ML20059D481

Requests That Proprietary WCAP-12672, Steam Generator Sleeving Rept Laser Welded Sleeves Jm Farley Units 1 & 2, Be Withheld Per 10CFR2.790(b)(4)

ML20059D481
Person / Time
Site:	Farley
Issue date:	08/14/1990
From:	Wiesemann R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19307A549	List: ML20059D461 ML20059D468 ML20059D481 ML20059D485
References
CAW-90-063, CAW-90-63, NUDOCS 9009070057
Download: ML20059D481 (16)

Text

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Westinghouse Energy Systems Ba 355 Electric Corporation Pittsburgh Pennsylvama 15230 035$  ;

August 14, 1990 I

CAW-90-063 Document Control Desk US Nuclear Regulatory Commission ,

Washington, DC 20555 Attention: Dr. Thomas Murley, Director APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE  !

Subject:

" Steam Generator Sleeving Report - Laser Welded Sleeves . J. M.  ;

Farley Units 1 and 2" (WCAP-12672)

Dear Dr. Murley:

The proprietar,i information for which withholding is being requested in the above-referenced letter is further identified in Affidavit CAW-90-063 signed by the owner of the proprietary information, Westinghouse Electric Corporation.

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 2.790 of the Commission's regulations.  !

. Accordingly, this letter authorizes the utilization of the accompanying  !

Affidavit by Alabama Power Company.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-90-063, and should be addressed to the undersigned.

Very truly yours,

/0 0 Robert A. Wiesemann, Manager Enclosures Regulatory & Legislative Affairs  ;

cc: C. M. Holzle, Esq.

Office of the General Counsel, NRC V. Wilson, NRR 9009070057 DR 900816 ADOCK 0500o34g PDC j u

CAW-90-063 AFFIDAVIT COMMONWEALTH Of PENNSYLVANIA:  !

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COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally apper. red Robert A. Wiesemann, who, being by me-duly sworn accordira to law, ,

deposes and says that he is authorized to execute this Aifidavit on i behalf of Westinghouse " tric Corporation (" Westinghouse") and that l the averments of fact at forth in this Affidavit are true and correct - I to the best of his knowledge, information, and belief:

Robert A. Wiesemann, Manager Regulatory- and Legislative Affairs Sworn to and subscribed before me this // day of[hthMb ,1990.

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l CAW 90 063 l (1) I am Manager, Regulatory and Legislative Affairs, in the Nuclear and Advanced Technology Divisiot , of the Westir .ouse Electric Corporation und as such, I have been specifically delegated the function of reviewing  !

the proprietary in.'ormation sought to be withheld from public disclosure in connection with nuclear power plant licensing and rulemaking proceedings, and am authorized to apply for its withholding on behalf of the Westinghouse Energy Systems Business (Jnit'.

(2) I am making this Affidavit in conformance with the provisions of 10CFR j Section 2.790 of the Commission's regulations and in conjunction with the Westinghouse application for withholding accompanyino this Affidavit.

(3) I have personal knowledge of the criteria and procedures utilized by the  ;

Westinghouse Energy Systems Business Unit 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 2.790 of the i Commission's regulations, the following is furnished for consideration by ,

the Commission in determining whether the information sought to be withheld from public disclosure should be withheld, i (i) The information sought to be withheld from public disclosure n owned and has been held in confidence by Westinghouse.

i CAW-90-063  ;

i (ii) The information is of a type cestomarily held in confidence by Westinghouse and not customarily disclosed to the public.

Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to j hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides 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 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 anantage, e.g., by optimization or improved marketability.

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CAW-90-063 1

(c) Its use by a competitor would reduce his expenditure of l resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of.

quality, or licensing a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of f

potential commercial value to Westinghcuse.

(f) It contains patentable ideas, for wt.ich patent protection may be desirable.

(g) It is not the property of Westinghouse, but must be treated

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as proprietary by Westinghouse according to agreements with the owner.

Ihcre are sound policy reasons behind the Westinghouse system which include the following:

(a) Iha use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors.

It is, therefore, withheld from disclosure to protect the i Westinghouse competitive position. '

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l CAW-90-063 (b) It is information which is marketable in many ways. The extent to which such information is available to- i competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.

4 (c) Use by our competitor would put Westinghouse at a ,

competitive disadvantage by reducing his expendi;ure of resources at our expense.

i (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the enH te puzzle, thereby depriving Westinghouse of a com, itive 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.

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CAW-90-063 (iii) The informa ; ion is being transmitted to the Commission in i confidence and, under the provisions of 10CFR Section  ;

2.790, it is to be received in confidence by.the  !

Commission.

r (iv) The information sought to be protected is not available in -j public sources or available information has not been previously employed in the same original manner or method ,

to the best of our '.nowledge and belief.

(v) The proprietary information sought to be withheld in this N .

submittal is that which is appropriately marked in " Steam l Generator Sleeving Report - Laser Welded Sleeves" for Joseph M. Farley Units 1 and 2, WCAP-12672, (Proprietary) being trant.nitted by the Alabama Power Company (APCo) ,

letter and Application for Withholding Proprietary Information from Public Disclosure, Mr. W. G. Hairston III,  !

APCo, to Document Control Desk, attention Dr. Thomas l Murley, August, 1990.- The proprietary information as submitted for use by Alabama Power Company for Joseph M.

Farley Units 1 and 2 is expected to be applicable in other licensee submittals in response to certain NRC requirements for justification of use of laser welded sleeving in steam generator tubes, i

CAW 90-063

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[{ This information is part or that which will enable Westinghouse to:

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T (a) Provide documentation of the methods for laser welded 4 sleeving of steam generator tubes.

(b) Establish applicable testing methods, en (c) Establish the use of fiber optics in laser welded i sleeving applications. .

(d) Establish applicable codes and standards which are to be applied to-the process.

e (e) Assist the customer to obtain NRC aporoval.

E' Further this information has substantial commercial value as follows:

(a) Westinghouse plans to sell the use of similar information to its customers for purposes of meeting i

_ NRC requirements for li censing documentation.

(b) Westinghouse can sell support and. defense of the i technology to its customers in the licensing process.

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Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of destinghouse because it would enhance i%e ability of competitors to provide similar sleeving services and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.

In order for competitors of Westinghouse to duplicate this-information, similar technical programs would have to be performed and a significant manpower effort, having-the '

requisite talent and experience, woula have to be expended for developing testing and analytical methods and performing tests.

Further the deponent sayeth not, t

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.. Attachment 3 10CFR50.92 Significant Hazards Consideration h

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NS PL RCSCL 90 255, Rev. 1 PAGE 2 0F 7 l

REPAIR OF STEAM GENERATOR TUBES USING LASER WELDED SLEEVES J. M. FARLEY NUCLEAR PLANT UNITS 1 AND 2 >

$1GNIFICANT HAZARDS CONSIDERATION ANALYSIS i

INTRODUCTION L As required by 10 CFR 50.91 (a)(1) this analysis is provided to demonstrate  !

h that a proposed license amendment to implement repair of tubes e ing tube sleeves for the Farley Nuclear Plant Units 1 and 2 steam generators represents no significant h'azards consideration. In-accordance with the three factor test of 10 CFR 50.92(c), implementation of the proposed license l-amendment was analyzed using the following standards and found not to: 1)

involve a significant increase in the probability or consequences for an #

! accident previously evaluated; 2) create the possibility of e new'or i

different kind of accident from any accident previously evaluated; or 3) involve a significant reduction in a margin of safety.

Due to the importance of the barrier provided by the steam generator tubes, maintenance of tube bundle integrity has been provided for by regular j inspection of the tubes and removal from service-of tubes which have indication of degradation in excess of specified~ criteria.- A repair method using sleeves placed inside the tubes at the location of the degradation has been developed. The sleeves are short lengths of tubing with an outside

{ diameter less than the inside diameter of the degraded tube. The sleeve is i placed inside the tube and is joined at the top and bottom by a. laser welding process to sound portions of the tube. The installed sleeve in a degraded or

! defective tube restores the integrity of the barrier provided by the tubes l be' ween the primary and secondary fluids Using Technical Specification tube plugging criteria without provision for

[ sleeving, tubes with indications of degradation'in excess of the plugging i criteria would have to be removed from service. Removal of a tube from service results in a reduction of reactor coolant flow through the steam a

generator. This small reduction in flow has an impact on the margin in the i

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NS.PL RCSCL 90 259. Rev. 1 PAGE 3 0F 7 J

l reactor coolant flow through the steam generator in LOCA analyses and on the heat transfer efficiency of the steam generator. Repair of a tube with sleeving maintains the tube in service and results in a much smaller flow I l reduction. Therefore the use of sleeving in lieu of plugging would minimize y

loss of margin in reactor coolant system flow and assist in assuring that .

minimum flow rates are maintained in excess of that required for operation at full power. Also, minimizing.the reduction in flow has operational benefits

and minimizis the increase in heat flux across the tubes remaining in l

service, 4ncreased heat fluxes hau been associated with an increased potential for tube corrosion.

The proposed amendment would modify a portion of the Technical Specifications to specify the requirements for the repair of a steam generator tube by I

installation of sleeves with laser welded joints. Currently, Farley Units 1 and 2 Technical Specifications include requirements for repair using sleeves with mechanical joints for those steam generator tubes with addy current indications showing greater than 40% through wall degradation. The current Technical Specification language was established before the proposed sleeving repair method using laser welded joints to repair tubes and maintain the tubes in service was developed for Farley Units 1 and 2. The proposed Technical Specification change would specify the requirements for repairing degraded or defective tubes utilizing sleeves with laser welded joints in the Farley Units I and 2 steam generators. The proposed amendment also includes criteria for allowable wall degradation in the sleeve and in the tube in the region of the sleeve to tube joint.

ANALYSIS

'l Conformance of the proposed amendments to the standards for a determination of no significant hazard as defined in 10 CFR 50.92 (three factor test) is shown in the following:

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l NS PL RCSCL 90 259. Rev. 1 PAGE 4 0F 7 l I) Operation of the Farley Units 1 and 2 in accordance with the proposed j license amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

l TL supporting technical anet safety evaluations of the subject amendment l (Westinghouse WCAP 12F!, "Farley Units 1 and 2, Steam Generator Sleeving i Report, (Laser Welded Sieeves)" (Proprietary) and WCAP 12673, "Farley Units 1 and 2, Steam Generator Sleeving Report. (Laser Welded Sleeves)"

! (Non-Proprietary)) demonstrate that repair of degraded tubes using

! sleeves will result in tube bundle integrity consistent with the original

design bssis.

The sleeve configuration has been designed and analyzed in accordance l with the rules of the ASME Boiler and Pressure Vessel Code. Fatigue and stress analyses of the sleeved tube assemblies produced acceptable results. Mechanical testing has shown that the structural strength of -

the sleeves under normal, faulted and upset conditions is within acceptable limits. Leak rate testing has demonstrated that the leak rates of the joints between the sleeve and the existing tube under normal, faulted and upset conditions are well below acceptable rates.

The existing Technical Specification leakage rate requirements and accident analysis assumptions remain unchanged in the event significant leakage from the sleeve would occur. Any leakage through the sleeved region of the tube due to hypothetical localized tube degradation is fully bounded by leak before break considerations and ultimately the existing steam generator tube rupture analysis included in the Farley Units 1 and 2 Final Safety Analysis Report Update. The proposed Technical Specification change to support the installation of laser welded joint sleeves does not adversely impact any other previously evaluated design basis accident or the results of LOCA and Non-LOCA accident analyses. The results of the qualification testing, analyses, _

and plant operating experience demonstrate that the sleeve-assembly is an acceptable means of maintaining tubes in service. Furthermore, per

NS PL RCSCL 90 259, Rev. 1  !

PAGE 5 0F 7 Regulatory Guide 1.83 recomendations, the sleeved tube can be monitored through periodic inspections with present addy current techniques.

Plugging limit criteria are established in the technical specifications for the tube in the region of the sleeve and the sleeve. These measures demonstrate that installation of sleeves which span degraded areas of the tube will restore the tube to its original design basis.

2) The proposed license amendmer,t does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Implementation of the proposed tube degradation repair method does not introduce significant changes to the plant design basis. Repair of tubes does not provide a mechanism to result in an accident outside of the sleeved area. Any hypothetical accident as a result of potential tube or sleeve degradation in the repaired portion of the tube would be bounded by the existing tube rupture accident analysis.

J) The proposed license amendment does not involve a significant reduction in a margin of safety.

The sleeve repair of degraded steam generators tubes as identified in sleeving report has been demonstrated to restore the integrity of the tube bundle under normal and postulated accident conditions. The safety factors used in the design of sleeves for the repair of degraded tubes are consistent with the safety factors in the ASME Boiler and Pressure Vessel Code used in steam generator design. The plugging limit criteria for the sleeve has been established using the method of Regulatory Guide 1.121. The design of the sleeve joints has been verified by testing to preclude significant leakage during normal and postulated accident conditions. Use of the ASME Code and Regulatory Guide 1.121 criteria and methods assures that the margin to safety with respect to structural integrity is the same for the sleeves as for the original steam generator tubes.

NS PL RCSCL 90 259, Rev. 1 PAGE 6 0F 7 The effect of sleeving on the design transients and accident safety analyses has been reviewed based on the installation up to the level of the licensed plugging level. The installation of sleeves can be evaluated as the equivalent of some level of steam generator tube plugging. The Farley Units 1 and 2 steam generators are currently licensed to 10 percent steam generator tube plugging (SGTP). An evaluation is being completed to support an increase of the licensed plugging level to an average of 15 per cent with up to 20 percent in the most plugged steam generator. Evaluation of the installation of sleeves is based on the determination th.; LOCA evaluations for the licensed tube plugging level bound the effect of a combination of tube plugging and sleeving up to an equivalent of the licensed SGTP. For the purpose of assessing the impact on the non LOCA safety analyses and the design transients, it has been determined-that the analyses and evaluations for the licensed plugging level bound the effect of up to the equivalent SGTP' due to a combination of sleeving and plugging, therefore, the non-LOCA safety analyses and design transients are not adversely impacted by steam generator sleeving.

The safety margins in the analysis of postulated accident conditions and L design transients are provided in the assumptions and conservatism in

the calculations and computer codes used and in the requirements and l

recomendations of the NRC. Accordingly, based on the information outlined above, there is no decrease in the safety margins defined in the bases of the plant Technical Specifications.

Implementation of tube repair by sleeving will decrease the number of

, tubes which must be taken out of nervice with tube plugs. Installation of tube plugs reduces the RCS flow margin, thus implementation of tube repair by sleeving will maintain the margin of flow that would otherwise be reduced in the event of increased plugging. Based on the above, it is concluded that.the proposed change does not result in a significant reduction in a loss of margin with respect to plant safety as defined in the Updated Final Safety Analysis Report or the bases of the plant technical specifications.

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NS PL RCSCL-90 259 Rev. l~

PAGE 7 0F 7 CONCLUSION Based on the preceding analysis it is concluded that operation of J. M. ,

Farley Nuclear Plant Units 1 and 2 in accordance with the proposed amendment does not result in the creation of an unreviewed safety question, an increase ,

in the probability of an accident previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, nor reduce any margins to plant safety. Therefore, the license amendment does nnt involve a significant Hazards Consideration as defined in 10 CFR 50.92.

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