3F1209-02, Relief Request 08-002-RR, Revision 0, Completion of Regulatory Commitments
| ML100190743 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 12/17/2009 |
| From: | Cahill S Progress Energy Florida |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 08-002-RR, Rev 0, 3F1209-02, TAC ME0023 | |
| Download: ML100190743 (11) | |
Text
Progress Energy Crystal River Nuclear Plant Docket No..50-302 Operating License No. DPR-72 Refs. 10 CFR 2.390(a)(4) 10 CFR 50.55a December 17, 2009 3F1209-02 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
Subject:
Crystal River Unit 3 - Relief Request #08-002-RR, Revision 0, Completion of Regulatory Commitments (TAC NO. ME0023)
Reference:
CR-3 to NRC letter, dated March 12, 2009, "Crystal River Unit 3 - Response to Request for Additional Information Regarding Relief Request #08-002-RR, Revision 0, Dissimilar Metal Weld Overlay Repair During the Fourth 10-Year Inservice Inspection Interval (TAC NO. ME0023)"
Dear Sir:
In the above referenced letter, Florida Power Corporation (FPC), doing business as Progress Energy Florida, Inc., (PEF), made two regulatory commitments related to submittal of an analysis of the residual stresses and flaw growth of repaired weldment, including crack growth calculations, related to the mitigation of the of the "A" Hot Leg surge pipe-to-surge nozzle Alloy 600/82/182 dissimilar metal butt weld.
The preliminary analysis and evaluation were to be submitted to the NRC prior to entering Mode 4 during restart from Crystal River Unit 3 (CR-3)
Refueling Outage 16 (R16). The final analysis and evaluation were to be submitted to the NRC 60 days after plant restart from R16.
By submitting the final analysis and evaluation prior to entering Mode 4, both of the above regulatory commitments are considered complete. provides a list of the titles and a short description of the analysis and evaluation being submitted. Attachment 2 of this submittal is a CD-ROM containing the analysis and evaluation that complete two regulatory commitments made in the referenced letter.
The CD-ROM accompanying this submittal (Attachment 2) contains proprietary documents.
AREVA NP Inc. requests the proprietary information in this CD-ROM be withheld from public disclosure in accordance with 10CFR2.390(a)(4). Two (2) affidavits supporting the request, one for each document, are provided in Attachment 3. This submittal contains no new regulatory commitments.
If you have any questions regarding this submittal, please contact Mr. Dan Westcott, Superintendent, Licensing and Regulatory Programs at (352) 563-4796, Sincerely, Stephen J. Cahill, Manager Engineering SJC/dwh Attachments:
- 1.
Table of Referenced Documents
- 2.
CD-ROM Containing Referenced Documents (PROPRIETARY)
- 3.
Affidavits for Withholding Proprietary Information from Public Disclosure xc:
NRR Project Manager Regional Administrator, Region II Senior Resident Inspector Progress Energy Florida, Inc.
Crystal River Nuclear Plant 15760 W. Power Line Street Crystal River, FL 34428
PROGRESS ENERGY FLORIDA, INC.
CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50 - 302 / LICENSE NUMBER DPR - 72 Table of Referenced Documents
U.S. Nuclear Regulatory Commission 3F1209-02 Page 1 of 1 Table of Referenced Documents These documents are on the CD-ROM that is referenced as Attachment 2 of this submittal.
Analysis Number Title Summary AREVA NP Inc.
Crystal River Unit 3 Hot Leg Surge Documents the predicted weld residual Document Weld Overlay Repair Residual stress finite element analysis of the hot leg 32-9092285-001 Stress Analysis surge nozzle after the application of the (12/16/08)
Structural Weld Overlay (SWOL)
AREVA NP Inc.
Crystal River Unit 3 Hot Leg Surge Evaluates the fatigue and primary water Document Weld Overlay Repair Crack Growth stress corrosion crack growth of 32-9092939-001 Evaluation postulated, inside surface connected, 3600 (12/16/08) circumferential and semi-elliptical axial flaws in the weld overlaid Hot Leg Surge I Nozzle NOTE:
Both document revisions are the latest and applicable revision level.
The analysis within each document was completed in 2008 and was based upon the Structural Weld Overlay (SWOL) design and implementation drawing. The actual SWOL was installed during the Crystal River Unit 3 (CR-3) Refueling Outage 16 (R16) in accordance with the same drawings.
Therefore, the basis for the analysis remains valid.
The above documents will not be updated Post R16 SWOL because there is no need to do so.
PROGRESS ENERGY FLORIDA, INC.
CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50 - 302 / LICENSE NUMBER DPR - 72 CD-ROM Containing Referenced Documents (PROPRIETARY)
PROGRESS ENERGY FLORIDA, INC.
CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50 - 302 / LICENSE NUMBER DPR - 72 Affidavits for Withholding Proprietary Information from Public Disclosure
AFFIDAVIT COMMONWEALTH OF VIRGINIA
)
) ss.
CITY OF LYNCHBURG
)
- 1.
My name is Gayle F. Elliott. I am Manager, Product Licensing, for AREVA NP Inc. and as such I am authorized to execute this Affidavit.
- 2.
I am familiar with the criteria applied by AREVA NP to determine whether certain AREVA NP information is proprietary. I am familiar with the policies established by AREVA NP to ensure the proper application of these criteria.
- 3.
1 am familiar with the AREVA NP information contained in the Calculation Summary Sheet (CSS) 32-9092285-001, entitled "CR3 HL Surge WOL Repair Residual Stress Analysis," dated December 2008, and referred to herein as "Document." Information contained in this Document has been classified by AREVA NP as proprietary in accordance with the policies established by AREVA NP for the control and protection of proprietary and confidential information.
- 4.
This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by AREVA NP and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.
- 5.
This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure. The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is Page A-1 of 3
requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial information."
- 6.
The following criteria are customarily applied by AREVA NP to determine whether information should be classified as proprietary:
(a)
The information reveals details of AREVA NP's research and development plans and programs or their results.
(b)
Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.
(c)
The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for AREVA NP.
(d)
The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA NP in product optimization or marketability.
(e)
The information is vital to a competitive advantage held by AREVA NP, would be helpful to competitors to AREVA NP, and would likely cause substantial harm to the competitive position of AREVA NP.
The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b) and 6(c) above.
- 7.
In accordance with AREVA NP's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA NP only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8.
AREVA NP policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.
Page A-2 of 3
- 9.
The foregoing statements are true and correct to the best of my knowledge, information, and belief.
SUBSCRIBED before me this____
day of 2009.
Danita R. Kidd NOTARY PUBLIC, STATE OF VIRGINIA MY COMMISSION EXPIRES: 12/31/12 Reg. # 205569 Page A-3 of 3
AFFIDAVIT COMMONWEALTH OF VIRGINIA
)
) ss.
CITY OF LYNCHBURG
)
- 1.
My name is Gayle F. Elliott. I am Manager, Product Licensing, for AREVA NP Inc. and as such I am authorized to execute this Affidavit.
- 2.
I am familiar with the criteria applied by AREVA NP to determine whether certain AREVA NP information is proprietary. I am familiar with the policies established by AREVA NP to ensure the proper application of these criteria.
- 3.
I am familiar with the AREVA NP information contained in the Calculation Summary Sheet (CSS) 32-9092939-001, entitled "CR-HL Surge Weld Overlay Repair Crack Growth Evaluation," dated December 2008, and referred to herein as "Document." Information contained in this Document has been classified by AREVA NP as proprietary in accordance with the policies established by AREVA NP for the control and protection of proprietary and confidential information.
- 4.
This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by AREVA NP and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained inmthis Document as proprietary and confidential.
- 5.
This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure. The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is Page B-1 of 3
requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial information."
- 6.
The following criteria are customarily applied by AREVA NP to determine whether information should be classified as proprietary:
(a)
The information reveals details of AREVA NP's research and development plans and programs or their results.
(b)
Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.
(c)
The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for AREVA NP.
(d)
The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA NP in product optimization or marketability.
(e)
The information is vital to a competitive advantage held by AREVA NP, would be helpful to competitors to AREVA NP, and would likely cause substantial harm to the competitive position of AREVA NP.
The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b) and 6(c) above.
- 7.
In accordance with AREVA NP's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA NP only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8.
AREVA NP policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.
Page B-2 of 3
- 9.
The foregoing statements are true and correct to the best of my knowledge, information, and belief.
SUBSCRIBED before me this day of
_ i.2
, 2009.
Danita R. Kidd NOTARY PUBLIC, STATE OF VIRGINIA MY COMMISSION EXPIRES: 12/31/12 Reg. # 205569 Page B-3 of 3