ML051030283

Response to Request for Additional Information Regarding Permanent Relief from Inservice Inspection Requirements of 10 CFR 50.55a(g) and Request to Revise Pressure/Temperature Curves of Technical Specification 3.4.11

ML051030283
Person / Time
Site:	Columbia
Issue date:	04/01/2005
From:	Oxenford W Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
G02-05-064
Download: ML051030283 (6)

Text

ENERGY A NORTHWEST People -Vision -Solutions P.O. Box 968

• Richland, WA

• 99352-0968 Confidential Trade Secret Information submitted pursuant to 10 CFR 2.390 April 1, 2005 G02-05-064 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING PERMANENT RELIEF FROM INSERVICE INSPECTION REQUIREMENTS OF 10 CFR 50.55a(g) AND REQUEST TO REVISE PRESSUREITEMPERATURE CURVES OF TECHNICAL SPECIFICATION 3.4.11

References:

(1) Letter Dated June 9, 2004, G02-04-107, DKAtkinson (Energy Northwest) to NRC, "License Amendment Request to Revise Technical Specification 3.4.11 Reactor Coolant System (RCS)

Pressure and Temperature (P/T) Limits."

(2) Letter Dated July 15, 2004, G02-04-125, DKAtkinson (Energy Northwest) to NRC, "Permanent Relief from Inservice Inspection Requirements of 10 CFR 50.55a(g) for the Volumetric Examination of Circumferential Reactor Pressure Vessel Welds."

Dear Sir or Madam:

Inthe letter of Reference 1, Energy Northwest requested an amendment to the Columbia Generating Station (Columbia) Technical Specifications (TS) Limiting Condition for Operation 3.4.11, "RCS Pressure and Temperature (P/T) Limits." Specifically, this proposed amendment would replace the PIT curves for Inservice Leak and Hydrostatic Testing, Non-Nuclear Heating and Cooldown, and Nuclear Heating and Cooldown currently illustrated in TS Figures 3.4.11-1, 3.4.11-2, and 3.4.11-3, respectively. Inthe letter of Reference 2, Energy Northwest requested NRC approval for permanent relief from inservice inspection requirements of 10 CFR 50.55a(g) for the volumetric examination of circumferential reactor pressure vessel welds for Columbia. This category of welds is specified in the American Society of Mechanical Engineers Code Section Xl, Table IWB-2500-1, Examination Category B-A, Item B1.11, Circumferential Shell Welds. ALO

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING PERMANENT RELIEF FROM INSERVICE INSPECTION REQUIREMENTS OF 10 CFR 50.55a(g) AND REQUEST TO REVISE PRESSURE/TEMPERATURE CURVES OF TECHNICAL SPECIFICATION 3.4.11 Page 2 of 2 Subsequent to submittal of the referenced requests, Energy Northwest received Requests for Additional Information (RAls) from NRC staff reviewing the referenced documents. Energy Northwest's responses to the RAls are contained herein as and Attachment 2 to this letter.

The tables on pages 2 and 3 of Attachment 1 and page 3 of Attachment 2 contain proprietary information. The Electric Power Research Institute (EPRI) requests this information be withheld from public disclosure. The enclosed affidavit from EPRI (the owner of the information) provides the basis for the request. The proprietary information is denoted as required by 10 CFR 2.390(b)(A)

If you have any questions or require additional information regarding this matter, please contact Mr. DW Coleman, Manager, Regulatory Programs, at (509) 377-4342.

Respectfully, Vice rident, Technical Services Mail op PE04

Enclosure:

EPRI Affidavit Attachments: (1) Response to RAI Regarding Columbia Generating Station Pressure and Temperature Limits (2) Response to RAI Regarding Relief Request from Volumetric Examination of Circumferential RPV Welds cc: BS Mallet - NRC - RIV BJ Benney - NRC - NRR NRC Sr. Resident Inspector - 988C RN Sherman - BPA/1 399 WA Horin - Winston & Strawn

EL EC TR IF Y T HE W OR L D 2 March 22, 2005 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Request for Withholding of Proprietary Information Entitled "BWRVIP Integrated Surveillance Data (ISP) for Heat 5P6756 (Fluence Values, and Unirradiated and Irradiated (T30 ) Transition Temperature Data)" (the "Information").

Attn Document Control Desk:

This is a request under 10 CFR 2.390 that the NRC withhold from public disclosure the Information identified in the enclosed affidavit consisting of EPRI owned proprietary information, entitled "BWRVIP Integrated Surveillance Data (ISP) for Heat 5P6756 (Fluence Values, and Unirradiated and Irradiated (T30) Transition Temperature Data" (the "Information").

A copy of the Information and the affidavit in support of this request are enclosed.

EPRI desires to disclose the Information in confidence to the NRC for informational purposes to assist the NRC. EPRI would welcome any discussions with the NRC related to the Information that the NRC desires to conduct.

The Information is for the NRC's internal use and may be used only for the purposes for which it is disclosed by EPRI. The Information should not be otherwise used or disclosed to any person outside the NRC without prior written permission from EPRI.

If you have any questions about the legal aspects of this request for withholding, please contact EPRI's Legal Department at 650-855-2000.

Sincerely, David J. Modeen Vice President & Chief Nuclear Officer Enclosures cc: Licensing 1300 W.T. Harris Boulevard I Charlotte, NC 28262 USA 1704.547.3774 1FAX 704.547.6168 1www.epri.com

AFFIDAVIT RE: Request for Withholding of Proprietary Information Entitled "BWRVIP Integrated Surveillance Data for Heat 5P6756 (Fluence Values, and Unirradiated and Irradiated (T30 )

Transition Temperature Data)" (the "Information")

I, DAVID MODEEN, being duly sworn, depose and state as follows:

I am the Vice President & Chief Nuclear Officer at the Electric Power Research Institute

("EPRI") and I specifically have been delegated responsibility for the Information listed above that is sought under this affidavit to be withheld (the "Information") and authorized to apply for its withholding on behalf of EPRI. This affidavit is submitted to the Nuclear Regulatory Commission ("NRC") pursuant to 10 CFR 2.790 (a)(4) based on the fact that the Information consists of trade secrets of EPRI and that the NRC will receive the Information from EPRI under privilege and in confidence.

The basis for withholding such Information from the public is set forth below:

(1) The Information has been held in confidence by EPRI, its owner. All those accepting copies of the Information must agree to preserve the confidentiality of the Information.

(2) The Information is a type customarily held in confidence by EPRI and there is a rational basis therefor. The Information is a type that EPRI holds in confidence by means of a trade secret(s). This information is held in confidence by EPRI because disclosing it would prevent EPRI from licensing the Information and collecting royalties. Such royalty fees allow EPRI to recover its investment. If consultants and/or other businesses providing services in the electric/nuclear power industry were able to publicly obtain the Information, they would be able to use it commercially for profit and avoid spending the large amount of money that EPRI was required to spend in preparation of the Information. The rational basis that EPRI has for classifying the Information as a trade secret(s) is justified by the Uniform Trade Secrets Act.

which California adopted in 1984 and which has been adopted by over twenty states. The Uniform Trade Secrets Act defines a "trade secret" as follows:

"Trade secret" means information, including a formula, pattern, compilation, program, device, method, technique, or process, that:

(i) Derives independent economic value, actual or potential, from not being generally known to the public or to other persons who can obtain economic value from its disclosure or use; and (ii) Is the subject of efforts that are reasonable under the circumstances to maintain its secrecy.

(3) The Information will be transmitted to the NRC in confidence.

(4) The Information is not available in public sources. EPRI developed the Information only after making a determination that the Information was not available from public sources.

Developing the Information required a large expenditure of dollars and EPRI employees' time.

The money spent, plus the value of EPRI's staff time in preparing the Information, shows that the Information is highly valuable to EPRI. Finally, the Information was developed only after a long period of effort of at least several months.

(5) A public disclosure of the Information would be highly likely to cause substantial harm to EPRI's competitive position and the ability of EPRI to license the Information both domestically and internationally. The Information can only be acquired and/or duplicated by others using an equivalent investment of time and effort.

I have read the foregoing, and the matters stated therein are true and correct to the best of my knowledge, information and belief. I make this affidavit under penalty of perjury under the laws of the United States of America and under the laws of the State of California.

Executed at 3412 Hillview Avenue, Palo Alto, being the premises and place of business of the Electric Power Research Institute.

March 22, 2005 David J. Modeen March 22, 2005 Huang fork, Notary Public iI htokco b rb Wirn5es J~rAt

SUBSCRIBING WITNESS JURAT

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WITNESS my hand and officil seal.

NOTARY'S SIGNATURE OPTIONAL INFORMATION The information below is optional. However, it may prove valuable and could prevent fraudulent attachment of this form to an unauthorized document.

CAPACITY CLAIMED BY SIGNER (PRINCIPAL) DESCRIPTION OF ATTACHED DOCUMENT

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[1 CORPORATE OFFICER TITLE OR TYPE OF DOCUMENT TITLE(S)

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