Text

Actions Concerning License Renewal Commitments 41 and 42 in Response to LR-ISG-2016-01, Changes to Aging Management Guidance for Various Steam Generator Components.
	ML17023A209
Person / Time
Site:	Indian Point
Issue date:	01/17/2017
From:	Vitale A; Entergy Nuclear Northeast
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NL-17-005
	Download: ML17023A209 (58)
	v • d • e

.-===*Entergy; Entergy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel (914) 254-6700 Anthony J Vitale Site Vice President NL-17-005 January 17, 2017 U.S. Nuclear Regulatory Commission Document Control Desk 11545 Rockville Pike, TWFN-2 F1 Rockville, MD 20852-2738

SUBJECT:

Entergy Actions Concerning License Renewal Commitments 41 and 42 in Response to LR-ISG-2016-01, "Changes to Aging Management Guidance for Various Steam Generator Components" Indian Point Nuclear Generating Unit Nos. 2 and 3 Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64

REFERENCES:

1) LR-ISG-2016-01, "Changes to Aging Management Guidance for Various Steam Generator Components" (Nov. 30, 2016) (MU 6237 A383)

2) NUREG-1930, Supp. 1, "Safety Evaluation Report Related to the License Renewal of Indian Point Nuclear Generating Units 2 and 3" (Aug. 2011)

3) NRC Letter, "Request for Additional Information for the Review of the Indian Point Nuclear Generating Unit Numbers 2 and 3 License Renewal Application" (Feb. 10, 2011) (ML110190809)

4) Entergy letter NL-11-032, "Response to Request for Additional Information (RAI) Aging Management Programs" (Mar. 28, 2011) (ML12334A665) .

5) Entergy letter NL-11-074, "Response to Request for Additional Information (RAI) Aging Management Programs" (July 14, 2011) (ML12334A671)

6) Entergy letter NL-11-090, "Clarification for Request for Additional Information (RAI) Aging Management Programs" (July 27, 2011) (ML12334A674)

7) EPRI 3002002850, "Steam Generator Management Program: Investigation of Crack Initiation and Propagation in the Steam Generator Channel Head Assembly" (Oct. 2014)

8) EPRI Information Letter SGMP-IL-16-02, "Changes to Aging Management Guidance for Steam Generator Channel Head Components" (Oct. 2016)

Dear Sir or Madam:

The purpose of this letter is to inform the Nuclear Regulatory Commission (NRC ) Staff that based on the guidance contained in LR-ISG-2016-01, "Changes to Aging Management Guidance for Various Steam Generator Components" (December 2016) (Reference 1}, Entergy has taken certain actions with respect to License Renewal Commitments 41 and 42. Specifically, Entergy has determined that the industry analyses referenced in LR-ISG-2016-01 are bounding for the

,....-.

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NL-17-005 Dockets 50-247 and 50-286 Page 2 of 7 Indian Point Unit 2 (IP2) and Unit'3 (IP3) steam generator divider plate assemblies and tube-to-tubesheet welds, such that Entergy may manage the aging effect of primary water stress corrosion cracking (PWSCC) in those steam generator components in accordance with the new guidance contained in LR-ISG-2016-01. Accordingly, Entergy has eliminated License Renewal Commitment 41 because it is no longer necessary, and has closed License Renewal Commitment 42 by virtue of having satisfied Option 1 (Analysis) of that commitment.

Entergy is notifying the Staff of these actions because the Staff discussed and credited Commitments 41 and 42 in Supplement 1 to its Safety Evaluation Report (SSER 1) (Reference 2),

which was issued in August 2011, about five years before the issuance of LR-ISG-2016-01.

Additional background and explanation concerning Entergy's actions relative to Commitments 41 and 42 are provided below and in Attachment 1, "Indian Point Units 2 and 3 - Technical Justification for Elimination of License Renewal Commitment 41 Regarding Steam Generator Divider Plate Assemblies and Closure of Commitment 42 Regarding Tube-to-Tubesheet Welds Based On Analysis Option."

Background Concerning License Renewal Commitments 41 and 42 On February 10, 2011, in response to certain foreign operating experience, the NRC Staff issued a request for additional information (RAI) (Reference 3) in which it asked Entergy to describe the materials of construction of the IP2 and IP3 steam generator divider plate assemblies and the associated welds. The Staff further requested that, if any of the material was susceptible to PWSCC (i.e., Alloy 600 and associated weld materials), Entergy explain how it plans to manage PWSCC to prevent the potential propagation of cracks into items that are part of the reactor coolant system (RCS) pressure boundary.

Entergy responded to the Staff's RAI on March 28, 2011 (Reference 4), and later amended its response by letters dated July 14, 2011 (Reference 5) and July 27, 2011 (Reference 6). Entergy explained that the IP2 and IP3 divider plates are Alloy 600, and that it conservatively assumed that the associated weld metals (i.e., Alloy 182/82) were used in the welding process. Entergy also clarified that the IP2 original Westinghouse Model 44 steam generators were replaced with Model 44F units in 2000, and that the IP3 original Westinghouse Model 44 steam generators were replaced with Model 44F units in 1989.

Entergy further noted that the industry had begun to study divider plate crack growth and develop a resolution to the issue through the EPRI Steam Generator Management Program (SGMP)

Engineering and Regulatory Technical Advisory Group. At that time, EPRI had concluded that a cracked divider plate in a Westinghouse Model 44F steam generatqr (such as those at Indian Point Energy Center (IPEC)) was not a safety concern: and that crack propagation is not likely due to the nature of the loading on the steam generator structure. However, recognizing that EPRl's evaluation of this generic issue was ongoing, Entergy stated, in Commitment 41, that it will inspect the IP2 and IP3 steam generators to assess the condition of the divider plate assemblies using an examination technique that is capable of detecting PWSCC. Specifically, Entergy stated that it will inspect the I P2 steam generator divider plates within the first ten years of the period of extended operation (before September 28, 2023), and the IP3 steam generator divider plates within the first refueling outage following the beginning of the period of extended operation (in Spring 2017).

In its February 1O, 2011 RAI (Reference 3), the NRC also asked questions related to the steam generator tube-to-tubesheet welds. Those questions were not tied to the same foreign operating experience with divider plates as noted above, but instead were based on the Staff's concern that

NL-17-005 Dockets 50-247 and 50-286 Page 3 of 7 certain tube-to-tubesheet welds and cladding materials may have insufficient chromium content to mitigate initiation of PWSCC, and that cracks in the divider plate could subsequently propagate to the tubesheet cladding and affect the tube-to-tubesheet welds. The Staff noted that unless there is an NRG-approved redefinition of the RCS pressure boundary, the effectiveness of the PWR Water Ctiemistry Program should be verified through a one-time inspection to ensure PWSCC is not occurring in the tube-to-tubesheet welds. Based on this background, the NRG Staff asked Entergy to justify how the Steam Generator Integrity Program (or another program) is capable of managing PWSCC in tube-to-tubesheet welds.

In its responses to Staff questions concerning whether the IP2 tube-to-tubesheet welds are part of the RCS pressure boundary or subject to permanently-approved alternate repair criteria (References 4-6), Entergy stated that the IP2 tube-to-tubesheet welds are part of the RCS pressure boundary, and that no alternate repair criteria had been approved (e.g., by defining the pressure boundary via a license amendment). In Commitment 42, Entergy stated that it would address the Staff's concern through one of two options - either through an analytical evaluation or an inspection. Under the analysis option, Entergy would evaluate the tube-to-tubesheet welds to establish a technical basis for either determining that those welds are not susceptible to PWSCC, or redefining the RCS pressure boundary, such that the welds would not be required for the pressure boundary function. (The latter option requires an NRG-approved license amendment.)

Entergy further explained that under the inspection option (if the analysis results are not acceptable), it would perform a one-time inspection of a representative number of welds in each steam generator. If cracking is identified, then the condition will be resolved through a repair or engineering evaluation, and an ongoing monitoring program will be established for the life of the steam generators.

In August 2011, the NRG Staff issued Supplement 1 to its Safety Evaluation Report (SSER 1)

(Reference 2), in which it found Entergy's RAI response and Commitments 41 and 42 acceptable.

The Staff found Commitment 41 "acceptable because the applicant will assess the condition of the divider plate assembly in each [steam generator] at both units by inspection during the period of extended operation, in a time period consistent with the detection of potential PWSCC cracks, with appropriate examination techniques." SSER 1 at 3-19. The Staff found Commitment 42 acceptable because it requires Entergy to manage the aging effect of cracking due to PWSCC in the tube-to-tubesheet welds either by: (1) demonstrating that those welds are not susceptible to PWSCC or redefining the reactor coolant pressure boundary such that it no longer includes the tube-to-tubesheet welds; or (2) implementing a one-time inspection on a representative number of welds. Id. at 3-23. The Staff further noted that any identified degradation would be addressed through the IPEC corrective action program.

New Staff Aging Management Guidance in LR-ISG-2016-01 LR-ISG-2016-01 (Reference 1), which the Staff first issued in draft for public comment in June 2016, describes changes to the aging management guidance for steam generator components in NUREG-1801 (GALL Report), Revision 2, and NUREG-1800 (SRP-LR), Revision 2, including guidance for managing cracking due to PWSCC in steam generator divider plate assemblies and tube-to-tubesheet welds. Specifically, it revises GALL Report aging management program (AMP)

Xl.M19, "Steam Generators," and SRP-LR Sections 3.1.2.2.11 and 3.1.3.2.11, "Cracking Due to Primary Water Stress Corrosion Cracking." The revised guidance reflects the Staff's acceptance of the technical conclusions from the EPRI SGMP investigation into the initiation and propagation of cracking ih the steam generator channel head components, as documented in several EPRI reports, principally EPRI 3002002850, "Steam Generator M_anagement Program: Investigation of

NL-17-005 Dockets 50-247 and 50-286 Page 4 of 7 Crack Initiation and Propagation in the Steam Generator Channel Head Assembly (Oct. 2014)

(EPRI 2014 Report) (Reference 7).

As relevant to IP2 and IP3, LR-ISG-2016-01 provides the following guidance with respect to the steam generator divider plates:

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For units with divider plate assemblies fabricated with Alloy 600 or Alloy 600 weld materials, if the analyses performed by the industry (as documented in the EPRI 2014 Report) are applicable and bounding for the unit, the primary water chemistry program is supplemented with a general visual inspection of the steam generator channel head (as part of the steam generator program as discussed in LR-ISG-2016-01 ). The purpose of the visual inspection is to identify rust stains or other abnormal conditions that could indicate the presence of cracking (e.g., distortion of divider plates). The general visual inspection is performed on each steam generator at least every 72 effective full power months or every third refueling outage, whichever results in more frequent inspections. LR-ISG-2016-01 at 4-5.

As pertinent to IP2 and IP3, LR-ISG-2016-01 provides the following guidance with respect to the steam generator tube-to-tubesheet welds:

For units with Alloy 600 steam generator tubes and for which an alternate repair criterion such as C*, F*, W*, or H* has been permanently approved for both the hot- and cold-leg side of the steam generator, the weld is no longer part of the reactor coolant pressure boundary and a plant-specific AMP is not necessary. LR-ISG-2016-01 at 8.

For units with thermally treated Alloy 690 steam generator tubes and with tubesheet cladding using Alloy 600 weld material, a plant-specific AMP is necessary unless the applicant confirms that the industry's analyses for tube-to-tubesheet weld cracking (e.g.,

chromium content for the tube-to-tubesheet welds is approximately 22 percent and the tubesheet cladding is in compression) are applicable and bounding for its unit, and the applicant will perform general visual inspections of the tubesheet region looking for evidence of cracking (e.g., rust stains on the tubesheet cladding) as part of the steam generator program. In lieu of a plant-specific AMP, the applicant may provide a rationale for why a plant-specific AMP is not necessary. LR-ISG-2016-01 at 8.

Related EPRI Guidelines in Information Letter SGMP-IL-16-02 for Determining If a Plant's Steam Generators are Bounded by EPRl's SGMP Analyses In parallel with the NRG Staff's finalization of LR-ISG-2016-01, EPRI prepared, and issued on October 10, 2016, Information Letter SGMP-IL-16-02, "Changes to Aging Management Guidance for Steam Generator Channel Head Components" (Reference 8). The purpose of SGMP-IL-16-02 is to inform the industry- that the NRG LR-ISG-2016-01 accepts the conclusions of the SGMP investigation into the initiation and propagation of cracking in the steam generator channel head components. SGMP-IL-16-02 states that the EPRI 2014 Report and LR-ISG-2016-01 may be used as a basis for updating aging management programs for license renewal for plants with susceptible materials. Attachment 1 to SGMP-IL-16-02 is a Checklist entitled "Guidance for Addressing Aging Management Plans for Steam Generator Channel Head Components" (EPRI Checklist) that reflects the bounding conditions considered in the EPRI 2014 Report and other related EPRI technical reports, and which licensees can use to document that the EPRI 2014 Report analysis bounds their plants' steam generators.

NL-17-005 Dockets 50-247 and 50-286 Page 5 of 7 Applicability of LR-ISG-2016-01 Guidance to IP2 and IP3 Steam Generator Divider Plate Assemblies and Tube-to-Tubesheet Welds The EPRI Checklist states that if Alloy 600 or Alloy 600 variations were used in fabricating a plant's steam generator divider plate assemblies or weld materials, then the reviewer should use the Checklist to verify that there is an adequate technical basis for concluding that the plant is bounded by the analyses performed in EPRI Technical Reports 3002002850, 1014982, 1020988. If all responses to the EPRI Checklist are "Yes" or other appropriate technical justification is provided, then the plant is bounded by the above-referenced EPRI Technical Reports and can appropriately rely on the aging management guidance in LR-ISG-2016-01.

As noted above, IP2 and IP3 both have divider plate assemblies fabricated with Alloy 600 and its associated weld metals (Alloy 182/82). Therefore, it is necessary to use the EPRI Checklist and the pertinent plant-specific attributes to demonstrate that IP2 and IP3 are bounded by the EPRI SGMP analyses. This demonstration is provided in the attached Technical Justification (Attachment 1) using the EPRI Checklist, which was completed using technical information obtained from the EPRI 2014 Report, the IP2 and IP3 steam generator technical manuals (TM 1440-C348 and TMMC 1440-C350\ and Westinghouse Electric Company LLC, the manufacturer of the Model 44F replacement steam generators installed in IP2 and IP3. As demonstrated in the Technical Justification, the industry analyses are bounding for the IP2 and IP3 steam generator divider plate assemblies and for the IP3 tube-to-tubesheet weld materials. 2 Therefore, the guidance contained in LR-ISG-2016-01 is appropriate for managing the aging effect of PWSCC in those steam generator components. Accordingly, Entergy has eliminated Commitment 41 as no longer necessary and closed Commitment 42 as satisfying Option 1 (Analysis) of that commitment.

Related Administrative Matters Changes to the List of Regulatory Commitments are provided in Attachment 2 and reflect the deletion of Commitment 41 and closure of commitment 42. There are no new commitments being made in this submittal. to this letter contains information that is considered proprietary to EPRI and Westinghouse and should be withheld from public disclosure pursuant to 10 CFR 2.390. With respect to EPRI, Attachment 1 contains information that was obtained from the EPRI 2014 Report (Reference 7), an EPRl-proprietary document. EPRI has authorized Entergy to provide the proprietary information obtained from the EPRI 2014 Report (as contained in Attachment 1) to the Westinghouse Technical Manual No. TM 1440-C348, "Vertical Steam Generator Instructions for Consolidated Edison Company of New York, Indian Point Station - Unit 2" (2001); Westinghouse Technical Manual No. TMMC 1440-C350, "Vertical Steam Generator Instruction for New York Power Authority - Indian Point Nuclear Plant No. 3" (Dec. 1989).

2 IP2 is a unit with Alloy 600 steam generator tubes for which an alternate repair criteria, H*, has been permanently approved for both the hot- and cold-leg side of the steam generator. The H* approval was documented in Technical Specification amendment 277 dated September 5, 2014. Therefore, the tube-to-tubesheet welds are no longer part of the reactor coolant pressure boundary and a plant-specific AMP is not necessary for IP2. See Letter from D. Pickett, NRC, to Vice President, Operations, Entergy, "Indian Point Nuclear Generating Unit No. 2 - Issuance of Amendment re: H* Alternate Repair Criteria for Steam Generator Tube Inspection and Repair (TAC No. MF3369)" (Sept. 5, 2014) (ML14198A161);

License Renewal Commitment Closure Verification Form - Commitment #42, Rev. 1 (Oct. 15, 2014)

(ML15331A242).

NL-17-005 Dockets 50-247 and 50-286 Page 6 of 7 NRC, but requests that this proprietary information be withheld from public disclosure in accordance with 10 CFR 2.390. EPRI previously has requested that the EPRI 2014 Report be withheld from public disclosure in accordance with 10 CFR 2.390(a)(4), as supported by the November 6, 2014 Affidavit of Mr. Neil Wilmshurst, EPRI Vice President and Chief Nuclear Officer.

See Letter from Neil Wilmshurst, EPRI, to Ken Karowski, NRC, "Request for Withholding of the Following Commercial Document: Steam Generator Management Program: Investigation of Crack Initiation and Propagation in the Steam Generator Channel Head Assembly. EPRI, Palo Alto, CA:

2014.3002002850" (Nov. 6, 2016) (ML14323A193).

In addition, the completed EPRI Checklist included in Attachment 1 contains IP2 and IP3 steam generator design information obtained from the above-referenced technical manuals and a December 7, 2016 Westinghouse letter to Entergy (LTR-CDA-16-40) that is Westinghouse Proprietary Class 2 information. Westinghouse has authorized Entergy to provide the Westinghouse proprietary information contained in Attachment 1 to the NRC, but requests that the proprietary information obtained from TM 1440-C348, TMMC 1440-C350, and LTR-CDA-16-40 be withheld from public disclosure in accordance with 10 CFR 2.390. 3 In support of that request, 1_

Entergy has enclosed Westinghouse Applications tor Withholding Proprietary Information from Public Disclosure CAW-16-4524, CAW-16-4525, and CAW-16-4526; accompanying Affidavits by James A. Gresham, Manager, Regulatory Compliance, Westinghouse; Proprietary Information Notices; and Copyright Notices. The Affidavits set forth the bases on which the information may be withheld from public disclosure by the Commission and address with specificity the considerations listed in 10 CFR 2.390(b)(4). 4 If you have any questions, or require additional information, please contact Mr. Robert Walpole at 914-254-6710.

I declare under penalty of perjury that the foregoing is true and correct. Executed on 1-17 ,2017.

Sincerely,

/

AJV/rl Attachments: 1. Technical Justification tor Elimination of License Renewal Commitment 41 Regarding Indian Point Units 2 and 3 Steam Generator Divider Plate 3

Entergy is not including copies of TM 1440-C348, TMMC 1440-C350, or LTR-CDA-16-40 with this submittal. However, those documents were prepared and classified as Westinghouse Proprietary Class 2, and Westinghouse considers all three documents to be proprietary in their entirety.

4 Correspondence with respect to the copyright or proprietary aspects of the Westinghouse documents listed above or the supporting Westinghouse Affidavits should reference CAW-16-4524, CAW-16-4525, or CAW-16-4526, as applicable, 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.

NL-17-005 Dockets 50-24 7 and 50-286 Page 7 of 7 Assemblies and Closure of License Renewal Commitment 42 Regarding Indian Point Unit 3 Tube-to-Tubesheet Welds Based On Analysis Option

2. Indian Point Units 2 and 3 License Renewal Application, List of Regulatory Commitments, Revision 30

Enclosures:

1. Westinghouse Letter CAW-16-4524, "Application for Withholding Proprietary Information from Public Disclosure" (Dec. 21, 2016) (concerning Westinghouse LTR-CDA-16-40)

2. Westinghouse Letter CAW-16-4525, "Application for Withholding Proprietary Information from Public Disclosure" (Dec. 22, 2016) (concerning Westinghouse TM 1440-C348)

3. Westinghouse Letter CAW-16-4526, "Application for Withholding Proprietary Information from Public Disclosure" (Dec. 22, 2016) (concerning Westinghouse TMMC 1440-C350) cc: Mr. Daniel H. Dorman, Regional Administrator, NRC Region I Mr. Sherwin E. Turk, NRC Office of General Counsel, Special Counsel Mr. William Burton, NRC Senior Project Manager, Division of License Renewal Mr. Douglas Pickett, NRR Senior Project Manager Ms. Bridget Frymire, New York State Department of Public Service (w/o Attachment 1)

Mr. John B. Rhodes, President and CEO NYSERDA (w/o Attachment 1)

NRC Resident Inspector's Office

_J

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ATTACHMENT 1 TO NL-17-005 TECHNICAL JUSTIFICATION FOR ELIMINATION OF LICENSE RENEWAL COMMITMENT 41 REGARDING INDIAN POINT UNITS 2 AND 3 STEAM GENERATOR DIVIDER PLATE ASSEMBLIES AND CLOSURE OF LICENSE RENEWAL COMMITMENT 42 REGARDING INDIAN POINT UNIT 3 TUBE-TO-TUBESHEET WELDS BASED ON ANALVSIS OPTION ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 DOCKET NOS. 50-247 AND 50-286

ENCLOSURE 1 TO NL-17-005 WESTINGHOUSE LETTER CAW-16-4524, DATED DECEMBER 21, 2016 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE, "

SUBJECT:

LTR-CDA-16-40, TRANSMITTAL OF INDIAN POINT UNIT 2 AND UNIT 3 REPLACEMENT STEAM DESIGN INFORMATION" (PROPRIETARY)"

ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 DOCKET NOS. 50-247 AND 50-286

Westinghouse Non-Proprietary Class 3

@ Westinghouse Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (724) 940-8560 11555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852 CA W-16-4524 December 21, 2016 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

LTR-CDA-16-40, "Transmittal of Indian Point Unit 2 and Unit 3 Replacement Steam Design, Information" (Proprietary)

The Application for Withholding Proprietary Information from Public Disclosure is submitted by Westinghouse Electric Company LLC ("Westinghouse"), pursuant t'o the provisions of paragraph (b)(l) of Section 2.390 of the Commission's regulations. It contains commercial strategic information proprietary to Westinghouse and customarily held in confidence.

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-16-4524 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.

The subject document was prepared and classified as Westinghouse Proprietary Class 2. Westinghouse requests that the document be considered proprietary in its entirety. As such, a non-proprietary version will not be issued.

Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Entergy Nuclear Northeast.

Correspondence with respect to the proprietary aspects of the Application for Withholding or the Westinghouse Affidavit should reference CAW-16-4524, 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.

2d'6:~cr Regulatory Compliance

CA W-16-4524 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

SS COUNTY OF BUTLER:

I, James A. Gresham, 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 knowledg~. information, and belief.

ames A. Gresham, Manager Regulatory Compliance Date: ! ZVtff~I

__ I

3 CA W-16-4524 (I) I am Manager, Regulatory Compliance, 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 I 0 CFR Section 2.390 af 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

4 CAW-16-4524 Westinghouse's competitors without 1icense 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 ofresources 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.

5 CA W-16-4524 (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 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.

(t) 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 IO CPR Section 2.390, 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 man'ner 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 contained in LTR-CDA-16-40, "Transmittal of Indian Point Unit 2 and Unit 3 Replacement Steam Design Information" (Proprietary), for submittal to the Commission, being transmitted by Entergy Nuclear Northeast 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 design information regarding the partition plates, tubesheet, and tube-to-tubesheet welds of the Model 44F replacement steam generators at Indian Point Unit 2 and Unit 3 and is provided for use in response to License Renewal Commitments 41and 42 and may be used only for that purpose.

6 CA W-16-4524 (a) This information is part of that which will enable Westinghouse to provide sufficient detail of steam generator manufacturing information and technology.

(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 as-built steam generator design documentation.

(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 is the proprietary version of a document, furnished to the NRC in connection with requests for generic and/or plant-specific review and approval. The document is to be considered proprietary in its entirety.

COPYRIGHT NOTICE The report transmitted herewith bears a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in this report which is 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. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

ENCLOSURE 2 TO NL-17-005 WESTINGHOUSE LETTER CAW-16-4525, DATED DECEMBER 22, 2016 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE, "

SUBJECT:

TM 1440-C348, "VERTICAL STEAM GENERATOR INSTRUCTIONS FOR CONSOLIDATED EDISON COMPANY OF NEW YORK, INDIAN POINT STATION - UNIT 2" (PROPRIETARY)"

ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 DOCKET NOS. 50-247 AND 50-286

Westinghouse Non-Proprietary Class 3

@Westinghouse Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (724) 940-8560 11555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852 CAW-16-4525 December 22, 2016 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

TM 1440-C348, "Vertical Steam Generator Instructions for Consolidated Edison Company of New York Indian Point Station - Unit 2" (Proprietary)

The Application for Withholding Proprietary Information from Public Disclosure is submitted by Westinghouse Electric Company LLC ("Westinghouse"), pursuant to the provisions of paragraph (b)( l) of Section 2.390 of the Commission's regulations. It contains commercial strategic informatio_n proprietary to Westinghouse and customarily held in confidence.

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-16-4525 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 l 0 CFR Section 2.390 of the Commission's regulations.

The subject document was prepared and classified as Westinghouse Proprietary Class 2. Westinghouse requests that the document be considered proprietary in its entirety. As such, a non-proprietary version will not be issued.

Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Entergy Nuclear Northeast.

Correspondence with respect to the proprietary aspects of the Application for Withholding or the Westinghouse Affidavit should reference CAW-16-4525, 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.

a~aM~r Regulatory Compliance

CAW-16-4525 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

SS COUNTY OF BUTLER:

I, James A. Gresham, 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.

James A. Gresham, Manager Regulatory Compliance I

i I Date: ftfiLh I '

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(1) I am Manager, Regulatory Compliance, 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

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4 CAW-16-4525 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 Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse:,

CO 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.

5 CAW-16-4525 (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 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, 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 contained in TM 1440-C348, "Vertical Steam Generator Instructions for Consolidated Edison Company of New York Indian Point Station- Unit 2" (Proprietary), for submittal to the Commission, being transmitted by Entergy Nuclear Northeast 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 design information regarding the Model 44F replacement steam generators at Indian Point Unit 2 and is provided for use in response to License Renewal Commitments 41 and 42 and may be used only for that purpose.

(a) This information is part of that which will enable Westinghouse to provide sufficient detail of steam generator manufacturing information and technology.

6 CAW-16-4525 (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 as-built steam generator design documentation.

(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 is the proprietary version of a document, furnished to the NRC in connection with requests for generic and/or plant-specific review and approval. The document is to be considered proprietary in its entirety.

COPYRIGHT NOTICE

. I The report transmitted herewith bears a Westinghouse'copyright notice. The NRC is permitted to make the number of copies of the information contained in this report which is necessary for its internaluse 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. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

ENCLOSURE 3 TO NL-17-005 WESTINGHOUSE LETTER CAW-16-4526, DATED DECEMBER 22, 2016 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE, "

SUBJECT:

TM 1440-C350, "VERTICAL STEAM GENERATOR INSTRUCTIONS FOR NEW YORK POWER AUTHORITY, INDIAN POINT STATION- UNIT 3" (PROPRIETARY)"

Westinghouse Non-Proprietary Class 3

@Westinghouse Westinghouse Electric Company

1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (724) 940-8560 11555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852 CAW-16-4526 December 22, 2016 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

TM 1440-C350, "Vertical Steam Generator Instructions for New York Power Authority Indian Point Nuclear Plant No. 3" (Proprietary)

The Application for Withholding Proprietary Information from Public Disclosure is submitted by Westinghouse Electric Company LLC ("Westinghouse"), pursuant to the provisions of paragraph (b)(l) of Section 2. 390 of the Commission's regulations. It contains commercial strategic information proprietary to Westinghouse and customarily held in confidence.

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-16-4526 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.

The subject document was prepared and classified as Westinghouse Proprietary Class 2. Westinghouse requests that the document be considered proprietary in its entirety. As such, a non-proprietary version will not be issued.

Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Entergy Nuclear Northeast.

Correspondence with respect to the proprietary aspects of the Application for Withholding or the Westinghouse Affidavit should reference CAW-16-4526, 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..

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t.mes A. Gresham, Manager Regulatory Compliance

CA W-16-4526 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

SS COUNTY OF BUTLER:

I, James A. Gresham, 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.

li:mes A. Gresham, Manager Regulatory Compliance Date: tefzt/(~

II 1~ 3 CAW-16-4526 (1) I am Manager, Regulatory Compliance, 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, J 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

II 4 CAW-16-4526 H

Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.