ULNRC-05100, Transmittal of Inservice Inspection, Summary Report for Refuel 13 and WCAP-16280-P, Flaw Evaluation Handbook for Plant Reactor Vessel Inlet Nozzle Safe-End Weld Region, May 2004
| ML043650441 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 12/13/2004 |
| From: | Keith Young AmerenUE |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| ULNRC-05100 | |
| Download: ML043650441 (13) | |
Text
AmerenUE PO Box 620 Callaway Plant Fulton, MIO 65251 December 13, 2004 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 Ladies and Gentlemen: ULNRC-05 100 WAmeren DOCKET NUMBER 50-483 UNION ELECTRIC COMPANY RE CALLAWAY PLANT TRANSMITTAL OF INSERVICE INSPECTION
SUMMARY
REPORT FOR REFUEL 13, AND WCAP-16280-P, "FLAWNEVALUATION HANDBOOK FOR CALLAWAY UNIT I REACTOR VESSEL INLET NOZZLE SAFE-END WELD REGION, " MAY 2004 Enclosed is the Inservice Inspection (ISI) Summary Report for Refuel 13 (RF-13) at Callaway. The report summarizes ISI activities performed in connection with the refueling outage and/or Cycle 13, and is submitted pursuant to American Society of Mechanical Engineers (ASME) Code Case N-532. Accordingly, the report includes Form OAR-I, "Owner's Activity Report," and attendant information. The report is being submitted in advance of the end of the ongoing inspection period in accordance with a verbal agreement made with the NRC staff during RF-1 3, as further explained below.
During RF- 13 (Spring 2004), non-destructive (ultrasonic) examination of the reactor pressure vessel (RPV) nozzle safe-end welds, using the latest technique qualified per the industry's Performance Demonstration Initiative (PDI), confirmed a small flaw in the safe-end to elbow weld of the RPV 'C' inlet (cold leg) nozzle. The indication was discussed extensively with NRC staff personnel (Office of Nuclear Reactor Regulation and Region IV) during several telephone conferences, including those conducted on May 1, 3, 5 and 14, 2004.
It was noted during the telephone conferences that the indicated flaw had been detected in the last in-service inspection conducted on this area (in 1995) at which time it was characterized as an imbedded indication and evaluated as acceptable per the applicable criteria of the ASME Code (Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," 1989 Edition, No Addenda). The ultrasonic characterization of the flaw, as performed by WesDyne International, LLC during RF-13 was discussed. Additionally, the preliminary results of evaluations by v -11 a subsidiaryofAmeren Corporation
ULNRC-05 100 December 13, 2004 Page 2 Callaway staff and selected contractors, i.e., Westinghouse Electric Company, LLC (Westinghouse); Structural Integrity Associates, Inc., and Dominion Engineering, were thoroughly discussed. The evaluation being performed by Westinghouse to determine the acceptability of the flaw using the procedures and acceptance criteria for indications in austenitic piping pursuant to Paragraph IWB-3640 of ASME Section XI was particularly discussed. It was noted that Westinghouse's evaluation determined the flaw to be well within acceptable limits so that the weld was acceptable for further service without repair. It was also acknowledged during one of the telephone discussions that the documented evaluation method used by Westinghouse, including the evaluation results, would be submitted to the NRC with the RF-13 ISI Summary Report, subsequent to the outage.
Accordingly, AmerenUE is submitting the documented evaluation as an enclosure to this letter (along with the RF-1 3 ISI Summary Report). The enclosed Westinghouse document provides the results of an applied methodology that can be used throughout plant life to evaluate flaws in selected locations (in this case, specifically for the inlet nozzle safe-end to elbow weld region). It thus includes evaluation of the indication identified during RF-13. Note that a proprietary version and a non-proprietary version are provided: WCAP-16280-P, "Flaw Evaluation Handbook for Callaway Unit I Reactor Vessel Inlet Nozzle Safe End Weld Region,"
May 2004 (Proprietary), and WCAP-16280-NP, "Flaw Evaluation Handbook for Callaway Unit 1 Reactor Vessel Inlet Nozzle Safe End Weld Region," May 2004 (Nonproprietary). The non-proprietary version of the report is included within the ISI Summary Report. The proprietary version is provided as a separate enclosure.
In support of the enclosed proprietary version of the Westinghouse report, additional documents are enclosed. One is Westinghouse authorization letter CAW-04-1852, "Application for Withholding Proprietary Information from Public Disclosure," dated June 10, 2004, to which an affidavit prepared by Westinghouse is attached. The affidavit sets forth the basis on which the information provided by Westinghouse may be withheld from public disclosure by the Commission, and it addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations. The remaining enclosed documents are a proprietary information notice and a copyright notice, both provided by Westinghouse.
Consistent with the above, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in Two flaws are evaluated in the attached Westinghouse report, since two indications were actually identified in the subject weld area during Rr-13. One indication, identified as Indication I in the attached report, is a small near-surface flaw that that was immediately determined to be acceptable in accordance with the IWB tables of ASME Section Xl. For completeness, however, Indication I was included for evaluation in the attached report even though it met the Acceptance Standards of IWB-3500 of ASME Section Xl. The second indication, which was the subject of the noted discussions with the NRC during the outage, is identified as Indication 2 in the attached report. This indication required analytical evaluation to determine its acceptability.
ULNRC-05 100 December 13, 2004 Page 3 accordance with 10 CFR 2.390. Questions/correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse affidavit should reference the enclosed Westinghouse letter, CAW-04-1852, 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. Please contact us for any other questions or requests you may have regarding this submittal.
Very truly yours, KMa e RD.o AoungfCl Manager - Regulatory Affairs TBE/jdg
Enclosures:
- 1. Callaway Refuel 13 Inservice Inspection Summary Report
- 2. WCAP-16280-P, "Flaw Evaluation Handbook for Callaway Unit I Reactor Vessel Inlet Nozzle Safe End Weld Region," May 2004 (Proprietary)
- 3. Proprietary Information Notice
- 4. Copyright Notice
- 5. Westinghouse Letter CAW-04-1852, "Application for Withholding Proprietary Information from Public Disclosure," June 10, 2004
ULNRC-05100 December 13, 2004 Page 4 cc: U.S. Nuclear Regulatory Commission (Original and I copy)
Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 Mr. Bruce S. Mallett Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Jack N. Donohew Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 7EI Washington, DC 20555-2738 Missouri Public Service Commission (wv/o)
Governor Office Building 200 Madison Street PO Box 360 Jefferson City, MO 65102-0360
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.
Westinghouse Westinghouse Electric Company Nuclear Services P.O. Box 355 Pittsburgh, Pennsylvania 15230-0355 USA U.S. Nuclear Regulatory Commission Directtel: (412) 374-4643 Document Control Desk Direct fax: (412) 374-4011 Washington, DC 20555-0001 e-mail: greshajagwestinghouse.com Our ref: CAW-04-1852 June 10, 2004 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
WCAP-16280-P, Revision 0, "Flaw Evaluation Ilandbook for Callaway Unit I Reactor Vessel Inlet Nozzle Safe End Weld Region," May 2004 (Proprietary).
The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-04-1852 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 AmerenUE.
Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-04-1852, 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 yo s, J. A. Gresham, Manager Regulatory Compliance and Plant Licensing Enclosures cc: G. Shukla B. Benney E. Peyton A BNFL Group company
CAW 1852 June 10,2004 bcc: J. A. Gresham (ECE 4-7A) IL R. Bastien, IL, IA (Nivelles, Belgium)
C. Brinkman, IL, IA (Westinghouse Electric Co., 12300 Twinbrook Parkway, Suite 330, Rockvillc, MD 20852)
RCPL Administrative Aide (ECE 4-7A) IL, IA (letter and affidavit only)
A BNFL Group company
CAW 1852 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:
J. A. Gresham, Manager Regulatory Compliance and Plant Licensing Sworn to and subscribed before me this A21- day of , 2004 C1t'.4 Notary Public Notarial Seal Margaret L Gonano. Notary Public Monroeville Boro. Allegheny County My Commission Expires Jan. 3,2006 Member. Pennsylvaria Associa on Of Notanes
2 CAW-04-1852 (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
3 CAW-04-1852 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.
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 1852 (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) Unrcstricted 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 Wcstinghouse 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-16280-P, "Flaw Evaluation Ilandbook for Callaway Unit I Reactor Vessel Inlet Nozzle Safe End Weld Region" (Proprietary) dated May 2004, for Callaway Unit 1, being transmitted by AmerenUE 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 Callaway Unit I is expected to be applicable for other licensee submittals in response to certain NRC requirements for justification of the structural integrity of the reactor vessel inlet nozzle safe end weld region for continued operation of Callaway Unit 1.
This information is part of that which will enable Westinghouse to:
5 CAW 152 (a) Assess the risk of operation with indications in the reactor vessel inlet nozzle safe end weld region.
(b) Assist the customer in obtaining NRC approval.
Further this information has substantial commercial value as follows:
(a) Westinghouse plans to sell the use of similar information to its customers for purposes of meeting NRC requirements for licensing documentation.
(b) Westinghouse can sell support and defense of continued operation with indications in the reactor vessel inlet nozzle safe end weld region.
(c) 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 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 tecdnical 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.