ML20148C136
| ML20148C136 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 01/22/1980 |
| From: | Stallings C VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Harold Denton, Parr O Office of Nuclear Reactor Regulation |
| References | |
| 756A-090779, 756A-90779, NUDOCS 8001250456 | |
| Download: ML20148C136 (35) | |
Text
e VIRGINIA ELncTurc Axu Powen Coniwxy R 2 cnx o s n.VJ Ho I N 1 A f.! O O 61 January 22, 1980 Mr. Harold R. Denton, Director Serial Nos.
756A/090779 Office of Nuclear Reactor Regulation 1162/121879 Attn:
Mr. O. D. Parr, Chief Light Water Reactors Branch No. 3 FR/MLB Division of Project Management LQA/EGS: SHS U. S. Nuclear Regulatory Commission Docket Nos.
50-339 Washington, DC 20555
Dear Mr. Denton:
FUEL ASSEMBLY GUIDE TUBE THIRELE WEAR 40n Pro e n t+ v y \\f tr$t on In response to Mr. Parr's letters of September 7, 1979 and December 18, 1979, which reques ted additional information on the generic Westinghouse modeling of fuel assembly guide tube wear, we are providing information in Attachments 1 and1(proprie tary and non-proprietary versions, respectively) that has been developed by Wes tinghotise. 'These responses, and the details of the Wes tinghouse model, were discussed with the NRC Staff on October 12, 1979. The responses, and the generic Wes tinghouse modeling of guide tube wear have been reviewed by Vepco and concluded to be applicable to North Anna Unit No. 2.
Picase note that in our response to Question 4, we have committed to pro-viding additional surveillance data to confirm the predictions made with the Wes tinghouse guide tube wear model. However, the exact mechanism for providing the surveillance data is still being decided. There is the possibility that the data will be provided through a cooperative utility owner's group.
e will formally U
advise you of the exact mechanism as soon as possible.
We concur with the conclusion in Mr. Parr's letter of December 18, 1979, that this matter is resolved for Cycle 1 of North Annc Unit 2.
Further, we believe that this conclusion will remain valid through Cycle 2, since our current fuel management plans do not result in any fuel assembly experiencing more than one cycle of residence under a fully withdrawn control rod until Cycle 3.
As this subutittal contains information proprietar'y to Westinghouse Electric Corporation, it is supported by an af fidavit signed by Wes tinghouse, the owner of the information (see Attachment 3).
The affidavit cets forth the basis on which the information may be withheld from public disclosure by the Conraission and addresses with specificity the considerations listed in paragraph (b) (4) of Section 2.790 of the Cor:nission's regulations.
8001 4 0
Vs uois rA Ette;aic no Powra Cowrur To Mr. Harold R. Denton 2
i 1
Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.790 of the Coc: mission's regulations.
Correspondence with respect to the proprietary aspects of this application for withholding or the supporting Westinghouse affidavit should reference CAW-79-40, and should be addressed to R. A. Wiesemann, Manager, Regulatory and Legislative Affairs, Westinghouse Electric Corporation, P. O. Box 355, Pittsburgh, PA 15230.
Please contact us should you require additional information or clarification.
Very truly yours, C. M. Stallings Vice President-Power Supply and Production Operations Attachments:
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QUEST!0ft1 Please provide the basis and derivation of the guid2 thimble wear n:cdel described.
in Reference 1.
In particular, explain assumption 4 cnd the equations provided under assumption 7.
Does the model predict maximum local ucar or average circum-ferential 'icar?
PESPO!!SE 1 Consider the interfecc between the guide tube, the control rod asscnbly and the fuel assembly, shown in Figure 1.
Each absorber rodlet is guided in the upper intet nals by the guide tube, and in the core by the fuel asseubly guide thinble tube.
The rodlet is claaNd again:t the guide tube by the coolent pressure, as illustrated in Figure 2.
The length of the clamped portion de; ends on the coolant pressure Ag i
and the alignment of the guide tube with the fuel asser.bly.
The rodiet bottom be is pinncd in tha fuel assembly guide thi:r.ble tube.
As illustrated in Figure 2, a certain portion of tae absorber rodlet, with a larg/4 "L",
is unsup,70rtcd.
As sho..n in Figure 3, p p,d
.] The corre:r ondir - r,q'.,
e vibri.ti'm of th; cylindrical redlet results in the oscillatica of th2 pir.: :.d rcel ;t tip,'. tith a.Oxiin u.gle of rot: tion 1.
Tha amplitude 0 - Ucar motion is a f:.>.ctia,1 of thir, engie, as shocin in Fi,gure 4.
The cain.c angle of rotation o is (1, 2)
F 5.72 QU 2 ((x ) 7 0 =
p
'the re :
q is the r::gnification factor
[ is the funda.7:ntal cleopad-pinned c:cde shape is the obscissa of the dynamic lif t force
,xp f is the fraction cf F at rod frequency F is the dynamic li f t force L
L is the unsupported length K is the rodlet dynamic stiffness The lotal travel of the rodlet tip, in contact with the guide thirtle tube inner
~
surface, is:
T 2oD f t
=
g n tihere:
D is the redlet diamater g
f is the rodlet natural frequency n
t is the total vibration time; this is the total time during which'
.the rodlet i: pa,rted in a given axial position.
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Finally, the wear volume associated with this travel is V
F.T.W.
=
'hore:
F is the lateral contact force botusen the redlet tip and the thimble tube
~
ll is the wear coefficient in order to convert the wear volume into a wear depth, ccasider a typictl wear scar in Figure 5; fec:a the observations of wear scar geoa:etries, the waar depth !! can D
Le detemined from t1I f
W.dL
[a,c]
[
]
and Y
=
g O
where:
il is the wear area l
g I
is the cr.iil length of the wear scar g
figure C reprccents a wsar' scar as,:c:sured in a thir.,ble tube and confira. ti.c illustra ico cf Figure 5.
lhe abcVe ecuations relate the maximu:a local wear depth 1.'g to the pare.:eten cifcc.-
ing the rodlet vibration: ge:metries, ficw, stif fness and tr.2 wear phanecenon:
con t act fc rce, ti,7.3, staar coefficient.
Ik fcrences:
fl)
Y. C. Fung " Fluctuating lif t and drag cctir.g cn a cylinder in a flow at supercritical P.cynolds nu::dars", Jnl. cerospace scien:2, vol. 27, !?o. II, j
i;ovc htcr, 1960, l
,1
[?) !!. T. Thomson, "Vibratica theory and crplications",1965, Prenticc hall,
)
eg. 10.7-14 Appendix C.
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a-Que_s t. ion 2_
Using the guide thimble ucar model, Westirighouse has predicted maximum stresses and stress intensity limits for worn guide thimble walls in two fuel assembly designs, which were subjected to a 69 handling load.
These calculated values are listed in Table 4.1 of Reference 1.
We note that the stress intensity limits increase as a function of time for both fuel assembly designs and that the limits always rcmain greater than the maximum stresses, which increase as the wall is worn away.
From the supporting discussion pecceeding Table 4.1, it is not clear if the stress intensity limits are ti:re dependent.
Such an assun:ption would explain the r.oted increase in stress limits, but does not address the decreasing material toughness, associated with irradiation hardening.
If such credit is being used, it is contrary to tne previous Westinghouse position in Reference 2 and itcm 4.0.5 of Reference 1.
Please clarify whether or not llestinghouse has taken credit for irradiation strengthening.
Show that the criteria adopted rcprescnts the more conservative approach.
RESP 0.1SE 2 i
The accelerations and resulting loads applied to a fuel assembly during handling operations are non-operationai iccds, as opposed to conditions 1, 2, 3 and 4 induced loads.
In analyzing the non-c.n rM:ional Ic'.d5, credit is tchen for the ir. cec:se of the yield r.nd ui; naate s trer.gth ui th irradiation.
On the other har.d, the fracture analysis is performad to address the de:reasing naterial toughness.
As you reention, the ~:aterial tou,;hness, cncrectorized by the critical stress in'.cr.sity fac'.or, shsuld be a de:reasing functior of irrglatien and th;refnra of tir.a.
The critical stress intensity fact:'r of 25,000 m i iin is
]
te:t]h_on 4"r pM hydrogen :narged enWaled the r.:cx tru:a c:sceri:..:n tal val ue f rc n/cid, E > 1MU. [1]
zircaloy 2 af ter irradiation to 2.5 x 10 This minirum value, apolic:ble to 250 week results, has conservatively betn applied to 25 weak resul ts in Table 4.1 of our report US-TMA-2102.
Ca.d In additic1, the pos tula ted crack in a thin ble ttie, f.
'], will be in a state of plane..streu and thereby will de/elop higher toughnsss.
The 25,033 psi /IE in Table <l.1 of MS-TM-2102, which corresponds to plcne strain te:,'. results, represents a lower bound toughness.
In sunn:ary, credit is taken for irradiation hardening when Sy and Su are considered for non-opera tional loading conditions.
The uinimuu fractore toughnc 5s is conser-vatively used, regardless of irradiation; this experimental value, derised from plane strain tests, is conservatively applied to pli.no stress conditions.
In addition, a 69 handling load has been assumed.
This load is significanti/
higher than the actual load actually impos2d on the fuel during handling operations.
No credit is taken for the uneven load distribution in the thir.bles unich results in load transfer when yiciding is reached.
Finally the yield strength value used represents a lowcr bound as indicated in Response to Question 8.
Reference 1.
R. G. Hoagland and R. G. Rowe, " fracture of irradiated Zircaloy 2", Journal of Nucien Meterials 20 (19G9), p.179 - 195.
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QUEST!0fl 3 Guide thimble wear data, which were taken from Point Coach Units 1 and 2 spent j
fuel, are discussed, listed, and plotted in Section 2.3, Tabic 2.1, and Figure 5, Please confirm that the time units in Section 2.3 respectively, of Reference 1.
Should not the units and Table 2.1 are in error and make corrections as needed.
be days instead of hours?
LESP0i!SE 3 The units should be
. The time units in Section 2.3 an<J Table 2.1 are in error.
days instead of hours.
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QUEST 10il4 Subsitted Westinghouse infonnation does not explain uhy the guide thimble wear model, which was developed frora measuren:ents taken on two 2-loop plants with 14 x 14 fuel asscmblics, is applicable to wear predictions on plants of of.her designs.
Other !!S5S-vendor-designed plants have experienced a " plant-specific" and " core-position" decendence in the observed wear.
Therefore, please explain how the nodel accounts for wear differences and provide suppurting data for all Ueslinghouse design variations.
If the analytical treatr:ent of desion variaLions are justified, the sur,nneting data can be provided in a confirmatory :enner after imC approval of the model.
Please provida details of ycur data-cathcring propesal, a schedule for its impiecentation, and state your co:rmit"ent to carry out this confinnatory program.
This data-gathering progema should be completed expeditiausly considerin'; the availability of irradiated assemblics in all Westinghouse plants.
RESP 0ilSE 4 The guide thimble wear results obtained frcn Point Beach Units 1 and 2 presented in Table 2.1 of our report US-TiW2102, were statistically evaluated to identify a possible core location ef fect on the ie; ear depth.
The core location relative to the reactor.:ssel inlet and cutlet nonics is of particular interest.
The anilysis of the dat3 shras [
.]
,q c ef The plant siacific effect results fec" dif ferences in r.mchanical and hydr :lic cha ra c teri s tics These differences are accounted for in t5;e wear r:sdcl discusMd in response to Question 1.
The various par.w.ers affecting the wesr dgth L.';
change as the fuel assr';1y desirin, the control ecd asse>bly, the recc ce intarn.iis er the flo<t change.
This explains the diffccan; rctuits prcdicte: fcr 14 x l>
w'a r dep th :.3 cc:.:p rad to 17 x 17, anJ split tuto guidance as cc": pared to 3 heath guidance.
Report l'S-Ti,-2102 and the response to ques tion 1 prescn t the anal"tical tru t-mot of M. inn variables such as ce:matries ar.d flow, ar.d their it:;act on tha ucar predict. ions.
'The safety analysis, perforrnd according to standard SAR require *"eds, shous ade-quate safety cargins even in the extrame case of uorn-through guide thicble tubes.
This analysis, the measurements performed at Point Beach Units 1 and 2 and cwten-
.sive trouble free experience provides substantial evidence that guice thir.ble wear is not a safety concern in Ucstinghouse plants.
In response to the NaC requc:::t, we are comitted to providing additional surveillance da ta. Ecwe'rer, the exact mechanism for providing these surveillance data is still being decided, and ray be in the form of a cooperative utility cuners' group. We will for: rally advise you on the specifics of our surveillance program, and' the schedule for its iglementation, as soon as possible.
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l QUESTI0ll 5
\\
In Reference 3, Westinghouse stated that the effect of hydrogen content on the mechanical properties of Zircaloy is discussed in WCAP-9179 (Reference 4).
We have reviewed that topical report and f ound no information on this issue.
Please provide your evaluation of how this consideration affects the safety analysis.
Include in this evaluation a description of the propcasily for hydrogen ~
uptake of th Zircaloy as a function of the accur::ulative wear.
RESP 0f!SE 5 i
Hydrogen r easurements on a thimble tube exposed in UEP Point Coach Unit 1 for one cycle warc [
]
D'. 0 Maximuni pre-irradiation hydrogen content was j'
].
At or.c location in a bulce- [.:,,c]
joint the hydrogen concentration, observed natallognphically, [
D. c'!
- ].
The hydrog:n concentration was es ti,ina ted at [
f.4,c.]
compared to the maximum measured value of [
3 b
b.c3
,1 TA d At the Westinghouse P.esearch Laboratorics in Pittsburch, fretting tests were perforc.ed in a wa ter filicd autocicve with cold worht;. and stres3-relieved enn2 alm,
,t M:::.5W]
,] and st..i Zi rcalo.'-4 tubir.g, [
of 304 stainicss steel.
TheSe tc ts were crnducted for four days in C00'F y.:cter containing 1500 pp tecn and r:ai: tained at a PH of s G.1 throuQus0 ci LR'.
,hc re'ul;s ihr r.2csurnd hyde:g:r. contcn; in sh; watcr '.es 12.33 cc par Kg..;'s.
i
,,, '[.],.,
{
of this tcst snc.-ed that [
].
Earlic.r inves tigtions into the ef fects of hydric'o pl: telets on tta fractureP,: led a t E 2 t.c i l e.i s r 't a s t L a '. s e;. '."ni e s.
4.0u '.I.nnss o f Z i rc al e.n 2 '.a rt. conducte r
r.
.,.cm. e0,
.,u:
. a n, m,, ; 1 plcie r:a teric.1, o f re:ctor grad.1 Zircalcy-d (.
i. <
r ;-
rch : tion i;u) v ere addisionally cold..arkcd by roliing to levels of 0, 20 cr.d 20:
in thickness cnd anc.aled at 7ETC for one i. cur.
A nwaer c:, anucl"d IE0cirans (c; rain size ci.035 o 0.40 -9 ura charged 'm'i th hydecy jo iev;1s of K,q jnd
/00 pp:1 a t 2 60"C.
Me allographic exer.ir.ation revealc. tn2 i c ci.; L i o n cp, ur.1 ; c r[.
hydride dis;ribution.
Uncer irra..ia'.2d ctrMi tions of 2. 5 x 10" n/cc._ G.t I '3\\
i
/
end 400 p;..: cor.centratir1 level, a r'ininum '.oughness of 1c = 2E51 on. was c'> tu i ned ba c..:-en 0 - 2 0 ' C.
In aciition, at hichar tes t te.J.gergo: es, tne toughn'.ss incrccsed, cnd no sub-critical cracting v.as otscrved at m RO r.
'] in the f, V.}
Therefore, [
The critical strer.s intensi ty factor, 25 k,si >,in.
, ~
West inghou.u to imC response.
used in 141e 4.1 of the analysis was appropriate for safety anal /,is of th, able u
wear.
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i gUESTI0tl6 L' hon Eddy current testing was conducted on worn guide thimble tubes from the Point fleach Units, did the presence of zirconium nydridas affect the results?
i How sensitive is the iiiterpretation of eddy current signals to hydride presence?
How is this ef fect taken into account?
P, ESP 0.'!SE 6 Eddy current measure ents that were taken at the Point Ceach spent fuel pit are 3,Ca, Q f-i The effect of these components is to increase the resistivity of the Zirconiu'a 4
[c., e.]
E
(,6, <3 3
The wear depth was obtained as the difference between the signal in tht unworn f a, c]/
f.*4 <
zone minus the Gigr.al in the worn zone,
{'
3.
The uorn zene being C
'].
This results in an apparent thir:ble tube thinning in
/ *,4.,g the worn section.
Mo 6tterpt h's been r.Mje to inclu:!O this Offect in the data cynluation cue to its conservativc n:ture.
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QUEST 10:t7-References 1, 3, and 5 do not address the consequences of hole formation in worn Marcover, it is not clear from the submitted infon::ation guide thiable tubes.if 1.'estinghouse (1) has observed holes during inspection of
, tubes that were examined in the Point Deac the guida thimble wear model) hole formation to occur during projected fuel life-Also, if holes hnve been obscrved or are anticipated, provida a discussion on the impact of such holes nn guide thimble tubn integrity, time.
Please citrify.
This discussion should control ro 1 notion, and thencal-hydraulic performnce.
also account for flow-induced vibrction rcculting in crack pre m ation and This possibly fatigue frccture in locally thir:ned areas of the thi:cble wall.
discussion should address the integrity of the thimbic tubes
^
assemblics are not under RCCAs.
RESP 0::S./.
Westinghouse has not observed holes during inspection of the t.9 guide thitble l
~
I that were cxcuincd in the Point Beach spent fuel.
The pre!ictisr3 of the guide thinble uct.r ccdel are presented in Figure 5 of our
}~.:,,4 J l'w d 3 re;:or t G-T!'.1-2iC2.
They rcpresent a (
].
AL [
F W'3 J
].
All tne curves are [
].
[
w:1 l
f,J./.)
)-
in cyclic stre ncs in The fic.. induced vibration of the fu:.1 msar:bly will resultA. the wear sc
?c A.l the guic'a thirie L.;ces.
the roxit"m 2:ressc., are origin:.ted frc. the [
,1'93J ofvit. ration [Iihe analysis cf the vibration of a worn-through thi::Sle tube shc.is t
].
is [
the pen to peak stress, at the wear scar,] vibration s:pii tude was conserva tivcly assuc a curve s!c..n in figure 7.
A[
The The thwmal hydraulic impact of a worn-throuch thir$le tube was investigated.a h D'$
increase in core b'/ pass flow, ahich n sul.s frc::
l'/.c- )
calculated to be [
] would have to be worn thrcugh in GJ '
j.
At least [
nrder to increase the core bypass flow by f,'] this ef fect in insi jnificant.
[;>!.-
e The worn cross section is located above the absorher rodlet inttem end plug con f the which guidos the rodlet and, therefore, does not jeopardize the ciove:.;ent o control rod asscmbly.
The impact of such a hole on guide tube integrity is provided in our report NS-1MA-2102.
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I QUESTI0il8 During the review of I! CAP-9179 (Reference 6), the staff questioned the Westinghouse value for the ultilaate tensile strength of Zircaley cc:nponents.
The subsequent !!estinghouse respon:e (Reference 2) stated thet the ultimate tensile strength of Zirccioy was not used in the design nnalyses of present
{
fuel assembly designs.
Houaver, tE analysis contained ir, Reference 1 uses the ultimate strength as a limiting variable.
Therefore, plcuse sub: Sit for i
revicw the !lestinghouse correlation for the ultimate tensile strengtn of Zircaloy.
l RESP 0i!SE 8 1
Unirradiated values for.2% yield strength and ultimate strength used worn' lower bouns va tucs as indicated belo,;:
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Yield Strength
[
]
?. 3.'.]
0 < TF
,_ 600' F U1 tima te Stror.gth
[
]
@, <]
0 < TF 003 F 1rrediated vslues of.2% yield strength ussd w:re icwcr bound values indicatcd below:
IieldStrer.gth
[
]
['s, g]
O < T*F <. 600 F nyt > 2x1020 g,, yjg,j; Becai the [.y.e of the limited uniform clongation present in irradiated annealed Zircaloy-<1, 3
9,c,7 I!"5}
i The values for ultimate strength of Zircalcy-4 are usert for failure analysis to determine bath failure r.iode and crgin available for particul:r con.penents.
Origina l design and analysis is based on the yield strength for Zircalcy-4 e
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4 QUEST 101 9 Section 4.1 of P.crcrence 1 states that the stress intensity factors are plotted as a function of titc.c for 14x14 and 17x17 fac1 assc:ablics in Figure 5.
.. n s 1.>
not true.
Picase provide such a figure or amend Figure o as nc:.essary.
1 RESPO!!SE 9 The stress intensity factors are plotted as a function cf titre for 14x14 and 17x17 fuel asseir.blics in Figurc 6 of ou r repor t..S-Tm,, _10..
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QUEST 10:1 10 Per item 4, Section 4.0 of Reference 1, your analyses are based on unifonn we Address the margin of conservatism fur this assun.ption.
j Compare your results with anelysis that considers non-unifona we in all thimble tubes.
in a chif t of the neutral axis.
stress and bending stresses.
P.CSPO::SE 10 Assumption 4 of Section 4.0 states that wear is assum for occur in a thimble tube under a split tube, or sheath, location is the same thimble tubes.
all thitble tubes under a split tube, or sheath, in this fuel assembly.
Point I;occh measurements show wear results that vary, within th assembly, from thiuble to thimble.
the n.axiuum predicted local wear is does not take credit for this cbservation:
in a given fuel applied to all thimbic tubes under a split tube, or sheath,
assembly.
wear, and cur analyses do tal:e into consideration the snif t of the model dcas predict ra: icum local t
l exis a 1 the resultir,9 cirect and bendin;j stresses.
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QUESTI0ft 11 For Condition 1 and 2 load analyses of Reference 1, a shcu factor is mentioned that accounts for the uneven axial load distribution.
Clarify hcw the skew factor is related to both gte::etric changes (resulting fro:a uneven wear) and assenbly misalignn.cnt.
lica dcas the shcw factor irrpact the load analyses?
RESP 0.';SE 11 During fuel assently mechanical testing, strain gages were mounted' on thiihle tubes to measure thit:61c loads as a function of thinble 'ocation in the fuel asstmbly.
The measurbments sho,ted that,[
[c,c]
Q C1
.][
L% C.l l.[
f% 'l
.] It was conscrvatively assumed thr.t all thirble t'..' es under a split tube loca:icn have the ser locd as the tube c
with the,nxis a load, in a split tuba lo:ation.
Simil:riy, all th:
le tubes under a sheath locatiren have the src lead as the tub u.i. th:-
maxit.Um load on a sheath locaticr..
In addition, [
9' M j.'s L3
] This is due to the fact thLt the gras di:t:
":2huJ the loads cver thimbles and fuel rods.
The sht.u fcctors usec corre:;c.
- c the top span al tho.qh the stress ar2aiysis is don" ene scan Lti
- ':, viere tN wear scar is leceted.
This tends to overrstinate the skcu factors cnd, therc foce, the ic:.d on the thimbles.
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QUESTI0il12 lio. :ver,
The equation for the wear volo.c in Reference 1 appears l Please provido iniorr.ation on how these parcc:eters are appears to be non-linear.
related.
P. ESP 0'M 12 is discussed in the The nca-linearity of the wcar depth versus ti:ac relatio:ishiP l'id >
Response to Quastion 1.
It r:sults frc:n[
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QUCSTIO'l 13 for Condition 3 and 4 lead analyses, describ'd in Reference 1, it is stated that the stresses in a worn guide thiir.ble tube are based on generic stress cal cul a tions.
Please reference where these generic strer,s calculations can be found.
It is also stated that the stresses in 'he un!cen guide thictie tubes are increased to account for the reduction of ti.' tube cr'oss-section due to the wear scar.
Thi: would indicate credit for a loca redistritution to the unwern guide thimble tubes.
Is a skew factor empicycd in the Cor.dition 3 ar.c a lead
. Onalyses? Describe the state of stress in the worn guide tubcs and her.l the uneven ucar af fects the load-bearing characteristics of the worn tubes.
RESP 0flSE 13 The Condition 3 and 4 load analysis for the earn thir.61e tubes was based c6 generic scismic pit.s LCCA evt.nt thi: Ole s tress values, (
[c., df
], from
'.-l AP 8?2G, /.ddendu.1 1.
These str m m [c., a]
9 Cth cre calculatcd using finite eltc.ents core rodals as dercrit ad in 'lC The stresscs calculated in '<lNP S225 Mdend'c I are strcsns in cn unworn guide thimble tube.
The cxi:tence of a wear sccr 01d tha resulting tube cross-section reduction and ner.ral axis I,hif t are t:::en into c.co..nt in the wear an::ljsis.
For a given thichio tu!: 0, the wese resul:s in increased s'.resies and na crtdit is tal.en for ield redi:'.ril:v:icn.
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s QUES,TIO!!14 Discuss the potential for guide thinble vicar in fuel assemblies v:ith core components other than control red assemblics, RESP 0@E 14 Core cc:':ponentt, other than the control rod assemblics are:
thin:ble plugs,
burnable poison:,, cod sources.
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ATrAcmENT 3 Westinghouse Water Reactor MS R2*n ciW58 Electric Corporation DMslons so m 3 Par 20sgfiPennsyNano t3220 November 7, 1979 CAU-79-40 M"r. H. R. Denton, Director Of fice of Nuclear Reactor Regulation U. S. fluclear Regulatory Commission Washington, D. C.
20555 APPLICATI0ft FOR WITHHOLDING PROPRIETARY IllFORt4ATI0tf FROM PUBLIC DISCLOSURE
SUBJECT:
Diablo Canyon, Units 1 and 2 (Docket flumbers 50-275 and 50-323)
McGuire, Units 1 and 2 (Docket Numbers 50-369 and 50-370) florth Anna, Unit 2 (Docket flumber 50-339)
Salem, Unit 2 (Docket Number 50-311 Sequoyah, Units 1 and 2 (Docket flumbers 50-327 and 50-328)
Responses to NRC Questions on Guide Tube Thimble Wear Letter from Utility to Denton Gen tl emen:
This application for withholding is submitted by Westinghouse Electric Corporatinn pursuant to the provisions of paragraph (b)(1) of 10CFR Section 2.790 of the Commission's Regulations.
The accompanying affidavit identifies the information sought to be withheld frcm pu'alic disclosure, sets forth the basis on which the information may be withheld from public disclosure by the Cc.mmission, and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.790 of the Consission's regulations.
The undersigned has reviewed the information sought to be withheld and is authorized to apply for its withholding on behalf of Westinghouse, WRD, notification of which was sent to the Secretary of the Commission on t
April 19, 1976.
It is requested, therefore, that the Westinghouse proprietary information i
being transmitted by the involved utility letter referenced above be with-I held from public disclosure in accordance with the provisions of 10CFR Section 2.790 of the Commission's regulations.
9
A Mr. H. R. Denton November 7,1979 CAkt-79-40 Correspondence with respect to the proprietary aspects of this appli-cation for withholding or the accompanying affidavit should reference CAki-79-40 and should be addressed to the undersigned.
Very truly yours, I
WhULL Robert A. kliesemann, Manager Regulatory & Legislative Affairs
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At tacbeent i.
cc:
J. A. Cooke, Esq.
Office of the Executive Legal Director I
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CAW-79-40 J
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l COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF ALLEGHENY:
Before me, the undersigned authority, personally appeared Robert A. Uiesemann, who, being by me duly sworn according to la./,
deposes and says that,he i's authorized to execute this Affidavit on behalf of Westinghouse Electric Corporation (" Westinghouse") and ta t the averments of fact set forth in this Affidavit are true and corrut to the best of his knowledge, information, and belief:
'hd itu () 1A!)2 LLC !h
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kobert A. Wiesema'in, Manager Regulatory & Legislative Affairs i
Sworn to and subscribed befremethisI day of
%u-</M979.
W ]r t.Gi9f Notary Publi 8
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CAW-79-40 2
(1)
I am Manager, Regulatory and Legislative Affairs, in the fluclear l
Technology Division, of Westinghouse Electric Corporation and as l
such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public dis-closure in connection with nuclear power plant licensing or rule-making proceedings, and am authorized to apply for its withholding on behalf of the Westinghouse Water Reactor Divisions.
(2)
I am making this Affidavit in conformance with the provisions of 10CFR Section 2.790 of the Commission's regulations and in con-junction with the Uestinghouse application for withholding accompanying this Affidavit.
(3)
I have personal knowledge of the criteria and procedures utilized by Westinghouse Nuclear Energy Systems 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 Commission's regulations, the following is furnished for consideration by the Commission in determining whether the infor-mation sought to be withheld from public disclosure should be withheld.
(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.
h
CAW-79-40 (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 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.
In determining whether information in a document or report is proprietary, the following criteria and standards are utilized in Westinghopse.
Information is proprietary if any one of the following are met:
(c)
The information reveals tne distinguishing aspccts of a process (or component, structure, tool, method, etc.)
where prevention of its use by any of Westinghouse's competitors without license from Wastinghouse 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 advantage, e.g., by optimization or improved marketability.
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CAW-79-40 (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 of a similar product.
(d)
It :eveals cost or price information, production capaci-ties, budget levels, or commercial strategies of Westing-house, its customers or suppliers.
(e)
It reveals aspects of past, present, or future Westing-house or customer fundad development plans and programs of potential commercial value to Westinghouse.
9 (f)
It contains patentable ideas, for which patent protection may be desirable.
(g)
It is not the property of Westinghouse, but must be treated as proprietary by Westinghouse according to agreements with the' owner.
(iii) The information is being transmitted t.o the Commission in con-fidence and, under the provisions of ICCFR Section 2.790, it is to be received in confidenca by the Commission.
(iv) The information is not available in public sources to the best of our knowledge and belief.
l 9
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CAW-79-40 (v) The proprietary information sought to be withheld in this sub-mittal are the responses to flRC questions related to guide tube thimble wear directed to applicants for operating licenses
)
for Diablo Canyon Units 1 and 2, McGuire Units 1 and 2, ilorth l
Anna Unit 2, Salem Unit 2, and Sequoyah Units 1 and 2.
Public disclosure of this information is likely to cause sub-stantial harm to the competitive position of Westinghouse as it would reveal the basis of the Westinghouse fuel assembly design for the designated plants and similar plants, which is recognized by the Staff to be of competitive value and because of the large amount of effort and money expended by Westing-house in development.of this design.
This information is valuable to Westinghouse because:
(a)
Information resulting frem this design gives Westinghouse a competitive advantage over its competitors.
It is.
therefore, withheld from disclosure to protect the Westing-house competitive position.
(b)
It is information which is marketable in many ways. The extent to which such information is available to competi-tors diminishes the Westinghouse ability to sell products and services involving the use of the information.
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CAW-79-40
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- l (c) Use by our competitor would put Westinghouse at a com-petitive disadvantage by reducing his expenditure of l
resources at our expense.
(d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as t
valuable as the total competitive advantage.
If com-petitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.
This information enables Westinghouse to:
(a) Justify the design basis for the fuel (b) Assist its customers to obtain licenses (c) Meet warranties Further, this information has substantial commercial value as follows:
(a) Westinghouse sells the use of the information to its customers for purposes of meeting NRC requirements for licensing documentation.
(b) Westinghouse uses the information to perform and justify analyses which are sold to customers.
4 s
9
e.,
CAH-79-40 (c) Westinnhouse uses the information to sell nuclear fuel and related services to its customers.
Public disclosure of this information is likely to cause substan-tial hana to the competitive position of Westinghouse in selling nuclear fuel and related services.
Competitors could obtain the equivalent information, with dif ficulty, by investing similar sums of money and provided they had the appropriate resources available and the requisite experience.
Further the deponent sayeth not.
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