ML18040A240
| ML18040A240 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 12/15/1995 |
| From: | Abbott R NIAGARA MOHAWK POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML17059B019 | List: |
| References | |
| RTR-NUREG-0619, RTR-NUREG-619 NMP1L-1014, TAC-M89792, NUDOCS 9512220190 | |
| Download: ML18040A240 (47) | |
Text
- PRL(3RI EY 1
(ACCELERATED RIDS PROCESSING REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9512220190 DOC.DATE: 95/12/15 NOTARIZED: YES DOCKET FACIL:50-220 Nine Mile Point Nuclear Station, Unit 1, Niagara owe 05000220 AUTH.NAME AUTHOR AFFILIATION ABBOTT,R.B.
Niagara Mohawk Power Corp.
RECIP.NAME RECIPIENT AFFILIATION e
Document Control Branch (Document Control Desk)
P 0
R
SUBJECT:
Forwards response to NRC 951109 RAI re NUREG-0619, "BWR FW Nozzle
& CRD Return Line Nozzle Cracking"
& GE proprietary nonproprietary documents.GE proprietary documents withheld t
per 10CFR2.790.
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RICNARD B. ABBOTT VIce Prestdent NueIear Generathn 0 MQolgggfg NIAGARAMOHAWKPOWER CORPORATION/NINE MILEPOINT NUCLEARSTATION, P.O. BOX 63, LYCOMING,N.Y.13093/TEL (315) 349.1812 FAX(315) 34%4417 December 15, 1995 NMP1L 1014 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 RE:
Nine Mile Point Unit 1 Docket No. 50-220 DPR-
Subject:
Response
to Request forAddMonal lqformation Dated November 9, 1995, Regarding NUREG-0619, "BWR Feed)vater Nozzle and Control Rod Drive Return Line Nozzle Cracking, " (TAC No. MS9792)
Gentlemen; By letter dated November 9, 1995, the Staff requested additional information regarding Nine MilePoint Unit 1's (NMP1) letter dated June 23, 1994 (NlVP1L 0829).
The NMP1 letter was submitted to inform the NRC of Niagara Mohawk's decision to amend our commitment with respect to NUREG-0619, "BWR Feedwater Nozzle and Control Rod Drive Return Line Nozzle Cracking."
In the November 9, 1995 Request for Additional Information, the Staff requested information for those areas dealing with establishing the capabilities of detecting and sizing cracks; establishing the validity of modeling; and establishing the fracture mechanics.
The requested information is attached.
Enclosures 1 through 4 were prepared by General Electric.
Enclosures 2 and 3 are considered by their preparer, General Electric, to contain proprietary information exempt from disclosure pursuant to 10CFR2.790.
Therefore, on behalf of General Electric, Niagara Mohawk hereby makes application to withhold these documents from public disclosure in accordance with 10CFR2.790(b)(1).
Affidavits executed by General Electric detailing the reasons for the request to withhold the proprietary information have been included as Attachment 6.
Non-proprietary versions of these documents willbe provided by January 31, 1996.
Very truly yours, 2-OO36 R. B. Abbott Vice President - Nuclear Generation In'512220190 9'51215 PDR ADOCK 05000220 P
PDR gg t@/8(
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RBA/TWEVlmc Enclosures Page 2 xc:
(without enclosures)
Regional Administrator, Region I Mr. B. S. Norris, Senior Resident Inspector Mr. L. B. Marsh, Director, Project Directorate I-l, NRR Mr. G. E. Edison, Senior Project Manager, NRR Records Management
ATTACHMENT RESPONSE TO REQUEST FOR ADDITIONALINFORMATION DATED NOVEMBER 9, 1995 REGARDING NUREG-0619, "BWR FEEDWATER NOZZLE AND CONTROL ROD DRIVERETURN LINE NOZZLE CRACKING," (TAC NO. M89792) 1.
Establishing the capabilities of detecting and sizing cracks:
a.
Identify the areas of the nozzles that could be missed because of physical interferences or areas in which the transducer angles may not be optimized to detect and size shallow cracks.
Response
Physical interferences are unique to each nozzle.
When obstructions limited automated UT examinations, these areas were inspected utilizing manual techniques.
Areas with less than 100% coverage are documented on speciJ7c data sheets identifying the limitation and percent ofcoverage obtained.
Even withphysical scan limitations essentially 100% ofthe ID was examined Pom at least one direction.
The ultrasonic parameters (beam and rotation angles) used in the modeling were optimized to obtain the best overall coverage for detection and sizing of flaws.
With these parameters, the entire inside diameter (ID) surface is examined with sound beam-to flaw angles within the bounds determined on GE's nozzle mockup.
The boundary limitsfor the GE Nozzle Modeling are documented in General Electric Nuclear Energy Report GE-NE-C3100016-02.
b.
Provide a copy of the ultrasonic test (UT) procedure that NMPC willuse for the inner-radius examination. Ifnot part of the procedure, identify the detection and sizing techniques that NMPC willbe using.
Response
GE procedures utilized at Nine Mile Point Unit 1 for detection and sizing of Inner-radius examinations were:
Detection procedure UT-NMP-703VO Rev. 0 UT-NMP-311 VO Rev. 0 Sizing Procedure UT-NMP-309VO Rev. 0 These procedures are provided as Enclosure 4.
Page 1 of 12
0
Identify the demonstration NMPC is using for the qualification demonstration of the GERIS-2000.
Describe any deviations NMPC made from the GE Procedure.
Response
The qualification demonstration utilized by NMPCfor the GERIS-2000 was performed by General Electric Nuclear Energy and documented in GE Report ¹ GE-NE-508-038-0394.
The qualification ofthe GERIS-2000 is based on testing offull-scale mockups.
The qualification mockups incorporated EDM notches and fatigue cracks.
Detection of the fatigue cracks coupled with extensive qualificatio with the EDM notches provides confirmatio ofthe effectiveness for detecting and sizing fatigue cracks with the GERIS-2000 UT system.
No deviations Porn the GE procedures were made during examination ofNMPCfeedwater nozzles or the control rod drive return nozzle.
Describe how cracks originating from a grind-out or any other condition unique to NMPC would be detected and sized.
Response
The techniques for detection and sizing ofcracks originating Pom the bottom ofthe grindout would be the same as the techniques for the ID surface ofthe nozzle bore.
To demonstrate this, an axial grindout was made in a nozzle mockup and axial EDM notches were placed in the bottom surface ofthe grindout.
The EDM notches were readily detected.
Since grindouts can not be modeled with the GE Modeling techniques, manual calculations using AutoCad to determine misorientation at the bottom ofthe grindout were performed.
Describe the acceptance criteria for the UT inspections, including how these criteria equate to the GE qualification demonstration.
Discuss sensitivity and changes in sensitivity during the examination.
How do these sensitivity settings compare with the settings used during the GE qualification demonstration'2
Response
The acceptance criteria for the UTinspections or definin relevant indications is described in UT-NMP-703VO Rev. 0 and UT-NMP-311VO Rev. 0. Both ofthese procedures use the baseline noise for definin relevant indications.
Acceptance criteria ofrelevant indications is based upon ASME Section XI, 1983 Edition Summer 83 Addenda, Table IWB-3512-1 and NUREG 909 acceptance for a.25 postulated flaw and applying Pacture mechanics over the life ofthe plant.
Page 2 of 12
The qualification plan focused on portions ofASME Section XI Appendix VIIIthat are applicable to the feedwater nozzle inspection.
Flaw depths in the range of0.105" to 0.375" were in the sample set, encompassing the 0.250" basis in NUREG 0619.
The examination sensitivities were the same as the qualtftcation.
The GERIS-2000 UTImaging System used for the Nine Mile Unit 1 examinations is afixe gain logarithmic ultrasonic system (i.e., no settings can be changed except through internal hardware configuratio).
No hardware changes were made during the examination and sensitivities were the same as the qualification.
c)
Describe any blind examinations performed using the GERIS-2000 equipment (by GE, NMPC, and/or the UT examiner) and/or NMPC's UT procedures that are applicable to the NMPC inner-radius feedwater nozzle-to-vessel and control rod drive return line (CRDRL) nozzle-to-vessel configurations.
Include a discussion on false calls.
Response
GERIS-2000 UT System qualification and Appendix VIIIdemonstrations are as follows:
1992 Nuclenor (Spain) required that the GERIS-2000 and procedures be qualifie on under clad flaws.
The qualification was performed Pom the clad surface.
A "blind test" was performed on a RPV test specimen provided by Nuclenor.
Nofalse calls were made and the sizing statistics were within the criteria ofAppendix VIII.
1993 EKM (Switzerland).
A demonstration was performed prior to the examination ofthe RPVPom the inside surface.
The demonstration met the criteria ofNE-14.
NE-14 is the equivalent to our ASME Code.
1993 Spirit ofAppendix VIIIqualificatioforBrown Ferry Nuclear.
This was a "blind test" qualtftcation.
The qualification was for the GERIS-2000 system, procedures and personnel.
False calls were within the Appendix VIIIcriteria.
The qualification was performed Pom the inside surfaces (through the cladding) ofthe RPV.
EPRI was the test administrators.
1994 PDI Appendix VIIIqualification.
The qualification was in accordance with the PDIprotocol.
The qualification results met the criteria established in the PDIprotocol.
False calls were also within the criteria.
1994 Unclad Nozzle Qualification.
GE performed a qualification on unclad feedwater nozzles.
This qualification was not a "blind test. " The qualtflcation plan was based on testing full-scale mockups.
The qualtflcation plan focused on specific portions ofAppendix VIIIthat could be applied to the feedwater nozzle inspection.
Flaw depths encompassed the 0.250 basis in NUREG-0619.
Page 3 of 12
H
)9
The flaw sizing statistical measurement criteria provided by Appendix VIIIwas applied to the flaw sizing to generate a measurement that can be compared to the actual notch depth.
The sizing criteria ofAppendix VIIIwas met.
Nineteen EDM notches and two crack implants were used for the qualificatio flaws.
Reference GE Report No. GE-NE-508-038-0394 forfurther information pertaining to the qualification.
1995 NUREG-0619 qualificatio on clad feedwater nozzles.
This qualification involved the detection and sizing ofcracks.
A "blind test" was performed on 4 notches and 2 cracks.
The detection portion was a "non-blind test. "
However, detection criteria ofprocedures was demonstrated to 1VRR, 1VRC Region IIand EPRI on the ability ofthe GERIS-2000 and techniques to detect flaws.
Included in the demonstration was the methods and techniques used in the implementation ofnozzle modeling.
Modeling was used in the qualification program to locate the "most dificult"inspection area with the proposed techniques.
In this area ofthe nozzle, a 0.150" deep crack >vas placed in the carbon steel (0.4" including clad).
d.
Discuss the indications detected during the 1995 RFO-13.
Include noninnocuous indications that were detected, as well as indications that were observed in previous examinations.
Response
No indications ofcracking were recorded during UT examinations ofNMPC feedwater nozzles or the control rod drive return nozzle during RFO 13.
Geometric indications such as, clad noise, nozzle bore reflections, and shear redirect were recorded and documented on data sheets where noted.
Indications observed in previous examinations are summarized below and listed in NMPC submittal to the US Nuclear Regulatory Commission dated 10/3/95, NUREG-0619, "BWR Feedwater Nozzle and Control Rod Drive Return Line Nozzle Cracking ".
During the 1981 refueling outage (RFO-8), an inservice UT examination ofthe fourfeedwater nozzles was performed by 1VES and also by GE.
An apparent change Pom the baseline examination was observed.
Further evaluation required removal ofthe sparger Pom the southeast nozzle.
Based on the results ofthe additional nondestructive examinations, Niagara Mohawk concluded that the UTindication was caused by a geometric reflector and not by a crack in the nozzle.
A new feedwater sparger was installed in the southeast nozzle.
The design ofthe new sparger was the same as the replacement spargers installed during the 1977 refueling outage.
During the 1983 safe-end outage, inservice inspections ofthe feedwater nozzles were not required by NUREG-0619 schedule commitment.
However, the nozzles were examined by 1VESforinformation only. An increase in the amplitude ofthe signalPom the geometric reflector in the southeast nozzle was Page 4 of 12
noted.
A more rigorous evaluation ofthis indication was performed during the 1984 refueling outage clearly identifying and documenting that this reflector is geometric and has exhibited no growth or change.
During the 1986 refueling outage (RFO-10), inservice UT examinations ofthe fourfeedwater nozzles were performed by NES.
No significant changes from the previous examinations were identijfed.
During the 1988 refueling outage (RFO-ll), inservice UT examinations ofthe fourfeedwater nozzles were performed by NES.
These examinations identified approximately 25 indications in the vicinityofthe nozzle to safe-end weld of the northeast nozzle "A"at 45 degrees.
Although these indications might have been caused by scratch marks made during sparger installation, we conservatively evaluated them as cracks.
NUREG 0619, Section 4.3.2.3 states, "ifrecordable indications are interpreted to be cracks in any nozzle, proceed with sparger removal, PT ofthe nozzle bore and nozzle blend radius,
'nd repair." Eighteen ofthe twentyflve indications were observed at 20 to 25% ofthe distance amplitude correction curve (DAC). However, the applicable ASME Code recording criteria is 50% DAC.
Therefore, these indications were not "recordable" and did not require further evaluation.
The remaining indications appeared to be two separate flaws, one located in the nozzle and one located near the safe end weld.
The indications appeared at approximately 50% DAC.
The flaws were axially oriented and their size well within the ASME Section XIacceptance criteria (alt-4.7% and 7% versus allowable of11.02% and 11.23%).
The examination was performed using a 45 degree shear wave transducer on a calibration standard with a 5% T-notch reflector.
The Code permits calibration on notches up to 10% T (Tis the nominal thickness ofthe calibration block).
Consequently, the examination sensitivity exceeds the Code required sensitivity. Ifa 10% T notch had been used, these indications may not have been recordable per ASME Section XI.
Considering that the examination was performed at a higher sensitivity than required by Code, that the indications are at the threshold ofthe recording criteria, and that the indications willremain within allowable size for at least the next two operating cycles, Niagara Mohawk determined that further evaluation ofthese indications was not required.
APacture mechanics evaluation ofthese twoflaws was performed.
The results ofthe analysis predicted growth ofthe flaws not to exceed 0.001 inches over a 40-year period.
Therefore, the conclusion was made that the flaws were not significan and should not acct continued plant operation.
Additionally, Niagara Mohawk committed to examine feedwater nozzle "A"during the next refueling outage (1993).
Page 5 of 12
5 b
I
During the 1993 refueling outage (RFO-12), inservice UT examinations of feedwater nozzle "A" (N4A) Zones 1, 2, 3 and 4 were performed by General Electric Nuclear Energy (GE-NE).
Note the indications identtfied in 1988 (RFO-11) were contained in Zone 4 (safe-end bore region) ofN4A.
The same ultrasonic techniques were employed as used during the 1988 refueling outage (RFO-ll) examinations, other than, the calibration standard was modtji ed to include Code allowable 10% notches as well as the previously used 5%
notches.
The examinations indicated no reportable indications.
The Zone 4 indications detected in the 1988 outage were seen but not at recordable levels based on either the 5% or 10% notch calibrations.
Electric Power Research Institute (EPRI) sizing techniques were then attempted to see ifan adequate through-mall dimension could be attained on the previously recorded indications. Although a base signal could be seen, no tip signals were noted with either the Relative Arrival Time technique or the Absolute Arrival Time technique.
Since no tip could be resolved, the source ofthese reflectors was determined to bePom scratches or inside diameter (ID) surface irregularities and notPom ID cracking.
These inservice inspection results have been reviewed and approved by a Niagara Mohawk Level IIIexaminer.
By letter dated June 23, 1994 (NMPIL 0820), NMPC informed the Commission, and provided technical basis for, utilization ofthe GE GERIS 2000 automated system (UT)forfuture examinations in lieu ofperforming a PT.
This amended our prior NUREG 0619 commitment.
In a letter dated January 12, 1995, the NRC determined that it was acceptable for NMPC to proceed with the described commitment changes and the NMPC would be advised ofthe ftnal results ofthe NRC review.
During the 1995 refueling outage (RFO-13), inservice examinations were performed onfour (4)feedwater and the control rod drive return line nozzles.
These UT examinations were performed by GE-NE utilizing the GERIS 2000 automated system and manual UTpickups.
No reportable indications were noted with the GERIS 2000 system or during manual examinations.
- However, the indications noted in the safe-end bore region during the 1988 and 1993 outages were seen in the same locations at less than recordable levels.
e.
Describe when manual UT would be used to supplement the GERIS-2000 examination, along with the appropriate technique.
Response
Manual examinations were only performed when physical interferences limited automated examination coverage. Ifcracklike indications were noted with the automated system, manual methods would be utilized to verify location and
'size.
Manual techniques forflaw detection uses shear waves with both compound and single angle beam >vedge designs.
Manual techniques forflaw Page 6 of 12
E I'
sizing utilize shear waves producing a beam angle between 45'and 60'ith respect to the plane ofthe flaw.
Establishing the validity of modeling a.
Describe the extent to which modeling is being used for the preparation and implementation of the UT examination, that is, the percentage of coverage, transducer selection, flaw characterization, and so on.
Response
Modeling is used to characterize the procedure's performance during the initial qualtftcation ofthe UTsystem and techniques as well as the projected performance ofthe proposed techniques on the Nine Mile Point Unit 1 nozzle.
Modeling together within the initialprocedure qualtftcation determines what the maximum misorientation ofthe sound beam toflaw can be tolerated.
Proposed techniques are evaluated with the modeling process.
Only those techniques that produce acceptable results (i.e., acceptable misorientation angles) are used for the examinations.
SpectJic information on percentage of coverage and transducer selection is detailed in b. below.
b.
What is the limiting "mis-orientation" (the maximum acceptable angle from ideal for a returning signal) angle being used?
How was the angle established?
Identify the transducers being used and provide coverage maps or a composite coverage map.
Describe the locations and the percentage of examination for the areas that willexceed the limiting "mis-orientation" angle.
Response
The maximum misorientation angle used was 37'or the feedwater nozzle and 27'or the CRD return line.
The misorientation angle was established on a series ofEDM notches and crack implants that are 0.250 inches in through wall depth on the feedwater nozzle and 2% of "T" crackfor the CRD return line.
The data for the feedwater nozzle is referenced in GE Proprietary Report GE-NE-C3100016-02 dated January 1995.
Coverages ofthe examination area are:
1)for the feedwater nozzle, 100% of the modeled area was within the maximum misorientation angle established value of37'nd 2)for the CRD return nozzle, 97% ofthe examination area was within the maximum misorientation angle of27'.
The transducers used for the Nine Mile Unit 1 Feedwater Nozzle were:
1) 60'nd 65'hear wave Pom the vessel plate; 2) 65.5 Shear Wave Pom the Nozzle Outer Blend Radius; 3) 39.6'nd 21.2'hear Waves from the Nozzle Barrel; 4) 45'hear wave Pom the Nozzle Taper and Nozzle Taper to Safe end Blend Radius; and 5) 45'hear wave on the Safe End OD surface.
Page 7 of 12
,i4
~
The transducers used for the Nine Mile 1 CRD return nozzle were:
- 1) 45',
60', 65'nd 70'hear Wave Pom the vessel plate; and 2) 65.5'hear Wave Pom the Nozzle Outer Blend Radius.
The preceding transducers were scanned in both the clockwise and counter
, clockwise directions on the feedwater nozzles and CRD return nozzle.
Modeling coverage maps for the above scans are contained in GE Report GENE-955-002-0195, "Nine Mile Unit 1 Feedwater Nozzle Analysis, dated January 20, 1995, "provided as Enclosure l. Allareas ofthe bore and bottom ofthe grindouts were under the maximum misorientation angle.
C.
Describe the differences between the model and the NMPC configuration.
Explain how the model was verified for accuracy.
Explain how the model is representative of the NMPC configuration.
Response
There are no differences in the model and the Nine Mile configurations with the c t' o the rind t.
The geometries in the model are based upon the Nine Mile nozzle dimensions Pom fabrication drawings and applicable as-built clad-removed machining modification drawings.
The modeling of grindouts (worst case grindout) is assessed separately by using an AutoCad program.
This assessment is made by constructing a 3 dimensional model of the ID and OD nozzle conj7guration.
The bottom surface ofthe grindout was constructed in the 3d model.
UT beam vectors were projected to the grindout ID surface and the misorientation angles measured.
As mentioned previously, this was performed on the worst case grindout.
The Model is verij7ed for geometric accuracy by comparing the output with other models and commercial Cad packages, and fabrication drawings.
For additional details refer to GE Report GE-NE-955-002-0195, "Nine Mile Unit 1 Feedwater Nozzle Analysis, "provided as Enclosure l.
Establishing the fracture mechanics:
a, Identify which zone in Figure 1, page 4 of Enclosure 3 (Technical Basis for Utilization...), of your June 23, 1994, submittal has the largest sizing tolerance and explain the effects of the tolerance on fracture mechanics calculations.
Response
Based upon the sizing data, the maximum undersizing was in the Zone 2 area.
The value was 0.051" as referenced in Table 4 ofGE Report No. GE-NE-508-038-0394.
Page 8 of 12
V S
4
Flaw sizing tolerance can be accounted for when entering the crack growth curves.
The number ofstress cycles or operating years for any detected flaw to grow to any pre-determined finalflaw size can be determined Pom Figure 3-6 in References (1) and P).
Flaw size tolerance due to ultrasonic test uncertainty can 'be accounted for by increasing, as necessary, the assumed size ofthe detected flaw over that reported in the inspection.
Compare the operational history (startup-shutdown cycles and feedwater thermal transients) with GE's generic duty cycle.
Response
A comparison ofthe NMPl operational history with GE's generic duty cycle is provided in Appendix A ofReference (1).
The NMP1 spectflc load cycles are summarized in Table 1 and the GE generic duty cycles are summarized in Table 2.
The fracture mechanics analysis uses the GE-deflned load cycle but modtfles it to reflect NMPl speci(Pc conditions, including:
~
Actual plant operating parameters.
~
Plant experience regarding number ofcycles.
~
Plant configuration that impacts cycle duration or magnitude, such as:
Routing ofReactor Water Cleanup (RWCU) return flowto the feedwater lines (1979).
Improved lowflow (feedwater) control (1984) although leakage through main feedwater control valves was significant enough to reduce the lowflow control effectiveness.
Closing the block valve for the main flow control valve associated with the operating motor-driven feed pump to stop leakage during lowflow operation (1990).
This action made lowflow control effective.
While the NMP1 plant specric thermal cycles are, in general, less severe than the GE generic duty cycles, they are based on actual plant conditions and physical modifications that were made specifically to reduce thermal transient severity.
Therefore, the plant specijfc loads are the appropriate ones for this analysis.
The GE generic duty cycles were not used for the fracture mechanics analysis and are provided for comparison only.
Page 9 of 12
Table 1 NMP1 Feedwater Nozzle Load Cydes r".:.':P.,'",:>Nu'ntb'er'!'of,~'i.:i'~ li'::!'¹intber':,'of,:Sub'.>>'j,i!':',.:",,",";TeNp'e'ra'tux e:.,'i:;,':
'ji':gi.:':-:;1,:cjclii1:
Startup/Shutdown Scram to LP Hot Standby and Return to Power 1
1 16 20 1'9 0
402 22 63 199 22 66 1030 955 0
0 1094 0
0 Table 2 GE Generic Duty Feedwater Nozzle Load Cycles
'i;:5,:;,:Li,'.:::;::Cy'cie:';:.':,":,":,'-:.,;,':.:::
Startup/Shutdown
'!:,::;,::::i:.:;¹iiiib'er'.;,'off>+<',".,',.jII';.:mNu'n'tb'er'::,of;:,,Sub'-. j
- -';';,"
- i;Cy'cle's/Yr'.',",".,.@~,.";. >;,,'Cy'cies:,Per",;:;Cycle "i
1 1
27 12 N'j%>.Range +T:;::.('"..F)ki'")
0 385 330 200 1050 930 0
0 Scram to LP Hot Standby and Return to Power 9.75 1
11 60 330 330 200 1080 0
0 c.
In the analysis of the CRDRL, identify the stresses used for computing cyclic crack loads.
Response
Stresses for the fatigue crack growth analysis ofthe CRDRL nozzle are provided in Appendix H ofReference P).
Stresses Pom the following two load cases were used:
Reactor Pressure = 1250 psig Reactor Fluid Temperature = 525'F CRDRL Fluid Temperature = 70'F 2.
Reactor Pressure = 1250 psig Reactor Fluid Temperature = 525'F CRDRL Fluid Temperature = 525'F Page 10 of 12
~
~
Stresses used for the analysis were taken along a worst case path through the nozzle, approximately a 4$'ngle through the blend.
Table 3 lists the ftnite element analysis stress results for the two load cases.
Table 3 Stress Analysis and Curve Fit Results g$$91s'taen'ce'hr'o'u jh;:%all.'!(i')"'('"'j:::::q4%<:::i~@5pg< '::. (8 ?N<pe.??:.'g <?<'ze;.;f p+j:,"e;:,:;fjgj":::Mm?>N@g?'Pfp???@)Ngj fp::.j??"@gpss pp<?Ye 0.1128 0.2256 0.3384 0.4511 0.5639 0.6767 0.7895 0.9023 1.0151 110.0 91.2 88.9 86.2 83.3 80.8 78.4 76.1 74.1 72.1 65.3 56.4 55.5 54.2 52.8 51.5 50.3 49.1 48.0 47.0 R~eferene MPR-1484, Revision 0, "Nine MilePoint Unit 1 Feedwater Nozzle Fatigue Evaluation," dated April 1994.
2.
MPR-1485, Revision 0, "Nine Mile Point Unit 1 Control. Rod Drive Return Nozzle Fatigue Evaluation," dated April 1994.
Enclo ur for RAI on NURE 61 1.
GENE-955-002-0195 dated January 20, 1995, "Nine MileUnit 1 Feedwater Nozzle Analysis."
2.
GENE-C3100016-02 dated January 16, 1995, "GE Nozzle Modeling for the Assessment of UT Examination Techniques."
3.
GE-NE-508-038-0394 Rev. 1, dated April20, 1994, "GERIS 2000 Ultrasonic Inspection of Feedwater Nozzles."
Page 11 of 12
4.
GE Nuclear Energy Procedures UT-NMP-703VO Rev. 0, UT-NMP-309VO Rev. 0, and UT-NMP-311VO Rev. 0.
5.
Nine MilePoint Unit 1 Report of Reactor Pressure Vessel Feedwater and Control Rod Drive Return Line Nozzle Examinations (NUREG-0619).
6.
General Electric affidavits on GENE-C3100016-02 and GE-NE-508-038-0394 Rev. 1.
Items Previ usl ent 2.
MPR-1484, Revision 0, "Nine Mile Point Unit 1 Feedwater Nozzle Fatigue Evaluation," dated April 1994.
MPR-1485, Revision 0, "Nine MilePoint Unit 1 Control Rod Drive Return Nozzle Fatigue Evaluation," dated April 1994.
Page 12 of 12
General Electric Company AFFIDAVIT I, David J. Robare, being duly sworn, depose and state as follows:
(1) I am Project Manager, Technical Services, 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 the GE proprietary report GENE-C3100016-02, "GE Nozzle Modeling for the Assessment ofUT Examination Techniques",
Class III (GE Company Proprietary Information), dated January 16, 1995.
The proprietary information is delineated by bars marked in the margin adjacent to the specific material.
(3)
In making this application for withholding ofproprietary information ofwhich 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),
2.790(a)(4),
and 2.790(d)(1) for "trade secrets and commercial or financial information obtained from a person and privileged or confidential" (Exemption 4).
The material for which exemption from disclosure is here sought is all "confidential commercial information", and some portions also qualify under the narrower definition of "trade secret",
within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, C
97272d271 Cld 21. 19927, d
y+~, 704F2d1280 (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 ofits use by General Electric's competitors without license from General Electric constitutes a competitive economic advantage over other companies; b.
Information which, ifused by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance ofquality, or licensing ofa similar product; l2/l3/93RTH AffidavitPage 1
c.
Information which reveals cost or price information, production capacities, budget levels, or commercial strategies of General Electric, its customers, or its suppliers; d.
Information which reveals aspects of past, present, or future General Electric customer-funded development plans and programs, of potential commercial value to General Electric; e.
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 both paragraphs (4)a. and (4)b., above.
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 forth 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 ofthe 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 ofexternal release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager ofthe cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive eQect, and determination ofthe accuracy ofthe 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.
The information identified in paragraph (2), above, is classified as proprietary because it contains detailed results of analytical models, methods and processes, which GE has developed, for the examination ofFeedwater Nozzles.
This development was achieved at a significant cost, on the order of one million dollars, to GE. Itconstitutes a significant GE asset.
12/l3/93RTH AffidavitPage 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 withNRC-approved methods.
The research, development, engineering, analytical and NRC review costs comprise a substantial investment oftime and money by GE.
The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficultto quantify, but itclearly is substantial.
GE's competitive advantage willbe lost ifits competitors are able to use the results of the GE experience to normalize or verify their own process or ifthey are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.
The value ofthis information to GE would be lost ifthe 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.
12/13/93RTH AffidavitPage 3
STATE OF CALIFORNIA
)
)
COUNTY OF SANTACLARA
)
ss:
David J. Robare, being duly sworn, deposes and says:
That he has read the foregoing aAidavit and the matters stated therein are true and correct to the best ofhis knowledge, information, and belief.
Executed at San Jose, California, this l~
day of 1995.
PAUtA F. HUSSEY COMM. 01046120 Notcrry Public Ca9fornia SANTAClARACOUN1Y MyCcmm. Expires DEC 1.1998 David J. Robare General Electric Company Subscribed and sworn before methis~ day of ~isor i995.
Notary Public, State ofCal'nia l2/13/93RT11 Affidav>tPage 4
f T'l 1
W
.i +~~of Q
.ez 1g+fj V/
General Electric Company AFFIDAVIT I, David S. Robare, being duly sworn, depose and state as follows:
(1) I am Project Manager, Technical Services, 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 the GE proprietary report GE-NE-508-038-0394 Revision 1, "GERIS 2000 Ultrasonic Inspection of Feedwater Nozzles", Class III (GE Company Proprietary Information), dated April 20, 1994.
The proprietary information is delineated by bars marked in the margin adjacent to the specific material.
(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),
2.790(a)(4),
and 2.790(d)(1) for "trade secrets and commercial or financial information obtained from a person and privileged or confidential" (Exemption 4).
The material for which exemption from disclosure is here sought is all "confidential commercial information", and some portions also qualify under the narrower definition of "trade secret",
within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, 97992d271 91C C1
. 19927, d
z~M, 704F2d1280 (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 ofits use by General Electric's competitors without license from General Electric constitutes a competitive economic advantage over other companies; b.
Information which, ifused by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance ofquality, or licensing ofa similar product; 12/13/93RTH AffidavitPage I
I
c.
Information which reveals cost or price information, production capacities, budget levels, or commercial strategies of General Electric, its customers, or its suppliers; d.
Information which reveals aspects of past, present, or future General Electric customer-funded development plans and programs, of potential commercial value to General Electric; e.
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 both paragraphs (4)a. and (4)b., above.
(5)
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 forth 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 ofthe 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 ofexternal release ofsuch a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager ofthe cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination ofthe accuracy ofthe 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, which GE has developed, for the examination ofFeedwater Nozzles.
This development was achieved at a significant cost, on the order of one million dollars, to GE. It constitutes a significant GE asset.
12/l3/93RTH AffidavitPage 2
A I
(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 withNRC-approved methods.
The research, development, engineering, analytical and NRC review costs comprise a substantial investment oftime and money by GE.
The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is diQicultto quantify, but itclearly is substantial.
GE's competitive advantage willbe lost ifits competitors are able to use the results of the GE experience to normalize or verify their own process or ifthey are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.
The value ofthis information to GE would be lost ifthe information were disclosed to the public.
Making such information available to competitors without their having been required to undertake a similar expenditure ofresources 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.
12/13/93RTH AffidavitPage 3
'4
STATE OF CALIFORNIA
)
)
COUNTY OF SANTACLARA
)
ss:
David J. Robare, being duly sworn, deposes and says:
That he has read the foregoing affidavit and the matters stated therein are true and correct to the best ofhis knowledge, information, and belief.
Executed at San Jose, California, this
>~
day of 3)EC 864 1995.
pAULAF. KUSSEy COMM.410461 Netrsry putsiic Caiifomia 4p SANTACLARACOUN1Y MyComm. Expires OEC 1,19%
David J. Robare General Electric Company Subscribed and sworn before me this ~
day of J 1995.
Notary Public, State ofCalif ia 12/l3/93RTH AffidavitPagg 4
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