ML20081D195
| ML20081D195 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood  |
| Issue date: | 03/14/1995 |
| From: | Saccomando D COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19325F501 | List: |
| References | |
| NUDOCS 9503200167 | |
| Download: ML20081D195 (17) | |
Text
.
Onnmonweahh Ediwn Company
.+:
1 tco Opm Place
- i> owners onn e, it. <m i s 9
March 14,1995 Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn:
Document Control Desk
Subject:
Response to Request for Additional Information for Application to Facility Operating Licenses:
Byron Station Units 1 and 2 NPF-37/66: 50-454 and 50-455 Braidwood Station Units 1 and 2 NPF-72/77: 50-456 and 50-457 "F* Technical Specification Amendment Request"
References:
(a)
J. Bauer letter to T. Murley dated March 20,1994, transmitting Application for Amendment to Facility Operating Licenses for Byron and Braldwood Stations pertaining to an Alternative Repair Criteria defined as F*.
(b)
D. Saccomando letter to the Document Control Desk dated December 2,1994, responding to a request for additional information on the F* methodology.
(c)
G. Dick letter to D. Farrar dated February 22,1995, requesting additional information on the F* methodology.
In reference (a), Comed requested an amendment permitting application of the F*
criteria to the Unit 1 steam generators. In reference (b), Comed responded to the NRC questions relative to the F* submittal. Reference (c) transmitted an another request for additional information. Attached is Comed's responce to this request.
Comed's response is as follows:
Attachment A contains the Staff's questions and Comed's responses, some of which refer to Attachment B, "BWNT Responses to NRC questions on F* from Topical Report BAW-10196P" dated March 8,1995, proprietary version. Also included is Attachment C, a nonproprietary version of BAW-10196P.
200054 Kinla\\byrbwdifstarrai\\1
[(/
- h
[d 9503200167 950314 I
PDR ADOCK 05000454 yM P
PDR d
umcom n,me.m>
l
J
[
t NRC Document Control Desk March 14,1995
[
i Please note that "BWNT Responses to NRC _questbns on F* from Topical Report BAW-10196P" dated March 8,1995, contains information proprietary to B&W Nuclear Technologies, supported by an affidavit signed by B&W Nuclear Technologies the owner of the information. The affidavit sets forth the basis on which tlie information f
may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.790 of the' Commission's regulation. Accordir' gly, it is requested that the information which is proprietary to B&W be withheld from public disclosure. The affidavit regarding this matter is provided in Attachment D.
Please address any further comments or questions regarding this matter to this office.
i Sincerely, Y
fg x
Denise M. Sac mando Nuclear Licensing Administrator cc: R. Assa, Braidwood Projact Manager, NRR G. Dick, Byron Project Manager, NRR S. Dupont, Senior Resident inspector, Braidwood Station l
H. Peterson, Senior Resident inspector, Byron Station i
J. Martin, Regional Administrator, Rill l
Office of Nuclear Safety, IDNS 1
i 5
i Kinla'byrbwd\\fstarrai\\2
I i
l l
l a
ATTACHMENT D
~
B&W Nuclear Technologies Affidavit 1
r I
l i
K:nla\\I"frtWd\\ f Starr ai\\7
E
' ~~ :
3,,; W
.i
.l
.1 AEFIDAVIT OF JAMFS H. TAYLOR I
JA.
M~y name is James H. Taylor. I am Manager of Licensing Services for B&W. Nuclear l
Technologies (BWNT), and as such I am authorized to_ execute this Affidavit.
t
. B.
I am familiar with the criteria applied by BWNT to determine whether certain information -
of BWNT is proprietary and I am familiar with the procedures established within BWNT to j
- ensure the proper application of these criteria.
j l
C.
In determining whether a BWNT document is to be classified as proprietary information, an initial determination is made by the Unit Manager, who is responsible for originating the
]
document, as to whether it falls within the criteria set forth in Paragraph D hereof. If the
{
information falls within any one of these criteria, it is classified as proprietary by the
]
originating Unit Manager. This initial determination is reviewed by the cognizant Section Manager. If the document is designated as proprietary, it is reviewed again by Licensing-l personnel and other management within BWNT as designated by the Manager of Licensing -
Services to assure that the regulatory requirements of 10 CFR Section 2.790 are met.
i D.
The following information is provided to demonstrate that the provisions of 10 CFR Section 2.790 of the Commission's regulations have been considered:
l
~
(i)
The information has been held in confidence by BWNT. Ccpies of the document '
are clearly identified as proprietary. In addition, whenever BWNT transmits the'-
information to a customer, customer's agent, potential customer or regulatory :
agency, the transmittal requests the recipient to hold the information as proprietary. Also, in order to strictly limit any potential or actual customer's use q
of proprietary information, the following provisien is included in all proposals s
submitted by BWNT, and an applicable version of the proprietary provision is included in all of BWNT's contracts:
2
(
.~
(, 7,
- v e
o m'
i I
AFFIDAVIT OF JAMES H. TAYLOR (Cont'd.)
.l l
r
" Purchaser may retain Company's proposal for use in ' connection with any -
contract resulting therefrom, and, for that purpose, make suchLeopies thereof as may be necessary. Any proprietary information concerning j
Company's or its Supplier's products or manufac' ring processes which is '
l i
so designated by. Company or its Suppliers and disclosed to Purchaser incident to the performance of such contract shall remain the property of Company or its Suppliers and is disclosed in confidence, and Purchaser shall not publish or otherwise disclose it to others without the written.
approval of Company, and no rights, implied or otherwise, are granted to i
produce or have produced any products or to practice or cause to be i
practiced any manufacturing processes covered thereby.
Notwithstanding the above, Purchaser may provide the NRC or any other i
regulatory agency with any such proprietary information as the NRC or l
such other agency may require; provided, however, that Purchaser shall first give Company written notice of such proposed disclosure and '
Company. shall have the right to amend such proprietary information so as to make it non-proprietary. In the event that Company cannot amend such proprietary information, Purchaser shall prior to disclosing such information, use its best efforts to obtain a commitment from NRC or such l
e other agency to have such information withheld from public inspection.
l J
Company shall be given the right to participate in pursuit of such j
confidential treatment."
.)
l i
'l 1
2
'I
yy 4
g AFFIDAVIT OF JAMFS H. TAYLOR (Cont'd.)
v:
(ii).
The following criteria are customarily applied by BWNT in a rational decision
- process to determine whether the information should be classified as proprietary.
- Information may be classified as proprietary if one or more of the following l criteria are met:
a.
Information reveals cost or price information, commercial strategies, production capabilities, or budget levels of BWNT, its customers or suppliers.
b.
The information reveals data or material concerning BWNT research or-development plans or programs of present or potential competitive advantage to BWNT.
c.
The use of the information by a competitor would decrease his expenditures, in time or resources, in designing, producing or marketing a similar product.
d.
The information consists of test data or other similar data concerning a process, method or component, the application of which results in a competitive advantage to BWNT.
e.
The information reveals special aspects of a process, method, component -
or the like, the exclusive use of which results in a competitive advantage to BWNT.
f.
The information contair.s ideas for which patent protection may be sought.
i i
3
- p-mir-mpe-w, y-w w.
>ww N
y y.-.
-)
' AFFIDAVIT OF JAMES Hi TAYLOR (Cont'd.)
k t
The document (s) listed on Exhibit "A", which is attached hereto and made a part hereof, has been evaluated in accordance with normal BWNT procedures with j
i respect to classification and has been found to contain information which falls within one or more of the criteria enumerated above. Exhibit "B",.which is l
attached hereto and made a part hereof, specifically identifies the criteria applicable to the document (s) listed in Exhibit "A".
(iii)
The document (s) listed in Exhibit "A", which has been made available to the '
United States Nuclear Regulatory Commission was made available in confidence l
with a request that the document (s) and the information contained therein be withheld from public disclosure.
l (iv)
' The information is not available in the open literature and to the best of our i
knowledge is not known by Combustion Engineering, EXXON, General Electric, Westinghouse or other current or potential domestic or foreign competitors of BWNT.
(v)
Specific information with regard to whether public disclosure of the information is likely to cause harm to the competitive position of BWNT, taking into account the value of the information to BWNT; the amount of effort or money expended by.
f BWNT developing the information; and the ease or difficulty with which the -
information could be properly duplicated by others is given in Exhibit "B".
I E.
I have personally reviewed the document (s) listed on Exhibit "A" and have found that it is considered proprietary by BWNT because it contains information which falls within one or -
more of the criteria enumerated in Paragraph D, and it is information wt*ch is customarily.
held in confidence and protected as proprietary information by BWNT. This report l
{
l i
.,. i+?,;
AFFIDAVIT OF JAMES H. TAYLOR (Cont'd.)
i comprises information utilized by BWNT in its business which afford BWNT an opportunity to obtain a competitive advantage over those who may wish to know or use the information contained in the document (s).
s AMES H. TA R
State of Virginia)
)
SS. Lynchburg City of Lynchburg)
James H. Taylor, being duly sworn, on his oath deposes and says that he is the person who subscribed his name to the foregoing statement, and that Se matters and facts set forth in the statement are true.
if;;/pt/s N-AMES H. TAYbR Subscribed and sworn before me this 101%y of Ibelv 1993.
% wA b.
Dewa Notary Public in and for the City of Lynchburg, State of Virginia.
My Commission ExpiresJuly31,1995 5
~
e ATTACHMENT A Comed's RESPONSE to the NRC's REQUEST FOR ADDITIONAL INFORMATION on F*
dated February 22,1995 t
t
[
K:nla\\byrbwd\\fstarral\\3
i i
1.
- In determining the uncertainty in measuring the F* distance with eddy current inspection methods, different probes were used (bobbin and MRPC). Also, Section 5.3.2 states that several different frequencies were utilized as well.
Please indicate what type of probe (s) and what frequencies will be used to measure the F* distance during an actualinspection.*
I
RESPONSE
The eddy current (ECT) equipment and methods that was used to develop the eddy current uncertainty value as specified in the Topical Report are consistent with the equipment and methods used during normal inservice inspections in the field.
a Both bobbin and Motor Operated Rotating Pancake Coil (MRPC) were tested to determine their accuracy in measuring the F* distance. If different acquisition and analysis equipment is used at Byron 1 or Braidwood 1, then verification shall be performed to demonstrate the Topical Report requirements for ECT uncertainty remain bounding. This verification may be performed through thS use of a i
qualification standard made to the same requirements as the qualification standard used in the Topical Report. Other means of verification may be used if they are l
determined to be equivalent to the methods and standards specified in the Topical Report.
For the qualification described in the Topical Report BAW-10196P, the bobbin data was acquired per BWNT procedure ISI-424 Rev.18, utilizing two 0.610 M/ULC Bobbin coil probes (live and reference). The top of tubesheet (TTS) and tube end were located utilizing the 35 KHz channel. The 550 KHz channel was utilized to determine the location of the roll transition. The defect was located by either the 550 KHz channel or a " TURBO" mix created by mixing the 550,300,
}
and 130 KHz differential signals. Once the defect was located, its position with respect.to the TTS and roll transition was then determined. This is consistent with normal BWNT field inspection practices.
The MRPC data was acquired per BWNT procedure ISI-510 Rev.13, utilizing a 0.590 3-coil MRPC probe with a motor unit. Although the data was acquired using the 300,200,100, and 10 KHz channels, only the 300 KHz channel was used to i
make measurements. As for the Bobbin, the specific landmarks (i.e. TTS, tube j
end, roll transition, and defect) were located, and the F* length was calculated.
This is consistent with normal BWNT field inspection practices.
j K i nla \\l>yrtwd\\ f stan al\\1 A-1
i i
2.
"The December 2,1994, submittal had attached a copy of W-D4 F* Qualification Report (BAW-10196-P). The following questions pertain to Table 5.3.3 (ECT Measurement Accuracy Comparisons):
l 1
1)
Please provide a description of how the average difference between "MRPC and Actual' and the average difference between " Bobbin and Actual" was determined (i.e. measured-actual or actual-measured), and 2). The mean value for all data sets was negative. Is there a reason all the mean values are negative (i.e. consequence of procedure)? Assuming the negative mean values are indicative of measuring a larger F* distance than the actual distance, provide the basis for anticipating that the measured value r
of F* will be larger during an inspection.'
RESPONSE
- 1) The average difference between the ECT measurements and the actual measurements were determined by subtracting the actual measurement from
.i the ECT measurement (measured minus actual).
2)
In general, a probe will "see" a defect before actually reaching it (this is the "look ahead" effect). Because the ECT probe " sees" the defect sooner, ECT typically determines the top of the defect to be closer to the top of the tubesheet and the roll transition than it physically is. For this reason, only the l
random error associated with using ECT is included in the margin allowance for determining F*. The two standard deviations added to the mean value for j
each comparison conservatively account for the random error between the ECT measurements and actual measurements.
P h
Kinla\\byrbwdifstarrai\\2 A-2 i
i I
e 3.
"In calculating the proposed F* value at a 95% confidence level, the final required F* length (F*,g ) was determined by first subtracting two standard deviations (2a) from the pullout loa,' and then computing the final value of F* using the equation in Section 5.4. Another method of determining F* at a 95% confidence levelis to add a length equal to two standard deviations of calculated F* values on the mean value of F*. If the transformation between pullout load is linear the resultant F* values will be equal. However, the transformation between F* and pullout load is nonlinear. Does the approenh in Section 5.4 produce a resultant F* which is smaller, larger, or equal to that if F* is determined by adding 2a of F* to the mean value?'
RESPONSE
Attachment B, "BWNT Responses to NRC questions on F* from Topical Report BAW-10196P", page 1 of 3, illustrates the calculation of the final required F*
length usly both approaches as shown. The approach in BAW-10196-P, Section 5.4, produces a resultant F* which is larger than determining individual F* lengths and adding 2a to the mean value. Comed considers the method used to calculate the resultant F* length to be more conservative than determining individual F* lengths.
l l
K:nla\\byrtvd\\fstarrai\\3 A-3
y, 4.
. As stated in Section 5.1.4, 'F* Determination and Correction", the most limiting condition for an F* tube to tubesheetjoint exists during faulted conditions. The axialload during faulted conditions is based on the peak primary to secondary differentialpressure. A tube which becomes locked into a tube support plate
^
during operating conditions may experience additional axial tensile loads during a steam line break. Pleasc explain if the axialload determined for faulted conditions is a bounding value when considering the blowdown loads induced into tube that is locked into one of the upper tube support plates."
RESPONSE
See Attachment B, "BWNT Responses to NRC questions on F* from Topical Report BAW-10196P", page 2 of 3 Attachment B indicated a relationship between locked tube loads and tie rod loads. This relationship is based on the sharing of support plate loads proportionally distributed between the tie rod and the tube based on geometries.
and material stiffness.
The maximum locked tube load used in F* qualification testing resulted in a postulated tie rod load considerably higher than the MSLB tie rod loads for the Byron /Braidwood generators. Therefore, the qualification testing bounds the locked tube condition for a single locked tube. It should also be recognized that additional locked tubes (n) in the vicinity would reduce the tube load by a factor of
(
1/n. The likelihood of having just one locked tube in a generator is very small and that the locked tubes resulting from a MSLB event would be even lower, thus
]
providing more conservatism in the qualification testing.
It was recognized that away from the tie rods, the TSP may deflect more,
(
potentially creating additional load contribution for a locked tube in that region.
j However, the magnitude of this resultant load is in tho same range of valuce
]
tested during the locked tube evaluation. The testing that was performed adequately addresses the potential additionalloading due to a MSLB for a single I
locked tube in an upper TSP.
Kinla\\byrbwdifstarrai\\4 A-4 a
a
ATTACHMENT C B&W Nuclear Technologies
'Non-Proprietary Information 1
Topical Report BAW-10196P dated March 8,1995 Kinla\\byrbwd\\fstarrai\\6
r b
BWNT RESPONSES TO NRC QUESTIONS ON F* FROM TOPICAL REPORT BAW-101%P - MARCH 8,1995 3)-
Questiou In calculating the proposed F* value at a 95% conSdence level, the final required F* length (F* calc) was determined by first subtractmg two staedard deviations (2o) from the pullout load and then computing l
the final value ofF* using the equation in Section 5.4. Another method of determinmg F* at a 95%
confidence level is to add a length equal to two standard deviations ofcalculated F* values on the mean value of F*. If the transformation between pullout load is linear the resultant F* values will be equal.
However, the transformation between F* and pullout load is nonlinear. Does the approach in Section 5.4 produce a resultant F' which is smaller, larger, or equal to that ifF* is determined by adding 2a of F* to the mean value?
Response
As shown below, the approach used in the topical report Section 5.4 produces a resultant F* which is larger than determirung individual F* lengths and adding 20 to the mean value.-
I l
s
)
1 l
i Notes: (1)
The calculated F* is determined as described in Section 5.1.4 of the qualification report:
I 1
(2)
The Final F* using the ultimate load average is calculated as described in Section 5.4 of the qualification report and utilizes the maximum tested F* length and the minimum expected ultimate load.
1 i
1 1
i (3)
Includes ECT uncenainty [
]per Section 5.4.
j BWNT NON-PROPRIETARY Page 1 of 3
EWNT RESPONSES TO NRC QUESTIONS ON F* FROM TOPICAL REPORT BAW-10196P - MARCH 8,1995 4)
Question As stated in Section 5.1.4, "F* Determination and Correction, "the most limiting condition for an F* tube to tubesheet joint exists during faulted conditions. The axial load during faulted conditions is based on the peak primary to secondary differential pressure. A tube which becomes locked into a tube support plate during operating conditions may experience additional axial tensile loads during a steam line break. Please explain if the axial load determined for faulted conditions is a bounding value when considering the blowdown loads induced into a tube locked into one of the upper tube support plates.
Response
The locked tube load considered is [
]. During a MSLB, the loading condition for a single locked tube could potentially consist of the differential pressure end load (difference from normal operating to faulted conditions) plus the contribution due to TSP movement from the blowdown differential pressure across it. [
]. The full pressure differential of[
] psi was used for end loading and is nearly [ ] psi greater than the 2560 psid actual for Byron 1 and Braidwood 1. Additional axialload was also added to account for the Reg. Guide 1.121 prescribed safety factors. [
]. Furthermore, the likelihood of having just one locked tube is small, as evidenced by past experience (i.e. tube pulls, inspections, and locked tube tests). This likelihood also assumes that the singular locked tube happens to be severed at the F* distance.
To evaluate the effect of the combined loading as postulated by the staff, the following is provided. Based on the locked tube load testing performed during the qualification, a maximum tube load applied was [ ] lb per Table 5.23. Thus, if a single tube locks into a TSP near one tie I
rod location, the combined load described above will be shared by the tie rod and locked tube.
The amount of sharing will be [
].
The following calculation determines what maximum resulting tie rod load would bound the postulated condition as supported by the testing.
(
I l
]
BWNT NON-PROPRIETARY Page 2 of 3
BWNT RESPONSES TO NRC QUESTIONS ON Fa FROM TOPICAL REPORT CAW-10196P - MARCH 8,1995 t
. The above calculation indicates that a tie rod load greater than [
] Ib. would not be bounded by the values for tube loading tested as part of the qualification. It is recognized that away from the tie rods, the j
. TSP may deflect more and potentially create additional load contribution for a locked tube in that region.[
]. Typically, the limits for loading of tie rods during faulted conditions may be confirmed through site SAR, stress reports, or other design documentation which should verify the conservatism in the tested locked tube loads.
Since the locked tube Ic ds applied were [
l
] addresses the potential additional loading due to a MSLB for a single locked tube in an upper TSP. [
l
].. It is also recognized that additional locked tubes (n) in the vicinity would reduce the tube load [
].
t i
i i
BWhT NON PROPRIE's ARY Page 3 of 3
-