ML18039A361

Forwards Description of TVA Insp & Repair Plan for BFN Unit 3 Core Spray Sys Piping Internal to Reactor Vessel & Ltr Forwarding Proprietary GE Drawings.Proprietary Encls Withheld

ML18039A361
Person / Time
Site:	Browns Ferry
Issue date:	05/20/1998
From:	Abney T TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18039A362	List: ML18039A361
References
TAC-M98059, NUDOCS 9806020008
Download: ML18039A361 (26)

Text

CATEGORY 1 A~iSULATOY TMFORMATTOM DTSTRTBUTYOPSYSTEM (RTDS)

'CCESSION NBR:9806020008 DOC.DATE: 98/05/20 NOTARIZED: YES DOCKET ¹ FACIL:50-296 Browns Ferry Nuclear. Power Station, Unit 3, Tennessee 05000296 AUTH. NAME AUTHOR AFFILIATION ABNEY,T.N. Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch. (Document Control Desk) repair plan for

SUBJECT:

Forwards 3

description of TVA insp E core spray sys piping internal to reactor vessel &.

forwarding proprietary GE drawings. Proprietary encls ltrUnit BFN withheld.

'DISTRIBUTION CODE: D030D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: TVA Facilities Routine Correspondence NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL 0 PD2-3 1 1 PD2-3-PD 1 1 DEAGAZIO,A 1 1 INTERNAL: ACRS 1 ILE CE , 1 1 1 OGC/HDS3 0 RES/DE/SSEB/SES 1 1 EXTERNAL: NOAC 1~ NRC PDR Q'%

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NOTE TO ALL MRIDSE RECIPIENTS PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 9 ENCL 8

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Tennessee Vattey Authority. Post Otfice Box 2000, Decatur, Alabama 35609 May 20, 1998 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:

In the Matter of Docket No. 50-296 Tennessee Valley Authority BROWNS FERRY NUCLEAR PLANT (BFN) UNIT 3 REACTOR PRESSURE VESSEL INTERNALS I AUGMENTED WELD INSPECT ION I IND CATIONS AT THE CORE SPRAY SYSTEM PIPING COLLAR-TO-SHROUD WELD INSPECTION AND REPAIR PLANS FOR THE CYCLE 8 REFUELING OUTAGE (TAC NO. M98059)

On March 7, 1997, TVA submitted a description of flaws identified during an inspection of Core Spray System piping within the reactor vessel for BFN Unit 3. TVA also provided an evaluation of the effect of the identified flaws on the structural integrity of the core spray piping. In addition, TVA provided supplemental information, by letters dated March 9, 1997 and March 10, 1997.

In the March 10, 1997 letter, TVA committed to work with the Boiling Water Reactor Vessel and Internals Project (BWRVIP)

Committee to develop inspection methods and repair criteria for the P4d weld. TVA also committed to reinspect or repair the Core Spray System piping and to provide its plans to the NRC staff 120 days prior to the start of the BFN Unit 3 Cycle 8 (Fall 1998) refueling outage.

The enclosure to this letter describes TVA's inspection and repair plan for the BFN Unit 3 Core Spray System piping internal to the reactor vessel. Attachment A to the 9'806020008 980520 PDR ADOCK 05000296 P PDR Q~

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U.S. Nuclear Regulatory Commission Page 2 Hay 20, 1998 enclosure contains information proprietary to General Electric (GE). GE requests that these documents be withheld from public disclosure in accordance with 10 CFR 2.790(a)(4).

An affidavit supporting this request is provided in the enclosure in accordance with 10 CFR 2.790(b)(1).

If you have further questions regarding this information please call me at (256) 729-2636.

S'erely, E.

Manager of Lice ng and Industry Affai s Enclosure cc (Enclosure):

Mr. 'Harold O.. Christensen, Branch Chief U.S. Nuclear .Regulatory Commission Region II 61 Forsyth Street, S.W.

.Suite 23T85 Atlanta, Georgia 30303 NRC Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611 Mr. Albert W. De Agazio, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852

0 ( ~ i ENCLOSURE TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)

UNIT 3 CORE SPRAY SYSTEM ~ AUGMENTED WELD INSPECT ION ~

INDICATIONS AT CORE SPRAY SYSTEM PIPING COLLAR-TO-SHROUD WELD INSPECTION AND REPAIR PLANS FOR THE CYCLE 8 REFUELING OUTAGE BACKGROUND In response to instances of cracking in core spray spargers, NRC requested in IE Bulletin 80-13, "Cracking In Core Spray Spargers," that all operating boiling water reactor facilities perform a visual inspection of the core spray spargers and the segment of piping between the inlet nozzle and the vessel shroud. NRC requested this inspection be performed at the next scheduled refueling outage and each subsequent refueling outage until further notice. The bulletin also requested that any identified cracking be evaluated and reported to NRC. TVA complied with this request.

On March 7,, 1997, TVA submitted by letter, a description and structural evaluation of indications identified during the Unit 3 Cycle 7 examination of the Core Spray System piping. As a result of verbal requests for additional information from the NRC staff, TVA submitted supplemental information on March 9 and 10, 1997. In the March 10, 1997 letter, TVA committed to (1) work with the Boiling Water Reactor Vessel and Internals Project (BWRVIP) Committee to develop an inspection methodology and criteria for repair of the P4d weld (which had shown indications upon visual examination), and (2) provid'e TVA's plan for inspection of the P4d weld to the staff 120 days prior to the start of the Unit 3 Cycle 8 (Fall 1998) refueling outage.

NRC letter dated March 11, 1997, informed TVA that the staff had not identified any technical issues, during its initial review, that would prevent the restart of BFN Unit 3 from the Cycle 7 refueling outage. As part of its ongoing review, the NRC staff subsequently identified a question regarding the structural integrity of weld P9. The staff requested

t5 additional information, by letter dated May 28, 1997, regarding the structural integrity of weld P9 in order to assess the effect of the failure of welds P9 and P8, which could result in degraded Core Spray System function. TVA provided the information requested by letter dated June 10, 1997. In addition, TVA letter dated June 24, 1997, provided information to clarify the methodology used for the calculation of peak cladding temperature for loss of coolant accidents. NRC issued a safety evaluation report by letter dated September 22, 1997. In that evaluation, the NRC staff determined that continued operation of BFN Unit 3 for the current fuel cycle (Cycle 8) was acceptable.

TVA's commitments and actions taken regarding the BFN Unit 3 Core Spray piping weld indications are summarized below.

TVA Commitment TVA will submit its plans to the NRC for the reinspection or repair of the BFN Unit 3 Core Spray System piping, internal to the reactor vessel, 120 days prior to the start of the Cycle 8 refueling outage. (TVA letter to NRC dated March 7, 1997)

Actions Taken TVA's inspection and repair plans for the BFN Unit 3 Core Spray System piping, internal to the reactor vessel, are as follows:

Replacement of the lower section piping of downcomer C will be performed to address the crack indications found during the Unit 3 Cycle 7 refueling outage in welds P8b and P4d.

This replacement consists of a General Electric (GE) supplied designed repair which will replace the piping from upstream of the slip joint down to the shroud attachment.

As shown on the attached sketches (Attachment A), this repair will eliminate the hidden P9 weld. The lower section replacement was designed in accordance with the guidance provided in the BWRVIP-16, "Internal Core Spray Piping and Sparger Replacement Design Criteria," which has been submitted for NRC review. The replacement design will be consistent with the existing BFN design/licensing basis, and will be evaluated pursuant to 10 CFR 50.59 to determine whether prior NRC approval is required.

The core spray spargers and associated piping will be inspected using the guidance provided in the currently issued "BWRVIP-18, BWR Core Spray Internals Inspection E-2

41 (Qi and Flaw Evaluation Guidelines." Visual inspections will be performed on the Unit 3 core spray t-box repair brackets of

'both loops. Ultrasonic (UT) examination will be performed on the accessible areas of piping welds P4a, P4b, P4c, P4d, P5, P6, P7, PSa, and PSb of downcomers A, B, and D. The accessible areas of P4a and P4b piping welds of downcomer C will be examined by UT. Piping welds from upstream of the slip joint to the shroud (welds P4c, P4d, P5, P6, P7, P8a, and PSb) of downcomer C will be replaced as part of the planned repair effort. The accessible areas of piping welds and brackets (P2, P3, and PB) not being replaced or receiving a UT examination will receive a visual inspection. The accessible areas of core spray sparger brackets (Sb) and sparger welds (Sl, S2, S3, and S4) will be visually inspected. As previously committed, arc strikes and linear indications identified during previous inspection efforts will receive a visual reinspection. These indications have received repeated inspections with no growth noted.

Since the issuance of IE Bulletin 80-13, TVA has conducted inspections which included examination of the piping general surface area away from welds. The inspection of these areas away from welds has not resulted in the identification of any crack indications. Therefore, in accordance with the guidance listed in BWRVIP-18, no inspection of the piping general surface area away from the welds is planned. As stated in BWRVIP-18, it is expected that portions of surfaces be observed on a regular basis as cameras move past 'ill these areas to inspect the core spray welds or other reactor internal components.

TVA Commitment TVA will work with the BWRVIP Committee to develop an inspection methodology and criteria for repair of the P4d weld. (TVA letter to NRC dated March 10, 1997)

Actions Taken TVA has actively participated in the BWRVIP Committees which have prepared and submitted the reactor internals inspection and evaluation documents for NRC review. Additionally, TVA has worked with GE on the application of a methodology which provides the capability to perform ultrasonic examination of the accessible areas of weld P4d. This ultrasonic methodology was used successfully during the recent Unit 2 Cycle 9 refueling outage and will also be utilized during the Unit 3 Cycle 8 (Fall 1998) refueling outage.

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Ql <Qi TVA Commitment The inspection plan for the P4d weld will be submitted 120 days prior to the start of the Unit 3 Cycle 8 refueling outage currently scheduled for October 1998. (TVA letter to NRC dated March 10, 1997)

Actions Taken As described above, the subject P4d weld on downcomer C will be removed as part of the planned lower section replacement.

The accessible area of the P4d welds on the other three downcomers are scheduled to be inspected using UT techniques during the Unit 3 Cycle 8 (.Fall 1998) refueling outage.

4l ii INFORM'ATION CONTAINED NITHIN ATTACEB4ENT A, FIL M&S:

BFN-CS-01 BFN-CS-02 BFN-CS-03 BFN-CS-04 BFN-CS-05 BFN-CS-06 BFN-CS-07 PROPRIETARY INFORMATION AFFIDAVIT ATTACHED PER 10 CFR 2. 790 (B) (1)

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<gi GE Nuclear Energy Reactor Modification Services 175 Curtner Avenue, MIC 571 San Jose, CA 95125 May .1'4, 1998 1HHVV-S005 Mr. F. E. Hartwig Browns Ferry Nuclear Plant Tennessee Valley Authority PO Box 2000, MODS 2-A Decatur, AL 35609

SUBJECT:

Core Spray Lower Sectional Replacement - Phase 2 Propietary Drawing'Transmittal PO No. 92NNP-82068D,.Release No. 1227955

Dear Mr. Hartwig:

'This letter transmits. the following GE,proprietary figures contained in Attachment A to TVA:

Figure BFN-CS-Ol Figure BFN-CS-02 Figure BFN-CS-03 Figure BFN-CS-04 Figure BFN-CS-05 Figure BFN-CS-06 Figure BFN-CS-07 Note: This letter with the attached figures and the supplied affidavit are to be submitted as a package.

Please call me (408-925-3770), ifyou have any, questions regarding this, item.

Sine rel,

. P. Svarney Core Spray P 'nager GE Nuclear Energy cc: G. Nelson, J. Rodabaugh

<Qi General Electric. Company AFFIDAVIT I, David J. Robare, being duly sworn, depose and state as follows:

.(1) I am Technical Account Manager, Technical Services, General Electric Company

("GE") and have been delegated;the function of. reviewing. the information described in,paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.

(2) The information sought to be withheld is contained in a letter &om GE to TVA,

'letter number 1HHVV-S005, dated May 14 1998, subject "Core Spray Lower Sectional Replacement - Phase 2. The proprietary information is the entirety of attached figures BFN-CS-1,2,3,4,5,6,7 of Attachment A.

(3) In making this application for withholding of proprietary information of which it is the owner,.GE relies upon the exemption &om disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), 2.790(a)(4), and 2.790(d)(1) for "trade secrets and commercial or financial information obtained from a person and privileged: or confidential" (Exemption 4). The material for which exemption &om disclosure is here sought is all "confidential commercial information", and some. portions also qualify under the narrower definition of "trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Ener Pro'ect v. Nuclear Re ulato Commission 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Grou

v. FDA 704F2d1280 (DC Cir. 1983).

(4) Some examples of categories of information which fit into the definition of proprietary information are:

a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by General Electric's competitors without license from General Electric constitutes a competitive economic

, advantage over other companies;

b. Information which, if used 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; 12/13/93RTH AffidavitPage 1

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c. Information which reveals cost or price information, production capacities, budget levels, or commercial strategies of General Electric, its customers, or its suppliers;

d. Information which reveals aspects of past, present, or future General Electric customer-funded development plans and programs, of potential commercial value to General Electric;

e. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

The information sought to be withheld is considered to be proprietary for the reasons set forth in both paragraphs (4)a., (4)b., and (4)e. above.

(5) The information sought to be withheld is being submitted to NRC in confidence.

The, information is of a sort customarily held'in confidence by GE, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GE, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary, agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.

(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to such documents within GE is limited on a "need to know" basis.

(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GE are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

(8) The information identified in paragraph (2), above, is classified as proprietary because it contains conceptual design information depicting the GE method for replacing the lower segment of the core spray line. Patent disclosures for this design have been submitted . This design was developed at significant expense to GE.

12/l3/93RTH AffidavitPage 2

~I I+I (9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GE's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GE's comprehensive BWR.safety and technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

'The research, development, engineering, analytical and,NRC review costs comprise

. a substantial investment of time and money by GE.

The precise value of the expertise to devise an evaluation process and apply the

correct analytical methodology is dificult to quantify, but it clearly is substantial.

if GE's competitive advantage will be lost its competitors-are able to-use the results if of the GE:experience to normalize or verify their own process or they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

The value of this information to GE would be-'lost ifthe information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources. would unfairly provide competitors with a windfall, and deprive GE of the opportunity to exercise its competitive advantage.to seek an adequate return on its large investment in developing these very valuable analytical tools.

12/13/93RTH AffidavitPage 3

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STATE OF CALIFORNIA )

) ss:

COUNTY OF SANTA CLARA )

David J. Robare, being duly sworn, deposes and says:

That he has read the foregoing affidavit and the matters stated therein are true and correct to the best of his'knowledge, information, and belief.

Executed at San Jose, California, this 14 th day of May 1998.

David J. Robare General Electric Company Subscribed.and sworn before me this 14 th day of May 1998.

Notary Public, State of California

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COMM. 01030164 O- NOTARY PUBLIGCALIFORNIA, Q tL SAN FRANCISCO COUNTY My Comm ExOIres June 19, 1998 12/l3/93RTH AffidavitPage 4

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