ML20087N618

Application for Withholding Proprietary Response to NRC Questions on Setpoint Methodology

ML20087N618
Person / Time
Site:	Wolf Creek, Callaway, 05000000
Issue date:	03/22/1984
From:	Wiesemann R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML19268E741	List: ML20087N618 NRC-84-0050, Forwards Proprietary & Nonproprietary Response to NRC 840309 Questions on Setpoint Methodology.Proprietary Response Withheld (Ref 10CFR2.790).Application for Withholding & Affidavit Encl
References
CAW-84-22, NUDOCS 8404040088
Download: ML20087N618 (16)

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1 sox 355 Westinghouse Water Reactor PittsburghPemsyfvana15230  ;

Electric Corporation Divisions ,

March 22,1984 CAW-84-22 Mr. Harold R. Denton Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Comission Phillips Building 7920 Norfolk Avenue Bethesda, Maryland 20014 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE y e

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SUBJECT:

Response to NRC Questions on Setpoint Methodology for SNUPPS >-

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REF: Att Letter from SNUPPS to NRC (Petrick to Denton), March,1984 U

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Dear Mr. Denton:

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The proprietary material transmitted by the reference letter for which g withholding is being requested by the Standardized Nuclear Unit Power Plant System (SNUPPS) is of the same technical type as that proprietary material previously submitted by Westinghouse concerning Reactor Protection

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System / Engineered Safety Features Actuation System Setpoint Methodology. The W G

previous application for withholding, AW-76-60, was accompanied by an affidavit signed by the owner of the proprietary information, Westinghouse Electric Ccrporation. Further, the affidavit submitted to justify the previous material was approved by the Comission on April 17, 1978, and is equally applicable to the subject material. The subject proprietary material is being submitted by y the Standardized Nuclear Unit Power Plant System (SNUPPS) for theCKansas City Power and Light Company's Wolf Creek (STN 50 482) and the Union Electric -

Company's Callaway (STN 50 483).

8404040088 840323 PDR ADOCK 05000482 A PDR 7

1. Pir. Harold R. D;nton March 22, 1984 j Accordingly, this letter authorizes the utilization by SNUPPS of the previously furnished affidavit. A copy of the affidavit, AW-76-60, dated December 1, 1976, is attached.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference CAW-84-22 and should-be addressed to the undersigned.

Very truly yours, Robert A. Wiesemann, Manager Regulatory & Legislative Affairs

/dr Attachment cc: E. C. Shomaker, Esq.

Office of the Executive Legal Director, NRC 4

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4 All-76-60 AFFIDAVIT-COW 0NWEALTH OF pef;NSYLVANIA:

ss COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally appeared Robert A. Wiesemann, who, being by me duly sworn according to law, de-poses and says that he is authorized'to execute this Affidavit on behalf

of W'estinghouse Electric Corporation (" Westinghouse") and that the aver-ments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief

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- Robert A. Wiesemann, Manager Licensing Programs Sworn to and subscribed before,methis8 day of II/ord d 1976.

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AW-76-60 (1) I am Manager, Licensing Programs, in the Pressurized Water Reactor Systems Division, of Westinghouse Electric Corporation and as such,

.I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public dis-closure in connection with nuclear power plant licensing or rule-making proceedings, and am authorized to apply for its withholding "on behalf of the Westinghouse Water Reactor Divisions.

(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.790 of the Commission's regulations and in con-junction with the Westinghouse application for withholding ac-companying this Affidavit.

(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse Nuclear Energy Systems 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 in-formatio 6 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 field in confidence by Westinghouse.

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AW-7G-60 e

(ii) The information is of a type customarily held in confidence by Westinghouse and no't 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 ap-plication 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 com-petitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.)

where prevention of its use by any of Westinghouse's

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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.

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AW-76-60 (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 cap-acities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future West-inghouse or customer funded development plans and pro-grams of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent pro-tection may be desirable.

(g) It is not the property of Westinghouse, but must be treated as proprietary by Westinghouse according to agreements with the owner.

• 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 com-l petitors. It is,' therefore, withheld from disclosure to protect the Westinghouse competitive position.

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AW-76-60 (b) It is information which is marketable in many ways. e The extent to 'which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.

(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

(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 infor-mation, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

(e) Unrestricted disclosure would jeopardize the pos.ition

' of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition in 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.

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. i (iii) The information ,is being transmitted to the Commission in l

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confidence and, under the provisions of 10 CFR Section 2.790, it is to be received in confidence by the Commission.

(iv) The information is not available in public sources to the best of our knowledge and belief.

(v) The proprietary information sought to be withheld in this sub-mittal is that which is appropriately marked in the attach-mers to Westinghouse letter number NS-CE-1298, Eicheldinger to Stolz, dated December 1,1976, concerning information relating to NRC review of WCAP-0567-P and WCAP-8568 entitled, " Improved Thermal Design Procedure," defining the sensitivity of DNB ratio to various core parameters. The letter and attachment are being submitted in response to the NRC request at the October.29, 1976 NRC/ Westinghouse meeting.

This information enables Westinghouse to:

(a) Justify the Westinghouse design.

(b) Assist its customers to obtain licenses.

(c) Meet warranties. .

(d) Provide greater operational flexibility to customers assuring them of safe and reliable operation.

(e) Justify increased power capability or operating margin for plants while assuring safe and reliable operation.

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• AW-76-60 (f) Optimize reactor design and performance while maintaining a high level of fuel integrity.

Further, the information gained from the improved thermal design procedure is of significant commercial value as follows:

I (a) Westinghouse uses the information to perform and justify analyses which are sold to customers.

(b) Westinghouse sells analysis services based upon the ,

experience gained and the methods developed.

Public disclosure of this information concerning design pro-cedures is likely to cause substantial harm to the competitive position of Westinghouse because competitors could utilize this information to assess and justify their own designs without commensurate expense.

The parametric analyses performed and their evaluation represent a considerable amount of highly qualified development effort.

This work was contingent upon a design method development pro- ,

gram which has been underway during the past two years.

Altogether, a substantial amount of money and effort has been expended by Westinghouse which could only be duplicated by a competitor if he were to invest similar sums of money and pro-vided he had the appropriate talent available.

Further the deponent sayeth not.

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( i Attachment 2

. WESTINGHOUSE RESPONSE TO NRC OUESTIONS ON SETPOINT ME'IHODr1 nnY FOR SNUPPS

1. The methodology utilized in deter 1nining the adequacy of the difference between the nominal trip setpoint in the Technical Specifications and the setpoint assumed in the SNUPPS accident analyses is the same as that utilized for Virgil C. Stamer. '!his methodology was approved by the staff in NUREG-0717, supplement No. 4, dated 8/82.

2. Four protection factions have nominal trip setpoints such that the 955 probability value for the instrument mcertainties could place the trip function within 5% of the top or bottom of the instrumentation calibration range. The functions and closeness to the top or bottom of the range are:

A. Power range Neutron Flux - High Setpoint - [] +a,c from top of instrument range, B. PressurizerWaterLevel-High-[]*** from top of instrument range, C. Steam Generators Water Level - Low-Low - []+a,c from bottom of instrument range, and D. Pressurizer Pressure - Low - SI - []+8'" from bottom of instrument range.

In a continuing effort to monitor protection system operability, Westinghouse has reviewed reported LERs for RPS and ESF trip ftmetions, and when available, plant data on fm etional test results. During this monitoring process, there t

has been no indication that the above trip functions experience any more additional drift than trip ftmetions with setpoints greater than 55 from the top or bottom of the instrtunent span. As part of the calibration procedures, several points across the calibrated instrument range including the 0% and 100%

span values are checked. Inspection of as left/as found data from these checks do not indicate any significant variances from the instrument range intermediate points. In addition, transmitters are purchased such that the upper and lower range limits for the transmitters are greater than the upper and lower range values, (See SAMA Standard PMC 20.1-1973), i.e., the calibrated instrument range is not the design limit for the device. Based on the above, Westinghouse does not believe that ftmetions which have 955 probability setpoints (when including uncertainties using the approved Westinghouse setpoint methodology) within 5% of j the top or bottom of the instrument range will respond any differently than any l

other protection function.

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10. NOT WESTIN

1. ALL VALUES IN PERCENT SP AN.

y 2. AS NOTED IN T ABLE 15.0-4 0F FSAR.

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PL ANT TECHNIC AL SPEC IFIC AT10NS.

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S. NOT USED ]N THE SAFETY AN ALYSIS.

6. AS N O T E D IN F IGURE 15.0 - 1 0 F F S AR . 15. INCLUDE D

7. AS NOTED IN TABLE 2.2-1 NOTE I 0F 16. INC ORE X PL ANT TECHNIC AL SPE C IFIC ATIONS. T ABLE 4.3

8. AS NOTED IN T ABLE 2.2-1 NOTE 3 0F t7. [

PL ANT TECHNIC AL SPEC 1FIC AT 10NS. '

9. NOT NOTED IN T ABLE 15.0-4 0F FSAR BUT USED IN SAFETY AN ALYSIS.

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PROCESS PRI.

PROTECTION CHANNEL [CURC CC til I POWER R ANGE, NEUTRON FLUX - HIGH SETPOINT 2 POWER R ANGE, NEUTRON FLUX - LOW SETP0lNT 3 POWER R ANGE, NEUTRON FLUX -

HIGH POSIT IVE R ATE 4 POWER R ANGE, NEUTRON FLUX - HIGH NE GAT IVE R AT E 5 INTERMEDI ATE R ANGE, NEUTRON FLUX

.-__ L s 3 u A c L NNJiGra- [LLU2 -____-.___ __ ___ _--------_---- --- -------- --- --- -._____ _

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[6MrL=R/ro e Cou OAy N OTE S F OR T ABL E 3 - 16,RE V.O iTINGHOUSE SCOPE.

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D IN [ ]+e.c EXC ORE f(A!) C OMPARISON AS NOTED IN (4.3 -! 0F PL ANT TECHN IC AL SPEC IF IC AT IONS

]+ e.c T ABLE 3 - 16 RE AC T OR PROTEC TION SYSTE M/EN GINEERE D SAFE TY FE ATURES ACTU ATION SYSTEM CHANNEL ERROR ALLOWANCES C ALLAWAY. _ STATION

' = INSTRUMENT R

= SENSOR 6 7_ 8 9 2 3 4 5 TEMPERATURE DRIFT E NVIR ONVE NT AL C AllBR ATION COMPARATOR TEMP

' PR IM ARY C AL IBR AT l0N PRESSURE SE T TIN G EF til ALLOWANCE ACCURACY AC CUR AC Y EFFECTS EFFECTS

$LEVENT til til (1) ACCURACY

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10 11 12 13 14 15 16 17 IE MPER ATURE DRIFT SAFETY STS STS TOTAL CHANNEL MARGly EFFECTS (1) ANALYSIS ALLOWABLE TRIP ALL OWANCE ST AT IST IC AL (1) 111 L IM IT VAL UE SETPOINT (1) AL L OWANC E

...o (21 (3) (3) II) + a.c l.O 118% R TP 112.3% RTP 109% RTP i 1.0 35% RTP 28.3% RTP 25% RTP 2 0.5 151 6.3% RTP 4.0% RTP 3 6.9% P 4 0.5 6.3% R TP 4.0% R TP 4.2 (5) 35.3% R TP 25% RTP 5 5 5 3.0 (5) 1.6 10 1.0gg,g lg

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• OVERTE MPE,R ATURE AT AT C H AN NE L 8 T AVG CHANNEL 9 _

10 PRESSURIZER PRESSURE CHANNEL 11 ffAI) CHANNEL 12 OVERPOWER AT AT C H A N N E t_

13 14 T AVG CHANNEL IS PRESSUR IZER PRE SSURE - LOW, RE AC TOR T R IP 16 PRESSURlZER PRESSURE - HIGH _.

17 PRESSURIZER WATER LEVEL - HIGH 18 L OSS OF FLOW 19 STEAM GE NER ATOR WATER LEVEL - L OW-L OW _ _.

20 U N DE R V OL T AGE - R C P _

21 U N DE R F RE QUE NC Y - RCP 22 C ONTAINMENT PRESSURE - H I GH - l _ _ _ _ _ - . _ _ _ _ _ _

23 PRESSURIZER PRESSURE - L OW.S l ____ _ ___

24 STE AMLINE PRESSURE - LOW 25 CONT AINMENT PRESSURE - HIGH-2 26 C ONTAINMENT PRESSURE - H IGH -3 - - -

27 NEGAT IVE STE AM PRESSURE R ATE - HIGH _ _ _

28 STEAM 3ENER ATOR WATER LEVEL - H IGH - H [GH

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