ML24289A237

Transmittal of Revision 1 Additional Errata Pages for WCAP-18830-P (Proprietary) and WCAP-18830-NP (Non-Proprietary), Turkey Point Fuel Storage Criticality Analysis for 24 Month Cycles

ML24289A237
Person / Time
Site:	Turkey Point, Westinghouse
Issue date:	10/15/2024
From:	Ewing J Westinghouse
To:	Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML24289A236	List: ML24289A237 ML24289A239
References
LTR-NRC-24-39
Download: ML24289A237 (1)

Text

Westinghouse Non-Proprietary Class 3 LTR-NRC-24-39 Page 1 of 2

U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4318 Document Control Desk e-mail: jerrod.ewing@westinghouse.com 11555 Rockville Pike Rockville, MD 20852 LTR-NRC-24-39

October 15, 2024

Subject:

Transmittal of Revision 1 Additional Errata Pages for WCAP-18830-P (Proprietary) and WCAP-18830-NP (Non-Proprietary), Turkey Point Fuel Storage Criticality Analysis for 24 Month Cycles

References:

1. Westinghouse to NRC, Transmittal of WCAP-18830-P/NP Turkey Point Fuel Storage Criticality Analysis for 24 Month Cycles to Support a License Amendment Request from FPL - License Amendment Request 277 Updated Spent Fuel Pool Criticality Analysis, September 22, 2023. (ADAMS Accession No. ML23265A548)

2. Florida Power & Light letter L-2023-077, License Amendment Request 277, Updated Spent Fuel Pool Criticality Analysis, October 12, 2023. (ADAMS Accessi on No.

ML23285A035)

3. Transmittal of Errata Pages for WCAP-18830-P (Proprietary) and WCAP-18830-NP (Non-Proprietary), Turkey Point Fuel Storage Criticality Analysis for 24 Mont h Cycles, June 21st, 2024 (ML24176A192)

3. Transmittal of Additional Errata Pages for WCAP-18830-P (Proprietary) and WCAP-18830-NP (Non-Proprietary), Turkey Point Fuel Storage Criticality Analysis for 24 Month Cycles, September 18 th, 2024 (ML24262A226)

4. Florida Power & Light letter L-2024-151, Respons e to Request for Additional Information Regarding License Amendment Request 277, Updated Spent Fuel Pool Criticality Analysis, September 24, 2024. (ML24268A286)

Enclosed is Errata pages 4-30, 5-29 and B-6 for both WCAP-18830-P (Enclosure 1) and WCAP-18830-NP (Enclosure 2), Turkey Point Fuel Storage Criticality Analysis for 24 Month Cycles (Reference 1).

This revision was identified while updating the proposed UFSAR changes associated with Reference 4.

Specifically, Table 5-33 in Section 5.7.2 of Reference 1 has the following footnote: *Includes administrative margin (0.005¨ k). Results for the Region I and Region II for one specific analysis did not account for this administrative margin. This was corrected to account for administrative margin as follows: For the Region I specific analysis, 0.005 k administrative margin was added. For Region II, specific borated biases and uncertainties were calculated and a final administrative margin for the Region II specific analysis was set to 0.0025 k.

No changes are needed to Reference 2 or 4 because of this revision.

This submittal contains proprietary information of Westinghouse. In conformance with the requirements of 10 CFR Section 2.390, as amended, of the Nuclear Regulatory Commissions (Commissions) regulations, we are enclosing with this submittal an Affidavit (Enclosure 3). The Affidavit sets forth the

• • • This record was final approved on 10/15/2024 16:22:10. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 LTR-NRC-24-39 Page 2 of 2

basis on which the information identified as proprietary may be withheld from public disclosure by the Commission.

Correspondence with respect to the proprietary aspects of this submittal or the Westinghouse Affidavit should reference AW-24-066 and should be addressed to Zachary S. Harper, Consulting Engineer, Licensing, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 1, Cranberry Township, PA 16066.

Jerrod Ewing, Manager Licensing Engineering

cc: Ekaterina Lenning Michael Mahoney

Enclosures:

(1) Errata Pages for WCAP-18830-P (Proprietary)

(2) Errata Pages for WCAP-18830-NP (Non-Proprietary)

(3) Affidavit

• • • This record was final approved on 10/15/2024 16:22:10. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 LTR-NRC-24-39 Enclosure 3

Enclosure 3

Affidavit

October 2024

AW-24-066

(4 pages including this cover page)

Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, PA 16066

© 2024 Westinghouse Electric Company LLC All Rights Reserved

• • • This record was final approved on 10/15/2024 16:22:10. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 AFFIDAVIT AW-24-066 Page 1 of 3

Commonwealth of Pennsylvania:

County of Butler:

(1) I, Zachary Harper, Consulting Engineer, Licensing, have been specifically delegated and authorized to apply for withholding and execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse).

(2) I am requesting the proprietary portions of LTR-NRC-24-39, Revision 0 Enclosure 1 be withheld from public disclosure under 10 CFR 2.390.

(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged, or as confidential commercial or financial information.

(4) Pursuant to 10 CFR 2.390, 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 and is not customarily disclosed to the public.

(ii) The information sought to be withheld is being transmitted to the Commission in confidence and, to Westinghouses knowledge, is not available in public sources.

(iii) Westinghouse notes that a showing of substantial harm is no longer an applicable criterion for analyzing whether a document should be withheld from public disclosure. Nevertheless, public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

• • • This record was final approved on 10/10/2024 09:27:47. *** This record was final approved on 10/15/2024 16:22:10. ((This statement was added bThis statement was added byy the PRIME s the PRIME syystem upon its validationstem upon its validation))

Westinghouse Non-Proprietary Class 3 AFFIDAVIT AW-24-066 Page 2 of 3

(5) Westinghouse has policies in place to identify proprietary information. Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage (e.g., by optimization or improved marketability).

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

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

(6) The attached documents are bracketed and marked to indicate the bases for withholding. The justification for withholding is indicated in both versions by means of lower-case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower-case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (5)(a) through (f) of this Affidavit.

• • • This record was final approved on 10/10/2024 09:27:47. *** This record was final approved on 10/15/2024 16:22:10. ((This statement was added bThis statement was added byy the PRIME s the PRIME syystem upon its validationstem upon its validation))

Westinghouse Non-Proprietary Class 3 AFFIDAVIT AW-24-066 Page 3 of 3

I declare that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief. I declare under penalty of perjury that the foregoing is true and correct.

Executed on: 10/8/2024 Signed electronically by Zachary Harper

• • • This record was final approved on 10/10/2024 09:27:47. *** This record was final approved on 10/15/2024 16:22:10. ((This statement was added bThis statement was added byy the PRIME s the PRIME syystem upon its validationstem upon its validation))