ML20138N964

Requests That W Responses to NRC RAI on AP600 Be Withheld from Public Disclosure,Per 10CFR2.790

ML20138N964
Person / Time
Site:	05200003
Issue date:	02/21/1997
From:	Mcintyre B WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	Quay T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20057G394	List: ML20138N964 NSD-NRC-97-4992, Forwards non-proprietary & Proprietary Versions of Responses to 970103 Comments on Revised AP600 PRHR Heat Exchanger Test Rept.Affidavit,Encl
References
AW-97-1080, NUDOCS 9703030474
Download: ML20138N964 (17)

Text

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l Westinghouse Energy Systems Ba 355 Pinsburgh Pennsylvania 15230-0355 l Electric Corporation l

l l AW-97-1080 February 21,1997 Document Control Desk U.S. Nuclear Regulatory Commission ,

Washington, DC 20555 ATTENTION: MR. T. R. QUAY l l APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

SUBJECT:

WESTINGHOUSE RESPONSES TO NRC REQUESTS FOR ADDITIONAL i INFORMATION ON Tile AP600

Dear Mr. Quay:

l The application for withholding is submitted by Westinghouse Electric Corporation (" Westinghouse")

pursuant to the provisions of paragraph (b)(1) of Section 2.790 of the Conunission's regulations. It contains commercial strategic information proprietary to Westinghouse and customarily held in confidence.

l The proprietary material for which withholding is being requested is identified in the proprietary l version of the subject report. In conformance with 10CFR Section 2.790, Affidavit AW-97-1080 l accompanies this application for withholding setting forth the basis on which the identified proprietary information may be withheld from public disclosure.

Accordingly, it is respectfully requested that the subject information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10CFR Section 2.790 of the i Commission's regulations.

l Correspondence with respect to this application for withholding or the accompanying affidavit should reference AW-97-1080 and should be addressed to the undersigned.

Very truly yours, Ba/*' u Brian A. McIntyre, anager Advanced Plant Safety and Licensing i jml

( cc: Kevin Bohrer NRC OWFN - MS 12E20 9703030474 970221 PDR A00CK 05200003 l A PDR & ,

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AW-97-1080 I

AFFIDAVIT l

COMMONWEALTH OF PENNSYLVANIA:

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ss COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally appeared Brian A. McIntyre, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on l

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: l A # _f Brian A. McIntyre, Manager l

Advanced Plant Safety and Licensing >

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Sworn to and subscribed before me this g6M day 4 of

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/J v ,

NotarialSeal  ;

Janet A. Schwab. Notary Public g ,

Monroeville Boro, NMgheny County My Commuion Expires May 22,2000 Notary Public Member, Pennsylvanta Assocacon of Notate ms

AW-97-1080 (1) I am Manager, Advanced Plant Safety And Licensing, in the Advanced Technology Business Area, of the Westinghouse Electric Corporation and as such, I have been specifically delegated the function of reviewing the proprie ary 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 procedur 'ilized 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 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 imormation in confidence. The application of that system and the substance of that system l

constitutes Westinghouse policy and provides the rational basis required.

I 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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. AW-97-1080 (a) The information reveals the distinguishing aspects of a proa= (as 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 prognms of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

There are sound policy reasons behind the Westinghouse system which include the following:

(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors it is, therefore, withheld from disclosure to nrotect 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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. AW-97-1080 (c) Use by our competitor would put Westinghouse at a competitive disadvantage 1.y reducing his expenditure of resources at our expense.

I (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 raay 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. t (iv) The information sought to be protected is not available in public sources or available infermation has not been previously employed in the same original manner or method to the best of our knowledge and belief.

(v) Enclosed is Letter NS.D-NRC-97-4992, February 21,1997 being transmitted by Westinghouse Electric Corporation (W) letter and Application for Withholding Proprietary Information from Public Disclosure, Brian A. McIntyre (E), to Mr. T. R. Quay, Office of NRR. The proprietary infonnation as submitted for use by Westinghouse Electric Corporation is in response to questions concerning the AP600 plant and the associated design certification application and is expected to be applicable in other licensee submittals in response to certain NRC requirements for i

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. AW-97-1080 justification of licensing advanced nuclear power plant designs.

This information is part of that which will enable Westinghouse to:

(a) Demonstrate the design and safety of the AP600 Passive Safety Systems.

(b) Establish applicable verification testing methods.

(c) Design Advanced Nuclear Power Plants that meet NRC requirements.

(d) Establish technical and licensing approaches for the AP600 that will ultimately result in a certified design.

(e) Assist customers in obtaining NRC approval for future plants.

Further this information has substantial commercial value as follows:

(a) Westinghouse plans to sell the use of similar information to its customers for purposes of meeting NRC requirements for advanced plant lice'ises.

(b) Westinghouse can sell support and defense of the technology to its customers  !

in the licensing process.  !

Public disclosure of this proprietary infonnation is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar advanced nuclear power designs and licensing defense j services for commercial power reactors without commensurate expenses. Also, public j 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 f information.

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- . .W-97-1080 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 duphcate 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 for developing analytical methods and receiving NRC approval for those methods.

Further the deponent sayeth not.

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o Attachment #2 to NSD-NRC-97-4992 j

Discussion items from January 3,1997 letter.

Technical

1. It would be helpful for the reader to know which orifice plate was used for each test, to better understand how flow data are computed.

Response

Each test is identified as having a high (H), medium (M) or low (L) flow rate orifice as indicated in Table 6-2. A footnote will be added to Tables 8-1

, through 8-5. to clarifiy this convention. Replacement pages will be issued in a report errata to be issued.

2. Uncertainties in actual data are appropriate and useful. However, given the importance of the information derived from the raw data, estimates of the uncertainties in derived quantities, such as flow rates, heat transfer rates, and heat transfer coefficients should be provided.

Response

The uncertainity in the mass flow rate was calculated and presented in Section

6. The estimated error on the mass flow calculation was 1.2% of reported value based on the combined effects of temperature error, differential pressure error, pressure measurement error and uncertainty in orifice and pipe diameters. The error estimates on the heat fluxes and heat transfer coefficients were not individually calculated. The calculated quantities were viewed as a universe of test data to be compared and correlated with various correlations.

The confidence levels in the heat transport propenies were estimated from the range of test data results as shown in Figure 9-20 of the PRHR report. In addition, the heat fluxes were determined from a curve fit of the individual tube temperature readings to eliminate or minimize the impact of individual temperature readings. No additional error analysis is necessary.

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3. The discussion in Section 8 is somewhat misleading and rather difficult to j follow, in some cases due to errors in the figures (see below). The data do seem to support a conclusion that the tank is well-mixed radially (e.g. Fig. 8-25). Vertical mixing, however, is not as efficient, and the discussion on p. 8-5 seems to focus on long-term behavior (~95N sec). Comparing the top and bottom tank elevations overlooks for instance, tae behavior shown in Table 8- j 8, before the top of the tank saturates. Here (column "D"), while there is only 42*F gradient between the 23.917 and 1.917 ft elevation (the reference in the text to the 4.917 elevation as the lowest is not clear), there is almost 95'F between the 1.917 and tube-top (19.917 ft) elevations. j l

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Response

The legend on Figure 8-24 is in error and should be reversed, i.e. "A" should be elevation 1.917 feet, "B" should be elevation 4.917 feet, etc. The 4.917 foot elevation obviously is not the lowest elevation. The 4.917 foot elevation was used only because of the considerable lag in the temperature at the bottom wm

1 Attachment #2 to NSD-NRC-97-4992 1 of the vessel and therefore is not indictive of the majority of the vessel. The sentence will be revised to clarify the purpose of the statement. Replacement pages will be issued in a report errata to be issued.

4. The staff understands that the report is limited, for the most part, to a discussion of the test program without any specific consideration of applicability to the current AP600 PRHR HX design (which has been addressed by Westinghouse in RAI responses). Nevertheless, some of the discussion in Section 8 is also misleading in this regard. For instance, in discussing the plume tests, Section 8-2 (p. 8-3) states, " . there should be no interactions between rows of HX tubes exist (sic) when the distance between the rows 2 feet or more." While this may have been a pertinent observation for the 1989 HX design, it has no relevance whatsoever to the current design.

Similarly, when discussing zones of influence of the plume, the report indicates that there is a minimum of tube-to-tube interaction. Since the tube spacing (center-to-center) 1. inches within rows of the current HX design and 3" between rows, and the plume measurements show an influence, in some cases, more than 1.5" from the tube centerlineit seems reasonable to believe that there will, in fact, be some degree of tube-to-tube interaction in the current design. Note too, that the measurements presented in Figs. 8-7 and 8-8 represent plumes between the tank wall and a tube; no data are shown that would correspond to a plume (or interacting plumes) between tubes.

Response

The paragraph will be rewritten as follows. A replacement page will be issued in a report errata to be issued.:

A comparison of plots for test P01 and CO2 show that the shape of the plume was largely unaffected by the placement of the back wall 1 foot closer to the tubes. The measurement of the plume was limited to 3 inches on either side of the outside tube at the wall of the vessel. A comparison of the plots of C03 ,

and CN which relocate a baffle to within a foot in front of the row of tubes  !

show that the plume temperatures are generally higher than those observed during the tests without baffles in front of the tubes. The plume tests shows that the major portion of the buoyant plume does exist in a relatively confined ,

area around a given tube and buoyancy is limited to the immediate area around  ;

the tubes on the order of i t.0 inches on either side of the tube centerline. j The buoyant plume does become sightly larger along the tube toward the top of the tank. The plume data indicates that the zone of influence of temperature effects is limited to approximately i2.0 inches on either side of the tube centerline based on the plume test and configuration test temperature ,

profiles.

Since the PRHR rows are on a 3 inch square pitch, this does not exclude some j thermal interaction but would limit interaction because the primary plume is less than 1.5 inches from the tube centerline. Therefore the vertical tubes can i be assumed to behave independently. Thus, the data from this series of tests  !

also apply to multi-headered tube arrays. This observation combined with the similar heat fluxes for tests C03 and CM indicate that there should be limited )

interactions between rows of HX tubes when the distance between the rows is 3 inches or more. Observation of the test video tapes indicates that the plume w

Attachment #2 to NSD-NRC-97-4992

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is very localized along the tube during the high heat flux.

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Editorial '

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5. Figure 9-18 does not appear to be a plot of PRHR boiling data as stated, but rather a copy of Fig. 9-3. the single-phase (Inside tube) heat transfer data.

Response

The correct figure will be issued in a report errata to be issued.

6. Figure 8-24 is mislabeled and there are other data problems in Section 8.

Looking at Table 8-7 and comparing the data to Fig. 8-24 (column "D") at about 5000 seconds location "G" is not the hottest, as plotted in the figure; "C" (19.917 ft) is hottest. Also, in column "J" of the tables, the 4.917 ft.

elevation is markedly colder than the 1.911 ft. elevation (see Tables 8-8 and 8-9, for instance); it appears that the thermocouple may have a significant bias, which should be noted in the figures or in the text. Even if the curve is relabeled, though, there appears to be a general discrepancy between the tables and the curves.

Responses:

The legend of table 8-24 is mislabled and should be reversed. This would make location "G" at the top of the tubes. Column "J" in Tables 8-7, 8-8 and 8-9 are displaced; the revised table are attached. Replacement pages will be issued in a report errata to be issued.

7. Section 4.4.1, p. 4-4. first sentence-the tube length should be 18.16 " feet" not

" inches."

Response

The tube length should be 18.16 feet.. A replacement page will be issued in a i report errata to be issued.

8. Section 9: Why is Eq. 9-10 different from the "PRHR Data" equation shown in Fiq. 9-37

Response

The equation on the figure is correct and represents all of the tube 1 and tube 2 data. A replacement page will be issued in a report errata to be issued.

9. In Fig. 9-1, what is the distinction (If any) between the " triangle", " square" and " diamond" data? There is no legend to distinguish between them.

Response

The three symbols indicate three tests from the initial PRHR test runs S-7, S-8 and S-9. The figure is only for illustration only. No action is required.

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Attachment #2 to NSD-NRC-97-4992 l

10. In Fig. 9-3, the dashed line" in the legend for the Ditrus-Boelter and Petukhov-Popov correlations look identical; they also cannot be differentiated l in the figure itself.

Response

A replacement page will be issued in a report errata to be issued.

11. Figures 9-21 and 5'-22 do not appear to be labeled properly; the relevance of the curves cannot be determined.

Response

Figures 9-22 and 9-23 should be identified as 9-21 and 9-22, respectively.

The figures need to have additional labeling to clarify. Replacement pages will be issued in a report errata to be issued.

12. Page 9-7, eqn 9-20, liquid thermal diffusivity isn't used in the equation and should not be listed in the nomenclature.

Response

Yes, it will be deleted. A replacement page will be issued in a report errata to be issued.

13. Page 9-11, eqn 9-25, right hand side, denominator under the radical, rho sub r should be rho sub v.

Response

Yes, it will be changed. A replacement page will be issued in a report errata to be issued.

14. Page 9-14, second to last paragraph, " Figures 9-22 and 9-23" should be 9-21 and 9-22, both times it appears.

Response

Yes, it will be changed. A replacement page will be issued in a report errata to be issued.

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- i TABLE 8-7 PASSIVE RESIDUAL HEAT REMOVAL TANK TEMPERATURES FOR .

TEST T02 AFTER 5172 SECONDS Location in Tank Elevation C D E F G H K J

~ A b,c-s 28.000 26.000 23.917 22.917 21.417

~

19.917-

~

18.417 16.917 15.417 .

13.917

~

12.417

~

10.917 9.417

~

7.917

~

6.417

~

4.917

~

3.417

~

1.917 0.417 l-

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TABLE 8-8 PASSIVE RESIDUAL HEAT REMOVAL TANK TEMPERATURES FOR TEST T02 AFTER 7983 SECONDS Location in Tank

' Elevation C D E F G H K J

28.000 a mummma 26.000 a,b, c

23.917 22.917 21.417 19,917

~

18.417

~

16.917

~

15.417

~

13.917 12.417 10.917 9.417 7.917 6.417 4.917 3.417 1.917 ,

1 0.417

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B TABLE 8-9 PASSIVE RESIDUAL HEAT REMOVAL TANK TEMPERATURES FOR TEST T02 AFTER 14178 SECONDS Location in Tank Elevation C D E F G H J K 28.000 - -8 -  ;

~

26.000 a,b,  !

c 23.917 im 22.917 21.417

~

19.917 ,

~

18.417 16.917 15.417 13.917 .

1 12.417 1

10.917 9.417 7.917 6.417 4.917 i 3.417 1.917 0.417 .

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C;<

~

PRHR HEAT EXCHANGER TEST T-02 TANK TEMPERATURES $.

A A Elevation 1.917 (ft) g, B B Elevation 4.917 (ft) {,

C "

C Elevation 7.917 (ft)

D E

D Elevation 10.917 (ft)

E Elevation 13.917 (ft) f y

F F Elevation 16.917 (ft) g G G Elevation 19.917 (ft) s H H Elevation 22.917 (ft) [

I I Elevation 23.917(ft) E

=

2N l 1 l ,

9 a 7 * ^

m

• .- 6. 200 - r 7

E w

% 150 - _

n b

E

[- 100 - _

50 - ,  ;  : m 0 5000 10000 15b00 20000 $

. m Time (s) >

m i 1990 TEST DATA

s.  !

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_.. _.. - - -.. = _ ._ _. .._ . .

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Figure 9-18 ,

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Recommended Fit of PRHR Data Using Rohsenow Parameters 100  :

10= i A

E8 I+

o PRilR Data Expressed in Rohsenow  !

Pihg } kPe-P.) Pa ram eters  !

Rohsenow Ibrm Correlation ,

f 0.1 -  :

0.01-  :

I I 0.001--

0.001 0.01 0.1 1 ,

C,AT' I

( h, , Pr, i

I PageI  !

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REFNUPR.XLS prEt I Comparison of the PRHR Data with the Heat Transfer Correlations -

100000 - t 10000 -

1000 -

2 o PRilR Data Nu 100 -

Ditius-Boetter

- - - Petukhow-Popov gon PRHR Data 10 -

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- I 10k 1000 0.1 DVp F

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Prepared by Fred Peters 2/13/97 Page1

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