ML15149A283

PWROG-15042-P, Revision 0, Appendix a, NextEra Energy, Seabrook, Unit 1, Summary Report for the Cold Work Assessment (Non-Proprietary). Application for Withholding Proprietary Information from Disclosure and Affidavit

ML15149A283
Person / Time
Site:	Seabrook
Issue date:	05/26/2015
From:	PWR Owners Group, Westinghouse
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML15149A278	List: ML15149A280 ML15149A282 ML15149A283 SBK-L-15073, Responses to Applicant/Licensee Action Items for the Inspection and Evaluation Guidelines for Pressurized Water Reactor Vessel Internals (MRP-227-A)
References
CAW-15-4190, MRP-227-A, SBK-L-15073, TAC ME4028 PWROG-15042-P, Rev 0
Download: ML15149A283 (13)

Text

Enclosure 8 to SBK-L-15073Appendix A of Westinghouse Report (PWROG-15042-P, Revision 0)NextEra Energy, Seabrook Unit 1Summary Report for the Cold Work Assessment(Non-Proprietary)

WESTINGHOUSE NON-PROPRIETARY CLASS 3A-1APPENDIX ACOLD WORK ASSESSMENTWestinghouse Electric Company LLC1000 Westinghouse DriveCranberry Township, PA 16066, USA© 2015 Westinghouse Electric Company LLCAll Rights ReservedPWROG-1 5042-PMay 2015Revision 0-WESTINGHOUSE NON-PROPRIETARY CLASS 3A-2A.1 REACTOR INTERNALS COLD WORK ASSESSMENTAs a result of the review of the Applicant/Licensee Action Items (AILAI) 1, 2 and 7 responsessubmitted by the industry, the U.S. Nuclear Regulatory Commission (NRC) has requested thatadditional information on cold work in Reactor Vessel Internals (RVI) be provided to supportA/LAI 1 plant-specific demonstration of MRP-227-A [4] applicability. The issue of cold work instainless steel relates to the criteria in MRP-1 75 [3] for stress corrosion cracking (SCC). Thespecific NRC question is focused on whether the materials of original construction for thedomestic fleet RVI components contain "severe cold work" (greater than 20 percent). Aguideline template (MRP 2013-025 [1]) was completed by Westinghouse and the Electric PowerResearch Institute (EPRI) to define a process for evaluating cold work in the RVI componentmaterials. For the purposes of this evaluation, it is noted that the assessments are based onthe screening and binning process based exclusively on material specifications. Thisassessment did not specifically investigate any other avenues, such as field installation.The MRP-227-A [4] Applicability Template Guideline, as summarized in MRP 2013-025 [1], isfollowed to support this assessment and response to the NRC.A.2 SEABROOK UNIT 1 -REACTOR INTERNALS COLD WORK ASSESSMENTWestinghouse has evaluated the Seabrook Unit I reactor internals components according toindustry guideline MRP 2013-025 [1] and the MRP-191 [2] industry generic component listingsand screening criteria (including consideration of cold work as defined in MRP-175 [3], notingthe requirements of subsection 3.2.3). In addition to consideration of the material fabrication,forming and finishing process, a general screening definition of "severe cold work" as a resultingreduction in wall thickness of 20 percent was applied as an evaluation limit. It was confirmedthat all of Seabrook Unit 1 components, as applicable for the design, are included directly in theMRP-191 component lists, or have been evaluated accordingly.The evaluation included a review of all plant modifications affecting reactor internals and theplant operating history. The components were procured according to the American Society forTesting and Materials (ASTM) International or American Society of Mechanical Engineers(ASME) material specifications that were called out on the original plant construction drawings.Material and component procurement was through applicable quality-controlled protocols.Therefore, material identification based on the material call-outs and notes in the componentdrawings was an efficient and reasonable approach to identify the materials of construction forthe RVI components in Seabrook Unit 1.Based on the specifications called out on the Seabrook Unit 1 component drawings, theRVI components are binned into the five material categories identified in MRP 2013-025 [1].Cold work categories based on MRP 2013-025 include:* Cast austenitic stainless steel (CASS) (Category 1)* Hot-formed austenitic stainless steel (Category 2)PWROG-15042-P May 2015Revision 0 WESTINGHOUSE NON-PROPRIETARY CLASS 3A-3* Annealed austenitic stainless steel (Category 3)* Fasteners austenitic stainless steel (Category 4)Cold-formed austenitic stainless steel without subsequent solution annealing(Category 5)The potential for cold work is directly controlled by the materials specifications. Essentially all ofthe components that are binned (based on their specified materials) as Categories 1, 2 and 3are non-cold worked; therefore, they have less than 20 percent cold work according to theNRC criterion. Similarly, any component binned under Category 5 has the potential to containgreater than 20 percent cold work. Category 4 materials are fasteners that may have beenintentionally strain-hardened.During the fabrication of fasteners, the strain hardening was typically intentionally restricted toless than 20 percent. These restrictions, if present, were noted on engineering drawings. Arestriction or limitation on the material yield stress (e.g., a maximum of 90 ksi) would indicatethat the material cold work would be limited to be less than 20 percent. In the absence of arestriction on the maximum yield stress of strain-hardened material, a conservative approachhas been taken to assume the potential for greater than 20 percent cold work.Where multiple options existed for a component or assembly, the bounding condition of coldwork was taken as the option that had the greater potential to include greater than 20 percentcold work. This option was then employed in the assessment of the component, and wasselected for the purposes of the assessment. In some instances, sequential fabrication wouldappear to mitigate any potential for cold work; however, since the historical record was notdetailed the potential is noted, but a conservative approach was selected for this assessment.The evaluation, performed consistently with the industry guideline [1], concluded that the reactorinternals Category 1, 2 and 3 (non-bolting) components at Seabrook Unit 1 contain no cold workgreater than 20 percent as a result of material specification and controlled fabricationconstruction. No Seabrook Unit 1 components were binned as Category 5. Therefore, the onlymaterials with the potential for greater than 20 percent cold work for Seabrook werestrain-hardened fasteners binned as Category 4 components. For some Category 4components, the material drawing notes and Westinghouse purchasing specifications that wereemployed in addition to ASME and ASTM specifications for parts purchase were found to limitthe strength of the employed materials such that the use of greater than 20 percent cold workmaterial was precluded. In cases where additional specifications were not clearly identified, aconservative posture was selected to consider the component as being cold worked for thepurposes of this assessment. Category 4 components were already assumed to have thepotential for cold work in the MRP-1 91 generic assessments.The detailed evaluation for Seabrook Unit 1 cold work assessments concluded that theplant-specific material fabrication and design was consistent with the MRP-191 basis, and thatthe MRP-227-A sampling inspection aging management requirements as related to cold workare directly applicable to Seabrook Unit 1.PWROG-1 5042-P May 2015Revision 0 WESTINGHOUSE NON-PROPRIETARY CLASS 3A-4A.3 REFERENCES1. EPRI Letter, MRP 2013-025, "MRP-227-A Applicability Template Guideline,"October 14, 2013.2. Materials Reliability Program: Screening, Categorization, and Ranking of ReactorInternals Components for Westinghouse and Combustion Engineering PWR Design(MRP-19 1). EPRI, Palo Alto, CA: 2006. 1013234.3. Materials Reliability Program: PWR Internals Material Aging Degradation MechanismScreening and Threshold Values (MRP-175). EPRI, Palo Alto, CA: 2005. 1012081.4. Materials Reliability Program: Pressurized Water Reactor Internals Inspection andEvaluation Guidelines (MRP-227-A). EPRI, Palo Alto, CA: 2011. 1022863.PWROG-1 5042-PMay 2015Revision 0

Enclosure

9 to SBK-L-15073Application for Withholding Proprietary InformationFrom Public Disclosure and Affidavit

(*) WestinghouseU.S. Nuclear Regulatory CommissionDocument Control Desk11555 Rockville PikeRockville, MD 20852Westinghouse Electric CompanyEngineering, Equipment and Major Projects1000 Westinghouse Drive, Building 3Cranberry Township, Pennsylvania 16066USADirect tel:Direct fax:e-mail:(412) 374-4643(724) 940-8560greshaja@westinghouse.comCAW-15-4190May 20,2015APPLICATION FOR WITHHOLDING PROPRIETARYINFORMATION FROM PUBLIC DISCLOSURESubject: PWROG-15023-P, Revision 1, "Seabrook Station Unit I Summary Report for the FuelDesign/Fuel Management Assessments to Demonstrate MRP-227-A Applicability"(Proprietary)The proprietary information for which withholding is being requested in the above-referenced report isfurther identified in Affidavit CAW-15-4190 signed by the owner of the proprietary information,Westinghouse Electric Company LLC. The Affidavit, which accompanies this letter, sets forth the basison which the information may be withheld from public disclosure by the Commission and addresses withspecificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission'sregulations.Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Pressurized WaterReactor Owners Group (PWROG).Correspondence with respect to the proprietary aspects of the Application for Withholding or theWestinghouse Affidavit should reference CAW- 15-4190 and should be addressed to James A. Gresham,Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive,Building 3 Suite 310, Cranberry Township, Pennsylvania 16066.Very truly yours,ames A. Gresham, ManagerRegulatory Compliance CAW-15-4190May 20,2015AFFIDAVITCOMMONWEALTH OF PENNSYLVANIA:SSCOUNTY OF BUTLER:I, James A. Gresham, am authorized to execute this Affidavit on behalf of Westinghouse ElectricCompany LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true andcorrect to the best of my knowledge, information, and belief./James A. Gresham, ManagerRegulatory Compliance 2CAW-15-4190(1) I am Manager, Regulatory Compliance, Westinghouse Electric Company LLC (Westinghouse),and as such, I have been specifically delegated the function of reviewing the proprietaryinformation sought to be withheld from public disclosure in connection with nuclear power plantlicensing and rule making proceedings, and am authorized to apply for its withholding on behalfof Westinghouse.(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of theCommission's regulations and in conjunction with the Westinghouse Application for WithholdingProprietary Information from Public Disclosure accompanying this Affidavit.(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designatinginformation 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 theinformation 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 heldin confidence by Westinghouse.(ii) The information is of a type customarily held in confidence by Westinghouse and notcustomarily disclosed to the public. Westinghouse has a rational basis for determiningthe types of information customarily held in confidence by it and, in that connection,utilizes a system to determine when and whether to hold certain types of information inconfidence. The application of that system and the substance of that system constituteWestinghouse policy and provide the rational basis required.Under that system, information is held in confidence if it falls in one or more of severaltypes, the release of which might result in the loss of an existing or potential competitiveadvantage, 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 3CAW-15-4190Westinghouse's competitors without license from Westinghouse constitutes acompetitive economic advantage over other companies.(b) It consists of supporting data, including test data, relative to a process (orcomponent, structure, tool, method, etc.), the application of which data secures acompetitive economic advantage, e.g., by optimization or improvedmarketability.(c) Its use by a competitor would reduce his expenditure of resources or improve hiscompetitive position in the design, manufacture, shipment, installation, assuranceof quality, or licensing a similar product.(d) It reveals cost or price information, production capacities, budget levels, orcommercial strategies of Westinghouse, its customers or suppliers.(e) It reveals aspects of past, present, or future Westinghouse or customer fundeddevelopment plans and programs of potential commercial value to Westinghouse.(f) It contains patentable ideas, for which patent protection may be desirable.(iii) There are sound policy reasons behind the Westinghouse system which include thefollowing:(a) The use of such information by Westinghouse gives Westinghouse a competitiveadvantage over its competitors. It is, therefore, withheld from disclosure toprotect the Westinghouse competitive position.(b) It is information that is marketable in many ways. The extent to which suchinformation is available to competitors diminishes the Westinghouse ability tosell products and services involving the use of the information.(c) Use by our competitor would put Westinghouse at a competitive disadvantage byreducing his expenditure of resources at our expense.

4CAW-15-4190(d) Each component of proprietary information pertinent to a particular competitiveadvantage is potentially as valuable as the total competitive advantage. Ifcompetitors acquire components of proprietary information, any one componentmay be the key to the entire puzzle, thereby depriving Westinghouse of acompetitive advantage.(e) Unrestricted disclosure would jeopardize the position of prominence ofWestinghouse in the world market, and thereby give a market advantage to thecompetition of those countries.(f) The Westinghouse capacity to invest corporate assets in research anddevelopment depends upon the success in obtaining and maintaining acompetitive advantage.(iv) The information is being transmitted to the Commission in confidence and, under theprovisions of 10 CFR Section 2.390, it is to be received in confidence by theCommission.(v) The information sought to be protected is not available in public sources or availableinformation has not been previously employed in the same original manner or method tothe best of our knowledge and belief.(vi) The proprietary information sought to be withheld in this submittal is that which isappropriately marked in PWROG-15023-P, Revision 1, "Seabrook Station Unit 1 SummaryReport for the Fuel Design/Fuel Management Assessments to Demonstrate MRP-227-AApplicability" (Proprietary), for submittal to the Commission, being transmitted byPWROG letter OG-15-198 and Application for Withholding Proprietary Information fromPublic Disclosure, to the Document Control Desk. The proprietary information assubmitted by Westinghouse is that associated with the NRC Letter, "Request for AdditionalInformation Related to the Review of the Seabrook Station License Renewal Application -Set 21 (TAC NO. ME4028)," ML14101A324 April 25, 2014 and may be used only for thatpurpose.

5CAW-15-4190(a) This information is part of that which will enable Westinghouse to:(i) Support reactor vessel internals aging management.(b) Further this information has substantial commercial value as follows:(i) Westinghouse plans to sell the use of similar information to its customersfor the purpose of supporting reactor internals aging management(ii) Westinghouse can sell support and defense of industry guidelines andacceptance criteria for plant-specific applications.(iii) The information requested to be withheld reveals the distinguishingaspects of a methodology which was developed by Westinghouse.Public disclosure of this proprietary information is likely to cause substantial harm to thecompetitive position of Westinghouse because it would enhance the ability ofcompetitors to provide similar technical evaluation justifications and licensing defenseservices for commercial power reactors without commensurate expenses. Also, publicdisclosure of the information would enable others to use the information to meet NRCrequirements for licensing documentation without purchasing the right to use theinformation.The development of the technology described in part by the information is the result ofapplying the results of many years of experience in an intensive Westinghouse effort andthe expenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technicalprograms would have to be performed and a significant manpower effort, having therequisite talent and experience, would have to be expended.Further the deponent sayeth not.

PROPRIETARY INFORMATION NOTICETransmitted herewith is the proprietary and non-proprietary version of a document furnished to the NRCassociated with the NRC letter, "Request for Additional Information Related to the Review of theSeabrook Station License Renewal Application -Set 21 (TAC NO. ME4028)," ML14101A324 April 25,2014 and may be used only for that purpose.In order toconform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning theprotection of proprietary information so submitted to the NRC, the information which is proprietary in theproprietary versions is contained within brackets, and where the proprietary information has been deletedin the non-proprietary versions, only the brackets remain (the information that was contained within thebrackets in the proprietary versions having been deleted). The justification for claiming the informationso 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 beingidentified as proprietary or in the margin opposite such information. These lower case letters refer to thetypes 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 NOTICEThe reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted tomake the number of copies of the information contained in these reports which are necessary for itsinternal 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 publicdisclosure to the extent such information has been identified as proprietary by Westinghouse, copyrightprotection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC ispermitted to make the number of copies beyond those necessary for its internal use which are necessary inorder to have one copy available for public viewing in the appropriate docket files in the public documentroom in Washington, DC and in local public document rooms as may be. required by NRC regulations ifthe number of copies submitted is insufficient for this purpose. Copies made by the NRC must includethe copyright notice in all instances and the proprietary notice if the original was identified as proprietary.