L-2002-167, ASME Section XI Relief Requests Nos. 30 & 31, Associated with Reactor Vessel Closure Head Repair, Additional Information & Affidavit

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ASME Section XI Relief Requests Nos. 30 & 31, Associated with Reactor Vessel Closure Head Repair, Additional Information & Affidavit
ML022330656
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 08/19/2002
From: Mcelwain J
Florida Power & Light Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2002-167
Download: ML022330656 (7)
v • d • e


Text

AUG 19 2002 L-2002-1 67 10 CFR 50.55a FIPL U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 251 ASME Section XI Relief Requests Nos. 30 & 31, Associated With Reactor Vessel Closure Head Repair, Additional Information and Affidavit Florida Power & Light Company (FPL) submitted Relief Requests 30 and 31 via letter L-2002-044 dated March 1, 2002. Additional information was provided as requested, in letter L 2002-087 dated June 6, 2002.

This letter provides additional information, which was requested on July 19, 2002. Attachment 1 provides proprietary Framatome documents and accompanying affidavit. Attachment 2 provides non-proprietary Framatome documents, and Attachment 3 provides non-proprietary Dominion documents.

Since Attachment 1 contains information proprietary to Framatome ANP, it is supported by an on affidavit signed by Framatome, the owner of the information. The affidavit sets forth the basis the which the information may be withheld from public disclosure by the Commission and addresses considerations listed in paragraph (b) (4) of 10 CFR Section 2.790 of the Commission's regulations.

Accordingly, it is respectfully requested that the information which is proprietary to Framatome ANP be withheld from public disclosure in accordance with 10 CFR Section 2.790 of the Commission's regulations.

Correspondence with respect to the copyright or proprietary aspects of the items or the supporting of Framatome affidavit listed in Attachment 1 should be addressed to James F. Mallay, Director Regulatory Affairs, Framatome ANP, 3315 Old Forest Road, Lynchburg, VA 24501.

Relief Requests 30 and 31 are needed to support potential corrective actions resulting from any future Reactor Vessel Head Penetration inspections. Please contact John Manso at (305) 246-6622, if there are any questions about this submittal.

Very truly yours, 4ý'Jaohn 4P.McEZwaih" Vice President Turkey Point Plant DRL Attachments 1-3 cc: Eva Brown, NRR Turkey Point Project Manager C)4/7 an FPL Group company

AFFIDAVIT COMMONWEALTH OF VIRGINIA )

) ss.

CITY OF LYNCHBURG )

1. My name is James F. Mallay. I am Director, Regulatory Affairs, for Framatome ANP ("FRA-ANP"), and as such I am authorized to execute this Affidavit.
2. I am familiar with the criteria applied by FRA-ANP to determine whether certain FRA-ANP information is proprietary. I am familiar with the policies established by FRA-ANP to ensure the proper application of these criteria.
3. I am familiar with the FRA-ANP information contained in the documents that are listed in the attachment related to CRDM manufacture, inspection, and repair provided to the NRC by Florida Power & Light and referred to herein as "Documents." Information contained in these Documents has been classified by FRA-ANP as proprietary in accordance with the policies established by FRA-ANP for the control and protection of proprietary and confidential information.
4. These Documents contain information of a proprietary and confidential nature and is of the type customarily held in confidence by FRA-ANP and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in these Documents as proprietary and confidential.
5. These Documents are being made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in the Documents be withheld from public disclosure.
6. The following criteria are customarily applied by FRA-ANP to determine whether information should be classified as proprietary:

(a) The information reveals details of FRA-ANP'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 FRA-ANP.

(d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for FRA-ANP in product optimization or marketability.

(e) The information is vital to a competitive advantage held by FRA-ANP, would be helpful to competitors to FRA-ANP, and would likely cause substantial harm to the competitive position of FRA-ANP.

7. In accordance with FRA-ANP's policies governing the protection and control of information, proprietary information contained in these Documents has been made available, on a limited basis, to others outside FRA-ANP only as required and under suitable agreement providing for nondisclosure and limited use of the information.
8. FRA-ANP 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.

SUBSCRIBED before me this day of ,2002.

Ella F. Carr-Payne NOTARY PUBLIC, STATE OF VIRGINIA MY COMMISSION EXPIRES: 8/31/05

Attachment to Affidavit Dated and Signed on August 7,2002, Listing Documents Related to Manufacture, Inspection, and Repair Provided to the NRC by Florida Power & Light

1. Framatome Document 51-5014709, Rev. 2, Dated 6/3/02, Turkey Point 3 RV Head Penetration IDTB Weld Repair - Life Assessment Summary
2. Framatome Document 51-5014708, Rev. 2, Dated 3/13/02, PWSCC Assessment of Turkey Point 3 & 4 RV Head Penetration IDTB Weld Repair
3. Framatome Document 51-5014707, Rev. 2, Dated 5/31/02, Corrosion Evaluation of Turkey Point 3 RV Head Penetration IDTB Weld Repair
4. Framatome Document 32-5014129, Rev. 1, Dated 1/31/02, Turkey Point 3 - CRDMH 3D FE Model
5. Framatome Document 32-5014640, Rev. 3, Dated 5/20/02, Turkey Point 3 - CRDM Temperbead Bore Weld Analysis
6. Framatome Document 32-5014624, Rev. 2, Dated 5/31/02, TP-3 CRDM Nozzle IDTB J Groove Weld Flaw Evaluation
7. Framatome Document 32-5014623, Rev. 2, Dated 5/31/02, TP-3 CRDM Nozzle IDTB Weld Anomaly Flaw Evaluation
8. Framatome Document 51-5017363, Rev. 1, Dated 6/3/02, Turkey Point 4 RV Head Penetration IDTB Weld Repair- Life Assessment Summary
9. Framatome Document 51-5017362, Rev. 1, Dated 3/20/02, Corrosion Evaluation of Turkey Point 4 RV Head Penetration IDTB Weld Repair
10. Framatome Document 33-5017337, Rev. 0, Dated 3/12/02, ASME Stress Report, CRDM ID Temperbead Repair Stress Report, Turkey Point Unit 4
11. Framatome Document 32-5016966, Rev. 2, Dated 6/3/02, TP-4 CRDM Nozzle IDTB J Groove Weld Flaw Evaluation
12. Framatome Document 51-5012728, Rev. 3, Dated 10/29/01, Weld Anomaly Considerations in the CRDM ID Temper Bead Weld Repair
13. Framatome Document 51-5013731, Rev. 0, Dated 7/20/01,Turkey Point 3 & 4 CRDM Nozzle Fabrication History & Dimensions
14. Framatome Document 32-5016967, Rev. 2, Dated 6/3/02, TP-4 CRDM Nozzle IDTB Weld Anomaly Flaw Evaluation
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