ML20199G257

Provides Responses to 981216 RAI Re 981027 Amend Request to Revise TSs to Use Electrosleeves to Repair SG Tubes. Proprietary Encl Withheld

ML20199G257
Person / Time
Site:	Callaway
Issue date:	01/11/1999
From:	Passwater A UNION ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20136B432	List: ML20199G257
References
TAC-MA3954, ULNRC-3948, NUDOCS 9901220230
Download: ML20199G257 (15)

Text

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4 g Union Elzetric One Ameren Plaza

• 1901 Chouteau Avenue PO Ilox 66149 j St. louis, MO 63166-6149 314 621.3222 January 11,1999 U.S. Nuclear Regulatory Commission ATTN: Document ControlDesk Mail Station PI-137 Washington, D.C. 20555-0001 Gentlemen: ULNRC 3948 gyg TAC No. MA 3954

[N8[I/I CALLAWAY PLANT UE DOCKENT NUMBER 50-483 REVISION TO TECHNICAL SPECIFICATION 3/4.4 REACTOR COOLANT SYSTEM

Reference:

1) ULNRC-3910 dated October 27,1998

2) Mel Gray letter to G. L. Randolph datd December 16,1998.

Reference 1 transmitted an amendment request to revise the Callaway Technical Specifications to use Electrosleeves to repair steam generator tubes.

Enclosure I to this letter provides responses to requests for additional information transmitted in Reference 2.

Framatome Technologies, Inc. has determined that information contained in the response to Item 4 (Enclosure 2) is proprietary, and is supported in an affidavit (Enclosure 4) signed by Framatome, the owner of the information. The affidavit 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 10CFR 2.790. Accordingly, it is respectfully requested that the information that is proprietary to Framatome be withheld from g public disclosure in accordance with 10CFR 2.790. Enclosure 3 provides a non- \ ,

proprietary response to Item 4.

Enclosure 5 contains Technical Specification Markups to reflect the responses provided in Enclosure 1. These changes have been approved by the Callaway Onsite Review Committee and do not change the Significant Hazards ' 'yr; I Evaluation transmitted by Reference 1.

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a sasidiary ot Amoren Corporation

, U.S. Nuclear Regulatory Commission Page 2 1 January 11,1999 If you have any questions related to this matter, please contact me.

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E itruu Alan C. Passwater Manager, Corporate Nuclear Services DS/mlo

Enclosures:

1) Responses to 12/16/98 RAI

2) Response to Item 4 (Proprietary)

3) Response to Item 4 (Non-Proprietary)

4) Affidavit ofJoseph J. Kelly

5) Technical Specification Markups

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STATE OF MISSOURI )

) SS CITY OF ST. LOUIS ) l l

l Alan C. Passwater, of lawful age, being first duly ,

sworn upon oath says that he is Manager, Corporate Nuclear  !

Services for Union 21ectric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said company with l full power and authority to do so; and that the facts l therein stated are true and correct to the best of his knowledge, information and belief. '

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By Alan C. Passwater Manager, Corporate Nuclear Services SUBSCRIBED and sworn to before me this  !!! day of Littt 2</ , 1999.

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'Ww OF M.a PATRICIA L REYNOLDS WinlWMATEOF MMIGUN r ST. LOUIS COUNTY 1 WWRAMB1011EXPilES DEC.If,3150 l,

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-. . . _ - . _ . _. _ ~ _ _ . -. - .- . _.= - -

l cc:- M. ' H . Fletcher 4/0 Professional Nuclear Consulting, Inc.

19041 Raines Drive Derwood, MD 20855-2432 Regional Administrator w/t U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive. 1 Suite 400 '

Arlington, TX 76011-8064 Senior Resident Inspector o /( ,

Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road i Steedman, MO 65077 Mr. Mel Gray (2) W /*-  !

Office of Nuclear Reactor Regulation l U.S. Nuclear Regulatory Commission 1 White Flint, North, Mail Stop 13E16 {

11555 Rockville Pike '

Rockville, MD 20852-2738 Manager, Electric Department W/*

Missouri Public Service Commission P.O. Box 360 Jefferson City, MO'65102 Ron Kucera w/o Department of Natural Resources P.O. Box 176 l Jefferson City, MO 65102 1

Denny Buschbaum M/*

TU Electric 4 P.O. Box 1002 Glen Rose, TX 76043 Pat Nugent W/0 Pacific Gas & Electric I Regulatory Services P.O. Box 56 Avila Beach, CA 93424

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. . Enclosure 4

, ULNRC-03948 l

AFFIDAVIT OF JOSEPH J. KELLY A. My name is Joseph J. Kelly. I am Manager ofB&W Owners Group Services for Framatome Technologies, Inc. (FTI), and as such, I am authorized to execute this Affidavit.

B. I am familiar with the criteria applied by FTI to determine whether certain information of FTI is proprietary and I am familiar with the procedures established within FTI to ensure the proper application of these criteria.

C. In determining whether an FTI 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 me to assure that the regulatory requirements of 10 CFR Section 2.790 are met.

. 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:

i (i) The information has been held in confidence by FTI. Copies of the document are clearly identified as proprietary. In addition, whenever FTI 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 of proprietary information, the substance of the following provision is included in i all agreements entered into by FTI, and an equivalent version of the proprietary l

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provision is included in all of FTI's proposals:

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l j AFFIDAVIT OF JOSEPH J. KELLY (Cont'd.) )

"Any proprietary information concerning Company's or its Supplier's j products or manufacturing processes which is so designated by Company or its Suppliers and disclosed to Purchaser incident to the performance of such contract shall remain the propeny 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 produce or have produced any products or to practice or cause to be practiced any manufacturing processes covered thereby.

Notwithstanding the above, Purchaser may provide the NRC or any other regulatory agency with any such proprietary information as the NRC or j 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 other agency to have such information withheld from public inspection.

l Company shall be given the right to panicipate in pursuit of such confidential treatment."

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• AFFIDAVIT OF JOSEPH J. KELLY (Cont'd.)

l l (ii) The following criteria are customarily applied by FTI in a rational decision process to determine whether the information should be classified as proprietary. I Infonnation may be classified as proprietanj if one or more of the following criteria j l

are met: 1 l a. Information reveals cost or price information, commercial strategies, production capabilities, or budget levels of FTI, its customers or suppliers.

b. The information reveals data or material concerning FTI research or development plans or programs of present or potential competitive advantage to FTI.

c. The use of the information by a competitor would decrease his expenditures, in time or resources, in designing, producing or marketing I 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 FTI. l l

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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 FTI.

f. The information contains ideas for which patent protection may be sought.

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AFFIDAVIT OF JOSEPH J. KELLY (Cont'd.)  !

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The document (s) listed on Exhibit "A", which is attached hereto and made a part hereof, has been evaluated in accordance with normal FTI procedures with 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 attached hereto j 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 with a request that the document (s) and the information contained therein be withheld i from public disclosure.

(iv) The information is not available in the open literature and to the best of our knowledge is not known by Combustion Engineering, EXXON, General Electric, Westinghouse or other current or potential domestic or foreign competitors of FTI.

l (v) Specific information with regard to whether public disclosure of the information is likely to cause harm to the competitive position of FTI, taking into account the value of the information to FTI; the amount of effort or money expended by FTI 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 FTI because it contains information which falls within one or more of the criteria enumerated in Paragraph D, and it is information which is customarily held in confidence and protected as proprietary information by FTI. This report comprises 4

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I AFFIDAVIT OF JOSEPH J. KELLY (Cont'd.)

l Information utilized by FTI in its business which afford FTI an opportunity to obh a competitive advantage over those who may wish to know or use the information contained in the document (s).

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State of Virginia) I

) SS. Lynchburg l City ofLynchburg)  ;

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Joseph J. Kelly, being duly sworn, on his oath deposes and says that he is the person who subscribed his name to the foregoing statement, and that the matters and facts set forth in the statement are true.

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LLY JOSE {H'  ;

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Subscribed and sworn before me this 8* day of dontu vl999.

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.u&0.Dow Notary Public in and for the City of Lynchburg, State of Virginia.

My Commission Expires kb 31,1999 l 1 5

. Enclosure 1 ULNRC-3948 RESPONSES TO 12/16/98 RAI

1. Table 12.5.2 ofBAW-10219P, Revision 3 contains a description of the plugging limit for '

inner diameter (ID) pits in region "B" and "C" which conflicts with the proposed TS p' ' wing limit of 20% through the sleeve. Per a conference call with UE personnel on <

November 24,1998, the licensee stated that the plugging limit specified in the TS would be utilized. Please modify the TS wording and revise BAW-10219P or provide an l addendum to BAW-10219P (which should also be referenced in the TS) to resolve this conflict between the proposed TS plugging limit and the topical report.  ;

Response

Enclosure 5 provides TS wording which applies the 20% limit to inner diameter pits in Regions B and C for Callaway.

2. The proposed insert "A" to TS 4.4.5.4.a.10 (TS page 3/4 4-15) inccrrectly references Revision 2 of BAW-10219P. Please modify the proposed TS to reference the correct topical report revision number and also include the date of the topical repc't.

Response

l l Enclosure 5 corrects the topical revision number and adds the date.

j 3. The proposed insert "A" to TS 4.4.5.4.a.10 indicates that "Any steam generator tube containing an Electrosleeve which has been inservice for 2 cycles of plant operation must be removed from service; and...". The wording of this statement would permit l electrosleeves to be installed continuously (cycle after cycle), as long as the

! electrosleeves were removed two cycles later. The NRC staff discussed this issue with l UE personnel during a meeting on July 7,1998. At that time, the NRC staff stated that all electrosleeves should be removed from the steam generators two cycles after the outage the electrosleeves are first installed at Callaway. For example:

a. Electrosleeves are first installed during outage #1.

b. Electrosleeves are installed during outage #2.

c. All electrosleeves shall be removed during outage #3. No other electrosleeves shall be installed.

Please modify the proposed TS wording in your application accordingly.

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. Enclosure 1 l .

ULNRC-3948 l

Response

Enclosure 5 modifies the TS to clearly state that all tubes containing Electrosleeves will l be removed from service after 2 cycles following initial installation of Electrosleeves.

4. Some of the assumptions used in the determination of the structural limits reported in Table 8.5.1 ofBAW-10219P, Revision 3, are unclear. Specifically, provide the loads l

imparted on peripheral tubes under locked conditions that were considered in establishing the 45 percent through allowable defect for Service Level A conditions. Also, describe the transient where these loads became significant. The staff recognizes that the issu: of degradation in locked tubes is not applicable for the proposed interim sleeving l

amendment for Callaway. However, the locked tube loads form the basis for the limiting flaw and the proposed plugging limit for Electrosleeve repairs. Therefore, the staff considers it appropriate to obtain these loads in order to verify the conclusions in the topical report.

Response

i Framatome Technologies, Inc. considers a portion of the response to this item to be l proprietary. Enclosure 2 provides the proprietary response and Enclosure 3 provides the non-proprietary response. An affidavit to support this is provided by Enclosure 4.

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Enclosure 3

. ULNRC-3948 I

RESPONSE TO ITT6M 4 - NON-PROPRIETARY

4. Some of the assumptions used in the determination of the structural limits reported in Table 8.5.1 ofBAW-10219P, Revision 3, are unclear. Specifically, provide the loads imparted on peripheral tubes under locked conditions that were considered in establishing the 45 percent through allowable defect for Service Level A conditions. Also, describe the transient where these loads became significant. The staff recognizes that the issue of degradation in locked tubes is not applicable for the proposed interim sleeving amendment for Callaway. However, the locked tube loads form the basis for the limiting  ;

flaw and the proposed plugging limit for Electrosleeve repairs. Therefore, the staff l considers it appropriate to obtain these loads in order to verify the conclusions in the i topical report.

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Response

The loads imparted on the peripheral tubes for the locked tube conditions considered in establishing the 45% through wall allowable defect for Level A/B conditions presented in Table 8.5.1 are as follows. The locked tube loading calculations assume that the tube i locks into the TSP at 100% power. Thus, the axial load in the tube at 100% power is  ;

equal to the pressure end cap loading. The loads listed below are the maximum identified I tensile loadings to occur during the normal and upset transients evaluated. The axial loadings include the effects of thermal and pressure differentials specific to the transient evaluated. Note that the AP listed in Table 8.5.1 was used to determine the radial stress component.

For 11/16" OD x 0.040" Wall Tubes:

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For 3/4" OD x 0.042/43" Wall Tubes:

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For 3/4" OD x 0.048" Wall Tubes:

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For 7/8" OD x 0.050" Wall Tubes:

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FTI Non Proprietary Reganse l

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. Enclosure 5  !

ULNRC-3948 i i

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TECHNICAL SPECIFICATION MARKUPS i.

See Attached Pages:

1 Insert A to TS 4.4.5.4.a.10 (Page 3/4 4-15)

Insert to Insett A l

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, 3,80/98 ll h IN RT A TO TS 4.4.5.4.a.10 (Page 3/4 4-15) b) Electros! 'ng as described in Framatome Technical Report B AW-10219P, Revisio 2, ' Electrosleeving Qualification forPWR Recirculating Steam  ;

Genera ube Repair." 4 mmom 3ca:micr ed: = dig sI'k.mamim.m

"+lch hr ber . ::::~i= for 2 j:!:: cfp!=: Operrier mu: bc immoved ^ um

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I Degraded Sleeve means a sleeve centaining imperfections greater than 0% but 11) less than 20% of the nominal wall thickness caused by degradation.

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INSERT TO INSERT A The plugging or repair limit for the pressure boundary portion of Electrosleeves is i determined to be 20% through wall of the nominal sleeve wall thickness (as determined  !

by NDE). The 20% plugging or repair limit will apply to inner diameter pits in Regions l

B and C.

All steam generator tubes containing an Electrosleeve will be removed form service afh r )

. 2 cycles following initial installation of Electrosleeves.

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