ML17059B239

Forwards Final Design Documentation for Two Stabilizer Mods, Per GL 94-03

ML17059B239
Person / Time
Site:	Nine Mile Point
Issue date:	08/14/1996
From:	Terry C NIAGARA MOHAWK POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17059B240	List: ML17059B239 ML17059B241 ML17059B242 ML17059B243 ML17059B244 ML18040A180
References
GL-94-03, GL-94-3, NMP1L-1111, TAC-M90102, NUDOCS 9608210133
Download: ML17059B239 (18)

Text

CATEGORY t'EGULAT INFORMAkSQMMLSTRJBUTION SYSTEM (RIDS)

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ACCESSION NBR:9608210133 DOC.DATE: 96/08/14 NOTARIZED: YES DOCKET I FACIL:50-220 Nine Mile Point Nuclear Station, Unit 1, Niagara Powe 05000220 AUTH. NAME AUTHOR AFFILIATION TERRY,C.D. Niagara Mohawk Power Corp.

RECIP.NAME RECIPIENT AFFILIATION Document'Control Branch (Document Control Desk) g~

SUBJECT:

Forwards final design documentation for two stabilizer mods.

DISTRIBUTION CODE: A018D COPIES RECEIVED:LTR ) ENCL I SIZE:

TITLE: GL 94-03 Intergranular Stress Corrosion Cracking of Core Shrou s inBA NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL HOOD,D 1 "1 INTERNAL: E CENTE 01 1 1 NRR/DE/EMCB 1

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1 1 NRR/DRPM/PECB 1 NRR/DSSA/SRXB 1 1 RES/DET/EMMEB 1 1 EXTERNAL: NRC PDR 1 1 hit wI ~ /l//

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NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN 5D-5(EXT. 415-2083) TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 8 ENCL 8

0 ~ ,14 NIAGARA MOHAWK G E N E RAT I 0 N NINE MILE POINT NUCLEAR STATION/LAKEROAD, P.o. BOX 63, LYCOMING, NEW YORK 13093/TELEPHONE (315) 349-7263 FAX (315) 349-4753 BUSINESS GROUP August 14, 1996 CARL D. TERRY Vice President NMP 1L 1111 Nuclear Engineering U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 RE: Nine Mile Point Unit 1 Docket No. 50-220

Subject:

Generic Letter 94-03, "Intergranular Stress Corrosion Cracking of Core S1rrouds in Boiling Water Reactors" (TAC No. 'M90102)

Gentlemen:

During the 1995 refueling outage, Niagara Mohawk Power Corporation (NMPC) installed four (4) core shroud stabilizer assemblies in the Nine Mile Point Unit One (NMP1) reactor vessel.

As discussed in NMPC correspondence dated March 23, 1995 (NMP1L 0927) and April 30, 1996 (NMP1L 1067), conditions were identified during the stabilizer post-installation inspections and subsequent reviews that differed from the intended design. Niagara Mohawk committed to implement appropriate corrective actions during the next refueling outage to restore the shroud stabilizers to their original design criteria. By letter dated May 30, 1996 (NMP1L 1078), Niagara Mohawk submitted preliminary details of our proposed corrective actions. In that letter, Niagara Mohawk informed the Commission that two stabilizer modifications are planned and that final design documentation for the modifications would be submitted for NRC staff review and approval. This letter and the enclosures provide the final design documentation.

The proposed core shroud repair modifications are not included under the ASME Code,Section XI, definition for repair or replacement. As such, the design details of the proposed core shroud repair are being submitted to the NRC staff for review and approval as an alternative repair, pursuant to 10 CFR 50.55a(a)(3)(i) NMPC performed an evaluation of the

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changes made to the facility as described in the Final Safety Analysis Report (including the NRC Safety Evaluation (SE) of the NMP1 Core Shroud Repair) in accordance with 10 CFR 50.59. NMPC concluded that installation of the proposed shroud repair modifications does not 3

involve an unreviewed safety question. A summary of the safety criteria evaluated along with the basis for conformance is provided in Enclosure 2.

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Page 2 , entitled, "Nine Mile Point 1 Core Shroud Repair Modification Summary Report" provides a description of the proposed modifications and is intended to serve as a "roadmap" for the detailed analyses and drawings provided in the attachments to Enclosure 1. The attachments are listed in Section 8 of Enclosure 1. The Summary Report also provides a summary of the results and conclusions based on the material in the attachments. .1 is considered by its preparer, General Electric, to contain proprietary information exempt from disclosure pursuant to 10 CFR 2.790. Therefore, on behalf of General Electric, Niagara Mohawk hereby makes application to withhold this document from public disclosure in accordance with 10 CFR 2.790(b)(1). An affidavit executed by General Electric detailing the reasons for the request to withhold the proprietary information has been included as Enclosure 3. A non-proprietary version of this document has been included with this letter as Enclosure 4.

NMPC intends to implement the shroud repair modifications during our spring refueling and maintenance outage currently scheduled to commence on February 8, 1997. NMPC requests NRC approval of the final design documentation via a revision to the existing NRC shroud repair safety evaluation by December 15, 1996. This will allow the NMPC and GE Shroud Team to focus on critical installation mockup, tooling, training and procedure development, and other pre-installation activities during the two months immediately preceding the scheduled outage.

Very truly yours, Carl D. Terry Vice President - Nuclear Engineering CDT/TWR/lmc Enclosures xc: Regional Administrator, Region I Mr. B. S. Norris, Senior Resident Inspector Mr. D. S. Hood, Senior Project Manager, NRR Records Management

ENCLOS 3 AFFIDAVIT

GE NUCLEAR ENERGY General Electric Company 175 Curtner Avc., San Jose, CA 95125 August 15, 1996 Roy Corieri Niagara Mohawk Power Corporation Nine Mile Point Nuclear Power Station PO Box 63 Lycoming, NY 13093

Subject:

GENE B15-01759-03, Supplement 1, Nine Mile Point 1 Seismic Analysis, Core Shroud Repair Modification

Dear Roy,

The subject document contains GE-NE proprietary information which is provided under the Niagara Mohawk Power Corporation/GE-NE proprietary information agreement. GE-NE customarily maintains this information in confidence and withholds it from public disclosure.

The attached affidavit identifies that the designated information has been handled and classified as proprietary to GE-NE. Along with the affidavit this information is suitable for review by the NRC. GE-NE hereby requests that the designated information be withheld from public disclosure in accordance with the provisions of 10 CFR 2.790.

KJ..

T. E. Gleason, Principal Engineer Reactor Modification Services

General Electric Company AFFIDAVIT I, George B. Stramback, being duly sworn, depose and state as follows:

(1) I am Project Manager, Regulatory Services, General Electric Company ("GE") and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.

(2) The information sought to be withheld is contained in the Attachments to GE proprietary report B13-01739-03, Supplement I Nine Mile Point 1 Seismic Analysis, Core Shroud Repair Modification, Supplement 1, Class III (GE Proprietary Information), dated August 1996. The proprietary information is delineated by bars marked in the margin adjacent to the specific material.

(3) In making this application for withholding of proprietary information of which it is the owner, GE relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), 2.790(a)(4), and 2.790(d)(1) for "trade secrets and commercial or financial information obtained from a person and privileged or confidential" (Exemption 4). The material for which exemption from disclosure is here sought is all "confidential commercial information", and some portions also qualify under the narrower definition of "trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, 97292dll717DDD.19927, d

~vD5, 704F2d1280 (DC Cir. 1983).

(4) Some examples of categories of information which fit into the definition of proprietary information are:

a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by General Electric's competitors without license from General Electric constitutes a competitive economic advantage over other companies;

b. Information which, if used 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 of a similar product; GBS-96-8-afnmp10.doc AffidavitPage 1

c. Information which reveals cost or price information, production capacities, budget levels, or commercial strategies of General Electric, its customers, or its suppliers;

d. Information which reveals aspects of past, present, or future General Electric customer-funded development plans and programs, of potential commercial value to General Electric;

e. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

The information sought to be withheld is considered to be proprietary for the reasons set forth in both paragraphs (4)a. and (4)b., above.

(5) The information sought to be withheld is being submitted to NRC in confidence.

The information is of a sort customarily held in confidence by GE, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GE, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.

(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to such documents within GE is limited on a "need to know" basis.

(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GE are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

(8) The information. identified in paragraph (2), above, is classified as proprietary because it contains detailed results of analytical models, methods and processes, including computer codes, which GE has developed and applied to perform evaluations of the core shroud repair for the BWR.

GBS-96-8-afnmp10.doc AffidavitPage 2

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The development and approval of the BWR Shroud Repair Program was achieved at a significant cost, on the order of one million dollars, to GE.

The development of the evaluation process contained in the paragraph (2) document along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GE asset.

(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GE's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GE's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GE.

The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficultto quantify, but it clearly is substantial.

GE's competitive advantage will be lost if its competitors are able to use the results of the GE experience to normalize or verify their own process or ifthey are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

The value of this information to GE would be lost ifthe information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GE of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing these very valuable analytical tools.

GBS-96-8-afnmp10.doc AffidavitPage 3

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STATE OF CALIFORNIA )

) ss:

COUNTY OF SANTA CLARA )

George B. Stramback, being duly sworn, deposes and says:

That he has read the foregoing affidavit and the matters stated therein are true and correct Executed at San Jose, California, this ~

to the best of his knowledge, information, and belief.

day of 1996.

G rge B. tramback General Electric Company mdL P~-

Subscribed and sworn before me this day of 1996.

Notary Public, State of Cali rnia PAULA F. HVSSEY z s t

COMM. 1046120 goto'ublic Callfotnlo

<4~ SANA CLARACOUNlY My Comm. ~es OEC 1.W'~

GBS-96-8-afnmp 1 0.doc AffidavitPage 4

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