ML070040095
| ML070040095 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 12/22/2006 |
| From: | Spina J Calvert Cliffs, Constellation Generation Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML070040095 (17) | |
Text
James A. Spina Vice President 0Constellation Energy Generation Group.
Calvert Cliffs Nuclear Power Plant, Inc.
1650 Calvert Cliffs Parkway Lusby, Maryland 20657 410.495.5200 410.495.3500 Fax December 22, 2006 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
SUBJECT:
Document Control Desk Calvert Cliffs Nuclear Power Plant Unit No. 1; Docket No. 5 0-3 17 Response to NRC Request for Additional Information Regarding our letter dated May 31, 2006, "ASME Code Section XI Flaw. Evaluation of Dissimilar Metal Weld Flaws Identified by Ultrasonic Testing" (a)
Letter from Mr. P. D. Milano (NRC) to Mr. J. A. Spina (CCNPP), dated October 27, 2006, Calvert Cliffs Nuclear Power Plant, Unit No. 1 (CCNPP I-Request for Additional Information Regarding Flaw Evaluation of Dissimilar Metal Welds (TAC Nos. MCD23 5 1)
REFERENCES:
(b)
Letter from Mr. J. A. Spina (CCNPP) to Document Control Desk (NRC),
dated May 31, 2006, ASME Code Section XI Flaw Evaluation of Dissimilar Metal Weld Flaws Identified by Ultrasonic Testing The purpose of this letter is to provide Calvert Cliffs Nuclear Power Plant, Inc.'s (CCNPP's) responses to Nuclear Regulatory Commission's request for additional information (Reference a) regarding CCNPP's submittal of the subject flaw evaluation data (Reference b). The requested information is provided as attachments to this letter. Attachments (1) and (2) contain the requested non-proprietary information.
Please note that Attachment (3) is considered by Westinghouse Electric Company to be proprietary information as defined by 10 CFR 2.3 90. Westinghouse Electric Company has requested the contents of Attachment (3) to be withheld from public disclosure as attested in the accompanying affidavit (Attachment 4). The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses the considerations in 10 CFR 2.390(b)(4). Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure. There is no non-proprietary version of this Attachment.
£ Document Control Desk December 22, 2006 Page 2 Should you have questions regarding this matter, please contact Mr. J. S. Gaines at (410) 495-5219.
Very truly yours, for James A. Spina Vice President - Calvert Cliffs Nuclear Power Plant JAS/MJ-Y/bjd Attachments:
(1)
Calvert Cliffs Nuclear Power Plant Response to the NRC Request for Additional Information dated October 27, 2006 (Non-Proprietary)
(2)
Ultrasonic Examination Evaluation Sheets for Subject Welds (3)
LTR-MRCDA-06-220, Rev. 1, Responses to the NRC Request for Additional Information (RAI) Regarding Flaw Evaluation of Hot Leg Surge Line and Drain Nozzle Welds at Calvert Cliffs, dated December 8, 2006 (Proprietary)
(4)
Westinghouse Electric Company Affidavit from B. F. Maurer cc:
P. D. Milano, NRC S. J. Collins, NRC Resident Inspector, NRC (Without Attachments)
R. 1. McLean, DNR
ATTACHMENT (1)
CALVERT CLIFFS NUCLEAR POWER PLANT RESPONSE TO THE NRC REQUEST FOR ADDITIONAL INFORMATION DATED OCTOBER 27, 2006 (Non-Proprietary)
Calvert Cliffs Nuclear Power Plant, Inc.
December 22, 2006
ATTACHMENT (1)
CALVERT CLIFFS NUCLEAR POWER PLANT RESPONSE TO THE NRC REQUEST FOR ADDITIONAL INFORMATION DATED OCTOBER 27, 2006 (NON-PROPRIETAY Reciuested Information 1:
In Table 1, the wall thicknesses of the surge line and drain line area are identified as 1. 313 inches and
- 0. 375 inches, respectively. In Table 2, the wall thicknesses of the surge line and drain line are identified as 1. 6 inches and 0. 54 inch, respectively.
(a) Discuss whether the discrepancies of the wall thicknesses between Tables 1 and 2 are due to cladding in the pipe.
(b) Discuss which thicknesses were used in the flaw evaluation.
CCNPP Response:
a)
Dimensional data in Table I [Reference 1] was taken from Westinghouse drawings and represents the design dimensions. This data does not include the cladding thickness and is used for calculation of applied stresses. As-built wall thickness dimensions in Table 2 are at the flaw locations and obtained from the ultrasonic examinations (UT) performed at Calvert Cliffs Nuclear Power Plant (CCNPP) during the spring 2006 outage. The as-built wall thickness was taken in the weld area which does not have cladding.
b)
Ultrasonic examinations dimensions at the flaw locations (Table 2) were used in the fracture mechanics evaluation of as-found indications. American Society of Mechanical Engineers (ASME)
Section XI Article IWA-3200 permits use of component thickness dimensions observed values and flaws detected by nondestructive examinations of flaw evaluations per IWB3-3000.
Requested Information 2:
The surge nozzle piping loads, as shown in Table 3, did not include loads from the transients such as heat up, cooldown, and reflood Discuss why transient loads were not considered in the flaw evaluation of the surge line nozzle.
CCNPP Response:
The flaw evaluation performed in Reference 1 assessed the acceptability of as-found flaws during the pre-outage operation prior to the Mechanical Stress Improvement Process (MSIP) repair. This acceptability represents the end-of-evaluation period just prior to the outage. The flaw evaluation does not include the crack growth; therefore, the thermal transients such as heat-up, cooldown, and reflood are not included in Table 3.
Reauested Information 3:
In Figures 2 and 3, the NRC staff observed that if the ratio offlaw depth (a) versus wall thickness (t) of the indication in the surge line were 1. 0 (i. e., 100% through wall), the flaw would still be acceptable. The same observation is true for the drain line in Figures 10 and 11. This observation contfradicts the limit (i.e., 0. 75) on the a/t ratio, as specified in Table C-531 0-1 of Appendix C to Section XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Coder (ASME Code). Discuss whether the upper limit of 0. 75 for a/t ratio should be included in Figures 2, 3, 10, and 11.I CCNPP Response:
American Society of Mechanical Engineers Code Section XI Table C-53 10 limits the maximum allowable flaw depth to thickness ratios of 75% through-wall.
Analytical equations in ASME Appendix C were used to generate the allowable limits in Figures 2, 3, 10, and I11 for the Calvert Cliffs'
ATTACHMENT (1)
CALVERT CLIFFS NUCLEAR POWER PLANT RESPONSE TO THE NRC REQUEST FOR ADDITIONAL INFORMATION DATED OCTOBER 27, 2006 (NON-PROPRIETARY) plant-specific geometry and loading. These figures represent the analytical limits and not the ASME Code Table limits. Code limits of 75% are reflected by the upper range in Figures 4 and 6.
Requested information 4:
On page 2, it is stated that Article C-5321 and Tables C-531JO-i through C-5310-4 of Appendix C to the ASME Code,Section XI were used for the flaw evaluation, However, prior to the use of the flaw evaluation methodology in the Article C-5000 procedures, certain screening criteria in Article C-4000 should be satisfied Provide information to show that the screening criteria of Article C-4000 have been satisfied such that the flaw evaluation methodology of Article C-S5000 can be appropriately applied to the surge and drain line nozzles.
CCNPP Response:
Calvert Cliffs currently invokes the 1998 edition of ASME Code Section XI for Inservice Inspection. The 1998 edition of the ASME Code Section XI Appendix C, does not have screening criteria. The screening criteria available in 2004 edition of the Code, Article C-4000, were not used in the flaw evaluation.
Instead, a conservative approach was used that included the normnal thermal and stratification loads in the stress ratio and compared with the bending stress allowable values in Article C-5000 using the limit load approach.
Evaluation of the same flaws using the elastic-plastic fracture mechanics (EPFM), per Article C-6000, also shows that the as-found flaws at the Calvert Cliffs surge line are well within the EPFM allowable bending stresses and are considered acceptable.
Requested Information 5:
Provide sketches or diagrams to show the locations of the indications in the surge and drain line nozzles.
The sketches should include the nozzle, safe end, weld, and pipe. The sketches should show whether the indications are surface connected or embedded.
CCNPP Response:
The requested documentation is included as Attachment 2.
2
ATTACHMENT (1)
CAL VERT CLIFFS NUCLEAR POWER PLANT RESPONSE TO THE NRC REQUEST FOR ADDITIONAL INFORMATION DATED OCTOBER 27, 2006 (NON-PROPRIETARY)
Requested Information 6:
Identify the ASME Code material specifications of the nozzle, sa fe end, weld, and pipe.
CCNPP Response:
The following table provides material information extracted from for the pressurizer surge nozzle and the hot leg drain nozzle.
the manufacturing data [Reference 2]
Component Description Material Designation -
Material Designation -
Pressurizer Surge Nozzle Drain Nozzle Nozzle SA-508 Cl. 2 SA-105 Gr. 2 Nozzle Butter Inconel 182 Inconel 182 Cladding E308 E308 Nozzle to Safe End Weld Inconel 182 Inconel 182 Safe End SA-351 CF8M SA-182 F316 Pipe to Safe End Weld E308L E308L Pipe SA-351 CF8M SA-376 TP316 Requested Information 7:
Submit copies of References 1, 2a, 2b, and 2c.
CCNPP Response:
Reference 1 is included in Attachment (2). References 2a, 2b, and 2c are Westinghouse proprietary and are included in Attachment (3) as a Westinghouse proprietary document. Attachment (4) contains the Westinghouse request for withholding proprietary information.
References:
- 1)
Westinghouse Letter, LTR-CI-06-26, Rev. 0, "Evaluation of As-found Flaws in Surge, Drain and Relief Valve Nozzle Safe-end Welds at Calvert Cliffs Unit 1 during March 2006 Outage," March 20, 2006
- 2)
Westinghouse Letter, LTR-RCUMP-05-69, Rev. 0, "Calvert Cliffs Unit 1 & 2, Engineering Data,"
October 18, 2005 3
ATTACHMENT (2)
ULTRASONIC EXAMINATION EVALUATION SHEETS FOR SUBJECT WELDS Calvert Cliffs Nuclear Power Plant, Inc.
December 22, 2006
0 Constellation Energy Calvert Cliffs Nuclear Power Plant, Inc.
February 27, 2006 Edward A. Ray Westinghouse Electric Co.
P.O. Box 355 Pittsburgh, PA. 15230
Subject:
Flaw evaluation of Calvert Cliffs Unit 1 Reactor Coolant System Pressure Retaining Welds
Enclosures:
1.WesDyne Ultrasonic Examination Evaluation Sheet for Reportable Indications, Weld Number 12CC9-1 001 (W 13)
- 2. WesDyne Ultrasonic Examination Evaluation Sheet for Reportable Indications, Weld Number 2CC9-1007 (W I)
- 3. WesDyne Ultrasonic Examination Evaluation Sheet for Reportable Indications, Weld Number 4CC 10-1006 (W 1)
Ed, The enclosed information is provided to Westinghouse to perform the analytical evaluation of flaws found in Dissimilar Metal Welds. Refer to each Ultrasonic Examination Evaluation Sheet for Reportable Indications for information regarding the geometry, size and orientation of each flaw. Complete analytical evaluations in accordance with ASME Code Section XI IWB-3 600 for flaws exceeding the acceptance standards of IWB-3500 are requested by March 10, 2006 to support plant start up. From preliminary comparison to the acceptance standards the flaw in weld number 12CC9-1 001 (W 13) and weld number 2CC9-1007(W1) will require analytical evaluation. The evaluations should reflect pre and post Mechanical Stress Improvement Process results.
Should you require any further information regarding this matter,. please do not /he tat~e to contact us.
Bernard C. uKdefl Engineering Programs cc: Douglass Warren, Westinghouse Greg Turley, Westinghouse Reddy Ganta, Westinghouse Andrew Henni
ATTACHMENT (2)
ULTRASONIC EXAMINATION EVALUATION SHEETS FOR SUBJECT WELDS 4" RV-201 Weld No. CC1O-1006(W-1) 19WESDvflE WESDYNE INTERNATIONAL, LLC Attachment to :
PDI-1 0-004 UIT Sheet No.
Page of____
ULTRASONIC EXAMINATION EVALUATION SHEET FOR REPORTABLE INDICATIONS Weld Number 4" CC1O0-1 006 (W-1)
Size of Indication:
Length:
0.6 Widthi
N/A Characterization of Flaw Indication per Para.
Type of Flaw:
Suspect PWSCC Sketch of Indication:
Indication Number(s)
Depth:1 Matil. Thickness:
1
.2 Remaining Ligament 1.3 (Ultrasonic) estimate IWA-3300 Datum Zero:
TDC Axial Indication detected on Nozzle Side at approx. 1.0" OW No:
Area of Indication z
SE\\
/EL Flaw Characteristics Calculations:
a =
0.1
[0=
0.6 S = -
0 Surface Subsurface rn EXAMINER EXAMINER APPROVAL ______
Client REVIEWER_______
Authorized Inspection Agency.
-LEVEL __
_DATE
-LEVEL __
_DATE LEVEL ____DATE LEVEL ____DATE
_________DATE I
ATTACHMENT (2)
ULTRASONIC EXAMINATION EVALUATION SHEETS FOR SUBJECT WELDS 2" Hot Leg Drain to 11 Hot Leg Weld No. CC9-1007(W-1)
Page-___
of ULTRASONIC EXAMINATION EVALUATION SHEET FOR REPORTABLE INDICATIONS Weld Number 200C9-11007 (W-1)
Indication Number(s) 1 Size of Indication:
Length:
.450" Depth:
0.45 Remaining Ligament Width:
N/A Matil. Thickness:
0.54 (Ultrasonic)
Characterization of Flaw Indication per Para.
IWA-3300 Type of Flaw:
Suspect PWSCC Datum Zero:
TDC Sketch of Indication:
Circ Indication located on Nozzle side at pipe TDC Area of Indication Noz SE Flaw Characteristics Calculations:
a =
0.1 Surface W
Ell
=0.45 S
0 Subsurface EXAMINER __________________LEVEL
___DATE______
EXAMINER __________________LEVEL
___DATE______
APPROVAL _________________LEVEL
____DATE______
Client REVIEWER ____________________LEVEL
____DATE_______
Authorized Inspection Agency _____________________DATE 2
ATTACHMENT (2)
ULTRASONIC EXAMINATION EVALUATION SHEETS FOR SUBJECT WELDS 12" Surge line to 11 Hot Leg Weld No. CC2-1001(W-1) nwESoyflE WESOYNE INTERNATIONAL, LLC Attachment to :
PDI-10-002 UIT Sheet No.
Page
-___ of____
ULTRASONIC EXAMINATION EVALUATION SHEET FOR REPORTABLE INDICATIONS Weld Number 12 CC2-11 001 (W 13)
Size of Indication:
Length:
2.4" Width:
N/A Characterization of Flaw Indication per Para.
Type of Flaw:
Suspect PWSCC Sketch of indinati~nn Indication Number(s)
Depth:
Matil. Thickness:
1
.2' Remaining Ligament 1.6 (Ultrasonic)
IWA-3300 Datum Zero :
Elbow Extradose Indication recorded on Nozzle side at 11.6" to 14.0' OW Flaw Characteristics Calculations:
a=
_U=
S-0.4 2.4 0
Surface Subsurface S
S EXAMINER EXAMINER APPROVAL Client REVIEWER_______
Authorized Inspection Agency
-LEVEL __
_DATE LEVEL ___DATE LEVEL ____DATE LEVEL ____DATE
__________DATE_______
3
ATTACHMENT (4)
Westinghouse Electric Company Affidavit from B.; F. Maurer Calvert Cliffs Nuclear Power Plant, Inc.
December 22, 2006
CAW-W6222 I AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF ALLEGHENY:
Before me, the undersigned authority, personally appeared B. F. Maurer, 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 bis knowledge, information, and belief:
B. F. Maurer, Principal Engineer Regulatory Compliance and Plant Licensing Sworn to and subscribed before me ibis 8th day of December, 2006 Notary Public Notarial Sea]
Sharon L. Riod, Notary Public Mon ro.ville Bore. Allegheny County My Comrn~ssion Expires January 29,2007 Memnber, Pennsylvania Assoc-ction Of Notaries
2 2
~CAW-06-222 1
(1) 1 am Principal Engineer, 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 informnation 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) 1 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 competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.
3 3
~CAW-06-2221I (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.
(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.
4 4
~CAW-06-2221I (e)
Unrestricted disclosure would jeopardize the position of prom inence 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 Proprietary in LTR-MRCDA-02-220, Rev. 1, "Responses to the Nuclear Regulatory Commission's (NRC) Request for Additional Information (RAI)
Reqarding Flaw Evaluation of Hot Leg Surge Line and Drain Line Nozzle Welds at Calvert Cliffs," being transmitted by the Calvert Cliffs Nuclear Power Plant letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse for the Calvert Cliffs Nuclear Power Plant is expected to be applicable for other licensee submittals in response to certain NRC requirements forjustification of Information requested on nozzles.
This information is part of that which will enable Westinghouse to:
(a) Provide information on the stress distribution on the nozzles that can be used to develop methodology for determining crack evaluations.
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.
5 5
CAW-06-2221I (b)
Westinghouse can sell support and defense of the flaw analysis.
(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 weld overlay designs 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 informnation 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.