ML20235V381

Requests Proprietary Responses for Amend to Tech Specs Re Adoption of Tube Sheet Region Plugging Criterion Be Withheld (Ref 10CFR2.790).Justification & Discussion of NSHC Encl

ML20235V381
Person / Time
Site:	Catawba
Issue date:	09/16/1987
From:	Wiesemann R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	Murley T Office of Nuclear Reactor Regulation
Shared Package
ML19304B580	List: ML20235V365 ML20235V381 ML20235V393 ML20235V427
References
CAW-87-087, CAW-87-87, TAC-66356, TAC-66357, NUDOCS 8710150116
Download: ML20235V381 (17)

Text

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Septunber 16, 1987 CAW-87-087 Dr.. Thomas Murley, Director Office of Nuclear ' Reactor. Regulation U.S. Nuclear Regulatory Commission Washington, D.C. :205551 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

Tube Sheet Region Plugging Criterion for'the Duke Power Company Catawba Unit.

1 Nuclear Station Steam Generators

Dear,

Dr. Murley:

The proprietary material for which withholding is being requested in the reference letter by the Duke Power Company.is further identified in an affidavit signed by the owner of the' proprietary. information,. Westinghouse Electric. Corporation.- The

affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in. paragraph (b)(4)'of 10CFR Section 2.790 of the Commission's regulations.

The proprietary material for which withholding 'is being requested is of the same .

technical type as that proprietary material previously submitted with Application for Withholding CAW-81-079.

' Accordingly.,= this'1etter authorizes' the utilization of the accompanying affidavit by Duke, Power Company.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-87-087,~ and-should;be addressed to the undersigned.

Ver. .truly yours,

%*Tb5 WA PJ sfu$la]amasa)

Robert A. Wiesemann, Manager

/dmr - Regulatory & Legislative Affairs Enclosure (s) cc: E. C. Shomaker, Esq.

Office of the General Council, NRC

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4 PROPRIETARY INFOPyATION NOTICE TRANSMITTED HDEWITH ARE PROPRETARY AND/OR NON-PROPRETARY VEPJ D0QJMDi73 FURNISHED TD THE NRC IN CONNECTION WITH REQUDTS P PLAh7 SPP.CIFIC REVEW AND APPROVAL.

t IN ORDER TO CohTORM TD THE REQUIRD!FhTS OF 10CFP2.790 & THE COMK PEULATIONS CONCERNING THE PROTECTION OF PROPP.IETARY INFDPyATION SO SUBFJT 70 THE NRC, THE INFOPyATION WHICH IS PROPRIETARY IN THE PROPRIETARY YERSIONS CONTAINED WITHIN BRADITS AND WHDE THE PROPRETARY INFOP/ATIG$1

• DELETD IN THE NON-PROPRIETARY VERSIONS GC.Y THE BPACKETS REMAIN, THE -

IATORPATION THAT WAS CONTAINED WITHIN THE BRACKETS IN THE PR HAVING BEEN DELETED.

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THE JUSTIFICATION POR Q. AIMING THE INFORMATION SO DESIDNATED AS PROPRIETARY IS INDICATED IN BOIH VERSIONS BY ME LETIERS (a) THROUGH (g) C0h7AINED WITHIN PAREN7HESES LOCATED AS A SUPERSCRIP IMMEDIATELY FOLLOWING THE BRACKETS Dic.CSING EACH ITEM OF INF0 IDD;TIFIED AS PROPRIETARY OR IN THE MARGIN OPPOSITE SUCHTHESE IhTOPyATION.

LORD CASE LETTERS FIFER TD THE TYPES OF INF0FFATION WESTINGH HOLTS IN CONFIDDiCE IDEh7IFIID IN SECTIONS (4)(ii)(a) through (4)(ii)(g) 0F THE AFFIDAVIT ACCOMPAh7ING 1HIS TRANSMITTAL PURSJAh7 7010CFP2 790 e

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AFFIDAVjT COMMONWEALTH OF PENN$YLYANIA:

st COUNTY OF ALLEGHENY:

Sefore me, the undersigned authority, personally appeared Robert A. Wiesemann, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Corporation (" Westinghouse") and that the avennents of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:

!  !^ ol lA Robert A. Wiesemann, Manager Regulatory and Legislative Affairs Sworn to and subscribed before me this A day of 1 e./d 1981. '

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Notary Publi.c if g... .

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-2 CAW-81-7g (1) I am Manager. Regulatory and Legislative Affairs in the, Nuclear Technology Division, of Westinghouse Electric Corporation and as 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 DVvisions.

(2) I am making this Affidavit in conformance with the provisions of 10CFR Section 2.790 of the Comission's regulations and in con-junction with the Westinghouse application for withholding ac-companying this Affidavit.

(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse Nuclear Energy Systems in designating infomation as a trade secret, privileged or as confidential comercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.7g0 of the Comission's regulations, the following is furnished for consideration by the Comission in detemining whether the in-formation sought to be withheld from public disclosure should be withheld.

(1) Yne information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse't.

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CM-81-7g l

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(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, utilize; 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.

'l Under that system, information is held in confidence if it falls in one or more of several types, the release of which I might result in ~the loss of an existing or potential com-petitive advantage, as follows:

(a) The information reveals the distinguishing a'spects of a process (or component. structure, tool, method, etc.)

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where prevention of its use by any of Westinghouse's competitors without license from Westinghouse consti-tutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, j 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. l 4 ,

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.4- CAW 81-7g l: a f

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

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(d) It reveals cost or price information, production cap-

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acities, budget levels, or comercial strategies of I Westinghouse. its customers or suppliars.

(e) It reveals aspects of past, present, or future West-inghouse or customer funded development plans and pro-grams of potential comercial value to Westinghouse.

q (f.) It contains patentable ideas, for which patent pro- '

tection 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. '

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

l (a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its com-petitors. It is. therefore, withheld from disclosure

.to protect the Westinghouse competitive position.'

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l- CAW 81-79 (b) It is infomation 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.

l (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary infor-nation, any one component may be the key to the entire puzzle. thereby depriving Westinghouse of a competitive advantage.

(e) Unrestricted disclosure would , jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition in those countries, i (f) TheWestinghousecapacitytoinvestcorporatekssets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

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,- CAW-81-79 (iii) The 'information is being transmitted to the Coeniss on in r,onfidence and, under the provisions of 10CFR Section 2.790, it is to be received in confidence by the Consnission.

(iv) The information sought to be protected is not available in public sources or available information has not been pre-viously employed in the same original manner or method to the best of our knowledge and belief.

s (v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in " Steam Generator Tube Plugging Margin Analysis' for the Ytrgil C.

Sumer Nuclear Power Plant Unit No.1. WCAP-9912. Revi-aion 2 (Proprietary) being transmitted by South Carolina Lfectric and Gas Company letter Application for Withholding Proprietary Information from Public Disclosure. Nichols to Denton, November 1981. The proprietary information as sub-  !

mitted for South Carolina Electric and Gas Company Virgil C.

Sumer Nuclear Station use is expected to be applicable in other licensee and applicant submittals in response to cer- '

tain NRC requirements for justification of the steam generator tube plugging margin.

This infomation is part of that which will enable Westing-house to:

(a) Provide documentation of the analyses, method and test-ing for determining plugging margin.

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-7 CAW-Bl.79

.I (b) . Establish the ninimum wall thickness in compliance with Regulatory Guitie 1.121.

(c) Establish the stress limits versus thinning of the remaining tube wall.

(d) Establish the maximum allowable leakage in support of the leak-before-break criteria.

(e) Assist the customer to obtain NRC approval.

Further this information has substantial comercial value as follows:

(a) Westinghouse plans to sell similar information to its customers for purposes of meeting NRC requirements for licensing documentation.

(b) Westinghouse can sell support and defense of the tech-nology to its customers in the licensing process.

Public disclosure of this infomation is likely to cause substantial ham to the competitive position of Westinghouse because it would enhance ths ability of competitors to pro-vide similar analytical documentation and licensing defense services for comercial power reactors without comensur' ate expenses. Also, public disclosure of ti.e information would enable others to use the information to meet NRC require-ments for licensing documentation without purchasing the ~

right to use the information. '

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.g. CAW-81 7p The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.

l 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 system design software development.

Further the deponent sayeth not.

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JUSTIFICATION AND DISCUSSION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS I

JUSTIFICATION AND DISCUSSION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS l

This amendment request applies to the Catawba Unit 1, Westinghouse model D3 steam generators and assesses the integrity of the tube bundle for tuba eddy current inspection indications occurring in the length of tubing located within the tubesheet.

Alternate plugging criteria have been developed for use in determining whether or not plugging of full depth roll expanded tubes is necessary for degradation which has been detected in the expanded portion of the tube which is within the tubesheet (WCAP 11581). Existing Catawba Unit 1 steam generator tube plugging criteria apply throughout the tube length but do not take into account the reinforcing effect of the tubesheet on the external surface of the tube.

Plugging uiteria have been developed for tube degradation in the tube expansion region below the transition of the expanded to unexpanded portions of the tube.

The elastic preload applied by tubesheet spring-back from the roll procedure and friction between the tube and the tubesheet due to the roll expansion provides the force required to resist pullout. The presence of the tubesheet acts to constrain the tube and complement its integrity in that region by essentially precluding tube deformation beyond its expanded outside. diameter i.e., the resistance to both tube rupture and collapse is significantly strengthened by the tubesheet. In addition, the proximity of the tubesheet significantly affects the leak behavior of through wall tube cracks in this region.

The F* criterion, represents a length, designated F*, of continuous tube expansion in the tubesheet such that tube pullout would not occur during either normal operation or postulated accident condition loadings. The F* distance is measured form the bottom of the roll expansion transition or the top of the tubesheet if the bottom of the roll expansion is above the top of the tubesheet.

As neither tube burst or collspse can occur within the tubesheet region, steam generator tube integrity has been assessed on the bt. sis of both tube pullout and primary to secondary leakage considerations.

In order to evaluate the F* criterion concept for indications within the tubesheet, it was postulated that a circumferential severance of a tube could occur, which is contrary to existing plant experience. Based on plant operation and laboratory experience the configuration of any cracks in the tubesheet roll region, should they occur, is axial. For axial indications in the tubesheet region, the tube end at the tube-to-tubesheet weld remains structurally intact minimizing any potential for tube pullout. Implicit in assuming a  ;

circumferential severance to occur in the development of the F* criterion is the consideration that degradation of any extent or orientation within the tubesheet is demonstrated to be acceptable during normal and postulated accident conditions z bnlow the F* location.

An evaluation consisting of analysis and testing programs of the Westinghouse f steam generator tubes roll expanded into the tubesheet was conducted to determine l the length of roll expansion necessary to resist tube pullout forces during normal and faulted condition loadings. The required engagement length, F*, below (

the bottom of the roll expansion transition or the top of the tubesheet, i whichever is lower, to preclude tube pullout under postulated accident conditions 4

JUSTIFICATION AND DISCUSSION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS (Cont.) j was calculated with a safety factor of 1.43, to be 1.06 inches. The safety factor of 1.43 corresponds to an ASME Code safety factor of 1.0/0.7 for allowable stress for faulted conditions. The calculation for normal operation loading conditions with a safety factor of 3 results in a distance of 1.04 inches so the postulated accident loading condition value of 1.05 inches is limiting. The engagement length determination method was derived from preload testing and was verified as conservative by both tube pullout and hydraulic proof (pressure) testing. Specifically, the F* criterion was calculated from a derived preload force and an assumed conservative static coefficient of friction for tube to tubesheet contact. Both the tube pullout and hydraulic proof testing conducted on rolled joints provided support for the derived preload force as well as an indirect measurement of the actual static coefficient of friction. Also, in assessing the F* criterion, it is expected that the radial preload resulting form the roll expansion is sufficient to significantly restrict leakage during normal operating and postulated accident condition loadings.

Use of a conservative eddy current elevation location uncertainty increases the operational value of F* above that which has been calculated as the minimum required engagement length. The uncertainty value is based on previous experience and laboratory testing.

On the basis of this evaluation, it is determined that tubes with any tube degradation within the tubesheet region below the operational F* pullout criterion (including allowance for eddy current elevation uncertainty) can be left in service. Tubes with tube degradation which is located a distance of less than F* below the bottom of the roll expansion transition or the top of the tubesheet should be removed from service by plugging in accordance with Technical Specification requirements.

The criteria defined in this evaluation have been demonstrated to result in tube integrity considerations commensurate with Regulatory Guide 1.121 criteria both analytically (tube preload) and empirically (tube pullout and proof testing and leakage testing). Therefore, implementation of the alternate tubesheet region plugging criteria within the Catawba Unit 1 steam generators is determined not to represent an unreviewed safety question as defined in 10 CFR 50.59 (a)(2).

As required by 10 CFR 50.91 (a)(1) this analysis is provided to demonstrate that a proposed license amendment to implement alternate tubesheet region tube plugging criteria for the Catawba Unit 1 steam generators represents no significant hazards consideration. In accordance with the three factor test of 10 CFR 50.92(c), implementation of the proposed license amendment was analyzed using the following standards and found not to: 1) involve a significant increase in the probability or consequences for an accident previously evaluated; or 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or 3) involve a significant reduction in a margin of safety.

The amendment has been proposed to address potential cddy current indications of tubo degradation in the roll expanded portion of the tubes within the tubesheet in the steam generators at Catawba Unit 1. These steam generators were fabricated

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i JUSTIFICATION AND DISCUSSION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS (Cont.)

with a mechanical roll expansion of the tube the full depth of the tubesheet.

Using existing Technical specification tube plugging criteria, many of the tubes which may be' identified to exhibit these indications would have to be removed from service., It can be shown that tube plugging is not required in many cases to maintain tube bundle integrity.

The proposed license amendment (Technical Specification change) addresses the action required when degradation has been detected in the roll expanded portion of. steam generator tubes within the steam generator tubesheet. Existing plugging criteria, i.e., current applications of Regulatory Guide 1.121, do not take into account the effect of the tubesheet on the external surface of the tube. The presence of the tubesheet will enhance the integrity of degraded tubes in that

region by precluding tube deformation beyond the expanded outside diameter.

Additionally, a portion of the roll expansion at the top end of the tube expansion is sufficient to preclude pullout of the tube during normal operation and postulated accident condition loadings if a tube were postulated to sever circumferential1y during plant operations *in the portion of the tube covered by the proposed amendment. Finally, the roll expansion of the tube into the tubesheet providee a barrier to significant leakage for through wall cracking of the tube in the expanded region.

The proposed change designates a portion of the tube for which tube degradation does not necessitate remedial action except as dictated for compliance with tube leakage limits as set forth in the Catawba Unit 1 Technical Specifications. As noted above, the area subject to this change is in the expanded portion of the tube within the tubesheet of the steam generators. The length of expansion required to resist pullout for all postulated conditions, designated F*, has been determined to be 1.06 inches. Since the expansion of the tube above F* is sufficient to preclude pullout of the tube, use of the F* criteria does not depend on any determination of the condition of tube degradation in the portion of the tube below the F* distance. The addition of an eddy current elevation location uncertainty allowance results in an operational F* value which is greater than the calculated minimum required engagement length of 1.06 inches.

l The proposed amendment would modify Technical Specifications 3/4.4.5 (Steam Generator' Bases), 4.4.5.2, 4.4.5.4 and 4.4.5.5 (Steam Generator Surveillance Requirements) which provide tube inspection requirements and acceptance criteria to determine the level of degradation for which the tube may remain in service.

The proposed amendment would add definitions required for the alternate plugging criteria and prescribe the portion of the tube subject to the criteria. The

- proposed Technical Specification changes accompany this analysis. j l

The proposed amendment would preclude occupational radiation exposure that would I otherwise be incurred by plant workers involved in tube plugging operations. The J proposed amendment would minimize the loss of margin in the reactor coolant flow through the steam generator in LOCA analyses. The proposed amendment would avoid loss of margin in reactor coolant system flow and therefore assist in assuring that minimum flow rates are maintained in excess of that required for operation at full power. Reduction in the amount of tube plugging required can reduce the length of plant outages and reduce the time that the steam generator is open to the containment environment during an outage.

I I JUSTIFICATION AND DISCUSSION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS (Cont.)

10 CFR 50.92 states that a proposed amendment involves no significant hazards considerations if operation in accordance with the proposed amendment would not:

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin of safety.

(1) Operation of Catawba Unit 1 in accordance with the proposed license amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The supporting technical and safety evaluations of the subject criteria (WCAP 11581, proprietary and WCAP 11582, non proprietary, and SECL 87-389) demonstrate that the presence of the tubesheet will enhance the tube integrity in the region of the hardroll by precluding tube deformation beyond its initial expanded outsido diameter. The resistance to both tube rupture and tube collapse is strengthened by the presence of the tubesheet in that region. The result of the expansion of the tube into the tubesheet is an interference fit between the tube and the tubecheet. Tube rupture can not occur because the contact between the tube and tubesheet does not permit sufficient movement of tube material. In a similar manner, the tubesheet does not permit sufficient movement of tube material to permit buckling collapse of the tube during postulated LCOA loadings.

• Additionally through analysis and testing, Westinghouse has demonstrated that the roll expansion above the F* distance is sufficient preclude pullout of the tube from the tubesheet. Even with the conservative assumption that a tube could completely sever circumferential1y below the F* distance, test results demonstrate that pullout of the tube is precluded under normal and postulatedaccident/Qchditionloadings. This assumption is conservative as the degradation that has been observed in operating units has been typified as short and axially oriented. A conservative allowance is added for eddy current elevation location uncertainty to determine the operational value of F*.

Relative to expected leakage, the length of roll expansion above F* is sufficient to preclude significant leakage form tube degradation located below the F* distance. The existing Technical Specification leakage rate requirements and accident analysis assumptions remain unchanged in the 1 unlikely event significant leakage from this region does occur. As noted above, tube rupture and pullout is not expected for tubes using the alternate plugging criteria. Any leakage out of the tube from within the tubesheet at any elevation in the tubesheet is fully bounded by the existing steam generator tube rupture analysis included in the Catawba Final Safety Analysis Report. The proposed alternate plugging criteria do not adversely impact any other previously evaluated design basis accident.

l JUSTIFICATION AND DISCUSSION'0F NO SIGNIFICANT HAZARDS CONSIDERATIONS (Cont.)

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

Implementation of the proposed alternate tubesheet plugging criteria doce not introduce any significant changes to the plant design basin. Use of the criteria is a passive activity and does not provide a mechanism to result in a new or'different accident outside of the region of the tubesheet expansion or below the F* length. Primary-to-secondary tube leakage as a result of degradation below the F* 1ength would still be subjected to the limits for

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leakage as defined in the Technical Specifications. Any hypothetical accident as a result of any tube degradation in the expanded portion of the tube would be bounded by the existing tube rupture accident analysis.

-(3) 'The proposed license amendment does not involve a significant reduction in a margin of safety.

The use of the alternate tubesheet plugging criteria (F*) has been demonstrated to maintain the integrity of the tube bundle commensurate with the requirements of Regulatory Guide 1.121 for indications in the free span of' tubes and the primary to secondary pressure boundary under normal and postulated accident conditions. Acceptable tube degradation is any degradation in the tubesheet more than the F* distance and the strength of-degraded tubes are consistent with the safety factors in the SAME Boiler and Pressure Vessel Code used in steam generator design. The F* distance has been verified by testing to be greater than the length of roll expansion required to preclude significant leakage during normal and postulated accident conditions. 'The allowance used for eddy current elevation location measurement uncertainty has been supported by previous experience and laboratory testing.

For axial or nearly axial indications in the tubesheet region, the tube end remains structurally intact further decreasing any potential for tube pullout. For tubes with axial or nearly axial cracks, the strength of the tube relative to an axial load would not be reduced below the strength required to resist potential axial loads. In~this case, leakage is the dominant consideration to determine the necessity of tube plugging. Again, j based on testing, using the alternate plugging criteria would not be expected to result in significant leakage form through wall cracks located below the F* distance.

Implementation of the alternate tubesheet plugging criterion will decrease

. the number of tubos which must be taken out of service with tube plugs.

Tube plugs reduce the RCS flow margin, thus implementation of the alternate plugging criteria will maintain the margin of flow that would otherwise be reduced in the event of increased plugging. Based on the above, it is concluded that the proposed change does not result in a significant j reduction in a loss of margin with respect to plant safety as defined in the '

Final Safety Analysis Report or the bases of the Technical Specifications.

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J KJUSTIFIChTIONANDDISCUSSIONOFli[$IGNIFICANTHAZARDSCONSIDERATIONS(Cont.)'

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"y Basdont'f.precedinganalysisitisconcludedthat pedation d .Chsawba Unit 1 in icconNnce with the proposed amendment does not res: ult, d the creation of an ' I unreviewed/safetyquestion,anincreaseintheprobabilityofanaccident

.J(previously. evaluated,createthepossibilityofanewordifferentkindof , g 7 a ~ accidentsfrom any accident previously evaluated, nor reduce any margins to plant '

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safetyt Therefore, the lhense amendment does not involve a Significant Hazards t.3 Consid) ration as defined in 16 CFR 50.92. -

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