ML20092N028
| ML20092N028 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 02/10/1992 |
| From: | Dipiazza R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20034D323 | List: |
| References | |
| CAW-92-265, NUDOCS 9202280291 | |
| Download: ML20092N028 (18) | |
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- Westinghouse -
Energy Systems
$3ygnn,gnm33 g33 q
Electric Corporation February 10, 1992 CAW-92-265 Document Control Desk i
US_ Nuclear Regulatory Commission Washington, DC 20555 Attention:
Dr. Thomas Murley, Director APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
- "J.
M. Farley Units 1 and 2 Steam Generator Tube Plugging Criteria for ODSCC at Tube Support Plates (WCAP 12871, Rev. 2, Proprietary)"
Dear-Dr. Murley:
-The proprietary information for which withholding is being requested in the above-referenced letter-is further identified in Affidavit CAW-92-265 signed by thel 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 Southern Nuclear Operating Company.
Correspondence with respect _to the proprietary aspects of the application for
- withholding or the Westinghouse = affidavit-should reference this letter, CAW-92-265, and should be addressed to the undersigned.
-Very_truly yours, v frfsetk
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. P. DiPiazza, Manager Enclosures Nuclear Safety Licensing cc:
M. P. Siemien, Esq.
- 0ffice 'of the General Counsel, NRC
_9202280291 920220 PDR ADOCK 05000364 C091: JM/0210Y4 I.
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i Proprietary Information Notice Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the flRC in connection with requests for generic and/or plant-specific review and approval.
In order to conform to the requirements of 10 CFR 2.790 of the Commission's
-regulations concerning the protection _of proprietary information so submitted to the f1RC, the information which is proprietary in-the proprietary versions is contained within brackets, and where the proprietary-information has been
-deleted in the non-proprietary versions, o..ly the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (g) contained within parentheses located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information.
These lower case-letters refer to the types of information Westinghouse customarily holos in confidence identified in'Section's (4)(ii)(a) through (4)(ii)(g) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.790(b)(1),
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Copyright Notice The reports transmitted herewith each bear a Westinghouse copyright notice.
The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or-violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.790 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection not withstanding.
With. respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in-the appropriate docket files in the public document room in Washington, UC and in local public document rooms as may be' required by NRC regulations if_the number of copies submitted is insufficient for this purpose. The NRC is not authorized to make copies for the personal use of members of the public who make use of the NRC public document rooms. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.
b C091:RJM/021092
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CAW 92-265 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF ALLEGHENY:
.Before me, the undersigned authority, personally appeared Ronald P. DiPiaz 1, who, being by me duly sworn according to ',aw, deposes and says that he is authorized to execute this Affidavit on
- behalf of ilestinghouse Electric Corporation (" Westinghouse") and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowlo'ge, information, and belief:
W Y AU Tonald P. DiPiazza, Makd)-
Nuclear Safety Licensing Sworn to and subscribed before-me this.t ay of; M 8 %tA-f, 1992'.
V hh.lw.c.i)N.
attl e Notary Public Ljcms A I$myPutk wc~esh.
Member,Porreykuva Awrrurn oHeanos
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_ CAW 92-265 (1) I am Manager, Nuclear Safety Licensing, in the Nuclear and Advanced Technology Division, of the Westinghouse Electric Corporation and as such, I have been specifically deleg'ated the function of reviewing the proprietary information 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 Unit.
(2) I-am making this Affidavit in conformance with the provisions of 10CFR Section 2.790 of the Commission's regulations and in conjunction with the Westinghouse application for withholding accompanying 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 f:nancial information.
.(4) 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 should be withheld.
(1) The information sought' to be withheld from public-disclosure is owned and has been held in confidence by Westinghouse.
(-
l l CAW-92-265 (ii) The information is of a type customarily 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 hold certain tjpes 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 f alls 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 te a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.
-4.
CAW-92-265 4
-(c)
Its use by a competitor would-reduce his expenditure of 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 potential commercial value to Westinghouse.
(f)- It contains patentable ideas, for which patent protection may be desirable.
(g)
It is' not the roperty of Westinghouse, but must be treated as 1
proprietary by Westinghouse according to agreements with the
- owner, g
There are sound policy reasons behind the Westinghouse system which include tu following:
(a)
The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors, it is, therefore, withheld from disclosure to protect the Westinghouse competitive i
position.
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-CAW 92-265 (b).It is information which is marketable in many ways, The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.
(c) Use by our_ competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense (d)
Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage.
If competitors acquire l
components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.
(e) _ Vnrestricted 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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-p CAW-92-265
-(iii)
The information is being transmitted to the Commission in confidence and, under the provisions of 10CFR Section 2.790, it is to be received in confidence by the Commission.
(iv)
The information sought to be protected is not available in public l
sources or available information has not been previously employed in the same original manner or method to the best-of our knowledge and belief.
(v)
The proprietary information sought to be withheld in this submittal is that which is appropriately marked in "Farley Units 1 and 2 Steam Generator-Tube Plugging Criteria For ODSCC At-Tube Support Plates", WCAP-12871 Revision 2, (Proprietary), February 1992, for Joseph M. Farley Units 1 and 2, being transmitted by the Southern Nuclear Operating Company (SNC) letter and Application for Withholding Proprietary Information from Public Disclosure'to Document Control Desk to the Attention Dr. Thomas t
y Murl ey.
The-proprietary information as submitted for use by Southern Nuclear Operating Company for the J. M. Farley Units 1 and 2 is expected to be applicable in other 1icensee submittals
'in response to certain NRC requirements for steam generator plugging criteria at tube support plates.
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- ,. CAW-92-265 This information is part of that which will enable Westinghouse to
(a)
Provide documentation of the methods for tube plugging criteria for ODSCC at tube support plates.
i (b)
Establish applicable analytical technologies.
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(c)
Establish the margins against tube burst.
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-(d) Assist the customer to obtain NRC approval.
l Further this information has substantial commercial value as follows:
(a) Westinghause plans to sell the use of similar information to its customers for purposes of meeting NRC requirements for licensing documentation.
(b) Westinghouse can sell support and defense of the technology to its customers in the licensing process.
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-8t CAW 92-265 Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar methodologies 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 consideral'.e 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, would have to be expended for developing testing-and analytical methods and performing tests.
-Further the deponent sayeth not.
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r Responses to the January 29, 1992 Request for Additional Information l-i.
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Responses to the January 29, 1992 Request for Additional Information
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.NRC Ouestioni Should the most recent results from Trojan be_ incorporated in the alternate plugging criteria?
Southern Nyslear Response:
Revision 2 to WCAP-12871 has been updated to include to all available Trojan data in support of the alternate plugging criteria. Appendix B addresses the methodology-used to include the data.
-2.
NRC ouestiqn Additional tubes should be pulled to determine if IGA or circumferential cracking is present at Farley and to verify the burst pressure-bobbin valtage correlation.
Eggthern Nuclear Re_iponse:.
Seven tubes-with tube-support plate intersections have been pJlled from Unit L since 1985, three at the last outage in support of the ale.ernate plugging criteria. The analysis of these intersections is documented in Section 4 of WCAP-12871, Revision 2.
Significant intergranular attack
-(IGA) has not been found at Farley Nuclear Plant.
Volumetric IGA similar to that-recently found at other plants has never been found at Farley Nuclear Plant. Consequently, little is to be gained by pulling additional tubes-from Unit 2.
On approval of the alternate plugging criteria, Southern Nuclear will attempt to pull two additional tubes from Unit I with a total of four intersections. These tube pulls would be based on the priority of
- pulling a leaking tube, pulling a tube with a large voltage flaw, and, if possible, a dented intersection. The application and/or update of the alternate plugging criteria would not be dependent on completing the examination of these tubes.
The need to pull additional tubes will be evaluated after the Unit 1 outage.
3.
NRC Ouestion:
For tube support plates with dent voltages exceeding an allowable threshold, an RPC inspection should be required or the alternate plugging eritaria would not apply.
Southern Nuclear Response: to this letter includes a sampling plan for use with the proposed interim plugging criteria. The sampling plan places a high pr_iority on conducting an RPC inspection of dented intersections.
Based-on the results of the Unit 2 outage, Southern Nuclear will evaluate the need to revise the s'ampling plan for future use.
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NRC Onstion:
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-The analysis guidelines given in Appendix A should be more detailed in order to provide the data analyst with more comprehensive guidance on
-appropriate procedures to apply for dealing with distorted signals.
What information is available on the variation in measure bobbin coil voltages for several analysts evaluating the same data?
Southern Nuclear Response:
Revision-2 to WCAP-12871. Section 8.8, contains an analysis-of variability between analysts. Appendix A has also been updated to provide mor'e guidance to the analyst.
5.
NRC Ouestion Given the uncertainties in the bobbin coil technique, what is the detection and sizing accuracy of the method described in Appendix A for cracks extending beyond the tube support plate?
Southern Nuclear Relgonse:
Response provided in February 6, 1992 meeting.
Response to be documented in WCAP provided for meeting.
6.
NRC Ouestion:
Demonstrate that the cumulative probability of tube burst for the entire steam generator under steam line break is at or below the level given in NUREG-0844.
Southern Nuclear Responsql Based on practices described in Revision 2 to WCAP-12871, Section 12.4.1, the estimated probability of tube rupture in an SLB, based on a 4
2.5 volt repair threshold, was less than 1 X 10. This probability is based on running 100,000 Monte Carlo simulations. This probability could be reduced even further; however, the benefit of running additional simulations is questionable.
7.
NRC Ouestio_n_1 Bobbin coil voltage - leak rate correlation may have significant error due to the small data base.
Southern Nuclear Response:
Response provided in February 6, 1992 meeting.
Response to be documented in WCAP provided for meeting.
8.
URC Ouestion:
What effect does allowable variations in the fabrication of the four hole standards have on the magnitude of uncertainties?
Southern Nuclear Response:
Response.provided in February 6, 1992 meeting.
Response to be documented in WCAP provided for meeting.
9.
NRC'Ouestion:
What is the probability of detection of "significant" flaws?
L Southern Nuclear Response:
Response.provided in February 6, 1992 meeting. Response to be documented in WCAP provided for meeting.
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NRC-Ouestion:
It is recommended that a sampling inspection of about 100 tubes be performed.with RPC.
l Southern Nuclear Response:
-Attachment 1_to this letter includes a sampling plan for use with the
-proposed interim plugging criteria.
The sampling plan places a high priority on conducting an RPC inspection of_ dented intersections.
Based on the-results of the Unit 2 outage, Southern Nuclear will evaluate the need to revise the sampling plan for future use.
11.
NRC Question:
Are there plans for additional tube pulls to strengthen the data bases and validate the various correlations?
Eguthern Nuclear Resp _gnel See the response to question 2.
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Unit 2 Eighth Refueling Outage Proposed Eddy Current Guidelines for use with the Interim Plugging Criteria l
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Eddy Current-Guidelines for use with the Interim Plugging Criteria This attachment contains_ guidelines which provide direction in applying the interim plugging criteria, The following items define probe specifications, calibration requirements, specific acquisition and analysis criteria, and flaw recording guidelines to be used for the_ inspection of the steam generators.
Bobbin Coil Prohg 1,
Bobbin Coil Probe Specification See _Section-A.2.1 of Appendix A to WCAP-12871, Revision 2.
2.
Bobbin Coil Calibration Standard See Section-A.2.2 and A.2.3 of Appendix A to WCAP-12871, Revision-2.
3.
Bobbin Coil Data Acouisition and Analysis See Section A.2.4, A.2.5 and A.2.6 of Appendix A to WCAP-12871, Revision 2.
Data evaluation of the bobbin signal will be conducted in accordance with Sections A.3.l, A.3.2, A.3.3, A.3.4, and A.3.7 of Appendix A to WCAP-12871, Revision 2, with the exception that the RPC threshold will be reduced to 1.0 volt from 1.5 volts.
4 Bobbin Coil Flaw Recordino Guidelines All flaw signals on the 400/100 mix channel at tube support intersections whose peak to peak voltage exceeds 1.0 volt must be recorded.
-RPC Probe 1.
RFC Probe Soecification See Section A.2.1 of. Appendix A to WCAP-12871, Revision 2.
2.
RPC Calibration Standad See Section A.2.2 of-Appendix A to WCAP-12871, Revision 2.
3.
RPC Data Acouisition and Analysis RPC inspection of all tube support intersections with bobbin coil flaw indications registering greater than 1.0 volt shall be inspected-with the RPC.
See Section A.3.6 of Appendix A to WCAP-12871, Revision 2.
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RPC Flaw Recordina Guidelines for TSP intersections with a bobbin flaw indication voltage greater than 1 volt, all RPC indications of flaws shall be recorded.
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