L-2020-104, Fifth Ten-Year Inservice Inspection Interval Relief Request No. 7 for Train a and B Component Cooling Water (CCW) Supply and Return Piping

Fifth Ten-Year Inservice Inspection Interval Relief Request No. 7 for Train a and B Component Cooling Water (CCW) Supply and Return Piping

ML20266G309
Person / Time
Site:	Turkey Point
Issue date:	09/18/2020
From:	Hess R Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML20266G308	List: L-2020-104, Fifth Ten-Year Inservice Inspection Interval Relief Request No. 7 for Train a and B Component Cooling Water (CCW) Supply and Return Piping
References
L-2020-104
Download: ML20266G309 (16)

Text

Florida Power & Light Company 9760 S.W. 344th Street Homestead, FL 33035 September 18, 2020 L-2020-104 10 CFR 50.55a 10 CFR 2.390 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555-0001 Re:

Turkey Point Unit 4 Docket Nos. 50-251 Subsequent Renewed License No. DPR-41 Fifth Ten-Year Inservice Inspection Interval Turkey Point Unit 4 Relief Request No. 7 for Train A and B Component Cooling Water (CCW) Supply and Return Piping Pursuant to 10 CFR 50.55a(z)(2), Florida Power & Light Company (FPL) requests the Nuclear Regulatory Commission (NRC) for relief from the applicable American Society of Mechanical EngineersSection XI Code (ASME Code) requirements for the repair/replacement activity identified in this request. This relief requests to repair certain sections of the degraded Unit 4 Component Cooling Water supply and return piping by installing a welded proprietary repair device, PMCap Restoration Method - US Patent 6,860,297to these moderate energy Class 3 pressure boundary piping with new pressure boundary material without removing the sections of degraded piping. The basis for the relief is that compliance with the specified ASME Code repairs would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

The details of the Turkey Point Unit 4 Relief Request No. 7 are presented in Attachment 1.

The PMCap proprietary information is provided separately in Attachment 2. Attachment 3 contains the Affidavit of Mr. Paul S. Manzon of PMC Engineering, certifying that the material provided in Attachment 2 is proprietary in nature and FPL requests that the material in be withheld from public disclosure under the provisions of 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding The extent of degradation due to corrosion is unknown at this time. The degraded area of piping will be characterized using NDE techniques during the upcoming Turkey Point Unit 4 refueling outage, scheduled to start on October 3, 2020. The attached relief request includes two potential options that represent the worst possible degraded piping conditions classified as:

1. Option 1: If a through-wall leak is discovered.

2. Option 2: If a thinning beyond code allowable minimum is discovered.

Due to the unknown circumstances surrounding this relief request, FPL is requesting approval of these options, as applicable and as required, prior to Mode 2, after the Unit 4 refueling outage. It should be noted, that upon discovery of the actual conditions of the degraded piping, FPL will promptly provide supplemental information with sufficient details to support NRCs review and approval of this relief request.

L-2020-104 Page2 If you have any questions or require additional information, please contact Robert J. Hess, Licensing Manager, at (305) 246-4112.

Sincerely, Robert J. Hess Licensing Manager Turkey Point Nuclear Plant Attachments cc:

USNRC Regional Administrator, Region II, USNRC USNRC Senior Resident Inspector, USNRC, Turkey Point Nuclear Plant USNRC Project Manager, Turkey Point Nuclear Plant

ATTACHMENT 1 L-2020-104 TURKEY POINT UNIT 4 RELIEF REQUEST No. 7

Turkey Point, Unit 4 Fifth 10-Year Interval Relief Request No. 7 Component Cooling Water Welded Repairs for External Corrosion L-2020-104 1

In Accordance with 10 CFR 50.55a(z)(2)

--Hardship or Unusual difficulty without a compensating increase in the level of quality and Safety--

1.0 ASME CODE COMPONENT(S) AFFECTED The affected components are the Turkey Point Unit 4 Component Cooling Water (CCW) Train A & B supply and return piping.

The 18-inch carbon steel supply and return piping are located outside of the Turkey Point Unit 4 containment. The locations of interest are in the vicinity of the floor penetration in the CCW heat exchanger room.

The supply and return CCW piping were constructed in accordance with construction code for pressure piping USAS B31.1-1955 and was later reconciled to code of record ANSI B31.1 1973 Edition through Winter 1976 Addenda. For the purpose of this relief request, the safety significance and quality class of the code of record ANSI B31.1 1973, is considered equivalent to ASME Code Section III, Class 3 piping (Reference 1). Accordingly, this piping is subject to repair/replacement requirements of ASME Code,Section XI, IWA 4000.

The following design data pertains to these moderate energy Class 3 CCW supply and return pressure boundary piping:

• Pipe Schedule: 18-inch Sch. STD (tnom = 0.375-inch)

• Design Pressure: 150 psig

• Design Temperature: 200°F

• Material Specification: Carbon Steel, ASME SA-53 Grade A welded The CCW System loop is the heat sink for the residual heat removal System, the Chemical and Volume Control System, the spent fuel cooling loop and various Reactor Coolant System components. The design basis of the CCW System is to provide sufficient heat removal from the Engineered Safety Features to the ultimate heat sink, post-accident. The system, which is normally operated in an open configuration, is designed with sufficient capability to accommodate the failure of any single, active component without resulting in undue risk to the health and safety of the public following a Maximum Hypothetical Accident.

Turkey Point, Unit 4 Fifth 10-Year Interval Relief Request No. 7 Component Cooling Water Welded Repairs for External Corrosion L-2020-104 2

2.0 APPLICABLE CODE EDITION AND ADDENDA The Turkey Point Unit 4 applicable Code for the fifth 10-year Inservice inspection (ISI) Interval is the ASME Code Section XI 2007 Edition with 2008 Addenda (Reference 2). The Turkey Point Unit 4 Fifth ISI 10-Year interval started on February 22, 2014 and ends on February 21, 2024.

3.0 APPLICABLE CODE REQUIREMENTS The applicable Code sections for which the relief is requested are ASME Code,Section XI, 2007 Edition, with 2008 Addenda. Article IWA-4421, General requirements, of Section XI of the ASME Code, requires that defects be removed in accordance with IWA-4340, IWA-4411, IWA-4412, IWA-4461 or IWA-4462.

It should be noted that use of IWA-4340 is prohibited by 10 CFR 50.55a(b)(2)(xxv)(A), which states: The use of the provisions for mitigation in IWA-4340 of Section XI 2001 Edition through the 2010 Addenda, is prohibited.

4.0 REASON FOR REQUEST The Trains A and B CCW supply and return piping degradation has not yet been characterized using ISI non-destructive examination (NDE) techniques. Upon discovery of the actual degraded piping conditions during the Turkey Point Unit 4 refueling outage, which is scheduled to start on October 3, 2020, additional evaluation will be performed, and provided to NRC to supplement this relief request. Hence, this relief request contains two potential options which are deemed to be the two worst possible degraded piping conditions. These options are:

1. Option 1: A through-wall leak.

2. Option 2: Thinning beyond code allowable minimum.

10 CFR 50.55a(z) authorizes the Director, Office of Nuclear Reactor Regulation, to approve alternatives to the requirements of paragraphs (b) through (h) of 10 CFR 50.55a, including relief from the prohibition on IWA-4340 specified in 10 CFR 50.55a(b)(2)(xxv)(A). Accordingly,

• Relief is requested from the requirements of IWA-4421 to remove defects in accordance with IWA-4411, IWA-4461, or IWA-4462 on the subject piping identified in this request, prior to performing repair/replacement activities.

• Relief is also requested from the prohibition of IWA-4340 in 10 CFR 50.55a(b)(2)(xxv)(A).

Turkey Point, Unit 4 Fifth 10-Year Interval Relief Request No. 7 Component Cooling Water Welded Repairs for External Corrosion L-2020-104 3

This relief request is submitted to allow the installation of pressure retaining parts that will be used to restore areas with unacceptable wall thickness loss or through wall leakage caused by corrosion. Installation of replacement pressure retaining parts without first removing the degraded portions of the subject Trains A and B CCW supply and return piping does not comply with the requirements of IWA-4421.

The proposed alternative has been developed because other repair/replacement options that would fully comply with IWA-4421 create a hardship or unusual difficulty without a compensating increase in the level of quality and safety for reasons detailed in this request.

5.0 PROPOSED ALTERNATIVE AND BASIS FOR USE Proposed Alternative In lieu of the requirement of IWA-4421 to remove the defective portion of the component prior to performing repair/replacement activities by welding, unacceptable wall thickness loss or through-wall leakage caused by localized general or pitting corrosion shall be corrected by installation of replacement pressure retaining parts that fully restore the degraded piping. Accordingly,

• In the case of a through-wall leakage in the subject components, an IWA-4340 modification/repair is needed to be installed around the circumference of the degraded piping without removal of the degraded area. The through-wall leak is to be first sealed using a housekeeping repair, to enable additional welding activities on a dry surface. ASME Code Case N-513-4 will be used to justify the structural stability of the CCW piping for past operability, as well as continued operation during the outage, prior to installation of the IWA-4340 modification /repair.

• In the case of localized thinning that results in stresses that exceed the Code allowable stresses in the subject components, an IWA-4340 modification/repair is to be installed around the circumference of the degraded piping without removal or local repair of the degraded area.

• The modification/repair is a welded proprietary repair device, PMCap Restoration Method - US Patent 6,860,297, hereafter referred to as PMCap, installed on the outside of the pipe, and is designed in accordance with ASME B31.1, 1973 edition w/Addenda through Winter 1976, to replace the pressure boundary and to maintain the structural integrity of the degraded piping. The proposed repair is to restore the entire sections of 18-inch CCW piping containing the degradation (pipe/elbow external wall loss due to corrosion) with 20 OD PMCaps. The modification shall provide for the structural integrity of the pipe, such that it no longer relies on the defective area, including projected corrosion growth.

Turkey Point, Unit 4 Fifth 10-Year Interval Relief Request No. 7 Component Cooling Water Welded Repairs for External Corrosion L-2020-104 4

o The PMCaps are ASME Code compliant components that replace existing Code pressure boundary components with new Code pressure boundary components.

o The PMCaps are constructed of carbon steel and will be protected from future external corrosion by coating the PMCaps per FPL Protective Coatings for Areas Outside the Reactor Containment requirements and use of a redesigned boot seal to prevent exposure to corrosive environments and/or flood water.

o The PMCaps are constructed with all welds being full penetration and are configured to be full penetration to the existing 18 piping. Existing piping locations where PMCaps are to be attached will be examined to assure adequate soundness and material thickness.

o The PMCap weld designs are per the requirements of ANSI B31.1-1973, the piping code of construction for the CCW system at Turkey Point Nuclear Units 3 and 4 (Reference 1).

o The fabrication/assembly of the PMCap follows the welding guidelines for Code Class 3 components.

o All welding for the installation of the PMCap will be accomplished per requirements of the FPL Welding Control Manual and vendor drawings and qualified as pressure boundary welds.

• The proposed alternative is the installation of PMCap in accordance with IWA-4340, except as noted below regarding flaw growth and future examinations, with the repair being for extended acceptance. NRC allows the use of mitigation of defects by modification (Reference 3) in accordance with 10 CFR 50.55a(b)(2)(xxv)(B) Second Provision, which states that:

The provisions for the mitigation of defects by modification in IWA-4340 of Section XI, 2011 Edition through the 2017 Edition may be used subject to the following three conditions:

(1) The use of the provisions in IWA 4340 to mitigate crack-like defects or those associated with flow accelerated corrosion are prohibited.

(2) The design of a modification that mitigates a defect shall incorporate a loss of material rate either 2 times the actual measured corrosion rate in that pipe location (established based on wall thickness measurements conducted at least twice in two prior consecutive or nonconsecutive refueling outage cycles in the 10 year period prior to installation of the modification), or 4 times the estimated maximum corrosion rate for the piping system.

Turkey Point, Unit 4 Fifth 10-Year Interval Relief Request No. 7 Component Cooling Water Welded Repairs for External Corrosion L-2020-104 5

(3) The licensee shall perform a wall thickness examination in the vicinity of the modification and relevant pipe base metal. Except as provided in paragraphs (b)(2)(xxv)(B)(3)(i) and (ii), the examination must be performed during each refueling outage cycle to detect propagation of the defect into the material credited for structural integrity of the item unless the examinations in the two refueling outage cycles subsequent to the installation of the modification are capable of validating the projected flaw growth. Where the projected flaw growth has been validated, the modification must be examined at half its expected life or once per interval, whichever is smaller These conditions are related to the form of degradation, future degradation, and future examination. The subject CCW pipe degradation is caused by external corrosion not cracking, and not flow accelerated corrosion, therefore IWA-4340 is applicable. Regarding Condition # 2, since the component will be metallized and externally coated, the degradation mechanism is mitigated, corrosion is no longer a valid degradation mechanism. Regarding Condition # 3, because external corrosion is no longer a valid degradation mechanism, future wall thickness examinations are not required, and as such, they will not be performed.

• Applicable only for the case that a through-wall leak is discovered, prior to installation of the modification/repair, the through-wall leakage will be stopped with a seal. Stopping the leakage is only necessary to enable installation of the PMCap.

• The PMCap is to be installed around the circumference of the degraded piping without removal of the degraded area. The localized flaw appears to be due to external corrosion caused by drainage water in a salt air environment contacting the outside surface of the piping. The localized wall thickness in the degraded area of piping will be further characterized using ultrasonic (UT) examination techniques, and a PMCap will be applied which covers the degraded area and accounts for any future wall loss.

• Where the PMCap is to be welded to the 18-inch pipe, a UT thickness measurement shall also be performed to confirm that material thickness is adequate for the repair design.

• The locations where the PMCap is to be welded to the system pressure boundary shall be located sufficiently far from locations of identified wall thinning to preclude the growth of identified corrosion from challenging the integrity of the repair for the remaining life of the component to which the PMCap is welded.

• The PMCap repair is designed such that it shall not rely on the existing pipe wall.

After installation, an aluminum coating will be applied to the outer surface of the

Turkey Point, Unit 4 Fifth 10-Year Interval Relief Request No. 7 Component Cooling Water Welded Repairs for External Corrosion L-2020-104 6

component in order to prevent any future external degradation. Therefore, future external wall loss will not be considered.

• Restoration of the defective or locally thinned area(s) at each location shall be performed only once.

• Welding of the PMCap to the CCW pipe and all required non-destructive examination (NDE) will be per FPL controlled processes for ASME Class 3 components.

• The PMCaps will include ports to perform post-installation pressure testing.

• Future NDE will be in accordance with ASME Code,Section XI, Table IWD-2500-1 for Examination Category D-A. The piping internal to the PMCap boundary is inaccessible and will not be examined in the future because credit will no longer be taken for its pressure retaining function, thus, it will be outside the Inservice examination requirements of Section XI of the ASME Code. Since the outer surface is being coated external corrosion will not recur.

Basis for the Request Complying with IWA-4421 requirements to remove degraded portions of this piping prior to performing a repair/replacement activity represents a hardship or unusual difficulty without a compensating increase in the level of quality and safety for the following reasons:

Removal of defective portions of this piping would require that the piping be isolated and depressurized. The 18-inch piping cannot be isolated for the following reasons:

• Previous attempts to close some of the isolation valves (upstream of the PMCap locations) have not provided adequate isolation of the CCW piping to be able to perform piping repair work. These isolation butterfly valves are leaking by preventing a moisture free environment to allow welding. The proposed weld area for the pipe butt-welds must be dry as required by the FPL Welding Control Manual.

• CCW system isolation to allow maintenance work on the leaking upstream valves, is operationally not possible due to requirements of the CCW system to remain operational at all plant modes (Operable for Modes 1, 2, 3 and 4 per Technical Specification 3.7.2; and functional for Modes 5 and 6 as heat sink for residual heat removal system and for the Spent Fuel pool heat exchangers).

Turkey Point, Unit 4 Fifth 10-Year Interval Relief Request No. 7 Component Cooling Water Welded Repairs for External Corrosion L-2020-104 7

• Installation of a mechanical stop in the 18-inch piping for system isolation is potentially possible. However, installation of a line stop will result in a permanent branch connection on the CCW piping that may require the design of a new support/restraint in an otherwise congested piping area. Also, installation of the new branch line is not entirely desirable because this activity could result in metal shavings due to the boring process and the removed portion of the pipe wall dislodging, entering the system, and becoming debris that could hinder system operation and make it difficult to retrieve the loose foreign material.

• Use of a freeze seal to isolate the 18-inch CCW pipes in order to replace the degraded piping section presents some complications in establishing a freeze plug on this large bore vertical piping with fluid flow in the pipe. The size of the pipe presents some problem with this method and situating the freeze seal equipment in the CCW Heat Exchanger Room is a challenge in the congested piping area. The installed freeze seal equipment on the piping will impose new added design loads on the piping and will require the provision of new or temporary pipe supports and re-analysis of the affected piping portion of the CCW system.

In conclusion, the ASME B & PV Code Section XI requirement, IWD-3120(b), is to correct a component containing a flaw(s). The proposed alternative is to relocate the pressure boundary by restoring the area, with a twenty (20) inch diameter PMCap with a full penetration weld at locations previously confirmed to have adequate material thickness and not correct the piping containing the flaw(s) but show by qualitative assessment that the material and the presence of the postulated worst case flaw(s) will not be detrimental to the pressure retaining function of the component cooling water piping system. For these reasons, Turkey Point believes that the proposed alternative will provide reasonable assurance of continued structural integrity of the subject CCW components.

6.0 DURATION OF PROPOSED ALTERNATIVE The licensee requests approval of the proposed alternative for the remaining life of the plant, as supported by the PMCap design documentation, or until such time that further repair/replacement activities are required for the affected portions of the CCW system piping, whichever occurs first.

Turkey Point, Unit 4 Fifth 10-Year Interval Relief Request No. 7 Component Cooling Water Welded Repairs for External Corrosion L-2020-104 8

7.0 PRECEDENT

1. Duke Energy Carolinas, LLC, Oconee Nuclear Station, Units 1 and 2, Relief Request Serial #15-ON-001, (Agency wide Documents Access and Management System (ADAMS) Accession No. ML15349A453.

2. Florida Power & Light Company, letter L-2020-056, Turkey Point Unit 3 Relief Request No. 6, dated March 30, 2020, as superseded by FPL letters dated April 13 and supplemented by publicly-available letters dated April 15 and 19, 2020, ADAMS Accession Nos. ML20090K520, ML20104B999, ML20106F200, and ML20110A000, respectively, and NRC Verbal approval email, ADAMS Accession No. ML20111A279.

8.0 REFERENCES

1) ASME/ANSI B31.1, 1973 Edition w/Addenda through Winter 1976

2)

American Society of Mechanical Engineers (ASME) Boiler & Pressure Vessel Code,Section XI, 2007 Edition, 2008 Addenda.

3) Federal Register, 85 FR 26540, Volume 85, Number 86, document citation 26540, publication date May 4, 2020, effective date June 3, 2020.

Turkey Point, Unit 4 Fifth 10-Year Interval Relief Request No. 7 Component Cooling Water Welded Repairs for External Corrosion L-2020-104 L-2020-104 Proprietary Information Affidavit Supporting Request for Withholding

U4 Affidavit, R0. Page 1 of 4 U4 AFFIDAVIT, Rev. 0 I, Paul S. Manzon, state as follows:

1. I am the owner of PMC Engineering Solutions, Inc., Pottstown, PA, 19465. I am the inventor and owner of United States Patent 6,860,297, "Local degraded area repair and restoration component for pressure retaining items", and am addressing the proprietary documents listed in (2) below, containing information which is sought to be withheld, and am applying for its withholding.

2. The information sought to be withheld is contained in the following PMC Engineering Solutions, Inc.

documents:

a. PMC Engineering Drawing - PMCap shop fabrication details drawing, U4 CCW Line A and B Train PMCap Restoration Hardware Shop Fabrication Details, Drawing No. 201927-M-0003, R1, Sheets 1 through 6.

b. PMC Engineering Drawing - PMCap installation details drawing, U4 CCW Line A and B Train Piping PMCap Restoration Hardware Installation Details, Drawing No. 201927-M-0004, R1, Sheets 1 through 6.

3. In making this application for withholding of proprietary information of which it is the owner, PMC Engineering Solutions, Inc. relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4) and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) for "trade secrets" (Exemption 4). The information for which exemption from disclosure is here sought also qualifies under the narrower definition of "trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission. 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA.

704F2d1280 (DC Cir. 1983).

4. Some examples of categories of information which fit into the definition of proprietary information are:

a. Information that discloses a process, method, or apparatus, including supporting data and analysis, where prevention of its use by PMC Engineering Solutions, lnc.'s competitors without license from PMC Engineering Solutions, Inc. constitutes an economic advantage over other companies

U4 Affidavit, R0, Page 2 of 4

b. Information which, if used by a competitor, would reduce their expenditure of resources, or improve their competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product

c. Information which reveals aspects of past, present, or future PMC Engineering Solutions, Inc. customer funded development plans and programs, resulting in potential products to PMC Engineering Solutions, Inc.

d. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4) a., (4) b., and (4) d., above.

5. To address 10 CFR 2.390 (b) (4), the information sought to be withheld is being submitted to the NRC in confidence. The information is of a sort customarily held in confidence by PMC Engineering Solutions, Inc., and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by PMC Engineering Solutions, Inc. No public disclosures to third parties including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions which provide for the maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are set forth in paragraphs (6) and (7) following.

6. Approval of proprietary treatment of a document is made by me, Paul S. Manzon, owner of PMC Engineering Solutions, Inc. I am the person most acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to such documents within PMC Engineering Solutions, Inc. is limited on a "need to know" basis.

7. The procedure for approval of external release of such a document requires review by me, Paul S.

Manzon, owner, PMC Engineering Solutions, Inc., for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside PMC Engineering Solutions, Inc. are limited to regulatory bodies, customers, potential customers, and their agents, suppliers, and business and licensees, Authorized ASME Code Nuclear Inspectors, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

U4 Affidavit, R0, Page 3 of 4

8. The documents identified in paragraphs 2.a. and 2.b., above, are classified as proprietary because they contain "know-how" and "unique information" developed by PMC Engineering Solutions, Inc. within our product development programs. The development of these documents, supporting methods, and information constitutes a major PMC Engineering Solutions, Inc. asset in this current market. Supporting aspects for the application to withhold information specific to each of the document containing proprietary information are as follows:

a. U4 CCW Line A and B Train PMCap Restoration Hardware Shop Fabrication Details, Drawing No. 201927-M-0003, R1, Sheets 1 through 6.

i.

Drawing 201927-M-0003, Revision 1, Sheets 1 through 6, contains specific shop fabrication details required to construct ASME B31.1 Code Safety-Related restoration hardware (PMCaps). The development of these shop fabrication details applicable to and supporting ASME B31.1 Code Safety-Related material, design, fabrication, examination, and testing requirements are a major PMC Engineering Solutions, Inc. asset in this current market. These shop fabrication details were developed at a very high level of effort and expense over the past several years during which PMC Engineering Solutions, Inc. has been offering the nuclear power industry its comprehensive PMC Restoration Method (U.S. Patent 6,860,297) products and services which include those protected by U.S. Patent 6,860,297.

b. U4 CCW Line A and B Train Piping PMCap Restoration Hardware Installation Details, Drawing No. 201927-M-0004, R1, Sheets 1 through 6.

i.

Drawing 201927-M-0004, Revision 1, Sheets 1 through 6, contains specific field installation details required to install ASME Section Ill, Code stamped restoration hardware (PMCaps). The development of these field installation details applicable to and supporting ASME Section Ill Code compliance of the PMCaps and the pipe with PMCaps installed are a major PMC Engineering Solutions, Inc. asset in this current market. These installation details were developed at a very high level of effort and expense over the past several years during which PMC Engineering Solutions, Inc. has been offering the nuclear power industry its comprehensive PMC Restoration Method (U.S. Patent 6,860,297) products and services which include those protected by U.S. Patent 6,860,297.

9. The entirety of the information contained in the documents listed in paragraphs 2.a. and 2.b.,

above, is sought to be withheld from Public Disclosure under 10 CFR 2.390:

U4 Affidavit, R0, Page 4 of 4

10. Public disclosure of the information sought to be withheld is likely to cause substantial harm to PMC Engineering Solutions, lnc.'s competitive position and foreclose or reduce availability of profit-making opportunities. The information is part of PMC Engineering Solutions, lnc.'s comprehensive PMC Restoration Method products and services offerings which include those protected by U.S. Patent 6,860,297, and its commercial value extends beyond the original development costs. The value of the technology base goes beyond the information contained in the documents and includes development of the expertise to determine and apply the appropriate data, requirements, criteria, limitations, approaches and methodologies used in the development and preparation of the design, design details, and supporting documentation for the restoration covered by the information sought to be withheld.

The research, development, engineering, and analytical costs comprise substantial investment of time and money by PMC Engineering Solutions, Inc.

The precise value of the expertise to devise a restoration method and apply the appropriate and correct Code and regulatory requirements to the restoration is difficult to quantify, but it clearly is substantial.

PMC Engineering Solutions, lnc.'s competitive advantage will be lost if its competitors are able to use the results of the PMC Engineering Solutions, Inc. experience to develop or modify their own restoration method or if they are able to claim an equivalent understanding by demonstrating that they can develop the same or similar restoration method.

The value of this information to PMC Engineering Solutions, Inc. would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive PMC Engineering Solutions, Inc. of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing these very valuable analytical tools.

I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.

Sincerely, Paul S. Manzon

__08.11.2020__

Owner Date PMC Engineering Solutions, Inc.