ML20204D921

Proposed Tech Specs Re OTSG Tubes Surveillance Program,Tube Repair Roll Process

ML20204D921
Person / Time
Site:	Crystal River
Issue date:	03/18/1999
From:	FLORIDA POWER CORP.
To:
Shared Package
ML20137D077	List: 3F0399-01, Rev 1 to LAR 235 to License DPR-72,proposing Repair Roll Process for CR-3 OTSG tubes.Non-proprietary Rev 1 to BAW-2342 & Proprietary Rev 1 to BAW-2342P Repts Encl. Proprietary Rept Withheld,Per 10CFR2.790(b)(4) ML20204D921 ML20204D966
References
NUDOCS 9903240310
Download: ML20204D921 (23)

Text

... _

FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3 i

DOCKET NUMBER 50-302/ LICENSE NUMBER DPR-72 I

e ATTACHMENT B i

LICENSE AMENDMENT REQ'UEST #235, REVISION 1 ONCE THROUGH STEAM GENERATOR TUBE SURVEILLANCE

~

i PROGRAM, TUBE REPAIR ROLL PROCESS Proposed Technical Specification Change Pages t

(Strikeout / Shaded)

I l

i G

9903240310 990318

~~

PDR ADOCK 05000302 P

pop j

l

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Procedures, Programs and Manuals 5.6 5.6 Procedures, Programs and Manuals 5.6.2.10 OTSG Tube Surveillance Program (continued) 4.

Acceptance criteria:

a.

Vocabulary as used in this Specification:

1.

Tubing or Tube means that portion of the tube or sleeve which forms the primary system to secondary system pressure boundary.

2.

Imperfection means an exception to the dimensions, finish or contour of a tube from that required by fabrication drawings or specifications.

Eddy-current testing indications below 20% of the nominal tube all thickness, if detectable, may be considered as imperfections.

3.

Degradation means a service-induced cracking, wastage, wear, or general corrosion occurring on either inside or outside of a tube.

4.

Degraded Tube means a tube containing imperfections iiiifs'ditish 2 20% of the acminal wall thickness caused by degradatica except where all such degradation nr. been 3-tnsttMaticaofasleevethF6sgN:anned-by-th irs 11NWi 5.

% DegradationIK"ThF6sgN~~saTl means the percentage of the tube bhaksureiboundaF9) wall thickness affected or removed by degradation.

6.

Defect 19 Bills means an imperfectica of such sevefity that it exceeds the plugging / sleeving limit except where the imperfection has been spanned by the installation of a sleeve. A 5 tube containing a defect in its didEidati6TGE40%

}lliliriliiIgfdsaHHEib'e pressure boundary is defective. Any tube which does not permit the passage of the eddy-current inspection probe shall be deemed a defective tube.

7.

Pit-like Intergranular Attack (ICA) indication means a bobbin coil indication confirmed by Motorized Rotating Pancake Coil (MRPC) or other qualified inspection techniques to have a volumetric, pit-like morphology characteristic of IGA.

(continued)

Crystal River Unit 3 5.0-16 Amendment No.1-56

Procedures, Programs and Manuals 5.6 5.6-Procedures, Programs and Manuals 5.6.2.10 OTSG Tube Surveillance Program (continued) 8.

Plugging / Sleeving lt565% Limit means the extent of iirissdre3tisiEilsFW degradation beyond which the tube shall b90erj be resteres to serviceabiMty-by the installatica cf a sleeve er removed from service because it may beceme unserviceable prior tc the next inspection and is equal to 40% cf the acminal tsbe ci sleeve Wall thickness 6 75sti1Til

~~T45th'eliiifei'!bfJdegisdaM66 shiU$$

j icef(afnew[pressufs boundifyi.

-=-._j nglanhA fagespaih;pprovedfRepaM Techni g.j

~

11mit31sijo%

'hrc~

$ntel boundary t

1. e gt M[.o Ne mere than five thessend-sheves d

may be installed in each OTSC.

9.

Unserviceable describes the condition of a tube if it leaks or contains a defect large enough to 1

affect its structural integrity in the event of an Operating Basis Earthquake, a loss-of-coolEnt accident, or a main steam line or feedwater line break, as specified in 5.6.2.10.3.c, above.

10.

Tube Inspection means an inspection of the entwe OTSG tube as far as pessible 5Fe~'sifiilb6UhdsF9 s

,siiaEis?Y5Eiiiclis%issEoiEsF 1GAiiiir~isid ithansp1 "*

' b_ap> 1Deenfacceptedi byktheiteltClis 4

y

,g hessui 'D isidflf3

_pst$'

yi aFo notate App

,t EXIEE iiiTa&diddiiii6iiiiiFith'tEi Ydnscribedife; report aseelthanifiveDthossand ta11edminreactCOT5G2 SE TUr511saEftisiRWiiief

1. 9"N'with7the Framatomii ated#prAcesses?(or t_

!$]h ligg $

in;raphrysteAW-2303g W,

imay;bel peci%jeher:: single gerocessg(e Es rmed?once p? ? g "Qo11Xarea4111[be eC

. rrent meth6dsffol16iiEg

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$ sis f$

frspai$rollfeust?belfreti ofh C T e s d 0andidegFadationiforZthe Espahltis2besseMidadediacceptabl e J (continued)

Crystal River Unit 3 5.0-17 Amendment No. 169

Procedures, Programs and Manuals 5.6 1

5.6 Procedures, Programs and Manuals 5IQ303MOTSG%TsSsISUF/4111sWEelpfsgram nER6Wii ssed)

TKdFepilhTFoll3ihisichitu6e"iirllW63 Iinsp5cted (du rj nd;each l subsequentWinsshWEs

$ n pectioA;shileithe dubetwith7 nepairitoll a

KM n iserv'i ceV UThe? repai r2 roll ? willi lui coAsidered ) a (specifi c311mited PEpsauand (iiiill Irtedit[will{beja; th'ehahdom {deplinj @iniG W e dludedsfrom' Nd knn[fodmeetingsthelm

'1iasplejize?

KfyfilisiF95to-sec6iidai9513akijEi@T nietermined ;? the? pl antj and Lthe/c Shutdowntof l

toibeldegradationhnfanpaYi:

%11Fi100K?ofdtheirepefrdoll'siinhhatiQTSG shallybeisxaminedM:IfMhat%1nspsEtion

'resu150 i ni entering?Categor9/CV2for;CMf67 ispecific n imitediacea!inspectidnKas?detailid iln iTablel 5 s 6i213 M;100%s ofNthe a rapii ricolli hallitielexaminedlinIthelother10TSC b.

The OTSG shall be determined OPERABLE after completing the corresponding actions (plug or s4eeve FsEEH all tubes exceeding the plugging /sleevtng fi5s k limit and all tubes containing through-wall cracks) required by Table 5.6.2-2 (and Table 5.6.2-3 if the provisions of Specification 5.6.2.10.2.d are utilized).

Defective tubes may be repaired in accordance with the SaW process (cc-methcd) equivalent-to-the-method described in report 0AW-2120P.-

There are a number of OTSG tubes that have the potential to exceed the tube plugging /slesving Fe~ pig limit as a result of tube end anomalies. Defective tubes will be repaired or plugged during the next outage of sufficient duration. An evaluation has been performed which confirms that operability of the CR-3 OTSGs will not be impacted with those tubes iniservice.

5.6.2.11 Secondary Water Chemistry Program This program provides controls for monitoring secondary water chemistry to inhibit steam generator tube degradation and low pressure turbine disc stress corrosion cracking. The program shall include:

a.

Identification of a sampling schedule for the critical variables and control pints for these variables; b.

Identification of the procedures used to measure the values of the critical variables; (continued)

Crystal River Unit 3 5!0s17A Amendment No.

Procedures, Programs and Manuals 5.6 TABLE 5.6.2-2 (page 1 of 1)

OTSG TUBE INSPECTION 1st Sample Inspection 2nd Sample Inspection 3rd Sample Inspection Sample Size Result Action Result Action Result Action Required Required Required I

A minimum of C-1 None N/A N/A N/A N/A 5 tubes per OTSG C-2 Plug or C-1 None N/A N/A Meeve MWilN defective C-2 Plug or C-1 None tubes and Meeve inspect an repMt additional defective C-2 Plug or-25 tubes in tubes and Meeve this OTSG.

inspect WeMM additional defective 45 tubes in

tubes, this OTSG.

C-3 Perform action for C-3 result of first sample.

i f

1 a

1 C-3 Perform N/A N/A action for C-3 result of first j

sample.

1 C-3

-Inspect all All other None N/A N/A tubes in OPSGs are this OTSG, C-1 plug or Meeve W

Some OTSGs Perform N/A N/A defective C-2 but no action for

tubes, additional C-2 result inspect 25 OTSCs are of second tubes in C-3

sample, each other OTSG, and notify NRC Additional Inspect all N/A N/A per OTSG is C-3 tubes in 10CFR50.72 each OTSG, plug or Meeve i

repsif defective i

tubes, and notify NRC per 10CFR50.72.

S = 3 N/n %

Where N is the number of OTSGs in the unit end n is the number of OTSGs inspected during inspection period.

4 i

i i

Crystal River Unit 3 5.0-25 Amendment No. 149

Procedures, Programs and Manuals 5.6-TABLE 5.6.2-3 '(page 1 of 1)

SPECIFIC LIMITED AREA INSPECTION 1st Sample Inspection of a 2nd Sample Inspection of a

" Specific Limited Area"

" Specific Limited Area" l

Sample Size Result Action Result Action Required Required 100% of area C-1 None N/A N/A in both OTSGs C-2 Plug or N/A N/A M eeve bpiid defective tubes.

C-3 Plug or N/A N/A Meeve Niiff defective tubes.

l 100% of area C-1 None N/A N/A l

in one OTSG C-2 Plug or C-1 None Meeve#4 pill defective tubes and C-2 Plug or inspect 100%

Meeve heiitE of defective correspond-tubes.

ing area in other OTSG C-3 Plug or t

Meeve M.

defective tubes.

l C-3 Plug or C-1 None I

sleeve Meis4f defective tubes and C-2 Plug or inspect 100%

M eeve M5Bli of defective correspond-tubes.

ing area in other OTSG.

C-3 Plug or sleeve MpisfE i

defective tubes.

I l

'i f

i Crystal River Unit 3 5.0-26 Amendment No. -149

Reporting Requirements 5.7 5.7 Reporting Requirements 5.7.2 Special Reports (continued)

The following Special Reports shall be submitted:

a.

When a Special Report is required by Condition B or F of LCO 3.3.17 " Post Accident Monitoring (PAM)

Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

b.

Any abnormal degradation of the containment structure detected during the tests required by the Containment Tendon Surveillance Program shall be reported to the NRC within 30 days. The report shall include a description of the i

tendon condition, the condition of the concrete (especially at tendon anchorages), the inspection procedures, the i

tolerances on cracking, and the corrective action taken.

c.

Following each inservice inspection of steam generator (OTSG) tubes, the NRC shall be notified of the following prior to ascension into MODE 4:

1.

Number of tubes plugged and sheved EipiiFid}

2.

Crack-like indications EiidIisTesikeist7oCUFf6Wthlf66 3iidilidiH6hl in the first span?

3.

An-assessment c,f growth in the first span indicationsT and 4--Results of in-situ pressure testing, if performed.

d'.UQiihl tsT6EOTKilidiMiiisEWoi5?sccordancetwith 30 Celt 50,223thi ffillB sha111bettepotteditolthMClini R

The complete results of the OTSG tube inservice inspection shall be submitted to the NRC within 90 days following the completion of the inspection. The report shall include:

1.

Number and extent of tubes inspected, l

i 2.

Location and percent of wall-thickness penetration for i

each indication of an imperfection, 3.

Location, bobbin coil amplitude, and axial and circumferential extent (if determined) for each first span ICA indication, and FisiffiiDi6dfi~peifffiiafionM,gged and-tubes sleeved by Identification of tubes plu 4.

Zth's]FepiiEfineth'6d616gy 3mplementeddotieschitubel (continued)

Crystal River Unit 3 5.0-29 Amendment No. 156

Reporting R:quiremsnts 5.7 5.7 Reporting Requirements

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i Crystal River Unit 3 6:0-29A Amendment Noe ISS

. -. =.. -. _. - -. -. -.

FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302/ LICENSE NUMBER DPR-72 t

ATTACHMENT C LICENSE AMENDMENT REQUEST #235, REVISION 1 ONCE THROUGH STEAM GENERATOR TUBE SURVEILLANCE PROGRAM, TUBE REPAIR ROLL PROCESS Proposed Technical Specification Change Pages (Revision Bars) 4

Procedures, Programs and Manuals 5.6 5.6 Procedures, Programs and Manuals -

l l

5.6.2.10 OTSG Tube Surveillance Program (continued) 4.

Acceptance criteria:

a.

Vocabulary as used in this Specification:

1.

Tubing or Tuoe mcans that portion of the tube or sletve which forms the primary system to secondary system pressure boundary.

2.

Imperfection means an exception to the dimensions, i

finish or contour of a tube from that required by l

fabrication drawings or specifications.

Eddy-current testing indications below 20% of the nominal tube wall thickness, if detectable, may be considered as imperfections.

3.

Degradation means a service-induced cracking, wastage, wear, or general corrosion occurring on i

either inside or outside of a tube.

4.

Degraded Tube means a tube containing degradation 2 20% through-wall but < 40% through-wall in the pressure boundary.

5.

% Degradation /% Through-wall means the percentage of the tube (pressure boundary) wall thickness affected or removed by degradation.

6.

Defective Tube means a tube containing degradation 2 40% through-wall in the pressure boundary. Any tube which does not permit the passage of the eddy-current inspection probe shall be deemed a defective tube.

4 7.

Pit-like Intergranular Attack (IGA) indication means a bobbin coil indication confirmed by Motorized Rotating Pancake Coil (MRPC) or other qualified inspection techniques to have a volumetric, pit-like morphology characteristic of IGA.

(continued)

Crystal River Unit 3 5.0-16 Amendment No.

l

-..-. ~ ~.

..~ - -.

Procedures, Programs and Manuals 5.6 l

5.6 Procedures, Programs and Manuals 5.6.2.10 OTSG Tube Surveillance Program (continued) i 8.

Plugging / Repair Limit means the extent of pressure boundary degradation beyond which the tube shall either be removed from service by installation of plugs or the area of degradation shall be removed from service (a new pressure boundary established) using an Approved Repair Technique. The plugging / repair limit is 40% through-wall for all pressure boundary degradation.

9.

Unserviceable describes the condition of a tube if it leaks or contains a defect large enough to affect its structural integrity in the event of an Operating Basis Earthquake, a loss-of-coolant accident, or a main steam line or feedwater line break, as specified in 5.6.2.10.3.c, above.

10.

Tube Inspection means an inspection of the OTSG tube pressure boundary.

11.

Approved Repair Technique means a technique, other than plugging, that has been accepted by the NRC as a methodology to remove or repair degraded or defective portions of the pressure boundary and to establish a new pressure boundary. Following are Approved Repair Techniques:

a)

Sleeve installation in accordance with the B&W process (or method) described in report BAW-2120P. No more than five thousand sleeves may be installed in each OTSG.

J b)

Installation of repair rolls in the upper tubesheet in accordance with the Framatome Technologies Incorporated processes (or i

methods) described in reports BAW-2303P and BAW-2342P. The repair process (either single roll or double roll) may be performed once per tube. The repair roll area will be examined using eddy-current methods following installation. The repair roll must be free of imperfections and degradation for the repair to be considered acceptable.

(continued)

Crystal. River Unit 3 5.0-17 Amendment No.

l 3

Procedures, Programs and Manuals 5.6 5.6 Procedures, Programs and Manuals 5.6.2.10 OTSG Tube Surveillance Program (continued) l The repair roll in each tube will be inspected during each subsequent inservice inspection while the tube with a repair roll is in service. The repair roll will be considered a specific limited area and will be excluded from the random sampling. No credit will be taken for meetirg the minimum sample size.

If primary-to-secondary leakage results in a shutdown of the plant and the cause is determined to be degradation in a repair roll,100% of the repair rolls in that OTSG shall be examined. If that inspection results in entering Category C-2 or C-3 for specific limited area inspection, as detailed in Table 5.6.2-3, 100% of the repair rolls shall be examined in the other OTSG.

b.

The OTSG shall be determined OPERABLE after completing the corresponding actions (plug or repair all tubes exceeding the plugging / repair limit) required by Table 5.6.2-2 (and Table 5.6.2-3 if the provisions of Specification 5.6.2.10.2.d are utilized).

l There are a number of OTSG tubes that have the potential to exceed the tube plugging / repair limit as a l result of tube end anomalies.

Defective tubes will be repaired or pluggec; during the next outage of sufficient duration. An evaluation has been performed which confirms that operability of the CR-3 OTSGs will not be impacted with those tubes in service.

l 5.6.2.11 Secondary Water Chemistry Program This program provides controls for monitoring secondary water chemistry to inhibit steam generator tube degradation and low pressure turbine disc stress corrosion cracking. The program shall include:

a.

Identification of a sampling schedule for the critical variables and control pints for these variables; b.

Identification of the procedures used to measure the values of the critical variables; (continued)

Crystal River Unit 3 5.0-17A Amendment No.

l J

Procedures, Programs and Manuals 5.6 TABLE 5.6.2-2 (page 1 of 1)

OTSG TUBE INSPECTION 1st Sample Inspection 2nd Sample Inspection 3rd Sample Inspection Sample Size Resul t Action Result Action Result Action Required Required Required A minimum of C-1 None N/A N/A N/A N/A 5 tubes per OTSG C-2 Plug or C-1 None N/A N/A repair l

defective tubes and C-2 Plug or C-1 None inspect an repair j

additional defactive 25 tubes in tubes and C-2 Plug or this OTSG.

inspect repair l

additional defective 45 tubes in

tubes, this OTSG.

C-3 Perform action for C-3 result of first sample.

C-3 Perform N/A N/A action for C-3 result of first sample.

C-3 Inspect all All other None N/A N/A tubes in OTSGs are J

this CTt' C-1 plug o l

repair l

defective Some OTSGs Perform N/A N/A

tubes, C-2 but no action for inspect 25 additi(nal C-2 result tubes in OTSGs are of second each other C-3 sample.

OTSG, and notify NRC per Additional Inspect all N/A N/A 10CFR50.72 OTSG is C-3 tubes in each OTSG, plug or repair l

defective tubes, and notify NRC

)

per 10CFR50.72.

I S = 3 N/n %

Where N is the number of OTSGs in the unit and n is the number of OTSGs inspected during inspection period.

i l

l l

Crystal _ River Unit 3 S.0-25 Amendment No.

l

~ _ _.

~_. -._.

l Procedures, Programs and Manuals 5.6 i

(

TABLE 5.6.2-3 (page 1 of 1)

SPECIFIC LIMITED AREA INSPECTION ist Sample Inspection of a 2nd Sample Inspection of a

" Specific Limited Area"

" Specific Limited Area" Sample Size Result Action Result Action Required Required 100% of area C-1 None N/A N/A i

I in both OTSGs C-2 Plug or N/A N/A repair l

defective tubes.

C-3 Plug or N/A N/A repair I

defective tubes.

100% of area C-1 None N/A N/A in one OTSG C-2 C-1 None repair l

defective tubes and C-2 Plug or inspect 100%

repair l

defective corres nding tubes.

area in other OTSG C-3 Plug or repair l

defective tubes.

C-3 C-1 None repair j

defective tubes and C-2 Plug or inspect 100%

repair l

defective corres nding tubes.

area in other

OTSG, C-3 Fiug or eepair l

defective tubes.

i t

i Crystal River Unit 3 5.0-26 Amendment No.

l

.--~ _...--_--__- _- -

. ~....... -

Reporting Requiremtnts 5.7 i

3 5.7 Reporting Requirements j

5.7.2 Special Reports (continued) i

-The following Special Reports shall be submitted:

j.

.a.

When a Special Report is required by Condition B or F of LCO 3.3.17 " Post Accident Monitoring (PAM)

Instrumentation," a report shall be submitted within the 4

i following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability,. and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

b.

Any abnormal degradation of the containment structure detected during the tests required by the Containment Tendon Survefilance Program shall be reported to the NRC within 30 days. The report shall include a description of the i

tendon condition, the condition of the concrete (especially i

at tendon anchorages), the inspection procedures, the i

tolerances on cracking, and the corrective action taken.

c.

Following each inservice inspection of steam generator (OTSG) tubes, the NRC shall be notified of the following 4

prior to ascension into MODE 4:

1.

Number of tubes plugged and repaired, l

2.

Crack-like indications and assessment of growth for a

indications in the first span, 3.

Results of in-situ pressure testing, if performed.

l d.

Results of OTSG tube inspections that fall into Category C-3 shall be reported to the NRC in accordance with 10CFR50.72.

1 l

4 e.

The complete results of the OTSG tube inservice inspection shall be submitted to the NRC within 90 days following the completion of the inspection. The report shall include:

1.

Number and extent of tubes inspected, i

2.

Location and percent of wall-thickness penetration for each indication of an imperfection, 3.

. Location, bobbin. coil amplitude, and axial and i '

circumferential extent (if determined) for each first span IGA indication, and 4.

Identification of tubes plugged or repaired and specification of the repair metnodology implemented for each tube.

(continued)

-Crystal ~ River Unit 3 5.0-29 Amendment No.

l

- - -. _ = -

FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3 d

DOCKET NUMBER 50-302/ LICENSE NUMBER DPR-72 ATTACHMENT D LICENSE AMENDMENT REQUEST #235, REVISION 1 ONCE THROUGH STEAM GENERATOR TUBE SURVEILLANCE PROGRAM, TUBE REPAIR ROLL PROCESS FTI Proprietary Version, BAW-2342P, Revision 0 "OTSG Repair Holl Qualification Report, Addendum A" n

~. _._

AFFIDAVIT OF JOSEPH J. KELLX A.

My name is Joseph J. Kelly. I am Manager of B&W Owners Group Services for Framatome Technologies, Inc. (FTI), and as such, I am authorized to execute this Affidavit.

B.

I am familiar with the criteria applied by FTI to determine whether certain information of FTI is proprietary and I am familiar with the procedures established within FTI to ensure the

. proper application of these criteria.

)

C.

In determining whether an FTI document is to be classified as proprietary information, an initial determinati in is made by the Unit Manager, who is responsible for originating the document, as to whether it falls within the c:iteria set forth in Paragraph D hereof. If the information falls within any one of these criteria, it is classified as proprietary by the originating Unit Manager. This initial determination is reviewed by the cognizant Section Manager. If the document is designated as proprietag, it is reviewed again by me to assure that the regulatory requirements of 10 CFR Section 2.790 are met.

D.

The following information is provided to demonstrate that the provisions of 10 CFR Section 2.790 of the Commission's regulations have been considered:

)

(i)

The information has been held in confidence by FTI. Copies of the document are clearly identified as proprietary. 'In addition, whenever FTI transmits the l

information to a customer, customer's agent, potential customer or regulatory agency, the transmittal requests the recipient to hold the information as i

l proprietary. Also, in order to strictly limit any potential or actual customer's use L

of proprietary information, the substance of the following provision is included in all agreements entered into by ETI, and an equivalent version of the proprietary provision is included in all of FTI's proposals:

l l

l l

i AFFIDAVIT OF JOSEPH J. KELLY (Cont'd.)

"Any proprietary information concerning Company's or its Supplier's products or manufacturing processes which is so designated by Company or its Suppliers and disclosed to Purchaser incident to the performance of such contract shall remain the property of Company or its Suppliers and is disclosed in confidence, and Purchaser shall not publish or otherwise disclose it to others without the written approval of Compt.ny, and no rights, implied or otherwise, ere granted to produce or have produced any products or to practice or cause to be practiced any manufacturing processes covered thereby.

Notwithstanding the above, Purchaser may provide the NRC or any other regulatory agency with any such proprietary information as the NRC or such other agency may require; provided, however, that Purchaser shall first give Company written notice of such proposed disclosure and Company shall have the right to amend such proprietary information so as to make it non-proprietary. In the event that Company cannot amend such proprietary information, Purchaser shall prior to disclosing such information, use its best efforts to obtain a commitment from NRC or such other agency to have such information withheld from public inspection.

Company shall be given the right to participate in pursuit of such confidential treatment."

l L'

2

l' l

l

's r

l AFFIDAVIT OF JOSEPH J. KELLY (Cont'd.)

l (ii)

The following criteria are customarily applied by Ffl in a rational decision process to determine whether the information.should be classified as proprietary.

Information may be classified as proprietary if one or more of the following criteria are met:

a.

Information reveals cost or price information, commercial strategies, production capabilities, or budget levels of FTI, its customers or suppliers.

l b.

The information reveals data or material concerning FTI research or l

development plans or programs of present or potential competitive advantage to FTI.

l l

c.

The use of the information by a competitor would decrease his expenditures, in time or resources, in designing, producing or marketing a similar product.

l d.

The information consists of test data or other similar data concerning a i.

process, method or component, the application of which results in a

. competitive advantage to FTI.

l e.

The information reveals special aspects of a process, method, component l

l or the like, the exclusive use of which results in a competitive advantage l

l to FTI.

i f.

The information contains ideas for which patent protection may be sought.

i i

{

t I-3

AFFIDAVIT OF JOSEPH J. KELLY (Cont'd.)

. The document (s) listed on Exhibit "A", which is attached hereto and made a part hereof, has been evaluated in accordance with normal FTI procedures with respect to classification and has been found to contain information which falls within one or more of the criteria enumerated above. Exhibit "B", which is attached hereto

~

and made a part hereof, specifically identifies the criteria applicable to the document (s) listed in Exhibit "A".

(iii)

The document (s) listed in Exhibit "A", which has been made available to the United States Nuclear Regulatory Commission was made available in confidence with a request that the document (s) and the information contained therein be withheld from public disclosure.

(iv)

The information is not available in the open literature and to the best of our knowledge is not known by Combustion Engineering, EXXON, General Electric, Westinghouse or other current or potential domestic or foreign competitors of FTI.

(v)

Specific information with regard to whether public disclosure of the information is likely to cause harm to the competitive position of FTI, taking into account the value of the information to FTI; the amount of effort or money expended by FTI developing the information; and the case or difficulty with which the information could be properly duplicated by others is given in Exhibit "B".

E.

I have personally reviewed the document (s) listed on Exhibit "A" and have found that it is considered proprietary by FTI because it contains information which falls within one or more

- of the criteria enumerated in Paragraph D, and it is information which is customarily held in confidence and protected as proprietary information by FTI. This report comprises 4

_ - _. _ _ _ _ _ _ _ _ _ _ ~

c-,

AFFIDAVIT OF JOSEPH J. KELLY (Cont'd.)

Information utilized by FTI in its business which afford FTI an opportunity to obtain a competitive advantage over those who may wish to know or use the information contained in the document (s).

) n,CV J

PF LY State o Virginia) r

)

SS. Lynchburg City of Lynchburg)

Joseph J. Kelly, being duly swom, on his oath deposes and says that he is the person who subscribed his name to the foregoing statement, and that the matters and facts set forth in the statement are true.

\\

J S iPH Jh L Subscribed and sworn before me l7& ey of hcl 1999.

this d

ud b, w

Notary Public in and for the City of Lynchburg, State of Virginia.

My Commission Expires Ouly 3/,19??

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a i c

\\.-

-EXHIBITS A & B j

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l EXHIBIT A i

l FTI's Topical Report BAW-2342P, Revision 1, "OTSG Repair Roll Qualification Report, Addendum A," dated March 1999.

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l EXHIBIT B The above listed document contains information which is considered Proprietary in accordance with Criteria b, c, and d of the attached aflidavit.

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l FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302/ LICENSE NUMBER DPR-72 l

ATTACHMENT E l

i LICENSE AMENDMENT REQUEST #235, REVISION 1 ONCE THROUGH STEAM GENERATOR TUBE SURVEILLANCE l

PROGRAM, TUBE REPAIR ROLL PROCESS FTI Non-Proprietary Version, BAW-2342, Revision 0 l

l "OTSG Repair Roll Qualification Report, Addendum A" i

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