CNL-21-076, Request for Alternative, 21-ISI-2, Alternative Inspection for Upper Head Injection J-groove Welds
| ML21246A169 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/03/2021 |
| From: | Polickoski J Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML21246A168 | List: |
| References | |
| CNL-21-076 | |
| Download: ML21246A169 (16) | |
Text
Proprietary Information Withhold Under 10 CFR § 2.390 This letter is decontrolled when separated from Enclosure 1 TENNESSEE 1\14 VALLEY AUTHORITY 1101 Market Street, Chattanooga, Tennessee 37402 CNL-21-076 September 3, 2021 10 CFR 50.55a(z)(2)
ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Sequoyah Nuclear Plant, Unit 2 Renewed Facility Operating License No. DPR-79 NRC Docket No. 50-328
Subject:
Sequoyah Nuclear Plant, Unit 2, Request for Alternative, 21-ISI-2, Alternative Inspection for Upper Head Injection J-groove Welds In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.55a, Codes and Standards, paragraph (z)(2), Enclosure 1 to this submittal contains the Tennessee Valley Authority (TVA) request for alternative (RFA) 21-ISI-2 for the Sequoyah Nuclear Plant (SQN),
Unit 2, from the ASME [American Society of Mechanical Engineers] Boiler and Pressure Vessel Code (ASME Code),Section XI, Code Case N-729-6. The RFA relates specifically to the inspection in the fall 2021 outage of SQN Unit 2, Upper Head Injection (UHI) J-groove welds.
Due to updated requirements in the current version of Code Case N-729-6, and that the SQN UHI penetrations are larger than other reactor vessel head penetrations, a new procedure must be developed and a new technique qualification test specimen must be constructed.
Complexities in the design have impacted fabrication schedules for the specimen, which may not be available when needed for the upcoming Unit 2 outage. The alternative surface examination of the welds would involve high radiation exposure for personnel involved.
TVA proposes the use of nondestructive examination procedures that meet Code Case N-729-1 Paragraph -2500, using a previous vendor technical justification. A separate supplemental ultrasonic testing examination will also be performed using a procedure that employs the equipment and techniques that are currently under development and are planned to be qualified in accordance with Code Case N-729-6.
Proprietary Information Withhold Under 10 CFR § 2.390 This letter is decontrolled when separated from Enclosure 1
Proprietary Information Withhold Under 10 CFR § 2.390 This letter is decontrolled when separated from Enclosure 1 U.S. Nuclear Regulatory Commission CNL-21-076 Page 2 September 3, 2021 to this letter contains information that Framatome Inc. (Framatome) considers proprietary in nature pursuant to 10 CFR 2.390, Public inspections, exemptions, requests for withholding, paragraph (a)(4). Enclosure 2 contains a non-proprietary version of Enclosure 1. provides the Framatome affidavit supporting the proprietary information withholding request. TVA requests that the information, which is proprietary to Framatome, be withheld from public disclosure in accordance with 10 CFR Section 2.390. Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Framatome affidavits should reference the corresponding report and should be addressed to Jeff Ross, Framatome, Project Manager, 155 Mill Ridge Road, Lynchburg, Virginia 24502.
TVA requests approval of this alternative by October 16, 2021. The reactor vessel closure head will be placed on the reactor vessel on or about this day, which will be the last opportunity to inspect the subject welds during the refueling outage.
There are no new regulatory commitments contained in this letter. If you have any questions regarding this submittal, please contact Kimberly D. Hulvey, Senior Manager, Fleet Licensing at 423-751-3275.
Respectfully, James T. Polickoski Director, Nuclear Regulatory Affairs
Enclosures:
- 1. Sequoyah Nuclear Plant, Unit 2, American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, Inservice Inspection Program, Request for Alternative, 21-ISI-2 (Proprietary)
- 2. Sequoyah Nuclear Plant, Unit 2, American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, Inservice Inspection Program, Request for Alternative, 21-ISI-2 (Non-Proprietary)
NRC Regional Administrator - Region II NRC Senior Resident Inspector - Sequoyah Nuclear Plant NRC Project Manager - Sequoyah Nuclear Plant Proprietary Information Withhold Under 10 CFR § 2.390 This letter is decontrolled when separated from Enclosure 1
Proprietary Information Withhold Under 10 CFR § 2.390 Enclosure 1 Sequoyah Nuclear Plant, Unit 2, American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, Inservice Inspection Program, Request for Alternative, 21-ISI-2 (Proprietary)
CNL-21-076 Proprietary Information Withhold Under 10 CFR § 2.390
Enclosure 2 Sequoyah Nuclear Plant, Unit 2, American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, Inservice Inspection Program, Request for Alternative, 21-ISI-2 (Non-Proprietary)
CNL-21-076
Enclosure 2 Sequoyah Nuclear Plant, Unit 2, American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, lnservice Inspection Program, Request for Alternative, 21-ISl-2 I. ASME Code Component(s) Affected:
Code Class: 1
Reference:
Code Case N-729-6 Examination Category: Table 1 - Class 1 Power Reactor Vessel Upper Head Item Number: 84.20
==
Description:==
UNS N06600 nozzles and UNS N06082 or UNS W86 182 partial-penetration welds in head Component Number: Reactor Pressure Vessel (RPV) Head with partial-penetration Upper Head Injection (UHi ) welds, identified in the In-service Inspection (ISi ) Program as:
UPIW-23, UPIW-24 , UPIW-25, and UPIW-26 II. ASME Code Edition and Addenda:
Sequoyah Nuclear Plant (SQN), Unit 2, is in the fourth 10-year ISi interval , scheduled to end on April 30, 2025. The ISi Code of Record is the ASME [American Society of Mechanical Engineers] Boiler and Pressure Vessel Code (ASME Code),Section XI, 2007 Edition through 2008 Addenda, as conditioned by Title 10 of the Code of Federal Regulations (10 CFR) 50.55a .
Throughout this submittal, references to ASME Code Section XI are from the 2007 Edition through 2008 Addenda unless otherwise specified .
Ill. Applicable Code Requirement:
ASM E Code Case N-729-6, Paragraph -2500, sub-Paragraphs (a) through U), which describe qualification requirements outside of ASME Section V, Article 14, includes sub-Paragraph (b),
w hich states in part, "Procedures are qualified to examine nozzles within the minimum and maximum nominal inside diameters of the demonstration mockups." As worded, there are no tolerances specified for components with diameters greater than the largest diameter included in the qualification specimen test set, nor are there provisions for the use of a technical justification (T J) to address diameters outside of the qualified procedure range.
IV. Reason for Request:
Tennessee Valley Authority (TVA), the licensee for SQN Unit 2, is requesting approval of an alternative to the specified requirements of ASME Code Case N-729-6, Paragraph -2500, pursuant to 10 CFR 50.55a(z )(2), as the provisions that require extended procedure qualification through blind demonstration on test specimens that encompass the actual diameter of the component represents a hardship or unusual difficulty without a compensating increase in the level of quality and safety.
During pre-outage preparations, in March 2021 , TVA conducted an initial outage preparation meeting with the primary vendor Framatome, Inc. (Framatome), scheduled to re-perform a volumetric inspection of SQN's Unit 2 reactor vessel closure head (RVCH ) partial penetration CN L-21-076 E2-1 of 8
Enclosure 2 welds in accordance with ASME Code Case N-729-6. During the meeting, TVA nondestructive examination (NOE) personnel challenged the vendor NOE personnel to begin a review of the current applicable NOE procedures, in an effort to identify necessary revisions for the upcoming project, which is scheduled for the SQN U2R24 outage, with a starting date of October 2, 2021 .
The review conducted by the primary vendor focused on the relevant changes to 10 CFR 50 .55a, the applicable ASME Code and Code Case requirements, and additional site commitments, if any, that are required since the last examination, and to determine the impact that changes may have on the qualified procedures, many of which were used in the previous examination held in May 2014, during the U2R19 outage, though potentially in earlier revisions of the procedures.
By mid-April 2021 , the results of the primary vendor's review had concluded that the previous procedure used in the U2R19 outage was qualified through blind demonstration to ASME Code Case N-729-1 and was supplemented by a T J. This TJ was necessary due to the procedure qualification demonstration being limited to specimens w ith a maximum internal diameter less than the 4.375 in. ID configuration for SQN Unit 2's UHi nozzle bore. The T J analyzed results from a series of examinations conducted on a calibration specimen that matched the maximum demonstrated size and compared results of similar calibration block reflectors on a calibration specimen that matched the diameter of SQN Unit 2's UHi nozzles (4.375 in. ID). The results of the comparison demonstrated favorable responses from the 4.375 in. ID calibration specimen, compared to those detected in the specimen that matched the maximum demonstrated size w hen the same procedurally required setups and equipment were used on both specimens.
However, subsequent revisions to the NOE procedure have incorporated revisions made to the Code Case between versions N-729-1 and N-729-6, which removed provisions to apply a T J for purposes of expanding the procedurally qualified diameter ranges. Specifically, ASME Code Case N-729-6, Paragraph -2500, sub-Paragraphs (a) through U), which describe qualification requirements outside of ASME Section V, Article 14, includes sub-Paragraph (b), which states in part, "Procedures are qualified to examine nozzles within the minimum and maximum nominal inside diameters of the demonstration mockups." Without provisions to use a TJ for qualification expansion of component diameter ranges, the NOE procedure is not qualified to meet the requirements of Code Case N-729-6 for the UHi J-groove welds.
Provisions to perform a surface examination in lieu of a volumetric examination have been explored, but deemed to be radiation dose prohibitive due to high dose rates under the reactor pressure vessel head. Based on industry operating experience (OE), estimated dose rates per nozzle examination average 300 mrem for dye penetrant (PT) testing. For manual eddy current (ET) surface examination , the estimated average is 350 mrem. Industry OE has also ind icated an approximate 40 degrees limitation, both sides of O degrees, low hill side. Based on the estimates for the examination of the four nozzles, examination personnel would receive approximately 1200 mrem to 1400 mrem, depending on the methods employed . However, it is anticipated that surface preparation of the RVCH ID surface, w hich is in an as-welded condition ,
would be required to perform these surface examinations. Such preparation is expected to incur 7 to 8 rem/hr of personnel radiation exposure.
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Enclosure 2 V. Proposed Alternative and Basis for Use:
Four SQN Unit 2 upper head injection nozzle J-groove welds are scheduled for volumetric examination in accordance with the examination requirements of ASME Code Case N-729-6, Paragraph -2500. The subject welds are ASME Class 1, Item 84 .20, as defined by ASME Code Case N-729-6, Table 1. The components are fabricated with UNS N06600 nozzles and UNS 0N06082 or UNS W86182 partial-penetration welds located at the ID of the vessel head.
Pursuant to 10 CFR 50.55a(z)(2), TVA proposes performing the examinations in accordance w ith the examination requirements of ASME Code Case N-729-1, Paragraph -2500, utilizing Framatome's May 2014 procedure, as supplemented by the T J.
The techn iques employed by the procedure used in May 2014 for the examination of welds UPIW-23, UPIW-24, UPIW-25, and UPIW-26 include the use of a rotating transducer head w hich is inserted into the UHi nozzles via a robotic scanner, which is ositioned under the reactor ressure vessel head. The UHi transducer head contains a These techniques have been demonstrated for the detection, characterization, and sizing of axial, circumferential , and off-axis flaws greater than 10 percent of wall thickness initiating from the inside surface (ID) or outside surface (OD) of the penetration base material only. While the techn iques in this procedure are not intended to detect or characterize indications in the J-groove weld material, targets within the weld can be observed. In addition, the techniques have been demonstrated to effectively perform leak-path assessment in those penetrations with an interference fit region . If it is unknown whether an interference fit region exists, the default condition will be to treat each penetration as if an interference fit region is present.
As a supplement to the examination techniques performed in accordance with the May 2014 procedure, TVA proposes performing an examination of the four subject UHi welds utilizing a procedure that employs equipment and techniques that are currently under development. TVA anticipates qualification of the techniques to meet the requirements of ASME Code Case N-729-6, including Paragraph -2500 and associated sub-Paragraphs (a) through U), as applicable, for the 4.375 in. ID configuration representative of SQN Unit 2's UHi welds after the components have been examined. The tables below show information from the previously used TJ and the newly designed technique that w ill be demonstrated at Electric Power Research Institute (EPRI ). The calibration and analysis setup are anticipated to be performed using the same essential variables as those used in the May 2014 procedure, as supplemented by the T J.
Previous 2014 Examination Techni ue CNL-21-076 E2-3 of 8
Enclosure 2 New Examination Techni ue Demonstration Scheduled for Se tember It is common for parties to make minor changes to a procedure during qualification activities.
Outside of changes to essential variables, modifications may address administrative functions or technical enhancements that do not impact the quality of the examination. Changes to the defined 'Essential Variables' between the final qualified procedure and the working revision utilized for the supplemental examination of the four UHi welds will be evaluated by TVA to further determine the adequacy of the supplemental techniques. The changes w ill be captured as internal operating experience (OE) within TVA's Corrective Action Program (CAP) to aid in future examinations of the UHi J-groove welds and to ensure that the working techniques employed during the SQN U2R24 outage were sufficient to pass the Performance Demonstration qualification. An evaluation w ill be performed by comparing the planned Performance Demonstration qualified procedure with the working procedure that was employed during the SQN U2R24 outage. Should the results demonstrate that the working procedure does not adequately pass a qualification demonstration, due to non-conservative results (e.g., detection of flaws, under-sizing the depth or length measurements of the specimen flaws),
then re-examination with a qualified procedure will be scheduled for the next refuel outage.
Basis for Use Revisions to Code Case N-729-6, have been incorporated since the previous examination of SQN Unit 2's UHi J-groove welds: UPIW-23, UPIW-24, UPIW-25, and UPIW-26. These revisions include the addition of sub-Paragraphs (a) through U) of Paragraph -2500, which describes qualification requirements for volumetric examinations that are outside of ASME Section V, Article 14. Inclusive of these requirements, sub-Paragraph (b) states in part, "Procedures are qualified to examine nozzles within the minimum and maximum nominal inside diameters of the demonstration mockups." As worded, there are no tolerances specified for components w ith diameters greater than the largest diameter specimen that was included in the qualification test set, nor are there provisions for the use of a T J to address diameters outside of the qualified procedure range.
TVA's consultation with Performance Demonstration Administrators (PDA) at the Electric Power Research Institute (EPRI ), revealed that blind test specimens applicable to SQN Unit 2's UHi welds are not currently included in the Performance Demonstration test specimen inventory.
Further, TVA's significant attempts to have unique, site specific specimens built that could be used to expand the qualified diameter range of the examination procedure, prior to the scheduled examination date, have been challenged by the extensive nature of the specimen fabrication process.
However, the proposed alternative examination techn iques described above are anticipated to offer the same level of quality, or better, compared to an examination that is conducted in compliance with the minimum requirements ASME Code Case N-729-6.
CNL-21-076 E2-4 of 8
Enclosure 2 Some benefits resulting from the proposed alternatives that would not be realized through compliance with the minimum requirements of Code Case N-729-6 include the following.
- Examination equipment, personnel certification requirements, software configuration, and analysis strategies will closely replicate those conducted during the previous examination , allowing the qualified data analysts to perform direct comparisons of the ultrasound data collected during the upcoming SQN U2R24 outage to the previous ultrasound data collected during the U2R19 outage .
- The supplemental examinations will be conducted using revised techniques, including transducers that are designed with a contour specifically for the 4.375 in. ID of the UHi nozzle bore. These additional examinations will provide another opportun ity for the qualified data analysts to scrutinize the integrity of the UHi J-groove weld region .
In addition , there is reasonable assurance that the techn iques defined in the May 2014 procedure will provide the necessary quality to determine the safe operation of SQN Unit 2's UHi welds. The T J provides an in-depth comparison of examination results from two calibration blocks, using the qualified techniques and equipment defined in the procedure . One of the calibration blocks matches the procedures maximum demonstrated size and the other matches the diameter of SQN Unit 2's UHi nozzles (4.375 in. ID). Details extracted from the comparative analysis are as follows.
Two calibration standards were used in the comparison; the qualified in core instrumentation (ICI) and the 4 .375 in. auxiliary head adapter (AHA)/UHI ID. The use of calibration standards is reasonable because the major effect of ID diameter change challenges the ability of the transducer to transmit sound into the component. As such, the effect would be the same on other types of reflector used in the comparative analysis w ith emphasis placed on the detection of reflectors and the associated signal to noise ratio.
The calibration parameters both essential and non-essential, as defined in the May 2014 procedure were identical between the ICI and AHA/UHi data sets. The calibration was derived from the ICI data and applied directly to the AHA/UHi data. The data gathered for the comparative analysis was analyzed for reflector detection, depth, length, and signal to noise ratio. These values are presented in the Table below .
CNL-21-076 E2-5 of 8
Enclosure 2
]
As demonstrated, the root mean square (RMS) error values collected on the ICI calibration block compared to the values collected on the 4.375 in. calibration block show a maximum difference of 0.021 inches in depth measurements ], and a maximum difference in length of 0.038 inches [
In addition , while it is acknowledged that the T J demonstration was performed in a non-blind manner on electrical discharge machining calibration notches, it is still noteworthy that both the depth and length RMS error values for each rotating probe, as recorded for the 4.375 in.
calibration notches, are well below the limits set in Code Case N-729-6, Paragraph -2500 (f) and (g); specifically the RMS error of the flaw depth measurements as compared to the true flaw depths, do not exceed 1/8 inch (0.125 in or 3 mm), and the RMS error of the flaw length measurements, as compared to the true flaw lengths, do not exceed 3/8 inch (0.375 in.
or 10 mm), respectively. Further, the Signal to Noise ratio values for each transducer show no appreciable loss of fidelity between the examination on the ICI calibration block that is w ithin the qualified range and the 4.375 in. ID calibration block.
In conclusion, evidence supports that the alternative techniques proposed above will provide examinations that are comparable to, or better than, examinations performed to the minimum requ irements of ASME Code Case N-729-6, Paragraph -2500, with regards to quality, for the safe operation of the SQN U2 UHi J-groove welds.
CNL-21-076 E2-6 of 8
Enclosure 2 Hardship or Unusual Difficulty On March 29, 2021 , a project kickoff meeting was conducted to plan for the upcoming SQN Unit 2 volumetric examination of the RVCH and related components. The meeting was attended by TVA members including the project management team, Programs Engineering, NOE Personnel , and other departments within TVA, along with the primary inspection vendor project management team and NOE Personnel. The purpose of the meeting was to discuss the scope of work that is scheduled for the U2R24 outage, with a start date of October 2, 2021.
During this meeting, TVA NOE personnel challenged Framatome NOE personnel to begin a review of the current applicable NOE procedures, many of which were used in the previous examination held in May 2014 during the U2R 19 outage, in an effort to identify necessary revisions for the upcoming project. The vendor accepted this action and conducted the review w ith a focus on the relevant changes to 10 CFR 50 .55a, the applicable ASME Code and Code Case requirements, and additional site commitments, if any, that were added since the last examination. Revisions and additions identified were then weighed against the applicable NOE procedures to determine the extent of impact.
On April 15, 2021 , the primary vendor contacted TVA NOE personnel to notify them that the review identified a discrepancy in the May 2014 procedure, which was qualified through blind demonstration to the requirements of ASME Code Case N-729-1, but did not meet the current requirements of ASME Code Case N-729-6 for examination of the UHi J-groove welds, identified as UPIW-23, UPIW-24, UPIW-25, and UPIW-26. More specifically, the procedure was supplemented by a TJ that provided expansion of the procedure's qualified diameter range from the maximum demonstrated ID to the 4.375 in. ID configuration that meets SQN Unit 2's UHi nozzle configuration. Although the results of the TJ demonstrated favorable responses from the 4.375 in. ID calibration specimen compared to those detected in the ICI specimen, the later Code Case N-729-6 held no provisions to allow for qualification expansion through a T J.
TVA contacted the PDA at the Electric Power Research Institute (EPRI), on April 16, 2021 , to consult on the issue and possible solutions. EPRI PDA informed TVA that blind test specimens applicable to SQN Unit 2's UHi welds were not included in the Performance Demonstration test specimen inventory. Furthermore, it was determined that SQN (Units 1 and 2) were unique in the configuration of the UHi J-groove welds. Thus, TVA engaged in a project with EPRI to facilitate fabrication of a blind test specimen, an open practice sample, and a calibration block that meets the configuration of the UHi J-groove welds. Formal work began May 2021.
During the first status meeting, held between TVA and EPRI, a timeline was discussed to assure that the project could be feasibly completed and that the NOE vendor could complete the expansion qualification prior to the start of the outage. It was acknowledged and accepted by all parties that expedited services would be necessary to complete the work in a timely manner.
On June 10, 2021, a formal plan was discussed which included project milestones to accept the final specimen product by August 15, 2021. This date coincided with the NOE vendor qualification milestones to commence qualification activities on August 31, 2021 , and the final issuance of the Performance Demonstration Qualification Summary on September 10, 2021 ,
leaving a window of three weeks between the completion of the qualification activities and the beginning of the inspection outage.
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Enclosure 2 On July 8, 2021, TVA was notified that a reassessment of the schedule, and a schedule slip due to material shipping logistics, had impacted the initial completion estimations by approximately two weeks. Because the project was already following an aggressive expedited plan, there remains very little float and no apparent opportunities to pull the schedule forward . Further, multiple instances of operating experience (OE) have been recorded that demonstrate the complexity of fabricating blind mockup samples and an elevated possibility of experiencing fabrication errors. Such errors are likely to have considerable impact on project completion , up to and including re-work of the mockup, possibly a multi-month setback. Additional delays are likely to push the project completion date well beyond the scheduled examination date, possibly delaying plant startup.
As mentioned above, provisions to perform a surface examination in lieu of a volumetric examination have been explored, but deemed to be radiation dose prohibitive due to high dose rates under the reactor pressure vessel head. Based on Industry OE, estimated dose rates per nozzle examination average 300 mrem for dye penetrant (PT) testing. For manual eddy current (ET) surface examination, the estimated average is 350 mrem. Industry OE has also indicated an approximate 40 degrees limitation, both sides of O degrees, low hill side. Based on the estimates for the examination of the four nozzles, examination personnel would receive approximately 1200 mrem to 1400 mrem, depending on the methods employed . However, it is anticipated that surface preparation of the RVCH ID surface, w hich is in an as-welded condition ,
would be required to perform these surface examinations. Such preparation is expected to incur 7 to 8 rem/hr of personnel radiation exposure.
VI. Duration of Proposed Alternative:
This alternative is requested for inspections performed during the fall 2021 outage of SQN Unit 2.
VII. Precedents This request for alternative is similar to the following alternative request approved by the Nuclear Regulatory Commission, which identified performing the surface examination is a hardship because of the dose involved with the examination:
- NRC Letter to Entergy Nuclear Operations, Inc., "Indian Point Nuclear Generating Unit No. 2 - Issuance of Relief Request IP3-ISI-RR-14 Re: Alternative Examination Required by ASME Code Case N-729-4 (EPID L-2018-LLR-0102)," dated February 25, 2019 (ML19039A149)
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Enclosure 3 Framatome Affidavit CNL-21-076
- 1. My name is Gayle Elliott. I am Deputy Director, Licensing and Regulatory Affairs, for Framatome Inc. (Framatome) and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by Framatome to determine whether certain Framatome information is proprietary. I am familiar with the policies established by Framatome to ensure the proper application of these criteria.
- 3. I am familiar with the Framatome information contained in Enclosure 1 to Letter, Document Control Desk (NRC) from Mr. James T. Polickoski, (TVA), Sequoyah Nuclear Plant, Unit 2, Request for Alternative, 21-ISI-2, Alternative Inspection for Upper Head Injection J-groove Welds, CNL-21-076, dated September 2021, and referred to herein as Document. Information contained in this Document has been classified by Framatome as proprietary in accordance with the policies established by Framatome 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 Framatome 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 requested qualifies under 10 CFR 2.390(a)(4) Trade secrets and commercial or financial information.
- 6. The following criteria are customarily applied by Framatome to determine whether information should be classified as proprietary:
(a) The information reveals details of Framatomes 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 Framatome.
(d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for Framatome in product optimization or marketability.
(e) The information is vital to a competitive advantage held by Framatome, would be helpful to competitors to Framatome, and would likely cause substantial harm to the competitive position of Framatome.
The information in this Document is considered proprietary for the reasons set forth in paragraphs 6(d) and 6(e) above.
- 7. In accordance with Framatomes policies governing the protection and control of information, proprietary information contained in this Document has been made available, on a limited basis, to others outside Framatome only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. Framatome policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.
- 9. The foregoing statements are true and correct to the best of my knowledge, information, and belief.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on: September 1, 2021 Digitally signed by ELLIOTT ELLIOTT Gayle Gayle A
Date: 2021.09.01 11:06:24 -04'00' Gayle Elliott