ML19095A597

Submittal of Supplement to Subsequent License Renewal Application Change Notice 2

ML19095A597
Person / Time
Site:	Surry
Issue date:	04/02/2019
From:	Gerald Bichof Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML19095A666	List: ML19095A597 ML19095A600 ML19095A602 ML19095A605
References
19-096
Download: ML19095A597 (13)

Text

PROPRIETARY INFORMATION - WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 10CFR50 10CFR51 April 2, 2019 . 10 CFR 54 United States Nuclear Regulatory Commission Serial No.: 19-096 Attention: Document Control Desk NRA/DEA: RO Washington, D.C. 20555-0001 Docket Nos.: 50-280/281 License Nos.: DPR-32/37 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION (SPS) UNITS 1 AND 2 SUPPLEMENT TO SUBSEQUENT LICENSE RENEWAL APPLICATION CHANGE NOTICE 2 By letter dated October 15, 2018 (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML18291A842), Virginia Electric and Power Company (Dominion Energy Virginia) submitted an application for the subsequent license renewal of Renewed Facility Operating License Nos. DPR-32 and DPR-37 for the Surry Power Station.

The NRC has been conducting an in-office regulatory audit of the SPS Subsequent License Renewal Application (SLRA). The purpose of this letter is to provide additional information and clarifications to address NRC audit needs.

Change Notice 2 consists of the following five

Enclosures:

Enclosure 1: Provides a description of the forty-four topics that require a SLRA supplement and identifies the affected SLRA section. and/or table.

Enclosure 2: Includes mark-ups of affected SLRA sections being supplemented, as described in Enclosure 1. It should be noted that changes to ten commitments (Items #8, #16, #18, #25, #27, #28, #29, #31, #34 and #39) are reflected in Table A4.0-1.

Enclosure 3: Westinghouse Affidavit for Topical Report WCAP-15550-P, Technical Justification for Eliminating Large Primary Loop Pipe Rupture as the Structural Design Basis for Surry Units 1 and 2 Nuclear Power Plants for the Subsequent License Renewal Program (80 Years) Leak-Before-Break Evaluation, Revision 2 (proprietary)

Enclosure 4: Westinghouse Topical Report, WCAP-15550-P, Technical Justification for Eliminating Large Primary Loop Pipe Rupture as the Structural Design Basis for Surry Units 1 and 2 Nuclear Power Plants for the Subsequent License Renewal Program (80 Years)

Leak-Before-Break Evaluation, Revision 2 (Proprietary) A 5 Enclosure 5: Westinghouse Topical Report, WCAP-15550-NP, Technical rD 3 Justification for Eliminating Large Primary Loop Pipe Rupture as . J.i p the Structural Design Basis for Surry Units 1 and 2 Nuclear Power fVI",....__

Plants for the Subsequent License Renewal Program (80 Years)

Leak-Before-Break Evaluation, Revision 2 (Non-proprietary) contains information that is being withheld from public disclosure under 10 CFR 2.390.

Upon separation from Enclosure 4, this letter is decontrolled.

Serial No.: 19-096 Docket Nos.: 50-280/281 SLRA Supplement for In-Office Audit - Change Notice 2 Page 2 of 7 Since Enclosure 4 contains proprietary information, it is supported by an affidavit signed by the owner of the information (Enclosure 3). 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 10 CFR 2.390.

Accordingly, it is respectfully requested that the proprietary information be withheld from public disclosure in accordance with 10 CFR 2.390. A redacted, non-proprietary version is provided in Enclosure 5 as noted above.

If there are any questions regarding this submittal or if additional information is needed, please contact Mr. Paul Aitken at (804) 273-2818.

Sincerely,

~c?o!f-v Senior Vice President - Nuclear Operations and Fleet Performance COMMONWEALTH OF VIRGINIA COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Gerald T.

Bischof, who is Senior Vice President - Nuclear Operations and Fleet Performance of Virginia Electric and Power Company. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statemeats r, the doc,mem ,,. true to the bost of h* k ~ g ; " ' belief.

?lier' .

Acknowledged before me t h i s ~ day of r. ,2019.

5 - ,3 / -~,ii My Commission Expires:

/lid; X!lldL Notary Public Commitments made in this letter:

The Licensee Commitments identified in Table A4.0-1 of Appendix A, Final Safety Analysis Report Supplement, are proposed to support approval of the subsequent renewed operating licenses and may change during the NRC review period.

VICKI L. HULL NOTARY PUBLIC .

REG. # 140542 * :'"'

COMMONWEALTH OF.VIRGINIA ,11i-, , .. '

MY COMMISSLON EXPIRES 513112022

Serial No;: 19-096 Docket Nos.: 50-280/281 SLRA Supplement for In-Office Audit - Change Notice 2 Page 3 of 7

Enclosures:

- Topics That Require a SLRA Supplement - SLRA Mark-ups - Change Notice 2 - Affidavit for Withholding Topical Report WCAP-15550-P, Rev. 2 - Topical Report WCAP-15550-P, Rev. 2 - Topical Report WCAP-15550-NP, Rev. 2

Serial No.: 19-096 Docket Nos.: 50-280/281 SLRA Supplement for In-Office Audit - Change Notice 2 Page 4 of 7 cc: (w/o Enclosures except *)

U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Avenue, NE Suite 1200 Atlanta, Georgia 30303-1257 NRC Senior Resident Inspector Surry Power Station Mr. Emmanuel Sayoc

• NRC Project Manager U.S. Nuclear Regulatory Commission One White Flint North Mail Stop O 11 F1 11555 Rockville Pike Rockville, Maryland 20852-2738 Mr. Tam Tran

• NRC Project Manager U.S. Nuclear Regulatory Commission One White Flint North Mail Stop O 11 F1 11555 Rockville Pike Rockville, Maryland 20852-2738 Ms. Karen Cotton NRC Project Manager U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, Maryland 20852-2738 Mr. James R. Hall NRC Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 B 1-A 11555 Rockville Pike Rockville, Maryland 20852-2738

Serial No.: 19-096 Docket Nos.: 280/281 SLRA Supplement for In-Office Audit - Change Notice 2 Page 5 of 7 State Health Commissioner Virginia Department of Health James Madison Building - ?1h Floor 109 Governor Street Room 730 Richmond, Virginia 23219 Mr. David K. Paylor, Director Virginia Department of Environmental Quality P.O. Box 1105 Richmond, VA 23218 Ms. Melanie D. Davenport, Director Water Permitting Division Virginia Department of Environmental Quality P.O. Box 1105 Richmond, VA 23218 Ms. Bettina Rayfield, Manager Office of Environmental Impact Review Virginia Department of Environmental Quality P.O. Box 1105 Richmond, VA 23218 Mr. Michael Dowd, Director Air Division Virginia Department of Environmental Quality P.O. Box 1105 Richmond, VA 23218 Mr. Justin Williams, Director Division of Land Protection and Revitalization Virginia Department of Environmental Quality P.O. Box 1105 Richmond, VA 23218 Mr. James Golden, Regional Director Virginia Department of Environmental Quality Piedmont Regional Office 4949-A Cox Road Glen Allen, VA 23060 Mr. Craig R. Nicol, Regional Director Virginia Department of Environmental Quality Tidewater Regional Office 5636 Southern Blvd Virginia Beach, VA 23462

Serial No.: 19-096 Docket Nos.: 50-280/281 SLRA Supplement for In-Office Audit- Change*Notice 2 Page 6 of 7 Ms. Jewel Bronaugh, Commissioner Virginia Department of Agriculture & Consumer Services 102 Governor Street Richmond, Virginia 23219 Mr. Jason Bulluck, Director Virginia Department of Conservation & Recreation Virginia Natural Heritage Program 600 East Main Street, 24th Floor Richmond, VA 23219 Mr. Robert W. Duncan, Director Virginia Department of Game and Inland Fisheries P.O. Box 90778 Henrico, VA 23228 Mr. Allen Knapp, Director Virginia Department of Health Office of Environmental Health Services 109 Governor St, 5th Floor Richmond, VA 23129 Ms. Julie Lagan, Director Virginia Department of Historic Resources State Historic Preservation Office 2801 Kensington Ave Richmond, VA 23221 Mr. Steven G. Bowman, Commissioner Virginia Marine Resources Commission 2600 Washington Ave Newport News, VA 23607 Dr. Mary Fabrizio, Professor Virginia Institute of Marine Science School of Marine Science 7509 Roper Rd, Nunnally Hall 135 Gloucester Point, VA 23062 Ms. Angel Deem, Director Virginia Department of Transportation Environmental Division 1401 East Broad St Richmond, VA 23219 Mr. Stephen Moret, President Virginia Economic Development Partnership 901 East Byrd St Richmond, VA 23219

Serial No.: 19-096 Docket Nos.: 50-280/281 SLRA Supplement for In-Office Audit - Change Notice 2 Page 7 of 7 Mr. William F. Stephens, Director Virginia State Corporation Commission Division of Public Utility Regulation 1300 East Main St, 4th Fl, Tyler Bldg Richmond, VA 23219 Mr. Jeff Caldwell, Director Virginia Department of Emergency Management 10501 Trade Rd Richmond, VA 23236 Mr. Bruce Sterling, Chief Regional Coordinator Virginia Department of Emergency Management 1070 University Blvd Portsmouth, VA 23703 Mr. Sanford B. Wanner, Administrator Surry County 45 School Street Surry, VA 23883

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Enclosed is:

CAW-19-4879, which includes: the Affidavit, Proprietary Information Notice, Copyright Notice The enclosure contains information proprietary to Westinghouse Electric Company LLC

("Westinghouse"), 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 Nuclear Regulatory Commission ("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 listed above or the supporting Westinghouse Affidavit should reference CAW-19-4879 and should be addressed to Camille T. Zozula, Manager, Infrastructure & Facilities Licensing, Westinghouse Electric Company, 1000 Westinghouse Drive, Suite 165, Cranberry Township, Pennsylvania 16066.

Change Notice 2 Serial No.: 19-096 SPS SLRA Docket Nos.: 50-280/281 Enclosure 3 AFFIDAVIT FOR WITHHOLDING TOPICAL REPORT WCAP-15550-P, REV. 2 Virginia Electric and Power Company (Dominion Energy Virginia)

Surry Power Station Units 1 and 2

Westinghouse Non-Proprietary Class 3 CAW-19-4879 Page 1 of 3 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

COUNTY OF BUTL~R:

(1) I, Korey L. Hosack, have been specifically delegated and authorized to apply for withholding and execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse).

(2) I am requesting the proprietary portions of WCAP-15550-P, Rev. 2 be withheld from public disclosure under 10 CFR 2.390.

(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 10 CFR 2.390, 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 and is not customarily disclosed to the public.

(ii) 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.

Westinghouse Non-Proprietary Class 3 CAW-19-4879 Page 2 of 3 AFFIDAVIT (5) Westinghouse has policies in place to identify proprietary information. 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 lise by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(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 Westinghous.e 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.

(6) The attached documents are bracketed and marked to indicate the bases for withholding. The justification for withholding 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

Westinghouse Non-Proprietary Class 3 CAW-19-4879 Page 3 of 3 AFFIDAVIT lower case letters refer to the types of infonnation Westinghouse customarily holds in confidence identified in Sections (5)(a) through (f) of this Affidavit.

I declare that the averments of fact set forth in this Affidavit are true and correct to the best of my a

knowledge, information, and belief.

I declare under penalty of perjury that the furegoing is

• Executed on:/rO/ '7 0 3/0 _ .~

Korey L. Josack, Manager Product Line Regulatory Support

PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and non-proprietary versions of a document, 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 propriet_ary 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).

Th~ 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 CPR 2.390(b)(l).

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. 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.