ML033000126

In Service Inspection Plan Third Ten-Year Interval Relief Request 22

ML033000126
Person / Time
Site:	Saint Lucie
Issue date:	10/15/2003
From:	Jefferson W Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2003-222
Download: ML033000126 (19)

Text

0 Florida Power & Light Company, 6501 S. Ocean Drive, Jensen Beach. FL 34957 FPL October 15, 2003 L-2003-222 10 CFR 50.4 10 CFR 50.55a U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Re:

St. Lucie Unit 1 Docket No. 50-335 In Service Inspection Plan Third Ten-Year Interval Relief Request 22 Pursuant to 10 CFR 50.55a (a)(3)(i), Florida Power and Light Company (FPL) requests approval of relief request 22, Extemal Weld Between Small Bore Nozzle And Reactor Coolant Piping Hot Leg, to utilize alternative welding requirements to those contained in the Code to be used for the repair. Relief is also requested from ASME Section Xl Code requirements that require flaw characterization. The alternative requirements provide an acceptable level of quality and safety for one cycle of operation. is Unit 1 IS Relief Request 22. Attachment 2 is the Westinghouse Electric Company LLC proprietary affidavit, pursuant to 10 CFR 2.790, for Calculation Note CN-CI-02-51 Rev. 00 and Calculation Note CN-CI-02-56 Rev. 00. Attachment 3 is non proprietary and proprietary versions of Calculation Note CN-CI-02-51 Rev. 00. is non proprietary and proprietary versions of Calculation Note CN-CI 56 Rev. 00.

Westinghouse Electric Company, LLC has determined that the proprietary versions.of Calculation Note CN-CI-02-51 Rev. 00 and Calculation Note CN-CI-02-56 Rev. 00 in Attachments 3 and 4 are proprietary in nature. Therefore, it is requested that these documents be withheld from public disclosure in accordance with the provisions of 10 CFR 2.790(a)(4). The Westinghouse reasons for the classification of this information as proprietary and the signed affidavit are included as Attachment 2.

AO3421 an FPL Group company

St. Lucie Unit 1 Docket No. 50-335 L-2003-222 Page 2 Approval is requested by March 1, 2004 to support the use of this relief request as a contingency during the upcoming spring 2004 Unit I refueling outage (SLI-19). Please contact George Madden at 772-467-7155 if there are any questions about this submittal.

William ~~

r.

Vice President St. Lucie Plant WJ/GRM Attachments Attachments 3 and 4 Contain 10 CFR 2.790 Information

St. Lucie Unit I Docket No. 50-335 L-2003-222 Attachment 1 Page 1 St. Lucie Unit 1 Relief Request 22 External Weld Between Small Bore Nozzle and Reactor Coolant Piping Hot Leg

1. ASME CODE COMPONENT(S) AFFECTED Small bore alloy 600 nozzles welded to the reactor coolant system (RCS) piping hot legs Reactor Coolant Piping Nozzle Details FPL Drawing Numbers: 8770-366, 8770-1496, 8770-3344

2. APPLICABLE CODE EDITION AND ADDENDA ASME Section Xi, 1989 Edition, No Addenda "Rules for In-Service-Inspection of Nuclear Power Plant Components (Reference 1)

ASME Section Xi, IWA-4120, states: "Repairs shall be performed in accordance with the Owner's Design Specification and the original Construction Code of the component or system. Later Editions and Addenda of the Construction Code or of Section III, either in their entirety or portions thereof, and Code Cases may be used."

The Construction Code of record for the St. Lucie Unit 1 reactor coolant system piping is ANSI B31.7, Code for Nuclear Power Piping, Class 1, February 1, 1968 Draft Edition for Trial Use and Comment.

The proposed repair will be conducted in accordance with the ASME Boiler &

Pressure Vessel Code,Section III, Subsection NB, 1989 Edition, No Addenda, (Reference 2)

3. APPLICABLE CODE REQUIREMENT Pursuant to 10 CFR 50.55a(a)(3)(i), relief is requested to utilize alternative weld repair requirements to those contained in the Code.

Relief is also requested from Code required flaw characterization.

The proposed alternative requirements provide an acceptable level of quality and safety.

Specifically, relief is requested from the following sections of the Code:

Reference 2, Figure NB-4244(d)-1, sketch (e), dimension "X". As defined by NB-3352.4(d) "X" is to be 1/16 inch minimum. The proposed repair will not establish such a gap and "X" will be zero.

Attachments 3 and 4 Contain 10 CFR 2.790 Information

St. Lucie Unit 1 Docket No. 50-335 L-2003-222 Attachment 1 Page 2 Reference 1, IWA-3300(b) and IWB-3420, requires flaw characterization based on the results of nondestructive examination (NDE). In lieu of flaw characterization, calculations will be performed to show that the worst case assumed flaws are acceptable.

Reference 1, IWB-2420(b) and IWB-2420(c); requires reexamination of the flaw for the next three inspection periods. Since initial inspection of the flaw is impractical, subsequent inspections will also be impractical.

4. REASON FOR REQUEST Small-bore nozzles are welded to the interior of the hot leg of the reactor coolant system piping. Industry experience has shown that cracks may develop in the nozzle base metal or in the weld metal joining the nozzles to the reactor coolant pipe and lead to leakage of the reactor coolant fluid. The cracks are believed to be caused by primary water stress corrosion cracking (PWSCC).

There are two types of small-bore nozzles of concern: flow measurement nozzles and nozzles that hold resistance temperature detectors (RTD).

The weld configuration for the flow nozzle is shown in Figure 1 and the weld configuration for the RTD nozzle is shown in Figure 2.

During the upcoming St. Lucie Unit 1 outage (SL1-19), FPL will be examining the RCS hot leg flow measurement and RTD nozzles for evidence of leakage.

Nozzles that show evidence of leakage will be repaired. The proposed repair will be a partial penetration weld with fillet reinforcement applied to the external surface of the hot leg piping at the junction with the nozzle. The weld joint design will comply with the ASME Boiler & Pressure Vessel Code,Section III, Subsection NB, 1989 Edition, No Addenda, Figure NB4244(d)-1, design (e),

except for dimension "X", the gap at the internal end of the nozzle. Dimension "X" should be 1/16 inch minimum. The repair weld will not produce a gap between the new external weld and the internal end of the nozzle; therefore "X" will be 0 inches. The repair configuration for the flow nozzle is shown in Figure 3 and the repair configuration for the RTD nozzle is shown in Figure 4.

ASME Sect. Xl, 1989 Edition, No Addenda, IWA-3100(a) requires an evaluation to be made of flaws detected during an inservice examination, as required by IWB-3000, for Class 1 pressure retaining components.

The original small-bore nozzle to hot leg piping weld configuration is extremely difficult to UT from the outside diameter of the hot leg pipe. This is due to the compound curvature and distance from the outside surface to the weld, as can be seen in Figures 1 and 2. These conditions preclude ultrasonic coupling and control of the sound beam in order to perform flaw sizing with reasonable confidence in the measured flaw dimension. Therefore, it is impractical, and Attachments 3 and 4 Contain 10 CFR 2.790 Information

St. Lucie Unit 1 Docket No. 50-335 L-2003-222 Attachment 1 Page 3 presently, the technology does not exist, to characterize flaw geometry that may exist therein.

Not only are the configurations not conducive to UT but the dissimilar metal interface between the Alloy 182 weld metal and the carbon steel pipe adds to the difficulty in achieving a meaningful UT.

This inability to characterize the flaw will continue in the foreseeable future and subsequent examinations would also be impractical.

5. PROPOSED ALTERNATIVES AND BASIS FOR USE There are two types of small-bore nozzles of concern: flow measurement nozzles and nozzles to hold resistance temperature detectors (RTD).

The weld configuration for the flow nozzle is shown in Figure 1 and the weld configuration for the RTD nozzle is shown in Figure 2.

The nozzles are made of Alloy 600, SB-166. The nozzles have a 1-inch nominal outside diameter; the flow measurement nozzles have a nominal inside diameter of Y/z inch; the RTD nozzles have a nominal inside diameter of 0.377 inch.

The reactor coolant piping material is SA-516 Gr 70 with internal austenitic stainless steel cladding. The pipe has a 42-inch internal diameter and a nominal wall thickness of 3 3/4 inches exclusive of the cladding.

The nozzles are welded to buttering applied on the internal diameter of the pipe.

The weld metal for both the buttering and joint between the nozzle and the buttering is Inconel 182 (SFA-5.11 Class ENiCrFe-3).

During the upcoming St. Lucie Unit 1 outage (SL1-19), FPL will examine the nozzles for evidence of leakage. Nozzles that show evidence of leakage will be repaired using the proposed alternative. Any nozzle repaired due to leakage will be replaced at the subsequent outage.

PROPOSED ALTERNATIVE WELD JOINT DESIGN The repair will be a partial penetration weld with fillet reinforcement applied to the external surface of the hot leg piping at the junction with the nozzle. The welding will be done manually using the GTAW process, F-43 filler metal, preheat of 200 degrees F and no post weld heat treatment. The welding procedure specification has been qualified in accordance with ASME Boiler & Pressure Vessel Code,Section IX.

As defined by Reference 2, NB-3352.4(d), "X" is to be 1/16 inch minimum. The proposed repair will not establish such a gap and "of will be zero. The new weld configuration, a nozzle penetrating a pipe with attachment welds at both the inside and outside diameters of the pipe, will require analysis in accordance with Reference 2. An appropriate analysis has been performed, References 3 and 4, Attachments 3 and 4 Contain 10 CFR 2.790 Information

St. Lucie Unit 1 Docket No. 50-335 L-2003-222 Attachment I Page 4 using a minimum weld size of 1/4 inch for both the J-groove depth and the reinforcing fillet weld.

The original design analyses were performed using conservative assumptions for structural interaction modeling and temperature and pressure mismatch interaction loadings. The same interaction model and stresses were used for the new analysis, except that the secondary thermal stress associated with the repair weld was superimposed upon the existing pressure, thermnal, and seismic stresses at the inside and outside surface of the nozzle.

There are no additional primary loads as a result of the repair. Therefore, the primary stress criteria are met by the existing analyses.

Reference 2, paragraph NB-3222.2, provides the criteria that primary plus secondary stress intensification must be less than 3 Sm. Normally, when a weld is performed in accordance with all of the requirements of Reference 2, that is justification for the acceptance of the weld.

The weld joint will comply with Reference 2, NB-4244(d)-l, design (e), with the exception that dimension '"" will be zero (0) inches ( i.e., no gap).

This exception means that an additional secondary thermal shear stress is developed in the weld that would not normally exist. Therefore, the weld is analyzed in pure shear from the thermal loading.

The special stress limits of Reference 2, NB-3227.2 for pure shear note: "primary plus secondary and peak shear stresses shall be converted to stress intensities (equal to two times the pure shear stress) and as such shall not exceed the basic stress limits of NB-3222.2 and NB-3222.4." Therefore, the criteria for the weld is the same as the criteria for the nozzle; primary plus secondary stress intensification must be less than 3 Sm and the cumulative usage factor must be less than 1. As a conservative measure, the weld shear stress based on the minimum area through the Inconel weld is evaluated using both the nozzle and pipe Sm values. Similarly, the fatigue analysis is performed using the fatigue curves for both the Inconel and carbon steel metals.

The analysis, References 3 and 4, show the primary plus secondary stress intensities for the weld joining both the RTD nozzles and the flow measurement nozzles to the reactor coolant hot leg piping are less than 3 Sm. The results follow:

Location Primary + Secondarv Stress Intensities RTD Nozzle, Inside Nozzle 41,364 ksi < 3Sm (69.9 ksi)

RTD Nozzle, Outside Nozzle 53,424 ksi < 3Sm (69.9 ksi)

RTD Nozzle, New Weld (Inconel allowable) 46,043 ksi < 3Sm (69.9 ksi)

RTD Nozzle, New Weld (Steel allowable) 46,043 ksi < 3Sm (55.9 ksi)

Attachments 3 and 4 Contain 10 CFR 2.790 Information

St. Lucie Unit I Docket No. 50-335 L-2003-222 Attachment 1 Page 5 Location Primary + Secondary Stress Intensities Flow Measurement Nozzle, Inside Nozzle 37,804 ksi < 3Sm (69.9 ksi)

Flow Measurement Nozzle, Outside Nozzle 54,264 ksi < 3Sm (69.9 ksi)

Flow Nozzle, New Weld (Inconel allowable) 41,797 ksi < 3Sm (69.9 ksi)

Flow Nozzle, New Weld (Steel allowable) 41,797 ksi < 3Sm (55.9 ksi)

Analysis for cyclic operation was performed in accordance with Paragraph NB-3222.4(e) of Reference 2 which requires the cumulative usage factor to be less than 1. The intent of this repair is to last for one fuel cycle of operation.

However, the fatigue analysis was performed using the full set of design transients from the original design report.

The fatigue evaluation was performed for the weld and the outside surface of the nozzle where there is a stress concentration factor of 5 on the stress components per Reference 2, NB-3222.4(e)(2).

The resultant stress intensities were calculated from the original design report.

From the heat-up, cool-down and normal operating transients, the two conditions yielding the maximum range of peak stress intensity under pressure and mismatch loading were selected.

These values were adjusted for seismic stress. The stress ranges are calculated based on the newly calculated stress intensities. The allowable number of cycles is based on the newly calculated stress intensities and is used to calculate the usage factor for each stress range.

Finally, the cumulative usage factor is calculated. The results are as follows:

Location Cumulative Usaae Factor RTD Nozzle, Outside 0.0401 < 1 RTD Nozzle Weld (Inconel fatigue curve) 0.0363 < I RTD Nozzle Weld (Carbon steel fatigue curve) 0.4765 < 1 Flow Nozzle, Outside 0.0473 < 1 Flow Nozzle Weld (Inconel fatigue curve) 0.0227 < I Flow Nozzle Weld (Carbon steel fatigue curve) 0.3222 < 1 The calculations (References 3 and 4) have shown that the proposed partial penetration weld joint design without an axial gap and with an increased weld size is an acceptable alternative to the weld joint design described in ASME B&PV Code,Section III, Figure NB-4244(d)-1, sketch (e).

PROPOSED ALTERNATIVE TO FLAW CHARACTERIZATION It will be impractical to characterize the subject flaws by NDE and it will be impractical to show the flaws do not extend into the ferritic piping base metal.

Attachments 3 and 4 Contain 10 CFR 2.790 Information

St. Lucie Unit 1 Docket No. 50-335 L-2003-222 Attachment 1 Page 6 The repair technique will not remove any metal suspected of containing the leak and no attempt will be made to characterize the leak as required by the ASME Boiler & Pressure Vessel Code Section Xl, IWA-3300. Therefore, an analytical evaluation of the crack is required as specified in paragraph IWB-3600. The analysis is to show that the flaw growth of the crack will be contained for the remaining life of the nozzle.

The original small-bore nozzle to hot leg piping weld configuration is extremely difficult to UT from the outside diameter of the hot leg pipe. This is due to the compound curvature and distance from the outside surface to the weld, as can be seen in Figures 1 and 2. These conditions preclude ultrasonic coupling and control of the sound beam in order to perform flaw sizing with reasonable confidence in the measured flaw dimension.

Therefore, it is impractical, and presently, the technology does not exist, to characterize flaw geometry that may exist therein. Not only is the configuration not conducive to UT but the dissimilar metal interface between the Alloy 182 weld metal and the carbon steel pipe further adds to the difficulty in achieving a meaningful UT.

This inability to characterize the flaw will continue in the foreseeable future and subsequent examinations would also be impractical.

Since the intent is to not repair the flaw, the flaw configuration must be evaluated in accordance with Reference 1, Appendix A, "Analysis of Flaw Indications", to demonstrate continued integrity of the pressure boundary during plant operation for the postulated plant life. This calculation is performed for a plant life of 60 years. A fracture mechanics evaluation has been performed, References 5 and 6, to demonstrate that degraded J-groove weld metal could be left in the pipe, with no examination to size any flaws that might remain following the repair. This evaluation considers an assumed double-sided crack that has propagated through the J-weld and is beginning to encroach on the carbon steel material that comprises the pressure boundary.

ACCEPTANCE CRITERIA Reference 1 acceptability criteria, IWB-3610, states that the flaw is acceptable for continued service during the evaluated period if the following are satisfied:

• The criteria of IWB-361 1, Acceptance Criteria Based on Flaw Size, or IWB-3612, Acceptance Criteria Based on Applied Stress Intensity Factor, and The primary stress limits of NB-3000 (assuming a local area reduction of the pressure retaining membrane accounting for the presence of the flaw).

Attachments 3 and 4 Contain 10 CFR 2.790 Information

St. Lucie Unit I Docket No. 50-335 L-2003-222 Attachment 1 Page 7 This evaluation addressed the criteria of IWB-3612 and NB-3000. For IWB-3612, acceptability is shown if the applied stress intensity factors at the flaw size a, satisfy the following criteria:

K1 < K1 i410 (Equation 1)

Ka < KiJ42 (Equation 2) where:

K, =

the maximum applied stress intensity factor for normal (including upset and test) conditions for the flaw size af using Equation I and for emergency and faulted conditions using Equation 2.

Kia = the available fracture toughness based on crack arrest for the corresponding crack tip temperature.

Ki = the available fracture toughness based on crack initiation for the corresponding crack tip temperature.

The values of K1a410 and K1,42 are also referred to as the allowable fracture toughness criteria. The crack depth at which the stress intensity factor equals the allowable fracture toughness is the maximum allowable crack depth.

MAXIMUM ALLOWABLE FLAW SIZE The maximum allowable flaw size was determined using the Reference 1 criteria for allowable fracture toughness.

This criterion was applied at the various instrument nozzle locations analyzed and was evaluated for a range of time points throughout the transients. The time points analyzed envelope the peak stress times as well as the times with the lowest temperatures in the transient, where the allowable fracture toughness is lowest. At each of these points, the appropriate mechanical and thermal loads are used in the calculation of the maximum allowable flaw size.

For the peak stress conditions where the metal temperature is high (above 2500F), the allowable fracture toughness for normal and upset conditions is calculated from K,4/410 where KLA is 200 ksi-4in and RTNDT is 600F, and results in a value of 63.246 ksi-4in. Similarly, at the lower temperature, 700F, the allowable fracture toughness is calculated as 13.018 ksi-4in. The maximum allowable fracture toughness for emergency and accident conditions is calculated from Kic/4I2 where Kic is 200 ksi-4in and RTNDT is 600F as 141.421 ksi-4in for the high temperature condition.

Under the loading conditions considered, there is no crack depth considered that produces a stress intensity factor greater than the allowable fracture toughness.

Attachments 3 and 4 Contain 10 CFR 2.790 Information

St. Lucie Unit 1 Docket No. 50-335 L-2003-222 Attachment 1 Page 8 NORMAL AND UPSET CONDITIONS The principal consideration for normal and upset condition transients in this evaluation is to determine fatigue crack growth of a postulated flaw. The fatigue crack growth of the postulated flaws was calculated for normal and upset conditions per Reference 1, Appendix A, for the assumed double-sided flaw configuration.

The evaluation was performed for axial and circumferentially oriented flaw configurations in the hot leg, as appropriate.

All the transients listed in the design specifications were addressed. Transients not mentioned do not contribute to crack growth or present no critical conditions for possibly exceeding the fracture toughness allowable. All transients are bounded by the following two conditions:

Cool-down cycle and tests (hydrostatic and leak tests): The cool-down description bounds these cycles and is used for determining fatigue crack growth as well as checking that the allowable fracture toughness is not exceeded.

Plant trips, loss of coolant flow, and loss of load: The plant trip is found to bound these events.

The plant trip is the primary driver of the fatigue crack growth with a slight contribution from the cool-down event.

The leak test transient conditions effectively mimic the normal heat-up and cool-down loading cycle and are accounted for by increasing the required number of normal heat-up/cool-down cycles to 1050.

NORMAL HEAT-UP/COOL-DOWN AND LEAK TEST At the low temperature condition, end-of-cool-down, is a stress intensity factor of 10.456 ksi-in, where the allowable fracture toughness limit is 13.018 ksi-'lin, based on ambient temperature (i.e., 700F), and RTNDT = 60'F. (It is noted that end-of-cool-down conditions do not control crack growth in this analysis.)

For the axial flaw case, the fatigue crack growth calculation resulted in a final crack depth of 1.001 inches after 720 reactor trips and 1050 heat-up/cool-down cycles. The axial flaw is not affected by OBE.

For the circumferential flaw case, the fatigue crack growth calculation considered 300 OBE cycles in addition to the cycles described for the axial case. This flaw is sensitive to beam action of the hot leg, which adds to the crack growth relative to the axial flaw. However, pressure stresses are less than half those for the Attachments 3 and 4 Contain 10 CFR 2.790 Information

St. Lucie Unit 1 Docket No. 50-335 L-2003-222 Attachment 1 Page 9 axial case. As a result, the circumferential flaw does not grow as much as the axial flaw. Final calculated crack depth was 0.974 inches.

THE REACTOR TRIP TRANSIENT The resulting initial stress intensity factor was 40.086 ksi->!in, which is below the allowable fracture toughness limit of 63.246 ksi4in.

EMERGENCY AND FAULTED CONDITIONS Only one emergency and faulted level transient is considered in this evaluation, the loss of secondary pressure. This transient is applied to the end-of-life flaw to check for stability in the event that it occurs.

The most severe crack direction is the circumferential direction.

Emergency conditions for a flaw oriented in the circumferential direction at peak stress conditions are investigated with the end of life flaw size. At this point, the resulting K1 value, 63.130 ksi-4in, is less than the allowable fracture toughness of 141.421 ksi4in. Therefore, the emergency and faulted conditions meet the ASME Code requirements.

NB-3000 PRIMARY STRESS EVALUATION A crack through the existing J-groove weld would predominantly affect the peak stress intensities, which affect fatigue.

Fatigue associated with the crack is adequately addressed by the crack growth evaluation. Reference 1, however, additionally requires that the primary stress limits of Reference 2, NB-3000 are satisfied for the geometry local to the crack.

In the original design stress analysis, the primary stresses in the hot leg piping were calculated for a section of the hot leg, but were not specifically calculated in the immediate vicinity of this hole. Rather, in the region, Reference 2 requires that adequate pipe material exist to reinforce the hole. This Reference 2 requirement was satisfied for the existing geometry in the original design stress analysis.

Based on this, a consistent approach can be taken to address the cracked geometry.

It was conservatively assumed that the crack, or multiple cracks, is removed. That is, it was assumed that the entire volume (defined by sweeping the crack area 360 degrees around the axis of the nozzle) is removed by grinding.

It is then a simple exercise to revise the existing calculation to demonstrate that the area of reinforcement remains adequate for the existing hole area plus the flawed area assumed not to exist. References 5 and 6 show that adequate area is available.

The hot leg instrument nozzles were shown structurally acceptable per the criteria of Reference 1. These locations were demonstrated to satisfy the Attachments 3 and 4 Contain 10 CFR 2.790 Information

St. Lucie Unit 1 Docket No. 50-335 L-2003-222 Attachment 1 Page 10 fracture toughness criteria at the initial flaw and the fatigue crack growth criteria associated with normal operation and upset conditions.

The emergency and faulted condition criterion was also satisfied for these same locations based on the calculated end of life crack size. The fatigue crack growth was determined by the cool-down event associated with certain reactor shutdown events and testing and on reactor trips. Calculations were based on 1050 cool-down occurrences and 600 reactor trips for a 60-year lifetime.

The calculations have shown that the maximum postulated crack is acceptable for the life of the plant and the calculations are an acceptable alternative to the flaw characterization and subsequent reinspections as required in ASME B&PV Code, Section Xl 1989, IWB-2420(b), IWB-2420(c), IWA-3300 (b) and IWB-3420.

6. DURATION OF PROPOSED ALTERNATIVE This relief is scheduled to be implemented, if required, during the St. Lucie Unit 1 spring 2004 refueling outage (SL1-19). This relief will also be implemented, if required, for any future examinations, during the current interval.

7. REFERENCES

1. ASME Boiler & Pressure Vessel Code, Section Xl, 1989 Edition, No Addenda, Rules for In-Service-Inspection of Nuclear Power Plant Components

2. ASME Boiler & Pressure Vessel Code,Section III, Subsection NB, 1989 Edition, No Addenda

3. Westinghouse Electric Company LLC, Calculation Note CN-CI-02-51 Rev. 00, RCS Hot Leg RTD Nozzle and Flow Measurement Nozzle Repair - Design Verification for St. Lucie Units 1 & 2 (Proprietary Version)

4. Westinghouse Electric Company LLC, Calculation Note CN-CI-02-51 Rev. 00, RCS Hot Leg RTD Nozzle and Flow Measurement Nozzle Repair - Design Verification for St. Lucie Units I & 2 (Non-Proprietary Version)

5. Westinghouse Electric Company LLC, Calculation Note CN-CI-02-56 Rev. 00, Section Xl Flaw Evaluation of Florida Power and Light Units 1 & 2 Hot Leg Instrumentation Nozzles - J Weld (Proprietary Version)

6. Westinghouse Electric Company LLC, Calculation Note CN-CI-02-56 Rev. 00, Section Xl Flaw Evaluation of Florida Power and Light Units 1 & 2 Hot Leg Instrumentation Nozzles - J Weld (Non-Proprietary Version)

Attachments 3 and 4 Contain 10 CFR 2.790 Information

St. Lucie Unit 1 Docket No. 50-335 L-2003-222 Attachment 1 Page 11 Ordinal Weld FIGURE 1 FLOW NOZZLE ORIGINAL WELD JOINT Attachments 3 and 4 Contain 10 CFR 2.790 Information

St. Lucie Unit 1 Docket No. 50-335 L-2003-222 Attachment 1 Page 12 Pipe ID Original Weld FIGURE 2 RTD NOZZLE ORIGINAL WELD JOINT Attachments 3 and 4 Contain 10 CFR 2.790 Information

St. Lucie Unit 1 Docket No. 50-335 L-2003-222 Attachment 1 Page 13 Odainal Weld FIGURE 3 FLOW NOZZLE NEW EXTERNAL WELD Attachments 3 and 4 Contain 10 CFR 2.790 Information

St. Lucie Unit 1 Docket No. 50-335 L-2003-222 Attachment 1 Page 14 Pipe ID Original Weld FIGURE 4 RTD NOZZLE NEW EXTERNAL WELD Attachments 3 and 4 Contain 10 CFR 2.790 Information

St. Lucie Unit 1 Docket No. 50-335 L-2003-222 Attachment 2 Page 1 Westinghouse Electric Company LLC Proprietary Affidavit Pursuant to 10 CFR 2.790 For Calculation Note CN-CI-02-51 Rev. 00 RCS Hot Leg RTD Nozzle and Flow Measurement Nozzle Repair - Design Verification for St. Lucie Units i & 2 (Proprietary Version)

And Calculation Note CN-CI-02-56 Rev. 00 Section Xl Flaw Evaluation of Florida Power and Light Units 1 & 2 Hot Leg Instrumentation Nozzles - J Weld (Proprietary Version)

(2 Pages)

Attachments 3 and 4 Contain 10 CFR 2.790 Information

)WestringIouse PropfetarV Affidavit pursuant to 10 CFR 2.790 Page 1 of 2 1, Norton L Shapiro, depose and say that I am the Advisory Engineer of CE Engineerng Technology, Westinghouse Electric Company LLC (WEC), duly authorized to make this affidavit, and have reviewed or caused to have reviewed the Information which is identified as proprietary and described below. I have personal knowledge of the criteria and procedures utilized byWEC in designating Information as a trade secret, privileged, or as confidential commercial or financial information.

This affidavit Is submitted in conformance with the provisions of 10 CFR 2.790 of the Commissions regulations for withholding proprietary information and in conjunction with the application of Florida Power and Light Company for withholding this information. The Information for which proprietary treatment is sought Is contained In the following documents which have been appropriately designated proprietary:

CN-CI-02-51, Rev. 0, RCS Hot Leg RTD Nozzle and Flow Measurement Nozzle Repair - Design Verification for St. Lucie Units 1 and 2, September 2002 CN-CI-02-56, Rev. 03 Section Xl Flaw Evaluation of Florida Power and ight Units 1 and 2 Hot Leg Instrumentation Nozzles J - Weld, September 2002 Pursuant to 10 CFR 2.790(b)(4) of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the Information Included in the document Identified above should be withheld from public disclosure.

1. The information sought to be withheld from public disclosure Is owned and has been held in confidence by WEC. It consists of analyses of flaws left in place following repairs to certain small nozzles in the reactor coolant pressure boundary and analyses of weld repairs to such nozzles.

2. The information consists of analyses or other similar data concerning a process, method or component, the application of which results in substantial competitive advantage to WEC.

3. The Information is of a type customarily held In confidence by WEC and not customarily disclosed to the public.

4. The Information is being transmitted to the Commission In confidence under the provisions of 10 CFR 2.790 with the understanding that it is to be received in confidence by the Commission.

5. The information, to the best of my knowledge and belief, Is not available in public sources, and any disclosure to third parties has been made pursuant to regulatory provisions or proprietary agreements that provide for maintenance of the information in confidence.

6. Public disclosure of the information Is likely to cause substantial harm to the competitive position of WEC because:

a. A similar product or seMce is provided by major competitors of WEC.

b. WEC has invested substantial funds and engineering resources in the development of this information. A competitor would have to undergo similar expense in generating equivalent information.

Westlinghouse ProprIetary Affidavit pursuant lo tO CFR 2X790 Page 2 of 2

c. The information consists of analyses of flaws left in place filiowing repairs to certain small nozzles in the reactor coolant pressure boundary and analyses of weld repairs to such nozzles, the application of which provides a competitive economic advantage. The availability of such information to competitors would enable them to design their product or service to better compete with WEC, take marketing or other actions to improve their products position or Impair the position of WEC's product, and avoid developing similar technical analysis In support of their processes, methods or apparatus.

d. Significant research, development, engineering, analytical, manufacturing, licensing, quality assurance and other costs and expenses must be Included in pricing WECs products and services. The ability of WEC's competitors to utilize such hIformation without similar expenditure of resources may enable them to sell at prices reflecting significantly lower costs.

e. Use of the information by competitors in the international marketplace would increase their ability to market comparable products or services by reducing the costs associated with their technology development. In addition, disclosure would have an adverse economic Impact on WECs potential for obtaining or maintaining foreign licenses.

Ao L4 Norton L Shapiro Advisory Engineer