ML092090215
| ML092090215 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 07/23/2009 |
| From: | Price J Dominion Nuclear Connecticut |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 09-376, CAW-09-2591, WCAP-16896-NP, Rev 2, WCAP-16896-P, Rev 2, FOIA/PA-2011-0115 | |
| Download: ML092090215 (12) | |
Text
Dominion Nuclear Connecticut, Inc.
D 5000 Dominion Boulevard, Glen Allen, Virginia 23060
.m Web Address: www.dom.com Proprietary Information-Withhold Under 10 CFR 2.390 July 23, 2009 U. S. Nuclear Regulatory Commission Serial No.09-376 Attention: Document Control Desk NSSLIWDC RO Washington, D.C. 20555 Docket No.
50-336 License No.
DPR-65 DOMINION NUCLEAR CONNECTICUT, INC.
MILLSTONE POWER STATION UNIT 2 REQUEST RR-89-61 REVISION 2, ALTERNATIVE REPAIR AND MITIGATION REQUIREMENTS FOR STRUCTURAL WELD OVERLAYS Dominion Nuclear Connecticut, Inc. (DNC) hereby requests U.S. Nuclear Regulatory Commission (NRC) review and approval of Request RR-89-61, Revision 2, for alternative requirements to apply dissimilar metal structural weld overlays (SWOLs) at Millstone Power Station Unit 2 (MPS2). This request adds the most recent revision of the enclosed technical reports, which are to be incorporated into the alternative requirements previously approved for use in NRC letter dated May 8, 2008 (Reference 1). In all other respects, RR-89-61, Revision 2, is as previously approved as an alternative providing an acceptable level of quality and safety, pursuant to provisions of 10 CFR 50.55a(a)(3)(i). This request further facilitates implementation of As Low As Reasonably Achievable (ALARA) dose exposures to workers by reducing the time required to complete weld overlays for five locations including three safety injection nozzles and two reactor coolant system (RCS) spray nozzles.
The change complies with the previously evaluated design basis already reviewed by the NRC and does not change report sections pertaining to the RCS surge, shutdown cooling, charging inlet, and letdown/drain nozzles.
The change in engineering analysis contained in the enclosed reports complies with the same applicable American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) requirements for a full SWOL repair and inspectability as approved by the NRC for RR-89-61, Revision 1. Specifically, the change in the enclosed reports updates the conservatively estimated fatigue crack growth (FCG) values used in the IWB-3640 flaw depth-to-thickness ratio evaluation using more accurate flaw growth values. A decreased maximum expected sacrificial layer deposition thickness is also used. With these parameters in the SWOL sizing calculation, the amount of additional thickness that satisfies the IWB-3640 requirements (for 100 percent through-wall flaws with flaw growth) is reduced from that previously approved for use at MPS2.
The recommended SWOL design thicknesses for the safety injection nozzle stainless steel welds were also reduced by removing unneeded conservatism. The changes are identified by revision bars in the enclosed proprietary and redacted versions of the MPS2 weld overlay qualification reports. contains information proprietary to Westinghouse Electric Company LLC.
It is supported by an affidavit (Enclosure 2) that is signed by Westinghouse, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in ENCLOSURE 3 CONTAINS PROPRIETARY INFORMATION THAT IS BEING WITHHELD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390. UPON SEPARATION OF ENCLOSURE 3, THIS LETTER IS DECONTROLLED.
Serial No.09-376 Docket No. 50-336 Revision to Request RR-89-61 Page 2 of 3 paragraph (b)(4) of Section 2.390 of the Commission's regulations.
Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR 2.390.
Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse affidavit should reference CAW-09-2591 and should be addressed to J. A. Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.
Should you have any questions about the information provided or require additional information, please contact Wanda D. Craft at (804) 273-4687.
Sincerely, J.
rice V*
resident-Nuclear Engineering Commitments made by this.letter: None
References:
- 1. NRC Letter, Millstone Power Station, Unit 2 - Relief Request RR-89-61 Regarding the use of Weld Overlays as an Alternative Repair and Mitigation Technique (TAC No.
MD6965)," May 8, 2008 (ADAMS Accession No. ML081150692)
Enclosures:
- 1. WCAP-16896-NP, Rev. 2 "Millstone Unit 2 RCS Surge, Spray, Shutdown Cooling, Safety Injection, Charging Inlet, and Letdown/Drain Nozzles Structural Weld Overlay Qualification," dated June, 2009 (Non-Proprietary).
- 2. Westinghouse Electric Company, LLC. authorization letter, CAW-09-2591, "Application for Withholding Proprietary Information from Public Disclosure" dated June 1, 2009 with Affidavit, Proprietary Information Notice, and Copyright Notice.
- 3. WCAP-16896-P, Rev. 2 "Millstone Unit 2 RCS Surge, Spray, Shutdown Cooling, Safety Injection, Charging Inlet, and Letdown/Drain Nozzles Structural Weld Overlay Qualification," dated June, 2009 (Proprietary).
Serial No.09-376 Docket No. 50-336 Revision to Request RR-89-61 Page 3 of 3 cc:
U.S. Nuclear Regulatory Commission (w/o Enclosures)
Region I 475 Allendale Road King of Prussia, PA 19406-1415 Ms. C. Sanders Project Manager U.S. Nuclear Regulatory Commission One White Flint North 1'1555 Rockville Pike Mail Stop 0-8 B3 Rockville, MD 20852-2738 NRC Senior Resident Inspector (w/o Enclosures)
Millstone Power Station
Serial No.09-376 Docket No. 50-336 ENCLOSURE 2 WESTINGHOUSE ELECTRIC COMPANY. LLC. AUTHORIZATION LETTER.
CAW-09-2591. "APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE" DATED JUNE 1. 2009 WITH AFFIDAVIT, PROPRIETARY INFORMATION NOTICE. AND COPYRIGHT NOTICE (Non-Proprietary)
MILLSTONE POWER STATION UNIT 2 DOMINION NUCLEAR CONNECTICUT, INC.
0 Westinghouse Westinghouse Electric Company Nuclear Services P.O. Box 355 Pittsburgh, Pennsylvania 15230-0355 USA U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Direct tel:
Direct fax:
e-mail:
(412) 374-4643 (412) 374-4011 greshaja@westinghouse.com Our ref: CAW-09-2591 June 1, 2009 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
WCAP-16896-P, Rev. 2,"Millstone Unit 2 RCS Surge, Spray, Shutdown Cooling, Safety Injection, Charging Inlet, and Letdown/Drain Nozzles Structural Weld Overlay Qualification."
June, 2009 (Proprietary)
The proprietary information for which withholding is being requested in the subject report is further identified in Affidavit CAW-09-2591 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter. sets forth the basis on which the information may be withheld firom public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.
Accordingly, this letter authorizes use of the accompanying affidavit by Dominion Nuclear Connecticut, Inc.
(DNC).
Correspondence with respect to this application for withholding or the accompanying Westinghouse affidavit should reference this letter, CAW-09-2591. and should be addressed to J. A. Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.
Very truly yours, J. A. Gresharn, Manager Regulatory Compliance and Plant Licensing Enclosures cc: C. Sanders (NRC OWFN 8B1A)
CAW-09-2591 AFFIDAVIT STATE OF CONNECTICUT:
s s COUNTY OF HARTFORD:
Before me, the undersigned authority, personally appeared Michael J. Gancarz, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:
7)
Michael J. Gancarz Product Manager, Systems and Equipment Engineering 11 Sworn to and subscribed before me this I st day of June, 2009 N
ry Public My Commission Expires:
a3/
0
2 CAW-09-2591 (1) 1 am Michael J. Gancarz. Product Manager, Systems and Equipment Engineering II in Nuclear Services. Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.
(2)
I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conj unction with the Westinghouse "Application for Withholding" accompanying this Affidavit.
(3) 1 have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.
(4)
Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the, Commission's regtulations, the following is furnished for consideration by the Commission in determining whether the information sought~to be withheld firom public disclosure should be withheld.
(i)
The information sought to be withheld friom public disclosure is owned and has been held in confidence by Westinghouse.
(ii)
The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.
Under that system, information is held in confidence if it falls in one or more of several types, the release of which might resuLlt in the loss of an existing or potential competitive advantage, as follows:
(a)
The information reveals the distingtuishing aspects of a process (or component, strtucture, tool, method, etc.) where prevention of its use by any of WestinghotIse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.
3 CAW-09-2591 (b)
It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economicz advantage. e.g., by optimization or improved marketability.
(c)
Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.
(d)
It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.
(e)
It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.
(f)
It contains patentable ideas, for which patent protection may be desirable.
There are sound policy reasons behind the Westinghouse system Which include the following:
(a)
The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.
(b)
It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.
(c)
Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at o'ur expense.
(d)
Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as tile total competitive advantage. If competitors acquire components of proprietary information, any one component
4 CAW-09-2591 may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.
(e)
.Unrestiricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.
(f)
The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.
(iii)
The information is being transmitted to the Commission in confidence and, under the provisions Of 10 CFR Section 2.390. it is to be received in confidence by the Commission.
(iv)
The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.
(v)
The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP-16896-P, Rev. 2, "Millstone Unit 2 RCS Surge, Spray.
Shutdown Cooling, Safety Injection, Charging Inlet, and Letdown/Drain Nozzles Structural Weld Overlay Qualification" (Proprietary), dated June, 2009. for submittal to the Commission, being transmitted by Dominion Nuclear Connecticut, Inc., Application for Withholding Proprietary Information from Public Disclosure to the Document Control Desk. The proprietary information contains design informration relevant to the Westinghouse weld overlay process that enables Westinghouse to support utilities in performing nozzle repairs. This infrnrmation includes analytical crack growth methods and results that support the application of weld overlay to various reactor coolant pressure boundary nozzles.
Further this information has substantial commercial value, as follows:
(a)
Westinghouse plans tosell the use of similar information to its customers for the purpose of meeting NRC requirements for licensing documentation.
5 CAW-09-2591 (b)
Westinghouse can sell support and defense of the technology to its customers in the licensing process.
Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar design and analytical services and licensing defense services for commercial power reactors 'vithout incurring commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.
The development of the technology described in part by the information sought to be withheld is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.
In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite.talent and experience, would have to be expended.
Further the deponent sayeth not.
6 6 CAW-09-2591 PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.
In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).
COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation sub ject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.
Dominion Nuclear Connecticut. Inc.
Letter for Transmittal to the NRC The following paragraphs should be included in your letter to thie NRC:
Enclosed are:
- 1. 1 copy of WCAP-I6896-P. Rev. 2, "Millstone Unit 2 RCS Surge, Spray, Shutdown Cooling, Safety Injection, Charging Inlet, and Letdown/Drain Nozzles Structural Weld Overlay Qualification", dated June, 2009 (Proprietary)
- 2.
1 copy of WCAP-16896-NP, Rev. 2, "Millstone Unit 2 RCS Surge, Spray, Shutdown Cooling, Safety Injection, Charging Inlet,and Letdown/Drain Nozzles Structural Weld Overlay Qualification",
dated June, 2009 (Non-Proprietary)
Also enclosed is Westinghouse authorization letter CAW-09-2591 with accompanying affidavit,
.Proprietary Information Notice, and Copyright Notice.
As Item I contains information proprietary to Westinghouse Electric Company LLC., it is supported by an affidavit signed by Westinghouse, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the consi derations listed in paragraph (b) (4) of Section 2.390 of the Commission's regulations.
Accordingly, it is respectfully requested that the information which is proprietary to Westinglouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.
Correspondence with respect to the copyright or proprietaly aspects of the items listed above or the supporting Westinghouse affidavit should reference CAW-09-2591 and should be addressed to J.A. Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.