ML20081K771
| ML20081K771 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 03/16/1995 |
| From: | Liparulo N WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | Russell W NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19325F534 | List: |
| References | |
| CAW-95-788, NUDOCS 9503290266 | |
| Download: ML20081K771 (12) | |
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Westinghouse Energy Systems
[$s!Ogn Pennsvivania mmo355 Electric Corporation f
' Document Control Desk March 16,1995 f
US Nuclear Regulatory Commission CAW-95-788 Washington, DC 20555 Attention: Mr. William T. Russell APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
" Supplementary Information on RCS Flow Reduction Evaluation", Proprietary
Dear Mr. Russell:
The proprietary information for which withholding is being requested in the above-referenced letter is further identified in Affidavit CAW-95-788 signed by the owner of the proprietary information, Westinghouse Electric Corporation. 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 2.790 of the Commission's regulations.
Accordingly, this letter authorizes the utilization of the accompanying Affidavit by American Electric Power Service Corporation.
9 Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference' this letter, CAW-95-788, and should be addressed to the i
undersigned.
i Very truly yours, i
Mr. Nichol
. Liparuto, Manager Nuclear Safety Regulatory and Licensing Activities ULB/bbp Enclosures cc: K. Bohrer/NRC (12H5)
N5RLAl24U3/1695 9503290266 950322 PDR ADDCK 05000423 P
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CAW-95-788 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF ALLEGHENY:
Before me, the undersigned authority, personally appeared Henry A. Sepp, 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 Corporation (" 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:
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Henry A. Sepp, Manager i
Regulatory and Licensing Initiatives Sworn to and subscribed 1t, before me this /[F day of MACM
,1995 Nc**JSeat Denise K Handercon, tttary Public LhCc Boro, Ahrf0.T/ CcW/
My Commidon Emims Ctt 23,1006 tkmtu,hnEFauAssmamnof tuancs Notary Public a
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ISNC-ULA121N5
, CAW-95-788 (1)
I am Manager, Regulatory and Licensing Initiatives, in the Nuclear Technology Division, of the Westinghouse Electric Corporation 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 rulemaking proceedings, and am authorized to apply for its withholding on behalf of the Westinghouse Energy Systems Business Unit.
(2)
I am making this Affidavit in conformance with the provisions of 10CFR Section 2.790 of the Commission's regulations and in conjunction with the Westinghouse application for withholding accompanying this Affidavit.
(3)
I have personal knowledge of the criteria and procedures utilized by the Westinghouse Energy Systems Business Unit 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 2.790 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 c(mfidence by Westinghouse.
(ii)
The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.
Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:
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, CAW-95-788 l
(a)
The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a -
competitive economic advantage over other companies.
(b)
It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.
(c)
Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.
(d)
It reveals cost or price information, production capacities, budget levels,'or commercial strategies of Westinghouse, its customers or suppliers.
(e)
It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.
(f)
It contains patentable ideas, for which patent protection may be desirable.
There are sound policy reasons behind the Westinghouse system which include the i
following:
r (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 which 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.
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. CAW-95-788 (c)
Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.
(d)
Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.
(e)
Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.
(f)
The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.
(iii)
The information is being transmitted to the Commission in confidence and, under the provisions of 10CFR Section 2.790, it is to be received in confidence by the Commission.
(iv)
The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.
(v)
The proprietary information sought to be withheld in this submittal is that which is appropriately marked in " Supplementary Information on RCS Flow Reduction Evaluation", March 1995, (Proprietary), being transmitted by Northeast Utilities Service Company letter and Application for Withholding Proprietary Information from Public Disclosure, to Document Control Desk, to Attention of Mr. William T.
Russell. The proprietary information as submitted for use by Northeast Utilities Service Company for Millstone Unit 3 is expected to be applicable in other license submittals in response to certain NRC requirements for justification of a reduction in RCS flow.
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' CAW-95-788 -
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"Ihis information is part of that which will enable Westinghouse to:
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(a)
Provide documentation for reduction in RCS flow.
(b):
Provide a basis for DNBR margin assessment.
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L (c)
Assist customers in obtaining NRC approval.
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Further this information has substantial commercial value as follows:
5 (a)
Westinghouse plans to sell the use of similar information to its customers for purposes of satisfying NRC requirements for licensing documentation.
e (b)
Westinghouse can sell support and defense of the technology to its customers -
in the licensmg process.
i Public disclosure of this proprietary information is likely to cause substantial harm to
.f the competitive position of Westinghouse because it would enhance the ability of l
-t competitors to provide similar design documentation and licensing defense services for l
commercial power reactors without commensurate expenses. Also, public disclosure l
of the infonnation would enable others to use the information to meet NRC
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requirements for licensing documentation without purchasing the right to use the l
t information.
i The development of the technology described in pan by the information is the result J
of applying the results of mariy years of experience in an intensive Westinghouse
-l mTort and the expenditure of a considerable sum of money.
i In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, l
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having the requisite alent and experience, would have to be expended for testing and i
analytic 4 melba is and performing tests, j
Further the deponent sayeth not.
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Y Proprietary Information Notice Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the' NRC in connection with requests for generic and/or plant-specific review and approval.
In order to conform to the requirements of 10 CFR 2.790 of the Commission's regulations concerning f
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 l
within the brackets in the proprietary versions having been deleted). The justification for claiming the l
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information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) contained within parentheses located as a superscript immediately following the brackets enclosing each item of information being identified as proprietar; 't 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 2.790(b)(1).
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Ctb10E ULA'122299
Copyright Notice ne reports transmitted herewith each bear a Westinghouse copyright notice. He 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 2.790 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. The NRC is not authorized to make copies for the personal use of members of the public who make use of the NRC public document rooms. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary, a
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Westinghouse Non-Proprietary Class 3 SUPPLEMENTARY INFORMATION ON RCS FLOW REDUCTION EVALUATION March 1995 Westinghouse Electric Corporation Nuclear Energy Systems P.O. Box 355 Pittsburgh, Pennsylvania 15230
- 1995 Westinsbouse Electric Corporation All Rights Reserved i
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SUPPLEMENTARY INFORMATION ON RCS FLOW REDUCTION EVALUATION Millstone Unit 3 Cycle 6 V5M (w/IFM) Fuel 4 % TD Flow Reduction Evaluation for N Loop Operation Effect Effect of of Thimble Plug Available DNB Margin Grid Reinsertion and Available DNS Margin Correlation Event Before TDF Reduction Rotation Decreased FdM After TDF Reduction Used
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- 1. Loss of Flow WRB-2 (RTDP)
- 2. Foodwater Malfunction WRB-2 (RTDP)
- 3. Excessive Load Increase WRB-2 (RTDP)
- 4. Loss of Load / Turbine Trip WRB-2-(RTDP)
- 5. RCCA Withdrawal at Power WRB-2 (RTDP) 6.
Inadvertent SI Actuation WRB-2 (RTDP)
- 7. RCS Depressurization WRB-2 (RTDP) 9.
RCCA Misalignment (Dropped RCCA Bank)
WRB-2 (RTDP)
- 9. Steam 11ne Break W-3 (Non-RTDP)
- 10. RCCA Withdrawal from suberitical W-3 (Non-RTDP)
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SUPPLEMENTARY INFORMATION ON RCS FLOW REDUCTION EVALUATION Overeressure Considerations 1.
Loss of Load Plant specific sensitivities performed for a 4% TDF reduction Turbine Trio confirm that the LOL/TT pressurization rate is 1 1" to small changes in RCS flowrate. The maximum RCS pressure reached assuming a 4% TOF reduction i 1" from the current Millstone 3 licensing basis analysis.
2.
Locked Rotor Although plant specific sensitivities were not performed for this event, sensitivities performed for cther plants indicate that a reduction in flow is (
1" with respect to maximum RCS pressures. Furthermore, the Millstone Unit 3 licensing basis locked rotor analysis shows that there is about i 1" margin to the limit (2750 psial for N loop operatioa which is more than sufficient to offset any penalty associated with a lower RCS flow.
3.
Feedline Break NRC personnel also expressed concerns about the peak secondary side pressure reached dunng a FLB event with reduced RCS flow. Th6 Millstone Unit 3 licensing basis FLB analysis uses a conservative model for SG safety valve relief through the 3 intact SG The safety valves are conservatively assumed to open at 110% of the SG design pressure.
This prevents the pressure in the SG from exceeding the design pressure limit as long as the valves have sufficient relief capacity. Since the total relief capacity of these vaives is not exceeded, this modelis considered appropriate.
Dese Considerations 1.
Locked Rotor 6% rods in DNB continues to apply after the 4% flow reduction.
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SUPPLEMENTARY INFORMATION ON 4
RCS FLOW REDUCTION EVALUATION 4
The potential offsite doses due to a steam generator tube rupture event for Millstone ttut 3 tTable 15 04 in FSAR) are compared in the following table with the corresponding orfsite dose linuts #page 15.6-9 in
- the FS AR L I Offsite Radiological Doses -
Thyroid Dose trem)
Whole Body Dose tremi Calculated Limit Calculated Limit Pre accident iodine spike 2.1 300 0.019 25 2 hr Exclusion Area Boundary l
Pre accident iodine spike 0.24 300 0.0012 25 3 hr Low Population Zone Concurrent iodine spike 0.34 30 0.018 2.5 1
2 hr Exclusion Area Boundary j
Concurrent iodine spike.
0.076 30 0.0011 2.5 f
[8 hr Low Populat. ion Zone As shown in the table above, a signi6 cant amount of margin exists between the current offsite radiological l
doses and the limits. The 4% thermal design flow reduction was determined to result in a slight increase of offsite radiological doses. Since, there is ampie margin to the limits to support even a substantial increase in the offsite radiological doses, it is apparent that the offsite dose will still be below the linuts with a 4% thermal design flow reduction. Therefore, the conclusions of the Millstone Unit 3 FSAR that the radiological doses remain below 10CFR100 guidel:nes with a pre accident iodine spike and below 10%
of 10CFR100 guidelines with a concurrent iodios spike temmin valid.
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