ML15156A389

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LTR-SGMP-15-25 Np, Response to NRC Request for Additional Information on the Design Features of the Sequoyah, Unit 2, Replacement Steam Generators.
ML15156A389
Person / Time
Site: Sequoyah Tennessee Valley Authority icon.png
Issue date: 04/28/2015
From: Baron J, Harden C, Lowes R
Westinghouse
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML15156A384 List:
References
TAC MF5422 LTR-SGMP-15-25 NP
Download: ML15156A389 (21)


Text

ENCLOSURE 4 LTR-SGMP-15-25 NP RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION ON THE DESIGN FEATURES OF THE SEQUOYAH UNIT 2 REPLACEMENT STEAM GENERATORS (NON-PROPRIETARY)

Westinghouse Non-Proprietary Class 3 LTR-SGMP-15-25 NP-Attachment Westinghouse Electric Company Response to NRC Request for Additional Information on the Design Features of the Sequoyah Unit 2 Replacement Steam Generators April 28, 2015 Author:

Electronically Approved*

Jesse S. Baron Steam Generator Management Programs Verifier:

ElectronicallyApproved*

Charles T. Harden Nuclear Component Engineering Approved:

ElectronicallyApproved*

Ryan R. Lowes, Acting Manager Steam Generator Management Programs

© 2015 Westinghouse Electric Company LLC All Rights Reserved

  • ElectronicallyApproved Records are Authenticatedin the ElectronicDocument ManagementSystem.

Page 1 of 12

LTR-SGMP- 15-25 NP-Attachment

1. General information concerning the design of your replacement steam generators (SGs) was provided in the submittal. In order for the staff to better understand the design of your replacement SGs, please provide the following information:
a. A tubesheet map depicting the row and column numbers Response: a,c,e Page 2 of 12

LTR-SGMP- 15-25 NP-Attachment

b. Tube pitch (e.g., triangular, 1.00-inch center-to-center).

Response

The tubesheet is a triangular pitch design. The pitch is [ ]ac .. The upper bundle vertical component of the pitch (i.e., Row to Row distance) is "stretched" in the U-bend so that it starts with the standard pitch at the transition of the straight leg tube to the bent portion and maxes out at the apex of the bend. From a fabrication standpoint the overall tube height or length was increased incrementally for each row making the tube-to-tube pitch in the U-bend larger than that in the straight leg portion of the tube bundle. The pitch ranges from

]a"c~e nominal triangular pitch in the straight leg portion to [

]a.ce nominal vertical pitch maximum at the apex of the U-bend.

c. Expansion method and extent (e.g., hydraulic expansion for the full length of the tubesheet)

Response

The tubes are expanded the full length of the tubesheet using a hydraulic expansion method.

d. Tube support plate and U-bend support material and design

Response

All support structure material in contact with the tubes is [ ]ace The straight leg tube supports are of a grid type design with interlocking

]ace. The U-bend areas of the tube are supported by

[ ]c*' with varying numbers of vertical and diagonal support elements depending on the location in the variable radius U-bends. The shortest tubes (smallest radius bends) have at least 3 tube-to-support interface points, and the longest tubes (largest radius bends) have up to 9 tube-to-support interface points.

e. Flow distribution baffle design, if applicable

Response

Not applicable. The Westinghouse Model 57AG+ design does not have a flow distribution baffle.

f. Whether tubes were stress relieved after bending, and if so, the rows that were stress relieved

Response

Rows [ ]ace tubes were stress relief heat treated full length following bending.

g. The smallest U-bend radius

Response

The smallest U-bend radius (Row 1) is [ ]ac,e nominal.

h. Tubesheet thickness with and without clad

Response

Base material thickness of the tubesheet is [ ]ap" nominal and the clad is I ]ac,, thick minimum. Together the tubesheet with clad is [ ]a,¢ce minimum.

Page 3 of 12

LTR-SGMP- 15-25 NP-Attachment

i. The naming convention for the U-bend support structures and a more detailed diagram (since it appears that there are various supports running between the vertical straps within the tube bundle)

Response

Reference:

Section 5.1.3 of SQN RSG ECT Examination Guidelines (L18140513801).

Support structure measurements are provided in Table 5.2 while Figure 5.2 illustrates a cross-sectional view of the steam generator tube support-structures and specific support nomenclature. Table 5.3 lists all dimensional and design specifics relative to the support structures within the Sequoyah steam generators and Table 5.4 gives the U-bend support structures through which the various tubes pass. Table 5.5 lists tube dimensions by row with respect to straight and curved sections. Figures 5.3 through 5.7 show representative drawings of the supports and Ventilated Support Bars (VSB). Table 5.6 gives the support nomenclature.

Sequoyah 2 Support Structure Measurements Location Inches from TE Center to Center a,c,e Table 5.2 Page 4 of 12

LTR-SGMP-15-25 NP-Attachment Westinghouse Model 57AG+

a,c,e Figure 5.2 Page 5 of 12

LTR-SGMP- 15-25 NP-Attachment SEQUOYAH 2 RSG DESIGN SPECIFICS Tubesheet Data:

]a,c,e Hole diameter -

Pitch - [ ]a,c,e Thickness - [ ]a,c,e Expansion process - Hydraulic (full expansion)

Tube Support Data:

Hole geometry - [ ]a,c,e Lattice dimensions - [ ]a,c,e Width x thickness - [ ]a,c,e Material - [ ]a,c,e Ventilated Support Bar Data:

Lock Bar Shape - [ ]a,c,e Width x thickness - [ ]a,c,e Straps Shape - [ ]a,c,e Width x thickness - a,c,e Material - [ ]a,c,e Tube Data:

OD - [ ]a,c,e

]a,c,e ID - [

Wall thickness:

Nominal - [a,c,e Number of tubes/SG - [ ]a,c,e U-bend radius:

Maximum - [ ]a,c,e Minimum - r Iac'e Table 5.3 Sequoyah 2 RSG U-Bend Support Intersections Rows Structures through which the Tubes Pass a,c,e Table 5.4 Page 6 of 12

LTR-SGMP- 15-25 NP-Attachment Sequoyah 2 RSG ATSG Lattice a,c,e Figure 5.3 Sequoyah 2 RSG ATSG Top View a,c,e Figure 5.4 Page 7 of 12

LTR-SGMP- 15-25 NP-Attachment Sequoyah 2 RSG ATSG (Advanced Tube Support Grid) a,ce Figure 5.5 Sequoyah 2 RSG U-Bend Support Structures Ventilated Support Bar (VSB) a,c,e Figure 5.6 Page 8 of 12

LTR-SGMP- 15-25 NP-Attachment Sequoyah 2 RSG U-Bend Support Straps Ventilated Support Bars (VSB) a,c,e Figure 5.7 Page 9 of 12

LTR-SGMP- 15-25 NP-Attachment Sequoyah 2 RSG Tube Dimensions by Row ROW TUBES Developed ROW TUBES Developed NUMBER REQUIRED "A" "B" "C" "D"_ Length NUMBER REQUIRED "A" "B" "C" "D" Length a,c,e 4- 4 4- 4 4 4-

4. 1 4. 4 l~ 4.
4. 4 4. 4. 9 4.

4- 4 4. 4 4 4.

4. 4 4. 4. 4 4.
4. 1 4.~ 4 4 4-
4. 4 4. 4. 4 4.

4- 4 4- 4 4 4.

4- 4 4- 4 4 4.

__ I 4-

__ I I I I I 4

4 4

4 4-

______ 4.

4.

4 4.

4.

4 4.

4 I

4.

4.

4. 4. 4 4 4 4.
4. 4. 4 4 1 4.
4. 4- 4 4 4 4.
4. 4- 4 4 4- 4.

__ .1.__ 1 ____ 1- 1 1

+ 4--4 4 4- 4. 4. 4 4. 4 4 4.

4 4 + 1 4 +

Page 10 of 12

LTR-SGMP- 15-25 NP-Attachment ROW TUBES Developed ROW TUBES Developed NUMBER REQUIRED "A" "B" C "D" Length NUMBER REQUIRED "*A" "C., "I'" Il..-oh B I .4 4 4 4 4 4

  • 4 4.

.4 I .4 4 4 4 I1 I I I I_ _ 1 I. _ 4 4 4 4 4 4.

.4 1 .4 & 4 .4

4. 1* 4. 4 1- 4. 4. 4 4. 4 4.

+ 4 4. 4 4 4 4 4 4

  • 4- 4.

.4 1 .4 4 4. 4

4. *I. 4- 4 1- 4. 4. 4 4 4.

4 4 4. 4 4 4 4 4 4

  • 4. 4.

.4 4 .4 4 4. 4 1* 4 4. 4.

4 4 4. 4 4 4 4 4 4

  • 4. 4.

.4 4 .4 &...J. .4 Table 5.5 Page 11 of 12

LTR-SGMP-15-25 NP-Attachment Support Notation Description a,c,e Table 5.6 Page 12 of 12

ENCLOSURE 3 WESTINGHOUSE AFFIDAVIT FOR LTR-SGMP-15-25 P

Westinghouse Westinghouse Electric Company Engineering, Equipment and Major Projects 1000 Westinghouse Drive, Building 3 Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (724) 940-8560 11555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852 Proj letter: TVA-15-29 CAW-15-4168 April 28, 2015 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

LTR-SGMP-15-25 P-Attachment, "Response to NRC Request for Additional Information on the Design Features of the Sequoyah Unit 2 Replacement Steam Generators" (Proprietary)

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-15-4168 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 Tennessee Valley Authority.

Correspondence with respect to the proprietary aspects of the Application for Withholding or the Westinghouse Affidavit should reference CAW-15-4168, and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 3 Suite 310, Cranberry Township, Pennsylvania 16066.

Very truly yours, James A. Gresham, Manager Regulatory Compliance

CAW-15-4168 April 28, 2015 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF BUTLER:

I, Henry A. Sepp, am 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 my knowledge, information, and belief.

Henry ý. Sepp, Director CRE-Systems and Components Engineering

2 CAW-15-4168 (1) I am Director, CRE-Systems and Components Engineering, 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) I 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 Proprietary Information from Public Disclosure 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 constitute Westinghouse policy and provide 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-15-4168 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.

(iii) 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-15-4168 (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.

(iv) 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.

(v) 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.

(vi) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in LTR-SGMP-15-25 P-Attachment, "Response to NRC Request for Additional Information on the Design Features of the Sequoyah Unit 2 Replacement Steam Generators" (Proprietary), for submittal to the Commission, being transmitted by Tennessee Valley Authority letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with providing a response to an NRC staff request for additional information concerning the Sequoyah Unit 2 replacement steam generator design features, and may be used only for that purpose.

5 CAW-15-4168 (a) This information is part of that which will enable Westinghouse to:

(i) Provide the information (e.g., component dimensions, material of construction, drawings, etc.) requested by the NRC staff concerning the design features of the Sequoyah Unit 2 replacement steam generators.

(b) Further this information has substantial commercial value as follows:

(i) Westinghouse plans to sell the use of similar design features to its customers for Westinghouse replacement steam generators.

(iii) 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 design features 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 non-proprietary versions of documents furnished to the NRC associated with providing a response to an NRC staff request for additional information concerning the Sequoyah Unit 2 replacement steam generator design features, and may be used only for that purpose.

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 publi6 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.