ML102850435

Resubmittal of Westinghouse Documentation Supporting License Amendment 249, Changes to the Steam Generator Inspection Scope and Repair Requirements

ML102850435
Person / Time
Site:	Millstone
Issue date:	10/07/2010
From:	Funderburk C Dominion Resources Services, Dominion Nuclear Connecticut
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME2978, 10-579A, FOIA/PA-2011-0115
Download: ML102850435 (7)

Text

Dominion R eso rceServices, Innsbrook Technical Center Inc.

5000 Dominion Boulevard, 2SE, Glen Allen, VA 23060 October 7, 2010 oiil U.S. Nuclear Regulatory Commission Serial No. 10-579A Attention: Document Control Desk NSSL/MLC RO Washington, DC 20555 Docket No. 50-423 License No. NPF-49 DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 3 RESUBMITTAL OF WESTINGHOUSE DOCUMENTATION SUPPORTING LICENSE AMENDMENT 249, "CHANGES TO THE STEAM GENERATOR INSPECTION SCOPE AND REPAIR REQUIREMENTS (TAC NO. ME2978)"

In a letter dated November 23, 2009, and supplemented by a letter dated April 26, 2010, Dominion Nuclear Connecticut, Inc. (DNC) submitted a request for a one-time revision to Facility Operating License NPF-49 for Millstone Power Station Unit 3 (MPS3). This amendment request proposed to revise Technical Specification (TS) 6.8.4.g, "Steam Generator (SG) Program," and TS 6.9.1.7, "Steam Generator Tube Inspection Report,"

to incorporate the one-time alternate repair criteria (H*). On May 3, 2010, in response to this request, the Nuclear Regulatory Commission (NRC) issued License Amendment (LA) 249 for Refueling Outage 13 and the subsequent operating cycle.

During the NRC's administrative processing of the supporting documentation for LA 249, the NRC discovered discrepancies with proprietary markings in some of the Westinghouse documents supporting the license amendment request dated November 23, 2009. On September 22, 2010, the NRC issued a letter to DNC requesting affected documents be revised and resubmitted to meet the requirements of 10 CFR 2.390(b)(1)(i). The specific discrepancies, which are administrative in nature, are detailed in Attachment 1. The revised documents and affidavits (as applicable), are provided in Attachments 2 through 9.

Attachments 4 and 6 contain proprietary information. Classification of these attachments as proprietary is supported by the affidavits provided in Attachments 3 and 5; therefore, it is respectfully requested that this information be withheld from public disclosure in accordance with 10 CFR 2.390.

If you have any questions regarding this submittal, please contact Mr. William D.

Bartron at (860) 444-4301.

Sincerely, C. L. Funderburk Director, Nuclear Licensing and Operations Support Dominion Resources Services, Inc. for Dominion Nuclear Connecticut, Inc.

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Serial No. 10-579A Docket No. 50-423 Page 2 of 3 Attachments:

1. Administrative Discrepancies in Westinghouse Documents Supporting License Amendment 249.

2. Westinghouse Electric Company LLC, WCAP-17071-NP, "H*: Alternate Repair Criteria for the Tubesheet Expansion Region in Steam Generators with Hydraulically Expanded Tubes (Model F)," Revision 2, dated September 2010. (Non-Proprietary)

3. Westinghouse Electric Company LLC, CAW-10-2966, "Application forWithholding Proprietary Information from Public Disclosure," for WCAP-17071-P, Revision 2, dated September 28, 2010. (Non-Proprietary)

4. Westinghouse Electric Company LLC, WCAP-17071-P, "H*: Alternate Repair Criteria for the Tubesheet Expansion Region in Steam Generators with Hydraulically Expanded Tubes (Model F)," Revision 2, dated September 2010. (Proprietary)

5. Westinghouse Electric Company LLC, CAW-1 0-2948, "Application for Withholding Proprietary Information from Public Disclosure," for LTR-SGMP-09-100 P-Attachment, Rev. 1, dated September 9, 2010. (Non-Proprietary)

6. Westinghouse Electric Company LLC, LTR-SGMP-09-100 P-Attachment, Rev. 1, "Response to NRC Request for Additional Information on H*; Model F and Model D5 Steam Generators, dated September 7, 2010. (Proprietary)

7. Westinghouse Electric Company LLC, LTR-SGMP-09-1100 NP-Attachment, Rev. 1, "Response to NRC Request for Additional Information on H*; Model F and Model D5 Steam Generators," dated September 7, 2010. (Non-Proprietary)

8. Westinghouse Electric Company LLC, LTR-RCPL-09-131, WCAP-17071-P, Rev. 0 Proprietary Information Clarification, dated August 27, 2009. (Non-Proprietary)

9. 'Westinghouse Electric Company LLC, LTR-SGMP-09-121, Replacements for Illegible Pages in Prior RAI Response (Reference 1), dated August 27, 2009. (Non-Proprietary)

Commitments made in this letter: None

Serial No. 10-579A Docket No. 50-423 Page 3 of 3 cc: U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406-1415 C. J. Sanders, Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 08-B3 Rockville, MD 20852-2738 NRC Senior Resident Inspector (w/o attachments)

Millstone Power Station

Serial No. 10-579A Docket No. 50-423 ATTACHMENT I ADMINISTRATIVE DISCREPANCIES IN WESTINGHOUSE DOCUMENTS SUPPORTING LICENSE AMENDMENT 249 DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 3 2

Serial No. 10-579A Docket No. 50-423 Attachment 1 Page 1 of 3 Administrative Discrepancies in Westinghouse Documents Supporting License Amendment 249 In a letter dated November 23, 2009, and supplemented by a letter dated April 26, 2010, Dominion Nuclear Connecticut, Inc. (DNC) submitted a request for a one-time revision to Facility Operating License NPF-49 for Millstone Power Station Unit 3 (MPS3). This amendment request proposed to revise Technical Specification (TS) 6.8.4.g, "Steam Generator (SG) Program," and TS 6.9.1.7, "Steam Generator Tube Inspection Report," to incorporate the one-time alternate repair criteria (H*). On May 3, 2010, in response to this request, the Nuclear Regulatory Commission (NRC) issued License Amendment (LA) 249 for Refueling Outage 13 and the subsequent operating cycle.

During the NRC's administrative processing of the supporting documentation for LA 249, the NRC discovered discrepancies with proprietary markings in some of the Westinghouse documents supporting the license amendment request dated November 23, 2009. On September 22, 2010, the NRC issued a letter (Agencywide Document Access and Management System (ADAMS) Accession No. ML102160749) to DNC requesting affected documents be revised and resubmitted to meet the requirements of 10 CFR 2.390(b)(1)(i). The specific discrepancies, which are administrative in nature, are detailed below:

1) Sections 9 and 10 of Enclosure 10, WCAP-17071-NP, "H*.: Alternate Repair Criteria for the Tubesheet Expansion Region in Steam Generatorswith Hydraulically Expanded Tubes (Model F)," (Non-Proprietary),,are marked "Westinghouse ProprietaryClass 2," at the top of each page although DNC clearly indicates that the document is non-proprietaryon page 6 of its November 23, 2009, letter.

Additionally, DNC identified the following:

Appendix A and the first page of Appendix B of WCAP-17071-NP, Revision 0, contain Proprietary Class 2 markings at the top of the page. These pages are non-proprietary and therefore should not be marked as Proprietary Class 2.

Appendix B of WCAP-1 7071 -P, Revision 0 (except for the first page), is not marked Proprietary Class 2 at the top of each page although the document is proprietary.

DNC Response Westinghouse documents WCAP-17071-NP and WCAP-17071-P have been revised to correct the discrepancies identified above. These corrected documents are provided as Revision 2 in Attachments 2 and 4, respectively. No new technical information is provided in Revision 2 to these documents.

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Serial No. 10-579A Docket No. 50-423 Attachment 1 Page 2 of 3 The proprietary information contained in WCAP-17071-P, Revision 2, is supported by the affidavit, CAW-10-2966, contained in Attachment 3. It is respectfully requested that this information be withheld from public disclosure in accordance with 10 CFR 2.390.

2) There is no non-proprietaryversion of Enclosure 8, LTR-RCLP-09-131, "WCAP-I 7071-P, Rev. 0 ProprietaryInformation Clarification."Also, the letter contains no basis for proposingthe information be withheld.

Note: The correct Westinghouse letter designation is LTR-RCPL-09-1 31.

DNC Response Westinghouse transmittal letter, LTR-RCPL-09-131, is marked Proprietary Class 2 by Westinghouse policy because it transmits a proprietary document. There is no information in the cover letter or in Attachment 1 to the letter that is proprietary.

Therefore, DNC is resubmitting LTR-RCPL-09-1 31 and Attachment 1, without the Proprietary Class 2 markings at the top of these pages. See Attachment 8.

3) There are no markings at the top of page 74 of Enclosure 6, LTR-SGMP-09-100, "Response to NRC Request for Additional Information on H*: Model F and Model D5 Steam Generators."

DNC Response Westinghouse document LTR-SGMP-09-100 P-Attachment, Revision 0, has been revised to add a Proprietary Class 2 marking and page number to page 74. These changes are contained in Revision 1. See Attachment 6. The proprietary information contained in LTR-SGMP-09-1 00 P-Attachment, Revision 1, is supported by the affidavit, CAW-1 0-2948, contained in Attachment 5. It is respectfully requested that this information be withheld from public disclosure in accordance with 10 CFR 2.390.

4) Page 78 of Enclosure 6, and its non-proprietarycounterpart (Enclosure 11), included bracketed information without providing a basis for proposingthe information be withheld.

DNC Response Westinghouse document, LTR-SGMP-09-100 NP-Attachment, Revision 0, has been revised to correct the erroneous deletion of non-proprietary information on page 78.

Additionally, Westinghouse document, LTR-SGMP-09-100 P-Attachment, Revision 0, has been revised to correct symbols on pages 46, 68, and 85 that did not transfer

Serial No. 10-579A Docket No. 50-423 Attachment 1 Page 3 of 3 properly to the .pdf version. These symbols were replaced with words or the symbol corrected.

LTR-SGMP-09-100 P-Attachment, Revision 1, and LTR-SGMP-09-100 NP-Attachment, Revision 1, are provided in Attachments 6 and 7, respectively. No new technical information is provided in Revision 1 to these documents.

The proprietary information contained in Attachment 6 is supported by the affidavit, CAW-10-2948, contained in Attachment 5. It is respectfully requested that this information be withheld from public disclosure in accordance with 10 CFR 2.390.

5) There is no non-proprietaryversion of Enclosure 9, LTR-SGMP-09-121, "Replacementsfor Illegible Pages in PriorRAI Response (Reference 1). Also, the letter contains no basis for proposing the information be withheld.

DNC Response Westinghouse transmittal letter, LTR-SGMP-09-121, is marked Proprietary Class 2 by Westinghouse policy because it transmits a proprietary document. There is no information in the cover letter that is proprietary. Therefore, DNC is resubmitting LTR-SGMP-09-121 without the Proprietary Class 2 markings at the top of that page. See Attachment 9.

There is no non-proprietary version of the replacement pages provided by Westinghouse transmittal letter LTR-SGMP-09-121. These illegible figuires were redacted in the non-proprietary version of LTR-SGMP-09-100, which is the reference document identified in LTR-SGMP-09-121, and therefore the corresponding pages did not require replacement.