ML042860138

R. E. Ginna - Fracture Mechanics Analysis Per GDC-4

ML042860138
Person / Time
Site:	Ginna
Issue date:	09/30/2004
From:	Widay J Constellation Energy Group
To:	Clark R Document Control Desk, Office of Nuclear Reactor Regulation
References
CAW-04-1886, WCAP-16311-NP, Rev 0, WCAP-16311-P, Rev 2
Download: ML042860138 (14)

Text

Joseph A. Widay 1503 Lake Road Plant Manager Ontario, NewYork 14519-9364 585.771.3000

.^Constellation Energy R.E. Ginna Nuclear Power Plant, LLC September 30, 2004 Mr. Robert L. Clark Office of Nuclear Regulatory Regulation U.S. Nuclear Regulatory Commission Attn:

Document Control Desk Washington, D.C. 20555-0001

Subject:

Fracture Mechanics Analysis per GDC-4 R.E. Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Clark:

Ginna is planning to submit a power uprate License Amendment Request to the NRC in June 2005. As part of this uprate, new calculations and evaluations are being performed by our contractors regarding the dynamic effects of postulated high energy line breaks in containment.

In accordance with 10 CFR 50, Appendix A, General Design Criterion 4, "Environmental and Dynamic Effects Design Bases", we have performed analyses to demonstrate that the probability of fluid system piping rupture for certain lines attached to the Reactor Coolant System is extremely low under conditions consistent with the design basis for the piping.

The following documents are enclosed with this transmittal letter

1.

Five (5) copies of WCAP-1 6311 -P, Revision 0, 'Technical Justification for Eliminating Pressurizer Surge Line Rupture as the Structural Design Basis for the R.E. Ginna Nuclear Power Plant, "August 2004 (Proprietary)

2.

Westinghouse authorization letter CAW-04-1886 with accompanying affidavit, Proprietary Information Notice, and Copyright Notice. The affidavit 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 Section 2.390 of the Commission's regulations.

3.

Five (5) copies of WCAP-1631 1-NP, Revision 0, 'Technical Justification for Eliminating Pressurizer Surge Line Rupture as the Structural Design Basis for the R.E. Ginna Nuclear Power Plant, "August 2004" (Non-proprietary) 100 1137

4.

Five (5) copies of Structural Integrity Associates Report SIR-99-036, "Leak-Before-Break Evaluation of Portions of the Accumulator A and B Piping at R.E.

Ginna Nuclear Power Station, June 1999.

Based on the information provided in the affidavit, 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.

Because the results of this analysis will be used to formulate our Power Uprate submittal scheduled for June 2005, we request NRC approval of the documents by the end of May 2005.

Very truly yours, J step A. Widay STATE OF NEW YORK

TO WIT:

COUNTY OF WAYNE I, Joseph A. Widay, being duly swom, state that I am Vice President - R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC), and that I am duly authorized to execute and file this response on behalf of Ginna LLC. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other Ginna LLC employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to be reliable.

Subscribed and sworn before me, a Notary Pubic in and for the State of New York and County of A /OeAK

, this BO day of

, 2004.

WITNESS my Hand and Notarial Seal:

)i'ACA-/e,'Z5' 2

is Notary Public My Commission Expires:

/Ii 6,'

MICHALENE A{ BUNTS Date Notary Public, State of Now York Registration No. 01 BUG01 8576 Monroe County Enclosures Commission Expires Jan 1/', X-'

cc:

J. A. Gresham, Manager Regulatory Compliance and Plant Licensing Westinghouse Electric Company, LLC P.O. Box 355 Pittsburgh, PA 15230-0355 Mr. Robert L. Clark (Mail Stop 0-8-C2)

Project Directorate I Division of Licensing Project Management Office of Nuclear Regulatory Regulation U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 U.S. NRC Ginna Senior Resident Inspector Mr. Peter R. Smith New York State Energy, Research, and Development Authority Corporate Plaza West 286 Washington Avenue Extension Albany, NY 12203-6399 Mr. Paul Eddy NYS Department of Public Service 3 Empire State Plaza, 10th Floor Albany, NY 12223 James M. Petro Jr.

Counsel, Generation - Nuclear Constellation Energy 750 East Pratt Street, 17th Floor Baltimore, MD 21202

Westinghouse Westinghouse Electric Company Nuclear Services P.O. Box 355 Pittsburgh. Pennsylvania 15230-0355 USA Mr. Mark Finley Constellation Generation Group R. E. Ginna Station 1503 Lake Road Ontario, NY 14519 Direct tel:

Direct fax:

e-mail:

Purchase Order Sales order:

Our ref:

860-731-1606 860-731-1674 & 1675 douglas.h.warren@us.westinghouse.com 5000007250 25720 RGE-0444 August 26, 2004 CONSTELLATION GENERATION GROUP R.-E. GINNA PLANT Affidavit for Withholding Proprietarv Information (CA W-04-1886) for WCAP-16311-P. Revision 0

References:

1. WCAP-1631 1-P, Revision 0, 'Technical Justification for Eliminating Pressurizer Surge Line Rupture as the Structural Design Basis for the R. E. Ginna Nuclear Power Plant," August 2004.

2. WCAP-163 1 1-NP, Revision 0, "Technical Justification for Eliminating Pressurizer Surge Line Rupture as the Structural Design Basis for the R. E. Ginna Nuclear Power Plant," August 2004.

Dear Mr. Finley:

This letter transmits the necessary information that can be used by Constellation Generation Group for a submittal of Westinghouse proprietary information included in the pressurizer surge line evaluation for R. E.

Ginna (References 1 and 2). The following documents are attached for your use in preparing the NRC submittals (Attachment 1):

1.

Information that should be included in your transmittal letter.

2.

Proprietary Information Notice to be attached to your NRC transmittal letter.

3.

Copyright Notice to be attached to your NRC transmittal letter

4.

Westinghouse letter "Application for Withholding Proprietary Information from Public Disclosure" (CAW-04-1886) with Affidavit CAW-04-1886.

Please transmit the original of Item 4 to the NRC with your transmittal. This effort was performed under Purchase Order Number 5000007250. If there are any questions, please contact Mr. Dave Sklarsky (412-374-4765) or me (860-731-1606).

Very truly yours, Douglas H. Warren Customer Projects Manager cc:

Al Butcavage Jim Dunne George Wrobel Avelino Rochino

- CGG (Ginna Site)

- CGG (Ginna Site)

- CGG (Ginna Site)

- CGG (Ginna Site)

A BNFL Group company

Direct tel:

U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Directfax: (412)374-4011 Washington, DC 20555-0001 e-mail: greshaja@westinghouse.com Ourref: CAW-04-1886 August 26, 2004 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

WCAP-16311 -P. Revision 0, 'Technical Justification for Eliminating Pressurizer Surge Line Rupture as the Structural Design Basis for the R. E. Ginna Nuclear Power Plant," August 2004.

(Proprietary)

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-04-1886 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. 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 CFR Section 2.390 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Constellation Generation Group.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-04-1886, and should be addressed to J. A. Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.

Very truly yours,

.A. Gresham, Manager Regulatory Compliance and Plant Licensing Enclosures cc:

W. Macon E. Peyton A BNFL Group company

CAW 1886 bcc: J. A. Gresham (ECE 4-7A) IL R. Bastien, IL (Nivelles, Belgium)

C. Brinkman, IL (Westinghouse Electric Co., 12300 Twinbrook Parkway, Suite 330, Rockville, MID 20852)

RCPL Administrative Aide (ECE 4-7A) IL, IA (letter and affidavit only)

A BNFL Group company

CAW-04-I 886 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally appeared J. A. Gresham, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:

A. Gresham, Manager Regulatory Compliance and Plant Licensing Sworn to and subscribed before me this =

I day of 2004 Notary Public Nota Sew Shamn L Rod, Notaly Putbl MonoeveBoAenyC My Counbion Ex#res Janay 29,2007 Meuber Pemnwarva Assod OfNoaes

2 CAW 1886 (1)

I am Manager, Regulatory Compliance and Plant Licensing, in Nuclear Services, 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) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse "Application for Withholding" 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 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 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

3 CAW 1886 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.

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.

4 CAW 1886 (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.

(iii)

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

(iv)

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.

(v)

The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP-1631 1-P, Revision 0, "Technical Justification for Eliminating Pressurizer Surge Line Rupture'as the Structural Design Basis for the R. E.

Ginna Nuclear Power Plant," August 2004 (Proprietary) being transmitted by the Constellation Generation Group letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted for use by Westinghouse for R. E. Ginna is expected to be applicable for other licensee submittals in response to certain NRC requirements for justification of Leak Before Break (LBB) application.

This information is part of that which will enable Westinghouse to:

(a) Provide documentation of the actual margins relative to flaw size.

5 CAW 1886 (b) Provide the application of the methodology to determine LBB margins.

(c) Assist the customer in obtaining NRC approval by responding to NRC questions.

Further this information has substantial commercial value as follows:

(a)

The information reveals the distinguishing aspects of a method; prevention of its use by any 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 process, 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.

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 support documentation 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/or non-proprietary versions of documents 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)(1).

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.

Page 3 Our ref: CAW-04-1886 August 26,2004 Constellation Generation Group Letter for Transmittal to the NRC The following paragraphs should be included in your letter to the NRC:

Enclosed are:

1. 10 copies of WCAP-1631 1-P, Revision 0, 'Technical Justification for Eliminating Pressurizer Surge Line Rupture as the Structural Design Basis for the R. E. Ginna Nuclear Power Plant," August 2004 (Proprietary)

2.

10 copies of WCAP-1631 I-NP, Revision 0, "Technical Justification for Eliminating Pressurizer Surge Line Rupture as the Structural Design Basis for the R. E. Ginna Nuclear Power Plant," August 2004 (Non-Proprietary)

Also enclosed is Westinghouse authorization letter CAW-04-1886 with accompanying affidavit, Proprietary Information Notice, and Copyright Notice.

As Item I contains information proprietary to Westinghouse Electric Company LLC, 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 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-04-1886 and should be addressed to J. A. Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.

Official Record Electronically Approved in EDMS 2000 A BNFL Group company