NRC 2004-0059, To Reactor Vessel Closure Head Penetration Repair and Flaw Characterization Relief Requests MR 02-018-1, Revision 1 and MR 02-018-2, Revision 1
| ML051470050 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 05/25/2004 |
| From: | Vanmiddlesworth G Nuclear Management Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| FOIA/PA-2004-0282, MR 02-018-1, Rev 1, MR 02-018-2, Rev 1, NRC 2004-0059 | |
| Download: ML051470050 (10) | |
Text
R, P k, P e- -/5 Committed to Nuclear Ecellence Point Beach Nuclear Plant Operated by Nuclear Management Company, LLC May 25, 2004 NRC 2004-0059 10 CFR 50.55a(a)(3)(i) 10 CFR 50.55a(g)(5)(iii)
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Point Beach Nuclear Plant, Unit 1 Docket 50-266 License No. DPR-24 Supplement 4 to Reactor Vessel Closure Head Penetration Repair and Flaw Characterization Relief Requests MR 02-018-1, Revision 1 and MR 02-018-2, Revision 1
References:
(1)
(2)
(3)
(4)
(5)
Letter from NMC to NRC dated May 13, 2004 (NRC 2004-0051)
NRC Safety Evaluation dated September 10, 2003 NRC Safety Evaluation dated September 24, 2003 Letter from NMC to NRC dated May 15, 2004 (NRC 2004-0053)
Letter from NMC to NRC dated May 20, 2004 (NRC 2004-0056)
In reference 1, Nuclear Management Company, LLC (NMC), licensee for Point Beach Nuclear Plant (PBNP), requested revision to the relief, granted in references 2 and 3, pertaining to reactor vessel closure head (RVCH) penetration repair and flaw characterization. References 4 and 5 provided supplemental information in support of the requested relief.
In reference 5, NMC committed to submit copies of the minutes from the Electric Power Research Institute - Materials Reliability Program (EPRI-MRP) crack growth expert panel meeting regarding primary water stress corrosion cracking (PWSCC) held on October 3, 2003. This letter fulfills that commitment.
Enclosed with this letter are proprietary and nonproprietary versions of the October 3, 2003 meeting minutes, which were requested by NRC staff.
Also included in the enclosures to this letter is an EPRI proprietary authorization affidavit.
As enclosure I contains information proprietary to EPRI, it is supported by an affidavit signed by EPRI, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.790 of the Commission's regulations.
6590 Nuclear Road
- Two Rivers, Wisconsin 54241 Telephone: 920.755.2321 7rl,
-difff. : -1 IfCT, -.I
Document Control Desk Page 2 Accordingly, it is respectfully requested that the information, which is proprietary to EPRI, be withheld from public disclosure in accordance with 10 CFR 2.790.
Correspondence regarding the proprietary aspects of the items listed above, or the supporting EPRI Affidavit, should reference the affidavit and be addressed to Warren J. Bilanin, Director Nuclear Power Sector, Electric Power Research Institute, Nuclear Power Sector, 3412 Hillview Avenue, Palo Alto, California, 94304.
This submittal contains no new regulatory commitments and fulfills one commitment.
Gary D. Van Middlesworth Site Vice-President, Point Beach Nuclear Plant Nuclear Management Company, LLC
Enclosures:
I -
Minutes of EPRI-MRP PWSCC Crack Growth Expert Panel Meeting, October 3, 2003 - Gaithersburg, Maryland (proprietary) 11 -
Minutes of EPRI-MRP PWSCC Crack Growth Expert Panel Meeting, October 3, 2003 - Gaithersburg, Maryland (non-proprietary)
IlIl -
EPRI Letter dated May 24, 2004, Transmittal of Proprietary Authorization Affidavit cc:
Project Manager, Point Beach Nuclear Plant, USNRC Regional Administrator, Region l1l, USNRC NRC Resident Inspector, Point Beach Nuclear Plant PSCW
ENCLOSURE I SUPPLEMENT 4 TO REACTOR VESSEL CLOSURE HEAD PENETRATION REPAIR AND FLAW CHARACTERIZATION RELIEF REQUESTS MR 02-018-1, REVISION 1 AND MR 02-018-2, REVISION I MINUTES OF EPRI-MRP PWSCC CRACK GROWTH EXPERT PANEL MEETING, OCTOBER 3,2003 - GAITHERSBURG, MARYLAND (PROPRIETARY)
POINT BEACH NUCLEAR PLANT, UNIT I 2 Pages Follow
ENCLOSURE II SUPPLEMENT 4 TO REACTOR VESSEL CLOSURE HEAD PENETRATION REPAIR AND FLAW CHARACTERIZATION RELIEF REQUESTS MR 02-018-1, REVISION I AND MR 02.018-2, REVISION 1 MINUTES OF EPRI-MRP PWSCC CRACK GROWTH EXPERT PANEL MEETING, OCTOBER 3,2003-GAITHERSBURG, MARYLAND (NON-PROPRIETARY)
POINT BEACH NUCLEAR PLANT, UNIT I 2 Pages Follow
Non-Proprietary POWERING PROGRESS THROUGH SCIENCE AND TECHNOLOGY S a PW R M R P PWR Materials Reliability Program PWR MRP 2003-38 October 20, 2003 TO:
EPRI-MRP PWSCC Crack Growth Expert Panel Alloy 600 ITG and WG ChairmenNice-chairmen All EPRI staff directly involved with Alloy 600 ITG Contractors currently working on this subject for the MRP FROM:
John Hickling
SUBJECT:
Minutes of EPRI-MRP PWSCC Crack Growth Expert Panel Meeting, October 3, 2003 - Gaithersburg, Maryland The final minutes of the subject meeting (incorporating comments from Panel members) are enclosed. They are being distributed more widely than usual so as to have an interim record of the agreement reached on CGR disposition curves for the Alloy 600 weld metals 182/132/82 prior to production and approval of a formal MRP report that will be analogous to MRP-55 for CGR through PWSCC in thick-section base material.
Please note that the information contained herein is preliminary in nature and should NOT be used as the basis for official submissions of any kind. Until the final report is available, all communications as to the results of the Panel's work must be channeled via EPRI. and no diagrams, equations, etc. shall be provided to outside bodies without prior, specific MRP approval.
If you have any comments or questions please contact me at 650-855-8976, or by email at ihicklin(tepri.com.
John Hickling Technical Leader - Materials Issues Nuclear Power - Science & Technology Dept.
Non-Proprietary IMRP 2003-38: Minutes of EPRI-MRP PWSCC Crack Growth Expert Panel Meeting, October 3,2003 - Gaithersburg, Maryland October 3, 2003 Marriott Washingtonian Center, Gaithersburg, MD Date:
Place:
Subiect:
EPRI-MRP PWSCC Crack Growth Expert Panel Meeting Attendees:
See Attachment I Summary:
The following summarizes the results of the meeting - see the subsequent text for a summary of the discussions leading to these. Italics are used throughout to denote action items or decisions reached.
- 1. Content Deleted - MRP/EPRI Proprietary Material
- 2. Content Deleted - MRP/EPRI Proprietary Material
- 3. Content Deleted - MRP/EPRI Proprietary Material
- 4. Content Deleted - MRP/EPRI Proprietary Material Content Deleted - MRP/EPRI Proprietary Material
- 5. Content Deleted - MRP/EPRI Proprietary Material
- 6. The panel agreed on the structure for the final report and assigned lead responsibilities for preparing various sections - a draft will be provided for ITG review in December 2003.
ENCLOSURE III SUPPLEMENT 4 TO REACTOR VESSEL CLOSURE HEAD PENETRATION REPAIR AND FLAW CHARACTERIZATION RELIEF REQUESTS MR 02-018-1, REVISION 1 AND MR 02-018-2, REVISION 1 EPRI LETTER DATED MAY 24,2004, TRANSMITTAL OF PROPRIETARY AUTHORIZATION AFFIDAVIT POINT BEACH NUCLEAR PLANT, UNIT I 3 Pages Follow
E L E C T R I F Y T H E W O R L D 2
May 24, 2004 Document Control Desk U.S. Nuclear Regulatory Commission 11555 Rockville Pike Washington DC, 20555
Subject:
Documentation: "Summary of Minutes of EPRI-MRP PWSCC Crack Growth Expert Panel Meeting, October 3, 2003 - Gaithersburg, Maryland" Attached to MRP Letter 2003-38 dated October 20, 2003 Gentlemen:
This is a request under 10CFR2.790(a)(4) that the NRC withhold from public disclosure the information identified in the enclosed affidavit consisting of EPRI owned Proprietary Information identified above (the "Documentation"). Copies of the Documentation and the affidavit in support of this request are enclosed. The Documentation consists only of the summary of the October 3, 2003 meeting minutes. Supporting details provided in the minutes are not included in this submittal because of their preliminary nature, the informal context in which they were developed, and their release would violate MRP administrative procedures concerning industry review and approval. The information contained in the summary is also considered preliminary, but is not expected to change when published in an anticipated EPRI technical report.
EPRI desires to disclose the "Documentation" in confidence to the NRC as a means of exchanging information in support of repairs of Point Beach Nuclear Plant Unit 1 CRDM Nozzle 26. Further, EPRI welcomes any discussion with the NRC regarding the "Documentation" that the NRC desires to conduct.
The "Documentation" is for the NRC's internal use and may be used only for the purposes for which it is disclosed by EPRI. The "Documentation" should not be otherwise used or disclosed to any person outside the NRC without prior written permission from EPRI.
If you have any questions about the legal aspects of this request for withholding, please do not hesitate to contact me at (650) 855-2340. Questions on the contents of the "Documentation" should be directed to Ms. Christine King of EPRI at (650) 855-2605.
Sincerely, Warren J. Bilanin Director, Nuclear Power Sector Enclosures c:
Nichole Edraos, EPRI CORPORATE HEAOOUARTERS 3412 HilIview Avenue I Palo Alto CA 94304-1395 USA I 650.855.2000 1 Customer Service 600.313.3774 I www.epri.com
BulI AFFIDAVIT RE:
Documentation: "Summary of Minutes of EPRI-MRP PWSCC Crack Growth Expert Panel Meeting, October 3, 2003 - Gaithersburg, Maryland" Attached to MRP Letter 2003-38 dated October 20, 2003 I, WARREN J. BILANIN, being duly swom, depose and state as follows:
I am a Director at the Electric Power Research Institute ("EPRI") and I have been specifically delegated responsibility for the Documentation listed above that is sought under this affidavit to be withheld (the "Documentation") and authorized to apply for their withholding on behalf of EPRI.
This affidavit is submitted to the Nuclear Regulatory Commission ("NRC")
pursuant to 10 CFR 2.790 (a)(4) based on the fact that the Documentation consists of trade secrets of EPRI and that the NRC will receive the Documentation from EPRI under privilege and in confidence.
The basis for withholding such Documentation from the public is set forth below:
(i) The Documentation has been held in confidence by EPRI, its owner. All those accepting copies of the Documentati6n must agree to preserve the confidentiality of the Documentation.
(ii) The Documentation is a type customarily held in confidence by EPRI and there is a rational basis thereof. The Documentation is a type, which EPRI considers as a trade secret(s) and is held in confidence by EPRI because to disclose it would prevent EPRI from licensing the Documentation at fees, which would allow EPRI to recover its investment. If consultants and/or other businesses providing services in the electric/nuclear power industry were able to publicly obtain the Documentation, they would be able to use it commercially for profit and avoid spending the large amount of money that EPRI was required to spend in preparation of the Documentation.
The rational basis that EPRI has for classifying this/these Documentation(s) as a trade secrets is justified by the Uniform Trade Secrets Act, which Califomia adopted in 1984 and which has been adopted by over twenty states. The Uniform Trade Secrets Act defines a "trade secret" as follows:
"Trade secret" means information, including a formula, pattem, compilation, program, device, method, technique, or process, that:
(1) Derives independent economic value, actual or potential, from not being generally known to the public or to other persons who can obtain economic value from its disclosure or use; and
8 I F2I (2) Is the subject of efforts that are reasonable under the circumstances to maintain its secrecy.
(iii) The Documentation will be transmitted to the NRC in confidence.
(iv) The Documentation is not available in public sources. EPRI developed the Documentation only after making a determination that the Documentation was not available from public sources. It required a large expenditure of dollars for EPRI to develop the Documentation. In addition, EPRI was required to use a large amount of time of EPRI employees. The money spent, plus the value of EPRI's staff time in preparing the Documentation, show that the Documentation is highly valuable to EPRI. Finally, the Documentation was developed only after a long period of effort of several years.
(v) A public disclosure of the Documentation would be highly likely to cause substantial harm to EPRI's competitive position and the ability of EPRI to license the Documentation both domestically and internationally. The Documentation can only be acquired and/or duplicated by others using an equivalent investment of time and effort.
I have read the foregoing and the matters stated therein are true and correct to the best of my knowledge, information and belief. I make this affidavit under penalty of perjury under the laws of the United States of America and under the laws of the State of California.
Executed at 3412 Hillview Avenue, Palo Alto, being the premises and place of business of the Electric Power Research Institute:
date 57-2,L- -
War J. Bilanin Subscribed and sworn before me this day:
date S
~iioleAlexana Edraos, Notary Public NICHOLE AlEXANDRA EDRAOS Comm. 11295461 imWoTfMCOFd O
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