANFLOW model, is one of the input parameters for a flow connector that include change in flow areas due to geometry or a presence of a SG internal component. For each segment of the flow connector, values for the positive loss-factor (FDP) and negative loss-factor (FDN) are input entries. In the Waterford Unit 3 RSG TRANFLOW model the form loss-factors are applied for the flow connectors and segments that include: the flow distribution plate, tube support plates, lower deck plate, primary separator swirl vane blades, secondary separators, steam outlet nozzle, drain pipes, downcomer entrance, wrapper opening at the tubesheet level, etc. These connectors represent flow area changes as a result of SG subcomponents or geometry change. The form loss-factors are calculated based on: Classical methods - Idel'chik Handbook (Reference 8)  Test data for the primary separators Secondary separator TH characteristics provided by the supplier (Peerless)
The following calculation illustrates the tube support plate loss-factor for a TRANFLOW flow connector:
The loss-factor for the flow area contraction and expansion through a tube support plate in the positive flow direction is based on loss-factor through a perforated plate in the I'del'chik handbook.
a,c,e Westinghouse Non-Proprietary Class 3 LTR-SGMP-18-20 NP-Attachment, Rev. 1  Page 12 of 21
* A discussion of how inputs were biased to ensure that the pressure loading on the internal components was conservative, and how these biases were different from the biases used in the approved application of TRANFLO to determine the flow quality at the break for a main steam line break.
 
Response:
The SLB thermal/hydraulic analyses of the Delta 110 RSG were performed using the computer program TRANFLOW (Reference 4). Three different cases for SLB conditions were analyzed and are presented in Table 1. All three were initiated from hot standby conditions; one with the water at the top tube support plate, one with the water at the lower deck plate and one with the normal operating water level. The SLB transient is assumed to initiate from hot-standby conditions since this gives the highest possible steam generator operating pressure. With initial conditions at the highest operating steam pressure, blowdown of steam and water through the steam outlet nozzle during a line break is maximized resulting in maximum hydraulic loads on the steam generator internals. The pressure drops across the tube support plates during a postulated SLB event are calculated for each of the three cases and are summarized in Table 1. Figure4 depicts the tube support plate and wrapper support assembly. Review of these results indicates that the case with initial water level at the top tube support plate produces the greatest SLB loadings on the tube support plates. Tube support plate B sees essentially the same pressure drop with an initial water level at the lower deck plate. In Table 2 the pressures shown in bold type face for the top tube support plate water level condition in Table 1 are used to determine the enveloping (conservative) forces on the tube support plates (TSPs) shown in Table 2. By way of contrast, quality is a measure of dryness of the flow, ranging from 1.0 (dry steam) to 0 (saturated liquid). An increment of 0.1 was conservatively added to the qualities predicted by the approved application of TRANFLO (Reference 6).
a,c,e Westinghouse Non-Proprietary Class 3 LTR-SGMP-18-20 NP-Attachment, Rev. 1  Page 13 of 21 Table 1 Steam Line Break (SLB) Pressure Drops on Tube Support Plates Tube Support Plate Location of Initial Water Level (1),(2) Nominal Setpoint Lower Deck Plate Top Tube Support Plate (3) Max (psi) Min (psi) Max (psi) Min (psi) Max (psi) Min (psi)
A      B      C      D      E      F      G      H        Notes:  (1) The load on the tube support plates is produced from a pressure drop across the plate. A positive DP means that the pressure is acting vertically upwards. A negative DP is means that the pressure is acting vertically downwards.  (2) SLB pressure drops per Reference 4.  (3) Values shown in bold bracket all SLB transient cases, the loss of feedwater transient, and the feedwater line transient cases. These values are used as the worst case for the SLB analysis.
a,c,e Westinghouse Non-Proprietary Class 3 LTR-SGMP-18-20 NP-Attachment, Rev. 1  Page 14 of 21 Table 2 - Calculation of Vertical Force on the Tube Support Plates Due to SLB Pressure Drops Tube Support Plate SLB DP(1) (psi) Fluid Approach Area(2) (in 2) Vertical Force Due to SLB DP(3)        (lbs) A    B    C    D    E    F    G    H      Notes: (1) Pressure drops per Table 1 for location of initial water level at the top tube    support plate.    (2) Fluid Approach Area per Section 8.1.1of Reference 5  (3) Vertical Force = Fluid Approach Area times SLB P. a,c,e Westinghouse Non-Proprietary Class 3 LTR-SGMP-18-20 NP-Attachment, Rev. 1  Page 15 of 21 
 
Figure 4 - Tube Support Plate and Wrapper Support Assembly -Waterford Unit 3 RSGs
 
a,c,e Westinghouse Non-Proprietary Class 3 LTR-SGMP-18-20 NP-Attachment, Rev. 1  Page 16 of 21
* A discussion of how the results of the TRANFLOW blowdown loads analysis are used in downstream mechanical/structural analyses, including a justification for why a simple component pressure drop, such as that provided in Table 1 of the licensee's submittal, is adequate rather than a more detailed distribution of the pressure around each component. Response: The TRANFLOW calculated values of thermal-hydraulic (TH) parameters: pressures, pressure loads (Ps), flow rates, flow loads (V 2), bulk fluid temperatures, metal surface temperatures and film heat transfer coefficients are used in the downstream structural, fatigue and non-ductile failure analyses in accordance with the ASME Boiler and Pressure Vessel Code, Section III, Rules for Construction of Nuclear Power Plant Components (Reference 9).
The TRANFLOW calculated TH parameters for each analysis, documented in References 10 through 14, are selected based on the ASME code requirements for the specific evaluation.
The simple component pressure drop, such as that provided in Table 1, of the licensee's submittal provided a comparison of the pressure differentials across the steam generator (SG) secondary side internal components during a hypothetical steam line break (SLB) transient for the Waterford Unit 3 original steam generators (OSGs) and the replacement steam generators (RSGs). For the Waterford Unit 3 OSGs, designed prior to the advent of modern computers and advanced computer codes, the pressure differentials (Ps) were manually calculated. First the 100% load steady conditions are obtained from the secondary circulation analysis of the OSGs. The secondary side flow rate / velocity during a SLB transient was assumed to be four  times greater than at the 100% steady state power. The pressure differential is proportional to the square of the velocity. Therefore, the pressure differentials were calculated to be sixteen  times the Ps at 100% power conditions.
For the Waterford Unit 3 RSGs these pressure differentials were calculated using the TRANFLOW computer code (Reference 30). Table 1 provides the comparison between the manually calculated values for the OSGs and the TRANFLOW calculated values for the RSGs. The TRANFLOW calculated TH parameters are selected for the downstream analyses as
 
follows:
Westinghouse Non-Proprietary Class 3 LTR-SGMP-18-20 NP-Attachment, Rev. 1  Page 17 of 21 Use of TRANFLOW TH Parameters in Downstream Mechanical/Structural Analyses The TRANFLOW calculated TH parameters for each structural analysis are selected based on the ASME code requirements as summarized in the following write-up.
1.As stated in Appendix D of the Waterford 3 Steam Electric Station Delta 110 Replacement Steam Generator Design Report, Reference 16, the heat transfer coefficient and temperature for the inside of the secondary shell were taken from the TRANFLOW output for the loss of feedwater transient.
2.For performing the thermal analysis of the lower shell and tubesheet in Reference 17, secondary side fluid temperatures and the associ ated film coefficien ts were obtained from the TRANFLOW analysis.
3.The temperature time history data used for the boundary conditions in the thermal analyses of the primary manways in Reference 18 were taken from the TRANFLOW outputs. 4.The secondary side pressure time histories, needed for the structural analysis of the tube-to-tubesheet weld in Reference 19, during the cold feedwater at low pressure from hot standby transient were obtained from the TRANFLOW analysis.
5.The temperatures for the Normal/Upset conditions (Level A & B Service Loadings) of the secondary side components for the tubing analysis, in Reference 20, are derived from the TRANFLOW analyses. Also, in this reference, the tube outside wall, secondary side and tube support plate (TSP) temperatures are based on the fluid node temperatures from the TRANFLOW analysis.
6.The inputs, transfer coefficients (HTCs) and bulk fluid temperatures (BFTs), for calculating thermal stress in the lower shell, transition cone and upper shell in Reference 21 are developed from the TRANFLOW Analyses. Also, the governing conditions for the thermal transients are evaluated by TRANFLOW.
7.For performing thermal analysis of small nozzles in Reference 22, the secondary side transient temperatures and pressures are extracted the TRANFLOW data. The film coefficients for the shell side are also extracted from the TRANFLOW data.
8.TRANFLOW calculated thermal-hydraulic parameters for the normal (Service Level A), upset (Level B) emergency (Level C) and faulted (Level D) transients are used for the feedwater nozzle and thermal sleeve evaluations in accordance with the ASME code in Reference 23.
9.The temperatures and pressures for the normal (Service Level A), upset (Level B) emergency (Level C) and faulted (Level D) transients as well as the HTC and BFT inputs for the thermal and structural analyses of the secondary-side manways, in Reference 24, were developed from the Waterford 3 TRANFLOW analyses.
10.The heat transfer film coefficients and bulk steam temperature for the thermal analysis of the steam outlet nozzle and elliptical head assembly, in Reference 25, were extracted from the TRANFLOW analysis.
Westinghouse Non-Proprietary Class 3 LTR-SGMP-18-20 NP-Attachment, Rev. 1  Page 18 of 21 11.TRANFLOW calculated TH parameters during the feedwater line break, loss of feedwater, and steam line break transients are extensively used for performing the structural analysis, in accord ance with the ASME Code, of the internal components in Reference 26. These include:
a.A unit-loading transient starting from hot standby conditions and ending at full load conditions (i.e., 100% power).
b.Pressure drops across TSPs.
c.Vertical loadings for wrapper support system d.Wrapper transition cone e.Lower deck plate f.Mid deck plate g.Primary separator swirl vane blades 12.The pressure loads on primary separator components from the TRANFLOW analyses are used in structural analysis of the primary separator assembly. This analysis was performed in accordance with the ASME Code (Reference 27). The loads applied to the primary separator assembly were the limiting cases chosen from the full range of water levels and steam generator tube plugging (SGTP) levels which were analyzed using TRANFLOW code. The flow loads on the primary separator assembly come from pressure drops in the TRANFLOW model.
13.The pressure loads on secondary separator components from the TRANFLOW analyses are used in structural analysis of the secondary separator assembly. This analysis was performed in accordance with the ASME code (Reference 28). The flow loads on the secondary separator assembly come from pressure drops in the TRANFLOW model.
14.TRANFLOW calculated thermal-hydraulic parameters: temperatures, pressure differentials, flow rates and film coefficients for the normal (Service Level A), upset (Level B) emergency (Level C) and faulted (L evel D) transients are used for the stress analysis and evaluation of the feedring, feedring supports, and spray nozzles (Reference 29). The structural and fatigue evaluati ons were performed in accordance with the ASME Boiler and Pressure Vessel Code.
 
Westinghouse Non-Proprietary Class 3 LTR-SGMP-18-20 NP-Attachment, Rev. 1  Page 19 of 21 Component Pressure Drop Justification The total load on each tube support plate due to the net pressure across the plate is calculated based on the fluid approach area to the tube support plate (Reference 5). The area used for the calculation of pressure on the tube support plate is the fluid approach area, not the actual surface area of the TSP. The fluid approach area is used to remain consistent with the pressure data obtained from TRANFLOW, which is calculated based on the fluid approach area. The effect of the trefoil, flow holes and flow slots is accounted for in loss factors within TRANFLOW.                  The fluid approach area is calculated as follows:
 
Multiplying the pressure drop across each tube support plate by the approach area gives a  total force on the tube support plate.
a,c,e Westinghouse Non-Proprietary Class 3 LTR-SGMP-18-20 NP-Attachment, Rev. 1  Page 20 of 21
 
==References:==
 
1.US NRC Letter from April L. Pulvirenti, Project Manager, to the Site Vice President, Entergy Operations, Inc., "Waterford Steam Electric Station, Unit 3 -  Supplemental Information Needed For Acceptance of Requested Licensing Action Re: Use of TRANFLOW C ode for Determining Pressure Drops Across Steam Generator Secondary Side Internal Components (EPID L-2018-LLA-0112)," June 1, 2018.
2.Westinghouse Letter LTR-SGMP-17-107 P-Attachment, Revision 0, "Acceptability of the TRANFLOW Computer Code for Steam Line Break Internal Pressure Loads for the Waterford Unit 3 Replacement Steam Generators," February 2018.
3.Westinghouse Report WCAP-14046, Revision 3, "Braidwood Unit 1 Technical Support for Cycle 5 Steam Generator Interim Plugging Criteria," March 1995.
4.Westinghouse Calculation Note CN-NCE-08-44, Revision 1, "Waterford 3 Replacement Steam Generator TRANFLOW Analysis: Emergency and Faulted Transients to Support Emergency Feedwater System Modifications," October 2016.
5.Westinghouse Calculation Note CN-NCE-W3RSG-17, "Waterford 3 Steam Electric Station Delta 110 Replacement Steam Generator Lower Internals Analysis," October 2012.
6.WCAP-8821-P-A, "TRANFLO Steam Generator Code Description," June 2001.
7.Westinghouse Letter LTR-NCE-08-3, Rev. 1, "TRANFLOW Version 3.0 User's Manual," March 2008. 8.I. E. Idel'chik, "Handbook of Hydraulic Resistances, Coefficients of Local Resistance and of Friction," Israel Program for Scientific Translation, Jerusalem 1966; Reproduced by National Technical Information Service, U. S. Department of Commerce, Springfield, VA 22161.
9.ASME Boiler and Pressure Vessel Code, Section III, Division 1, "Rules for Construction of Nuclear Power Plant Components," 1998 Edition with Addenda through 2000, The American Society of Mechanical Engineers, New York, New York.
10.CN-NCE-08-31, Revision 0, "Waterford 3 Replacement Steam Generator TRANFLOW Analysis: Base Deck Model and Loading/Unloading Transients," April 2009.
11.CN-NCE-08-42, Revision 0, "Waterford 3 Replacement Steam Generator TRANFLOW Analysis: Normal Transients," April 2009.
12.CN-NCE-08-43, Revision 0, "Waterford 3 Replacement Steam Generator TRANFLOW Analysis: Upset Transients," June 2009.
13.CN-NCE-08-44, Revision 0, "Waterford 3 Replacement Steam Generator TRANFLOW Analysis: Emergency and Faulted Transients," May 2009.
14.CN-NCE-08-44, Revision 1, "Waterford 3 Replacement Steam Generator TRANFLOW Analysis: Emergency and Faulted Transients to Support Emergency Feedwater System Modifications," October 2016.
Westinghouse Non-Proprietary Class 3 LTR-SGMP-18-20 NP-Attachment, Rev. 1  Page 21 of 21 15.Not used.
16.WCAP-17066-P, Revision 3, "Waterford 3 Steam Electric Station Delta 110 Replacement Steam Generator Design Report," November 2016.
17.CN-NCE W3RSG-1, Revision 1, "Waterford 3 Steam Electric Station Delta 110 Replacement Steam Generator Primary Chamber, Tubesheet, Lower Shell and Pedestal Support Complex Analysis," January 2012.
18.CN-NCE-W3RSG-4, Revision 0, "Waterford 3 Steam Electric Station Delta 110 Replacement Steam Generators Primary Manway Analysis," October 2010.
19.CN-NCE-W3RSG-5, Revision 1, "Waterford 3 Steam Electric Station Model Delta 110 Replacement Steam Generator Tube to Tubesheet Weld Analysis," February 2012.
20.CN-NCE-W3RSG-7, Revision 1, "Waterford 3 Steam Electric Station Delta 110 Replacement Steam Generator Tubing Analysis," February 2012.
21.CN-NCE-W3RSG-8, Revision 0, "Waterford 3 Model Delta 110 Replacement Steam Generator Lower Shell, Transition Cone and Upper Shell Analysis," March 2010.
22.CN-NCE-W3RSG-13, Revision 0, "Waterford 3 Steam Electric Station Delta 110 Replacement Steam Generator Minor Shell Taps Analysis," November 2010.
23.CN-NCE-W3RSG-14, Revision 0, "Waterford 3 Steam Electric Station Delta 110 Replacement Steam Generator Feedwater Nozzle and Thermal Sleeve Analysis," November 2010.
24.CN-NCE-W3RSG-15, Revision 0, "Waterford 3 Steam Electric Station Replacement Steam Generators Secondary Manway Analysis," June 2010.
25.CN-NCE-W3RSG-16, Revision 0, "Waterford 3 Steam Electric Station Model Delta 110 Replacement Steam Generator Steam Outlet Nozzle and Elliptical Head Assembly Analysis," November 2010.
26.CN-NCE-W3RSG-17, Revision 2, "Waterford 3 Steam Electric Station Delta 110 Replacement Steam Generator Lower Internals Analysis," October 2012.
27.CN-NCE-W3RSG-18, Revision 0, "Waterford 3 Steam Electric Station Delta 110 Replacement Steam Generator Primary Separator Assembly Analysis," November 2010.
28.CN-NCE-W3RSG-19, Revision 0, "Waterford 3 Steam Electric Station Delta 110 Replacement Steam Generator Secondary Separator Assembly Analysis," November 2010.
29.CN-NCE-W3RSG-21, Revision 0, "Waterford 3 Steam Electric Station Delta 110 Replacement Steam Generator Feedwater Feedring, Spray Nozzle and Supports Analysis," November 2010 30.LTR-NCE-11-118, Revision 0, "Software Release Letter for TRANFLOW Version 3.2 on GNU/Linux 2.6," Westinghouse Electric Company, October 12, 2011. 
 
Westinghouse Non-Proprietary Class 3 @Westinghouse U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA Direct tel: (412) 374-3382 Direct fax: (724) 940-8542 e-mail: russpa@westinghouse.com CAW-18-4763 June 13, 2018 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
 
==Subject:==
Responses to Waterford Unit 3 TRANFLOW License Amendment Request Non-Accept Sufficiency Items (Proprietary)
The Application for Withholding Proprietary Information from Public Disclosure is submitted by Westinghouse Electric Company LLC ("Westinghouse"), pursuant to the provisions of paragraph (b)(l) of Section 2.390 of the Nuclear Regulatory Commission's
("Commission's")
regulations.
It contains commercial strategic information proprietary to Westinghouse and customarily held in confidence.
The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CA W-18-4 763 signed by the owner of the proprietary information, Westinghouse.
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 CPR Section 2.390 of the Commission's regulations.
Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Entergy Operations, Inc. Correspondence with respect to the proprietary aspects of the Application for Withholding or the Westinghouse Affidavit should reference CAW-18-4763, and should be addressed to James A. Gresham, Consulting Engineer, Licensing and Regulatory Affairs, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 2 Suite 259, Cranberry Township, Pennsylvania 16066. Paul A. Russ, Director Licensing and Regulatory Affairs © 2018 Westinghouse Electric Company LLC. All Rights Reserved.
CAW-18-4763 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF BUTLER: I, Paul A. Russ, am authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC ("Westinghouse")
and declare that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief. Executed on: Paul A. Russ, Director Licensing and Regulatory Affairs 3 CAW-18-4763 (1) I am a Director, Licensing and Regulatory Affairs, 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 CPR Section 2.390 of the Nuclear Regulatory Commission's
("Commission's")
regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure 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, u,tilizes 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 constitute Westinghouse policy and provide 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 4 CAW-18-4763 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. (iii) 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.
5 CAW-18-4763 ( 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. (iv) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CPR Section 2.390, is to be received in confidence by the Commission. (v) 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. (vi) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in LTR-SGMP-18-20 P-Attachment, Revision 1, "Responses to Waterford Unit 3 TRANFLOW License Amendment Request Non-Accept Sufficiency Items" (Proprietary), for submittal to the Commission, being transmitted by Entergy Operations letter. The proprietary information as submitted by Westinghouse for use by Entergy Operations, Inc. for Waterford Unit 3 demonstrates the acceptability of using the computer code, TRANFLOW, to calculate replacement steam generator secondary side internal loads during a postulated steam line break event. (a) This information is part of that which will enable Westinghouse to describe the computer code, TRANFLOW, and to benchmark calculated pressure drops using TRANFLOW with other NRC approved computer code results.
6 CAW-18-4763 (b) Further, this information has substantial commercial value as follows: (i) Westinghouse can sell the use of similar information to its customers for the purpose of meeting NRC requirements for licensing documentation supporting the use of the computer code, TRANFLOW, during replacement steam generator design. (ii) Westinghouse can sell support and defense of this information to customers, if the need arises. (iii) The information requested to be withheld reveals the distinguishing aspects of a methodology which is utilized by Westinghouse for replacement steam generator design. 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 technical evaluation justifications 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 tµe 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 as attachments to LTR-SGMP-18-20, Revision 1 are proprietary and non-proprietary versions of a document, furnished to the NRC in support of a license amendment to obtain approval to use the computer code, TRANFLOW, for calculating secondary side internal loads during a postulated steam line break event in the Waterford Unit 3 replacement steam generators, and may be used only for that purpose. 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 as attachments to LTR-SGMP-18-20, Revision 1 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.
Entergy Operations, Inc. Letter for Transmittal to the NRC The following paragraphs should be included in your letter to the NRC Document Control Desk: Enclosed are: 1. LTR-SGMP-18-20 P-Attachment Revision 1, "Responses to Waterford Unit 3 TRANFLOW License Amendment Request Non-Accept Sufficiency Items" (Proprietary)
: 2. LTR-SGMP-18-20 NP-Attachment Revision 1, "Responses to Waterford Unit 3 TRANFLOW License Amendment Request Non-Accept Sufficiency Items" (Non-Proprietary)
Also enclosed are the Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-18-4763, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice. As Item 1 contains information proprietary to Westinghouse Electric Company LLC ("Westinghouse"), 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 Nuclear Regulatory Commission
("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 which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CPR Section 2.390 of the Commission's regulations.
Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse Affidavit should reference CAW-18-4763 and should be addressed to James A. Gresham, Consulting Engineer, Licensing and Regulatory Affairs, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 2 Suite 259, Cranberry Township, Pennsylvania 16066. 
 
Electronically Approved*
Electronically Approved* Electronically Approved*  Electronically Approved*
    © 2018 Westinghouse Electric Company LLC All Rights Reserved
*Electronically approved records are authenticated in the electronic document management system.
 
7
 
.
 
Westinghouse Non-Proprietary Class 3 @Westinghouse U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA Direct tel: (412) 374-4643 Direct fax: (724) 940-8542 e-mail: greshaja@westinghouse.com CAW-18-4712 February 26, 2018 APPLICATION FOR WITIIBOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
 
==Subject:==
Acceptability of the TRANFLOW Computer Code for Steam Line Break Internal Pressure Loads for the Waterford Unit 3 Replacement Steam Generators (Proprietary)
The Application for Withholding Proprietary Information from Public Disclosure is submitted by Westinghouse Electric Company LLC ("Westinghouse"), pursuant to the provisions of paragraph (b )( 1) of Section 2.390 of the Nuclear Regulatory Commission's
("Commission's")
regulations.
It contains commercial strategic information proprietary to Westinghouse and customarily held in confidence.
The proprietary information for which withholding is beiµg requested in the above-referenced report is further identified in Affidavit CAW-18-4712 signed by the owner of the proprietary information, Westinghouse.
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 Entergy Operations, Inc. Correspondence with respect to the proprietary aspects of the Application for Withholding or the Westinghouse Affidavit should reference CAW-18-4712, and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 2 Suite 259, Cranberry Township, Pennsylvania 16066. !.'+/-~~er Regulatory Compliance
© 2018 Westinghouse Electric Company LLC. All Rights Reserved.
CAW-18-4712 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF BUTLER: I, James A. Gresham, am authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC ("Westinghouse")
and declare that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief. Executed on: ~{t, { ) l~-l~mes A. Gresham, Manager Regulatory Compliance 3 CAW-18-4712 (1) I am Manager, Regulatory Compliance, 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 Nuclear Regulatory Commission's
("Commission's")
regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure 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 constitute Westinghouse policy and provide 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 4 CAW-18-4712 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. (iii) 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.
5 CAW-18-4712 (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. (iv) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CPR Section 2.390, is to be received in confidence by the Commission. (v) 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. (vi) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in L TR-SGMP-17-107 P-Attachment, "Acceptability of the TRANFLOW Computer Code for Steam Line Break Internal Pressure Loads for the Waterford Unit 3 Replacement Steam Generators" (Proprietary), for submittal to the Commission, being transmitted by Entergy Operations letter. The proprietary information as submitted by Westinghouse for use by Entergy Operations, Inc., for Waterford Unit 3 demonstrates the acceptability of using the computer code, TRANFLOW, to calculate replacement steam generator secondary side internal loads during a postulated steam line break event.
6 CAW-18-4712 (a) This information is part of that which will enable Westinghouse to describe the computer code, TRANFLOW, and to benchmark calculated pressure drops using TRANFLOW with other NRC approved computer code results. (b) Further, this information has substantial commercial value as follows: (i) Westinghouse can sell the use of similar information to its customers for the purpose of meeting NRC requirements for licensing documentation supporting the use of the computer code, TRANFLOW, during replacement steam generator design. (ii) Westinghouse can sell support and defense of this information to customers, if the need arises. (iii) The information requested to be withheld reveals the distinguishing aspects of a methodology which is utilized by Westinghouse for replacement steam generator design. 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 technical evaluation justifications 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 non-proprietary versions of a document, furnished to the NRC in support of a license amendment to obtain approval to use the computer code, TRANFLOW, for calculating secondary side internal loads during a postulated steam line break event in the Waterford Unit 3 replacement steam generators, and may be used only for that purpose. In order to conform to the requirements of IO 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 IO CFR 2.390(b)(l).
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 IO 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.}}

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