NRC 2016-0030, License Amendment Request for H: Alternate Repair Criteria for Steam Generator Tube Sheet Expansion Region

From kanterella
Revision as of 21:18, 6 May 2019 by StriderTol (talk | contribs) (Created page by program invented by StriderTol)
Jump to navigation Jump to search

License Amendment Request for H: Alternate Repair Criteria for Steam Generator Tube Sheet Expansion Region
ML16237A066
Person / Time
Site: Point Beach NextEra Energy icon.png
Issue date: 07/29/2016
From: Coffey R
Point Beach
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML16256A678 List:
References
NRC 2016-0030
Download: ML16237A066 (179)
v • d • e


Text

A.

&

Page 1 of 19

Page 2 of 19

Page 3 of 19

Page 4 of 19

Page 5 of 19 Page 6 of 19

Page 7 of 19

Page 8 of 19

Page 9 of 19 Page 10 of 19

Page 11 of 19 =12

Page 12 of 19

Page 13 of 19

Page 14 of 19

Page 15 of 19

Page 16 of 19

Page 17 of 19

Page 18 of 19

Page 19 of 19

RCS Operational LEAKAGE 3.4.13 Point Beach 3.4.13-1 Unit 1 - Amendment No. 223 Unit 2 - Amendment No. 229 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.13 RCS Operational LEAKAGE

LCO 3.4.13 RCS operational LEAKAGE shall be limited to:

a. No pressure boundary LEAKAGE;
b. 1 gpm unidentified LEAKAGE;
c. 10 gpm identified LEAKAGE; and
d. 150 gallons per day primary to secondary LEAKAGE through any one steam generator (SG).

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. RCS operational LEAKAGE not within limits for reasons other than pressure boundary LEAKAGE or primary to secondary LEAKAGE.

A.1 Reduce LEAKAGE to within limits.

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> B. Required Action and associated Completion Time of Condition A not met.

OR Pressure boundary LEAKAGE exists.

OR Primary to secondary LEAKAGE not within limit. B.1 Be in MODE 3.

AND B.2 Be in MODE 5.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours RCS Operational LEAKAGE 3.4.13 Point Beach 3.4.13-2 Unit 1 - Amendment No. 253 Unit 2 - Amendment No. 257 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.13.1 ---------------------------NOTES------------------------- 1. Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation.

2. Not applicable to primary to secondary LEAKAGE. --------------------------------------------------------------

Verify RCS Operational LEAKAGE is within limits by performance of RCS water inventory balance.

In accordance with the Surveillance Frequency Control Program

SR 3.4.13.2 ---------------------------NOTE--------------------------- Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation. --------------------------------------------------------------

Verify primary to secondary LEAKAGE is < 150 gallons per day through any one SG.

In accordance with the Surveillance

Frequency Control Program

Programs and Manuals 5.5 5.5 Programs and Manuals Point Beach 5.5-8 Unit 1 - Amendment No. 254 Unit 2 - Amendment No. 258 5.5.8 Steam Generator (SG) Program (continued) for all SGs and leakage rate for an individual SG. Leakage is not to exceed 500 gallons per day per SG.

3. The operational LEAKAGE performance criterion is specified in LCO 3.4.13, RCS Operational LEAKAGE.
c. Provisions for SG tube plugging criteria. Tubes found by inservice inspection to contain flaws with a depth equal to or exceeding 40% of the nominal tube wall thickness shall be plugged.
d. Provisions for SG tube inspections. Periodic SG tube inspections shall be performed. The number and portions of the tubes inspected and methods of inspection shall be performed with the objective of detecting flaws of any type (e.g., volumetric flaws, axial and circumferential cracks) that may be present along the length of the tube, from the tube-to-tubesheet weld at the tube inlet to the tube-to-tubesheet weld at the tube outlet, and that may satisfy the applicable tube plugging criteria. The tube-to-tubesheet weld is not part of the tube. In addition to meeting the requirements of d.1, d.2, and d.3 below, the inspection scope, inspection methods, and inspection intervals shall be such as to ensure that SG tube integrity is maintained until the next SG inspection. A degradation assessment shall be performed to determine the type and location of flaws to which the tubes may be susceptible and, based on this assessment, to determine which inspection methods need to be employed and at what location.
1. Inspect 100% of the tubes in each SG during the first refueling outage following SG installation. 2. i. Unit 1 (alloy 600 Thermally Treated tubes): After the first refueling outage following SG installation, inspect each SG at least every 48 effective full power months or at least every other refueling outage (whichever results in more frequent inspections). In addition, the minimum number of tubes inspected at each scheduled inspection shall be the number of tubes in all SGs divided by the number of SG inspection outages scheduled in each inspection period as defined in a, b, and c below. If a degradation assessment indicates the potential for a type of degradation to occur at a location not previously inspected with a technique capable of detecting this type of degradation at this location and that may satisfy the applicable Programs and Manuals 5.5 5.5 Programs and Manuals Point Beach 5.5-9 Unit 1 - Amendment No. 254 Unit 2 - Amendment No. 258 inspected with such a capable inspection technique during the remainder of the inspection period may be prorated. The fraction of locations to be inspected for this potential type of degradation at this location at the end of the inspection period shall be no less than the ratio of the number of times the SG is scheduled to be inspected in the inspection period after the determination that a new form of degradation could potentially be occurring at this location divided by the total number of times the SG is scheduled to be inspected in the inspection period. Each inspection period defined below may be extended up to 3 effective full power months to include a SG inspection outage in an inspection period and the subsequent inspection period begins at the conclusion of the included SG inspection outage.

a) After the first refueling outage following SG installation, inspect 100% of the tubes during the next 144 effective full power months.

This constitutes the first inspection period; b) During the next 120 effective full power months, inspect 100% of the tubes. This constitutes the second inspection period; c) During the next 96 effective full power months, inspect 100% of the tubes. This constitutes the third inspection period; and

d) During the remaining life of the SGs, inspect 100% of the tubes every 72 effective full power months. This constitutes the fourth and subsequent inspection periods.

3. If crack indications are found in any SG tube, then the next inspection for each affected and potentially affected SG for the degradation mechanism that caused the crack indication shall not exceed 24 effective full power months or one refueling outage (whichever results in more frequent inspections). If definitive information, such as from examination of a pulled tube, diagnostic non-destructive testing, or engineering evaluation indicates that a crack-like indication is not associated with a crack(s), then the indication need not be treated as a crack. e. Provisions for monitoring operational primary to secondary LEAKAGE.

Reporting Requirements 5.6 5.6 Reporting Requirements Point Beach 5.6-7 Unit 1 - Amendment No. 254 Unit 2 - Amendment No. 258 5.6.8 Steam Generator Tube Inspection Report (continued)

e. Number of tubes plugged during the inspection outage for each degradation mechanism,
f. The number and percentage of tubes plugged to date, and the effective plugging percentage in each steam generator, g. The results of condition monitoring, including the results of tube pulls and in-situ testing.

RCS Operational LEAKAGE B 3.4.13 BASES Point Beach B 3.4.13-3 Unit 1 - Amendment No. 223 Unit 2 - Amendment No. 229 LCO (continued)

b. Unidentified LEAKAGE One gallon per minute (gpm) of unidentified LEAKAGE is allowed as a reasonable minimum detectable amount that the containment air monitoring and containment sump level monitoring equipment can detect within a reasonable time period. Violation of this LCO could result in continued degradation of the RCPB, if the LEAKAGE is from the pressure boundary.
c. Identified LEAKAGE Up to 10 gpm of identified LEAKAGE is considered allowable because LEAKAGE is from known sources that do not interfere with detection of unidentified LEAKAGE and is well within the capability of the RCS Makeup System. Identified LEAKAGE includes LEAKAGE to the containment from specifically known and located sources, but does not include pressure boundary LEAKAGE or controlled reactor coolant pump (RCP) seal leakoff (a normal function not considered LEAKAGE). Violation of this LCO could result in continued degradation of a component or system.
d. Primary to Secondary LEAKAGE through Any One SG The limit of 150 gallons per day per SG is based on the operational LEAKAGE performance criterion in NEI 97-06, Steam Generator Program Guidelines (Ref. 3). The Steam Generator Program operational LEAKAGE performance criterion in NEI 97-06 states, The RCS operational primary to secondary leakage through any one SG shall be limited to 150 gallons per day. The limit is based on operating experience with SG tube degradation mechanisms that result in tube leakage. The operational leakage rate criterion in conjunction with the implementation of the Steam Generator Program is an effective measure for minimizing the frequency of steam generator tube ruptures.

APPLICABILITY

In MODES 1, 2, 3, and 4, the potential for RCPB LEAKAGE is greatest when the RCS is pressurized.

In MODES 5 and 6, LEAKAGE limits are not required because the reactor coolant pressure is far lower, resulting in lower stresses and reduced potentials for LEAKAGE.

RCS Operational LEAKAGE B 3.4.13 BASES Point Beach B 3.4.13-6 Unit 1 - Amendment No. 253 Unit 2 - Amendment No. 257 SURVEILLANCE REQUIREMENTS (continued)

SR 3.4.13.2

This SR verifies that primary to secondary LEAKAGE is less or equal to 150 gallons per day through any one SG. Satisfying the primary to secondary LEAKAGE limit ensures that the operational LEAKAGE performance criterion in the Steam Generator Program is met. If this SR is not met, compliance with LCO 3.4.17, Steam Generator Tube Integrity, should be evaluated. The 150 gallons per day limit is measured at room temperature as described in Reference 4. The operational LEAKAGE rate limit applies to LEAKAGE through any one SG. If it is not practical to assign the LEAKAGE to an individual SG, all the primary to secondary LEAKAGE should be conservatively assumed to be from one SG.

The Surveillance is modified by a Note which states that the Surveillance is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation. For RCS primary to secondary LEAKAGE determination, steady state is defined as stable RCS pressure, temperature, power level, pressurizer and makeup tank levels, makeup and letdown, and RCP seal injection and return flows. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. The primary to secondary LEAKAGE is determined using continuous process radiation monitors or radiochemical grab sampling in accordance with the EPRI guidelines (Ref. 4).

REFERENCES

1. FSAR Section 1.3.3.
2. FSAR, Section 14.
3. NEI 97-06, Steam Generator Program Guidelines.
4. EPRI, Pressurized Water Reactor Primary-to-Secondary Leak Guidelines.
5. 10 CFR 50.67, Accident Source Term.

SG Tube Integrity B 3.4.17 Point Beach B 3.4.17-2 Unit 1 - Amendment No. 254 Unit 2 - Amendment No. 258 BASES APPLICABLE The steam generator tube rupture (SGTR) accident is the limiting design SAFETY basis event for SG tubes and avoiding an SGTR is the basis for this ANALYSES Specification. The analysis of a SGTR event assumes a bounding primary to secondary LEAKAGE rate greater than or equal to equal to the operational LEAKAGE rate limits in LCO 3.4.13, RCS Operational LEAKAGE, plus the leakage rate associated with a double-ended rupture of a single tube. The accident analysis for a SGTR assumes the contaminated secondary fluid is released to the atmosphere via safety valves. The analysis for design basis accidents and transients other than a SGTR assume the SG tubes retain their structural integrity (i.e., they are assumed not to rupture.) In these analyses, the steam discharge to the atmosphere is based on the total primary to secondary LEAKAGE from all SGs of 500 gallons per day or is assumed to increase to 500 gallons per day as a result of accident induced conditions. For accidents that do not involve fuel damage, the primary coolant activity level of DOSE EQUIVALENT I-131 is assumed to be equal to the LCO 3.4.16, RCS Specific Activity, limits. For accidents that assume fuel damage, the primary coolant activity is a function of the amount of activity released from the damaged fuel. The dose consequences of these events are within the limits of GDC 19 (Ref. 2), and 10 CFR 50.67 (Ref. 3) dose guideline limit.

Steam generator tube integrity satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO The LCO requires that SG tube integrity be maintained. The LCO also requires that all SG tubes that satisfy the plugging criteria be plugged in accordance with the Steam Generator Program.

During an SG inspection, any inspected tube that satisfies the Steam Generator Program plugging criteria is removed from service by plugging. If a tube was determined to satisfy the plugging criteria but was not plugged, the tube may still have tube integrity.

In the context of this Specification, an SG tube is defined as the entire length of the tube, including the tube wall, between the tube-to-tubesheet weld at the tube inlet and the tube-to-tubesheet weld at the tube outlet.

The tube-to-tubesheet weld is not considered part of the tube.

A SG tube has tube integrity when it satisfies the SG performance criteria. The SG performance criteria are defined in Specification 5.5.8, Steam Generator Program, and describe acceptable SG tube performance.

SG Tube Integrity B 3.4.17 Point Beach B 3.4.17-4 Unit 1 - Amendment No. 254 Unit 2 - Amendment No. 258 BASES LCO (continued) primary to secondary LEAKAGE induced during the accident. The operational LEAKAGE performance criterion provides an observable indication of SG tube conditions during plant operation. The limit on operational LEAKAGE is contained in LCO 3.4.13, RCS Operational LEAKAGE, and limits primary to secondary LEAKAGE through any one SG to 150 gallons per day. This limit is based on the assumption that a single crack leaking this amount would not propagate to a SGTR under the stress conditions of a LOCA or a main steam line break. If this amount of LEAKAGE is due to more than one crack, the cracks are very small, and the above assumption is conservative.

APPLICABILITY Steam generator tube integrity is challenged when the pressure differential across the tubes is large. Large differential pressures across SG tubes can only be experienced in MODE 1, 2, 3, or 4.

RCS conditions are far less challenging in MODES 5 and 6 than during MODES 1, 2, 3, and 4. In MODES 5 and 6, primary to secondary differential pressure is low, resulting in lower stresses and reduced potential for LEAKAGE.

ACTIONS The ACTIONS are modified by a Note clarifying that the Conditions may be entered independently for each SG tube. This is acceptable because the Required Actions provide appropriate compensatory actions for each affected SG tube. Complying with the Required Actions may allow for continued operation, and subsequent affected SG tubes are governed by subsequent Condition entry and application of associated Required Actions. A.1 and A.2

Condition A applies if it is discovered that one or more SG tubes examined in an inservice inspection satisfy the tube plugging criteria but were not plugged in accordance with the Steam Generator Program as required by SR 3.4.17.2. An evaluation of SG tube integrity of the affected tube(s) must be made. Steam generator tube integrity is based on meeting the SG performance criteria described in the Steam Generator Program. The SG plugging criteria define limits on SG tube degradation that allow for flaw growth between inspections while still providing assurance that the SG performance criteria will continue to be met. In order to determine if a SG tube that should have been plugged has tube integrity, an evaluation must be completed that demonstrates that the SG performance criteria will continue to be met until the next refueling outage or SG tube inspection. The tube integrity determination

Westinghouse Non-Proprietary Clnss 3 U.S. Nuclear Regulatory Commission Document Control Desk 1 155 5 Rockville Pike Rockville, MD 20852 Direct tel: (412) 374-4643 Direct fax; (724) 940-8560 gresbaja@wcstinghouse.com NEXT-16-39 CA W-16-4388 March 23,2016 APPUCA TION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DlSCL,QSUB,P-.

Subject:

WCAP-18089-P, Revision 0, "Point Beach Unit 1 Steam Generator Tube Alternate Repair Criterion H*" (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)( of Section 2.390 of the Commission's regulations.

It contains commercial strategic infonnation proprietary to Westinghouse and customarily held in confidence.

The proprietary infonnation for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW 4388 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 the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanyiing Affidavit by NextEra Energy Point Beach. Correspondence with respect to the proprietary aspects of the Apphcation for Withholding or the Westinghouse Affidavit should reference CAW-16-4388 and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 3 Suite 3l 0, Cranberry Tmvnship, Pennsylvania 16066.

J;ames A. Gresham, Manager Regulatory Compliance

<<;) 20l6

*----

COMMONWEALTH OF PENNSYLV ANJ.A:

ss CA W-16-4388 March 23, 20 16 I, James A. Gresham, am authorized to execute this Affidavit on behalf of Electric Company LLC (Westinghouse), and that the averments of fact set in this Affidavit are tme and correct to the best of my kno"tvledge, information, and belief. Compliance

*-------------

2 CAW-16-4388 (1) am Manager, Regulatory Compliance, \Vestinghouse Company LLC (Westinghouse), and as such, 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 its withholding on behalf of Westinghouse.

(2) am making this Affidavit in conformance with the provisiions 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) 1 have personal knowledge of the criteria and procedures u1tilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial infonnation.

(4) Pursuant to the provisions of paragraph (bX 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) TI1e fnfonnation 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 infonnation customarily held in confidence by and, in that connection, utilizes a system to determine when and w!:tetherto ho!d 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 infonnation 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-16-4388 (b) 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 desik,rn, manufacture, shipment, installation, assurance of quality, or licensing a similar product. (d) 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. contains patentable ideas, for which patent protection may be desirable.

There are sound policy reasons behind the Westinghouse system which include the following: (a) The use of such information Westinghouse gives Westinghouse a competitive advantage over its competitors. 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 lnfommtion is available to competitors diminishes the Westinghouse ability to sell products and services involving the of the information. (c) Use by our competitor would put Westinghouse at a competiLive disadvantage by reducing his expenditure of resources at our expense. (d) Each component of proprietary information pertinent to a particular competitive advantage is potentia!ly as valuable as the 1total competitive advantage.

If competitors acquire c-omponents of proprie:tary information, any one component CAW-16-4388 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 competition ofthose countries. The Westinghouse capacity to invest corporate assets 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 avaiJ.able 1n public sources or available infommtion bas not been previously employed in the same original manner or method to the best of our knowledge and belief. (vi) The proprietary infom1ation sought to be withheld in this submittal is that which is appropriately marked in \VCAP-18089-P, Revision 0, "Point Beach Unit 1 Steam Generator Alternate Repair Criteria H*" (Proprietary), dated March 2016, for submittal to the Commission, being transmitted by NextEra Energy Point Beach letter and Application for Withholding Proprietary Infom1ation from Public Disclosure, to the Document Control Desk. The proprietary infommtion as submitted by Westinghouse is that associated with Westinghouse's request for NRC approval of WCAP-18089-P, and may be used only for that purpose. (a) This information is part of that which will 'enable Westinghouse to provide technical support for licensing the steam generator tube repair criteria, H*, for use at Point Beach Unit 5 CAW-16-4388 (b) Further, this information has substantial commercial value a<; follows: (i) Westinghouse p1ans to seH the use of similar information to its customers for the purpose of providing technical support for licensing the steam generator tube alternate repair criteria, H* .. (ii) Westinghouse can sel! support andl defense ofindustry 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 \Vestinghousc.

Public disclosure of this proprietary information is likely to cause substantia( hann 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 infonnation to meet NRC requirements for licensing documentation without purchasing the right to use the infonnation.

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 infom1ation, 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 INFORl)'IATION NOTICE Transmitted herewith are proprietary and non-proprietary versions of a document, furnished to the NRC in connection with requests for generic and/or plant-specific revie*w and approvaL ln order to conform to the requirements of lO 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 infonnation that was contained within the brackets in the proprietary versions having been deleted).

The justification for claiming the infonnation so designated as proprietary is indicated in both versions by means of lower case letters (a) through located a<; 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 infonnation Westinghouse customarily holds in confidence identified in Sections ( 4)(ii)( a) through (4)(ii)(f) of the Affidavit accompanying this transmittal pUJrsuant to J 0 CFR 2.390(bXl).

COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the infonnation contained in these reports which are necessary tor 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 to the requirements of I 0 CFR 2.390 regarding restrictions on public disclosure the extent such information has been identified as proprietary by Westinghouse, copyright protection nol:\vithstanding.

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 docwnent 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 lf the1 original was identified as proprietary.

ATTACHMENT Westinghouse Non-Proprietary Class 3 .. e 1n U.S. Nuclear Regulatory Commission Document Control Desk 1155 5 Rockville Pike Rockville, TviD 20852 Westinghouse Electric Company Direct lel: (412) 374-4643 Direct fax: (724) 940-8560 e-mail: greshaja@westinghouse.com NEXT-16-39 CA W-16-4387 March 23, 2016 APPLICATION WITHHOLDING PROPRIETARY iNFORMATION FROM PUBLIC

Subject:

LTR-SGMP-16-14 P-A ttachment, "Responses to Information Requests from the Nuclear Regulatory Commission Staff Concerning the Point Beach Unit l H* License Amendment Request Submittal" (Proprietary)

The Application for Withholding Proprietary

]nformation from Public Disclosure is submitted by Westinghouse Electric Company LLC (Westinghouse), pursuant the provisions ofparaj:,rraph (b)(l) of Section 2.390 of the Commission's regulations. contains commercial strategic information proprietary to \Vestinghouse and customarily held in confidence.

The propriet.ary information for which withholding is being requested in the above-referenced report is further identii1ed in Affidavit CAW 43 &7 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The Affidavit, which accompanies this Jetter, 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.

Accordingly, this letter authorizes the utilization of the accompanying Affidavit by NextEra Energy Point Beach. Correspondence with respect to the aspects of the Application for Withholding or the Westinghouse Affidavit should reference CAW-I 6-4387, and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 3 Suite 310, Cranbeny Township, Pennsylvania 16066. J)

(/ James Gresham, Manager Regulatory Compliance

(()2016 Westinghouse Electric Company LLC. A!l Rights Reserved.

COMMONWEALTH OF PENNSYLVANlA:

COUNTY BUTLER: AFFIDAVIT ss CAW-1 6-4387 March 23, 2016 I, James 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 At1idavit are true and correct to the best of my knowledge, information, and belief. !lt\ \\

Jnmes A. Gresham, 1\*tanager Regulatory Compliance 2 CAW-16-4387 (l) 1 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 authoriLed to apply for its withholding on behalf of Westinghouse.

(2) am making this Affidavit in confom1ance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conj!unction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

(3) I have personal knowledge ofthc criteria and procedures utilized by Westinghouse in designating information as a trade secret, 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 pub[ic disclosure is owned and has been held in confidence by Westinghouse.

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 ofthat 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 tallows: (a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of hs use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

3 CAW-16-4387 (b) 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 marketability. (c) lts use by a competitor would reduce his e:<penditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product (d) reveals cost or price infonnation, production capacities, budget levels, or commercial strategies of Westinghouse, its: customers or suppliers. (e) reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse. (f) lt 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, therdbre, withheld from disdosure to protect the Westinghouse competitive posi1tion. (b) is information that is marketable in many ways. The extent to whjch such infonnation is available to competitors diminishes the Westinghouse ability to sell products and services involving the of the infonnation. (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 infonnation pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. competitors acquire components of proprietary information, any one component 4 CAW-16--4387 may be the key to the entire competitive advantage.

thereby depriving Westinghouse of a (c) Unrestricted disclosure would jeopardize tihe position of prominence of Westinghouse in the world market, and the:reby give a market advantage to the competition of those countries. The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage. (iv) Tne information is being transmitted to the Commission confidence and, under the provisions of l 0 CFR Section 2.390, is to be received in confidence by the Commission. (v) The infonnation 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 infunnation sought to be withheld in this submittal is that which is appropriately marked in LTR-SGMP-16-14 P-Attachment, "Responses to lnfonnation Requests from the Nuclear Regulatory Commission (NRC) Staff Concerning Point Beach Unit I H* License Amendment Request Submittal" (Proprietary), submittal to the Commission, being transmitted by NextEra Energy Point Beach 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 Westinghouse's request for NRC approval ofl:fR-SGMP-16-14 Attachment, and may be used only tor that purpose. (a) This information is part oftbat which will t::mabte Westinghouse to provide technical support for licensing the alternate steam generator tube H*, for use at Point Beach Unit 1.

criteria, 5 (b) Further, this information has substantia!

commercial value as follows; Westinghouse plans to sell the use of similar information to its customers for the purpose of providing teclmical support for licensing the steam generator tube alternate repair criteria, H*. (ii) Westinghouse can sell support and defense of industry guidelines and acceptance criteria for plant-specific applications.

The information requested to be withheld reveals the distinguishing aspects of a methodology which developed by Westinghouse.

Public disclosure of this proprietary infonnation 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 infonnation 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 infonnation 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 infonnation, 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 are proprietary and non-proprietary versions of a document, 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 l 0 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 tl1e 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 oflower case letters (a) through (1) located as a superscript immediately following the brackets enclosing each item of infonnation being identified as proprietary or in the margin opposite such information.

These lower case k:tters refer to the types ofinformation Westinghouse customarily holds in confidence identified ln Sections (4)(ii)(a) through (4)(ri)(f) ofthe Affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).

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

With to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal usc which are necessary in order to have one copy available for public viewing ln 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 ifthe was identifi,ed as proprietary.

Westinghouse Non-Proprietary Class 3WCAP-18089-NP March 2016 Revision 0

(4)

(2)(3)

(1)

°

°

°

= ()()()()

= (1)

1

Retrieved from "https://kanterella.com/w/index.php?title=NRC_2016-0030,_License_Amendment_Request_for_H:_Alternate_Repair_Criteria_for_Steam_Generator_Tube_Sheet_Expansion_Region&oldid=1587604"