DCL-15-101, ASME Section XI Inservice Inspection Program Request for Relief NDE-SG-MS-IR, Main Steam Nozzle Inner Radius Examination Impracticality

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ASME Section XI Inservice Inspection Program Request for Relief NDE-SG-MS-IR, Main Steam Nozzle Inner Radius Examination Impracticality
ML15236A376
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 08/24/2015
From: Allen B S
Pacific Gas & Electric Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML15237A188 List:
References
DCL-15-101
Download: ML15236A376 (28)
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Text

Attachment 1 to the Enclosure contains Proprietary Withhold Under 10 CFR 2.390 Pacif i c Gas and E l ectric Company August24,2015 PG&E Letter DCL-15-1 01 B arry S. Allen Vice President, Nuclear Services Diablo Canyon Power Plant Mail Code 104/6 P. 0. Box 56 Avila Beach, CA 93424 805.545.4888 Internal:

691.4888 Fax: 805.545.6445 10 CFR 50.55a U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Power Plant (DCPP) Units 1 and 2 ASME Section Xllnservice Inspection Program Request for Relief NDE-SG-MS-IR.

Main Steam Nozzle Inner Radius Examination Impracticality Dear Commissioners and Staff: Pursuant to 10 CFR 50.55a(g)(5)(iv), Pacific Gas and Electric Company (PG&E) hereby requests NRC approval of lnservice Inspection (lSI) Request for Relief NDE-SG-MS-IR for the Diablo Canyon Power Plant (DCPP) Units 1 and 2 third lSI interval.

The request is associated with the impracticality of applying the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI volumetric examination requirements for inside radius examinations of Class 2 pressure retaining main steam nozzles in the replacement steam at DCPP. The details of the request are included in the Enclosure.

Attachment 1 to the Enclosure contains information that is proprietary to Westinghouse.

Attachment 1 includes a copy of L TR-CDA-15-5-P, "Information to Support Diablo Canyon Units 1 and 2 Request for Relief from the Nuclear Regulatory Commission from Inspection of the Main Steam Nozzle Inner Radius Examination (Proprietary)." Attachment 2 to the Enclosure contains nonproprietary version of Westinghouse information from Attachment

1. Attachment 3 to the Enclosure includes a copy of CAW-15-4250, the Westinghouse Application for Withholding Proprietary Information from Public Disclosure, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice. Attachment 1 to the Enclosure contains Proprietary Information When separated from Attachment 1 , this document is decontrolled.

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

  • Diablo Canyon
  • Palo Verde
  • Wolf Creek Attachment 1 to the Enclosure contains Proprietary Withhold Under 1 0 CFR 2. 390 Document Control Desk August 24, 2015 Page 2 PG&E Letter DCL-15-101 The document, L TR-CDA-15-5-P, was prepared and classified as Westinghouse Proprietary Class 2. Westinghouse requests that the document be considered proprietary.

The document, L TR-CDA-15-5-P, contains information proprietary to Westinghouse Electric Company LLC, and it is supported by an affidavit signed by Westinghouse, the owner of the information.

The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's Regulations.

Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.

Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse affidavit should reference CAW-15-4250 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. PG&E requests approval of NDE-SG-MS-IR by August 24, 2016. PG&E makes no regulatory commitments (as defined by NEI 99-04) in this letter. If you have any questions regarding the information enclosed, or other lSI program activities, please contact Mr. Hossein G. Hamzehee at (805) 545-4720.

Sincerely, Vice President, Nuclear Services rntt/4231/50033145-99 Enclosure cc: Diablo Distribution cc/enc: Marc L. Dapas, NRC Region IV Administrator Siva P. Lingam, NRC Project Manager Gonzalo L. Perez, Branch Chief, California Department of Public Health John P. Reynoso,* NRC Acting Senior Resident Inspector State of California, Pressure Vessel Unit Attachment 1 to the Enclosure contains Proprietary Information When separated from Attachment 1, this document is decontrolled. A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

  • Diablo Canyon
  • Palo Verde

--lnservice Inspection Impracticality--

Table of Contents 1. ASME Code Component(s)

Affected 2. Applicable Code Edition and Addenda 3. Applicable Code Requirement

4. Impracticality of Compliance
5. Burden Caused by Compliance
6. Proposed Alternative and Basis for Use 7. Duration of Proposed Alternative
8. Precedents ATTACHMENTS Attachment 1: Westinghouse document (Proprietary)

Attachment 2: Westinghouse document (Nonproprietary)

Attachment 3: Westinghouse Letter No. CAW-15-4250:

Application for Withholding Proprietary Information from Public Disclosure 1 Attachment 1 to the Enclosure contains Proprietary Information When separated from Attachment 1, this document is decontrolled.

Attachment 1 to the Enclosure contains Proprietary Withhold Under 10 CFR 2.390 Enclosure PG&E Letter DCL-15-101 10 CFR 50.55a Relief Request NDE-SG-MS-IR Main Steam Nozzle Inner Radius Examination Impracticality Relief Request in Accordance with 10 CFR 50.55a(g)(5)(iv)

--lnservice Inspection Impracticality--

1. American Society of Mechanical Engineers Code Components Affected American Society of Mechanical Engineers (ASME)Section XI Class 2 steam generator nozzle inner radius. See Figures 1, 2 and 3 for general configuration and material information.

Code Cat./ Description Part Examined Item No. C-8 I C2.22 Replacement Steam Nozzle Inside Radius Section Generator Main Steam Nozzles 2. Applicable Code Edition and Addenda The Diablo Canyon Power Plant (DCPP) third lnservice Inspection Interval Program Plan (ISIPP) is based on the ASME Boiler and Pressure Vessel Code,Section XI, 2001 Edition with Addenda through 2003. The DCPP Unit 1 third inspection interval commenced on January 1, 2006, and nominally ended on May 6, 2015. The DCPP Unit 2 third inspection interval commenced on July 1, 2006, and is nominally scheduled to end on March 12, 2016. Actual end dates of the intervals are dependent on the completion dates of the 19th refueling outages for each unit, in accordance with ASME Section XI, paragraph IWA-2430(d)(1

). 3. Applicable Code Requirement ASME Section XI requires that volumetric examination of the inside-radius section of nozzles at terminal ends of piping runs be performed in accordance with Figure IWC-2500-4(a), (b), or (d) each inspection interval.

The applicable nozzles include those welded to or integrally cast in vessels that connect to piping runs selected for examination under Examination Category C-F (manways and handholes are excluded).

2 Attachment 1 to the Enclosure contains Proprietary Information When separated from Attachment 1, this document is decontrolled.

Attachment 1 to the Enclosure contains Proprietary Withhold Under 10 CFR 2.390 4. Impracticality of Compliance Enclosure PG&E Letter DCL-15-1 01 The DCPP replacement steam generator (RSG) main steam outlet nozzles are a flow limiting design that is comprised of a set of seven holes bored parallel to the nozzle centerline in the one-piece elliptical top head forging. Venturi inserts are installed in each of the bore holes and attached by welding to 0.25" thick weld deposited cladding.

See Figures 1, 2 and 3 for sketches of the general nozzle configuration and materials of construction.

As depicted in Figures 1, 2 and 3, the configuration of the main steam outlet nozzles does not correspond to the examples shown in Code Figures IWC-2500-4(a), (b), or (d), nor does it incorporate a single large radius transition as shown in each of the ASME Code figures. The multiple bore hole with welded venturi design results in a complex internal profile that precludes meaningful ultrasonic examination.

Attachment 1 contains information about the main steam nozzle design extracted from WCAP-16816-P, Revision 1 (Westinghouse Proprietary Class 2). The figures selected show the vessel layout including the main steam nozzle location and configuration in the top elliptical head. Figure 7-21 depicts the limiting stress locations in the steam outlet nozzle and Figure 7-23 depicts the limiting stress locations in the flow limiting insert weld region. The associated Tables 7-38 and 7-39 respectively present the stress analysis summaries with reference to the limiting stress locations depicted in the Figures. Note 1 to Table 7-39 refers to "Reference 16," which is titled, "CN-NCE-DCPPRSG-14, 'Steam Outlet Nozzle Elliptical Head and Upper Shell Analysis,'

Delta 54 Replacement Steam Generator, Diablo Canyon Power Plant Units 1 and 2, Revision 1, February 2008." 5. Burden Caused by Compliance Compliance with Code requirements would require redesign and modification of the RSG main steam nozzles. This action would result in removal of the flow limiting design feature of the RSGs that is specifically intended to improve safety by limiting blowdown in the event of a main steam line break and therefore is unwarranted.

6. Proposed Alternative and Basis for Use Due to their flow restrictor-type design, the DCPP RSG main steam outlet nozzles do not contain a high-stress inside-radius section for which the Section XI volumetric examination is intended.

As a result of the multiple flow restrictor orifice nozzle design configuration, volumetric examination 3 Attachment 1 to the Enclosure contains Proprietary Information When separated from Attachment 1, this document is decontrolled.

Attachment 1 to the Enclosure contains Proprietary Withhold Under 10 CFR 2.390 Enclosure PG&E Letter DCL-15-1 01 is impractical for the DCPP RSGs and no alternative volumetric examinations are proposed. Code required VT -2 examination of the RSGs are performed each inspection period during the system leakage test. 7. Duration of Proposed Alternative Relief is requested for the remainder of the DCPP Units 1 and 2 third inservice inspection (lSI) intervals.

The DCPP Unit 1 third inspection interval nominally ended on May 6, 2015. The DCPP Unit 2 third inspection interval is nominally scheduled to end on March 12, 2016. Actual end dates of the interval are dependent on the completion dates of the 19th refueling outages for each unit, in accordance with ASME Section XI, paragraph IWA-2430(d)(1).

8. Precedents
1. NRC letter to Seabrook Station, dated June 27, 2012: Seabrook Station, Unit No. 1 -Request for Relief 31R-1, Examination Category C-8 Pressure Retaining Nozzle Welds in Vessels (TAC No. ME7257) (ML 120880245)
2. NRC letter to South Texas Project dated April 20, 2011: South Texas Project, Units 1 and 2-Request for Relief RR-ENG-3-01 from ASME Section XI Code Requirements for Steam Generator Nozzle Destructive Examination (TAC Nos. ME4766 and ME4767) (ML 11 0980347) 4 Attachment 1 to the Enclosure contains Proprietary Information When separated from Attachment 1 , this document is decontrolled.

Attachment 1 to the Enclosure contains Proprietary W i thhold Under 10 CFR 2.390 GIRTH WELD SEAM NO. B GIRTH WELD SEAM NO.7 GIRTH WELD SEAM N0.6 GIRTH WELD SEAM NO.5 GIRTH WELD SEAM ND. 4 G l RTH WELD SEAM NO.3 GIRTH WELD SEAM NO.2 !'A' ..... I BARREL " J' BARREL 'H' TRANS l T l ON CONE BARREL 'A' I FW-33.0 I

  • 0 I I FOR TRUE ORIENTATION SEE VIEWS FROM 'A' AND 'B' Enclosure PG&E Letter DCL-15-1 01 I / (Y)---______ -,/, I \ / I ' I \ \ VIEW FROM 11 A 11 (I /35) 0 I >A" <f> -A" VIEW FROM 11 8 11 ( I /35) Figure 1: RSG -General Arrangement Drawing 5 Attachment 1 to the Enclosure contains Proprietary Information When separated from Attachment 1, this document is decontrolled.

Attachment 1 to the Enclosure contains Proprietary Withhold Under 10 CFR 2.390 RSG To p Head P l a n Vi e w Enclosure PG&E Letter DCL-15-1 01 Figure 2: RSG Main Steam Outlet Nozzles -General Configuration 6 Attachment 1 to the Enclosure contains Proprietary Information When separated from Attachment 1, this document is decontrolled.

Attachment 1 to the Enclosure contains Proprietary Withhold Under 10 CFR 2.390 -Enclosure PG&E Letter DCL-15-1 01 / Main Steam Outlet See Detai l Below for Corner and Venturi Attachment Configurat i on Figure 3: RSG Main Steam Outlet Nozzles-Materials of Construction 7 Attachment 1 to the Enclosure contains Proprietary Information When separated from Attachment 1, this document is decontrolled.

Attachment 1 to the Enclosure contains Proprietary Withhold Under 10 CFR 2.390 Attachment 2 PG&E Letter DCL-15-1 01 Westinghouse document -(Non-Proprietary)

L TR-CDA-15-5-NP Information to Support Diablo Canyon Units 1 and 2 Request for Relief from the Nuclear Regulatory Commission from Inspection of the Main Steam Nozzle Inner Radius Examination Attachment 1 to the Enclosure contains Proprietary Information When separated from Attachment 1 , this document is decontrolled.

Westinghouse Non-Proprietary Class 3 Westinghouse Electric Company LTR-CDA-15-5 NP-Attachment Information to Support Diablo Canyon Units 1 and 2 Request for Relief from the Nuclear Regulatory Commission from Inspection of the Main Steam Nozzle Inner Radius Examination July 28, 2015 Authors: Electronically Approved*

Keith D. Taylor, Engineer Nuclear Components Engineering I Verifier:

Electronically Approved*

Keith E. Coe, Engineer Nuclear Components Engineering I Approved:

Electronically Approved*

David P. Lytle for Nicole D. Vitale, Manager Component Design & Analysis This document may contain technical data subject to the export controllcrws of the United States. In the event that this document does contain such information, the Recipient's acceptance of this document constitutes agreement that this information in document form (or any other medium), including any attachments and exhibits hereto, shall not be exported, released or disclosed to foreign persons whether in the United States or abroad by recipient except in compliance with all US. export control regulations.

Recipient shall include this notice with any reproduced or excerpted portion of this document or any document derived from, based on, inc01porating , using or relying on the information contained in this document. © 2015 Westinghouse Electric Company LLC All Rights Reserved *Electronically Approved Records are Authenticated in the Electronic Document Management System. Page 1 of 11 Attachment 1 Figure from WCAP-16816-P, 1 Figure 7-21 Limiting Stress Locations in the Steam Outlet Nozzle Page 2 of 11 LTR-CDA-15-5 NP-Attachment a,c,e Attachment 2 Figure from WCAP-16816-P, Revision 1 Figure 7-23 LTR-CDA-15-5 NP-Attachment a,c,e Limiting Stress Locations in the Flow Limiting Insert Weld Region Page 3 of 11 Attachment 3 Figure from WCAP-16816-P, Revision 1 Table 7-38 Stress Analysis Summary LTR-CDA-15-5 NP-Attachment for the Steam Outlet Nozzle, Elliptical Head, Separator Support Ring and Upper Shell ASN 1 ASN2 Loading Stress Stress Allow Ratio Stress Allow Ratio Condition Category (ksi) (ksi) (ksi) (ksi) Design Pm PL Pm + Pb Triaxial cr Normal and Upset (Service PL + pb + Q Level A and B) and Test-RSG Fatigue Program Usage Normal and Upset (Service PL + pb + Q Level A and B) and Test-Tavg Fatigue Window Program Usage Faulted (Service Level D) Pm PL Pm + Pb Test Pm PL Pm + Pb Triaxial cr -ASN3 ASN4 Loading Stress Stress Allow Ratio Stress Allow Ratio Condition Category (ksi) (ksi) (ksi) (ksi) Design Pm PL Pm + Pb Triaxial cr Normal and Upset (Service PL + pb + Q Level A and B) and Test-RSG Fatigue Program Usage Normal and Upset (Service PL + pb + Q Level A and B) and Test-Tavg Fatigue Window Program Usage Faulted (Service Level D) Pm PL Pm + Pb Test Pm PL Pm + Pb Triaxial cr -Page 4 of 11 a,c,e -a.c.e -

Attachment 3 (Continued)

Figure from WCAP-16816-P, Revision 1 Table 7-38 (Continued)

Stress Analysis Summary LTR-CDA-15-5 NP-Attachment for the Steam Outlet Nozzle, Elliptical Head, Separator Support Ring and Upper Shell ASN 5 Loading Stress Stress Allow Ratio a,c,e Condition Category (ksi) (ksi) Design Pm PL Pm + Pb Triaxial cr Normal and Upset (Service PL + pb + c Level A and B) and Test -RSG Fatigue Program Usage Normal and Upset (Service PL + pb + c Level A and B) and Test -Tavg Fatigue Window Program Usage Faulted (Service Level D) Pm PL Pm + Pb Test Pm PL Pm + Pb Triaxial cr '--Notes: 1. The triaxial stresses are negative at these sections.

Page 5 ofll Attachment 4 Figure from WCAP-16816-P, Revision 1 Table 7-39 Stress Analysis Summary for the Steam Outlet Nozzle Flow Limiting Insert Weld Region ASN V1 Loading Stress Stress Allow Ratio Stress Condition Category (ksi) (ksi) (ksi) Design Pm r--PL Pm + Pb Triaxial a Normal and Upset (Service PL + pb + Q Level A and B) and Test-Fatigue RSG Program Usage Normal and Upset (Service PL + pb + Q Level A and B) and Test-Fatigue Tavg Window Program Usage Faulted(1 J (Service Level D) Pm PL Pm + Pb Test Pm PL Pm + Pb Triaxial a -ASNV3 Loading Stress Stress Allow Ratio Stress Condition Category (ksi) (ksi) (ksi) Design Pm PL Pm + Pb Triaxial a Normal and Upset (Service PL + pb + Q Level A and B) and Test-Fatigue RSG Program Usage Normal and Upset (Service PL + pb + Q Level A and B) and Test-Fatigue Tavg Window Program Usage Faulted(1 J (Service Level D) Pm PL Pm + Pb Test I Pm I PL I Pm_+ Pb Triaxial a ....__ LTR-CDA-15-5 NP-Attachment ASNV2 Allow (ksi) ASNV4 Allow (ksi) Ratio Ratio Notes: 1. All conditions except Faulted Conditions produce negligible primary stresses as stated in Section 12.6 of Reference

16. Page 6 of 11 a ,c,e -r----a ,c,e -

Attachment 5 Figure from WCAP-16815-P, Revision 3 Figure 7-21 Limiting Stress Locations in the Steam Outlet Nozzle Page 7 of 11 LTR-CDA-15-5 NP-Attachment a,c,e Attachment 6 Figure from WCAP-16815-P, Revision 3 Figure 7-23 LTR-CDA-15-5 NP-Attachment Limiting Stress Locations in the Flow Limiting Insert Weld Region Page 8 of 11 a.c.e Attachment 7 Figure from WCAP-16815-P, Revision 3 Table 7-38 Stress Analysis Summary LTR-CDA-15-5 NP-Attachment for the Steam Outlet Nozzle, Elliptical Head, Separator Support Ring and Upper Shell ASN 1 ASN2 Loading Stress Stress Allow Ratio Stress Allow Ratio Condition Category (ksi) (ksi) (ksi) (ksi) Design Pm -PL Pm + Pb Triaxial cr Normal and Upset (Service PL + pb + Q Level A and B) and Test-RSG Fatigue Program Usage Normal and Upset (Service PL + pb + Q Level A and B) and Test-Tavg Fatigue Window Program Usage Faulted (Service Level D) Pm PL Pm + Pb Test Pm PL Pm + Pb Triaxial cr -ASNJ ASN4 Loading Stress Stress Allow Ratio Stress Allow Ratio Condition Category (ksi) (ksi) (ksi) (ksi) Design Pm PL Pm + Pb Triaxial cr Normal and Upset (Service PL + pb + Q Level A and B) and Test-RSG Fatigue Program Usage Normal and Upset (Service PL + pb + Q Level A and B) and Test-Tavg Fatigue Window Program Usage Faulted (Service Level D) Pm PL Pm + Pb Test Pm PL Pm + Pb Triaxial cr '----Page 9 of 11 a,c,e ---a,c,e -

Attachment 7 (Continued)

Figure from WCAP-16815-P, Revision 3 Table 7-38 (Continued)

Stress Analysis Summary LTR-CDA-15-5 NP-Attachment for the Steam Outlet Nozzle, Elliptical Head, Separator Support Ring and Upper Shell ASN 5 Loading Stress Stress Allow Ratio Condition Category (ksi) (ksi) a,c,e Design Pm PL Pm + Pb Triaxial cr Normal and Upset (Service PL + pb + Q Level A and B) and Test -RSG Fatigue Program Usage Normal and Upset (Service PL + pb + Q Level A and B) and Test -Tavg Fatigue Window Program Usage Faulted (Service Level D) Pm PL Pm + Pb Test Pm PL Pm + Pb Triaxial cr -Notes: 1. The triaxial stresses are negative at these sections.

Page 10 of 11 Attachment 8 Figure from WCAP-16815-P, Revision 3 Table 7-39 Stress Analysis Summary for the Steam Outlet Nozzle Flow Limiting Insert Weld Region ASN V1 Loading Stress Stress Allow Ratio Stress Condition Category (ksi) (ksi) (ksi) Design Pm PL Pm + Pb Triaxial a Normal and Upset (Service PL + pb + Q Level A and B) and Test-Fatigue RSG Program Usage Normal and Upset (Service PL + pb + Q Level A and B) and Test-Fatigue Tavg Window Program Usage Faulted(1) (Service Level D) Pm PL Pm + Pb Test Pm PL Pm + Pb Triaxial a '----ASN V3 Loading Stress Stress Allow Ratio Stress Condition Category (ksi) (ksi) (ksi) Design Pm PL Pm + Pb Triaxial a Normal and Upset (Service PL + pb + Q Level A and B) and Test-Fatigue RSG Program Usage Normal and Upset (Service PL + pb + Q Level A and B) and Test-Fatigue Tavg Window Program Usage Faulted(1) (Service Level D) Pm PL Pm + Pb Test Pm PL Pm + Pb Triaxial a -LTR-CDA-15-5 NP-Attachment ASNV2 Allow (ksi) ASNV4 Allow (ksi) Ratio Ratio Notes: 1. All conditions except Faulted Conditions produce negligible primary stresses as stated in Section 12.6 of Refer e n c e 16. Page 11 of 11 a.c.e -a.c.e -

Attachment 1 to the Enclosure contains Proprietary Withhold Under 10 CFR 2.390 Attachment 3 PG&E Letter DCL-15-101 Westinghouse Letter No. CAW-15-4250:

Application for Withholding Proprietary Information from Public Disclosure Attachment 1 to the Enclosure contains Proprietary Information When separated from Attachment 1 , this document is decontrolled.

I @

U.S. Nuclear Commission Document Control IJ>esk 11555 Rockville Rockville, MD 208 2 Westinghouse Electric Company 1 000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA Direct tel: (412) 374-4643 Direct fax: (724) 940-8560 e-mail: greshaja@westinghouse.com Proj letter: PGE-15-70 CAW-15-4250 July 29, 2015 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

LTR-CD,A-15-5 P-Attachment, Information to Support Diablo Canyon Units 1 and 2 Request for the Nuclear Regulatory Commission from Inspection of the Main Steam Nozzle Inner Radius Examination" (Proprietary)

The proprietaty i l ormation for which withholding is being requested in the above-referenced report is further identified l n Affidavit CAW-15-4250 signed by the owner of the proprietary information, Westinghouse EI J ctric Company LLC. The Affidavit, which accompanies this letter, sets forth the basis on which the inf 9b nation 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.

i Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Pacific Gas and Electric Compaby. Corresponden d e with respect to the proprietary aspects of the Application for Withholding or the Westinghouse J\ffidavit should reference CAW 4250, and should be addressed to James A. Gresham, Manager, Reg J iatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 3 Sui f e 310, Cranberry Township, Pennsylvania 16066.

j"Iames A. Gresham , Manager Regulatory Compliance COMMONWEALTH OF PENNSYLVANIA:

COUNTY OF BUTLER: AFFIDAVIT ss CAW-15-4250 July 29, 2015 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 know ledge, information, and be lief. Regulatory Compliance 2 CAW-15-4250 (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 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

3 CAW-15-4250 (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. (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. (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 4 CAW-15-4250 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, it 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 appropriately marked in LTR-CDA-15-5 P-Attachment, "Information to Support Diablo Canyon Units 1 and 2 Request for Relief from the Nuclear Regulatory Commission from Inspection of the Main Steam Nozzle Inner Radius Examination" (Proprietary), for submittal to the Commission, being transmitted by Pacific Gas and Electric Company 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 the preparation of a relief request to the NRC from specific American Society of Mechanical Engineers (ASME) Code ultrasonic inspection requirements of the inner radius of the main steam nozzles of the Diablo Canyon Units 1 and 2 replacement steam generators, and may be used only for that purpose. (a) This information is part of that which will enable Westinghouse to: (i) Support a Pacific Gas and Electric Company response to an NRC Request for Additional Information for Diablo Canyon Units 1 and 2 PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.

In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted).

The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information.

These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(t) of the Affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(l).

COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding.

With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

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