ML20037A219
| ML20037A219 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 04/17/1979 |
| From: | Counsil W NORTHEAST UTILITIES |
| To: | Reid R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7904230266 | |
| Download: ML20037A219 (11) | |
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NORTHEAST UTILITIES w uwo ew aw aw cr*=%'
P.O. BOX 270 3 C 2. M sY cb s, HARTFORD. CONNECTICUT 06101 hb b
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k L IJ April 17, 1979 Dccket No. 50-336 Director of Nuclear Reactor Regulation Attn:
Mr. R. Reid, Chief Operating Reactors Branch #4 U. S. Nuclear Regulatory Commission Washington, D. C.
20555
References:
(1)
W. G. Counsil letter to R. Reid dated December 18, 1978.
(2)
W. G. Counsil letter to R. Reid dated January 24, 1979.
(3)
W. G. Counsil letter to R. Reid dated Fbrch 29, 1979.
Gentlemen:
Millstone Nuclear Power Station, Unit No. 2 CEA Guide Tube Inspection Program In References (1), (2), and (3), Northeast Nuclear Energy Company (NNECO) provided information concerning the Sleeved CEA Guide Tube Inspection Program.
Subsequently, the NRC Staff has raised additional questions regarding the program. The purpose of this letter is to respond to those questions, and provide some preliminary results of the inspection program.
Responses to the questions noted above are provided in the attached report, CEN-106 (N)-P.
The response to Question 2 in the attached report states that pull tests are not planned for the center guide tube sleeves. lovever, as verbally indicated to the NRC Staff, pull tests will be performed on at least one center guide tube sleeve to the load indicated in CEN-106(N)-P.
Preliminary inspection results of the eddy-current testing of ten (10) fuel assem-blies prior to fuel movement indicated no detectable wear in any of the fif ty (50) sleeves inspected.
Some under expansion of the sleeves was observed and reported as a signal voltage. A total of five sleeves were inspected with a more sophis-ticated eddy-current probe to confirm the analysis of the testing with regard to the under expansion. These test results confirmed the existence of a 360* ring of under expansion. The two assemblies with the highest under expansion voltage readings are candidates for sleeve pull tests.
79042302%15
These results are preliminary in nature and must still be verified. Ilowever,
they are being reported here to maintain timely communication of results.
Due to the proprietary nature of the material contained in CEN-106(N)-P, NNECO requests that CEN-106(N)-F be withheld from public disclosure in accordance with the provisions of 10CFR2.790 and that this material be saf eguarded. The reasons for the classification of this material as proprietary are delineated in the enclosed affidavit provided by Combustion Engineering.
Copies of the non-proprietary version of this document are also provided.
Very truly yours, NORTIIEAST NUCLEAR ENERGY COMPANY
,I, (f/]l I
W. G. Counsil Vice President At tachment 4
AFFIDAVIT PURSUANT T010 CFR 2.790 Combustion Engineering, Inc.
)
State of Connecticut
)
County of Hartford
)
SS.:
I, P. L. McGill depose and say that I am the Vice President, Commercial 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 conformance with the provisions of 10 CFR 2.790 of the Commission's regulations and in conjunction with the application of Northeast Utilities dated March 29, 1979, for withholding this information.
The information for which proprietary treatment is sought is contained in the following document:
CEN-106(N)-P, Response to N.R.C. Questions To " Millstone Nuclear Power Station, Unit No. 2, Sleeved CEA Guide Tube Inspection Program",
Docket No. 50-336, March 29,1979.
This document has been appropriately designated as proprietary.
I have personal knowledge of the criteria and procedures utilized by Combustion Engineering in designating information as a trade secret, privileged or as confidential commercial or financial information.
Pursuant to the provisions of paragraph (b)-(4) of Section 2.790 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, included in the above referenced document, should be withheld.
i 1.
The information sought to be withheld from public disclosure is specific inspectida and equipment information, which is owned and has been 1
held in confidence by Ccqbustion Engineering.
2.
The information co'nsists of test data or other similar data concerning a process, method or component, the application of which results in a 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 documents herein are proprietary.
4.
The information is being transmitted to the Commission in confidence under the provisions of 10 CFR 2.790 with the 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 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 reactors competitors of Combustion Engineering.
b.
Development of this information by C-E required thousands of man-hours of effort and tens of thousands of dollars. To the best of my knowledge and belief a competitor would have to undergo similar expense in generating equivalent information.
c.
In order to acquire such information, a competitor would also require considerable time and inconvenience related to obtaining access to test reactor facilities and conducting extensive in-pile testing.
d.
The information required significant effort and expense to obtain the licensing approvals necessary for application of 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 supporting information, including test data relative to a process, method or apparatus, 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, manufacturing, licensing, quality assurance and other costs and expenses must be included.
The abil;.y of Combustion Engineering's competitors to utilize such information without similar expenditure of resources may enable them to sell at prices reflecting significantly lower costs.
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l g.
Use of the information by competitors in the international marketplace would increase their ability to market nuclear steam supply systems by reducing the costs associated with their technology development.
In addition, disclosure would have an adverse economic impact on Combustion Engineering's potential for obtaining or maintaining foreign licensees.
Further the deponent sayeth not.
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t P. L. McGill Vice President, Commercial Sworn to before me tnis 12th day of April 1979
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Notary Public un c reu..s. ="ny rt.cu t
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t CEN-106(N)-NP RESP 0t15E TO N.R.C. QUESTI0tlS TO "MILLST0tlE NUCLEAR POWER STATI0il, UNIT NO. 2, SLEEVED CEA GUIDE TUBE It1SPECTIGl PROGRAM", DOCKET i
NO. 50-336, MARCH 29,1979.
I APRIL 10, 1979 1
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Combustion Engineering, Inc.
i Nuclear Power Systems Windsor, Connecticut
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" LEGAL tiOTICE" "This report was prepared as an account of work sponsored by Ccmbustien Engineering, Inc.
!!either Combustion Engineering nor any person acting on its behalf:
"a.
liakes any warranty or representation, express or implied including the warranties of fitness for a particular purpose or rerchantability, with respect to the accuracy, completeness, or usefulness of the information contained in this report, or that the use of any information, apparatus, method, or process dis-closed in this report may not infringe privately owned rights; or
- b.
Assumes any liabilities with respect to the use of, or for damages resulting from the use of, any information, apparatus, t.cthod or process disclosed in this report."
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RESPONSE TO N.R.C. QUESTIONS TO " MILLSTONE NUCLEAR POWER STATION, UNIT NO. 2, SLEEVED CEA GUIDE TUBE INSPECTION PROGRAM", DOCKET N0. 50-336, MARCH 29, 1979.
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Questito State the load and basis for selection for the sleeve pull test.
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Response
The sleeve pull test load is [ ] pounds.
This load is consistent with the [ ]
pound pull test load used during initial installatien of the sleeves.
Question The center guide tube sleeve is of concern because of potentially higher thermal 1
duty (local crevice boiling, corrosion potential, etc.).
Could pull tests also i
be done for these center guide tube sleeves?
(Perhaps to spetified load for one' assembly and to complete withdrawal for the other assembly).
Response
The center guide tube is not more limiting in expected performance (local crevice boiling, corrosion potential, etc.) than the other guide tube / sleeve inter faces.
Therefore, pull tests for center guide tube sleeves are not planned.
Question State the acceptance criteria and statistical basis for the guide tube inspection program.
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Response
I The devel ameht program for eddy currcqc 'testi)g sleeved as'$cmblies has shown f
tha t, the[ *that ta;;er fr6m] Coil probes are easily capable of ~ detecting worn regions no wear tri [
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] arc.
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This standard corresponds
'.o a
[-,
] r,eductica it the sleeve cross-sectional s
area and a volume loss of [ ]oftheminimumvolume,requiredto[
] the sleeve.
If the eddy currei,t t'estina rqsul ts in indications be10u tnis standard, any fuel assembly can b'e lifted and're, se'i in any core location for en addi-tional cycle.
Therefore, text htandard,is,to be used to evaluatc initial site ECT data on a limited number bf fuel-ahemblies [
] to determir.e acceptable sleeve performance.
Tha conservatism associated with using the selected stan-dard allows positive conclusions-tron the inspection program 7.0,
[
] from high wear,cositions.
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be based on a m,
Due to the magn'f ftde of the margins discussed above, U1dications in excess of
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those cor esponding to the standard 6y only mply that the scope cf the it.-
spection should be broacened.
s Question Identify differences'in. eddy current orob'as to'be used 'for sleeve examinations relative to probes msed at th? 3DC-1. outage for guide tube examinations.
Des-cribe the calibration of the piobes and provide the resulting calibration curves.
f Respor.se The eddy current test (EC ) proces used for fuel assembly guide tube sle' eve,in-spection are smaller in diameter than th' probes usedsto inspect the inner e
diameter of guide tubes.
The sleeve inner diameter is naller than the guide s
tube inner diameter which recuttes a reduced size ELT. probe.
The[,
] coil probe has a higher frequency and a narrower focus than the
. j probes u' sed for EC-1 inspections.
TW t'odification in operating and geometric parameters was necessary to gain radial and axial resolution.
' k with a [ ] field.
The probe. used for dimuthal testing is a differentiaO] oil ]
The azinuthal ECT probe uscL at the EOC 1 jnssection was a single coil with shieldin'9 to reduce the field to a[ ] arc resulting in the same
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resosution as tne sing 10 L J co11..
The calibation standNJ for[
minimum of[ ] inch depth tapered]over[ ]of inner sleeve diameter arc,
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coil testing is based on iccntifying a Ques _ tion
' State the current Revision number and describe differences in sleeve installation
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procedures from the installation procedure used at EOC-1 (er more recently pro-vided precedure on another plant - i.e. Calvert 2).
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' Response The current sleeve installation procedure for sleeving Millstone II fuel is 00000-ESS-107 Revision 03, dated 10/18/78.
This is essentially the same pro-cedure used for the purpose of sleeving fuel at the E0C-1 with the following addition and change:
l 1.
Visually inspect tools for missing parts upon removal from pool and,
.2.
Allow full weight of expansion tools to rest on top of guide post during the expansion operations.
Question Provide the objective and specific goals of the CEA examinations, both visual j
and eddy current exams.
Describe the calibration and probe for the eddy cur-
]
rent examinations.
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Response
The purpose of the CEA inspection is to insure that the modified fuel assembly /
CEA interface geometry and the sleeve inner diameter chrome :'arface has no g
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adverse effect on the CEA cladding, j
The specific goals of the inspection program are:
1.
Determine if there are any surface indications on the control elements due j
to contact with the guide tube sleeves. (Eddy current and visual exam) 2.
Determine if there is any CEA clad thickness reduction at the elevation where the CEA enters the fuel assembly. (Eddy current exam)
The CEA probe is a differential [ ] ] cnildesigned to a resolution detection capability of [.
of CEA outer diameter arc.
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[
] indicates proprietary information i
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