ML060330268

Response to Request for Additional Information on Request for Relief from ASME Section XI Code Requirements for Repair of Pressurizer Nozzle Penetrations

ML060330268
Person / Time
Site:	Palisades
Issue date:	01/31/2006
From:	Harden P Nuclear Management Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CAW-06-2091, TAC MC8170
Download: ML060330268 (14)

Text

NM C Palisades Nuclear Plant Committed to Nuclear Exce ll" Operated by Nuclear Management Company, LLC January 31, 2006 10 CFR 50.55a U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Palisades Nuclear Power Plant Docket 50-255 License No. DPR-20 Response to Request for Additional Information on Request for Relief from ASME Section Xl Code Requirements for Rep air of Pressurizer Nozzle Penetrations (TAC NO. MC8170)By letter dated August 11, 2005, Nuclear Management Company, LLC (NMC)requested Nuclear Regulatory Commission (NRC) approval, pursuant to 10 CFR 50.55a(a)(3)(i), for the use of an alternative to the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section Xl, related to the repair of pressurizer heater sleeve penetrations at the Palisades Nuclear Plant (PNP).By letter dated December 28, 2005, the NRC issued a RAI on the subject relief request.Enclosure 1 contains the NMC response!

to the RAI for the Palisades Nuclear Plant.Attachment 1 contains Westinghouse Document LTR-RCPL-06-6, "Response to NRC Request for Additional Information on Palisades Relief Request to use Methodology of WCAP-1 5973-P-A, Rev. 0, "Low Alloy Steel Component Corrosion Analysis Supporting Small-D)iameter Alloy 600/690 Nozzle Repair/Replacement Programs," dated January 19, 2006 (Proprietary).

Also included in Attachment 1 is a Westinghouse authorization letter CAW-06-2091 with accompanying affidavit, Proprietary Information Notice, and Copyright Notice. Because Attachment 1 contains information proprietary to Westinghouse Electric Company LLC, it is supported by an affidavit signed by Westinghouse, 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 10 CFR 2.390.NMC requests that Attachment 1, which is proprietary to Westinghouse, be withheld from public disclosure in accordance with 10 CFR 2.390. Correspondence regarding the copyright or proprietary aspects of Attachment 1, or the supporting Westinghouse affidavit, should reference CAW-06-2091, and be addressed to B.F. Maurer, Acting Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburg, Pennsylvania 15230-0355.

27780 Blue Star Memorial Highway

• Covert, Michigan 49043-9530 Telephone:

269.764.2000 Document Control Desk Page 2 Attachment 2 contains Westinghouse Document LTR-RCPL-06-6, Response to NRC Request for Additional Information on Palisades Relief Request to use Methodology of WCAP-1 5973-P-A, Rev. 0, "Low Alloy Steel Component Corrosion Analysis Supporting Small-Diameter Alloy 600/690 Nozzle Repair/Replacement Programs," dated January 19, 2006 (Non-Proprietary).

Summarv of Commitments This letter contains no new commitments and no revisions to existing commitments.

Paul A. arden Site Vice President, Palisades Nuclear Plant Nuclear Management Company, LLC Enclosure (1)Attachments (2)CC Administrator, Region Ill, UISNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC ENCLOSURE I RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION PALISADES; NUCLEAR PLANT NRC Request Attachment I to Nuclear Management Company's (NMC's) submittal of August 11, 2005, provided information (NMC responses) that the Nuclear Regulatory Commission (NRC) needs (NRC Conditions) for utilities to use WCAP-159 73-P as a reference.

However, the NRC needs more information to complete its review. Please supply the additional information requested below.4.1 General Corrosion Assessment

a. Section 2.4 of WCAP-15973-P, "Low Alloy Steel Component Corrosion Analysis Supporting Small-Diameter Alloy 600/690 Nozzle Repair/Replacement Program," Revision 1, indicates that Palisad9s' pressurizer nozzles need further analysis using actual thickness measurements to determine acceptable hole diameters.

RAI 4. 1.a -Provide the actual thickness measurement for all nozzles that are being evaluated in this relief request, orjustify not needing the measurements.

NMC Response RAI 4.1.a Attachment 1 provides response.b. NMC's response to NRC Condition I indicates that an analysis performed by Westinghouse Electric Company calculated the limiting (allowable) diameter for pressurizer heater sleeve penetrations for Palisades relative to the following:

(1) the reduction in the effective weld shear area, and (2) the required area of reinforcement for the nozzle bore holes for each type nozzle (and heater sleeve) in the pressurizer, primary coolant system piping, and steam generator primary head for each Combustion Engineering, Inc., plant.NRC Request RAI 4. 1.b -Provide the following information for the weld shear stress and reinforcement area analyses: 1. Identify the criteria used to determine the allowable bore-hole size, and include any American Society of Mechanical Engineers code criteria.2. Identify the pressure and thermal transient conditions assumed in the analysis.Page 1 of 3

3. Explain how the information in response to a, b. (1) and b. (2) was used to calculate the allowable bore-hole size.NMC Response RAI 4.1.b Attachment 1 provides response.NRC Request c. NMC's response to NRC Condition 5 indicates that initial sleeve penetration diameter was 1.173 inches.RAI 4. i.c -Identify nominal, minimum, and maximum sleeve penetration diameter values for Palisades, and explain why 1.173 inches was used in the analysis.NMC Response RAI 4.1 .c Attachment 1 provides response.

Please note that the nominal value is the minimum value.NRC Request 4.2 Thermal Fatique Crack Growth Assessment NMC's response to NRC Condition 3 says that although Palisades' water-solid operation of its pressurizer practically eliminates in-surge and out-surge transients postulated in Westinghouse Calculation Note CN-CI-02-71, a plant-specific flaw fatigue growth analysis was performed.

The analysis, provided as Attachment 2 to NMC's letter of August 11, 2005, used a 220 of in-surge transient in lieu of the 320 of in-surge transient applied in the generic analysis.

The plant-specific flaw fatigue growth analysis was not provided in Attachment 2.RAI 4.21- Provide the linear elastic fracture mechanics (LEFM) analysis, and include an evaluation of the available Charpy impact test data to demonstrate the reference temperature (RTNDT) used in the LEFM is limiting for all Palisades nozzle penetrations included in this relief request.NMC Response RAI 4.2 Attachment 1 provides response.Page 2 of 3 NRC Request 4.3. Stress Corrosion Crack Growth Assessment NMC's response to NRC Condition 2 indicates that if a pressurizer heater sleeve is repaired at Palisades, NMC will perform a review of the Palisades reactor coolant system chemistry histories, over the last two operating cycles, to confirm that the conditions required by the topical report have been met.RAI 4.3 -Confirm that the conditionS, required by the topical report were met for the previous two cycles.NMC Response RAI 4.3 NMC has reviewed the primary coolant system (PCS) chemistry histories over fuel cycles 16 and 17 and confirmed that the hydrogen overpressure, dissolved oxygen, halide and sulfate concentrations were met at Palisades Nuclear Plant.Page 3 of 3 ATTACHMENT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION WESTINGHOUSE AUTHORIZATION LETTER CAW-06-2091 WITH ACCOMPANYING AFFIDAVIT, PROPRIETARY INFORMATION NOTICE, AND COPYRIGHT NOTICE WESTINGHOUSE DOCUMENT LTR-RCPL-06-6, RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION ON PALISADES RELIEF REQUEST TO USE METHODOLOGY OF WCAP-15973-P-Q, REV. 0, "LOW ALLOY STEEL COMPONENT CORROSION ANALYSIS SUPPORTING SMALL-DIAMETER ALLOY 600/690 NOZZLE REPAIR/REPLACEMENT PROGRAMS," DATED JANUARY 19, 2006 (PROPRIETARY) 31 Pages Follow O Westinghouse U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Westinghouse Electric Company Nuclear Services P.O. Box 355 Pittsburgh, Pennsylvania 15230-0355 USA Direct tel: (412) 374-4419 Direct fax: (412) 374-4011 e-mail: maurerbf~westinghouse.com Our ref: CAW-06-2091 January 20, 2006 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

Response to NRC Request for Additional Information on Palisades Relief Request to use Methodology of WCAP-1 5973-P-A, Rev. 0, "Low Alloy Steel Component Corrosion Analysis Supporting Small-Diameter Alloy 600/690 Nozzle Repair/Replacement Programs" The proprietary information for which withholding is being requested in the above-referenced letter is further identified in Affidavit CAW-06-2091 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. 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 2.390 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Nuclear Management Company LLC (NMC).Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-06-2091, and should be addressed to B. F. Maurer, Acting Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.

Very truly yours )B. IMaurer g ager{J Re mpliance and Plant Licensing Enclosures cc: B. Benney L. Feizollahi A BNFL Group company CAW-06-2091 bcc: B.F. Maurer (ECE 4-7A) IL R. Bastien, 1L (Nivelles, Belgium)C. Brinkman, IL (Westinghouse Electric Co., 12300 Twinbrook Parkway, Suite 330, Rockville, MD 20852)RCPL Administrative Aide (ECE 4-7A) 1 L, IA (letter and affidavit only)A BNFL Group company CAW-06-2091 AFFIDAVIT STATE OF CONNECTICUT:

ss: COUNTY OF HARTFORD: Before me, the undersigned authority, personally appeared Ian C. Rickard, 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 Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief: I. C. Rickard, Licensing Project Manager Regulatory Compliance and Plant Licensing Sworn to and subscribed PeO~re me this day 2006 My commission , .

2 CAW-06-2091 (1) I, Ian C. Rickard, dispose and say that I am a Licensing Project Manager, Westinghouse Electric Company LLC (Westinghouse), and as such I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 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 Westinghouse 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 2.390 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.(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.(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 whather 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.Under that system, information is held in confidence if it falls 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.

3 CAW-06-2091 (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.(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.

There are sound policy reasons behind the Westinghouse system which include the following: (a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its compel itors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.(b) It is information that 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 components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

4 CAW-06-209 1 (e) Unrestricted 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.(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.(iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.(a) (v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in "Response to NRC Request for Additional Information on Palisades Relief Request to use Methodology of WCAP-1 5973-P-A, Rev. 0, 'Low Alloy Steel Component Corrosion Analysis Supporting Small-Diameter Alloy 600/690 Nozzle Repair/Replacement Programs'," dated January 19, 2006, being transmitted by the Nuclear Management Company letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted for use by Westinghouse for Palisades Nuclear Plant enables Westinghouse to support utilities with NSSS plants in preparing nozzle repair or replacement designs for partial penetration nozzles or pressurizer heater sleeves.Further this information has substantial commercial value as follows: (a) Westinghouse 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 its methodology from which the Palisades work is based.

5 CAW-06-209 1 (c) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

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 nozzle repair 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 considerable 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.Further the deponent sayeth not.

PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, 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, only 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 (f)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 holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).

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 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding.

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, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.