ML14181A537
| ML14181A537 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 06/05/2014 |
| From: | Gebbie J P Indiana Michigan Power Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| AEP-NRC-2014-42, TAC MF2916 | |
| Download: ML14181A537 (34) | |
Text
zINDIANA Indiana Michigan PowerMICHIGAN Cook Nuclear PlantOne Cook PlaceBridgman, MI 49106A unit ofAmerican Electric Power IndianaMichiganPower.comJune 5, 2014 AEP-NRC-2014-4210 CFR 50.9010 CFR 50.36Docket No.: 50-315U. S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC, 20555-0001Donald C. Cook Nuclear Plant Unit 1Response to "Request for Additional Information on the Application for Amendment toRestore Normal Reactor Coolant System Pressure and Temperature Consistent with PreviouslyLicensed Conditions (TAC No. MF2916)," Dated May 6, 2014References:1. Letter from J. P. Gebbie, Indiana Michigan Power Company (I&M), to U. S. NuclearRegulatory Commission (NRC) Document Control Desk, "Donald C. Cook Nuclear PlantUnit 1 Docket No. 50-315, License Amendment Request Regarding Restoration ofNormal Reactor Coolant System Operating Pressure and Temperature Consistent withPreviously Licensed Conditions," dated October 8, 2013, Agencywide DocumentsAccess and Management System (ADAMS) Accession Number ML13283A121.2. Letter from T. J. Wengert, NRC, to L. J. Weber, I&M, "Donald C. Cook Nuclear Plant,Unit 1, Request for Additional Information on the Application for Amendment to RestoreNormal Reactor Coolant System Pressure And Temperature Consistent with PreviouslyLicensed Conditions (TAC No. MF2916)," dated March 31, 2014, ADAMS AccessionNumber ML14066A31 1.3. Letter from J. P. Gebbie, I&M, to NRC Document Control Desk, "Donald C. CookNuclear Plant Unit 1, Response to 'Request for Additional Information on the Applicationfor Amendment to Restore Normal Reactor Coolant System Pressure and TemperatureConsistent with Previously Licensed Conditions (TAC No. MF2916),"' datedApril 29, 2014, ADAMS Accession Number ML14121A422.4. Letter from T. J. Wengert, NRC, to L. J. Weber, I&M, "Donald C. Cook Nuclear Plant,Unit 1 -Request for Additional Information on the Application for Amendment to RestoreNormal Reactor Coolant System Pressure and Temperature Consistent with PreviouslyLicensed Conditions (TAC NO. MF2916)," dated May 6, 2014, ADAMS AccessionNumber ML14099A450.PROPRIETARY INFORMATIONEnclosure 6 to this Letter contains proprietary information.Withhold from public disclosure under 10 CFR 2.390.Upon removal of Enclosure 6, this Letter is decontrolled.
U. S. Nuclear Regulatory Commission AEP-NRC-2014-42Page 2By letter dated October 8, 2013 (Reference 1), Indiana Michigan Power Company (I&M) submittedan application for a license amendment to restore the normal reactor coolant system operatingpressure and temperature consistent with previously licensed conditions for the Donald C. CookNuclear Plant, Unit 1. The U.S. Nuclear Regulatory Commission (NRC) staff provided a Requestfor Additional Information (RAI) (Reference 2) to complete the review of Reference 1. I&Mresponded to Reference 2 by Reference 3. By letter dated May 6, 2014, the NRC provided anadditional RAI (Reference 4) to complete the review of Reference 1. This submittal provides I&M'sresponse to the RAIs contained in Reference 4, with the exception of RAIs Containment andVentilation Systems Branch (SCVB) RAI-3(c), SCVB RAI-9(a), and SCVB RAI-9(b). I&M plans torespond to these items by July 3, 2014.Enclosure 1 to this letter provides an affirmation statement. Enclosure 2 provides a cross referencefor I&M's response to the NRC RAI. Enclosure 3 provides responses to RAIs: SCVB RAI-5(b),SCVB RAI-10(a, b), SCVB RAI-11(a, b, c, d, e), Radiation Protection and Consequence Branch(ARCB) RAI-1(a, b), ARCB RAI-2(a, b), Electrical Engineering Branch (EEEB) RAI-1, EEEB RAI-2,EEEB RAI-3, EEEB RAI-4, and EEEB RAI-5. Enclosure 4 provides an "Application for WithholdingProprietary Information from Public Disclosure." Enclosure 5 provides non proprietary responses toRAIs: SCVB RAI-1 (a, b), SCVB RAI-2(a, b, c), SCVB RAI-3(a, b), SCVB RAI-4 (a, b, c, d, e), SCVBRAI-5(a), SCVB RAI-6, SCVB RAI-7, SCVB RAI-8, SCVB RAI-12, Nuclear Performance and CodeReview Branch (SNPB) RAI-1, SNPB RAI-2, and SNPB RAI-3(a, b). Enclosure 6 provides theresponse to NRC RAI: SCVB RAI-4(f) and includes proprietary information.This letter contains no new or revised commitments. Should you have any questions, pleasecontact Mr. Michael K. Scarpello, Regulatory Affairs Manager, at (269) 466-2649.Sincerely,Joel P. GebbieSite Vice PresidentJMT/ampEnclosures:1. Affirmation2. Donald C. Cook Nuclear Plant Unit 1 Cross Reference: Request for Additional Information -Response Enclosure3. Responses to SCVB RAI-5(b), SCVBRAI-10(a,b), SCVB RAI-11(a,b,c,d,e), ARCBRAI-1(a,b), ARCB RAI-2(a,b), EEEB RAI-1, EEEB RAI-2, EEEB RAI-3, EEEB RAI-4, andEEEB RAI-54. Westinghouse Letter, CAW-14-3954, Application for Withholding Proprietary. Informationfrom Public Disclosure, dated May 28, 2014PROPRIETARY INFORMATIONEnclosure 6 to this Letter contains proprietary information.Withhold from public disclosure under 10 CFR 2.390.Upon removal of Enclosure 6, this Letter is decontrolled.
U. S. Nuclear Regulatory CommissionPage 3AEP-NRC-2014-425. Attachment #2 (NP-Attachment) of Westinghouse Letter, LTR-PL-14-22, "WestinghouseResponses to NRC, "Donald C. Cook Nuclear Plant Unit 1 -Request for AdditionalInformation on the Application for Amendment to Restore Normal Reactor Coolant SystemPressure and Temperature Consistent with Previously Licensed Conditions (TAC No.MF2916)," dated May 28, 20146. Westinghouse Letter, LTR-PL-14-22 Cover Letter and Attachment #1 (P-Attachment),Westinghouse Responses to NRC, "Donald C. Cook Nuclear Plant Unit I -Request forAdditional Information on the Application for Amendment to Restore Normal ReactorCoolant System Pressure and Temperature Consistent with Previously Licensed Conditions(TAC No. MF2916)," dated May 28, 2014c: J. T. King, MPSCMDEQ -RMD/RPSNRC Resident InspectorC. D. Pederson, NRC Region IIIT. J. Wengert, NRC Washington DCA. J. Williamson, AEP Ft. Wayne, w/o enclosurePROPRIETARY INFORMATIONEnclosure 6 to this Letter contains proprietary information.Withhold from public disclosure under 10 CFR 2.390.Upon removal of Enclosure 6, this Letter is decontrolled.
ENCLOSURE 1 TO AEP-NRC-2014-42AFFIRMATIONI, Joel P. Gebbie, being duly sworn, state that I am Site Vice President of Indiana MichiganPower Company (I&M), that I am authorized to sign and file this request with the U. S. NuclearRegulatory Commission on behalf of I&M, and that the statements made and the matters setforth herein pertaining to I&M are true and correct to the best of my knowledge, information, andbelief.Indiana Michigan Power CompanyJoel P. GebbieSite Vice PresidentSWORN TO AND SUBSCRIBED BEFORE MEOTýPATRICIA ANN EDIEMy Commission Expires 1A-.P.. ,,.--,. SO -C of UmniuConins~u*MYcfsltmoimly
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2 to AEP-NRC-2014-42Donald C. Cook Nuclear Plant Unit ICross Reference: Request for Additional Information -Response EnclosureThe Request for Additional Information (RAI) responses are contained in separate Enclosures.Table 1 below provides a cross reference between the RAI and the Enclosure providing the RAIResponse.ISCVB RAI-1 a, b Enclosure 5, Non-ProprietarySCVB RAI-2 a, b, c Enclosure 5, Non-ProprietarySCVB RAI-3 a, b Enclosure 5, Non-ProprietarySCVB RAI-3 c July 3, 2014SCVB RAI-4 a, b, c, d, e Enclosure 5, Non-ProprietarySCVB RAI-4 f Enclosure 6, ProprietarySCVB RAI-5 a Enclosure 5, Non-ProprietarySCVB RAI-5 b Enclosure 3SCVB RAI-6 Enclosure 5, Non-ProprietarySCVB RAI-7 Enclosure 5, Non-ProprietarySCVB RAI-8 Enclosure 5, Non-ProprietarySCVB RAI-9 a, b July 3, 2014SCVB RAI-10 a, b Enclosure 3SCVB RAI-1 1 a, b, c, d, e Enclosure 3SCVB RAI-12 Enclosure 5, Non-ProprietaryARCB RAI-1 a, b Enclosure 3ARCB RAI-2 a, b Enclosure 3EEEB RAn1 B EncoureEEEB RAI-1 Enclosure 3EEEB RAI-2 Enclosure 3EEEB RAI-3 Enclosure 3EEEB RAI-4 Enclosure 3EEEB RAI-5 Enclosure 3SNPB RAI-1 Enclosure 5, Non-ProprietarySNPB RAI-2 Enclosure 5, Non-ProprietarySNPB RAI-3 a, b Enclosure 5, Non-Proprietary ENCLOSURE 3 TO AEP-NRC-2014-42Responses to SCVB RAI-5(b), SCVB RAI-10(a,b), SCVB RAI-11(a,b,c,d,e),ARCB RAI-1(a,b), ARCB RAI-2(a,b), EEEB RAI-1, EEEB RAI-2, EEEB RAI-3, EEEB RAI-4,and EEEB RAI-5
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3 to AEP-NRC-2014-42 Page 2Table of ContentsContainment and Ventilation Systems Branch (SCVB) .................................... 3SCVB RAI-5(b) ............................................................................................. 3SCVB RAI-10 ............................................................................................... 4SCVB RAI-11 ............................................................................................... 5Radiation Protection and Consequence Branch (ARCB) ................................. 9ARCB RAI-1 ................................................................................................. 9ARCB RAI-2 .................................................................................................. 9Electrical Engineering Branch (EEEB) .......................................................... 10EEEB RAI-1 .............................................................................................. 11EEEB RAI-2 ............................................................................................... 13EEEB RAI-3 ............................................................................................... 14EEEB RAI-4 ............................................................................................... 15EEEB RAI-5 ............................................................................................... 15R e fe re n ce s .......................................... ................................................ 2 0
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3 to AEP-NRC-2014-42Page 3Containment and Ventilation Systems Branch (SCVB)SCVB RAI-5(b)Reference 1, Enclosure 6, Section 5.4.2.6 states, in partThe evaluation of the long term LOCA M&E and peak containment pressure is predicated uponthe continued application of the operability assessment supporting NSAL- 11-5 (Reference 3), inconjunction with the AOR.(b) Describe the operability assessment supporting NSAL-11-5 (Reference 2), including theimpact of the corrected M&E release (due to the issues identified in NSAL-1 1-5), on thecontainment response AOR.Response:Donald C. Cook Nuclear Plant (CNP) has taken a multi-staged approach to address the issuesin Nuclear Safety Advisory Letter (NSAL)-1 1-5. The primary assessment for continuedoperability is the 6 pounds per square inch (psi) generic margin contained within theWestinghouse WCAP-10325 loss of coolant accident (LOCA) mass and energy (M&E) andContainment response analysis. The generic analysis margin, listed by Westinghouse inNSAL-1 1-5, consists of a conservative non-mechanistic calculation and input I initial conditionassumptions. A mechanistic calculation with realistic input assumptions would provide acalculated peak pressure more than 6 psi lower. This is more than enough to offset the 2.31 psiCNP specific penalty due to NSAL-1 1-5. CNP decided that switching to the WestinghouseWCOBRA/TRAC LOCA M/E and Containment response methodology (generic topicalWCAP-17721 currently under U. S. Nuclear Regulatory Commission (NRC) review) wouldprovide the best resolution to the NSAL-1 1-5 issues. Indiana Michigan Power Company (I&M)and Westinghouse are currently working to reanalyze the LOCA M/E and Containmentresponse using the WCOBRA/TRAC methodology. After approval of WCAP-17721, the CNPplant specific WCOBRAITRAC analysis will be submitted for review.Additionally, to supplement the generic operability evaluation, described above, Westinghouseperformed a CNP-specific LOCA containment peak pressure sensitivity analysis. The sensitivityanalysis found that sufficient ice is already contained in the ice condenser to also offset theerrors. This ice is above the Technical Specification minimum considered in the analysis ofrecord (AOR). SCVB RAI-5(b), Table 1, provides the calculated peak pressure results of theWestinghouse sensitivities. The ice mass is tracked using procedural guidance to ensure that itis available each cycle.
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3 to AEP-NRC-2014-42Page 4SCVB RAI-5(b), Table 1: CNP Calculated Peak Pressure SensitivitiesPeak Pressure(pounds per square inch gauge (psig))AOR 11.75AOR + NSAL-11-5 Errors 14.06AOR + NSAL-11-5 w/Additional Ice Mass 11.96Recently, Westinghouse issued NSAL-14-2 which identified additional errors in the LOCA M/Eand Containment response analysis relative to the modeling of the specific heat of the steamgenerator (SG) thick metal mass. The penalty has been assessed against the generic margincommunicated in NSAL-1 1-5 and excess ice contained within the condenser and both sourcesof margin continue to be sufficient to offset the combined NSAL-14-2 and NSAL-1 1-5 penalties.SCVB RAI-1OPlease describe the impact of the changes in M&E release during LOCA and main steam linebreak (MSLB) accident to the following containment analyses:(a) Sump water temperature response(b) Net Positive Suction Head (NPSH) analysis for Emergency Core Cooling System (ECCS)and the containment heat removal pumps that draw suction from the containment sump inthe post-accident recirculation mode.Response (a):The maximum recirculation sump water temperature value used as a design input to other CNPUnit 1 accident analyses is not itself based on an analysis. Instead, the temperature used asdesign input reflects measurements taken during Waltz Mill Facility ice condenser testingperformed in 1974, and as such, is not impacted by specific changes in M&E releasesassociated with returning the Unit 1 reactor coolant system (RCS) to normal operatingpressure/normal operation temperature (NOP/NOT) conditions.CNP Unit 1 Updated Final Safety Analysis Report (UFSAR), Revision 25, Chapter 14,Section 14.3.4.1.3.1.3, Peak Containment Pressure Transient, Item 4, identifies an icecondenser drain temperature of 190 degrees (0) Fahrenheit (F) as the sump temperature valueused for containment pressure analysis, citing WCAP-8282 as a reference. WCAP-8282(Reference 1) and WCAP-8282, Addendum 1 (Reference 2) document test values measured atthe Waltz Mill Facility. Per Page 23 of WCAP-8282, Addendum 1:
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3 to AEP-NRC-2014-42Page 5"The measured temperature of the condensate and drain at the end of blowdown is 220°F,but additional water drains from the ice bed after blowdown is complete. The resultantcondensate and drain temperature after this drainage is 190'F."Because the initiation of switchover of ECCS and containment spray (CTS) pumps from therefueling water storage tank to the recirculation sump occurs after biowdown is complete, typicalice condenser design basis containment pressure response analysis (post-blowdowncalculation) assume a maximum sump temperature of 190'F.However, subsequent calculations of sump temperature transients show sump temperature atthe initiation of the switchover to cold leg recirculation to be <1700F, which confirms that theassumption of 1 90°F maximum sump temperature is conservative.Response (b):To ensure the calculated NPSH-required value is conservatively maximized under all conditions,the CNP Unit 1 NPSH AOR (Reference 3) for the ECCS pumps and CTS pumps uses boundingdesign inputs rather than relying on specific containment conditions associated with specific M&Ereleases or pump flow rates associated with specific flow requirement scenarios. Thesebounding design inputs include use of negative containment pressure (12.9 pounds per squareinch absolute (psia)), maximum recirculation sump temperature (190°F), and conservative flowvalues during the cold leg recirculation and hot leg recirculation phases of the design basisaccident.Consequently, the ECCS and CTS pumps NPSH AOR is not affected by changes in M&Erelease associated with returning the Unit 1 RCS to NOP/NOT conditions.SCVB RAI-1IConsidering the changes (due to change in NOP/NOT) in the M&E release during LOCA andMSLB accident, please provide the following information for NRC staff review. Refer toSEC Y- 11-00 14 for more information.(a) The value of the required NPSH (i.e., NPSHR) for the ECCS and the containment heatremoval pumps that draw suction from the containment sump in the post-accidentrecirculation mode.(b) The basis for the NPSHR, including the standard on which it is based. As an example, theNPSHR for ECCS and containment heat removal system pumps is commonly based onthe Hydraulic Institute standard, to which the NPSHR is equal to the available NPSHdetermined in a factory test at the pump design flow with a three-percent drop in the totaldynamic head.(c) The uncertainty in the factory tested value of NPSHR based on the actual site conditions.(d) The minimum NPSH available in the proposed analysis at each pump inlet based onmaximizing the sump water temperature along with maximizing the suction strainer headloss based on Generic Safety Issue 191 resolution and maximizing piping head loss.
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3 to AEP-NRC-2014-42Page 6(e) The minimum NPSH margin for each pump and its percentage, based on NPSHR withuncertainty added.Response:As indicated in the response to SCVB RAI-10(b), because of the previous use of a conservativeanalysis approach, the NPSH AOR for the ECCS and CTS pumps is not impacted by specificchanges in M&E releases associated with returning the Unit 1 RCS to NOP/NOT conditions.Consequently, the current AOR (Reference 3) remains bounding. The responses to SCVBRAI-11 (a) through SCVB RAI-11 (e) reflect the current AOR (Reference 3).The results of NPSH analyses for CNP were previously submitted to addressGeneric Letter (GL) 97-04, "Assurance of Sufficient Net Positive Suction Head for EmergencyCore Cooling and Containment Heat Removal Pumps," and GL 2004-02, "Potential Impact ofDebris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors." The following public documents in Agencywide Documents AccessManagement System provide historical context and relevant technical information regarding CNPNPSH analysis:" ML003681807 (Reference 5), AEP revised response to GL 97-04" ML003710891 (Reference 6), Nuclear Reactor Regulation Safety Evaluation related toGL 97-04 response for CNP* ML080770394 (Reference 7), AEP supplemental response to GL 2004-02* ML1 01960128 (Reference 8), NRC Staff comments on GL 2004-02 response for CNPThe stated purpose of SECY-11-0014 is to "resolve issues regarding the use of containmentaccident pressure (CAP) in analyzing pump performance in emergency core cooling systemsand containment heat removal systems during postulated accidents." These issues are notrelevant for CNP because the AOR does not credit CAP, but rather conservatively assumes anegative pressure (12.9 psia) during all phases of a design basis accident. The acceptancecriteria in the AOR are consistent with the requirements of NRC Regulatory Guide 1.1, "NetPositive Suction Head for Emergency Core Cooling and Containment Heat Removal SystemPumps" (Reference 4), specifically stating that, "Results of this analysis are acceptable ifadequate NPSH (NPSHa > NPSHr) is provided to system pumps, assuming maximum expectedtemperatures of pumped fluids and no increase in containment pressure from that present priorto postulated loss of coolant accidents."Response (a):See Table RAI-SCVB-1 1-1 for the requested information taken from the current AOR.
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3 to AEP-NRC-2014-42Page 7Response (b):A response to this question was previously provided by AEP in a submittal related to resolution ofGL 2004-02 (Reference 7.3, NRC Information Item 3.g.3, p. 233). The text of the previousresponse, which remains valid, is provided below:"The required NPSH values are specified by the individual pump manufacturers, and are shownon the certified pump performance curves. Pump manufacturers typically set the required NPSHusing a test loop where pressure is lowered in the suction source until a drop of 3% of the totalhead is measured. The available NPSH at which the 3% head drop occurs is then defined as therequired NPSH for that flow. This method of required NPSH determination is used unless analternate method was specified by the customer. Since I&M did not specify an alternate methodto calculate required NPSH, it is assumed that the 3% head drop method was utilized."Response (c):SECY-11-0014, Section 6.0, provides draft Staff Guidance regarding treatment of uncertaintiesfor the use of CAP in analyzing pump performance in ECCS and containment heat removalsystems during postulated accidents. Included in the draft guidance is a qualitative discussionof potential uncertainty differences in NPSHr of a pump installed in the field versus a pumptested at the pump vendor's facility.The CNP NPSH AOR is not impacted by the proposed restoration of NOP/NOT conditions.Additionally, the AOR does not credit CAP. The AOR uses conservative (i.e., bounding) inputsand assumptions for the design basis accident case to produce bounding results, but does notquantify specific uncertainties.Response (d):See Table RAI-SCVB-1 1-1 for the requested information taken from the current AOR.Response (e):See Table RAI-SCVB-11-1 for the requested information taken from the current AOR.
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3 to AEP-NRC-2014-42Page 8Table RAI-SCVB-11-1: Cook Unit 1 ECCS and CTS Pumps NPSH MarginMinimum NSPS Margin Note 1 Limiting Recirculation Case from MD-01-ECCS-004-N Note 2Pump Designation NPSHr NPSHa Margin(ft.) (ft.) (ft.-) Ratio Case No. Description1-PP-50E East Centrifugal Charging 13.6 184.2 170.6 13.54 Rev 4, Case 10 Dual train with East RHR pump failure1-PP-50W West Centrifugal Charging 13.6 184.3 170.7 13.55 Rev 4, Case 10 Dual train with East RHR pump failure1-PP-26N North Safety Injection 16.2 159.1 142.9 9.82 Rev 4, Case 11 Dual train with West RHR pump failure1-PP-26S South Safety Injection 16.6 157.9 141.3 9.51 Rev 4, Case 11 Dual train with West RHR pump failure1-PP-35E East RHR 16.3 30.7 14.4 1.88 Rev 4, Case 11 Dual train with West RHR pump failure1-PP-35W West RHR 16.6 27.6 11.0 1.66 Rev 4, Case 10 Dual train with East RHR pump failure1-PP-9E East Containment Spray 15.0 26.9 11.9 1.79 Rev 6, Case 23 Dual train with West RHR pump failure1-PP-9W West Containment Spray 14.8 27.8 13.0 1.88 Rev 6, Case 8 Dual train with East RHR pump failureNote 1 Slight differences between values in this table and similar information tabulated in Ref. 7 reflect recent updates to the analysis-of-record associated with planned replacement of the CTS heat exchangers.Revision 2 (1/20/00) -Provides basis for information submitted in Ref. 5Revision 3 (2/29/08) -Calculation Impact Addendum to assess the impact resulting from EC-47743 (additional check valvesdownstream of RHR pump minimum flow connection and reconfigured cross-tie downstream of the RHR heat exchangers)Revision 4 (8/22/08) -Calculation Impact Addendum to incorporate revised recirculation sump level per EC-48234 (newNote 2 Containment Recirculation Sump Licensing Basis per GL 2004-02); provides basis for information previously submitted in Ref. 7 andalso the ECCS pump information included in this RAI responseRevision 5 (6/25/13) -Calculation Impact Addendum to reflect planned replacement of Unit I West CTS heat exchangerRevision 6 (11/11/13) -Calculation Impact Addendum to reflect planned replacement of Unit 1 East CTS heat exchanger; providesbasis for CTS pump information in this RAI response
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3 to AEP-NRC-2014-42Page 9Radiation Protection and Consequence Branch (ARCB)ARCB RAI-1On page 1 of Enclosure 8 to the October 8, 2013, application, Section 2.0 lists the proposedrevised parameters for the proposed amendment. Please provide additional Informationregarding the effect these revisions will have on each of the radiological design basis accidentanalyses.(a) For the revised analyses, were any changes made to the methodologies that are in thecurrent analyses of record?(b) What are the revised calculated dose values for the Exclusion Area Boundary, LowPopulation Zone, and Control Room?Response (a):No methodology changes were made to the current analyses of record.Response (b):The results of the revised Large Break (LB) LOCA radiological dose analyses, which were theonly analyses that required sensitivity runs du- to NOP/NOT-related input parameter changes,are found below:Control Room:Offsite (exclusion areaboundary (EAB)):Offsite (low-population zone(LPZ)):4.26 rem total effective dose equivalent (TEDE)23.6 rem / 2.64 rem (Thyroid / Whole Body)176 rem / 0.864 rem (Thyroid I Whole Body)The above results maintain greater than 90 percent (%) of the margin to the applicableacceptance criteria:Control Room:EAB:LPZ:5 rem TEDE (10 CFR 50.67)300 rem / 25 rem (Thyroid I Whole Body) (RG 1.195)300 rem 1 25 rem (Thyroid I Whole Body) (RG 1.195)ARCB RAI-2In Section 3.0 of Enclosure 8 to the October 8, 2013, application, it states that the proposedrevised parameters will affect the previous maximum and minimum RCS liquid mass values. Italso states that these values are used in same of the dose consequence analyses.(a) What are the revised values for the maximum and minimum RCS liquid mass?
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3 to AEP-NRC-2014-42Page 10(b) Which dose consequence analyses are being referred to in the above statement and howdoes that affect the resulting dose values for those analyses?Response (a):The Unit 1 and Unit 2 RCS liquid masses utilized in the current analyses of record are boundingwhen compared to the revised Unit 1 liquid mass at NOP/NOT conditions. The doseconsequence analyses are common to both units. For the AOR, the lower-bound liquid mass of2.2649E+08 grams is representative of Unit 2, and the upper-bound liquid mass of 2.3874E+08grams is representative of Unit 1. At NOP/NOT conditions, the Unit 1 liquid mass is reduced toapproximately 2.3696E+08 grams due to the decrease in liquid density caused by NOP/NOT.Since this value is greater than the lower-bound liquid mass (Unit 2) and less than the upper-bound liquid mass (pre-NOP/NOT Unit 1) utilized in the AOR, the previous values remainbounding.Response (b):As noted in ARCB RAI-2(a) above, the lower-bound and upper-bound liquid mass valuesutilized in the dose consequence analyses of record remain bounding for the CNP Unit 1 Returnto NOP/NOT Program. Therefore, no analyses require revision as a consequence of thisparameter. The upper-bound liquid mass value is used in the LOCA dose consequenceanalyses to conservatively increase the RCS fission product inventory available for release tothe environment through containment purge. The lower-bound liquid mass is utilized todetermine conservative RCS radionuclide concentrations and is used in a wide range of doseconsequence analyses such as the following scenarios: SG Tube Rupture, Main Steam LineBreak (MSLB), Control Rod Ejection, and Locked Rotor. Again, all of these analyses areunaffected as the RCS masses utilized in the analyses of record remain bounding.Electrical Engineering Branch (EEEB)BackgroundThe licensee proposes to implement a return to RCS NOP/NOT conditions for CNP Unit I byincreasing the current operating nominal full-power pressurizer pressure from 2100 psia to 2250psia and increasing the current operating nominal full-power Tavg from 556 OF to 571 °F.Implementation of the program is proposed to occur prior to CNP Unit I Cycle 26 startup(October 2014).The licensee states that the proposed change also revises the Containment AirRecirculation/Hydrogen Skimmer (CEQ) fan start time from "108 seconds < CEO fan delay <132 seconds" to "270 seconds < CEO fan delay < 300 seconds" and revise containment spraysystem (CTS) actuation time delay from 115 seconds to 315 seconds.The CTS design at CNP includes a time delay relay in the CTS pump start circuitry that ispresently used to properly sequence the pump onto the emergency diesel generator (EDG) busand prevent overloading of the diesel. To offset the adverse effects of the proposed increase infull power average RCS temperature on best estimate loss-of-coolant accident peak cladding
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3 to AEP-NRC-2014-42Page 11temperature (BELOCA-PCT), the setting of this time delay relay is increased to further delayCTS actuation following a Hi-Hi containment pressure signal. The new time delay settingcontinues to support proper EDG bus loading, but also results in a higher containment pressureduring large break loss of coolant accident RCS blowdown, which limits the rate of RCS massrelease to containment and improves BELOCA-PCT results.In order for the NRC staff to verify that there are no adverse effects on the EDGs and noenvironmental qualification changes of electrical equipment due to the proposed changes,please provide the following information:EEEB RAI-1Provide the loading sequence for each EDG at CNP Unit 1. In your response, please describethe changes that have been made to the EDG loading sequence and any changes in motorloads as a consequence of higher containment pressure.Response:The automatic start time for individual safety-related loads to be sequenced onto an emergencyelectrical bus following a loss of offsite power (LOOP) is determined by safety-related logiccircuitry and may vary depending on the type of LOOP scenario that has occurred, i.e., LOOPwithout LOCA, LOOP with concurrent safety injection (SI), or LOOP with concurrent CTS.The automatic starting sequence and nominal start times for affected equipment for each LOOPscenario are summarized in Table RAI-EEEB-1-1. The requested license amendment to allowrestoring the Unit 1 RCS to NOP/NOT conditions does not affect the "LOOP without LOCA" and"LOOP with Safety Injection" columns because the actuation of safety-related equipmentrequired for these scenarios remains unchanged. The "LOOP with CTS -Proposed" column ofthe table reflects the impact of the requested license amendment. Note that the "LOOP with SI"and "LOOP with CTS -Current" columns of the table reflect information provided in Section 8.4of the CNP UFSAR, Revision 25.0.
Enclosure
3 to AEP-NRC-2014-42Page 12Table RAI-EEEB-1-1: CNP EDG Automatic Loading Sequence (Train A and Train B)Nominal Start Time After LOOP Signal(seconds)Equipment LOOP LOOP with CTSwithout LOOP with LOPwtCTwithout SLOCA SI Current Proposed600 Volt Safety-Related Load (block) 10 10 10 10Centrifugal Charging Pump Note 1 13 13 13SI Pump Note 1 17 17 17RHR Pump Note 1 21 21 21Component Cooling Pump 13 25 25 25Essential Service Water Pump 17 30 30 30Auxiliary Feed Water Pump 21 35 35 35CTS Pump Note 1 Note 1 41 225Non-Essential Service Water (NESW) 25 47 Note 2 Note 2PumpNote I -Not Automatically StartedNote 2 -The breaker for the NESW pump is sequenced closed but is then automatically trippeddue to a load conservation interlock associated with the CTS signal. In either the Currentor Proposed scenario, the NESW pump breaker would be closed at a nominal47 seconds, but would have no impact on bus loading since the NESW pump logic wouldprevent it from starting. The CTS pump is the last load to start under either the current orthe proposed scenario.The only change to the current loading scenarios involves the "LOOP with CTS," in which thelast load automatically started, i.e., the CTS pump, moves from a nominal 41 seconds out to anominal 225 seconds.To clarify the question regarding "changes in motor loads as a consequence of highercontainment pressure," the containment design pressure is not affected by the proposedchanges. The delay in CTS pump and hydrogen skimmer fan (CEQ) actuation allows creditinga higher value for minimum containment pressure during the early phases of a LBLOCA, whichprovides a benefit to the Best Estimate LOCA Peak Clad Temperature analysis.Figure RAI-EEEB-1-1 shows the increase in credited backpressure in the time interval from 50to 500 seconds. From the plot, the credited backpressure at the peak of this interval increasesfrom 18.3 psia (3.6 psig) in the AOR to 19.5 psia (4.8 psig) in the proposed analysis. Thecredited minimum backpressure is well below the containment design pressure of 12 psig. Aspresented in Section 5.4.2.6 of Enclosure 6 of the original License Amendment Request (LAR),the long-term peak containment pressure remains within the original containment design
Enclosure
3 to AEP-NRC-2014-42Page 13pressure. Safety-related motor loads used in the CNP EDG evaluations bound maximumloading conditions consistent with maximum design performance of the driven equipment. Themotor loads used in the analysis and evaluations are not dependent on the transient responseof driven equipment. Therefore, there are no changes to analyzed motor loads as aconsequence of the proposed changes.EEEB RAI-2Please provide a summary of your analysis and tests performed to show that the EDGs willcontinue to perform within the voltage and frequency requirements during the load sequencingand steady state operation after implementing the delayed CTS pump start. Please confirmwhether the proposed delay in CTS pump start can result in overlapping of loads during EDGload sequencing if the containment Hi-Hi signal is generated after the permissive from thesequencer timer during LOCAs (for any break sizes).Response:The adequacy of the CNP EDGs for automatic load sequencing of safety-related loads duringLOOP events is demonstrated by dynamic simulation of EDG response based on a functionalcomputer model that was benchmarked and tuned against EDG performance tests. The AORtakes into account not only the nominal load sequence starting times for each equipment loadon an EDG, but also considers worst case stack-up of timer tolerances (i.e., evaluates the effectof combinations of latest and earliest start times for the various components). The calculationprovides a bounding analysis that applies to the two Unit 1 EDGs and the two Unit 2 EDGs.Based on the output of the simulation, each EDG will be able to start and accelerate its requiredloads during accident conditions with an assumed worst case LOOP scenario. Maximum dips involtage or frequency during transient loading are demonstrated to be acceptable.As discussed in the response to NRC RAI EEEB RAI-1, the only change to the currentautomatic loading scenarios involves the LOOP with concurrent CTS, in which the last loadautomatically started, i.e., the CTS pump, moves from a nominal 41 seconds out to a nominal225 seconds. The calculation identifies that the worst case loading transient occurs when thetime interval between two motor starts is minimized. Therefore, delaying the start of the lastload is conservative and the results of the AOR remain valid.The AOR considers that the containment pressure "Hi-Hi" signal is generated simultaneouslywith a SI signal, and as noted above, the CTS pump is the last load automatically added to theemergency bus (under both the current and proposed time delays). Having the containmentpressure "Hi-Hi" signal generated at any time subsequent to the SI signal serves only to movethe CTS pump start farther away in time from the previously started load. Consequently, theproposed delay in CTS pump start cannot result in overlapping of loads during EDG loadsequencing.Closeout activities for the engineering change package that implements NOP/NOT conditionsfor Unit 1 will update the AOR to acknowledge delayed actuation of CTS for Unit 1.Although not directly included in EEEB RAI-2, in addition to extending the start time of the CTSpumps, the proposed change also extends the start time of the 600-volt Containment Air
Enclosure
3 to AEP-NRC-2014-42Page 14Recirculation/CEQ fan motors. In the AOR for EDG loading, the 600-volt bus is energized uponEDG start and loads that are not process-driven are added immediately. Process-driven 600-volt motor loads, such as the CEQ fan motors that are actuated following a containmentpressure "Hi" signal, are conservatively assumed to start simultaneously as a block load at themost critical time (based on lowest voltage) in the automatic sequence. This point occurs priorto starting the CTS pump. Therefore, the delay in automatically starting the CEQ fans has noimpact on the EDG AOR.EEEB RAI-3Updated Final Safety Analysis Report Section 8.1.2 states:The engineered safety feature (ESF) Loads are sequenced onto the Reserve AuxiliaryTransformers (RA Ts), under accident conditions, using the same timing relays and sequence asused for the EDG sequencing. The RATs supply the reserve auxiliary power for both units,Under certain plant conditions and grid loading conditions, and with proper precautions andlimitations, it is possible for either transformer No. 4 or transformer No. 5 to feed the entire plantauxiliary load.Please provide a summary of your analysis to show that the RATs can provide the requiredvoltage to ESF loads without actuating protective devices and meet the accident analysisassumptions.Response:The Load Flow analysis for CNP is performed using Operation Technology, Inc.'s ElectricalTransient Analyzer Program (ETAP). The Block Motor Start LOCA Sequence analysis is run inmultiple cases with the plant fed from 34.5kV transformer TR4, TR5, and split bus configuration(both TR4 and TR5).The calculation identifies the Degraded Voltage Relay (DGR) voltage setpoint and tolerancesassociated with DGR time sequence energization and time delay setting and reset voltage withtolerances.The ETAP run analysis includes verification that each individual LOCA Sequence run hassteady state voltages that meet the acceptance criteria for the connected equipment and aLOCA Sequence output voltage vs. time plot on the 4.16kV T-Buses (T11A, T11D, T21A,T21 D), where the degraded voltage relays are located, that does not trip the degraded voltagerelays.During Mode 1, ESF buses are fed from the main generator via UATs and the RATs remainunloaded in standby. The RATs load tap changer controller maintains the tap position at132.4V (or 4634V at 4.16kV buses) when in standby. This allows for compensation of voltagedrop in TR4, TR5 and the RATs when the ESF buses are transferred to offsite power during aLOCA. After the 4.16kV buses are transferred to the RATs, the controller setting is changed to119.2V (or 4172V at 4.16kV buses) to maintain bus voltage at 100%. The analysis shows thatrequired grid voltages at 345kV and 765kV are less than 95% during normal split bus alignment(Train A on TR4 and Train B on TR5).
Enclosure
3 to AEP-NRC-2014-42Page 15EEEB RAI-4Enclosure 5 to AEP-NRC-2013-79, "UFSAR Section 6.3.2 Pages Marked To Show ProposedChanges, Containment Spray Systems, System Design, paragraph A states:Delaying actuation of the Containment Spray Pumps for a period of time following acontainment pressure Hi Hi signal, for example, has the effect of allowing a higher containmentbackpressure during the initial phases of a loss of coolant accident, which provides a benefit tothe Peak Clad Temperature analysis.Please explain the impact of additional loading on the RATs and EDGs and potential changes inthe fuel oil consumption as a result of the changes in backpressure that ECCS loads could besubjected to during loss of coolant accidents.Response:As discussed in the response to RAI EEEB RAI-1, the containment design pressure is notaffected by the proposed changes. Motor loads used in CNP electrical system analyses andevaluations bound the maximum loading conditions consistent with maximum designperformance of the driven equipment. The loads used in the analysis and evaluations are notdependent on the transient response of driven equipment. There are no changes to analyzedmotor loads as a consequence of the proposed changes, and therefore no impact on theanalyzed performance of the RATs or EDGs.Similarly, the transient containment pressure response is not a factor in determining designbasis EDG fuel oil consumption, so there is no impact on fuel oil consumption or credited fuel oilstorage.EEEB RAI-5Please provide a discussion of the impact (e.g., changes to environmental qualificationparameters such as temperature and pressure) on Environmental Qualification (EQ) ofequipment affected by the proposed change. To demonstrate that the equipment remainedqualified for service in the revised pressure and temperature environment, please provide acomparison of the EQ overlays with containment temperature and pressure profiles includinghow margins are being maintained for qualified equipment in accordance with Title 10 of theCode of Federal Regulations (10 CFR) Part 50.49.Response:For CNP, the EQ limiting condition for containment temperature occurs following a main steamline break (MSLB). As explained in Sections 5.5.1.1 and 5.5.2.1 of Enclosure 6 of the originalLAR, the MSLB AOR for Unit 1 is a bounding analysis that encompasses both Unit 1 and Unit 2at a higher-than-licensed power level. Because evaluating the impact of the proposed timingchanges to CTS and CEQ fan actuation on this bounding analysis was not straightforward, a
Enclosure
3 to AEP-NRC-2014-42Page 16decision was made to prepare a Unit 1-specific full spectrum MSLB analysis to support returningto NOP/NOT conditions. Among other refinements, the new analysis incorporated the Unit 1licensed power level, modeling of the replacement SGs installed in 2000, the proposed timingchange for CTS and CEQ fan actuation, and Westinghouse updates to standard analysis inputs.The results of the Unit 1 MSLB reanalysis show that the peak post-accident temperature valueconsidered in the EQ program (324.7°F) is not affected by the proposed change to restoreNOP/NOT conditions. However, the reanalysis did affect the shape of the post-MSLBtemperature profile, as illustrated in Figures RAI-EEEB-5-1 and RAI-EEEB-5-2. The change tothe transient temperature profile is being evaluated for impact on the EQ program in accordancewith 10CFR 50.49. In conjunction with implementation of NOP/NOT conditions for Unit 1, EQprogram documentation will be updated to acknowledge the longer transient. A boundingtemperature profile will be used for the update. Based on preliminary assessments andengineering judgment, the change will not adversely impact qualification of components.The EQ limiting condition for containment pressure occurs following a LOCA. As presented inSection 5.4.2.6 of Enclosure 6 of the original LAR, the long-term peak containment pressureunder NOP/NOT conditions remains within the original containment design pressure. The EQenvelope with regard to pressure for equipment in containment is not affected.The current qualification criteria for other EQ parameters for equipment inside containment,specifically containment post-accident radiation levels, flood level, and pH, are unaffected byimplementation of NOP/NOT conditions on Unit 1.
Enclosure
3 to AEP-NRC-2014-42 Page 17Original TCD Evaluation.. .Return to HOP/NOT Evaluation2624.-. ...0 100 200 300 400 500Time After Break (s)Figure RAI-EEEB-1-1: Comparison of Credited Containment Backpressure
Enclosure
3 to AEP-NRC-2014-42Page 18EPMII4-,* a a* a a* a I* a a* a a* a aa a a4........4* a a* a a* a a* a aa a a* a a* a a* a aI a a* a a* I a* a a* a a* a a..................................................................................................................................................I aa a* aa aa aa I* a........................................................................................* aa aa a* a* a* a...............................a aa a...........................4* I* aa aa a* aa aI I.4........a Iaaaa0 aia I a.70 100 2101UI 1 I400 Soo SooTooTime (Sec)E lfRTREFigure RAI-EEEB-5-1: Post-MSLB Containment Temperature Profile -CNP AOR
Enclosure
3 to AEP-NRC-2014-42 PagLower Compartment TemperatureUpper Compartment Temperature350300_ 250.... ...........................................25 ... ._. ....20 -...oE150100- ... ...' ". " .." .... ..... ..... ..... ... ... ... .. .. .. .. .....5 I I I ,I I p I p I I -I I I I I500 200 400 600 800 10o0Time (seconds)Figure RAI-EEEB-5-2: Post-MSLB Containment Temperature Profile -CNP Unit Ile 19Reanalysis
Enclosure
3 to AEP-NRC-2014-42Page 20References1. WCAP-8282, "Final Report Ice Condenser Full Scale Section Test at the Waltz Mill Facility,"Westinghouse Electric Company, February 1974 (Proprietary)2. WCAP-8282, Addendum 1, "Answers to AEC Questions on Report WCAP-8282,"Westinghouse Electric Company, May 1974 (Proprietary)3. Calculation MD-01-ECCS-004-N, Rev. 6, "Unit 1 ECCS Pumps NPSH Analysis," AmericanElectric Power, November 11, 20134. NRC Regulatory Guide 1.1, "Net Positive Suction Head for Emergency Core Cooling andContainment Heat Removal System Pumps," November 2, 19705. I&M to NRC letter C0200-09, "Donald C. Cook Nuclear Plants Units 1 and 2, Requestedinformation, Generic Letter (GL) 97-04, Assurance of Sufficient Net Positive Suction Headfor Emergency Core Cooling and Containment Heat Removal Pumps," February 4, 2000(ADAMS ML003681807)6. NRC to I&M letter, "Donald C. Cook (DC Cook) Units 1 and 2 -Revised Response to NRCGeneric Letter 97-04, 'Assurance of Sufficient Net Positive Suction Head for EmergencyCore Cooling and Containment Heat Removal Pumps' (TAC Nos. MA8265 and MA8266)",May 3, 2000, (ADAMS ML003710891)7. I&M to NRC letter AEP:NRC:8054-02, "Donald C. Cook Nuclear Plant Units 1 & 2,Supplemental Response to Nuclear Regulatory Commission Generic Letter 2004-02:Potential Impact of Debris Blockage on Emergency Recirculation During Design BasisAccidents at Pressurized Water Reactors, February 29, 2008 (ADAMS ML080770407,package)7.1. AEP:NRC:8054-02, cover letter (ADAMS ML080770394)7.2. AEP:NRC:8054-02, Attachment 1, "References," through Attachment 3, "SupplementalResponse to GL 2004-02 and Request for Additional Information," February 29, 2008(ADAMS ML080770395)7.3. AEP:NRC:8054-02, Attachment 3, "I&M Response to Information Item 3.f.4," to "NRCInformation Item 3, "Conclusions," February 29, 2008 (ADAMS ML080770396)7.4. AEP:NRC:8054-02, Attachment 4, Figure A4-1 to Attachment 5, Figure A5-40 (ADAMSML080770400)7.5. AEP:NRC:8054-02, Attachment 5, Figure A5-41 to Attachment 7, "RegulatoryCommitments," February 29, 2008 (ADAMS ML080770404)8. NRC to I&M letter, "Donald C. Cook Nuclear Plant, Units 1 and 2 (DCCNP 1&2) -NRC StaffComments on Licensee's Supplemental Responses to Generic Letter 2004-02 (TAC Nos.MC4679 and MC4680), July 27, 2010 (ADAMS ML101960128)
ENCLOSURE 4 TO AEP-NRC-2014-42Westinghouse Letter, CAW-14-3954,Application for Withholding Proprietary Information from Public Disclosure Westinghouse Electric CompanyEngineering, Equipment and Major Projects1000 Westinghouse Drive, Building 3Cranberry Township, Pennsylvania 16066USAU.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643Document Control Desk Direct fax: (724) 940-856011555 Rockville Pike e-mail: , greshaja@westinghouse.comRockville, MD 20852 Proj letter: AEP-14-23CAW-14-3954May 28, 2014APPLICATION FOR WITHHOLDING PROPRIETARYINFORMATION FROM PUBLIC DISCLOSURESubject: Westinghouse Responses to NRC, "Donald C. Cook Nuclear Plant Unit 1 -Request forAdditional Information on the Application for Amendment to Restore Normal Reactor CoolantSystem Pressure and Temperature Consistent with Previously Licensed Conditions (TAC No.MF2916)," Set #2, SCVB RAI-4f (Proprietary)The proprietary information for which withholding is being requested in the above-referenced report isfurther identified in Affidavit CAW-14-3954 signed by the owner of the proprietary information,Westinghouse Electric Company LLC. The Affidavit, which accompanies this letter, sets forth the basison which the information may be withheld from public disclosure by the Commission and addresses withspecificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission'sregulations.Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Indiana MichiganPower Company.Correspondence with respect to the proprietary aspects of the application for withholding or theWestinghouse Affidavit should reference CAW-14-3 954, and should be addressed to James A. Gresham,Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive,Building 3 Suite 310, Cranberry Township, Pennsylvania 16066.Very truly yours,'James A. Gresham, ManagerRegulatory ComplianceEnclosures CAW-14-3954AFFIDAVITCOMMONWEALTH OF PENNSYLVANIA:ssCOUNTY OF BUTLER:Before me, the undersigned authority, personally appeared James A. Gresham, who, being by meduly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf ofWestinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in thisAffidavit are true and correct to the best of his knowledge, information, and belief:P"imes A. Gresham, ManagerRegulatory ComplianceSworn to and subscribed before methis ý 2 JNgoary of 2 2014Noay[ biCOMMONWEA ,OF NNSM IAF[ NotarhlSealI/ Renee Glampole, Notary Public Il Penn Twp., WestmWeland Countyi My Commiss 2O Expires Sept. 25, 2017MEMJBER, P- NYLVJi -..---OFTWAR[E, 2CAW- 14-3954(1) 1 am Manager, Regulatory Compliance, Westinghouse Electric Company LLC (Westinghouse),and as such, I have been specifically delegated the function of reviewing the proprietaryinformation sought to be withheld from public disclosure in connection with nuclear power plantlicensing and rule making proceedings, and am authorized to apply for its withholding on behalfof Westinghouse.(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of theCommission's regulations and in conjunction with the Westinghouse Application for WithholdingProprietary Information from Public Disclosure accompanying this Affidavit.(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designatinginformation 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 theinformation 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 heldin confidence by Westinghouse.(ii) The information is of a type customarily held in confidence by Westinghouse and notcustomarily disclosed to the public. Westinghouse has a rational basis for determiningthe 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 inconfidence. The application of that system and the substance of that system constituteWestinghouse policy and provide the rational basis required.Under that system, information is held in confidence if it falls in one or more of severaltypes, the release of which might result in the loss of an existing or potential competitiveadvantage, 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 3CAW-14-3954Westinghouse's competitors without license from Westinghouse constitutes acompetitive economic advantage over other companies.(b) It consists of supporting data, including test data, relative to a process (orcomponent, structure, tool, method, etc.), the application of which data secures acompetitive economic advantage, e.g., by optimization or improvedmarketability.(c) Its use by a competitor would reduce his expenditure of resources or improve hiscompetitive position in the design, manufacture, shipment, installation, assuranceof quality, or licensing a similar product.(d) It reveals cost or price information, production capacities, budget levels, orcommercial strategies of Westinghouse, its customers or suppliers.(e) It reveals aspects of past, present, or future Westinghouse or customer fundeddevelopment 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 thefollowing:(a) The use of such information by Westinghouse gives Westinghouse a competitiveadvantage over its competitors. It is, therefore, withheld from disclosure toprotect the Westinghouse competitive position.(b) It is information that is marketable in many ways. The extent to which suchinformation is available to competitors diminishes the Westinghouse ability tosell products and services involving the use of the information.(c) Use by our competitor would put Westinghouse at a competitive disadvantage byreducing his expenditure of resources at our expense.
4CAW-14-3954(d) Each component of proprietary information pertinent to a particular competitiveadvantage is potentially as valuable as the total competitive advantage. Ifcompetitors acquire components of proprietary information, any one componentmay be the key to the entire puzzle, thereby depriving Westinghouse of acompetitive advantage.(e) Unrestricted disclosure would jeopardize the position of prominence ofWestinghouse in the world market, and thereby give a market advantage to thecompetition of those countries.(f) The Westinghouse capacity to invest corporate assets in research and'development depends upon the success in obtaining and maintaining acompetitive advantage.(iv) The information is being transmitted to the Commission in confidence and, under theprovisions of 10 CFR Section 2.390, it is to be received in confidence by theCommission.(v) The information sought to be protected is not available in public sources or availableinformation has not been previously employed in the same original manner or method tothe best of our knowledge and belief.(vi) The proprietary information sought to be withheld in this submittal is that which isappropriately marked in Westinghouse Responses to NRC, "Donald C. Cook NuclearPlant Unit 1 -Request for Additional Information on the Application for Amendment toRestore Normal Reactor Coolant System Pressure and Temperature Consistent withPreviously Licensed Conditions (TAC No. MF2916)" Set #2, SCVB RAI-4f(Proprietary), for submittal to the Commission, being transmitted by Indiana MichiganPower Company letter and Application for Withholding Proprietary Information fromPublic Disclosure, to the Document Control Desk. The proprietary information assubmitted by Westinghouse is that associated with NRC approval of WCAP- 1 7762-NP,and may be used only for that purpose.
5CAW-14-3954(a) This information is part of that which will enable Westinghouse to:(i) Provide input to Indiana Michigan Power Company for input to the U.S.Nuclear Regulatory Commission in response for Additional Informationregarding Restoration of Normal Operating Pressure and NormalOperating Temperature.(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 forthe purpose of obtaining license changes for a Westinghouse pressurizedwater reactor (PWR).(ii) Westinghouse can sell support and defense of the technology to tiscustomer in the licensing process.(iii) The information requested to be withheld reveals the distinguishingaspects of a methodology which was developed by Westinghouse.Public disclosure of this proprietary information is likely to cause substantial harm to thecompetitive position of Westinghouse because it would enhance the ability ofcompetitors to provide similar technical evaluation justifications and licensing defenseservices for commercial power reactors without commensurate expenses. Also, publicdisclosure of the information would enable others to use the information to meet NRCrequirements for licensing documentation without purchasing the right to use theinformation.The development of the technology described in part by the information is the result ofapplying the results of many years of experience in an intensive Westinghouse effort andthe expenditure of a considerable sum of money.
6 CAW-14-3954In order for competitors of Westinghouse to duplicate this information, similar technicalprograms would have to be performed and a significant manpower effort, having therequisite talent and experience, would have to be expended.Further the deponent sayeth not.
PROPRIETARY INFORMATION NOTICETransmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRCin connection with requests for generic and/or plant-specific review and approval.In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning theprotection of proprietary information so submitted to the NRC, the information which is proprietary in theproprietary versions is contained within brackets, and where the proprietary information has been deletedin the non-proprietary versions, only the brackets remain (the information that was contained within thebrackets in the proprietary versions having been deleted). The justification for claiming the informationso 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 beingidentified as proprietary or in the margin opposite such information. These lower case letters refer to thetypes 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 NOTICEThe reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted tomake the number of copies of the information contained in these reports which are necessary for itsinternal 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 publicdisclosure to the extent such information has been identified as proprietary by Westinghouse, copyrightprotection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC ispermitted to make the number of copies beyond those necessary for its internal use which are necessary inorder to have one copy available for public viewing in the appropriate docket files in the public documentroom in Washington, DC and in local public document rooms as may be required by NRC regulations ifthe number of copies submitted is insufficient for this purpose. Copies made by the NRC must includethe copyright notice in all instances and the proprietary notice if the original was identified as proprietary.