CNRO-2002-00004, Entergy Operations Inc., Meeting to Discuss Alternate Repair Techniques for Inconel 600

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Entergy Operations Inc., Meeting to Discuss Alternate Repair Techniques for Inconel 600
ML020640175
Person / Time
Site: Arkansas Nuclear  Entergy icon.png
Issue date: 02/15/2002
From: Krupa M
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CNRO-2002-00004
Download: ML020640175 (30)
v • d • e


Text

Entergy Operations, Inc.

Entergy 1340 Echelon Parkway Jackson, MS 39213-8298 Tel 601 368 5758 Michael A. Krupa Director Nuclear Safety &Licensing CNRO-2002-00004 February 15, 2002 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Entergy Operations, Inc.

Meeting to Discuss Alternate Repair Techniques for Inconel 600 Arkansas Nuclear One - Units 1 & 2 Docket Nos. 50-313 & 50-368 License Nos. DPR-51 & NPF-6 Waterford Steam Electric Station - Unit 3 Docket No. 50-382 License No. NPF-38

REFERENCE:

1. Letter CNRO-2002-00001 from Entergy Operations, Inc, to the NRC, "Letter of Intent - Proposed Alternatives to ASME Code Requirements," dated January 16, 2002
2. Letter CNRO-2002-00002 from Entergy Operations, Inc, to the NRC, "Meeting to Discuss Mechanical Nozzle Seal Assembly Design," dated January 17, 2002.

Dear Sir or Madam:

In Reference 1, Entergy Operations, Inc. (Entergy) notified the NRC of our intent to pursue licensing actions associated with review and approval of repair techniques that are alternative methods from those required by ASME Code. To further support communications regarding these actions, we requested a meeting with the appropriate NRC staff representatives to discuss these techniques.

Entergy considered portions of the information to be discussed at the meeting to be proprietary and confidential pursuant to 10 CFR 2.790(a)(4) and 10 CFR 9.17(a)(4).

Therefore, in Reference 2, we provided the proprietary information to the NRC and requested that it be withheld from public disclosure. The meeting was held on January 31, 2002. p,fyrlO

CNRO-2002-00004 Page 2 of 2 As requested by the NRC, this letter transmits the slide presentation presented at the January 31 meeting. This presentation contains information based on the information previously provided to the staff in Reference 2. As such, Entergy requests the proprietary information contained in the presentation be withheld from public disclosure. The affidavit supporting this request is provided in Attachment 1. The slide presentation is provided in with slides marked as proprietary, where appropriate. A redacted version of the presentation is provided in Attachment 3.

If you have any questions or require additional information, please contact Guy Davant at (601) 368-5756.

This letter contains no commitments.

Sincerely, MAK/GHD/baa Attachments:

1. Affidavit
2. Use of Alternate Repair Techniques for Inconel 600 - Proprietary Version
3. Use of Alternate Repair Techniques for Inconel 600 - Redacted Version cc: Mr. C. G. Anderson (ANO) (w/1)

Mr. W. R. Campbell (ECH) (w/l)

Mr. J. K. Thayer (ECH) (w/l)

Mr. J. E. Venable (W3) (w/1)

Mr. T. W. Alexion, NRR Project Manager (ANO-2)

Mr. R. A. Gramm, Section Chief, NRR Licensing Project Directorate IV (w/1)

Mr. E. W. Merschoff, NRC Regional Administrator, Region IV (w/l)

Mr. N. Kalyanam, NRR Project Manager (W3)

Mr. W. D. Reckley, NRR Project Manager (ANO-1)

CNRO-2002-00004 Page 1 of 2 AFFIDAVIT I, Michael A. Krupa, Director, Nuclear Safety and Licensing, of Entergy Operations, Inc.

(Entergy) do hereby affirm and state:

1. Entergy is providing information in support of a request made to the NRC staff. The document being provided in Attachment 2 of this letter ("Use of Alternate Repair Techniques for Inconel 600") contains technical information developed by Entergy and Westinghouse and owned by Entergy regarding the improved Mechanical Nozzle Seal Assembly (MNSA) design. This document contains proprietary commercial information that should be held in confidence by the NRC pursuant to 10 CFR 9.17(a)(4) and the policy reflected in 10 CFR 2.790, because:
i. The information is being held in confidence by Entergy. Because of the substantial investment made to develop this information and its commercial viability, Entergy has not released it to the public.

ii. The information is of a type that is customarily held in confidence by Entergy and not disclosed to the public.

ii.1 The information reveals distinguishing aspects of the improved MNSA design where its use by other companies without license or agreement from Entergy would prevent Entergy from recouping its investment in developing the component.

ii.2 The information contains supporting data relative to the improved MNSA design, the application of which increases Entergy's ability to recoup its investment in developing the component.

ii.3 The use of the information by another company would reduce its expenditure of resources in the design or licensing of a similar product.

iii. The information is being transmitted to the NRC in confidence with the understanding that the NRC will hold the information in confidence while determining if it meets the requirements of 10 CFR 2.790(b)(4). If the NRC determines that the information does not meet the requirements of 10 CFR 2.790(b)(4), the information will be returned to Entergy.

iv. The information is not available in public sources and could not be gathered readily from other publicly available information. The information has been developed by Entergy and Westinghouse and has not been made available to the public by either company.

v. The information sought to be withheld is that which is appropriately marked in Attachment 2. This information is submitted for use by the NRC staff and is expected to be applicable in other license submittals for justification of the use of the improved Mechanical Nozzle Seal Assembly design. The information provided in this document represents a substantial investment, public disclosure of which would reduce Entergy's ability to recoup part or all of that investment.

CNRO-2002-00004 Page 2 of 2

2. Accordingly, Entergy requests that the designated document be withheld from public disclosure pursuant to 10 CFR 2.790(a)(4) and 10 CFR 9.17(a)(4).

I declare under penalty of perjury that the foregoing is true and correct.

Executed on February 15, 2002 Michael A. Krupa

CNRO-2002-00004 Entergy Operations, Inc.

USE OF ALTERNATE REPAIR TECHNIQUES FOR INCONEL 600 Redacted Version

CNRO-2002-00004 Page 1 of 25 USE OF ALTERNATE REPAIR TECHNIQUES FOR INCONEL 600 Entergy Operations, Inc.

I Meeting Agenda

  • Introduction &Purpose

... Discussion of Alternate Repair Methods

  • Use of improved Mechanical Houle Seal Assembly design IMHSA-2)
  • Ambient Temperature Temper-Bead Weld Repair
  • Reactor Head Vent Line Repair S* Closing iiiiii~ii i2

CNRO-2002-00004 Page 2 of 25 Purpose

  • Minimize impact of emergent issues on both EOI and NRC staff during Spring refuel outages.

SIntroduce and discuss the MNSA-2 design.

  • +*Provide information to expedite NRC staff review of EOI relief requests.

3 Inconel 600 Contingencies ii*Reactor Vessel 40.... CRUM

  • Reactor Head Vent
  • Pressurizer
  • Vents
  • Instrument Taps 4

CNRO-2002-00004 Page 3 of 25 SPotential Repairs Requirin!

g Relief ii'*...:*Reactor Vessel

.- V - CRUM Ambient temperature temper-bead repair

- Alternative NDE for CRUM tube repair Reactor Head Vent Nozzle

- IDpartial nozzle repair

- NDE of corner weld

>:*Pressurizer

  • Use of MNSA-2 5

Schedule

+ Based on history

- Installed 3 MNSAs during Waterford 3 RF09.

- Approximately 20-day evolution from discovery to approval

  • Waterford 3 RF11 scheduled for 22 days
  • ANO-2 RF15 scheduled for 20 days 6

CNRO-2002-00004 Page 4 of 25 Improved Design of the Mechanical Nozzle Seal Assembly 7

Locations

- Small-bere pressurizer nozzles
  • ANO 90 locations

- Waterlord 3- 33 locations B

CNRO-2002-00004 Page 5 of 25 First Generation I INSA Basic Design

4. Grafoil seats against -T%, 01,,15 nozzle 0D and vessel CO;Opsks,,Oe 54,,

(Sr 5.

4 bolts load 0S t'2 E Is

+ PSI

.. ./......

x / 3o1(is II compression ring LOIS54.,eg slOe.

05255

"\X

    • Belleville washers Tie rods prevent election if loss of weld 9

Why Develop an Alternative Design?

+.*

Weld repairs

  • Core offload required (for heater and hot leg)
  • Difficult to make and keep alignment
  • High dose
  • 5 to 7 days to repair
  • Cost 10

CNRO-2002-00004 Page 6 of 25

  • Why Develop an Alternative DesignO MNSA Repair

- Will notwork if corrosion/erosion on base material

- As-built dimensions required

- Heater locations: parts not machined and shipped to site until after leak discovered (potential outage delay)

Iif primary seal leaks potential corrosion/erosion to base material Iif Seal Leaks complete seal replacement required (hard bolted]

  • Independent designs for each location 11 Desired Parameters for a New MNSA Design ENTERGY OPERATIONS, INC. - PROPRIETARY INFORMATION

CNRO-2002-00004 Page 7 of 25 MNSA-2 Design Features ENTERGY OPERATIONS, INC. - PROPRIETARY INFORMATION ENTERGY OPERATIONS, INC. - PROPRIETARY INFORMATION

CNRO-2002-00004 Page 8 of 25 MNSA-2 RTD ENTERGY OPERATIONS, INC. - PROPRIETARY INFORMATION MNSA-2 RTD ENTERGY OPERATIONS, INC. - PROPRIETARY INFORMATION

CNRO-2002-00004 Page 9 of 25 L

7 (Q,Q)j 777----4 2

'2

.2 y$Q2.Y)

.5.22222.

MNSA Heater Design 17 Similarities Between MNSA and MNSA-2

  • ,*4-bolt pattern

+ Grafoil primary seal

+ Same materials

. Same bolt torque values or less

  • Seal seats on 00 of nozzle

+ Analyzed to ASME NB 3200

-
. Prototype tested 18

CNRO-2002-00004 Page 10 of 25 Differences BetwiDen MNSA and MNSA-2 S~MNSA

  • Seal retained using collar and 00 of vessel
  • Difficult to machine for each location
  • Vessel surface isnot smooth for seating
  • Seal volume dependent on location Hard bolted ENTERGY OPERATIONS, INC .- PROPRIETARY INFORMATION 19

' Differences Betwieen MNSA and MNSA-2 MNSA

    • '* No channel path in case a leak Sof

>*

  • Potential for erosion of base material
    • Individual design for each location
  • As-built dimensions required

- Geometry dependent ENTERGY OPERATIONS, INC. - PROPRIETARY INFORMATION 20

CNRO-2002-00004 Page 11 of 25 F

Analysis of MNSA-2 Locations 21 MNSA-2 Stud Connection to Pressurizer

+-* Maximum allowable load i.: Evaluation of installation tol ENTERGY OPERATIONS, INC. - PROPRIETARY INFORMATION 22

CNRO-2002-00004 Page 12 of 25 Reinforcement Area Evaluation

+.Heater Sleeves (innermost and outermost locations)

Side Shell Instrument Nozzle

+ Lower Level Instrument Nozzle 23 Structural Evaluation of Attachment Locations on Pressurizer

+Heater Sleeves [outermost location) a P.In2-qiRni annalin' mathad

ENTERGY OPERATIONS, INC. - PROPRIETARY INFORMATION 24

CNRO-2002-00004 Page 13 of 25 Structural Evaluation of Attachment Locations on Pressurizer Side Shell and Lower Level Instrument

  • +.

Nozzles

  • Classical analvsis

- Classical analysis method ENTERGY OPERATIONS, INC. - PROPRIETARY INFORMATION 25 Fatigue Evaluations of Attachment Locations

+*.Heater Sleeves (outermost location]

ENTERGY OPERATIONS, INC. - PROPRIETARY INFORMATION 26

CNRO-2002-00004 Page 14 of 25 Fatigue Evaluations of Attachment Locations

+,Heater Sleeves (contd)

ENTERGY OPERATIONS, INC. - PROPRIETARY INFORMATION 27 Fatigue Evaluations of Attachment Locations

+:*

Side Shell and Lower Level Instrument Nozzles 9 Same scope as outlined for heater sleeves.

28

CNRO-2002-00004 Page 15 of 25 ENTERGY OPERATIONS, INC. - PROPRIETARY INFORMATION 2-1 FEA for Steady State and Transient Thermal Analyses, Pressurizer Shell and MNSA-2 Temperature Distribution during Operations ENTERGY OPERATIONS, INC. - PROPRIETARY INFORMATION

CNRO-2002-00004 Page 16 of 25 Steady State and Transient Thermal Analysis Results at the Counterhore Region ENTERGY OPERATIONS, INC. - PROPRIETARY INFORMATION MNSA-2 Connection to Side Shell and Lower Level Nozzles and Heater Sleeve ENTERGY OPERATIONS, INC. - PROPRIETARY INFORMATION 32

CNRO-2002-00004 Page 17 of 25 MNSA-2 Connection to Side Shell and Lower Level Nozzles and Heater Sleeve

.i,Connection to heater sleeve

  • Determine allowable load based on heaterlsleeve weld shear.
  • Determine maximum bearing load
  • Determine allowable load on sleeve/pressurizer i-weld shear.
  • Compare with maximum operating and impact loads.

L 33 MNSA-2 Loading Conditions

+.*Internal pressure

"*,.Loads due to operating temperature and plant heatup/cooldown

  • Installation pre-load as affected hy heatup/cooldown Impact load due to "sudden ejection" of

"*+.

nozzle/heaters 34

CNRO-2002-00004 Page 18 of 25 MNSA-2 Components Attachment

"*-* threaded rods to pressurizer shell

"*Tie rods for preventing nozzle ejection

"*Compression collar

  • Flanges, impact plate, clamps, and bolts ENTERGY OPERATIONS, INC. -PROPRIETARY INFORMATION 35 i Analysis per ASME III Code, 1989 Evaluate operating S: loads both prior to and post nozzlelheater election

-erform heat transfer (both classical and FEA P

methods] to determine MNSA-2 temperature profiles Compute maximum load in MNSA-2 resulting from ejection considering thermal growth effects 36

CNRO-2002-00004 "Attachment3 Page 19 of 25 Analysis per ASME Ill Code, 1989

"*÷* Determine installation pre-loads for fasteners and changes due to heatup/cooldown

"*:*Determine seismic loads on MNSA-2 Compute design, average, maximum, and shear stresses and compare with Code allowables.

37 Analysis per ASME III Code, 1989

      • Determine fatigue usage factor for 700 heatup/cooldown cycles.

+÷, Provide input loads for pressurizer attachment evaluations.

38

CNRO-2002-00004 Page 20 of 25 Analysis per ASME Ill Code, 1989 Component stresses meet ASME Code criteria.

  • Pressurizer attachment stresses meet ASME Code criteria.
  • .2-0 thermal analysis and 3-0 FEA analysis result in loads/stresses that are consistent with those used based on classical analysis methods.

39 Qualification Tests

  • 0.

-- Hydrostatic Test

. Perlorm hydrostatic test on MNSA-2 in accordance with ASME Code to demonstrate "zero" leakage.

  • Thermal Cycle Test
  • Planned 3 heat-up/cool-down cycles ENTERGY OPERATIONS, INC. - PROPRIETARY INFORMATION 40

CNRO-2002-00004 Page 21 of 25 Qualification Tests Seismic Test

+?*

  • Determine enveloping seismic criteria for pressurizer locaUons.
  • Verify rigid response of Waterford-3 heater sleeve design (selected as most critical design).
  • Perform seismic qualification test on MNSA-2 while pressurized to 3,000 psig.

41 Qualification Tests MNSA-2 will he qualified to the same

+?*

criteria as original MNSA.

+.*

Hydrostatic test and seismic test already successfully completed.

+ Thermal cycling inprogress. Results expected by 2/15/02.

42

CNRO-2002-00004 Page 22 of 25 MNSA-2 Request

+ System 0 RCs

+ Components

, Will identify specific nozzle locations

  • Section XI Applicability
  • Will identify year/addenda for each site 43 MNSA-2 Request
  • Code requirements for which relief is requested
  • Identify applicable industry information
  • Basis for Relief

"* Industry/inconel history

"* General application and description of the MNSA-2 design and materials

"*MNSA-2 unalification testing

"*Modification to the RCS pressure boundary 44

CNRO-2002-00004 Page 23 of 25 MNSA-2 Request Ambient Temperature Temper Bead Request Contingency for temper bead welding

".-,Information comparable to contents of Code Case N-638

" Similar to other relief request previously docketed 46

CNRO-2002-00004 Page 24 of 25 CRUM Tube NOE Request Alternative to NOE requirements contingency

"*ASME NB-2500 requires repair cavities, the lesser of 3/8" or 10% t to be radiographed

"*CHIM configuration does not permit radiography Alternative NOE may require surface inspection and ultrasonics 47 Reactor Head Vent Nozzle Request

  • -*IDpartial nozzle repair contingency

... NOE of corner weld vs. NOE for full or partial penetration weld 48

CNRO-2002-00004 Page 25 of 25 Relief Request Schedules

+ MNSA-2

- Waterford 3

- E0I submittal - 2128/02

- NRC approval - 3122/02

  • ANO-2

- E0i submittal - 3/20/02

- NRC approval- 4/12/02 49 Relief Request Schedules

  • Ambient Temperature Temper Bead

"*E0I submittals- 3/8102

"*NRC approvals- 3122/02

+.; CRUM Tube NOE

"*E01 submittals -2/25/02

"*NBC approvals -3/22/02

  • Vent Nozzle

"*E0I submittals - - 311102

"*NRC approvals -3/22/02 50

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