ML18114A115

Wolf Creek Nuclear Operating Corp., Supplement to License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term

ML18114A115
Person / Time
Site:	Wolf Creek
Issue date:	04/19/2018
From:	McCoy J H Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ET 18-0012
Download: ML18114A115 (12)

Text

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'NUCLEAR OPERATING CORPORATION April 19, 2018 Jaime H. McCoy Vice President Engineering ET 18-0012 U. S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555

References:

1) Letter ET 17-0001, dated January 17, 2017, from J. H. McCoy, WCNOC, to USNRC

Subject:

2) Letter dated December 4, 2017, from B. K. Singal, USNRC, to A. C. Heflin, WCNOC, "Wolf Creek Generating Station -Request for Additional Information Re: License Amendment Request for Transition to Westinghouse Core Design and Safety Analyses Including Adoption of Alternative Source Term (CAC No. MF9307; EPID L-2017-LLA-0211)

3) Letter WO 18-0004, dated January 15, 2018, from C. 0. Reasoner, WCNOC, to USNRC 4) Letter ET 18-0004, dated January 29, 2018, from J. H. McCoy, WCNOC, to USNRC Docket No. 50-482: Supplement to License Amendment Request to Revise Technical Specifications to Transition to Westinghouse Core Design and Safety Analysis Including Adoption of Alternative Source Term To Whom It May Concern:

Reference 1 provided the Wolf Creek Nuclear Operating Corporation (WCNOC) application to revise the Wolf Creek Generating Station (WCGS) Technical Specifications (TS). The proposed amendment would support transition to the Westinghouse Core Design and Safety Analysis methodologies.

In addition, the amendment request included revising the WCGS licensing basis by adopting the Alternative Source Term radiological analysis methodology in accordance with 10 CFR 50.67, "Accident Source Term." Reference 2 provided a request for additional information related to the application.

References 3 and 4 provided responses to requests for additional information (RAI) related to the application.

P.O. Box 411 / Burlington, KS 66839 / Phone: {620) 364-8831 An Equal Opportunity Employer M/F/HCNET ET 18-0012 Page 2 of 3 On March 19-20, 2018, Westinghouse and WCNOC participated in a technical audit requested by the Nuclear Regulatory Commission (NRG) to resolve questions over the responses provided in References 3 and 4. The audit resolved a portion of the RAI responses, but others required supplemental responses be provided.

This letter contains supplemental responses for the following RAI questions found in Reference 2: ARCB1-FHA-2, ARCB1-SGTR-2, ARCB1-MSLB-2, and ARCB1-WT-3.

The remaining RAI responses will be provided in a separate letter at a later date. The additional information does not expand the scope of the application and does not impact the no significant hazards consideration determination presented in Reference

1. In accordance with 1 O CFR 50.91, "Notice for public comment; State consultation,"

a copy of this submittal is being provided to the designated Kansas State official.

This letter contains no commitments.

If you have any questions concerning this matter, please contact me at (620) 364-4156, or Cynthia R. Hafenstine at (620) 364-4204.

Sincerely, 9~~W'7/ Jaime H. McCoy JHM/rlt

Enclosures:

Attachment 1 to SAP-18-34, "Supplemental 30 Day Responses to Nuclear Regulatory Commission Request for Additional Information Regarding Wolf Creek Generating Station Transition to Westinghouse Safety Analysis and Alternate Source Term Methodologies"

-Non-Proprietary II Attachment 2 to SAP-18-34, "Supplemental 30 Day Responses to Nuclear Regulatory Commission Request for Additional Information Regarding Wolf Creek Generating Station Transition to Westinghouse Safety Analysis and Alternate Source Term Methodologies"

-Proprietary Ill CAW-18-4733, Revision 0, "Application for Withholding Proprietary Information from Public Disclosure,"

April, 2018. cc: K. M. Kennedy (NRG), w/e B. K. Singal (NRG), w/e K. S. Steves (KDHE), w/e (Non-Proprietary only) N. H. Taylor (NRG), w/e Senior Resident Inspector (NRG), w/e ET 18-0012 Page 3 of 3 STATE OF KANSAS ) ) ss COUNTY OF COFFEY ) Jaime H. McCoy, of lawful age, being first duly sworn upon oath says that he is Vice President Engineering of Wolf Creek Nuclear Operating Corporation; that he has read the foregoing document and knows the contents thereof; that he has executed the same for and on behalf of said Corporation with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief. By ___ ...,.......

_________

..,.._ __ Jaime H. cCoy Vice Pr: sident Engineering SUBSCRIBED and sworn to before me this /qt~day of ~n' ( , 2018. GAYLE SHEPHEARD My Appoinbnent Expires July 24, 2019 &µJ Expiration Date __ !_( d-._c./-~f d)_EJ_/ q~-

Enclosure Ill to ET 18-0012 CAW-18-4733, Revision 0, "Application for Withholding Proprietary Information from Public Disclosure,"

April, 2018. (9 pages including this page)

Westinghouse Non-Proprietary Class 3 @ Westinghouse U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Westinghouse Electric Company 1000 Westinghouse Drive Cranberry

Township, Pennsylvania 16066 USA Direct tel: (412) 374-4643 Direct fax: (724) 940-8542 e-mail: greshaja@westinghouse.com CAW-18-4733 April 16, 2018 APPLICATION FOR WITHHOLDING PROPRJETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

SAP-18-34, P-Attachment, "Supplemental 30 Day Responses to Nuclear Regulatory Commission Request for Additional Information Regarding Wolf Creek Generating Station Transition to Westinghouse Safety Analysis and Alternate Source Term Methodologies

[Proprietary],"

April 2018 The Application for Withholding Proprietary Information from Public Disclosure is submitted by Westinghouse Electric Company llC ("Westinghouse"),

pursuant to the provisions of paragraph (b)(l) of Section 2.390 of the Nuclear Regulatory Commission's

("Commission's")

regulations.

It contains commercial strategic information proprietary to Westinghouse and customarily held in confidence.

The proprietary information for which withholding is being requested in the above-referenced report is further-identified in Affidavit CAW-18-4733 signed by the owner of the proprietary information, Westinghouse.

The Affidavit, which accompanies this letter, sets forth the basis on which the infonnation may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CPR Section 2.390 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Wolf Creek Nuclear Generating Station.

Correspondence with respect to the proprietary aspects of the Application for Withholding or the Westinghouse Affidavit should reference CA W-18-4 733, and should be addressed to James A. Gresham,

Manager, Regulatory Compliance, Westinghouse Electric

Company, 1000 Westinghouse Drive, Building 2, Suite 259, Cranberry

Township, Pennsylvania 16066. . ') A~,*,? t1 //[ ') ' . . "-1~.wY * *~ .. ----. If '"/ !/James A. Gresham, Manager Regulatory Compliance

© 2018 Westinghouse Electric Company LLC. All Rights Reserved.

CAW-18-4733 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF BUTLER: I, James A Gresham, am authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse")

and declare that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief. Executed on: 1--1-r~,

be....,.,

f-'-JY_*

--v James A Gresham, Manager Regulatory Compliance 3 CA W-18-4733 (1) I am Manager, Regulatory Compliance, Westinghouse Electric Company LLC ("Westinghouse"),

and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the ~uclear Regulatory Commission's

("Commission's")

regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

(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 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 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 information in confidence.

The application of that system and the substance of that system constitute Westinghouse policy and provide the rational basis required.

Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of 4 CAW-18-4733 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 cir improved marketability).

(c) Its use by a competitor would reduce his expenditure ofresources 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.

(iii) 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 protect the Westinghouse competitive position.

(b) It is information that 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.

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

5 CAW-18-4733 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage.

If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.

(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

(iv) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, is to be received in confidence by the Commission.

(v) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief. (vi) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in SAP-18-34 P-Attacbment, "Supplemental 30 Day Responses to Nuclear Regulatory Commission Request for Additional Information Regarding Wolf Creek Generating Station Transition to Westinghouse Safety Analysis and Alternate Source Term Methodologies

[Proprietary],"

April 2018, for submittal to the Commission, being transmitted by Wolf Creek Nuclear Generating Station letter. The proprietary information as submitted by Westinghouse is that associated with Westinghouse Alternate Source Term analysis and Methodology Transition, and may be used only for that purpose.

(a) This information is part of that which will enable Westinghouse to support Wolf Creek for the Alternate Source Term analysis and Methodology Transition.

6 CAW-18-4733 (b) Further, this information has substantial commercial value as follows:

(i) Westinghouse plans to sell the use of similar information to its customers for the purpose of Alternate Source Term analysis and Methodology Transition.

(ii) Westinghouse can sell support and defense of industry guidelines and acceptance criteria for plant-specific applications.

(iii) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

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.

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 duplicate 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.

Further the deponent sayeth not.

PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and non-proprietary versions of a document, furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.

In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary

versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted).

The justification for claiming the information so 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 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 (4)(ii)(a) through (4)(ii)(f) of the Affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(l).

COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for_ its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment,

transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding.

With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose.

Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

Wolf Creek Nuclear Generation Station Letter for Transmittal to the NRC The following paragraphs should be included in your letter to the NRC Document Control Desk: Enclosed are: 1. SAP-18-34 NP-Attachment, "Supplemental 30 Day Responses to Nuclear Regulatory Commission Request for Additional Information Regarding Wolf Creek Generating Station Transition to Westinghouse Safety Analysis and Alternate Source Term Methodologies

[Non-Proprietary],"

April 2018 2. SAP-18-34 P-Attachment, "Supplemental 30 Day Responses to Nuclear Regulatory Commission Request for Additional Information Regarding Wolf Creek Generating Station Transition to Westinghouse Safety Analysis and Alternate Source Term Methodologies

[Proprietary],"

April 2018 Also enclosed are the Westinghouse Application for Withholding Proprietary Information from Public Disclosure CA W-18-4733, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice. As Item 1 contains information proprietary to Westinghouse Electric Company LLC ("Westinghouse"),

it is supported by an Affidavit signed by Westinghouse, the owner of the information.

The Affidavit sets forth the b'asis on which the information may be withheld from public disclosure by the Nuclear Regulatory Commission

("Commission")

and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations.

Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.

Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse Affidavit should reference CAW-18-4733 and should be addressed to James A. Gresham,

Manager, Regulatory Compliance, Westinghouse Electric

Company, 1000 Westinghouse Drive, Building 2, Suite 259, Cranberry

Township, Pennsylvania 16066.