ML20012G340
| ML20012G340 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 02/16/1993 |
| From: | Denton R BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML17227A830 | List: |
| References | |
| TAC-M82505, NUDOCS 9302240407 | |
| Download: ML20012G340 (12) | |
Text
..
' DALTIMORE GAS AND ELECTRIC -
1650 CALVERT CUFFS PARKWAY. LUSBY, MARYLAND 20657-4702 ROBERT E. DENTON VICE PR[siotNT NUCLEAR ENERGY (4:0)260 4455 February 16,1993 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit No. 2; Docket No.50-318 Response to NRC's Request for Additional Information Regarding Baltimore Gas and Electric Company's Response to the 1991 Pressurized Thermal Shock fPTS) Rule. dated July 15.1992 (TAC NO. M82505)
REFERENCES:
(a)
Letter from Mr. D. G. Mcdonald, Jr. (NRC) to Mr. G. C. Creel (BG&E), dated July 15, 1992, Safety Evaluation for BG&E's Response to the 1991 PTS Rule,10 CFR 50.61, and Request for AdditionalInformation (b)
Letter from Mr. G. C. Creel (BG&E) to Document Control Desk (NRC), dated December 13,1991, Response to the 1991 PTS Rule (c)
Letter from Mr. G. C. Creel (BG&E) to Document Control Desk (NRC), dated May 22,1992, Response to NRC's Request for Additional Information Regarding BG&E's Response to the 1991 PTS Rule, dated March 31,1992 (d)
Letter from Mr. D. G. Mcdonald, Jr. (NRC) to Mr. G. C. Creel (BG&E), dated March 31,1992, Request for Additional Information Concerning BG&E's Response to the 1991 PTS Rule Gentlemen:
This letter provides Baltimore Gas and Electric Company's (BG&E) response to your request for additional information (RAI) transmitted by letter dated July 15,1992 (Reference a). The RAI pertains to the chemistry values of the Unit 2 reactor vessel welds reported in BG&E's response to the 1991 pressurized thermal shock (PTS) rule (References b and c). The specific request and our response are as follows:
hb
).
p[g 1
9302240407 930216
[ //[ h ~[
ADOCK0500g8 7
g DR
Document Control Desk
' Februay 16,1993 Page 2 REOUEST:
The staff requests that the licensee provide additionalinformation that demonstrates that the reported weight percent of copper and nickelfor weld seams 2-203-A,B,C in the reactor vessel of Cah'en Cliffs 2 comply with the requirements inparagraph (b)(2)(iv) of the amended PTS mie.
1.
The licensee shouldprovide: (a) the number and source of weld samples made with weld uire heat 8746 and (b) the amount ofcopper reponedfmm each sample.
2.
If the reponed value of copper (0.12 percent) is not a mean value from weld samples, the licensee is requested toprovide a best estimate of the amount of copper based on: (a) an upper limit from the material specification, (b) a conservative estimate based on generic data, or (c) the default value reponed in the amended PTS rule. Ifgeneric data is utilized, pmvide the data and identify its source (i.e., vessel and weld wire heat identity, material specification, and date ofitsfabrication relative to Calvert Cliffs 2).
3.
Since the amount of nickel is unknown for weld wire heat 8746, the licensee is requested to provide a best estimate of the amount of nickel based method (a), (b), or (c) in the previous paragraph.
4.
Based on the best estimate of weightpercent copper and nickelfor weld seams 2-203-A, B, C, the licensee is requested to detennine when the Cah'ert Cliffs 2 reactor vessel is pmjected to
?
reach the PTS screening criteria documented in 10 CFR 50.61.
RESPONSE
Hackereund:
In response to the 1991 PTS rule (Reference b), BG&E reported that the copper and nickel values for welds made with Weld-Wire Heat A8746 to be 0.12 wt. % and 1.01 wt. %, respectively. (Since nickel data could not be found for this wire, the value of 1.01 wt % reported for Ni was an upper-bound estimate.) Subsequent to that, in response to NRC's March 31,1992, RAI (Reference d),
BG&E reported that a review of fabrication records performed by Asea Brown Boveri/ Combustion Engineering (ABB/CE) had produced information which was expected to result in a substantial reduction in the nickel value for Weld-Wire Heat A8746 (Reference c).
On July 15,1992, NRC issued the Safety Evaluation for BG&E's response to the 1991 PE Rule, including a request for additional information on Weld Wire Heat A8746 (Reference a). Since i
Weld-Wire Heat A8746 was also used in reactor vessels at other CE-designed nuclear plants, BG&E.
proposed expanding the previous ABB/CE fabrication records review effort through the Combustion Engineering Owners Group (CEOG) to provide basis for the copper and nickel content. The proposal was accepted by CEOG, and the review task has since been completed. Attachment (1) is i
the non-proprietary version of the CEOG report documenting the records review study.
Attachment (2) is an ABB/CE proprietag affidavit for Attachment (3), pursuant to 10 CFR 2.790.
Attachment (3) is the proprietary version of the report.
i ls
Document Control Desk February 16,1993 Page 3 Resp <mse to Item 1:
The number and source of weld samples made with Weld-Wire Heat A8746 and the amount of copper reported from each sample is provided in the attached CEOG report.
Response to Item 2:
The reported value of copper (0.12 percent) was not a mean value from weld samples, it was a measured value of one weld sample. A conservative best estimate value of copper for Weld-Wire Heat A8746 is 0.16 Wt-Fc. A combination of actual sample data and " generic" data are utilized as the basis for this value. The justification is provided in the attached CEOG report.
Response to item 3:
A conservative best estimate value of nickel for Weld-Wire Heat A8746 is 0.10 WtNc. This value is a mean plus one standard deviation based on " generic" data. The justification is provided in the attached CEOG report.
Response to item 4:
Based on the best estimate of weight percent copper (0.16) and nickel (0.10) for Weld Scams 2-203-A, B, C, the Calvert Cliffs Unit 2 reactor vessel will not reach the PTS screening criteria before the end of the current 40-year Operating License nor the end of a 20-year renewed license period, should it be pursued.
Using 0.16 Wi#c copper and 0.10 Wt-Fc nickel, the new RTpn alues for Welds 2-203-A, B, C are v
as follows:
End of Cycle 9 (fluence value 1.57E19 n/cm )
RTyn = 98.8 F 2
End of 40-year license (fluence value 4.28E19 n/cm )
RTyn = 118.3 F 2
End of 60-year license (fluence value 6.35E19 n/cm2)
-RTyn = 124.3 F The 10 CFR 50.61 PTS screening criteria for axial weld materialis 270 F.
CONCLUSION The findings from the CEOG records review have substantially improved the embrittlement projections for welds made with Weld-Wire Heat A8746.
~.
Document Control Desk February 16,1993 Page 4 Hennest for NRC Action:
The current Calvert Cliffs Unit 2 Technical Specification Pressure / Temperature (P/F) limits, which are also based on the previously reported chemistry value for Weld-Wire Heat A8746, are valid for a
up to 12 Effective Full Power Years (EFPY) of operation. Calvert Cliffs Unit 2 is projected to reach 12 EFPY as early as May 1994. Based on the new findings, we plan to submit a Technical Specification amendment request to extend the P/r limits beyond 12 EFPY. Since the use of the new chemistry values is contingent upon your acceptance, we request notification by May 1,1993, to.
allow timely licensing action.
i Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
Very trulyyours,
, y j
'QgW for R. E. Denton Vice President - Nuclear Energy RED /GT/MEB/gt/ dim Attachments:
(1)
Report No. CE NPSD-906-NP, "CEOG Program to Evaluate Chemical Content of Weld Deposits Fabricated Using Heats A8746 and 348009, CEOG Task 747," February 1993; Non-Proprietary (2)
Proprietary Affidavit for Attachment (3)
(3)
Report No. CE NPSD-906-P, "CEOG Program to Evaluate Chemical Content - of Weld Deposits - Fabricated Using Heats A8746 and 34B009, CEOG Task 747," February 1993; Proprietary i
cc:
. (Without Attachments) i D. A. Brune, Esquire J. E. Silberg, Esquire 3
R. A. Capra, NRC D. G. Mcdonald, Jr., NRC T. T. Martin, NRC P. R. Wilson, NRC R. I. McIzan, DNR J. H. Walter, PSC l
l
i ATTACHMENT (1)
I I
i Report No. CE NPSD-906-NP l
i "CEOG Program to Evaluate Chemical Content of Weld Deposits Fabricated Using Heats A8746 and 34B009" CEOG Task 747 i
February 1993 Non-Proprietary l
i j
i Baltimore Gas & Electric Company Docket No. 50-318 February 16,1993 I
Y
-%^
j i
i A1TACHMENT (2) i.
Proprietary Affidavit for Attachment (3) l r
s I
r
.i i
i
-Baltimore Gas.& Electric Company Docket No. 50-318 l
February 16,1993
)
)
-)
J
- . a.
,,2
ATTACIB1ENT (3)
Report No. CE NPSD-906-P I
i "CEOG Program to Evaluate Chemical Content of Weld Deposits Fabricated Using Heats A8746 and 34B009" P
4 CEOG Task 747 February 1993 I
Proprietary t
i 9
i f
=:
Baltimore Gas & Electric Company l
Docket No. 50-318
.l February 16,1993 l
i t
r w
.--v-
=
AFFIDAVIT PURSUANT TO 10 CFR 2.790
\\
Combustion Engineering, Inc.
)
State of Connecticut
)
County of Hartford
)
SS.:
I, S. A. Toelle, depose and say that I am the Manager, Nuclear Licensing, of Combustion Engineering, Inc., duly authorized to make this affidavit, and have reviewed or caused to have reviewed the information which is identified as proprietary and referenced in the paragraph immediately below.
I am submitting this affidavit in conjunction with Baltimore Gas & Electric Company for withholding this information in conformance with the provisions of 10 CFR 2.790 of the Commission's regulations.
The information for which proprietary treatment is sought.is contained in the following document:
CE NPSD-906-P, "CEOG Program to Evaluate Chemical Content of Weld Deposits Fabricated Using Heats A8746 and 34B009," February 1993.
This document has been appropriately designated as proprietary.
I have personal knowledge of the criteria anu procedures utilized by Combustion Engineering in designating information as a trade secret, privileged or as confidential commercial of financial information.
[
Pursuant to the provisions of paragraph (b) (4) of Section 2.790
{
of the Commission's regulations, the following is furnished for i
consideration by the Commission in determining whether the L
3-information sought to be withheld from public disclosure, included in the above referenced document, should be withheld.
1.
The information sought to be withheld from public disclosure, which is owned and has been held in confidence by Combustion Engineering, is the reactor pressure vessel weld material specifications and procedures.
2.
The information consists of test data or other similar data concerning a process, method or component, the application of which results in substantial competitive advantage to Combustion Engineering.
3.
The information is of a type customarily held in confidence by Combustion Engineering and not customarily disclosed to the public.
Combustion Engineering 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 details of the aforementioned system were provided to the Nuclear Regulatory Commission via letter DP-537 from F.
M.
Stern to Frank Schroeder dated December.2, 1974.
This system was applied in determining that the subject document herein is proprietary.
4.
The information is being transmitted to the Commission in confidence under the provisions of 10 CFR 2.790 with the a
. l understanding that it is to be received in confidence by the Commission.
5.
The information, to the best of my knowledge and belief, is not i
available in public sources, and any disclosure to third parties has been made pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence.
6.
Public disclosure of the information is likely to cause substantial harm to the competitive position of Combustion Engineering because:
a.
A similar product is manufactured and sold by major pressurized water reactor competitors of Combustion Engineering.
b.
Development of this information by C-E required hundreds of thousands of manhours and millions of dollars.
To the best i
of my knowledge and belief, a competitor would have to i
undergo similar expense in generating equivalent j
information.
l c.
In order to acquire such information, a competitor would also require considerable time and inconvenience to ascertain the reactor pressure vessel weld material
]
specifications and procedures.
d.
The information required significant effort and expense to obtain the licensing approvals necessary for application of i
I
4.-
the information.
Avoidance of this expense would decrease a
competitor's cost in applying the information and marketing the product to which the information is applicable.
e.
The information consists of the reactor pressure vessel weld material specifications and procedures, the-application of which provides a competitive economic advantage.
The availability of such information to competitors would enable them to modify their product to better compete with Combustion Engineering, take marketing or other actions to improve their product's position or impair the position of Combustion Engineering's product, and avoid developing similar data and analyses in support of their processes, methods or apparatus.
f.
In pricing Combustion Engineering's products and services, significant research, development, engineering, analytical, P
manufacturing, licensing, quality assurance and other costs l
and expenses must be included.
The ability of. Combustion Engineering's competit"rs to utilize such information without similar expenditure of resources may enable them to t
sell at prices reflecting significantly lower costs.
I g.
Use of the information by competitors in the international i
marketplace would increase their ability to market nuclear 1
steam supply systems by reducing the costs associated with l
their technology development.
In addition, disclosure would have an adverse economic impact on Combustion-i
. es Engineering's potential for obtaining or maintaining foreign licensees.
Further the deponent sayeth not.
/3
- 5. R.
I S.
A. Toelle Manager Nuclear Licensing Sworn to before me this
/.2AL day of
- Mm u>
1993 d ma wn rs e
Notary Public My commission expires: /[3/[9F
,