ML15037A048

Transmittal of Affidavit from Areva for RAI Response to Relief Request 52

ML15037A048
Person / Time
Site:	Palo Verde
Issue date:	01/29/2015
From:	Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
102-07000-TNW/DCE, ANP-3375Q1P
Download: ML15037A048 (6)

Text

94 10 CFR 2.390 Palo Verde Nuclear Generating Station P.O. Box 52034 Phoenix, AZ 85072 Mail Station 7636 Tel: (623) 393-5764 102-07000-TNW/DCE January 29, 2015 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, Maryland 20852

References:

1. APS letter number 102-06991, Palo Verde Nuclear GeneratingStation Unit 3, Docket No. STN 50-530, Response to Request for Additional Information (RAI) for Unit 3 Bottom Mounted Instrument Relief Request 52, (ProprietaryVersion) dated January 16, 2015 [Agencywide Documents Access And Management System (ADAMS)

Accession No. ML15023A047]

2. NRC letter Palo Verde Nuclear Generating Station, Unit 3 - Request for Additional Information Re: Relief Request 52, Alternative to ASME Code,Section XI Requirements for Flaw Evaluation, Flaw Characterization,and Successive Examinations, dated December 4, 2014 (ADAMS Accession No. ML14330A510)

3. Arizona Public Service Company (APS) letter number 102-06879, Palo Verde Nuclear Generating Station Unit 3, Docket No. STN 50-530, American Society of Mechanical Engineers (ASME) Code,Section XI, Request for Approval of an Alternative to Flaw Removal, Flaw Characterizationand Successive Examinations - Relief Request 52, dated May 16, 2014 (ADAMS Accession No Accession No. ML14142A029)

Subject:

Palo Verde Nuclear Generating Station Units 1, 2, and 3 Docket Nos. STN 50-528/529/530 Transmittal of Affidavit from AREVA for RAI Response to Relief Request 52 On January 16, 2015, pursuant to 10 CFR 50.55a(a)(3)(i), Arizona Public Service Company (APS) submitted responses (Reference 1) to the NRC staff request for additional information (RAI) (Reference 2) from APS to clarify information provided in the Relief Request 52 (Reference 3).

Relief Request 52 was submitted to obtain NRC approval for operation of Unit 3 beyond the current operating cycle based on analyses that justify continued operation for the remainder of licensed operating life. The request was in response to the identification of leakage in Unit

3. Specifically, on October 6, 2013, APS identified evidence of leakage in the annulus of A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway 0 Diablo Canyon 0 Palo Verde 0 Wolf Creek

1b2e'07000-TNW/DCE ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Transmittal of Affidavit from AREVA for RAI Response to Relief Request 52 Page 2 the Palo Verde Nuclear Generating Station (PVNGS) Unit 3 reactor vessel (RV) bottom mounted instrument (BMI) nozzle penetration 3.

The response letter requested to withhold the proprietary information from public disclosure, specifically, AREVA document ANP-3375QIP, Responses to RAIs for APS PVNGS Unit 3 BMI Nozzle #3 Repair, contained in the letter's attachment.

After submittal of the proprietary documents, APS was informed by the NRC staff that the affidavit was placed in the attachment in such a manner that made it difficult to construe whether the affidavit itself was proprietary. This letter resubmits the affidavit in order to clarify the affidavit itself is not a proprietary document and maybe used by the NRC staff pursuant to 10 CFR 2.390.

No commitments are being made to the NRC in this letter. Should you need further information regarding this submittal, please contact Thomas N. Weber, Nuclear Regulatory Affairs Department Leader, at (623) 393-5764.

Sincerely, TNW/DCE/hsc

Enclosure:

AREVA Affidavit for AREVA Document ANP-3375QIP, Responses to RAIs for APS PVNGS Unit 3 BMI Nozzle #3 Repair cc: M. L. Dapas NRC Region IV Regional Administrator B. K. Singal NRC NRR Project Manager for PVNGS M. M. Watford NRC NRR Project Manager C. A. Peabody NRC Senior Resident Inspector for PVNGS

ENCLOSURE AREVA AFFIDAVIT FOR AREVA DOCUMENT ANP-3375QlP, RESPONSES TO RAIS FOR APS PVNGS UNIT 3 BMI NOZZLE #3 REPAIR

AFFIDAVIT COMMONWEALTH OF VIRGINIA )

) ss.

CITY OF LYNCHBURG )

1. My name is Phil Opsal. I am Manager, Product Licensing, for AREVA Inc.

(AREVA) and as such I am authorized to execute this Affidavit.

2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary. I am familiar with the policies established by AREVA to ensure the proper application of these criteria.

3. I am familiar with the AREVA information contained in the document ANP-3375Q1P titled "Responses to RAIs for APS PVNGS Unit 3 BMI Nozzle #3 Repair," dated January 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA Inc. for the control and protection of proprietary and confidential information.

4. This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by AREVA and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.

5. This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure. The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is

requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial information."

6. The following criteria are customarily applied by AREVA to determine whether information should be classified as proprietary:

(a) The information reveals details of AREVA'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 AREVA.

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

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

The information in this Document is considered proprietary for the reasons set forth in paragraphs 6(c), 6(d) and 6(e) above.

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

8. AREVA 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 1_54b__

day of 2015.

SHERRY L.MOMOEN m{csconsecuiooiuxpus Oct 31. 2018