ML18064A785
| ML18064A785 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/24/1995 |
| From: | Haas K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9505310652 | |
| Download: ML18064A785 (9) | |
Text
consumers Power POWERING MICHl&AN"S PIUl&RESS Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 May 24, 1995 U S Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT KurtM. Haas Plant Safety and Licensing Director PRESSURIZER SAFE END CRACK - FOLLOW-UP REQUEST PER 10 CFR 2.790 On September 16, 1993, a primary system through wall crack developed in the pressurizer power operated relief valve (PORV) nozzle safe end.
One of the reasons for the crack was later identified to be the result of primary water stress corrosion cracking (PWSCC).
Our October 7, 1993 letter to the NRC entitled "Pressurizer Safe End Crack Engineering Analysis and Root Cause Evaluation", contained references to reports of research and investigation concerning PWSCC in the nuclear industry.
One of the references was CEN-406-P, Revision 00, "A Status Report on CEOG [Combustion Engineering Owners Group]
Activities Concerning Primary Water Stress Corrosion Cracking of Inconel 600 Penetrations," dated May 1991.
CEN 406-P was intended to be only referenced by the October 7, 1993 letter, but inadvertently became designated in the NRC Document Control Center as an attachment to the letter. Since CEN-406-P, Revision 00, contains proprietary information, when docketed it should be accompanied by an application for withholding and an affidavit attesting to the need to withhold from public disclosure.
In accordance with 10 CFR 2.790 we request that CEN-460-P, as shown as docketed with the Consumers Power Company's October 7, 1991 letter, be withheld from public disclosure in accordance with the provisions of 10 CFR 2.790 and that the material be safeguarded.
The reasons for the classification of this report as proprietary are delineated in the affidavit contained in Attachment 1 to this letter.
A CMS ENERGY COMPANY
J
SUMMARY
OF COMMITMENTS This letter contains no new commitments and no revisions to existing commitments.
Kurt M Haas Plant Safety and Licensing Director CC Administrator, Region III, USNRC NRR Project Manager, USNRC NRC Resident Inspector - Palisades Attachment
ATTACHMENT.I CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 AFFIDAVIT PURSUANT TO 10 CFR 2.790 CEN-406-P, REVISION 00.
6 Pages
AFFIDAVIT PURSUANT TO 10 CFR 2.790 Combustion Engineering, Inc.
State of Connecticut County of Hartford SS.:
I, S. E. Ritterbusch, depose and say that I am the Manager, Standard Plant Licensing, of Combustion Engineering, Inc.,
duly authorized to make this affidavit, and have reviewed or caused to have reviewed the information 'which is identified as proprietary and referenced in the paragraph immediately below.
I am submitting this affidavit in conjunction with the applibation of Consumers Power Company in conformance with the provisions of 10 CFR 2.790 of the Commission's regulations for withholding this information.
The information fo_r which proprietary treatment is sought is contained in.the following document:
CEN-406-P, Revision 00, "A
Status Report on CEOG Activities Concerning Primary Water Stress Corrosion Cracking of Inconel 600 Penetrations," May 1991 This document has been designated as proprietary.
2 -
I have personal knowledge of the criteria and procedures utilized by Combustion Engineering in designating. information as a trade secret, privileged or as confidential commercial or financial information.
Pursuant to *the provisions of paragraph (b)
(4) of, Section
- 2. 790 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, included in the above referenced document, should be withheld.
- 1.
The information sought to be withheld from public disclosure, which is owned and has been held in confidence by Combustion Engineering, is design information and plant-specific assessments of primary water stress corrosion cracking.
- 2.
The information consists of test data or other similar data concerning a proces.s,.method or.. component, the application of which results in substantial competitive advantage to Combustion Engineering.
- ~
3 -
- 3.
The information is of a type customarily held in confidence by Combustion Engineering and not customarily disclosed to the public.
Combustion Engineering 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 details of the aforementioned system were provided to the Nuclear Regulatory Commission via letter DP-537 from F. M. Stern to Frank Schroeder dated December 2, 1974.
- 4.
The information is being transmitted to the Commission in confidence under the provisions of 10 CFR 2.790 with the understanding that it is to be received in confidence by the Commission.
- 5.
The information, to the best of my knowledge and belief, is not available in public sources, and any disclosure to third parties has been made pursuant to regulatory provisions or proprietary agreements which provide for maintenance* of the information in confidence.
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- 6.
Public disclosure of the information is likely to cause substantial harm to the competitive position of Combustion Engineering because:
- a.
A similar product is manufactured and sold by major pressurized water reactor competitors of Combustion Engineering.
- b.
Development of this information by Combustion Engineering required thousands of manhours and hundreds of thousands of dollars.
To the best of my knowledge and belief, a competitor would have to undergo similar expense in generating equivalent information.
- c.
In order to acquire such information, a competitor would.
also require considerable time and inconvenience surveying plants to determine the status and future plans.
- d.
The information required significant effort and expense to obtain the licensing approvals necessary for application of the information.
Avoidance of this expense would decrease a competitor's cost in applying the information and marketing the product to which the information is applicable.
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- e.
The information consists of design information and plant specific assessments of primary water stress corrosion cracking, the application of which provides a competitive
- f.
- g.
economic advantage.
The availability of such information to competitors would enable them to modify their product to better compete with Combustion Engineering, take marketing or other actions to improve their product's position or impair the position of Combustion Engineering's product, and avoid developing similar data and analyses in support of their processes, methods or apparatus.
In pricing Combustion Engineering's products and services, significant research, development, engineering, analytical, manufacturing, licensing, quality assurance and other costs and expenses must be included.
The ability of Combustion Engineering's competitors to utilize such information without similar expenditure of resources may enable them to sell at prices reflecting significantly lower costs.
Use of the information by competitors in the international marketplace would increase their ability to
If.
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market nuclear steam supply systems by reducing the costs associated with their technology development.
In
- addition, disclosure would have an adverse economic impact on Combustion Engineering's potential obtaining or maintaining foreign licensees.
Further the deponent sayeth not.
S. E. Ritterbusch Manager Standard Plant Licensing for Sworn to before me this /~-M day of _YV\\_~-------1 1995
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