L-17-105, MRP-227-A Applicant Action Item 8: Revised Time-Limited Aging Analysis (Tlaa)Regarding Reactor Vessel Internals Loss of Ductility at 60 Years

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MRP-227-A Applicant Action Item 8: Revised Time-Limited Aging Analysis (Tlaa)Regarding Reactor Vessel Internals Loss of Ductility at 60 Years
ML17086A031
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 03/23/2017
From: Boles B
FirstEnergy Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML17086A029 List:
References
L-17-105, MRP-227-A
Download: ML17086A031 (6)


Text

WITHHOLD IN ACCORDANCE WITH 10 CFR 2.390(a)(4)

FENOC' WHEN SEPARATED FROM ENCLOSURE C, HANDLE THIS DOCUMENT AS DECONTROLLED 5501 North State Route 2 Oak Harbor, Ohio 43449 RrstEnergy Nuclear Operating Company Brian D. Boles 419-321-7676 Vice President, Nuclear March 23, 2017 L-17-105 10 CFR 50 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Davis-Besse Nuclear Power Station, Unit No. 1 Docket No. 50-346, License Number NPF-3 MRP-227-A Applicant Action Item 8: Revised Time-Limited Aging Analysis (TLAA)

Regarding Reactor Vessel Internals Loss of Ductility at 60 Years By letter dated January 23, 2017, FirstEnergy Nuclear Operating Company (FENOC) submitted an evaluation required by License Renewal Commitment 54. That evaluation has been revised to address incorrectly redacted information.

The revised Enclosures listed below provide the Davis-Besse Time-Limited Aging Analysis (TLAA) Regarding Reactor Vessel Internals Loss of Ductility at 60 Years:

A. AREVA Affidavit to Support the Disclosure Request for the Proprietary AREVA TLAA Report ANP-3542P Revision 1, "Time-Limited Aging Analysis (TLAA)

Regarding Reactor Vessel Internals Loss of Ductility for Davis-Besse Nuclear Power Station, Unit No. 1 at 60 Years" B. AREVA Report ANP-3542NP Revision 1, "Time-Limited Aging Analysis (TLAA)

Regarding Reactor Vessel Internals Loss of Ductility for Davis-Besse Nuclear Power Station, Unit No. 1 at 60 Years" (Non-Proprietary)

C. AREVA Report ANP-3542P Revision 1, "Time-Limited Aging Analysis (TLAA)

Regarding Reactor Vessel Internals Loss of Ductility for Davis-Besse Nuclear Power Station, Unit No. 1 at 60 Years" (Proprietary)

AREVA Report ANP-3542P Revision 1 (Enclosure C) documents Davis-Besse reactor vessel internals TLAA analysis details that are considered proprietary information that is to be withheld from public disclosure pursuant to 10 CFR 2.390. A non-proprietary version of the document is provided as Enclosure B. Upon removal of Enclosure C, this letter can be decontrolled.

p;1 Davis-Besse Nuclear Power Station, Unit No. 1 L-17-105 Page2 There are no regulatory commitments contained in this *letter. If there are any questions or if additional information is required, please contact Mr. Patrick J. McCloskey, Manager - Regulatory Compliance, at (419) 321-7274.

Sincerely,

~y~c--Oi..ffaH ~'BtJi31-lv;,

Brian -~~:;;a

Enclosures:

A. AREVA Affidavit to Support the Disclosure Request for the Proprietary AREVA TLAA Report ANP-3542P Revision 1, "Time-Limited Aging Analysis (TLAA)

Regarding Reactor Vessel Internals Loss of Ductility for Davis-Besse Nuclear Power Station, Unit No. 1 at 60 Years" B. AREVA Report ANP-3542NP Revision 1, "Time-Limited Aging Analysis {TLAA)

Regarding Reactor Vessel Internals Loss of Ductility for Davis-Besse Nuclear Power Station, Unit No. 1 at 60 Years" (Non Proprietary)

C. AREVA Report ANP-3542P Revision 1, "Time-Limited Aging Analysis (TLAA)

Regarding Reactor Vessel Internals Loss of Ductility for Davis-Besse Nuclear Power Station, Unit No. 1 at 60 Years" (Proprietary) cc: w/o Enclosures NRC Region Ill Administrator

  • NRR Project Manager NRC Resident Inspector Utility Radiological Safety Board

Enclosure A Letter L-17-105 Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse)

AREVA Affidavit to Support the Disclosure Request for the Proprietary AREVA TLAA Report ANP-3542P Revision 1, "Time-Limited Aging Analysis CTLAA) Regarding Reactor Vessel Internals Loss of Ductility for Davis-Besse Nuclear Power Station, Unit No. 1 at 60 Years" 3 pages follow

AFFIDAVIT COMMONWEALTH OF VIRGINIA )

) SS.

CITY OF LYNCHBURG )

1. My name is Tom Ryan. I am Manager, Product Licensing, for AREVA Inc.

(AREVA) and as such I am authorized to execute this Affidavit.

2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary. I am familiar with the policies established by AREVA to ensure the proper application of these criteria.
3. I am familiar with the AREVA information contained in the AREVA document "ANP-3542P Revision 1, Time-Limited Aging Analysis (TLAA) Regarding Reactor Vessel Internals Loss of Ductility for Davis-Besse Nuclear Power Station, Unit No. 1 at 60 Years", and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA Inc. for the control and protection of proprietary and confidential information.
4. This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by AREVA and not made available to the public.

Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.

5. This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure. The request for withholding of proprietary information is made in

accordance with 10 CFR 2.390. The information for which withholding from disclosure is requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial information."

6. The following criteria are customarily applied by AREVA to determine whether information should be classified as proprietary:

(a) The information reveals details of AREVA's research and development plans and programs or their results.

(b) Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.

(c) The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for AREVA (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability.

(e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA The information in this Document is considered proprietary for the reasons set forth in paragraphs 6(a), 6(c) and 6(d) above.

7: In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document has been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.

8. AREVA policy requires that proprietary information be kept in a secured file or are~ and distributed on a need-to-know basis.
9. The foregoing statements are true and correct to the best of my knowledge, information, and belief.

SUBSCRl BED before me this _vv

, °" r.:--

day of ftHnJr~ ,2017. *"

Sherry L. McFaden NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 10/31/18 Reg.# 7079129 SHERRY l. MCFADeN NotarvPubllc

~ommonwealth of Virginia

'7079129 Mr Commlnlo~ &1!Jilr11 Qct..$1 ,.201'1