L-2010-086, Wastewater Permit Number FL0001562 Request for Minor Permit Modification Notification
| ML101270026 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 04/22/2010 |
| From: | Kiley M Florida Power & Light Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| FL0001562, L-2010-086 | |
| Download: ML101270026 (15) | |
Text
April 22, 2010 L-2010-086 FPL.
10 CFR 50.36 POWERING TODAY.
EMPOWERING TOMORROW.
U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555-0001 Re:
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Wastewater Permit Number FL0001562 Request for Minor Permit Modification Notification In accordance with Section 3.2.3 of the Turkey Point Units 3 and 4 Environmental Protection Plan (Appendix B of Facility Operating Licenses DPR-31 and DPR-41), enclosed is a copy of the request to revise Wastewater Permit Number FL0001 562. A minor revision is requested to allow the use of wood flour (fine wood sawdust) in the Turkey Point Units 3 and 4 condensers. Wood flour is to be applied through the cooling water system for the purpose of sealing small condenser tube leaks.
Should there be any questions, please contact Chip Bach, Turkey Point Chemistry Manager, at 305-246-6851.
Very truly yours, Michael Kiley Vice President Turkey Point Nuclear Plant Enclosure cc:
Regional. Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant QcDIj an FPL Group company
ENCLOSURE TO L-2010-086
Florida Power & Light 9760 SW 344 St. Homestead, Florida 33035 FPL April 21, 2010 Mr. Marc Harris, P.E.
Supervisor, Power Plant NPDES Permitting Industrial Wastewater Section
.Florida Department of Environmental Protection 2600 Blair Stone Road, MS 3545, Tallahassee, Florida 32399-2400 RE:
Florida Power & Light Company (FPL) - Turkey Point Nuclear Plant State NPDES Permit No. FL0001562 Use of Wood Flour for Unit 4 Condenser Tubes - Required Monitoring
Dear Mr. Harris:
Enclosed please find the request for a minor modification to the State NPDES Permit No.
FL000 1562 - to use wood flour (fine wood sawdust) in the Turkey Point Nuclear Unit 3 and 4 condensers. Wood flour is to be applied through the cooling water system for the purpose of sealing small condenser tube leaks.
Attached are the following items to support this minor modification:
- 1. Four (4) signed, sealed copies of FDEP Form 62-620(9), "Application for a Minor Revision to a Wastewater Facility or Activity Permit" including Attachment 1 and 2 to Request Minor Modification.
- 2.
An FPL check payable to the Florida Department of Environmental protection for the
$250 application fee.
If you have any questions or need additional information on this. matter, please contact Chip Bach, PTN Chemistry Manager, at 305-246-6851.
Sincerely, Michael Kiley Turkey Point Nuclear Plant Vice President FPL Nuclear Division Enclosures cc:
Tim Powell, FDEP, Southeast District Michael Halpin, FDEP, Tallahassee Robert Tomonto, FPL Gary Anderson, FPL
APPLICATION FOR A MINOR REVISION TO A WASTEWATER FACILITY OR ACTIVITY
__..._O__A PERMIT
- 1. Instructions
- a. In accordance with Rule 62-620.325, F.A.C., this form must be submitted to the appropriate Department district office or approved local program when requests for minor revisions to a permit or minor modifications to a facility are made by a permittee, except for transfer of a permit to a new permittee and addition of a major user of reclaimed water to a Part III reuse system. Application for transfer of a permit to a new permittee shall be made on DEP Form 62-620.910(11). Application for addition of a major user of reclaimed water shall be made on DEP Form 62-610.300(4)(a)1.
- b. Each applicable item must be completed in full in order to avoid delay in processing of this form. Where attached sheets or other technical documentation are provided, indicate appropriate cross-references.
- c. Three (3) copies of this application with supporting documentation shall be submitted with this form.
- d. All information is to be typed or printed in ink. Dates are to be entered in MM/DD/YR format.
- e. This application and attachments shall be signed in accordance with Rule 62-620.305, F.A.C. Also, as applicable, this application and all attachments shall be signed and sealed by a professional engineer registered in Florida in accordance with Rule 62-620.310, F.A.C.
- 2. Facility Information
- a. Permit Number:
FL0001562
- b. Facility Identification Number:
FL001562
- c. Project/Facility Name:
Florida Power & Light Company Turkey Point Plant Unit 3 & 4
- d. Contact Name:
Michael Kiley Number and Street:
9760 SW 344 Street City/State/Zip Code:
Florida City, FL 33035 Telephone 305-246-6113
- 3. Type of Revision Dl Correct Typographical Errors1 - Submit one copy of each page of the permit showing revisions being requested.
ED Change Improvement Schedule1 - Provide a description of the improvement, a list of the dates to be revised, and a reason for the proposed change in each date.
ED Change Expiration Date of Permit1 - Provide the current and proposed expiration dates for the permit and the reasons for the proposed change.
D Change Staffing Requirements' - Describe the proposed change and submit justification for the change in accordance with Chapter 62-699, F.A.C.
'A processing fee is not required.
DEP Form 62-620.910(9) 3A processing fee is required with the application Effective October 23, 2000 in accordance with Rule 62-4.050, F.A.C.
ED Change Monitoring and Reporting Requirements 2 - Describe the proposed change and submit justification for the change in accordance with Chapter 62-601, F.A.C.
ED Modify Approved Pretreatment Program' - Describe the proposed modification and provide the information required by Rule 62-625.540, F.A.C.
D Delete Point Source Outfall1 - Identify the outfall and explain why the outfall is being eliminated.
D Modify or Expand Approved Residuals Land Application Sites2 - Attach a new or updated Agricultural Use or Dedicated Site Plan as required by Chapter 62-640, F.A.C.
[
Minor Modification to the Facility2 - Provide a description of the proposed modification. If applicable, attach any reports, plans, and specifications which have been developed to implement this modification.
FD Other 2 - Provide appropriate documentation. Describe.
- 4. Certifications
- a. Applicant or Authorized Representative I certify under penalty of law that I have personally examined and am familiar with the information submitted in this application and all attachments and that, based on my inquiry of persons immediately responsible for obtaining the information contained in the application, I believe that the information is true, accurate and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment.
(Signature of Applicant or Au*oz*
esentative3)
(Date)
Name (please type)
Michael Kiley Title Plant Vice President Phone:
305-246-6113 Company Name Florida Power & Light Company Company Address:
9760 S.W. 344 Street City/State/Zip Code:
Florida City, Fl 33035
- b. Professional Engineer Registered in Florida I certify that the engineering features of this project have been (designed) (examined) by me and found to conform to engineering principles applicable to such projects. In my professional judgement, this facility, when properly constructed, operated, and maintained, will comply with all applicable statutes of the State of Florida and rules of the Department.
Name (please type):
Edward Preast Florida Registration Number:
33225 Company Name:
Florida Power & Light Company Company Address:
700 Universe Blvd.
City/State/Zip Code:
Juno Beach Florida 33408 Phone Number:
561-346-5312 (Seal, Signature, Date, and kegistraition Number) 3If signed by the authorized representative, attach a letter of authorization in accordance Rule 62-620.305, F.A.C.
Effective October 23, 2000
=
Reason for Request===
The FPL Turkey Point Nuclear Plant occasionally experiences very small cooling water leaks into the steam condensers on each Unit. The leakage is into the condensers because they are under a vacuum so saline cooling canal water leaks in rather than feedwater leaking out. The calculated saline cooling water in-leakage is less than 200 mls per day, but is large enough to produce elevated chloride and sodium contamination in the secondary system feedwater in the steam generators. This continual elevated contamination level is detrimental to the long term reliability of the steam generator tubes. Please note that this leakage is occurring in the "secondary" side of the plant, which is identical to the same system in a fossil-fired plant, and is not a "radiological" issue.
Turkey Point Nuclear has taken several corrective actions, such as helium leak searching the condenser water boxes, but has been unable to identify the leaking tubes. Industry experts have been queried and concur that there is no practical method of identifying such small leaks.
Industry experience has, however, reported success using wood flour (fine, hard wood dust) to temporally plug small condenser leaks. Turkey Point Nuclear has recently conducted a maintenance activity using wood flour, as approved by the FDEP, and FPL requests to be permitted for future use when similar events occur.
Proposed Application:
The Turkey Point Nuclear Plant is requesting permission for periodic wood flour additions to the cooling water system of the suspect leaking condenser water boxes.
Through discussion with peers and review of other plant (i.e.;. nuclear plants in other states) practices, we have developed the following plan. All quantities and frequencies are the maximum proposed and would be reduced if not necessary.
Hard wood flour (see Attachment 2 for MSDS) would be added to the inlet side of the condenser at a rate of 60 cubic feet (-4,000,lbs) of wood flour per treatment. Each treatment would last as long as it takes to pump the plugging media into the cooling water system fora specific condenser water box.
Following treatment, condenser and steam generator contaminant levels would have to be tracked for a day to determine if the treatment was successful. Only one condenser.will.
be treated at a time and only One treatment will be preformed per week, not to exceed 24 treatments in a year.
Maximum particulate loading of the cooling water system can be estimated using the following assumptions;
- 1. Circulating water design flow is 650,000 gpm per unit, for a total of 1,300,000 gpm with both units running. For the purpose of this evaluation, both units are assumed to be in service with normal circulating water flow. Units 1 and 2 also provide circulating water that is mixed with the total flow back to the canal system, however, zero dilution is credited from units 1 or 2.
- 2. 1000 lbs of wood flour is discharged into the intake at a maximum rate of 200 lbs per minute.
- 3. The application of wood flour will be to one intake structure; however it will be fully mixed with the total circulating water flow of 1,300,000 gpm within 25-50 yards of the discharge structure.
The calculation for the concentration of wood flour at the mixed. discharge is calculated as:
2001b / min* 453.59gram / lb
= 0.01 84gram / liter 18.4milligram / liter 1,300,O00gal / min* 3.785liter / gal is a Product data sheet for the wood flour.
FPL will abide by the monitoring requirements specified in the maintenance activity approval letter received from Marc Harris on September 23, 2009. Please refer to your files regarding our previous request to use wood flour in order to expedite your review of this minor permit modification request. FPL submitted the required cooling canal sample analysis data to your office on December 28, 2009. Copies of these above referenced transmittals are attached.
Florida Department of Charlie Cris
~Governor Environmental Protection I&
Ko.tkanp Lt. Governor Bob Martinez Center 2600 Blair Stone Road Michael W. Sole Tallahassee, Florida 32399-2400 Secretary September 23, 2009 BY CERTIFIED MAIL RETURN RECEIPT REQUESTED Mr. John Jones Power Generation Division Florida Power & Light Company P.O. Box 14000 Juno Beach, Florida 33408-0420 Re:
Florida Power & Light Company Turkey Point Power Plant NPDES Permit No. FL0001562 Use of Wood Flour for Unit 4 Condenser Tubes
Dear Mr. Jones:
Thank you for the information that you provided in your e-mails received on August 14 and.September 15, regarding use of wood flour (40 mesh, additive-free, pine sawdust) to temporarily repair pinhole leaks in the Turkey Point Unit 4 cooling water condenser tubes. The Department has reviewed the information and understands that Florida Power & Light Company (FPL) is conducting necessary temporary repairs to the Unit 4 condenser tubes to reduce in-leakage of hypersaline cooling water into the secondary side. FPL will use a maximum of 1,000 pounds of wood flour per weekly application at a maximum rate of 200 pounds a minute. The wood flour shall be used until the next Turkey Point Unit 4 refueling outage (currently scheduled to begin on October 25, 2009), or until November 1, 2009, whichever date is earlier, FPL will conduct more permanent repairs during the refueling outage.
Furthermore, FPL will discontinue the use of wood flour if after three applications FPL has determined that the wood flour is ineffective.
On this basis, the Department concurs that the proposed project can be considered "construction, replacement, or repair of components of an industrial site or plant," pursuant to Rule 62-620.200(26)(b), Florida Administrative Code. Moreover, repairing in-leakage or cooling water into the secondary side generally conforms to preventive maintenance BMPs required by permit under the NPDES program. Therefore, the project, as described herein,.
does not require a permit revision. It should be noted, however, that the use of wood flour past November 1, 2009, requires an application by FPL to revise the above referenced NDPES permit.
When discharging wood flour to the cooling canal system, FPL shall comply with the monitoring requirements in Table 1 of Attachment A. Please submit analytical results to the Department.
"AMore Protection, Less Process"
- r,4.1V dep.statc. fl.us
Mr. John Jones Turkey Point Power Plant September 23, 2009 Page 2 NPDES Permit No. FLO0O [562 Thank you again, and don't hesitate to contact either Bala Non' or me with any questions at (850) 245-8589.
Sincerely, Marc Harris, P.E.
Supervisor, Power Plant NPDES Permitting Industrial Wastewater Section cc:
Tim Powell, P.E., DEP Southeast District
Attachment A Table 1 -Monitoring Requirements for Use of Wood Flour at FPL Turkey Point Unit 4 Discharge Limitations Monitoring Requirements Parameters (units)
Monthly Daily Daily Monitoring Frequency Sample Sample Point(s)
-Average Maximum Minimum Type pH (su)
Report Report Weekly, When Applying Grab Unit 4 Cooling Wood Flour Water Discharge Solids, Total Dissolved Report Weekly, When Applying Grab Unit 4 Cooling
_ _DS) (raL)
Wood Flour Water Discharge Solids, Total Suspended Report Weekly, When Applying Grab Unit 4 Cooling
("SS) (rg/L)
Wood Flour Water Discharge Tnrbidi ty (NT)
Report Weekly, When Applying Unit 4 Cooling Tubiit oWood Flour Grab Water Discharge Weekly, When Applying Grab Secondary Side Sodium (rag/L)
-Report WodForGa-urSse
- ,Wood Flour Water System Secondary Side Water System Weekly, When Applying Grab Chlorides (mg/L)
Report WodForGa-SWood Flour Unit 4 Cooling Water Discharge Secondary Side Specific Report Weekly, When Applying Grab System Conductivity(umhos)
Wood Flour Grab WUnit 4 Coohing
__Water___DaterD hacrgg
Florida Power & Light 700 Universe Blvd. Juno Beach, Florida 33408 FPL December 28, 2009 Mr. Marc. Harris, P.E.
Supervisor, Power Plant NPDES Permitting Industrial Wastewater Section Florida Department of Environmental Protection 2600 Blair Stone Road, MS 3545 Tallahassee, Florida 32399-2400 RE:
Florida Power & Light Company (FPL) - Turkey Point Nuclear Plant State NPDES Permit No. FL0001562 Use of Wood Flour for Unit 4 Condenser Tubes - Required Monitoring
Dear Mr. Harris:
Enclosed please find the results of the requested cooling canal monitoring associated with the use of wood flour (fine wood sawdust) in the Turkey Point Nuclear Unit 4 once-through cooling water system for the purpose of sealing small condenser tube leaks.
If you have any questions or need additional information on this matter, please contact Chip Bach, PTN Chemistry Manager, at 305-246-6851.
cer Johi ones Environmental M ager FPL Nuclear Division
.Enelosures cc:
.DEP, Southeast District Nicholas (Chip) Bach, PTN
Monitoring Requirements for use of Wood Flour at FPL Turkey Point Nuclear Unit 4 Parameters (units)
Sample Point Date/Time Results pH (su)
Cooling Water Discharge 10/5/2009 @1130 hours 8.2 Solids, Total Dissolved (TDS) (mg/L)
Cooling Water Discharge 10/5/2009 @1130 hours 59,000 Solids, Total Suspended (TSS) (mg/f)
Cooling Water Discharge 10/5/2009 @13 0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> 9
Turbidity (NTU)
Cooling Water Discharge 10/5/2009 @1130 hours 2.9 Sodium (mg*L)
Secondary Side Water System 10/5/2009 @1130 hours 0.00005, Chlorides (mg/L)
Cooling Water Discharge 10/5/2009 @1130 hours 36,000 Secondary Side Water System 10/5/2009 @1130 hours 0.0001 Specific Conductance (uinhos)
Cooling Water Discharge 10/5/2009 @1130 hours 80,000 Secondary Side Water System 10/5/2009 @1130 hours 20.3
Monitoring Requirements for use of Wood Flour at FPL Turkey Point Nuclear Unit 4 Parameters (units)
Sample Point Date/Time Results pH (su)
Cooling Water Discharge 10/12/2009 @0820 hours 8.2 Solids, Total Dissolved (TDS) (mg/L)
Cooling Water Discharge 10/12/2009 @0820 hours 65,000 Solids, Total Suspended (TSS) (mg/L)
Cooling Water Discharge..
10/12/2009 @0820 hours 12 Turbidity (NTU)
Cooling Water Discharge 10/12/2009 @0820 hours 3.6 Sodium (mg/L)
Secondary Side Water System 10/12/2009 @0820 hours 0.00004 Chlorides (rmg/L)
Cooling Water Discharge 10/12/2009 @0820 hours 41,000 Secondary Side Water System 10/12/2009 @0820 hours 0.00008 Specific Conductance (umhos)
Cooling Water Discharge 10/12/2009 @0820 hours 83,000 Secondary Side Water System 10/12/2009 @0820 hours 23.7
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_Z61 Ov FIBE" MERICAN.W "D
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www.awf corn 9841 Broken Land Parkway Suite 502 Columnbia,.aryland 21046 (800) 624-9663-or (410) 29048700 Industrial Sales Ofce 10.0 Aldersoi.Sf-eet.
-8chofield,.WI 54476-0468 (800) 642-5448 or (715) 355-1900 Data Saeet
- TýRAD)E-NAME CAS. NO.
TSCA-LIST NFPA Hazard Label
'Woood Flour." Maple, Ponderosa Pine, Oak, Spruce, Southiern Yellow Pirie, Cedar.
'AllSpecies-AllGrades,
'None 9004-34-B (Cellulose)
Not Regulhted He.th 1".
Flamnmablity
-1 Reacti
--. 0 Special Notice None DESCRIPTION Particles generated by any manual or mechanical cutting or abrasion process performed on wood.
PHYSICALDATA Boiling Poirit.....:
- -Variable-dependent on wood species and moisture content)
Vapor Densit.."............................................
o..........
..........,.... I Not/ plicable Percent Volatiles by Volume.
Not.....a~
P e r c n t o l a ~ l e b y V ol m e............
N o t A p p lic a b le Melting Point..................
P..o.i n......
I
......................... P N6t Applicable -
Vbpor Pressure....................................
- ...Not-Applicable
ý§6gubility in Hz)0 (% by weight)........................
I.
Insoluble..
Eaiporation Rate (Butyl Acetate= 1).....................................
Not Applicable pH...
Not Applicable Appearance and Odor
..... Ligh to dark colored granularsolid. Color and odoi are dependenton the wood speiesand mesincdust ia' generate p..
FiRE ANb EXPLOSION DATA Flash Point...........................
................................................... Nof Applicable Auto-Ignition Temperature...........
..................... Variable (typically 400-5000 F)
Explosive Limits in Air.......................
40 grams/M3 (LEL)
Extinguishing Media..'..................... I....................................... W ater, C02, Sand Special Fire Fighting Procedures.................
Use water to wet down dustto reduce the likelihood of ignition
-or dispersion of dust into the air. Remove burned or wet-dust
'~wsj~al Fire "nd to bpen area aer fire is.iextinguisý d.
0usal Fire and Explosion Hazard.......
Wooddust Is a on hazard
-,I
'cloud* contacts an ignItlon source,.......-
J
.1" a.-.
""HEALTH EFlFECTS INFORMIATION
" Exposure Limit............. *"......... ! "...!
"TLA 5.0 tg ft o
"t-"
1
.0 imI(ceftaln-barhwobdslsubh as beech nroak)
'See foonotbelpw concerning PSHAEL7TWA-15.0Oimn1_
{totardust);.
OSHA P-L forlkod dust" -
+/---
mg]rO.(respr~ble foia.o)
Westem rdcedar TWA-A-2.6 mg/m.
Skin and Eye Contact......................
Wood-dust can cause eye irritatjon.Varipus speciesof wood
-" " " dust-can elicit-allergio-contict ddrmnitis In sensitzed:
indMduals.
/
iln AFL-CIO v. OSHA 965 F. 2d 962 (11b Clr. 1992) the court overturned OSHA's 1989 Air Contaminants Rule, *d,*dingth$specfi PE-s.for wood dust that OSHA had established at that tlime THE 1989 PELS WERE: TWA -5.0 moldm: STEL (15 MIN.)
10:0 mWm (ALL SOFT AND HARD woODS EXCEPT WESTERN RED CEDAR) WESTERNREDCEDAR TWA-2.5 mqam" Wdod dust Is now officially regulated as an organc dust undeithe Particulates Not Otherwis Regulated (PNOR) or Inert or Nuisance Dust categories at PFLs noted under Health Effeds-infomiation section ofthe MSDS. However.,ANUMBER OF-STATES HAVEINCORPORATED PROVISIONS OF THE 1989 STANDARD IN THEIR TATE PLANS.ADD. ONALLY0 "S
ANNO NCED -T IT MAY CIT C
- UNDER THE OSI-ACT GENERAL DUTY CLAUSE UNDER APPROPRIATE-CIRCUMSTANCES FOR NON-COMPLIANCE ~TE18 ES MSDS and NFPAHazadLabel~sfor Wood Flob~r
HEALTH EFF:CTS INFORMATION (Gond.)
- ot A
ingestioh....................... ".........:.
I.......................................
Not Applia le-Skin Absorptiono.....
n.............
Not known to occur Chronic Effects.........................................................................
Wood dust dependin g on species, niay cause dermatitis on prolonged, repetitive contact may cause respiratory sensitizaton andlor irritation. LARO classifies wood dust asa carcinoger to humans (Group 1). This classification is based prirnanly on IARC's evaluation of increased risk In the
- ocurronce of adenocarchnomas of the nasal cavities and.
.para nasal sinuses associated With exposure to wood dusl
- .IA1C did not find sufficient eviden-e to associate cancers of 1tW o
.rophary,,,
hypophaxx lung. lymphatic and heffiatopoleiic systemd, stomach, colon or rectum with eo)sure to wood dust REACTIVIT* DATA Conclitloný Contributing to Instability........................................
Stable urd r normal conditions.
lncompatibility............................
Avoid contact Wt bxidizng agents and drying oils. Avoid open flame. Prodtdct may ignite at temperatures in excess of 400.'F.
Hazardous Decomposition Products.........................................
Thermnal-oxidaMiv degradation of wood produces irritating and toxic furmes and gases, including CO, aldehydes and.
organic acids.
Conditions Contributing to Polymerizalion............ Not Applicable PRECAUTIO14S AND SAFE HANDLING a
Avoid Eye Contact
- AVoid Repeated or Prolonged J
Qcith Skin' Careful bathing and clean clobies axe Indicated after exposure.
-. Avoid PAblged orRepeated Breathing 6fWoodDust iri Air.
o Avoid Contact with Oxidizing Agents anid Drying Oiýs Avoid Open Flame.
GENERALLY APPUC L'LE CONTROL MEASUMS Venfti[aon: Provide adequate general and local exhaust ventilation to maintain heaIthfMl. w gcp.di.ns.AQns.
-Wea_.goggles-or-safety glassesOther protective eip suchas glo'es and approved-direirators may. be needed depending up6n dust conditions.'
EMERGENCY AND FIRST AID PROCEDURES Eyes Flush with water to remove dust particles.. If initation persists, get medical attentiorn" Skin If a rash or persistent irritation or dermati*is occurs, get medical advice before returning to work where wood dust is present Inhalai Rerhove to fresh air. If persistent irritation,
ý severe oughing, breathfing diffllulties occur, get medical advice before-returning to work where wo6d dust is present.
Ingestion.................... Not Applicable.'
SP1LULEcJ%*-C!E4"Up PROCEDUES Sweep-or-vacu~ni-iillifor recovery or disposal; avoiding creating dust conditions. Provide good ventilation where dust conditions may-occur. Place recovered wood dus in a container for disposal..
IMPORTANT: The infoWbmT and date herein are believed to be accurate and have been compiled from sourves believed to be reliable. It is offerod for you' consklerattori, Investigaffon; and verifcatfon. American Wood Fibers and APJ1NFPAIILMA or VA makes no mranty of any kind express orImpfied, concerning the accurmcy or completeness of te infotrmation and Sdata herein American Wood *býtrslnd APINFPAILMA or VA Wn7l not be liable for claims relaingto any parts 80 Of or relianceon information and datp ýoqtained herein regardless of whether it is claimed that the nformation and datae are inac~crate, incomplete or otherwise misleading.