ML14167A010

Response to Request for Additional Information Regarding License Amendment Request on Revising Section 3.6.5 of the Technical Specifications, Containment Air Temperature

ML14167A010
Person / Time
Site:	Ginna
Issue date:	06/06/2014
From:	Pacher J E Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML14167A010 (16)

Text

PROPRIETARY INFORMATION

-WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 Joe Pacher Site Vice President Exelon Generation RE. Ginna Nuclear Power Plant 1503 Lake Rd.Ontario. NY 14519 585 771 5200 Office 585 545 1586 Mobile www.excloncorp.com lose ph. pacher@exeloncorp.com June 6, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 R.E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRC Docket No. 50-244

References:

Response to Request for Additional Information regarding License Amendment Request on Revising Section 3.6.5 of the Technical Specifications, "Containment Air Temperature" (a) Letter from J.E. Pacher (REG) to NRC Document Control Desk, 'License Amendment Request, Revise Section 3.6.5 of the Technical Specifications, "Containment Air Temperature,"'

dated February 28, 2013 (ML13067A328)(b) E-mail from M.C. Thadani (NRC) to T. Harding, Jr. (REG), "Request for Additional Information-RE Containment Air Temperature Increase," dated April 21, 2014.By Reference (a), R.E. Ginna Nuclear Power Plant (REG) submitted a License Amendment Request to revise Section 3.6.5 of the Technical Specifications, "Containment Air Temperature," to increase the allowable containment average air temperature from 120°F to 125 0 F.R.E. Ginna Nuclear Power Plant, LLC 1503 Lake Road, Ontario, New York 14519-9364 ATTACHMENT 1A CONTAINS PROPRIETARY INFORMATION.

WHEN SEPARATED FROM ATTACHMENT 1A, THIS DOCUMENT IS DECONTROLLED.

A,4ooI June 6, 2014 U.S. Nuclear Regulatory Commission Page 2 By Reference (b), the U.S. Nuclear Regulatory Commission (NRC) requested additional information (RAI) from REG to complete its review. The response to Reference (b) is provided in Attachment (1A). A redacted, non-proprietary version of Attachment (1A) is provided in Attachment (1). Attachment (2) is the Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-14-3972 accompanying Affidavit, Proprietary Information Notice, and Copyright Notice.As Attachment (1A) contains information proprietary to Westinghouse Electric Company LLC, it is supported by an Affidavit signed by Westinghouse, the owner of the information.

The Affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations.

Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.

There are no regulatory commitments contained in this submittal.

Should you have any other questions regarding this submittal, please contact Thomas Harding at 585-771-5219.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this A day of JUm" 2014.Respectfully, s seph E. Pacher Site Vice President R.E. Ginna Nuclear Power Plant JEP/jpo June 6, 2014 U.S. Nuclear Regulatory Commission Page 3 Attachments:

(1) Response to Evaluation of Additional Cases in Request for Additional Information (Non-Proprietary Version) (4 Pages)(1A) Response to Evaluation of Additional Cases in Request for Additional Information (Proprietary Version) (4 Pages)(2) 10 CFR 2.390 Affidavit of Westinghouse

-CAW-14-3972 (7 Pages)cc: NRC Regional Administrator, Region I NRC Project Manager, Ginna NRC Senior Resident Inspector, Ginna ATTACHMENT I RESPONSE TO EVALUATION OF ADDITIONAL CASES IN REQUEST FOR ADDITIONAL INFORMATION (NON-PROPRIETARY VERSION)R.E. Ginna Nuclear Power Plant, LLC June 6, 2014 Westinghouse Non-Proprietary Class 3 ATTACHMENT I LTR-LIS-13-492, Revision 3 RESPONSE TO EVALUATION OF ADDITIONAL CASES NP-Attachment IN REQUEST FOR ADDITIONAL INFORMATION Response to Follow-Up NRC RAI Regarding the R.E. Ginna BE LBLOCA Evaluation of Elevated Initial Containment and Accumulator Temperature, NP-Attachment (4 pages including this cover page)Westinghouse Electric Company LLC 1000 Westinghouse Drive Cranberry Township, PA 16066©2014 Westinghouse Electric Company LLC All Rights Reserved NP-1 ATTACHMENT 1 LTR-LIS-13-492, Revision 3 RESPONSE TO EVALUATION OF ADDITIONAL CASES NP-Attachment IN REQUEST FOR ADDITIONAL INFORMATION

Background

This letter provides the response to the follow-up Nuclear Regulatory Commission (NRC)Request for Additional Information (RAI) related to the R.E. Ginna Best Estimate Large Break Loss-of-Coolant Accident (BE LBLOCA) evaluation of elevated initial containment and accumulator temperature.

The RAI is provided below.The NRC staff has determined that cases 2, 7, 18, 44, and 78 have high accumulator temperature and a peak cladding temperature greater than 1450'F from the 124-case analysis of record and were not re-executed during thermal conductivity degradation analysis or analysis for increased containment temperature.

We request that these cases evaluated for increased containment temperature and thermal conductivity degradation to demonstrate, in accordance with 10 CFR 50.46(a)(1)(i), that ECCS cooling performance is calculated for a number of postulated loss-of-coolant accidents of different sizes, locations, and other properties sufficient to provide assurance that the most severe postulated loss-of-coolant accidents are calculated and that the results show there is a high probability the calculated peak cladding temperature shall not exceed 2200 0 F.Response to RAI: All runs from the R.E. Ginna analysis-of-record (AOR) with a Peak Cladding Temperature (PCT)greater than 1500°F were considered for inclusion in the I]a.c that explicitly accounted for fuel pellet thermal conductivity degradation (TCD). The top 10 cases, as ranked by maximum PCT, from this run set were re-executed to evaluate the elevated accumulator temperature.

Table 3 of Attachment (1A) of Reference 1 indicates that the sampled accumulator temperature was greater than 120°F for four of these cases and less than 90°F for the other six cases. The maximum PCT from this run set, including the effects of fuel pellet TCD and the elevated accumulator temperature, was 2116°F as reported in Table 4 of Attachment (1) of Reference

2. The maximum total PCT increase from the effects of fuel pellet TCD and the elevated accumulator temperature was 380°F per Attachment (1) of Reference 3.The AOR PCT was between 1462°F and 1501'F for the requested cases (2, 7,18, 44, and 78).These cases were re-executed with the effects of fuel pellet TCD and the elevated accumulator temperature

[ Iac. The Automated Statistical Treatment of Uncertainty Method (ASTRUM) run attributes and results provided in Tables 1-3 of Attachment (1A) of Reference 1 are provided in Table 1 of this response for these additional cases. The information is sorted by run number. Table 1 indicates that the sampled accumulator temperature was greater than 114 0 F for all of these cases. The maximum PCT from these additional runs, including the effects of fuel pellet TCD and the elevated accumulator temperature, was 1547 0 F as reported in Table 1 of this response.The maximum total PCT increase for these additional cases from the effects of fuel pellet TCD and the elevated accumulator temperature was 85°F.NP-2 ATTACHMENT I LTR-LIS-13-492, Revision 3 RESPONSE TO EVALUATION OF ADDITIONAL CASES NP-Attachment IN REQUEST FOR ADDITIONAL INFORMATION The maximum PCT calculated for the additional requested cases (1547°F) is significantly lower than the maximum PCT reported in Table 4 of Attachment (1) of Reference 2 for the original run set used to evaluate the elevated accumulator temperature (2116°F).

Therefore, these additional cases corroborate the argument in Attachment (1A) of Reference 3 that the cases chosen in the original run set used to evaluate the elevated accumulator temperature captured all potentially limiting cases when considering the effects of fuel pellet TCD and elevated accumulator temperature.

References

1. Letter from Joseph E. Pacher (REG) to NRC Document Control Desk, 'Response to Request for Additional Information regarding License Amendment Request on Revising Section 3.6.5 of the Technical Specifications, "Containment Air Temperature",'

dated November 11, 2013 (ML13323A082)

2. Letter from Joseph E. Pacher (REG) to NRC Document Control Desk, 'License Amendment Request, Revise Section 3.6.5 of the Technical Specifications, "Containment Air Temperature",'

dated February 28, 2013 (ML13067A328)

3. Letter from J.E. Pacher (REG) to NRC Document Control Desk, 'Response to Request for Additional Information regarding License Amendment Request on Revising Section 3.6.5 of the Technical Specifications, "Containment Air Temperature",'

dated March 26, 2014 (ML14093A031)

NP-3 ATTACHMENT I LTR-LIS-13-492, Revision 3 RESPONSE TO EVALUATION OF ADDITIONAL CASES NP-Attachment IN REQUEST FOR ADDITIONAL INFORMATION Table I -R.E. Ginna Additional Evaluation of Elevated Accumulator Temperature Key Results and Run Attributes ac NP-4 ATTACHMENT 2 10 CFR 2.390 AFFIDAVIT OF WESTINGHOUSE

-CAW-14-3972 R.E. Ginna Nuclear Power Plant, LLC June 6, 2014 CAW- 14-3972 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF BUTLER: Before me, the undersigned authority, personally appeared James 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:/Jarmes A. Gresham, Manager Regulatory Compliance Sworn to and subscribed before me this 29th day of May 2014 Notary blic I~oeaNMWseal-~

SiReneeGimi P le, NOYIaublc Pen TWA, nd I 2 CAW-14-3972 (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) 1 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 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 (bX4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence.

The application of that system and the substance of that system 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 3 CAW-14-3972 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.

4 CAW- 14-3972 (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 CFR Section 2.390, it 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 "Response to Follow-Up NRC RAI Regarding the R.E. Ginna BE LBLOCA Evaluation of Elevated Initial Containment and Accumulator Temperature, P-Attachment" (Proprietary), for submittal to the Commission, being transmitted by Constellation Energy letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with NRC approval of a revision to Technical Specification 3.6.5, and may be used only for that purpose.

5 CAW-1 4-3972 (a) This information is part of that which will enable Westinghouse to: (i) Provide input to Constellation Energy to provide to the U.S. Nuclear Regulatory Commission in response to NRC Request for Additional Information Regarding Amendment to Revise Technical Specification 3.6.5.(ii) Provide licensing support for customer submittal.(b) Further this information has substantial commercial value as follows: (i) Westinghouse plans to sell the use of the information to its customers for the purpose of obtaining license changes for a Westinghouse pressurized water reactor (PWR).(ii) Westinghouse can sell support and defense of the technology to its customer in the licensing process.(iii) 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 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.

6 CAW-14-3972 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 NRC request for approval of a revision to Technical Specification 3.6.5, 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 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.