Turkey Point, Unit 3 - Inservice Inspection Plan - Fifth Inspection … › docs › ML1507 › ML15077A214.pdf · 2015-05-15 · Turkey Point Unit 3 Relief Request No. 1, Revision

I

0FPL. March 2, 2015

L-2015-05310 CFR 50.55a

10 CFR 2.390U. S. Nuclear Regulatory CommissionAttn: Document Control DeskWashington, DC 20555-0001

Re: Turkey Point Unit 3Docket No. 50-250Inservice Inspection Plan - Fifth Inspection IntervalUnit 3 Relief Request No. 1, Revision 1

References: 1) Florida Power & Light Company letter L-2014-096 to the NuclearRegulatory Commission, "Inservice Inspection Plan - Fifth InspectionInterval, Unit 3 Relief Request No. 1", dated April 4, 2014.

2) Florida Power & Light Company letter L-2014-100 to the NuclearRegulatory Commission, "Inservice Inspection Plan - Fifth InspectionInterval, Unit 3 Relief Request No. 1 - Response to Request forAdditional Information", dated April 9, 2014.

3) Florida Power & Light Company letter L-2014-105 to the NuclearRegulatory Commission, "Inservice Inspection Plan - Fifth InspectionInterval, Unit 3 Relief Request No. 1 - Response to Follow-up Requestfor Additional Information", dated April 14, 2014.

4) NRC letter to Florida Power & Light Company, "Turkey Point NuclearGenerating Unit No. 3 - Safety Evaluation for Relief Request No. 1 forFifth 10-Year Inservice Inspection Interval - Repair of PressurizerStainless Steel Heater Sleeve Without Flaw Removal (TAC NO.MF3834)", dated October 9, 2014.

By letter L-2014-096 dated April 4, 2014 (Reference 1) as supplemented by letters L-2014-100(Reference 2) and L-2014-105 (Reference 3), Florida Power & Light Company (FPL) requestedNuclear Regulatory Commission (NRC) approval to use an alternative to the ASME Boiler andPressure Vessel Code, Section Xl, 2007 Edition, including Addenda through 2008. FPLrequested approval to implement an alternative to IWB-3142.3, Acceptance by CorrectiveMeasures or Repair/Replacement Activity. Specifically the pressurizer heater sleeve repair wasperformed to the requirements of ASME Section Xl using an ASME Section III design byreplacing the pressurizer heater sleeve and relocating the pressure boundary to the outsidediameter (OD) of the pressurizer shell and abandoning the existing heater sleeve and insidediameter (ID) weld in place. Relief request No. 1 supported the pressurizer repair and leavingthe flaw in the abandoned pressure boundary weld.

Florida Power & Light Company

9760 SW 3 4 4th St., Florida City, FL 33035

pl,OPP

L-2015-053Page 2 of 3

Pursuant to 10 CFR 50.55a(a)(3)(ii), FPL determined that compliance with specifiedrequirements would result in hardship or unusual difficulty without a compensating increase inthe level of quality and safety. NRC authorized FPL to use the referenced request during aconference call on April 15, 2014 and per the follow-up written approval safety evaluation datedOctober 9, 2014 (Reference 4).

Due to the emergent nature of the discovery and repair, the duration of Relief Request No. 1was for one 18- month operating cycle until a life of plant ASME Section Xl flaw evaluation wascompleted to support the duration of the relief request for the 5 th Inservice Inspection (ISI)interval. Attachment 1 to this letter submits Revision 1 to Relief Request No. 1. The revisedrelief request provides the results of the life of plant ASME Section Xl flaw evaluation andcorrosion analysis.

FPL requests NRC review and approval of Relief Request No. 1, Revision 1, by October 2015,prior to the fall 2015 Unit 3 refueling outage.

Enclosure 1 to this letter provides one copy of Westinghouse Report, WCAP-17973-NP,Revision 1, "Turkey Point Units 3 and 4 Pressurizer Heater Sleeve Flaw Evaluation to SupportHalf-Nozzle Repairs." Enclosure 1 is a non-proprietary report. Enclosure 2 to this letterprovides one copy of Westinghouse Report, WCAP-17973-P, Revision 1, "Turkey Point Units 3and 4 Pressurizer Heater Sleeve Flaw Evaluation to Support Half-Nozzle Repairs." Enclosure 2is a proprietary report. Enclosure 3 provides the Westinghouse Application for WithholdingProprietary Information from Public Disclosure CAW-15-4110, accompanying Affidavit,Proprietary Information Notice, and Copyright Notice.

As Enclosure 2 contains information proprietary to Westinghouse Electric Company LLC, it issupported by an Affidavit signed by Westinghouse, the owner of the information. The Affidavitsets forth the basis on which the information may be withheld from public disclosure by theCommission and addresses with specificity the considerations listed in paragraph (b)(4) ofSection 2.390 of the Commission's regulations.

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

Correspondence with respect to the copyright or proprietary aspects of the items enclosed orthe supporting Westinghouse Affidavit should reference CAW-15-4097 and should beaddressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse ElectricCompany, 1000 Westinghouse Drive, Building 3 Suite 310, Cranberry Township, Pennsylvania16066.

L-2015-053Page 3 of 3

Please contact Mitch Guth, Licensing Manager, at 305-246-6698 if you have any questions orrequire any additional information about this submission.

Very truly yours,

Michael KileySite Vice PresidentTurkey Point Nuclear Plant

Attachment:Turkey Point Unit 3 Relief Request No. 1, Revision 1, for the 5 th Inspection Interval

Enclosures:1. WCAP-17973-NP, Revision 1, "Turkey Point Units 3 and 4 Pressurizer Heater Sleeve

Flaw Evaluation to Support Half-Nozzle Repairs," (Non-Proprietary).2. WCAP-17971-P, Revision 1, "Turkey Point Units 3 and 4 Pressurizer Heater Sleeve

Flaw Evaluation to Support Half-Nozzle Repairs," (Proprietary).3. Westinghouse Application for Withholding Proprietary Information from Public Disclosure

CAW-15-4110, accompanying Affidavit, Proprietary Information Notice, and CopyrightNotice.

cc: Regional Administrator, USNRC Region II (w/o enclosures)Senior Resident Inspector, USNRC, Turkey Point Nuclear Plant (w/o enclosures)

L-2015-053 Attachment

Turkey Point Unit 3 Fifth Inservice Inspection Interval

Relief Request No. 1, Revision 1

Repair of Pressurizer Stainless Steel Heater Sleeve Without Flaw Removal

L-2015-053AttachmentPage 1 of 8

TURKEY POINT UNIT 3FIFTH INSERVICE INSPECTION INTERVAL

. RELIEF REQUEST No. 1, Rev. 1

Proposed Alternative in Accordance with 10CFR 50.55a(a)(3)(ii)

Hardship or Unusual Difficulty without Compensating

Increase in Level of Quality or Safety

"REPAIR OF PRESSURIZER STAINLESS STEEL HEATER SLEEVE WITHOUT

FLAW REMOVAL"

1. ASME Code Component Affected

Turkey Point Unit 3

Components: Pressurizer and pressurizer heater sleeve(nozzle)

Code Class: ASME Section III 1965 Edition, includingAddenda through Summer 1965, Class A

Examination Category: B-PCode Item Number: B15.10Description: Pressurizer heater sleeve internally welded

to the pressurizer lower head claddingSize: 1.125" Nominal outside diameter, 0.095" wall

thicknessMaterial: Stainless steel SA-213 TP316 sleeve,

austenitic stainless steel cladding, SA-216Grade WCC lower head

2. Applicable Code Edition and Addenda

ASME B&PV Code Section Xl, "Rules for Inservice Inspection of Nuclear Power Plant

Components" 2007 Edition, including Addenda through 2008.

3. Applicable Code Requirement

Pursuant to 10 CFR 50.55a (a)(3)(ii) Florida Power & Light Company (FPL) requestsan alternative to the requirements of ASME B&PV Code, Section Xl, IWB-3142.3"Acceptance by Corrective Measures or Repair/Replacement Activity. A componentcontaining relevant conditions is acceptable for continued service if the relevant



RELIEF REQUEST No. 1, Rev. 1

conditions are corrected by a repair/replacement activity or corrective measures to theextent necessary to meet the acceptance standards of Table IWB-341 0-1 ."

4. Reason for Request

By letters L-2014-096 dated April 4, 2014, L-2014-100 dated April 9, 2014 andL-2014-105 dated April 14, 2014, FPL submitted Relief Request No. 1 and subsequentresponses to NRC requests for additional information (RAIs) to support the repair ofthe Turkey Point Unit 3 stainless steel pressurizer nozzle without flaw removal. Due tothe emergent nature of the discovery and repair, the duration of the relief request wasfor one refueling cycle until a life of plant ASME Section XI flaw evaluation wasprepared to support the duration of the 5 th ISI interval. Revision 1 provides the resultsof the life of plant ASME Section Xl flaw evaluation and corrosion analysis.

FPL conducted visual examinations of the pressurizer heater sleeve penetrationsduring the Turkey Point Unit 3 spring 2014 Refueling Outage. These examinationsrevealed evidence of leakage in the annulus between the outer surface of the heatersleeve and the lower head bore at heater penetration #11. There was no leakageobserved at the other heater penetrations. Manual nondestructive examination (NDE)was conducted from the sleeve bore using the eddy current method after the heaterwas removed from the heater sleeve. The examination did not reveal any flaw in thesleeve. Therefore, the most likely location of the flaw is located in the stainless steelweld between the heater sleeve and the stainless steel cladding buildup.

The heater sleeve is roll expanded into the lower head bore and welded with a partialpenetration weld to the stainless steel cladding buildup on the inside of the pressurizerlower head. The partial penetration weld joint does not extend into the lower headcarbon steel base material.

The cladding is final stress relieved prior to welding the heater sleeve thereto. Thecladding is approximately 3/8" thick and one layer of cladding of approximately 3/16"thick remains beneath the partial penetration weld. The heater is fillet welded to thebottom of the sleeve and extends upward through the two heater lateral support platesin the pressurizer.

To remove the heater sleeve-to-pressurizer weld requires accessing the internalsurface of the pressurizer and removal of the weld and any remaining sleeve basemetal. Such an activity results in high radiation exposure to the personnel involvedwhich is considered a hardship. Grinding and/or machining within the componentsalso exposes personnel to safety hazards as well as possible foreign materialremaining in the pressurizer that could later affect fuel performance.




FPL proposes to leave the upper portion of the existing heater sleeve and its weld to

the pressurizer lower head cladding in service.

5. Proposed Alternative and Basis for Use

PROPOSED ALTERNATIVE:The original weld will not be corrected and the heater sleeve base material wasremoved to approximately the mid wall of the pressurizer lower head. The heatersleeve was repaired by relocating the pressure boundary weld from the inside surfaceof the pressurizer to the outside surface. The repair is in accordance with the Class 1requirements of the ASME Boiler and Pressure Vessel Code Section II1.

The "half-nozzle" method was used for the repair to penetration #11. The heater wasremoved and the heater sleeve was severed below the pressurizer lower head. Theremaining lower portion of the heater sleeve was removed by boring to approximatelymid-wall of the lower head. The removed portion of the stainless steel sleeve wasreplaced with a section (half-nozzle) of low carbon stainless steel which was thenwelded to the outside surface of the pressurizer lower head using low carbon stainlesssteel weld filler. A new heater was welded to the bottom of the replacement lowersleeve using low carbon stainless steel weld filler. The upper portion of the sleeve,including the partial penetration weld, will remain in place. (See Figure 1)

Heater sleeve welds on pressurizers with Alloy 600 material have been repaired bythe industry using a similar "half-nozzle" technique. The half-nozzle method has beenused at the FPL's St. Lucie Unit 2 and many other CE designed NSSS plants.

The portion of the original heater weld to the pressurizer was examined with aborescope. An area of discoloration - Y2" along the reinforcing fillet weld face wasnoted. However, no indication of cracking was identified in the discolored region orany other part of the weld that was viewed.

The original heater sleeve remnant and weld will not receive any additional NDE. Thenew lower heater sleeve-to-lower head and heater/plug-to-lower heater sleevepressure boundary welds, on the exterior surface of the pressurizer, were examined inaccordance with the applicable requirements of the ASME Boiler and Pressure VesselCode Sections III and Xl.

BASIS FOR USE:Since the heater sleeve material and sleeve-to-clad weld are generally not susceptibleto a stress corrosion mechanism in the pressurizer environment it is presumed that the




weld flaw(s) was the result of an original fabrication flaw that propagated from service.Such service propagation could be a combination of thermal fatigue and/or SCC.

There has been no leakage at any other pressurizer heater sleeve location at TurkeyPoint Unit 3 or Unit 4. A review of industry operating experience (OE) from the 48 USPWRs with similar stainless steel heater sleeves welded to the interior clad surface,representing greater than 3800 heater sleeves and 23-42 years of service, has notidentified a leak at this location. OE was identified at one US plant but the leak was ata location in the heater sleeve material outside of the pressurizer shell attributed to ananomaly in the tube adjacent to the weld. The greater than 3800 stainless steelpressurizer heater sleeves with 23-42 years of operating history represents greaterthan 100,000 sleeve years of service with occurrence of only this single leak in theweld. This provides evidence of the excellent service history as well as the evidenceof the lack of a generic condition.

Further characterization of the weld by NDE was not practical as discussed below.Due to its location in the inside of the lower pressurizer head, the original heatersleeve-to-pressurizer clad partial penetration weld is extremely difficult to access fromthe pressurizer manway, through the heater support plates and heaters, to performNDE. Also, if it was accessible, to fully characterize the flaw(s) causing leakage wouldrequire a volumetric examination method, such as an ultrasonic (UT) examinationmethod. However, the weld configuration around the sleeve outer diameter precludesUT coupling and control of the sound beam needed to perform flaw characterizationand sizing, with reasonable confidence, of the measured flaw dimensions. If UTexamination of the original partial penetration weld were attempted from the outsidesurface of the pressurizer lower head, the cladding interface would provide anacoustic mismatch that would severely limit this examination. This UT examinationwould also encounter scanning interferences due to adjacent heaters as well as therequired long examination distances (i.e., metal paths) for interrogation of radial-axialoriented flaws at the opposite (inside) surface. These conditions would make accuratedetection, characterization, and sizing of flaw(s) problematic.

Currently, there is no qualified UT technique for examination of the original partialpenetration weld or adjacent carbon steel pressurizer lower head material from eitherthe inside or outside surface. Radiography of this area is also impractical because ofthe inability to position either a source or film inside the pressurizer. Additionally,other NDE methods, such as liquid penetrant, magnetic particle, and eddy currentwould not provide useful volumetric information needed for flaw characterization.

The current inspection performed every refueling outage at Turkey Point Unit 3 is aVT-2 exam, meeting the NEI-03-08 recommended inspection guidance and frequencyprovided by the PWR Owners Group. This examination is performed with the




insulation in place. The Turkey Point Unit 3 pressurizer lower head is insulated withglass or mineral fiber insulation. At the time of the initial inspection the insulationconfiguration provided gaps around the leaking penetration and several other heatersleeve locations to permit examination of the base metal. A complete bare metalvisual was performed at all 78 penetrations to determine the extent of condition.

Flaw Evaluation:

The effects of propagation of any flaw(s) that remain in the original heater sleeve weld,by fatigue crack growth and corrosion mechanisms, are considered. Postulated worstcase flaws are assessed for flaw growth. The flaw evaluation of the Turkey Pointpressurizer heater sleeves was performed per ASME Section Xl, IWB-3600 for theremaining life of the plant and is presented in WCAP-17973-P (Enclosure 2). Theevaluation concludes that the structural integrity of the pressurizer will not beadversely affected by postulated flaw(s) remaining in service for a period of twentyyears which bounds the end of the current license.

Maximum allowable end-of-evaluation period flaw sizes are determined in accordancewith the methodology in IWB-3610 of the ASME Code for all operating conditions(normal/upset/test/emergency/faulted), as well as the primary stress limit of ASMESection III NB-3000, assuming local area reduction of the primary membrane. Themaximum allowable end-of-evaluation period flaw size is based on the most limiting(smallest) flaw size of all the calculated results (Section 4 of WCAP-17973-P). Oncethe maximum allowable end-of-evaluation period flaw sizes are determined, a crackgrowth evaluation is performed using the applicable fatigue crack growth mechanismsand corrosion rates (Section 4.3 of WCAP-17973-P). The flaw evaluation assumed apostulated flaw with a depth equal to the partial penetration weld and the claddingthickness, resulting in exposure of the carbon steel pressurizer head. The postulatedflaw is then subjected to corrosion and all the applicable fatigue cyclespressure/thermal transients for the normal/upset/test conditions for the 60 year designlife, concentrating them into 40 years of service life. The corrosion rate used for theinitial evaluation was the same as that reported in WCAP-1 5973-P-A (ML050180528).The results of the crack growth evaluation are compared to the maximum allowableend-of-evaluation period flaw size results (Section 4.4 of WCAP-1 7973-P) to show thatthe maximum allowable end-of-evaluation period flaw size will not be exceeded in theremaining service life. Therefore the postulated flaws will remain stable.

An additional investigation was performed to determine the corrosion rate required tocause the postulated flaws to reach the maximum allowable end-of-evaluation periodflaw size within 40 years. That limiting corrosion rate was shown to be approximately5 times higher than the rate used (Section 5.0, WCAP-17973-P) in the crack growthanalysis. The review of the operating history at Turkey Point Unit 3 from the startup




on 12-02-04 to 4-26-14 showed that the unit operated at slightly greater than 88%,including a >200 day planned refueling outage for extended power upratemodifications. This operating history showed that the corrosion rates in WCAP-1 5973-P-A are appropriate. The operating history will continue to be tracked and reevaluatedat the next interval to show that the assumed corrosion rates and fracture mechanicsresults remain valid.

A corrosion evaluation was also performed for the exposed carbon steel in the heatersleeve bore to determine the acceptable life of the repair weld that is on the outsidesurface of the pressurizer lower head. Although the corrosion in a tight crevice of ahalf nozzle repair is expected to stifle once filled with corrosion product (Section 2.5 ofWCAP-15973-P-A, ML050180528), bulk water corrosion rates were conservativelyconsidered for this evaluation. Corrosion of the pressurizer lower head material wouldincrease the diameter of the heater sleeve bore, decreasing the area of the effectiveweld and the reinforcement area around the hole. The maximum allowable holediameter is calculated considering the reduction in the effective weld shear area andthe required area of reinforcement based on Section III of the ASME Code. Theresults showed that the general corrosion would not increase the existing heatersleeve bore diameter of 1.299" or the 0.25" radius depth partial penetration weld to anunacceptable size (Section 4.3.1, WCAP-17973-P). An additional investigation wasperformed to determine the maximum corrosion rate required to reach the maximumallowable hole diameter. The rate determined to reach the maximum allowable holediameter in 20 years was approximately 7 times the rate considered for normaloperation in WCAP-1 5973-P-A. The operating history will continue to be tracked andreevaluated at the next interval to show that the assumed corrosion rates and fracturemechanics results remain valid.

In conclusion, the ASME B & PV Code Section Xl requirement, IWB-3142.3, is tocorrect a component containing a flaw(s). The proposed alternative is to relocate thepressure boundary weld to the outside surface of the pressurizer and not correct theitem(s) containing the flaw(s). It has been determined Section Xl, IWB-3600evaluation, that the material and the presence of the postulated worst case flaw(s) willnot be detrimental to the pressure retaining function of the pressurizer for theremaining license life of the plant. The assessment summarized above and provided inthe attached WCAP-1 7973-P concludes that the structural integrity for the Turkey PointUnit 3 pressurizer will not be adversely affected by postulated flaw(s) remaining inservice for the remaining life of the plant. The corrosion rates in the WCAP-17973-Pand the plant operating conditions will be reassessed as part of a new relief request forthe next inspection interval.




6. Duration of Proposed Alternative

Relief is requested for the current 5 th inspection interval for Turkey Point Unit 3 whichexpires on February 21, 2024.

7. Precedents

There are no known precedents for pressurizer stainless steel heater sleeve leakagerequiring repair other than the FPL relief request previously submitted per letter L-2014-096. The modified configuration is similar to various half-nozzle repairsperformed by the industry for alloy 600 items that have experienced leakage that havetypically been caused by primary water SCC. However, there is a precedent forevaluating flaw growth in carbon steel and low alloy steel base material due to fatiguethat is exposed to reactor coolant in the pressurizer environment. References to thoseNRC submittals for flaw evaluations with half nozzle repairs are as follows:

"ATTACHMENT (6) UNIT 1 PRESSURIZER HEATER SLEEVE AS-LEFT J-GROOVEWELD FLAW EVALUATION FOR IDTB REPAIR - NON-PROPRIETARY," CalvertCliffs Nuclear Power Plant, LLC May 11, 2011, NRC Accession ML11132A183.

"ST. LUCIE NUCLEAR PLANT, UNIT 2 - REGARDING REQUEST FOR RELIEFFROM THE REQUIREMENTS OF THE ASME CODE (TAC NO. MC9502)," May 26,2006, NRC Accession ML061290056

0.11 Inches - Approximate ABetween Upper Sleeve RemLower Replacement Heater




Heater

,er Sleeve Renant• ••nlWelmant ' ////[ SS Clad, 2 layers, 3/8"

SSa Wel (0e3%MadC

•"bevel with I•"fillet

•ial Gap _.--

lnant &Sleeve

• • SS Weld (0.03% Max C)

SS Replacement LowerSleeve (0.03% Max C)

SS Weld (0.03% Max C

Figure 1

Penetration #11 Final Configuration

L-2015-053

Enclosure 3

Westinghouse Application for Withholding Proprietary Informationfrom Public Disclosure CAW-1 5-4110, accompanying Affidavit,

Proprietary Information Notice, and Copyright Notice

( ) Westinghouse

U.S. Nuclear Regulatory CommissionDocument Control Desk11555 Rockville PikeRockville, MD 20852

Westinghouse Electric CompanyEngineering, Equipment and Major Projects1000 Westinghouse Drive, Building 3Cranberry Township, Pennsylvania 16066USA

Direct tel:Direct fax:

e-mail:Proj letter.

(412) 374-4643(724) [email protected]

CAW-15-4110

February 25, 2015

APPLICATION FOR WITHHOLDING PROPRIETARYINFORMATION FROM PUBLIC DISCLOSURE

Subject: WCAP-17973-P, Revision 1, 'Turkey Point Units 3 and 4 Pressurizer Heater Sleeve FlawEvaluation to Support Half-Nozzle Repairs"

The proprietary information for which withholding is being requested in the above-referenced report isfurther identified in Affidavit CAW-15-4110 signed by the owner of the proprietary information,Westinghouse Electric Company LLC. The Affidavit, which accompanies this letter, sets forth the basison which the information may be withheld from public disclosure by the Commission and addresses withspecificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission'sregulations.

Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Florida Power andLight Company.

Correspondence with respect to the proprietary aspects of the Application for Withholding or theWestinghouse Affidavit should reference CAW-15-41 10, 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.

Very truly yours,

James A. Greshamn, Manager

Regulatory Compliance

CAW-15-4110

February 25, 2015

AFFIDAVIT

COMMONWEALTH OF PENNSYLVANIA:

ss

COUNTY OF BUTLER:

L Henry A. Sepp, 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 knowledge, information, and belief.

HenryA. DepD ctor

MCRE-Engineering Services

2 CAW-15-4110

(1) 1 am Director, MCRE-Engineering Services, 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-15-41 10

(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-15-41 10

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 WCAP-17973-P, Revision 1, "Turkey Point Units 3 and 4

Pressurizer Heater Sleeve Flaw Evaluation to Support Half-Nozzle Repairs"

(Proprietary), for submittal to the Commission, being transmitted by Florida Power and

Light 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 fracture mechanics technical

justification to support continued operation for Turkey Points Units 3 and 4 with

pressurizer heater sleeve half-nozzle repairs, and may be used only for that purpose.

(a) This information is part of that which will enable Westinghouse to:

(i) Provide fracture mechanics technical justification to support continued

operation for Turkey Points Units 3 and 4 with pressurizer heater sleeve

half-nozzle repairs.

5 CAW-15-41 10

(b) Further this information has substantial commercial value as follows:

(i) Westinghouse plans to sell the use of similar information to its customers

for the purpose of providing fracture mechanics technical justification to

support operation of pressurizers with heater sleeve half-nozzle repairs.

(ii) Westinghouse can sell support and defense of industry 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 Westinghouse.

Public disclosure of this proprietary information 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 information 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 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 information, 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 documents furnished to the NRC inconnection 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 theprotection of proprietary information so submitted to the NRC, the information which is proprietary in theproprietary versions is contained within brackets, and where the proprietary information has been deletedin the non-proprietary versions, only the brackets remain (the information that was contained within thebrackets in the proprietary versions having been deleted). The justification for claiming the informationso 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 beingidentified as proprietary or in the margin opposite such information. These lower case letters refer to thetypes of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a)through (4)(ii)(f) of the 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 tomake the number of copies of the information contained in these reports which are necessary for itsinternal 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 publicdisclosure to the extent such information has been identified as proprietary by Westinghouse, copyrightprotection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC ispermitted to make the number of copies beyond those necessary for its internal use which are necessary inorder to have one copy available for public viewing in the appropriate docket files in the public documentroom in Washington, DC and in local public document rooms as may be required by NRC regulations ifthe number of copies submitted is insufficient for this purpose. Copies made by the NRC must includethe copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

Turkey Point, Unit 3 - Inservice Inspection Plan - Fifth Inspection … › docs › ML1507 › ML15077A214.pdf · 2015-05-15 · Turkey Point Unit 3 Relief Request No. 1, Revision

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