NRC 2015-0068, Request for Additional Information for Relief Request 2-RR-11 - MF6615

Request for Additional Information for Relief Request 2-RR-11 - MF6615

ML15324A152
Person / Time
Site:	Point Beach
Issue date:	11/19/2015
From:	Mccartney E Point Beach
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML15324A319	List: NRC 2015-0068, Request for Additional Information for Relief Request 2-RR-11 - MF6615
References
CAW-15-4336, LTR-PAFM-15-108, NRC 2015-0068, TAC MF6615
Download: ML15324A152 (19)

Text

Proprietary Information- Withhold from Public Disclosure Under 10 CFR 2.390 NEXTera ENERGY ~

~-

BEACH November 19, 2015 NRC 2015-0068 10 CFR 50.55a U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Point Beach Nuclear Plant Unit 2 Docket 50-301 Renewed License No. DPR-27 Point Beach Nuclear Plant Unit 2- Request For Additional Information for Relief Request 2-RR MF6615

References:

(1) NextEra Energy Point Beach, LLC (NextEra) letter to NRC, dated August 13, 2015, 10 CFR 50.55a Request, Relief Request 2-RR-11 Unit 2 Steam Generator Nozzle to Safe-End Dissimilar Metal (OM) Weld Inspection (ML15225A104)

(2) NRC electronic mail to NextEra Energy Point Beach, LLC dated October 28, 2015, Point Beach Nuclear Plant Unit 2- Request For Additional Information for Relief Request 2-RR MF6615 By letter dated August 13, 2015 (Reference 1), NextEra Energy Point Beach, LLC (NextEra) submitted Relief Request 2-RR-11 . By Reference 2, NRC requests additional information to complete the Relief Request review. NextEra responses to the additional information request are provided in the Enclosure.

Attachment A contains one copy of the responses to the Request for Additional Information number 1 and 3 (Proprietary) to be withheld from public disclosure under 10 CFR 2. 390. Upon removal of Attachment A, this letter is uncontrolled. contains one copy of the responses to the Request for Additional Information number 1 and 3 (Non-Proprietary).

Attachment C contains the Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-15-4336, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice.

Proprietary Information- Withhold Under 10 CFR 2.390.

Attachment A Contains Proprietary Information, Upon Separation of Attachment A this letter is Non-Proprietary.

NextEra Energy Point Beach , LLC, 6610 Nuclear Road , Two Rivers, WI 54241

Proprietary Information- Withhold from Public Disclosure Under 10 CFR 2.390 Attachment A contains information proprietary to Westinghouse Electric Company LLC. It is supported by an Affidavit signed by Westinghouse, the owner of the information. The Affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390. Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure.

This letter contains no new Regulatory Commitments or revisions to existing Regulatory Commitments.

If you have questions or require additional information, please contact Mr. Bryan Woyak, Licensing Manager, at 920/755-7599.

In accordance with the provisions of 10 CFR 50.91, a copy of this submittal has been provided to the designated Wisconsin Official.

Very truly yours, NextEra Energy Point Beach, LLC Y-~~

Eric McCartney Site Vice President Enclosure cc: Regional Administrator, Region Ill, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC PSCW Mr. Mike Verhagan, Department of Commerce, State of Wisconsin Proprietary Information -Withhold Under 10 CFR 2.390.

Attachment A Contains Proprietary Information, Upon Separation of Attachment A this letter is Non-Proprietary.

ENCLOSURE NEXTERA ENERGY POINT BEACH, LLC POINT BEACH NUCLEAR PLANT, UNIT 2 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION 10 CFR 50.55a REQUEST, RELIEF REQUEST 2-RR-11 UNIT 2 STEAM GENERATOR NOZZLE TO SAFE-END DISSIMILAR METAL (OM} WELD INSPECTION Provide axial and hoop weld residual stresses without modification to include operating conditions (i.e. temperature and pressure).

Response to RAJ 1 Refer to Attachment A (Proprietary) or Attachment 8 (Non-Proprietary) for this response.

On page 2 of your request, you state that relief is being requested to extend the hot leg inspection schedule to be in line with the cold leg schedule, which is approximately 7.5 years from the previous examination. However, the cold leg inspection requirements per Code Case N-770-1 require inspections at least every 7 years. Please clarify if you are also requesting for an extension of the cold leg inspection frequency.

Response to RAJ 2 Yes, we are requesting that the cold leg inspections be performed at the same time as the hot leg inspections. Therefore, we are requesting the Code Case N-770-1 cold leg inspection interval be extended from 7 years to 7.5 years.

RAI3 In order to review NRC analysis results with the licensee's, please provide K calculations for axial and circumferential through-weld flaw growth.

Response to RAJ 3 Refer to Attachment A (Proprietary) or Attachment 8 (Non-Proprietary) for this response.

Attachment B (Non-Proprietary)

Responses to NRC RAis 1 and 3 Regarding Point Beach Unit 2 Steam Generator Primary Nozzle to Safe-end Weld Flaw Evaluation (7 pages follow)

Westinghouse Non-Proprietary Class 3 Page 1 of7 Attachment B Ourref: LTR-PAFM-15-108 November 16, 2015 Attachment B (Non-Proprietary)

Responses to NRC RAis Regarding Point Beach Unit 2 Steam Generator Primary Nozzle to Safe-end Weld Flaw Evaluation Portions of this report contain proprietary information. Proprietary information is identified and bracketed. For each of the bracketed sections, the reasons for the proprietary classification are provided using superscripted letters "a", "c", and "e". These letter designations are:

b. The information reveals the distinguishing aspects of a process or component, structure, tool, method, etc. The prevention of its use by Westinghouse's competitors, without license from Westinghouse, gives Westinghouse a competitive economic advantage.

d. The information, if used by a competitor, would reduce the competitor's expenditure of resources or improve the competitor's advantage in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product.

f The information reveals aspects of past, present, or future Westinghouse- or customer-funded development plans and programs of potential commercial value to Westinghouse.

Westinghouse Non-Proprietary Class 3 Page2 of7 Attachment B Our ref: LTR-PAFM-15-108 November 16, 2015 Responses to NRC RAis Regarding Point Beach Unit 2 Steam Generator Primary Nozzle to Safe-end Weld Flaw Evaluation The NRC submitted three RAis (Reference 1) for the crack growth analysis performed in LTR-PAFM 11-NP (Reference 2) for Point Beach Unit 2 Steam Generator primary nozzle to safe-end welds. Given below are the RAis based on the NRC email correspondence (Reference 1). NextEra Energy requested Westinghouse to provide responses to RAI Nos. 1 and 3, which are provided in this letter report.

Response to RAI No.2 will be generated by NextEra.

By letter dated August I3, 20I5, (Agencywide Documents Access and Management System (ADAMS)

Accession Number ML15225AI04), NextEra Energy submitted for US. Nuclear Regulatory Commission (NRC) staff review and approval Relief Request 2-RR-11, which requests an extension of inspection frequency of the primary Steam Generator (SG) nozzle to safe-end welds under American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Code Case N-770-I with conditions specified in I 0 CFR50. 55a(g)(6)(ii)(F) for duration of the extended license at Point Beach Nuclear Plant, Unit 2. To complete its review, the NRC staff requests the following additional iriformation:

I. Provide axial and hoop weld residual stresses without modification to include operating conditions (i.e. temperature and pressure).

2. On page 2 of your request, you state that relief is being requested to extend the hot leg inspection schedule to be in line with the cold leg schedule, which is approximately 7.5 years from the previous examination. However, the cold leg inspection requirements per Code Case N-770-I require inspections at least every 7 years. Please clarify if you are also requesting for an extension of the cold leg inspection frequency.

3. In order to review NRC analysis results with the licensee's, please provide K calculations for axial and circumferential through-weld flaw growth.

NRC RAJ I: Provide axial and hoop weld residual stresses without modification to include operating conditions (i.e. temperature and pressure).

Westinghouse Response:

The Point Beach Unit 2 steam generator primary nozzle to safe-end weld residual stresses shown in Figures 4-2 and 4-3 of LTR-PAFM-15-11-NP (Reference 2) contain the effects of normal operating pressure and temperature. The Point Beach Unit 2 steam generator primary nozzle to safe-end weld residual stresses in the as-welded condition are shown in Figures 1 and 2 in the hoop and axial direction, respectively. The welding residual stresses provided in Figures 1 and 2 do not account for normal operating pressure and temperature condition. The welding residual stresses were determined in Reference 3, and are plant specific to the Point Beach Unit 2 geometry and weld configuration as described in Section 4.0 ofLTR-PAFM-15-11-NP (Reference 2).

Westinghouse Non-Proprietary Class 3 Page 3 of7 Attachment B Ourref: LTR-PAFM-15-108 November 16, 2015 a,c,e Figure 1: Through-Wall Hoop Residual Stress at the SG Inlet and Outlet Nozzle DM Welds at the As-Welded Condition

Westinghouse Non-Proprietary Class 3 Page 4 of7 Attachment B Ourref: LTR-PAFM-15-108 November 16, 2015 a,c,e Figure 2: Through-Wall Axial Residual Stress at the SG Inlet and Outlet Nozzle DM Welds at the As-Welded Condition

Westinghouse Non-Proprietary Class 3 Page 5 of7 Attachment B Ourref: LTR-PAFM-15-108 November 16,2015 NRC RAJ 3: In order to review NRC analysis results with the licensee's, please provide K calculations for axial and circumferential through-weld flaw growth.

Westinghouse Response:

The stress intensity factors used in the Point Beach Unit 2 steam generator primary nozzle to safe-end crack growth analysis in LTR-PAFM-15-11-NP (Reference 2) were determined based on the stress intensity factor expressions from References 4 and 5 for axial and circumferential flaws, respectively, as discussed in Section 6 of Reference 2. The through-wall stress intensity factors for axial and circumferential flaws are shown in Figure 3.

The stress intensity factors were determined using a combination of stresses including the normal operating welding residual stresses from Reference 3. More specifically, the through-wall stress intensity factors shown in Figure 3 are based on the modified normal operating welding residual stresses as discussed in Section 4 ofLTR-PAFM-15-11-NP, which are provided in Figures 4-2 and 4-3 of Reference 2.

In addition to the normal operating welding residual stresses, the stress intensity factors also include normal operating steady state piping loads (deadweight and normal thermal), and effect of crack-face pressure on the crack front.

It should be noted that the stress intensity factors given in Figure 3 are based on the deepest point along the crack front. The difference between the stress intensity factor at the surface tip and the deepest tip of the crack front is small; the final crack growth results shown in Section 7.0 of LTR-PAFM-15-11-NP (Reference 2) conservatively consider the surface and deepest tip of the flaw.

Westinghouse Non-Proprietary Class 3 Page 6 of7 Attachment B Ourref: LTR-PAFM-15-108 November 16, 2015 a,c,e Figure 3: Through-Wall Axial and Circumferential Stress Intensity Factors at the SG Inlet and Outlet Nozzle DM Welds

Westinghouse Non-Proprietary Class 3 Page 7 of7 Attachment B Ourref: LTR-PAFM-15-108 November 16, 2015 References

1) NRC Email from Mahesh Chawla (NRC) to Thomas Schneider (NextEra),

Subject:

"Point Beach Nuclear Plant Unit 2 - Request For Additional Information for Relief Request 2-RR MF6615," dated October 28,2015.

2) Westinghouse Letter No. LTR-PAFM-15-11-NP, Rev. 0, "Point Beach Unit 2 Steam Generator Primary Nozzle to Safe-end Weld Crack Growth Analysis," June 2015.

3) Dominion Engineering, Inc, Document C-8850-00-01, Rev. 0, "Welding Residual Stress Calculation for Steam Generator Nozzle DMW."

4) S. R. Mettu, I. S. Raju, "Stress Intensity Factors for Part-through Surface Cracks in Hollow Cylinders," Jointly developed under Grants NASA-JSC 25685 and Lockheed ESC 30124, Job Order number 85-130, Call number 96N72214 (NASA-TM-111707), July 1992.

5) American Petroleum Institute, API 579-1/ASME FFS-1 (API 579 Second Edition), "Fitness-For-Service," June 2007.

Attachment C Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-15-4336, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice (7 pages follow)

@ Westinghouse Wes1inghouse Electric Company 1000 Westinghouse Drive 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 CAW-15-4336 November 12,2015 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

LTR-PAFM-15-108, Attachment A, "Responses to NRC RATs Regarding Point Beach Unit 2 Steam Generator Primary Nozzle to Safe-end Weld Flaw Evaluation" (Proprietary)

The Application for Withholding Proprietary Information from Public Disclosure is submitted by Westinghouse Electric Company LLC (Westinghouse), pursuant to the provisions of paragraph (b)(l) of Section 2.390 of the Commission's regulations. It contains commercial strategic information proprietary to Westinghouse and customarily held in confidence.

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-15-4336 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 NextEra Energy.

Correspondence with respect to the proprietary aspects of the Application for Withholding or the Westinghouse Affidavit should reference CAW-15-4336, 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,

!1~

ffames A. Gresham, Manager Regulatory Compliance

CAW-15-4336 November 12,2015 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF BUTLER:

I, James A. Gresham, 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, infonnation, and belief.

fames A. Gresham, Manager Regulatory Compliance

2 CAW-15-4336 (1) I am Manager, Regulatory Compliance, 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 CPR 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 Co'mmission in detennining 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 detennining the types of information customarily held in confidence by it and, in that collllection, 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-15-4336 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, orfuture Westinghouse or customerfunded 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 infonnation 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 infonnation.

(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

4 CAW-15-4336 (d) Each component of proprietary information pertin,ent 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 infonnation sought to be withheld in this submittal is that which is appropriately marked in LTR-PAFM-15-108, Attachment A, "Responses to NRC RAis Regarding Point Beach Unit 2 Steam Generator Primary Nozzle to Safe-end Weld Flaw Evaluation" (Proprietary), for submittal to the Commission, being transmitted by NextEra Energy 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 technical justification to support extended volumetric examination interval for Point Beach Unit 2 steam generator primary nozzle to safe-end dissimilar metal welds, and may be used only for that purpose.

(a) This information is part of that which will enable Westinghouse to provide technical justification to support extended volumetric examination interval for

5 CAW~15-4336 Point Beach Unit 2 steam generator primary nozzle to safe-end dissimilar metal welds.

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

(i) Westinghouse plans to sell the use of similar information to its customers for the purpose of providing technical justification to support extended volumetric examination interval for steam generator primary nozzle to safe end dissimilar metal welds.

(ii) Westinghouse can sell support and defense of industry guidelines and acceptance criteria for plant-specific applications.

(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 technical evaluation justifications 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 infom1ation.

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 perfom1ed and a significant manpower effott, 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 fracture mechanics technical justification to support extended volumetric examination interval for Point Beach Unit 2 steam generator primary nozzle to safe-end dissimilar metal welds.

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 infonnation 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)(t) of the Affidavit accompanying this transmittal pursuant to 10 CPR 2.390(b)(l).

COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the infonnation 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 pennitted 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 proprietmy notice ifthe original was identified as proprietary.