ML20237L044

Requests That Proprietary Replacement Pages for Rev 2 to WCAP-11306 Be Withheld (Ref 10CFR2.790).Affidavit Encl

ML20237L044
Person / Time
Site:	Farley
Issue date:	08/18/1987
From:	Wiesemann R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	Murley T Office of Nuclear Reactor Regulation
Shared Package
ML19292H703	List: ML20237L002 ML20237L029 ML20237L044
References
CAW-87-077, CAW-87-77, NUDOCS 8708270394
Download: ML20237L044 (23)

Text

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Westinghouse Power Systems pjllu gh Pennsylvania 15230-0355 Electric Corporation i 1

August 18, 1987 l CAW-87-077 j 1

Dr. Thomas Murley, Director )

Office of Nuclear Reactor Regulation i U.S. Nuclear Regulatory Commission Washington, D.C. 20555 APPLICATION FOR WITHHOLDING PROPRIETARY l INFORMATION FROM PUBLIC DISCLOSURE j l

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Subject:

Transmittal of Errata Sheets for WCAP-11306, Revision 2

Dear Dr. Murley:

I The proprietary material for which withho7 %g is being requested in the enclosed letter by the Alabama Pcwer Company is fu3 eer identified in an affidavit signed by the owner of the proprietary infonnation, 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 i 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 j Accordingly, this letter authorizes the utilization of the accompanying affidavit by Alabama Power Company.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-87-077, and should be addressed to the unders'.gned.

Very truly yours,

- ccwcu

/dmr h rt A. Wiesemann, Manager Regulatory & Legislative Affairs Enclosure (s) cc: E. C. Shomaker, Esq.

Office of the General Council, NRC 8708270394 870825

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PDR ADOCK 05000348 .

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i 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.

i IN ORDER TO CONFORM TO THE REQUIREMENTS OF 10CFR2.790 0F 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 VEP.SIONS HAVING BEEN 1 DELETED. THE JUSTIFICATION FOR CLAIMING THE INFORMATION S0 DESIGNATED AS PROPRIETARY IS INDICATED IN BOTH VERSIONS BY MEANS OF LOWER CASE LETTERS (a)

THROUGH (g) CONTAINED WITHlN PARENTHESES LOCATED AS A SUPERSCRIPT IMMEDIATELY FOLLOWING THE B. RACKETS 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)(11)(a) THROUGH (4)(ii)(g) 0F THE AFFIDAVIT ACCOMPANYING THIS TRANSMITTAL PURSUANT TO 10CFR2.790(b)(1) . )

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. . CAW-81-79 AFFIDAVIT l COMMONWEALTH OF PENNSYLVANIA: .

ss 1 COUNTY OF ALLEGHENY:

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l Before me, the undersigned authority, personally. appeared j I

Robert A. Wiesemann, who, being by me duly sworn according to law, l deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Corporation (" 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:

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Ch 8All/$ l Robert A. Wiesemann, Manager Regulatory and Legislative Affairs. '

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Swo'n to and subscribed before me this e day of. D & v. 41 1981.

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CAW-81-79 (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- j 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- l l

10CFR Section 2.790 of the Commission's regulations and in con-l junction with the Westinghouse application for withholding-ac- l companying this Affidavit.

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

J (4) Pursuant to the provisions of paragraph (b)(4) of Section 2.790 l of the Dmission's regulations, the following is furnished for l consid N tion by the Commission in determining whether the in-formation 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.

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l CAW-81 -79 (ii) The information is of a type customarily held in confidence by Westinghouse and not customari'y disclosed to the public.

Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in j that connection, utilizes a system to determine when and l 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 l rational basis required.

l Under that system, information is held in confidence if it.

l falls in one or more of several types, the release of which

'1 might result in the loss of an existing or potential com- )

f petitive advantage, as follows:

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

where prevention of its use by any of Westinghouse's j competitors without license from Westinghouse consti-tutes 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.

CAW-81-79 (c) Its use by a competitor would reduce his expenditure of. resources or 3mprove his competitive position in the design, manufn ture, shipment,. installation, assurance of quality, or licensing a similar. product.

1 (d) It reveals cost or price information, production cap-acities, budget levels, or comercial strategies of Westinghouse, its customers or suppliers.

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

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

(a) The use of such informa'cion by Westinghouse gives Westinghouse a competitive advantage over its com-petitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

CAW-81-79 (b) It is information 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.

(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-mation, 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.

(f) The Westinghouse capacity to invest corporate assets 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 Commission in confidence and, under the provisions of 10CFR Section 2.790, 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 pre-viously employed in the same ori.ginal manner or method to the best of our knowledge and belief.

(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 Virgil C.

Summer Nuclear Power Plant Unit No.1, WCAP-9912, Revi- i sion 2 (Proprietary) being transmitted by South Carolina Electric 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.

Summer 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 information is part of that which will enable Westing-house to:

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

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CAW-81-79 i

(b) Establish the minimum wall thickness in compliance with !

Regulatory Guide 1.121.

(c) Establish the stress limits "'.rsus 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 commercial 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.

i Ptslic disclosure of this information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to pro-vide similar analytical documentation 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 require-ments for licensing documentation without purchasing the right to use the information.

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CAW-81-79 1

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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 ..

I requisite talent and experience, would have to be expended . I 1

for system design software development.

i Further the deponent sayeth not.

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AW-77-58 AFFIDAVIT COMMONWEALTHOFPENNSYLVANI5:

ss COUNTY OF ALLEGHENY:

Before 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 averments of fact set forth.in this Affidavit are true and correct  !

to the best of his knowledge, information, and belief:

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. Robert A. Wiesemann, Manager Licensing Programs Sworn to and subscribed day befo e me this -

of . lwlo1977. l Y'

%a Notary Public oswa_- '

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4 (1) I am Manager, Licensing Programs, in the Pressurized Water Reactor Systems 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 disclosure in connection with nuclem power plant licensing or rulemaking l proceedings, and am authrized to apply for its withholding on f behalf of the Westinghc use Water Reactor Divisions.

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

_. l (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.

l (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 l

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 l .

, 3 's ' ,

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.

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 com-petitive advantage, as follows:

l (a) The information reveals the distinguishing aspects of-a process (or component, structure, tool, method', etc.) l where prevention of its use by any of Westinghouse's competitors without license from Westinghouse consti-tutes a competitive economic advantage over other companies.

J (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 3 i

or improved marketability.

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

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

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(e) It reveals aspects of past, present, or future Westing-house or cus~tomer funded development plans and programs of potential commercial value to Westinghouse.

l (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.

(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.790 it is to be received il confidence by the Commission.

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(iv) The information is not available in public sources to the best of our knowledge and belief.

I (v) The proprietary information sought to be withheld in this submittal is in the attachment to Westinghouse letter number NS-CE-1596, Eiche1dinger to Stuart, dated November 8,

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i 1977, concerning Westinghouse Steam Generator Programs.

The letter and attachment are being submitted in response to the request of the Commission and its October 25, 1977 memorandum, Stuart to Eisenhut concerning Westinghouse Steam Generator Programs.

Public disclosure of this information is likely to cause substantial harm to the competitive position of Westinghouse as it would reveal the strategic plans of Westinghouse regarding the nature .and direction of its development programs. .

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Information regarding its development programs is valuable to Westinghouse because:

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Information resulting from its development programs g'ives

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Westinghouse a competitive advantage over its competitors.

It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

-i (b) It is information which is marketable in many ways. The extent to which such information is available to compet-itors 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 com-petitive disadvantage by reducing his expenditure of resources at our expense.

(d) Each component of proprietary infomation pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If. competitors acquire components of proprietary information, any one

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component may be the key to the entire puzzle, thereby I depriving Westinghouse of a competitive advantage.

(e) The Westinghouse capacity to invest corporate, assets in ,

I research and development depends upon the success in obtaining and maintaining a competitive advantage.

Altogether, a substantial amount of money and effort has been and is being expended by Westinghouse in its development programs which could only be duplicated by a competitor if he were to invest similar sums of j

money and provided he had the appropriate talent available.

Further the deponent sayeth not.

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l Nori-Proprietary Pages

1 3.0 DESIGN I 4

3.1 SLEEVE DESIGN DOCUMENTATION The J. M. Farley Unit 1 and Unit 2 steam generators were built to the 1968 edition Summer 1970 Addenda and 1971 edition respectively of Section III of the ASME Boller and Pressure Vessel Code, however,'the sleeves have been designed.and analyzed to the 1983 edition of Section III of the Code through the winter 1983 addenda as well as applicable ~ Regulatory Guides. The associated materials and processes also meet the requirements of the Code.

The specific documentation applicable to this program are listed in Table 3.1-1.

3.2 SLEEVE DESIGN DESCRIPTION The reference design of the sleeve, as installed, is illustrated in Figure j 3.2-1. [

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l j a.c.e At the upper end, the sleeve configuration (see Figure 3.2-1) consists of a l section which is [

3a .c.e This I joint configuration is known as a hybrid expansion joint (HEJ). [

j ac.e In the process of sleeve length optimization and allowing for axial tolerance in locating defect by eddy current inspection, the guideline was the icwer most elevation of the hard roll region to be positioned a minimum of 1 inch above the eddy current detected defect area of the tube.

3592M/081087:49 3-1 i k

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TABLE 3.1-1 ASME CODE AND REGULATORY REQUIREMENTS l

Item Applicable Criteria Requirement l

Sleeve Design Section III NB-3200, Analysis NB-3300, Wall Thick-ness Operating Requirements Analysis Conditions l

Reg. Guide 1.83 S/G Tubing Inspec-tibility Reg. Guide 1.121 Plugging Margin Sleeve Material Section II Material Composition Section III NB-2000, Identifica-tion, Tests and Examination Code Case N-20 Mechanical Proper-

. ties Sleeve Joint 10CFR100 Plant Total Primary-Secondary Leak Rate Technical Specifications Plant Leak Rate 3592M/060986: 49 3-2

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ENCLOSURE 2 l l

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Tubesheet Region Plugging Criterion 4 Replacement Pages l 1

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2.1.1 - RAD 7AL PRELOAD TEST CONFIGURATION DESCRIPTION The test program was designed to simulate the interface of a tube-to-tubesheet full depth hardroll for a model 51 steam generator. The test configuration consisted of six cylindrical collars, approximately [ ]"'C inches in length, [ l a.c.e inches in outside diameter, and [ 3a ,c.e inch in I inside diameter. The RE process was designed to provide the same preload independent of hole diameters of up to approximately 0.935 in. The preload was determined by tube thinning which, in turn, was determined by roll expander motor stalling torque. A single nominal stalling torque value was used for all tube-to-tubesheet joints. A mill annealed, Inconel 600 (ASME SB-163), tubing specimen, approximately [ ]"'C inches long with a nominal outside diameter of [ Ja .c.e inch before rolling, was hard rolled into each collar using a process which simulated actual tube installation conditions.

The design of the collars was based on the results of performing finite element analfsis of a section of the steam generator tubesheet to determine radial stiffness and flexibility. The inside diameter of the collar was chosen to tuatch the size of holes drilled in the tubesheet. The outside diameter was selected to provide the same radial stiffness as the tubesheet..

The collars were fabricated from AISI 1018 carbon steel similar in mechanical properties to the actual tubesheet material. The collar assembly was clamped in a vise during the rolling process and for the post roll measurements of the tube ID. Following the taking of all post roll measurements, the collars were saw cut to within a small distance from the tube wall. The collars were then split for removal from the tube and tube ID and OD measurements were repeated.

Two end boundary conditions were imposed on the tube specimen during rolling.

The end was restrained from axial motion in order to perform a tack roll at j the bottom end, and was allowed to expand freely during the final roll..

4 2.1.2 PRELOAD TEST RESULTS DISCUSSION AND ANALYSIS All measurements taken during the test program are tabulated in Table 1. The data recorded was employed to determine the interfacial conditions of the 4306M:49/042487 9 ,

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pressures. The difference between an analysis assuming plane stress and one assuming plane strain is manifested only in a ci.ange in the constant C2 ' , i for materials having a Poisson's ratio of 0.3, the following relation holds:

C2 (Plane Strain) = 0.862

• C 2(Plane Stress) (2) ..

I 1 The effect on the calculated residual pressure is that plane strain results ,

are higher than plane stress results by slightly less than 10 percent.

Comparing this effect with the results reported in reference 2 indicated that ,

better agreement with test values is achieved. It is to be noted that the -

residual radial pressure at the tube to tubesheet interface 15.the compressive f radial stress at the OD of the tube, By substituting the expressions for the constants into equation (1) the deflection at any radial location within the tube wall as a function of the f internal and external pressure (radial stress at the ID and 00) is found. This [I expression was differentiated to obtain flexibility values for the tube '

3 deflection at the ID and 00 respectively, e.g., dui/dPo is the ratio of the radial deflection at the ID due to an OD pressure. Thus, dui/dPo was used to find the interface pressure and radial stress between the tube and the ,!

tubesheet as:

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S --P = - (ID Radial Springback). / (dU1/dPo) p (3) ro o - ,,.

g The calculated radial residual stress for each specimen at:each i location is tabulated in Table 2. The mean residual tube 00 radial stress Ind the standard deviation was found to be [ 3"'C psi and [ 3a c.e as respectively.

In order to determine a value to be used in the analysis, a rilerance' factor for [ Ja .c.e percent confidence to contain I J a 'C percent of the population was calculated, considering the [ -]"'C useable data points, to be [ l a.c.e Thus, a [

. 3 A 'C

lowr' tolerance limit (LTL) for the /

, ()

radial residual preload at room temperature is [ 3a ,c.e p3g, i

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a 4308M:49/042aB7 *

)/

= __ ___= _ __._ _ - Y i

, 7.16*10~0 in/in/*F. Thus, there is a net difference of 0.63*10-6 in/in/*F in the expansion property of the tv) materials. Considering l

a temperature difference of approximate?y 483*F between ambient and '

cold leg op'erating conditions the increase in preload between the tube (t) and the tubesheet (ts) was calculated as- I i

Sri = (0.63E-6)*(483)*RCollar ID) / 2 )/ ((dui/dP1)ts- (duo /dPo)t}

(4)

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This calculation was also performed and tabulated in Table 2. The results indicaH that the increase in preload radial stress due to l

thermal expansion'is ( )#'E'" psi. It is to be noted that this value applies for both normal operating and fa.ulted conditions. l

2. Internal Pressure Tightening - The maximum normal operating j differential pressure from the primary to secondary side of the steam g generator is ( Ja .c.e psi during a loss of Iced transient. The l internal pressure acting on the wall of the tube will result in an

increase c>f the radia' preload on the crhr of the pressure value. 1 The increase was found as

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q (duo /dPi) /( (dVi/dPi)g - (duo /dPo) ) l SrP -Po = - P3 (5)

[ In actuality, the increase in preload will be more dependent on the internal pressure :f ~the tube since water at secondary side pressure woula not be evpected between the tube and the tubesheet. This differential pressure, along with the associated temperature and tubesheet bowing effects, was the mcst stringent normal condition in ter.Ts of determining the f* itngth. Increased differential pressure not only increases radial preload directly, it also increases tubesheet bending which reduces preload.

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