ML18170A113
| ML18170A113 | |
| Person / Time | |
|---|---|
| Site: | 99902037 |
| Issue date: | 06/14/2018 |
| From: | Schrader K PWR Owners Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| OG-18-142, PWROG-17033-NP, Rev. 1, PWROG-17033-P, Rev. 1, WCAP-13045 | |
| Download: ML18170A113 (12) | |
Text
.. June 14, 2018 OG-18-142 Document Control De sk U.S. Nuclear Regulatory Commi ssion 11555 Rockville Pike Rockville , MD 20852-2738
Subject:
PWR Owners Group Program Management Office 1000 Westinghouse Drive, Suite 380 Cranberry Township, PA 16066 PWROG-1 7033-P and NP , Revi sion 1 Project Number 99902037 Transmittal of PWROG-17033-P
(&NP), Revision 1 2 "Update for Subsequent License Renewal: WCAP-13045, "Compliance to ASME Code Case N-481 of the Primary Loop Pump Casings of Westinghouse Type Nuclear Steam Supply Systems" PA-MSC-1498 The purpose of thi s letter i s to transmit Pre ssurize d Water Reactor Owners Group (PWROG) Topical Report (TR), PWROG-17033-P
(& NP), Revi sion 1, "Up date for Sub seq uent License Renewal: WCAP-13045 , "Compliance to ASME Code Case N-481 of the Primary Loop Pump Casings of Westinghouse Type Nuclear Steam Supply Sy stems" in accordance with the Nuclear Regulatory Commis si on (NRC) TR program for review and acceptance for referencing in regulatory actions (Enclosures 1 and 2). Topical Report Summary ASME Code Case N-48 1 allowed replacing the volumetric examination of primary loop pump casings with a fracture mechanics-based integrity evaluation s upplemented by spec ific visual in s pection s. WCAP-13 045 contains the integrity evaluation that was performed to demon strate compliance with ASME Code Case N-481 for 40 years of operation.
- 1. The NRC has approved seve ral plant license renewal applications for 60 years of operation that utilized the generic fracture mechanics analyses and conclusions m WCAP-13045 as discus sed below: 2. The NRC Safety Evaluation Report for Salem Units 1 and 2 discusses the use of the generic fracture mechanic s analysis in WCAP-13045 to meet the requirements of ASME Code Case N-481 for a 60 year licen se renewal in Section 4.4.4 of the SER. The NRC staff concluded that the generic analysis in WCAP-13 045 is applicable to the Salem design of the RCP casing s. The generic analysis, WCAP-13045 , bounds the plantspec ific analy sis, WCAP-169 57-P, as approved by the s taff in the SER. The analysis was show n to remain valid for extended operation.
A b t./-1 U.S. Nuclear Regulatory Commission OG-18-142 June 14, 2018 Page 2 of 4 3. In the 60 year license renewal NRC Safety Evaluation Report for D.C. Cook Units 1 and 2, NUREG-1831, Section 4.7.2, the NRC staff discusses the use of WCAP-13045 to satisfy the requirements of ASME Code Case N-481 ba sed on a plant-specific analysis, WCAP-13128.
In Section 4.7.2.4 of the SER, the NRC concludes that the time-limited aging analysis (TLAA) regarding ASME Code Case N-481 that was provided is acceptable.
- 4. The 60 year license renewal SER (Section 4.3.2.10) for Diablo Canyon Units 1 and 2 discusses that WCAP-13045 was used to demonstrate compliance with Code Case N-481 based on a plant-specific evaluation, WCAP-13895.
In Section 4.3.2.10.4 of the SER, the NRC concludes that it was shown that the aging of the RCP pump casings will be adequately managed for extended operation. 5. Ba sed on the Sequoyah 60 license renewal SER, the NRC concluded that the plant's LRA did not need to include a TLAA related to Code Case N-481 becau se the licensing basis is per the ASME Code Section XI Edition, which no longer relies on N-481 for ISI (in-service inspection interval) requirements.
Thus, it was not necessary to perform any TLAA analysis for RCP pump casings and N-481, as it does not meet Criterion 4 or 6 in 10 CFR 54.3(a). In s ummary , WCAP-13045 ha s been reviewed by NRC to support 60 year licen se renewal applications for severa l plants that used Code Case N-481 as a basis for their ISI examination programs.
The purpose of this TR is to extend the fracture mechanics integrity evaluation in WCAP-13045 through Subsequent License Renewal (SLR), 80 years of operation through 80 years of operation, and confirm that the evaluation remains applicable for subseq uent license renewal (SLR) periods of operation through this time period. Limits of Applicability WCAP-13045-A i s applicable to all Westinghouse De sign primary loop pump casings. This same applicability is carried over for the TR presented herein. This TR is applicable to all Westinghouse design primary loop pump casings for 80 years of operation.
Intended Application Licensees will reference PWROG-17033-P (&NP) in subsequent license renewal applications to satisfy the requirements of 10 C~. 54.2l(c)(l) for demonstrating the appropriate findings regarding the evaluation of time~limited aging analysis (TLAA) for Westinghouse design primary loop pump casings through the subse quent license renewal period of operation (80 years). Industry Implementation PWROG-17033-P
(&NP) can be implemented by all applicable U. S. PWRs as listed in the Limits of Applicability section above.
r .. U.S. Nuclear Regulatory Commission OG-18-142 June 14, 2018 Page 3 of 4 This TR is being submitted to the NRC for review and approval so that the NRC approved version can be utilized by licensees.
Licensees will reference PWROG-17033-P
(&NP) in a license renewal application to satisfy the requirements of 10 CFR 54.21(c)(l) for demonstrating the appropriate findings regarding the evaluation of time-limited aging analysis (TLAA) for Westinghouse design primary loop pump casings through the subsequent license renewal period of operation (80 years). NRC approval of the generic TR will reduce the impact on both licensee and NRC resources by eliminating the need for the preparation of and NRC review of plant specific justifications for the structural integrity of the Westinghouse RPV s due to underclad cracking.
NRC Review Schedule The PWROG requests that the NRC complete their review of the TR by June 2019. This letter transmits two copies of PWROG-1703 3-P , Revision 1 (Enclosure
- 1) and one copy of PWROG-17033-NP, Revision 1 (Enclosure 2). PWROG-17033-P, Revision 1 (Enclosure
- 1) contains information proprietary to Westinghouse which is supported by an affidavit signed by Westinghouse, owner of the information. The affidavit, CAW-18-4762, s ets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the con s iderations listed in paragraph (b) (4) of Section 2.390 of the Commission's regulations.
The affidavit is included as Enclosure
- 3. Accordingly , it is respectfully requested that this 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 related to this transmittal should be addressed to: Mr. W. Anthony Nowinowski, Program Manager PWR Owners Group , Program Management Office Westinghouse Electric Company 1000 Westinghouse Drive , Suite 386 Cranberry Township, Pennsylvania, 16066 If you have any questions, please do not hesitate to contact me at (805) 545-4328 or Mr. W. Anthony Nowinowski, Program Manager of the PWR Owners Group, Program Management Office at (412) 374-6855.
Sincerely yours, Ken Schrader, Chief Operating Officer and Chairman PWR Owners Group KS:WAN:am Electronicall y Approved Records Are Authenticated in the Electronic Document Management System J U.S. Nuclear Regulatory Commission OG-18-142 June 14, 2018 Page 4 of 4
Enclosures:
- 1. PWROG-17033-P Revision 1 "Update for Subsequent License Renewal: WCAP-13045, "Compliance to ASME Code Ca se N-481 of the Primary Loop Pump Casing s of We s tinghouse Type Nuclear Steam Supply System s" (Proprietary, 2 copies) 2. PWROG-17033-NP Revision 1 "Update for Subsequent Licen se Renewal: WCAP-13045, "Compliance to ASME Code Case N-481 of the Primary Loop Pump Casing s of We s tinghou s e Type Nuclear Steam Supply Systems" (Non-Proprietary, 1 copy) 3. Application of Withholding , CA W-1 8-4 762 cc: PWROG Management Committee PWROG Material s Committee PWROG Steering Committee PWROG Licen sing Committee PWROGPMO B. Benney , US NRC P. Atkin , DOM J. Andrachek, We s tinghou se J. Gre s ham , We sting hou se G. Hall , Westinghou s e E. Shen, We s tinghou s e S. Rigby, We sting hou s e M. Higby, Westinghouse T. Zalew ski, We s tinghou se P. Brusamonti , We s tinghou se J. Whelan , We s tinghouse 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-18-4742 May 7, 2018 APPLICATION FOR WITIIlIOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
PWROG-17034-P, Revision 0 , Change Pages 2-2 and 2-3 (Proprietary)
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-18-4742 signed by the owner of the proprietary information , Westinghouse.
The Affidavit, which accompanies this letter, sets forth the basis on which the information 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 Pressurized Water Reactor Owners Group (PWROG). Correspondence with respect to the proprietary aspects of the Application for Withholding or the Westinghouse Affidavit should reference CA W-18-4 7 42 and should be addressed to James A. Gresham, Consulting Engine e r, Licensing and Regulatory Affairs, Westinghouse Electric Company , 1000 Westinghouse Drive, Building 2 Suite 259 , Cranberry Township, Pennsylvania 16066. James A. Gresham, Consulting Engineer Licensing and Regulatory Affairs © 2018 Westinghouse Electric Company LLC. All Rights Reserved.
CA W-18-4742 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 Aff i davit are true and correct to the best of my knowledge, information, and belief. Executed on: <> ll ( If
- 1G.t1~ James A. Gresham, Consulting Engineer Licensing and Regulatory Affairs 3 CAW-18-4742 (1) I am Consulting Engineer, Licensing and Regulatory Affairs, 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 Nuclear 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-18-4742 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.
(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 pos i tion. (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 invol't i ng 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-18-4742 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. rr* 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 as pages titled "PWROG-17034-P, Revision 0, Change Pages 2-2 and 2-3"(Proprietary), for submittal to the Commission , being transmitted by PWROG Letter OG-18-108 and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with a PWR Owners Group topical report, which
- provides the technical basis for the continued use of the proprietary WCAP-10325-P-A methodology with the original metal material properties. (a) This information is part of that which will enable Westinghouse to obtain NRC review and approval of PWROG-17034 and obtain NRC acceptance for the continued use of the proprietary WCAP-10325-P-A methodology with the original metal material properties. *------~---------*~*-*------
6 CAW-18-4742 (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 calculating LOCA mass and energy releases using the proprietary WCAP-10325-P-A methodology. (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 i nformation. 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 change pages 2-2 and 2-3 for PWROG-17034, fwnished to the NRC in connect i on with requests for PWR Owners Group generic topical-report 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 th e 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 report s 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 , modificat i on , 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 re s pect 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.
Letter for Transmittal to the NRC The following paragraphs should be included in your letter to the NRC Document Control Desk: Enclosed are: 1. PWROG-17034-P, Revision 0, Change Pages 2-2 and 2-3 (Proprietary)
- 2. PWROG-17034-NP, Revision 0, Change Pages 2-2 and 2-3 (Non-Proprietary)
Also enclosed are the Westinghouse Application for Withholding Proprietary Information from Public Disclosure, CAW-18-4742, 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 basis 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 item listed above or the supporting Westinghouse Affidavit should reference CAW-18-4742 and should be addressed to James A. Gresham, Consulting Engineer, Licensing and Regulatory Affairs, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 2 Suite 259, Cranberry Township, Pennsylvania 16066. *!