ML15077A214
| ML15077A214 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 03/02/2015 |
| From: | Kiley M Florida Power & Light Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML15077A213 | List: |
| References | |
| L-2015-053, TAC MF3834 | |
| Download: ML15077A214 (20) | |
Text
I 0 FPL.March 2, 2015 L-2015-053 10 CFR 50.55a 10 CFR 2.390 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Re: Turkey Point Unit 3 Docket No. 50-250 Inservice Inspection Plan -Fifth Inspection Interval Unit 3 Relief Request No. 1, Revision 1
References:
- 1) Florida Power & Light Company letter L-2014-096 to the Nuclear Regulatory Commission, "Inservice Inspection Plan -Fifth Inspection Interval, Unit 3 Relief Request No. 1", dated April 4, 2014.2) Florida Power & Light Company letter L-2014-100 to the Nuclear Regulatory Commission, "Inservice Inspection Plan -Fifth Inspection Interval, Unit 3 Relief Request No. 1 -Response to Request for Additional Information", dated April 9, 2014.3) Florida Power & Light Company letter L-2014-105 to the Nuclear Regulatory Commission, "Inservice Inspection Plan -Fifth Inspection Interval, Unit 3 Relief Request No. 1 -Response to Follow-up Request for Additional Information", dated April 14, 2014.4) NRC letter to Florida Power & Light Company, "Turkey Point Nuclear Generating Unit No. 3 -Safety Evaluation for Relief Request No. 1 for Fifth 10-Year Inservice Inspection Interval -Repair of Pressurizer Stainless Steel Heater Sleeve Without Flaw Removal (TAC NO.MF3834)", dated October 9, 2014.By letter L-2014-096 dated April 4, 2014 (Reference
- 1) as supplemented by letters L-2014-100 (Reference
- 2) and L-2014-105 (Reference 3), Florida Power & Light Company (FPL) requested Nuclear Regulatory Commission (NRC) approval to use an alternative to the ASME Boiler and Pressure Vessel Code, Section Xl, 2007 Edition, including Addenda through 2008. FPL requested approval to implement an alternative to IWB-3142.3, Acceptance by Corrective Measures or Repair/Replacement Activity.
Specifically the pressurizer heater sleeve repair was performed to the requirements of ASME Section Xl using an ASME Section III design by replacing the pressurizer heater sleeve and relocating the pressure boundary to the outside diameter (OD) of the pressurizer shell and abandoning the existing heater sleeve and inside diameter (ID) weld in place. Relief request No. 1 supported the pressurizer repair and leaving the flaw in the abandoned pressure boundary weld.Florida Power & Light Company 9760 SW 3 4 4 th St., Florida City, FL 33035 pl, OPP L-2015-053 Page 2 of 3 Pursuant to 10 CFR 50.55a(a)(3)(ii), FPL determined that compliance with specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. NRC authorized FPL to use the referenced request during a conference call on April 15, 2014 and per the follow-up written approval safety evaluation dated October 9, 2014 (Reference 4).Due to the emergent nature of the discovery and repair, the duration of Relief Request No. 1 was for one 18- month operating cycle until a life of plant ASME Section Xl flaw evaluation was completed to support the duration of the relief request for the 5 th Inservice Inspection (ISI)interval.
Attachment 1 to this letter submits Revision 1 to Relief Request No. 1. The revised relief request provides the results of the life of plant ASME Section Xl flaw evaluation and corrosion analysis.FPL requests NRC review and approval of Relief Request No. 1, Revision 1, by October 2015, prior to the fall 2015 Unit 3 refueling outage.Enclosure 1 to this letter provides one copy of Westinghouse Report, WCAP-17973-NP, Revision 1, "Turkey Point Units 3 and 4 Pressurizer Heater Sleeve Flaw Evaluation to Support Half-Nozzle Repairs." Enclosure 1 is a non-proprietary report. Enclosure 2 to this letter provides one copy of Westinghouse Report, WCAP-17973-P, Revision 1, "Turkey Point Units 3 and 4 Pressurizer Heater Sleeve Flaw Evaluation to Support Half-Nozzle Repairs." Enclosure 2 is a proprietary report. Enclosure 3 provides the Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-15-4110, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice.As Enclosure 2 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 considerations 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 Westinghouse 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 proprietary aspects of the items enclosed or the supporting Westinghouse Affidavit should reference CAW-15-4097 and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 3 Suite 310, Cranberry Township, Pennsylvania 16066.
L-2015-053 Page 3 of 3 Please contact Mitch Guth, Licensing Manager, at 305-246-6698 if you have any questions or require any additional information about this submission.
Very truly yours, Michael Kiley Site Vice President Turkey Point Nuclear Plant
Attachment:
Turkey Point Unit 3 Relief Request No. 1, Revision 1, for the 5 th Inspection Interval
Enclosures:
- 1. WCAP-17973-NP, Revision 1, "Turkey Point Units 3 and 4 Pressurizer Heater Sleeve Flaw Evaluation to Support Half-Nozzle Repairs," (Non-Proprietary).
- 2. WCAP-17971-P, Revision 1, "Turkey Point Units 3 and 4 Pressurizer Heater Sleeve Flaw Evaluation to Support Half-Nozzle Repairs," (Proprietary).
- 3. Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-15-4110, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice.cc: Regional Administrator, USNRC Region II (w/o enclosures)
Senior Resident Inspector, USNRC, Turkey Point Nuclear Plant (w/o enclosures)
L-2015-053 Attachment Turkey Point Unit 3 Fifth Inservice Inspection Interval Relief Request No. 1, Revision 1 Repair of Pressurizer Stainless Steel Heater Sleeve Without Flaw Removal L-2015-053 Attachment Page 1 of 8 TURKEY POINT UNIT 3 FIFTH INSERVICE INSPECTION INTERVAL.RELIEF REQUEST No. 1, Rev. 1 Proposed Alternative in Accordance with 10CFR 50.55a(a)(3)(ii)
Hardship or Unusual Difficulty without Compensating Increase in Level of Quality or Safety"REPAIR OF PRESSURIZER STAINLESS STEEL HEATER SLEEVE WITHOUT FLAW REMOVAL" 1. ASME Code Component Affected Turkey Point Unit 3 Components:
Pressurizer and pressurizer heater sleeve (nozzle)Code Class: ASME Section III 1965 Edition, including Addenda through Summer 1965, Class A Examination Category:
B-P Code Item Number: B15.10
Description:
Pressurizer heater sleeve internally welded to the pressurizer lower head cladding Size: 1.125" Nominal outside diameter, 0.095" wall thickness Material:
Stainless steel SA-213 TP316 sleeve, austenitic stainless steel cladding, SA-216 Grade WCC lower head 2. Applicable Code Edition and Addenda ASME B&PV Code Section Xl, "Rules for Inservice Inspection of Nuclear Power Plant Components" 2007 Edition, including Addenda through 2008.3. Applicable Code Requirement Pursuant to 10 CFR 50.55a (a)(3)(ii)
Florida Power & Light Company (FPL) requests an alternative to the requirements of ASME B&PV Code, Section Xl, IWB-3142.3"Acceptance by Corrective Measures or Repair/Replacement Activity.
A component containing relevant conditions is acceptable for continued service if the relevant L-2015-053 Attachment Page 2 of 8 TURKEY POINT UNIT 3 FIFTH INSERVICE INSPECTION INTERVAL RELIEF REQUEST No. 1, Rev. 1 conditions are corrected by a repair/replacement activity or corrective measures to the extent necessary to meet the acceptance standards of Table IWB-341 0-1 ." 4. Reason for Request By letters L-2014-096 dated April 4, 2014, L-2014-100 dated April 9, 2014 and L-2014-105 dated April 14, 2014, FPL submitted Relief Request No. 1 and subsequent responses to NRC requests for additional information (RAIs) to support the repair of the Turkey Point Unit 3 stainless steel pressurizer nozzle without flaw removal. Due to the emergent nature of the discovery and repair, the duration of the relief request was for one refueling cycle until a life of plant ASME Section XI flaw evaluation was prepared to support the duration of the 5 th ISI interval.
Revision 1 provides the results of the life of plant ASME Section Xl flaw evaluation and corrosion analysis.FPL conducted visual examinations of the pressurizer heater sleeve penetrations during the Turkey Point Unit 3 spring 2014 Refueling Outage. These examinations revealed evidence of leakage in the annulus between the outer surface of the heater sleeve and the lower head bore at heater penetration
- 11. There was no leakage observed at the other heater penetrations.
Manual nondestructive examination (NDE)was conducted from the sleeve bore using the eddy current method after the heater was removed from the heater sleeve. The examination did not reveal any flaw in the sleeve. Therefore, the most likely location of the flaw is located in the stainless steel weld between the heater sleeve and the stainless steel cladding buildup.The heater sleeve is roll expanded into the lower head bore and welded with a partial penetration weld to the stainless steel cladding buildup on the inside of the pressurizer lower head. The partial penetration weld joint does not extend into the lower head carbon steel base material.The cladding is final stress relieved prior to welding the heater sleeve thereto. The cladding is approximately 3/8" thick and one layer of cladding of approximately 3/16" thick remains beneath the partial penetration weld. The heater is fillet welded to the bottom of the sleeve and extends upward through the two heater lateral support plates in the pressurizer.
To remove the heater sleeve-to-pressurizer weld requires accessing the internal surface of the pressurizer and removal of the weld and any remaining sleeve base metal. Such an activity results in high radiation exposure to the personnel involved which is considered a hardship.
Grinding and/or machining within the components also exposes personnel to safety hazards as well as possible foreign material remaining in the pressurizer that could later affect fuel performance.
L-2015-053 Attachment Page 3 of 8 TURKEY POINT UNIT 3 FIFTH INSERVICE INSPECTION INTERVAL RELIEF REQUEST No. 1, Rev. 1 FPL proposes to leave the upper portion of the existing heater sleeve and its weld to the pressurizer lower head cladding in service.5. Proposed Alternative and Basis for Use PROPOSED ALTERNATIVE:
The original weld will not be corrected and the heater sleeve base material was removed to approximately the mid wall of the pressurizer lower head. The heater sleeve was repaired by relocating the pressure boundary weld from the inside surface of the pressurizer to the outside surface. The repair is in accordance with the Class 1 requirements of the ASME Boiler and Pressure Vessel Code Section II1.The "half-nozzle" method was used for the repair to penetration
- 11. The heater was removed and the heater sleeve was severed below the pressurizer lower head. The remaining lower portion of the heater sleeve was removed by boring to approximately mid-wall of the lower head. The removed portion of the stainless steel sleeve was replaced with a section (half-nozzle) of low carbon stainless steel which was then welded to the outside surface of the pressurizer lower head using low carbon stainless steel weld filler. A new heater was welded to the bottom of the replacement lower sleeve using low carbon stainless steel weld filler. The upper portion of the sleeve, including the partial penetration weld, will remain in place. (See Figure 1)Heater sleeve welds on pressurizers with Alloy 600 material have been repaired by the industry using a similar "half-nozzle" technique.
The half-nozzle method has been used at the FPL's St. Lucie Unit 2 and many other CE designed NSSS plants.The portion of the original heater weld to the pressurizer was examined with a borescope.
An area of discoloration
-Y2" along the reinforcing fillet weld face was noted. However, no indication of cracking was identified in the discolored region or any other part of the weld that was viewed.The original heater sleeve remnant and weld will not receive any additional NDE. The new lower heater sleeve-to-lower head and heater/plug-to-lower heater sleeve pressure boundary welds, on the exterior surface of the pressurizer, were examined in accordance with the applicable requirements of the ASME Boiler and Pressure Vessel Code Sections III and Xl.BASIS FOR USE: Since the heater sleeve material and sleeve-to-clad weld are generally not susceptible to a stress corrosion mechanism in the pressurizer environment it is presumed that the L-2015-053 Attachment Page 4 of 8 TURKEY POINT UNIT 3 FIFTH INSERVICE INSPECTION INTERVAL RELIEF REQUEST No. 1, Rev. 1 weld flaw(s) was the result of an original fabrication flaw that propagated from service.Such service propagation could be a combination of thermal fatigue and/or SCC.There has been no leakage at any other pressurizer heater sleeve location at Turkey Point Unit 3 or Unit 4. A review of industry operating experience (OE) from the 48 US PWRs with similar stainless steel heater sleeves welded to the interior clad surface, representing greater than 3800 heater sleeves and 23-42 years of service, has not identified a leak at this location.
OE was identified at one US plant but the leak was at a location in the heater sleeve material outside of the pressurizer shell attributed to an anomaly in the tube adjacent to the weld. The greater than 3800 stainless steel pressurizer heater sleeves with 23-42 years of operating history represents greater than 100,000 sleeve years of service with occurrence of only this single leak in the weld. This provides evidence of the excellent service history as well as the evidence of the lack of a generic condition.
Further characterization of the weld by NDE was not practical as discussed below.Due to its location in the inside of the lower pressurizer head, the original heater sleeve-to-pressurizer clad partial penetration weld is extremely difficult to access from the pressurizer manway, through the heater support plates and heaters, to perform NDE. Also, if it was accessible, to fully characterize the flaw(s) causing leakage would require a volumetric examination method, such as an ultrasonic (UT) examination method. However, the weld configuration around the sleeve outer diameter precludes UT coupling and control of the sound beam needed to perform flaw characterization and sizing, with reasonable confidence, of the measured flaw dimensions.
If UT examination of the original partial penetration weld were attempted from the outside surface of the pressurizer lower head, the cladding interface would provide an acoustic mismatch that would severely limit this examination.
This UT examination would also encounter scanning interferences due to adjacent heaters as well as the required long examination distances (i.e., metal paths) for interrogation of radial-axial oriented flaws at the opposite (inside) surface. These conditions would make accurate detection, characterization, and sizing of flaw(s) problematic.
Currently, there is no qualified UT technique for examination of the original partial penetration weld or adjacent carbon steel pressurizer lower head material from either the inside or outside surface. Radiography of this area is also impractical because of the inability to position either a source or film inside the pressurizer.
Additionally, other NDE methods, such as liquid penetrant, magnetic particle, and eddy current would not provide useful volumetric information needed for flaw characterization.
The current inspection performed every refueling outage at Turkey Point Unit 3 is a VT-2 exam, meeting the NEI-03-08 recommended inspection guidance and frequency provided by the PWR Owners Group. This examination is performed with the L-2015-053 Attachment Page 5 of 8 TURKEY POINT UNIT 3 FIFTH INSERVICE INSPECTION INTERVAL RELIEF REQUEST No. 1, Rev. 1 insulation in place. The Turkey Point Unit 3 pressurizer lower head is insulated with glass or mineral fiber insulation.
At the time of the initial inspection the insulation configuration provided gaps around the leaking penetration and several other heater sleeve locations to permit examination of the base metal. A complete bare metal visual was performed at all 78 penetrations to determine the extent of condition.
Flaw Evaluation:
The effects of propagation of any flaw(s) that remain in the original heater sleeve weld, by fatigue crack growth and corrosion mechanisms, are considered.
Postulated worst case flaws are assessed for flaw growth. The flaw evaluation of the Turkey Point pressurizer heater sleeves was performed per ASME Section Xl, IWB-3600 for the remaining life of the plant and is presented in WCAP-17973-P (Enclosure 2). The evaluation concludes that the structural integrity of the pressurizer will not be adversely affected by postulated flaw(s) remaining in service for a period of twenty years which bounds the end of the current license.Maximum allowable end-of-evaluation period flaw sizes are determined in accordance with the methodology in IWB-3610 of the ASME Code for all operating conditions (normal/upset/test/emergency/faulted), as well as the primary stress limit of ASME Section III NB-3000, assuming local area reduction of the primary membrane.
The maximum allowable end-of-evaluation period flaw size is based on the most limiting (smallest) flaw size of all the calculated results (Section 4 of WCAP-17973-P).
Once the maximum allowable end-of-evaluation period flaw sizes are determined, a crack growth evaluation is performed using the applicable fatigue crack growth mechanisms and corrosion rates (Section 4.3 of WCAP-17973-P).
The flaw evaluation assumed a postulated flaw with a depth equal to the partial penetration weld and the cladding thickness, resulting in exposure of the carbon steel pressurizer head. The postulated flaw is then subjected to corrosion and all the applicable fatigue cycles pressure/thermal transients for the normal/upset/test conditions for the 60 year design life, concentrating them into 40 years of service life. The corrosion rate used for the initial evaluation was the same as that reported in WCAP-1 5973-P-A (ML050180528).
The results of the crack growth evaluation are compared to the maximum allowable end-of-evaluation period flaw size results (Section 4.4 of WCAP-1 7973-P) to show that the maximum allowable end-of-evaluation period flaw size will not be exceeded in the remaining service life. Therefore the postulated flaws will remain stable.An additional investigation was performed to determine the corrosion rate required to cause the postulated flaws to reach the maximum allowable end-of-evaluation period flaw size within 40 years. That limiting corrosion rate was shown to be approximately 5 times higher than the rate used (Section 5.0, WCAP-17973-P) in the crack growth analysis.
The review of the operating history at Turkey Point Unit 3 from the startup L-2015-053 Attachment Page 6 of 8 TURKEY POINT UNIT 3 FIFTH INSERVICE INSPECTION INTERVAL RELIEF REQUEST No. 1, Rev. 1 on 12-02-04 to 4-26-14 showed that the unit operated at slightly greater than 88%, including a >200 day planned refueling outage for extended power uprate modifications.
This operating history showed that the corrosion rates in WCAP-1 5973-P-A are appropriate.
The operating history will continue to be tracked and reevaluated at the next interval to show that the assumed corrosion rates and fracture mechanics results remain valid.A corrosion evaluation was also performed for the exposed carbon steel in the heater sleeve bore to determine the acceptable life of the repair weld that is on the outside surface of the pressurizer lower head. Although the corrosion in a tight crevice of a half nozzle repair is expected to stifle once filled with corrosion product (Section 2.5 of WCAP-15973-P-A, ML050180528), bulk water corrosion rates were conservatively considered for this evaluation.
Corrosion of the pressurizer lower head material would increase the diameter of the heater sleeve bore, decreasing the area of the effective weld and the reinforcement area around the hole. The maximum allowable hole diameter is calculated considering the reduction in the effective weld shear area and the required area of reinforcement based on Section III of the ASME Code. The results showed that the general corrosion would not increase the existing heater sleeve bore diameter of 1.299" or the 0.25" radius depth partial penetration weld to an unacceptable size (Section 4.3.1, WCAP-17973-P).
An additional investigation was performed to determine the maximum corrosion rate required to reach the maximum allowable hole diameter.
The rate determined to reach the maximum allowable hole diameter in 20 years was approximately 7 times the rate considered for normal operation in WCAP-1 5973-P-A.
The operating history will continue to be tracked and reevaluated at the next interval to show that the assumed corrosion rates and fracture mechanics results remain valid.In conclusion, the ASME B & PV Code Section Xl requirement, IWB-3142.3, is to correct a component containing a flaw(s). The proposed alternative is to relocate the pressure boundary weld to the outside surface of the pressurizer and not correct the item(s) containing the flaw(s). It has been determined Section Xl, IWB-3600 evaluation, that the material and the presence of the postulated worst case flaw(s) will not be detrimental to the pressure retaining function of the pressurizer for the remaining license life of the plant. The assessment summarized above and provided in the attached WCAP-1 7973-P concludes that the structural integrity for the Turkey Point Unit 3 pressurizer will not be adversely affected by postulated flaw(s) remaining in service for the remaining life of the plant. The corrosion rates in the WCAP-17973-P and the plant operating conditions will be reassessed as part of a new relief request for the next inspection interval.
L-2015-053 Attachment Page 7 of 8 TURKEY POINT UNIT 3 FIFTH INSERVICE INSPECTION INTERVAL RELIEF REQUEST No. 1, Rev. 1 6. Duration of Proposed Alternative Relief is requested for the current 5 th inspection interval for Turkey Point Unit 3 which expires on February 21, 2024.7. Precedents There are no known precedents for pressurizer stainless steel heater sleeve leakage requiring repair other than the FPL relief request previously submitted per letter L-2014-096.
The modified configuration is similar to various half-nozzle repairs performed by the industry for alloy 600 items that have experienced leakage that have typically been caused by primary water SCC. However, there is a precedent for evaluating flaw growth in carbon steel and low alloy steel base material due to fatigue that is exposed to reactor coolant in the pressurizer environment.
References to those NRC submittals for flaw evaluations with half nozzle repairs are as follows: "ATTACHMENT (6) UNIT 1 PRESSURIZER HEATER SLEEVE AS-LEFT J-GROOVE WELD FLAW EVALUATION FOR IDTB REPAIR -NON-PROPRIETARY," Calvert Cliffs Nuclear Power Plant, LLC May 11, 2011, NRC Accession ML11132A183."ST. LUCIE NUCLEAR PLANT, UNIT 2 -REGARDING REQUEST FOR RELIEF FROM THE REQUIREMENTS OF THE ASME CODE (TAC NO. MC9502)," May 26, 2006, NRC Accession ML061290056 0.11 Inches -Approximate A Between Upper Sleeve Rem Lower Replacement Heater L-2015-053 Attachment Page 8 of 8 TURKEY POINT UNIT 3 FIFTH INSERVICE INSPECTION INTERVAL RELIEF REQUEST No. 1, Rev. 1 Heater ,er Sleeve
' ////[ SS Clad, 2 layers, 3/8" SSa Wel (0e3%MadCwith IGap _.--lnant &Sleeve* SS Weld (0.03% Max C)SS Replacement Lower Sleeve (0.03% Max C)SS Weld (0.03% Max C Figure 1 Penetration
- 11 Final Configuration L-2015-053 Enclosure 3 Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-1 5-4110, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice
( ) Westinghouse U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Westinghouse Electric Company Engineering, Equipment and Major Projects 1000 Westinghouse Drive, Building 3 Cranberry Township, Pennsylvania 16066 USA Direct tel: Direct fax: e-mail: Proj letter.(412) 374-4643 (724) 940-8560 greshaja@westinghouse.com NEXT-15-21 CAW-15-4110 February 25, 2015 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
WCAP-17973-P, Revision 1, 'Turkey Point Units 3 and 4 Pressurizer Heater Sleeve Flaw Evaluation to Support Half-Nozzle Repairs" The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-15-4110 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 from 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 the utilization of the accompanying Affidavit by Florida Power and Light Company.Correspondence with respect to the proprietary aspects of the Application for Withholding or the Westinghouse Affidavit should reference CAW-15-41 10, and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 3 Suite 310, Cranberry Township, Pennsylvania 16066.Very truly yours, James A. Greshamn, Manager Regulatory Compliance CAW-15-4110 February 25, 2015 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF BUTLER: L Henry A. Sepp, am 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 my knowledge, information, and belief.HenryA. DepD ctor MCRE-Engineering Services 2 CAW-15-4110 (1) 1 am Director, MCRE-Engineering Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the 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 conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.
(3) I 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 regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.(i) The information sought to be withheld from 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 constitute Westinghouse policy and provide 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 result in the loss of an existing or potential competitive advantage, as follows: (a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.
3 CAW-15-41 10 (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 economic 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.(iii) 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 our expense.(d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage.
If competitors acquire components of proprietary information, any one component 4 CAW-15-41 10 may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.(e) Unrestricted 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.(iv) 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.(v) 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.(vi) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP-17973-P, Revision 1, "Turkey Point Units 3 and 4 Pressurizer Heater Sleeve Flaw Evaluation to Support Half-Nozzle Repairs" (Proprietary), for submittal to the Commission, being transmitted by Florida Power and Light Company letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with fracture mechanics technical justification to support continued operation for Turkey Points Units 3 and 4 with pressurizer heater sleeve half-nozzle repairs, and may be used only for that purpose.(a) This information is part of that which will enable Westinghouse to: (i) Provide fracture mechanics technical justification to support continued operation for Turkey Points Units 3 and 4 with pressurizer heater sleeve half-nozzle repairs.
5 CAW-15-41 10 (b) Further this information has substantial commercial value as follows: (i) Westinghouse plans to sell the use of similar information to its customers for the purpose of providing fracture mechanics technical justification to support operation of pressurizers with heater sleeve half-nozzle repairs.(ii) Westinghouse can sell support and defense of industry guidelines and acceptance criteria for plant-specific applications.(iii) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.
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 technical evaluation justifications and licensing defense services for commercial power reactors without 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 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.
PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and 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 subject 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.
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