ML17055C360

Submittal of Supplement to Proposed Alternative to ASME Section XI, Requirements for Repair/Replacement of Buried Circulating and Service Water Class 3 Piping with Carbon Fiber Reinforced Polymer

ML17055C360
Person / Time
Site:	Surry
Issue date:	02/23/2017
From:	Mark D. Sartain Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML17055C525	List: ML17055C360
References
Download: ML17055C360 (8)

Text

PROPRIETARY INFORMATION-WITHHOLD UNDER 10 CFR 2.390 VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 February 23, 2017 10 CFR 50.55a United States Nuclear Regulatory Commission Attention:

Document Control Desk Washington, D.C. 20555 Serial No.: NRNGDM: Docket Nos.: License Nos.: VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)

SURRY POWER STATION UNITS 1AND2 17-060 R1 50-280/281 DPR-32/37 SUPPLEMENT TO PROPOSED ALTERNATIVE TO ASME SECTION XI REQUIREMENTS FOR REPAIR/REPLACEMENT OF BURIED CIRCULATING AND SERVICE WATER CLASS 3 PIPING WITH CARBON FIBER REINFORCED POLYMER By letter dated December 14, 2016 (Serial No.16-448), Dominion submitted a proposed inservice inspection (ISi) alternative request in accordance with 10 CFR 50.55a(z)(1) to allow the use of a Carbon Fiber Reinforced Polymer (CFRP) system for the internal repair of buried Circulating Water (CW) and Service Water (SW) systems' piping at Surry Power Station (Surry) Units 1 and 2. By letter dated February 6, 2017, the NRC provided Dominion an opportunity to supplement the proposed alternative request identified above by providing:

1) specific analyses or technical evaluations demonstrating the structural integrity of the separate CFRP pipe repairs, and 2) the justification and rationale for the use of the Load and Resistance Factor Design methodology for safety related ASME Class 3 piping, and a discussion of the analysis method used in the original design for Class 3 CW and SW piping, and any variances from applying both methods. Dominion's response to the NRC's request for supplemental information is provided in Attachment

1. The supplemental technical information provided in Attachment 1 for the proposed alternative request was prepared by Simpson Gumpertz & Heger, Inc., and contains information proprietary to that company. Therefore, this information is supported by an affidavit, signed by Simpson Gumpertz-&

Heger, Inc., the owner of the information.

The affidavit sets forth the bases 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 2.390 of the Commission's regulations.

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

The affidavit is included in the Simpson Gumpertz & Heger, Inc. letter to the NRC entitled, "Withholding of Certain Proprietary Information Pursuant to 10 CFR 2.390," dated February 17, 2017. The Simpson Gumpertz & Heger, Inc. authorization letter is provided in Attachment

2. In conformance with the requirements ATTACHMENT 1 CONTAINS PROPRIETARY INFORMATION THAT IS BEING WITHHELD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390. UPON SEPARATION OF ATTACHMENT 1, THIS LETTER IS DECONTROLLED. .

Serial No.17-060 Docket Nos. 50-280/281 Supplemental Response CFRP Alternative Request Page 2 of 3 of 10 CFR 2.390 concerning the protection of proprietary information, the proprietary information included in Attachment 1 is considered to be proprietary in its entirety and has been marked in the manner authorized by 10 CFR 2.390(b)(1)(i)(A).

One editorial correction is also noted in Dominion's December 14, 2016 submittal.

Specifically, the submittal cover letter stated the date of the Structural Group, Inc., letter to the NRC entitled, "Application for Withholding Proprietary Information from Public Disclosure," which was included in Enclosure 10 of that letter, was dated November 23, 2015. The correct date is November 23, 2016. If you have any questions or require additional information, please contact Mr. Gary D. Miller at (804) 273-2771.

Sincerely, Mark Sartain Vice President

-Nuclear Engineering and Fleet Support Commitments contained in this correspondence:

None Attachments

1. Supplemental Response, Alternative Request to Use Carbon Fiber Reinforced Polymer System for the Internal Repair of Buried Circulating and Service Water Piping [PROPRIETARY]

2. Application for Withholding Proprietary Information from Public Disclosure cc: U.S. Nuclear Regulatory Commission

-Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 NRC Senior Resident Inspector Surry Power Station Ms. K. R. Cotton Gross NRC Project Manager-Surry U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 0-8 G9A 11555 Rockville Pike Rockville, Maryland 20852 Ms. B. L. Mozafari NRC Project Manager-North Anna U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 0-8 H12 11555 Rockville Pike Rockville, Maryland 20852 Serial No.17-060 Docket Nos. 50-280/281 Supplemental Response CFRP Alternative Request Page 3 of 3 Attachment 2 Serial No.17-060 Docket Nos. 50-280/281 Supplemental Response CFRP Alternative Request APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION

• FROM PUBLIC DISCLOSURE Virginia Electric and Power Company (Dominion)

Surry Power Station Units 1 and 2 I I 17 February 2017 U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD 20852 SIMPSON GUMPERTZ &. HEGER I Engineering of Slruclures and Building foclosures

Subject:

Withholding of Certain Proprietary Information Pursuant to 10 CFR 2.390 .

Reference:

(1) Supplemental Response to Letter from Virginia Electric; and Power Company to US NRC, "Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Circulating and service Water Class 3 Buried Piping in Accordance with 10 CFR 50.55a(z)(1

),'; Docket Nos. 50-280 and 50-281, Serial No.16-448. . Document No.: 161295-SGH-L-002 In Reference (1), Virginia Electric and Power Company (VEP) will provide a submittal to the U:S. Nuclear Regulatory Commission (NRG) that contains certain proprietary information owned by Simpson Gumpertz & Heger Inc. (SGH). SGH provided the information to VEP or a VEP affiliate to support the request made iri Reference (1 ); and VEP is authorized to use this information. .As explained in the attached affidavit, SGH'.s proprietary information contained in Reference (1) qualifies for withholding*

under the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 U.S.C. Section 552(b)(4), the Trade Secrets Act,* 18 U.S.G. Section 1905, an.d NRG regulations 10 GFR 9.17(a)(4) and 2 .. 390(a)(4) for trade secrets and commercial information.

SGH respectfully requests that the NRC withhold this information from public disclosure.

An affidavit supporting this request is attached.

Please contact me by phone at 781.907 .. 9231 or email at RPOjdrovic@sgh.com if you have any questions concerning this request..

Kind regards, Rasko P. Ojdrovic Vice President and Senior Principal Simpson Gumpertz & Heger Inc.

Attachment:

1 o CFR 2.390 Affidavit SIMPSON GUMPERTZ & HEGER INC. Seyon Stmel. Building.

l. Suite 500. Waltham. MA 02453 main: 181.907.9000 10.: 781.907.9009 www.5gh.com Boslon I I Haus.ton I New York I Son Francisco I

California I Woshington.

DC 10 CFR: 2.390 Affidavit

\\\DC. OJSl2()/000001.

JIS2313 vi SIMPSON GUMPERTZ & HEGERINC.

10 CFR 2.390 AFFIDAVIT OF RASKO P. OJDROVIC AFFIDAVIT I, Rasko P. Ojdrovic, hereby state as follows: {l) I am the Vice President and Senior Principal of Simpson Gumpertz & Heger Inc. {SGH), and I have been authorized to execute this affidavit on behalf of SGH. (2) Virginia Electric and Power Company will submit a transmittal to the US NRC entitled "Supplement to Proposed Alternative to ASME Section XI Requirements for Repair/Replacement of Buried Chculatingand Service Water Class 3 Piping with Carbon Fiber Reinforced Polymer" Docket Nos.

and 50-281, Serial No.17-060. Certain portions of that transmittal contain proprietary information owned by SGH. This information should be held in confidence by the NRC arid withheld from public disclosure.

The following is a list of the SOH proprietary information in Virginia Electric and Power Company's transmittal that SGH requests be withheld:

• Attachment 1, Supplemental Response, Alternative Request to Use Carbon Fiber Reinforced Polymer System for the Repair of Buried Circulating and Service Water Piping (3) In making this application for withholding of proprietary information of which it .is the owner, SGH believes that the information qualifies for withholding under the exemption from disclosure set forth in .the Freedom oflnforniation Act ("FOIA"), 5 U.S.C. Section 552(b)(4), the Trade Secrets Act, 18 U.S.C. Section 1905, and NRC regulations 10 CFR 9. 17(a)(4) and 2.390(a)(4) for trade secrets and commercial information be.cause:

1. This information is and has been held in confidence by SGH. ii. This information is of a type that is customarily held in confidence by SGH, and there is a rational basis for doing so because the information includes proprietary information that was developed and compiled by SGH at a significant cost to SGH. This information is classified as proprietary because it contains information relevant to analytical approaches and methodologies not available elsewhere.

m. The. information is being transmitted to the NRC voluntarily and in confidence.

iv. This information is not available in public sources and couid not be gathered readily from other publicly available information.

v. A substantial effort has been expended by SGH to develop and evaluate this information.

Public release ofthis information could lead to additional significant cost to SGH and is likely to cause substantial harm to SGH's competitive position and foreclose or redu.ce the ayailability of profit-making opportunities.

The value of this information to SGH would be lost or devalued if the information wete disclosed to the public. Affidavit Page 1 \\\DC* OJS 120/000001

• 3152313 vi vi. Public disclosure of the information sought to be withheld would provide other parties, including competitors, with valuable information.

SGH's competitive advantage would be lostif its competitors are able to use the results of SOI-I's activities to aid their own commercial activities.

For example, SGH's competitive advantage would be lost if its competitors are able to use the results of SGH' s analyses to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

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 SGH of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment.

vii. The commercial value of the information extends beyond the original development cost, and includes development of the expertise to determine and apply the appropriate evaluation process to the information.

The research, development, engineering, and analytical costs thatwent into generating this . information comprise a substantial investment of time and money by SGH. The precise value of this information is difficult to quantify, but clearly is substantial.

I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on 17, 2017.

Rasko P.

Affidavit Page 2 \\\DC ,*0351201000001*3152313 vi