ML060610585

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GE Non-Proprietary Report, GE-NE-0000-0050-5900NP, Revision 0, Comparative Evaluation of the Monticello Core Plate Rim Hold-Down Bolts and BWRVIP-25, Appendix a Analysis.
ML060610585
Person / Time
Site: Monticello Xcel Energy icon.png
Issue date: 02/28/2006
From: Chan J, Desai D, Krishnamachari S, Mahadevan A
General Electric Co
To:
Office of Nuclear Reactor Regulation
References
DRF 0000-0050-5899 GE-NE-0000-0050-5900NP, Rev 0
Download: ML060610585 (29)


Text

ENCLOSURE 2 GE Non-Proprietary Report GE-NE-ODOOO-0050-5900NP, Revision 0, "Comparative Evaluation of the Monticello Core Plate Rim Hold-Down Bolts and B'WRVIP-25, Appendix A Analysis 13 Pages Follow

S GE Energy, Nuclear 6705 Vallecitos Road Sunol, CA 94586 GE-NE-0000-0050-590ONP Revision 0 DRF 0000-0050-5899 Class I February 2006 Monticello Nuclear Power Station L.icense Renewal Project Comparative Evaluation of the Monticello Core Plate Rim Hold-Down Bolts and BWRVIP-25, Appendix A Analysis Prepared By:

S.I. Krishnamachari Verified By:

James K Chan Reviewed By. /

Dilip R.Desai Approved By.

A.Mahadevan i

GE-N.-O000-0050-5900NP Rev 0 Non-Proprietary Information TABLE! OF CONTENTS 1.0 Introduction . ......... 3 2 Scope. ..

I0 . .... .... -............................................ ............................

.....,,...3 2.1 S op je.... ... .. ..... ...... .............. ..... ......................... _3 2.1. .. ......... . .3 .bject....

3.0 Calculations .... ... 4 3.1. Assumptions. ........... ......... ....... ..........

3.2. Calculation Approach .......... ... ... . ...... ........................................ 4 3.3. Comparison of RWRVIP-25 and MiNGP Core Plates ... _. .. . ......-..........

5 3.4. Applicable Loads . ...... ..................

.. . 5 3.5. Calculation of Axial and Bending Stiffnesses of the MNGP Core Plate Bolts .. 6 3.6. Axial Loads and Membrane (Pm) Stresses in the Core Plate Bolts......... .................. 7 3.7. Bending Stresses in the Bolts due to Lateral Loads - Scenarios 1and 3. .7 3.8. Bending Stresses in the Bolts Due to Bowing of the Core Plate........... . ........... 8 3.9. Bending stresses in the Bolts due to Core Plate Bowing .............. .....

3.10. Scenario 2 - Shear Stress in the Aligner Pins .................... ................ 10 3.11. Summaryn.sul....

of .. ....

... ....... .. 11 4.0 nc s................... ........................................................... 12 5.0 ,

References . ..................... }.................................................

................ ,....... ................ ,... .....w...__1

GE-NE-O00Q-0050-5900NP Rev 0 Non-Proprietary Information LIST OF TABLES Table 33-1. Comparison of Physical and Load Data 5 Taeble 3.4-1. Comparison of Faulted Loads for BWRVIP-25 and MNGP 6 Table 3.5-1. Axial and Bending Stiffnesses of the Bolts 6 Table 3.6-1. Axial Loads and Membrane (Pm) Stresses in the Bolts. 7 Table 3.7-1. Bending Stresses in the Bolts Due to Lateral Faulted Loads 7 Table 3.10-1. Shear Stress in the Aligner Pins 10.

Table 3.11-1. Comparison of Stress Results for BWRVIP-25 and MNGP Core Plate BDlts 11

GE-NE:-0000-0050-5900NP Rev 0 Non-Proprietary Information

1.0 INTRODUCTION

This letter report documents the structural integrity evaluation of the core plate bolts; and aligner pins to support the License Renewal of the Monticello Nuclear Generating Plant (MNGP). The bases for the development of this report are NRC questions regarding the adequacy of the core plate bolts to support License Renewal. The BWRVIP-25 core plate finite element analysis was originally performed to help utilities determine a strategy for core plate inspections, wherein conservative geometric conditions and bounding, postulated worst-case scenarios were considered. It isnoted that the BWRVIP-25 analysis approach is not the original design basis requirement However, it isdesired that an analysis similar to that of BWRVlP-25 be performed for the MNGP core plate to demonstrate that the results documented in the BWRVIP-25 analysis bound those of the MNGP core plate. The ccre plate configuration used in the BWRVIP-25 analysis bears close similarities with the MNGP core plate; therefore, an evaluation is performed using the original BWRVIP-25 analysis as; the baseline and reconciling the results basec on comparison of MNGP-specific core plare geometric parameters and loading. This evaluation isperformed at the request of MNGP as a bounding evaluation to demonstrate that the core plate bolt integrity issatisfied for License Renewal.

2..0 SCOPE The scope of the stress calculations for tha core plate bolts and aligner pins performed herein isto consider the three scenarios of the core plate analysis per BWRVIP-25, Appendix-A, The three scenarios are listed below.

Scenario-l. Calculate loads and stresses in bolts with no credit for aligner pins.

Scenario-2. Calculate the shear load and shear stress in the aligner pins with no credit for horizontal bolt restraint Scenario-3. Calculate the loads and stresses inthe bolts with no credit for the aligner pins and with rim welds cracked.

2.1. Objective The objective of this evaluation isto show that the MNGP core plate bolts and aligner pins stresses in the faulted conditions are bounded by those calculated in BWRVIP-25, Appendix-A Given the nature of the scenarios, listed in BWRVIP-25, the calculations performed herein are not design basis calculations.

[GE-NE-0000-0050-5900NP Rev 0 INon-ProprietaryInformation 3.0 CALCULATIONS 3.1. Assumptions Calculations are performed considering MNGP-specific faulted condition loads,,

consistentwith BWRVIP-25, Appendix-A. Stress results for core plate bolts and aligner pins obtained from these calculations were compared with the corresponding stresses listed in BWRVIP-25 Appe'ndix-A.

[t 1))

32. Calculation Approach The review of the parameters (geometry/loading) of the BWRVIP-25 finite element model and the MNGP core plate shows that both core plates are similar. Based on this similarit,, the 8NRVIP-25 Appendix-A finite element analysis results can be utilized to evaluate the MNGP core plate bolt stresses. The evaluation considers the following approach.

1]

GE-NE-0000-0050-5900NP Rev 0 Noat-Proprietkay Information i:

3.3. Comparison of BWRVIP-25 and MNGP Core Plates

-The following table presents acomparison of the geometric sizes, features and loads applicable to the core plates of MNGP and those used in BWRVIP-25 (Ref 5.1.) ((

Table 3.3-1.Compari son of Physical and Load Data Applicable Loads :4.

The following faulted condition design basis loads are considered in the MNGP core plate bolt stress calculations.

[7 l GE-NE:-0000-0050-5900NP Rev 0 Non-Proprietay Information Table 3.4-1, Comparison of Faulted Loads for 8WRVIP-25 and MNGP

_ = I= I I))

3.5. Calculation of Axial and Bending Stiffnesses of the MNGP Core Plate Bolts

((

I]

Table 3.5-1. Axial and Bending Stiffnesses of the Bolts I _

II l Ace 6-"",,f 12

GE-NE-OOOO-0050-5900NP Rev 0 Non-Proprietary Information 3,6. Axial Loads and Membrane (Pm) Stresses in the Core Plate Bolts

[1

))

Table 3.6-1. Axial Loads and Membrane (Pm) Stresses inthe Bolts.

rIT=_

t I 3.7. Bending Stresses in the Bolts due to Lateral Loads - Scenarios 1and 3

[Ei Table 3.7-1. Bending Stresses in the Bolts Due to Lateral Faulted Loads

[.  : _________

_= CAF_-11

GE-NE-0000-0050-5900NP Rev 0 IAT Non-Proprietary Information

,,,I 3.8. Bending Stresses in the Bolts Due to Bowing of the Core Plate Since the MNGP and BWRVIP-25 core plates are similar ingeometry and configuration, ((

II

GE-NE-0000-0050-5900NP Rev 0 Non-Proprietary Information 1[

I]

3.9. Bending stresses in the Bolts due to Core Plate Bowing II 11

GE-NE-0000-0050-5906NP Rev 0 Non-Proprietary Information 3.10. Scenario 2 - Shear Stress in the Aligner Pins

[1 11 Table 3.10-1. Shear Stress in the Aligner Pins

  • 1. -

& .1. L -

I]

GE-NE-OO0-0050-5900NP Rev 0 Non-Proprietary Information I w

3.1; Sum a Qf.RiZ l The stress results for the 8WRVIP-25 and MNGP core plate bolts and aligner pins are provided in the table below.

Table 3.11-1. Comparison of Stress Results for BWRVIP-25 and MNGP Core Plate Bolts Scengrio ScnroDecito D~escription I ASME AlwbeLoad, Allowa ble SWRVIP-25 MN6P kips ____ L___Fmmen Load, kips comment Stresses. ksl Lod, Srs, 2.0' 2bot a*

kips bolt 2.0" bolt 25"bolt Total horizontal load [1 _ _

Total vertical load I i _

Scenario 1. Determine-.

the load on core plate Mean membrane stress, Pm 2.4Sm 40.56 I 8.00 1 7.91 Meets ASME bolts with no credit for allowables aligane rs j Mean bending stress, '^=sPb j t [.......

=.._=====_...............

====.......

25.84 32.18 sceeMen(Pm+Pb) n0. D M n stress 57. 3 33.84 40.09 BWVP2ounded By Scenarao 2.Determine Maximum lateral load shear load on aligner Bounded By pins with no credit for Mean shear stress , 1.5 Sm = 25.35 11.27 Bounded By horizontal bolt restraint 1 BWRVIP-25 Total horizontal load Scenario 3. Determine Total vertical load __ _ __ _

load on bolts with no Mean membrane stress, PM Z4Sm = 4056 8.0 7.91 Meets ASME credit for aligners and I I [allowables with rim weld cracked.

Mean bending stress, Pb 25.84 32.18 Bounded By BWRVIP-25 Mean (Pm+Pbl stress 3sm = su.7u D 33.84 4U.UY

. -" ,k,-"

i5

('-,I I '

GE-NE-..:0-0050-5900NIP Rev 0 I Non-Proprietary Information 4,0 CONCLUSIONS Considering the similarities in geometry and construction of the MNGP and BWRVIP-25 core plates, a conservative evaluation of the st esses in the core plate rim hold-down bolts has been performed.

Based on the comparative analysis described in the earlier sections of this reportand the estimated stress results summarized in Tcble 3.11-1, The following conclusions are made:.

  • The mean Pm stresses in the MNGP bolts are within ASME allowable limits, but are higher than those in Appendix A of 8WRVIP-25. This isdue to the pre-load used for MNGP being considerably higher than the preloads used in BWR\VP-25 analysis.
  • The mean (Pm + Pb) stresses for MNGP core plate bolts are within the ASME allowable limits. They remain bounded by those in Appendix A of BWRVIP-25. (Scenarios 1and 3)

The mean shear stress in the aligrer pins for MNGP iswithin the ASME allowable limits. It remains bounded by the shear stresses reported in Appendix A of BWRVIP-25.

5.0 REFERENCES

5.1. BWR Vessel and Internals Project. BWR Core Plate Inspection and Flow Evaluc bon Guidelines (BWRVIP-25).

5.2. Shigley. OMechanical Engineering CDesign', Third Edition, McGraw Hill, page 247.

5.3. Warren C. Young, 'Roark's Formulas for Stress and Strain', 6th Edition, McGraw Hill, Table 24, Cases 9a and 10a.

ENCLOSURE 3 GE Affidavit Support Withholding of Proprietary Report GE-NE-0000-0050-5900P, Revision 0, "Comparative Evaluation of the Monticello Core Plate Rim Hold-Down Bolts and BWRVIP-25, Appendix A Analysis" From Public Disclosure 3 Pages Follow

General Electric Company AFFIDAVIT I, Louis M. Quintana, state as follows:

(1) I am Manager, Licensing, General Electric Company ("GE"), and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.

(2) The information sought to be withheld is contained in Enclosure 1 to GE letter MNGP-LR-GE-018, Mr. George E. Paptzun (GE) to Joe Pairitz (Monticello NPS),

Monticello License Renewal Project - Transmittal - Comparative Evaluation of the Monticello Core Plate Rim Hold-down Bolts andB WR VIP-25, Appendix A Analysis, dated February 16, 2006. The proprietary information in Enclosure 1, Comparative Evaluation of the Monticello Core Plate Rim Hold- Down Bolts and BWR VIP-25, Appendix A Analysis, is identified by ((double underlines inside double square brackets 3 ) ]. In each case, the superscript notation{3 refers to Paragraph (3) of the enclosed affidavit, which provides the basis for the proprietary determination.

(3) In making this application for withholding of proprietary information of which it is the owner, GE relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) for "trade secrets" (Exemption 4). The material for which exemption from disclosure is here sought also qualify under the narrower definition of "trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704F2dl280 (DC Cir. 1983).

(4) Some examples of categories of' information which fit into the definition of proprietary information are:

a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by General E]lectric's competitors without license firom General Electric constitutes a competitive economic advantage over other companies;
b. Information which, if used 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 of a similar product; AIFEnclosure I to GE letter MNGP-LR-GE-018 Affidavit Page I
c. Information which reveals aspects of past, present, or future General Electric customer-funded development plans and programs, resulting in potential products to General Electric;
d. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

The information sought to be withheld is considered to be proprietary for the: reasons set forth in paragraphs (4)a. and (4)b. above.

(5) To address 10 CFR 2.390 (b) (4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GE, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GE, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set fbrth in paragraphs (6) and (7) following.

(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to such documents within GE is limited on a "need to know" basis.

(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GE are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

(8) The information identified in paragraph (2), above, is classified as proprietary because it contains detailed results of analytical models, methods and processes, including computer codes, which GE has developed and applied to perform evaluations of the core holddown structures for the BWR. The development and approval of the BWR core plate analysis basis was achieved at a significant; cost, on the order of one million dollars, to GE.

The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GE] asset.

Af Enclosure I to GE letter MNGP-LR-GE. 018 Affidavit Page 2

(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GE's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GE's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GE.

The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.

GE's competitive advantage will be lost if its competitors are able to use the results of the GE experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

The value of this information to GE would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GE of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing these very valuable analytical tools.

I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.

Executed on this 16th day of February 2006.

Louis M. Quintana Manager, Licensing Af Enclosure I to GE letter MNGP-LR-GE-.O 18 Affidavit Page 3

ENCLOSURE 4 Response to NRC Question Regarding N2 Nozzle USE Information

1. NRC RAI 4.2-3b In its initial response to RAI 4.2-3, dated October 28, 2005, the applicant provided a table projecting Upper Shelf Energy (USE) data through the period of extended operation. The staff noted the table was miss ing data for the nozzles. The applicant: referenced BWRVIP-74, which provided USE data for the plates. However, the staff noted that nozzles are forged components, not plates, and requested the applicant to provide a technical basis for their position that the plates are limiting components.

NMC Response Given the hot working normally associated with the fabrication of forgings (resulting in a more refined grain structure), it is expected that the fracture toughness properties of the A 508 Class 2 forging materials would be equivalent, if not better than, the corresponding A 533 Grade B plate materials typically used to fabricate beltline shell courses (see also Section 4.3.3 of Reference 4). A 508 Class 2 forging materials (or equivalent) have been used throughout the industry for fabrication of reactor vessel components, including the Monticello Nuclear Generating Plant (MNGP) recirculation inlet (N2) nozzles, and as such, a significant amount of data has been reported on the fracture toughness of these materials.

A study was performed using ithe NRC Reactor Vessel Integrity Database, Revision 2 (RVID2). All A 508 Class 2 (or equivalent) forging materials were reviewed, and the methodology used in BWRVIP-74-A (Reference 5) was applied to provide a comparison of the forging material properties to the plate material properties. Table I contains a listing of the unirradiated upper shelf energy (USE) for both BWR and PWR plants with beltline forging materials obtained from RVID2. Using the BWRVIP-74-A methodology including a 95/95 confidence interval, the following results were obtained. The mean of the USE data for forgings is 108 ft-lb, with a minimum observed USE of 70 ft-lb. As noted in Reference 4, there is some variability in the upper shelf energy results obtained from beltline forging materials. The standard deviation, a, is 24. As defined in NUREG-1475, for 95/95 confidence with a data set consisting of 67 data points, the K value is 1.9996. This results in a Mean - KaCof 60 fl-lb (see Figure 1). Being consistent with BWRVIP-74-A, because the Mean - KC was lower than the minimum observed USE, the Mean - iCa was conservatively used.

For comparison, the plate data used to develop the equivalent margin analysis is shown in Appendix B to BWRVIP-74-A. The mean equivalent Page 1 of 7

ENCLOSURE 4 plate transverse Charpy energy was reported as 82.5 ft-lb, with a minimum observed Charpy USE of 59 ft-lb. The Mean - KCa is 64.5 ft-lb (see Figure B-4 of Reference 5). Note that in the BWRVIP analysis, since the minimum value was lower than the Mean - Ka value, the minimum value of 59 ft-lb was used to demonstrate the acceptability of the equivalent margin analysis.

Based on these data, forging upper shelf energy is consistent with the observed beltline plate upper shelf energies, and is therefore bounded by the equivalent margin analysis.

To further demonstrate the acceptability of the N2 nozzle fracture!

toughness, forging data determined from RVID2 is applied specifically to MNGP. Figure 1 provides the forging data from RVID2 in a manner similar to Figure B-4 of Reference 5. Using Revision 2 of Regulatory Guide 1.99 (RG 1.99) in conjunction with the RVID2 forging database results, the MNGP-specific forging end-of-life (EOL) USE becomes:

MNGP 54 EFPY N2 5.23e17 n/cm2 Fluence MNGP N2 %Cu 0.18 (bounds worst case in RVID2 = 0.17 RG 1.99 Predicted 13.6 (using Figure 2 of RG 1.99)

%Decrease (Mean - Ka) * (1 - [108 - (1.9996

  • 24)] * [1 - 13.6/100)]

%Decrease/1 00)

EOL USE 52 ft-lb The EOL USE of 52 ft-lb exceeds the transverse plate requirement of 35 ft-lb for equivalent margin.

The RVID2 database surveillance capsule results were also reviewed to evaluate the behavior of forging materials with respect to plate materials.

Forty-three (43) transverse data points were obtained from RVID2, as shown in Table 2. Of the 43 data points, forty (40) demonstrate USE decreases that are bounded by the RG 1.99 predictions, using %Cu and capsule fluence. The three data points where the measured USE drop percentage exceeds the predicted USE percentage decrease are all from the same plant, a PWR with very low copper content. Figure 2 provides a plot of these values. Review of these results indicates that application of the RG 1.99 prediction to forgings adequately predicts the irradiated behavior of these materials.

Therefore, it has been demonstrated that the forging materials meet or exceed the requirements for plate materials, and that the MNGP N2 nozzle case is bounded by the! EMA plate requirements described in Page 2 of 7

EINCLOSURE 4 BWRVIP-74-A. Further, it has been demonstrated that, in general, irradiated forging materials behave in a manner consistent with the predictions of RG 1.99. Based on the results of this evaluation, the USE of the N2 nozzle forgings will be adequate for the period of extended operation.

Table 1: Beltline Forging Unirradiated Upper Shelf Energy (USE) From RVID2 PLANT Unirradiated USE(ft-lb)

ARKANSAS NUCLEAR 1 109 BRAIDWOOD 1 118 BRAIDWOOD 1 136 BRAIDWOOD 1 162 BRAIDWOOD 2 119 BRAIDWOOD 2 128 BRAIDWOOD 2 150 BYRON 1 138 BYRON 1 138 BYRON 1 150 BYRON 2 127 BYRON 2 149 BYRON 2 155 CATAWBA 1 134 CATAWBA 1 134 CRYSTAL RIVER 3 109 DAVIS-BESSE 122 DAVIS-BESSE 132 DAVIS-BESSE 140 GINNA 91 GINNA 114 GINNA 117 HOPE CREEK 70 HOPE CREEK 79 KEWAUNEE 92 KEWAUNEE 97 MCGUIRE 2 97 MCGUIRE 2 100 NORTH ANNA 1 74 NORTH ANNA 1 85 NORTH ANNA 1 92 NORTH ANNA 2 74 NORTH ANNA 2 74 Page 3 of 7

'I ENCLOSURE 4 PLANT Unirradiated USE(ft-lb)

NORTH ANNA 2 80 OCONEE 1 109 OCONEE 2 109 OCONEE 2 133 OCONEE 2 138 OCONEE 3 109 OCONEE 3 112 OCONEE 3 144 POINT BEACH 1 78 POINT BEACH 2 78 POINT BEACH 2 94 POINT BEACH 2 117 PRAIRIE ISLAND 1 84 PRAIRIE ISLAND 1 134 PRAIRIE ISLAND 1 143 PRAIRIE ISLAND 2 85 PRAIRIE ISLAND 2 106 PRAIRIE ISLAND 2 112 SEQUOYAH 1 72 SEQUOYAH 1 79 SEQUOYAH 2 88 SEQUOYAH2 100 SURRY 1 83 SURRY2 104 TMI-1 109 TURKEY POINT 3 93 TURKEY POINT 3 99 TURKEY POINT 3 100 TURKEY POINT 4 86 TURKEY POINT 4 88 TURKEY POINT 4 103 WATTS BAR 1 88 ZION 1 87 ZION 2 109 Mean 108 a 24 i a(67 data pts) 1.9996 Mean - xac 60 Page 4 of 7

ENCLOSURE 4 Table 2: Surveillance Capsule Forging Irradiated Upper Shelf Energy (USE) from RVID2

_Uirradiated Data US Measured USE Chpsule Ruence F 1.99 Measured Fbnt Rant #t-lb) 1t-Ib) tcrn2) /XOecrease OO/Cu %Decrease 1 Cconee 3 110 101 3.12EF18 0.01 82 8.18 2 Oconee3 110 92 1.45E219 0.01 12.5 16.36 3 Davis-Besse 116 113 5.92E218 0.02 10.5 2.59 4 Davis-Eesse 116 114 9.62EF18 0.02 11.5 1.72 5 Davis-Besse 116 118 1.96E+18 0.02 8 0.00 6 Coonee3 141 131 8.10E+17 0.02 6.5 7.09 7 Oconee3 141 124 3.12E218 0.02 8.8 12.06 8 Coonee3 141 124 1.45E219 0.02 13 12.06 E raidwood 2 168 166 225E219 0.026 15 1.19 ic Byron 1 145 145 4.04EF18 0.036 102 0.00 11_ yron 1 168 159 2.43EF19 0.036 162 5.36 12 Cavis-Eesse 140 127 129EF19 0.04 14.5 929 16 COonee2 127 127 3.37E218 0.04 102 0.00 14 Oconee 2 127 127 1.02E218 0.04 7.5 0.00 le; Oconee2 127 114 121E219 0.04 14 1024 1e Braidwood 1 168 168 3.87E218 0.05 102 0.00 17_ Braidwood 1 168 160 2.09E219 0.05 14.9 4.76 1S Braidwood 1 168 166 124EF19 0.05 13.3 1.19 1G, Byron 2 170 157 127E219 0.05 13A 7.65 2C Kewaunee 160 156.8 2.89E219 0.06 17.9 2.00 21 Kewaunee 160 160 1.94E219 0.06 16.4 0.00 22' Kewaunee 157 157 2.89EF19 0.06 17.9 0.00 22= Kewaunee 157 152.3 1.94E219 0.06 164 2.99 24 Rairie Island 1 143 155 627E218 0.06 12.8 0.00 26 Byron 2 170 162 2.30E219 0.075 19.4 471 26 Prairie Island 2 150 127 4.38EF19 0.085 24A 15.33 27 Prairie Island 2 150 133 120E+19 0.085 18.1 11.33 2e Catawba 1 168 151 2.33E219 0.086 21.1 10.12 2S= Catawba 1 168 153 1.32E219 0.086 18.6 8.93 30 NorthAnna2 115 120 9.80E+18 0.11 20.1 0.00 31 North Anna 2 120 120 2.46E218 0.11 14.5 0.00 32 9equoyah 1 116 98 2.74E218 0.13 16.4 1552 33 Soquoyah2 134 118 220E218 0.13 15.5 11.94 34 fquoyah 2 134 110 6.43E218 0.13 20.1 17.1

_ Ssquoyah2 134 123 1.11EF-19 0.13 22.7 821 36 WattsBar1 132 107 5.05E218 0.155 21.1 18.94 37 North Anna 1 135 122 2.63EF18 0.156 18.1 9.63 38 North Anna 1 135 95 2.05EF19 0.156 29.7 29.63 39 McIGuire2 156 122 1.96E219 0.16 29A 21.79 40 Mc(uire 2 156 134 327E+18 0.16 194 14.10 41 McGuire2 154 113 2.97E+19 0.16 32.3 26.62 42 McGuire 2 156 136 14A1 E219 0.16 272 12.82 43 Kewaunee 123 98A4 3.45E219 0.17 34.8 20.00 Page 5 of 7

ENCLOSURE 4 Figure 1 Forgings Meet Equivalent Margin Requirements 170 160 MEAN = 108 FT-LB 150 * **

140 130 * . .

120 110 .

100 z 90 w

  • A508 Forgings V) 80 LOWEST INITIAL USE = 70 FT-LB*

70 MEAN -iC- 60 FT-LB 60 MONTICELLO SPECIFIC EOL USE DECREASE OF 13.6% = 52 FT-LB EOL USE 50 40 30 10 ...il e ... .. pl tFae i l e u r m n s 0 10 20 30 40 50 60 70 80 90 100 110 120 130 Data Point (increments of 3)

Page 6 of 7

ENCLOSURE 4 Figure 2 Surveillance Capsule Forgings: RG1.99 Predicted Decrease vs. Measured Decrease Irradiated Forging Material RG1.99 Predicted USE Decrease vs. Measured USE Decrease 40 -

35 -

30 -

25 0) 1A 0 20

a.
  • Predicted LU Decrease S

n

  • Measured Decrease 15 10 5

0 0 5 10 15 20 25 30 35 40 45 50 Data Point Page 7of7 coI

ENCLOSURE 5 Supplemental Information Related to Previous RAls Responded to on December 7, 2005

1. NRC RAI 3.6-1a In a letter dated December 7, 2005, the applicant provided a response to RAI 3.6-1 which addressed the aging management program for electrical penetrations. The staff requested the applicant to verify that the non-safety-related drywell penetrations were qualified for a 60-year life. The staff also requested the applicant to provide the frequency of surveillance inspections for leak detection for the penetrations.

NIMC Response All primary containment electrical penetrations are classified as safely related and perform a primary containment function. Some electrical penetrations have been classified as equipment qualification (EQ) related. All non-EQ penetrations within the scope of License Renewal were procured to the same specification as EQ related penetrations. The EQ penetrations are all environmentally qualified for greater than 60 years. The non-EQ penetrations were manufactured to the same specification and from the same materials as the EQ penetrations.

Therefore, there is reasonable assurance that the non-EQ penetrations are qualified for greater than 60 years.

Preventative Maintenance Procedure 7269 - Containment Electrical FPenetrations PM or Procedure 01 37 Local Leak Rate Test of Containment Electrical Penetrations perform routine maintenance and testing of electrical penetrations.

The preventative maintenance procedure is performed to comply with Service Information Letter (SIL) No. 259 and the local leak rate testing is perlormed to comply with 10 CFR 50 Appendix J Option B. The scheduled frequency for Procedure 0137-01 is every refuelling outage and the scheduled frequency for Procedure 7269 is every 2 years.

2. NRC RAI 3.6-2a In its response to RAI 3.6-2, dated December 7, 2005, the applicant described the aging mechanisms for cable connectors. The applicant stated that the thermography program monitors substation equipment, 4-kV breakers, load centers, motor control centers, control panels, DC equipment, motors, generators, and connections associated with these components at least semi-annually. The staff requested the applicant to verify that the thermography program addresses the 10 program elements described in GALL AMP XI.E6.

The staff also requested the applicant verify that the switchyard connections and transmission connections were also covered by the thermography program.

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EINCLOSURE 5 NMC Response NMC commits to implementing a MNGP program which is consistent with the 1NUREG 1801, Revision 1, XL.E6, "Electrical Cable Connections Not subject to 10 CFR 50.49 Environmental Qualification Requirements" program. The details of this program will be consistent with the program description and the ten elements described in the NUREG 1801, Revision 1, XL.E6 program and will be provided in the March 2006 annual update.

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ENCLOSURE 6 Correction of Errors in Describing and Referencing Requirements of the American Society of Mechanicall Engineers (ASME) Section Xi Inservice Inspection and Testing Program for Purposes of License Renewal

1. Clarification of Bolting Program Statements Concerning Section XI MNGP is implementing the CRD bolting examination in accordance with Table IWB-2500, Category B-G-2, Item B7.80 of the 1995 Edition of Section Xl of the ASME Code.

This examination is listed in the MNGP Engineering Work Instruction for the ASME Code Section Xi In-Service Inspection Program.

In our License Renewal Application, MNGP took exception to this portion of NUREG-1801, Revision 0, because it calls out the 1995 Edition of Section Xl through the 1996 Addenda. The 1996 Addenda does not identify CRD bolting examinations in Table IWNB-2500. The applicable MNGP Aging Management Program states that the 1995 Edition with the 1995 Addenda will be implemented in order to perform the CRD bolting examination. However, during a subsequent review, it was found that the 1995 Addenda to the 1995 Edition of ASME Section Xi also eliminated the CR0D bolting examinations. The use of the 1995 Addenda for the CRD bolting examination is an editorial error in the MNGP Fourth Interval In-service Inspection Plan. This error has been entered into the site Corrective Action Program (AR No. 01013564). This discrepancy has no impact on the performance of the CRD bolting examinations since the requirements for this examination are contained in the implementing procedure.

The deletion of the applicability of the 1995 Addenda of Section Xi of the ASME Code requires (1) a revision to the MNGP Fourth Interval ISI Plan, (2) a revision to the applicable License Renewal Aging Management Plan, and (3) a change to the associated section of the LRA. The LRA will be updated during the annual update to be submitted in March of 2006.

This LRA update will indicate that the MNGP AMP takes exception to NURIEG-1 801, Revision 0, by not adopting the 1996 Addenda and complying with the 1995 Edition for the CR1) bolting examination.

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ENCLOSURE 6

2. Use of 2001 Edition of Section Xi of the ASME Code for Monticello Repairl Replacement Program In Enclosure 1, Table 1, "NRC Audit item B2.1.26-01: Alternatives to ASME Section Xi, ISI Program Impact On Aging Managemient," Item 8, of our submittal dated August 11, 2005, NMC provided the basis for the acceptability of the use of the 2001 Edition of the ASME Code, Section Xl, for the MNGP Repair/Replacement Program.

The reference to the applicable Federal Register Notice approving this version of Section Xl of the Code was incorrectly stated in our submittal. Our response referenced an earlier Federal Register Notice which only applied through the 2000 Ediition of the Code.

The correct reference is Federal Register Volume 69, No. 190, October 1, 2004.

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