ML19332E556
| ML19332E556 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 11/30/1989 |
| From: | PORTLAND GENERAL ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML19293A068 | List: |
| References | |
| NUDOCS 8912070366 | |
| Download: ML19332E556 (26) | |
Text
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p LCA 187-i' Attachment B Y
Page 1 of 7 r
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~ SURVEILLANCE REOUIREMENTS (Continued) s All-nonthrgyr/ tubes that previously /assed nor sleeved A1Ae at%fed had detectable all 1.
l penetrations (>20%)(Anf A va n( 6een r J
_ alldats thatprwovG h<d Joisefdk sleeve well genefravens kt have het been f aged,.
l 2.
Tubes in those areas where experience has indicated potential problems.
.3.
A tube inspection (pursuant to Specification 4.4.5.4.a.8) shall be performed on each selected tube. If any. selected tube does not permit the passage of-the eddy current probe for a-tube inspection, this shall be recorded and an adjacent tube shall be selected and-subjected to a tube inspection.
c.
In addition to the 35 sample, all tubes with defects below the
-F* distance which have not been plugged shall be inspected in the tube' sheet region.
d.
The tubes selected as the second and third samples (if required l
by Table 4.4-2) during each inservice inspection may be subjected to a partial tube inspection provided:
1 I"
1.
The tubes selected for these samples include the tubes from.those areas of the tube sheet array where tubes with.
imperfections were previously found.
cor tge sleeves 2.
The inspections include those portions of the tube where imperfections were previously found.
or fa,g,l,,y,3 l{
The results of each sample inspection shall be classified into one of i
'the following three categories:
Catecorv Insoection Results C Less than-5% of the total tubes inspected are degraded tubes and none of the inspected tubes are defective.
C-2 One or more tubes, but not more than 1% of the total tubes inspected are defective, or between 5% and 10% of the total tubes inspected are degraded tubes.
]
.C-3 More than 10% of the total tubes inspected are degraded tubes or more than 1% of tne inspected tubes are defective.
Note:
In all inspections. previously degraded tubes must exhibit significant (>10%) further wall penetrations to be included in the above percentage calculations.
1
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AmendmentNo.57f.{.II, TROlAN-UNIT 1 3/44-7
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'8912070366 891130 1
-hDR ADOCK 05000344 PDC
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... i LCA 187 Attachment B Page 2 of 7
)
k REACTOR COOLANT SYSTEM SURVEILLANCE RE0VIREMENTS (Continued)
-4.4.5.41 Accentance criteria D -
4.
As used in the Specification:
or fuhe sleeve' f
1.
-Imoerfection means a xception to the dimensions, finish w4 or contour of a tube f rom that required by fabrication 4
drawings or specifications. Eddy-current testing indica-
.- O tions below 20% of the nominal tu wall thickness, if-
-detectable, may be considered as erfections.
.D or $6e sleeve T..
- 2. -Deoradation means a service-induced cracking, wastage,-
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wear or general corrosion occurring on either inside or s
outside of a tube E
g ortsLc. sletyt
- [ -
.. ;i 3.
Decraded Tube means a tube containing imperfections 120%
w of the_ nominal wall thickness caused by degradation, b
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gfube ortute sleeve or Tuke.sfeeve 4.-
Y Decradation means the percentage of the tube # wall
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thickness affetted or removed by degradation.
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L 5.
9.11111 means angerfection of such severity that it exceeds,the d,.."-limit.
A tube containing a defecttht 4 M
defsctwe %Le is a a-t--* u-o-W Lieskiyinkt by skeving er o. sleaved %e +Mt Ms a defest w he sterd.
- ("'
N_Ob Limit means the imperfection depth at or beyond 6 8 which-the tube shall be removed from service'because it may become unse iceable prior to'the next inspection and is equal to of the nominal-tubeawall thickness. This definition)does not apply to_ the area of the tube shee 33 region below the F* distance, provided the tube has no indications'of cracking within the F* distance.
7.
Unserviceable describes the condition of a tube if it leaks-or contains a def ect large enough to af fect its structural integrity in the event of an Operating Basis Earthquake, a loss-of-coolant accident, or a steam line or feedwater line break as specified in 4.4.5.3.c above.
8.
Tube inspection means an inspection of the steam generator tube from the point of entry (hot leg side) completely l'
around the U-bend to the top support of the cold leg.
l TRO.1AN-UNIT 1 3/4 4-9 AmendmentNo.57,[Jf
--August--7, ' 987f
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LCA-187 Attachment.B j
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Page 3 of.7
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REACTOR COOLANT'SYSTEN
' SURVEILLANCE RE0VIREMENTS'(Continued)
^
_ 9 L. Preservice Insoection means an~ inspection of the full length ~
of each tube in each steam generator performed by eddy.
n current techniques prior to service to establish a baseline 4* s condition of the tubing. This inspection shall be performed
'after the field hydrostatic test and prior to initial POWER.
LOPERATION using the equipment and techniques expected to be
_ used during subsequent inservice inspections.
- 10. Tube Roll Exoansion is that portion of a tube which has been
~ increased in diameter by a rolling process such that no crevice exists between the outside diameter of the tube and the tube sheet.
~
11.
F* Distance is the minimum length of the roll expanded portion of the tube which cannot contain any indications of cracking o
Lin order to ensure the tube does not pull out of the tube T
sheet. The F* distance is 1.4 inches and is measured from the top of the roll expansion of the tube down-toward the j
bottom of the tube sheet. F* ss at aff%Ve Wa sleeve ks been mr.neainse.nu anaea p.cn.e n ue.
b.
The steam generator shall be determined OPERA 81.E after completing
'_the corresponding actions (plugiall tubes exceeding thegph;;ing-rf h limit) required by Table 4.4-2.\\.or slewe in #e d/ded uen J4.4.5.5 hDorts
- a..Following each inservice inspection of steam generator tubes, the number of tubes plugged in each steam generator shall be reported A
to the Comission within 15 days 3or steered
'b.
The complete results of the steam generator tube inservice
^
inspection shall be reported on an. annual basis for the period in which the inspection was completed. This report shall include:
1.
Number andlextent of tubes inspected.
2.
Location and percent of wall-thickness penetration for each indication of an-imperfection.
3.
Identification of tubes plugged g
c.
Results of-steam generator tube inspections which f all into Category C-3 shall be reviewed for reportability pursuant to Specification 6.6.1.
If the results are deemed reportable, such report aust be submitted to the Comission prior to the resumption or plant operation.
TROJAN-UNIT 1 3/4 4-9a AmendmentNo.57,k Auguit 7, 1937-E-m r
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LCA 187 Attachment B Page 5 of 7-1 REACTOR Cp0LANT SYSTEM aASES The power operated relief valves (PORVs) operate to reli
.i sure below the setting of'the pressuriter code safety valven. eve RCS pres-E
. These relief L
valves have remotely operated block valves-to provide a positive shutoff l>
capability should isolation of a relief valve be necessary.
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2/4.4.4 pat 1Sut12tt l-The requirement that.150 kw of pressurizer heaters and their assoc 1-j ated controls be capable of being supplied electrical power from an emergency bus provides assurance that these heaters can be energized during a loss of.offsite power condition to maintain natural circulation
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at NOT STANOBY._'A mintaus of'7 of the 23 kw heaters meets this requirement.
Q11 3/4.4.5 STEAM GENttATORS
[
-One OpttASLE steam generator provides sufficient heat removal capa-H bility to remove decay heat after a reactor shutdown. The requirement for two OptRA8Lt steam generators, combined with other requirements of the Limiting Conditions for Operation ensures adequate decay heat removal capabilities for RCS tosperatures greater than 350*F if one steam gen-erster becomes inoperable due to single failure considerations. Selow t(
350*F,-decay-heat.is removed by the RNA system.
E
-The surveillance Requirements for inspection of the steam generator tubes' ensure that the structural integrity of. this portion of the RCS b
will be maintained. ~ The program for inservice inspection of steam o
L generator tubes is based on a modification of Regulatory Guide 1.83, I
Revision 1.
Inservice inspection of steam generator tubing is essential in order to asintain surveillance of the conditions of the tubes in the event that there is evidence of mechanical damage or progressive degra-L dation due to design, manufacturing errors, or inservice conditions that lead to corrosion. Inservice inspection of steam generator tubing also f
provides a means 'of characteriting the nature and cause of any tube rtdc deeg o
L*
degradation so that corrective measures can be taken.
l The plant is expected to be operated in a manner such that the b.
secondary coolant will be enintained within those parameter limits found H
to result in negligible corrosion of the steam generator tubes. If the s
I secondary coolant chemistry is not asintained within these parameter limits, localized corrosion any likely result in stress corrosion cracking.
The extent of cracking during plant operation would be limited by the-limitation of steam generator tube leakage between the primary coolant
-A
- j Tt03AN-UNIT 1 8 3/4 4-2 Amendment No. If,
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m LCA 187-Attachment B Page 6 of 7
'1
.I REACTOR COOLANT SYSTEM-8ASES 3/4.4.5 STEAM GENERATORS CONTINUED J
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' system and the secondary coolant system (primary-to-secondary leakage =
w 500 gallons per oay per steam generator).- Cracks having a primary-to-y secondary leakage less than this limit during operation will have en g
adequate margin of safety to withstand the 1 cads imposed during normal operation and by postulated accidents. Operating plants have demonstrated that primary-to-secondary leakage -of 500 gallons per day. per steam u
generator can readily be detected by radiation monitors of steam generator 4 blowdown. Leakage in excess of this limit will require plant shutdown and "c
- an unscheduled inspection, during which the leaking tubes will be located or slegg) in the a(fcded ar@s Wastage-type defects are unlikely with the all volatile treatment (AVT)5.
of secondary coolant. However, even if a defect of similar type should g
' develop in service, it will be found during scheduled inservice steam J
generator tube examinations.
Pluggi will be required of all tubes with imperfections exceeding the Rg*%11mit which. by the definitio8ct.4f dfu L
of Specification 4.4.5.4.a is 40% of the tube
- nominal wall thickness.
~ Tubes with defects,below the F* distance do not have to be plugged or repaired as long as there are no indications of cracking in the F* dis-
. /33
- I
- tance. The F* distance isL1.4 inches and includes a safety factor of 3 and:a 0.5-inch eddy current measurement uncertainty. Steam generator tube inspections. of operating plants have demonstrated the capability to ~
/\\
. reliably detect wastage-type degradation that has penetrated 20% of the l/13),
original tube wall thickness.
Whenever the results of any steam generator tubing inservice inspection f all into Category C-3, these. results will be promptly reported to the Commission pursuant to Specification 6.9.1 prior to resumption of plant operation. Such cases will be considered by the Comission on a case-by-case basis and may result in a requirement for analysis, laboratory examinations, tests, additional eddy-current inspection, and revision of the Technical Specifications, if necessary, i
/4.4.6 REACTOR COOLANT SYSTEM LEAKAGE l-3/4.4.6.1 LEAKAGE DETECTION SYSTEMS l
L l:
The RCS leakage detection systems required by this specification are provided to monitor and detect leakage f rom the Reactor Coolant Pressure Bounda ry.
These detection systems are consistent with the recomendations of Regulatory Guide 1.45, ' Reactor Coolant Pressure Boundary Leakage Detection Systems" May 1973.
-(
TROJAN-UNIT 1 B 3/4 4-2a AmendmentNo.IT,,1)[
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r LCA 187 Attachment B Page 7 of 7 INSERT Degraded steam' generator tubes may be repaired by the installation of-
. sleeves which span the section of degraded steam generator tubing.
A.
1 steam generator tube with a sleeve installed meets the structural requ!rements of' tubes which~are not degraded.
~
The following sleeve designs have been found acceptable by the NRC staff:
g.
a. -- Babcock and Wilcox Kinetic Welded Sleeves (BAW-2094P, Revision 1).
b.
Bechtel-KWU Welded Sleeves (BKAT-01-P, Revision 1;-EDR-TRJ-01-P) c.; Combustion-Engineering Leak Tight Sleeves (CEN-395-P)
. Descriptions of other: future sleeve designs shall be submitted to the NRC for review and: approval prior to their use in the repair of degraded steam generator tubes.' The submittals related to other sleeve designs shall be made at least 90 days prior to use.
I e
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f 3954W.1189
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h LCA 187 At tachment C Pago 1 of>.9 7
j i
l E.
Nuclear Power Division Babcock & Wilcox.
Smi.i P,edue.od Integrated Field Services c? :
'a McDermott company 3110 Odd Fellows Road Lynchburg, VA 24501 (804) 847 3700 October 27, 1989 l
SGBM-89-1031 h
Wll f
[Mr. R. M. Nelson,--. Manager
. Nuclear Safety-and Regulation Department "l
. Portland General Electric Company 121-SW Salmon Street ~
Portland, Oregon 97204 l.
Subject:
Submittal of B&W Topical Report BAW-2094P, " Recirculating Steam Generator Kinetic Sleeve Qualification for 7/8" O.D.
Tubes," October, 1989.
~ Portland General Electric Purchase Order #NQ-53186 i
Dear Mr.' Nelson:
L Enclosed are four.(4) copies of the subject B&W proprietary topical L
report BAW-2094P.
This report describes the design, testing and u
tooling for.the subject sleeve.
The' report is to be used to support a. license' change application to the Trojan technical specifications to permit repair of.defe'etive steam generator tubes
.using the B&W sleeving method.
B&W-requests that this report be considered proprietary and, in addition, B&W requests.that its submittal to the NRC be a proprietary submittal in accordance with 10CFR2.790.
Information
- supporting this. request is included in the attached affidavit.
If~you have any questions or comments regarding this submittal, please feel free to contact me at (503) 225-0225 or Cary Bowles at (804): 847-3763.
Sin erely, R. A.
ernhard Regional Sales Manager, Portland
?
gl:crb-58-9 l
l-p cc:
CR Bowles p
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LCA.187-l g
Attachment C.
i
~
Page 2 of 9-W s
Rabvw&&MMCWC AFFIDAVIT OF JAMES H.
TAYLOR A..
My name is James H.-Taylor.
I am Manager of Licensing Services in the Nuclear Power Division.of the Babcock & Wilcox Company.
.The B&W Fuel Company is administratively responsible to the Babcock and Wilcox Nuclear Power Division (NPD) and utilitzes
]
-the NPD Licensing Services.
Therefore I an authorized to executa-this Affidavit.
t B.
I' am ' familiar with the criteria applied by Babcock & Wilcox to determine whether certain information of Babcock & Wilcox is L
proprietary and I an familiar with the procedures established b
within Babcock & Wilcox, particularly the Nuclear Power Division,'to ensure the proper application of these criteria.
C.
In' determining whether a Babcock & Wilcox document is to be
. classified.as' proprietary information, an initial determination j
L
-is made by t2un Unit Manager,- who is responsible for originating the document, as-to whether it falls within the criteria set forth 11n. Paragraph D hereof.
If the information falls within k
.any one of these criteria, it is classified as proprietary by
)
L the originating Unit Manager.
This initial determination is reviewed by the cognizant Section Manager.
If the document is designated as' proprietary, it-is reviewed again by Licensing 1
personnel-and other management within the Nuclear Power Division as designated by-the Manager of Licensing Services to assure that the regulatory requirements of 10 CFR Section 2.790 are met.
D.
The following information is provided to demonstrate that the provisions of 10 CFR Section 2.790 of the Commission's regulations have been considered:
J-l, (i)
The information has been held in confidence by the L
Babcock & Wilcox company.
Copies of the document are clearly identified as proprietary.
In addition, whenever
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LCA 187 Q
Attachment C Page 3 of 9-
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AFFIDAVIT Of JAMES H. TAY1DR (Cont'd.)
Babcock & Wilcox: transmits the information to a customer,
/
customer's agent, potential customer or regulatory E
agency,fthe transmittal requests the recipient to hold g
the'information as proprietary.
Also, in order to strictly limit any potential or actua2 customer's use j
of proprietary information, the following provision is includedLin all proposals submitted by Babcock & Wilcox, L
and.an applicable version of the proprietary provision is E
included in all of Babcock and Wilcox's contracts:
uU
- Purchaser may retain Company's proposal for use in connection with any contract resulting therefrom, l
and, for.that' purpose,.make such copies thereof as L
may.be necessary.
Any proprietary information L
concerning Company's or its supplier's products or manufacturing processes which is so designated by Company or its Suppliers and disclosed to Purchaser
' ncident to the performance of such contract shall i
h remain the property of company or its suppliers and L
L is disclosed in confidence, and Purchaser shall not n
p publish or otherwise disclose it to others without the written approval of Company, and no rights, implied or otherwise, are granted to produce or have produced any products or to practice or cause to be practiced any manufacturing processes covered thereby.
Notwithstanding the above, Purchaser may provide the L
NRC or any other regulatory agency with any such t
proprietary information as the NRC or such other agency may require; provided, however, that y
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- j, LCA.187
~
Attachment C'
,7 Page.-4 of 9-s u,
Babcock &WECOX AFFIDAVIT OF JAMES H. TAYLOR (Cont'd.)
Purchaser shall first;give Company written notice of such proposed disclosure =and Company shall have the right to amend such proprietary information so as to make it non-proprietary.
In the event that Company r
cannot amend such proprietary information, Purchaser
=shall, prior to disclosing such information, use its-best efforts to obtain a commitment from NRC or such other agency to have such information withheld from public inspection.
Company shall be given the right to participate in
_ pursuit of such confidential treatment."
_ (ii)1 The following criteria are customarily applied by Babcock & Wilcox in a rational decision process to determine whether the information should be classified as l
proprietary. 'Information may be classified as
,j' proprietary-if,one or more.of the following criteria are met:
a a.
Information reveals cost or price information, commercial strategies, production capabilities, or b
budget levels of Babcock & Wilcox, its customers or I
suppliers.
b.'
The information reveals data or material concerning Babcock & Wilcox research or development plans or programs of present or potential competitive advantage to Babcock & Wilcox.
c.
The use of the information by a competitor would decrease his expenditures, in time or resources, in designing, producing or marketing a similar product.
l 3
1 l
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. -. - ~ ~.
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.LCA 187
^
' Attachment C~
Page 5 of 9' N &W5coK "Cii 3
AFFIDAVIT OF JAMES H. TAYLOR (Cont'd.)
e
~d.-
The'information consists of test data or other similar data-concerning a process, method or component, the application of which resu.its in a
]
~
competitive advantage to Babcock & Wilcox.
e.
.The-information reveals special aspects of a
. process, method, component or'the like, the
+
exclusive use of which results in a competitive advantage to Babcock & Wilcox.
f.-
'The information contains ideas for which patent I
protection may be sought.
1.'
l-
.The document (s)-listed on Exhibit "A", which is attached hereto and made'a part hereof, has been evaluated in accordance with normal Babcock & Wilcox procedures with t
L respect to classification and has been found to contain information=which falls within one or more of the L
criteria enumerated above.- Exhibit-"B", which is attached ~ hereto and made a part hereof, specifically identifies the criteria' applicable to the document (s) listed:in Exhibit "A".
(iii)'
The' document (s) listed in Exhibit "A", which has been
- made-available to the United States Nuclear Regulatory
" Commission was made available in confidence with a request that the document (s) and the information c
contained therein be withheld from public disclosure, ip (iv)
The information is not available in the open literature and to the best of our knowledge is not known by Combustion Engineering, EXXON, General Electric, 4
l L
~~
- x,, 4 LCA 187:
Attachment-C'
+
Page 6 of'9 Rdwmek&$5cm 7.,
AFFIDAVIT OF JAMES H. TAYLDR (Cont'd.)
Westinghouse or other current-or potential domestic oc foreign competitors of Babcock & Wilcox.
(v)
Specific information with regard to whether public disclosure of the information is likely to cause harm to the competitive position of Babcock & Wilcox, taking into account the value of the information to Babcock & Wilcox; 3
the amount of effort or money expended by Babcock &
Wilcox developing the information; and the ease or difficulty with which the information could be properly Lduplicated: by others is given in Exhibit "B".
.E.-
I have personally reviewed the document (s) listed on Exhibit "A" and have found that it is considered proprietary by Babcock &
-Wilcox because it contains information which falls within one or more:of'the' criteria enumerated in' Paragraph D, and it is
'information which is customarily held in confidence and l_
protected as proprietary information by Babcock & Wilcox.
This report comprises information utilized by 3abcock & Wilcox in its L
business which afford Babcock & Wilcox an opportunity to obtain a competitive advantage over those who may wish-to know or use g
Jthe information contained in the document (s).
5
LCA 187, Attachment C' Page 7 of 9 Sabcock&WilC0K 4
AFFIDAVIT OF JAMES H. TAYIDR (Cont 8d.)
q.
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-[
JAMESH.TAYh State of Virginia)
)-
SS. Lynchburg City..of Lynchburg)
E
= James H. Taylor, being duly. sworn, on his oath deposes and says that he:is-the person who subscribed his name to the foregoing statement, and that the matters and facts set forth in the statement are true.
m
[hAMESH.TAYID[
.Subscrigedandswoyn,bforeme 4-9 this L -day of fUrIston 1989.
b Notary Public in and' for the City of Lynchburg, State-of-Virginia
.:My Commission Expires E Nf V f
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LCA 187-Attachment C
{
Page 8 of 9 I
AFFIDAVIT QE, JAMES L TAYLOR (CONT'D) i EXHIBIT. & - PROPRIETARY M UMENTS(S)
(
.BAW-2994P,." RECIRCULATING: STEAM GENERATOR' KINETIC SLEEVE
- QUALIFICATION
- FOR 7/8. INCH OD TUBES", OCTOBER, 1989.
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. LCA-187 56 Attachment C Page 9 of 9.
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i
&FFIDAVIT Of_ JAMES L. TAYLOR (CONT'D) 5'
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.EXRIBIT R; _ PROPRIETARY CRITERIA APPLICABLE From Paragraph'D'(11)', the,following are applicable:-
a.
b..
c.
d.
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$pMj I
s LCA 187-v E-Attachment D' L
14,
BechteloKWU rase 2.or 4 u.
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,c A L'L I A.N 0- E g
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15740 Shady Grove Road Gaithersburg, Maryland 208771454 7
.(301) 258 4600 Telecopy (301) 990-1293 j
Novemberi13, 1989
...i
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.Mr."Lanny"Dusek b
Portland GeneraliElectric.
. Trojan-Nuclear Plant
^
- Trojan' Building 1 North 1 NSRD
.e
-/1760: Columbia. River; Hwy' p.
Rainier,; Oregon-97048'
Dear Mr.:
Dusek:
Transmitted herewith a're.the following:
l I
1.
Draft letter; license change application for use of Bechtel-l A
'd
-KWU.: Alliance Sleeves.
V 2.
Calculati'on " Evaluation of.KWU Type I and II Sleeves for repairing Trojan Steam-Generator Tubes".
3.-
- Topical ~ Report "Repairiof Defective Steam:l Generator Tubes by.
1 Sleeving."BKAT-01-P!Rev. 1 April'.1989, 4' copies.
- This?.is provided:for your use.in' preparing a license amendment transmittal to the.NRC.for-use of.the Bechtel KWU Alliance
~
i sleeves at-Trojan Nuclear plant.'
l
'A plant specific design supplement for the Type II sleeve will be
.sent to;you.by November 22, 1989.
If you need additional information, please. call-me at (301) 258-4508.
P Sincerely, pl I 6',
t/ L_
._?'
L.
C. W. Hultman i
CWH:gs
?cc: Bob Brownlee i
4 r
l A Joint Venture of Bechtel Power Corporation and Sternens KWU, Inc.
e
LCA 187 Ba At tachunt D Page 2 Li 4 cg,
AFFIDAVIT s,'
STATE OF MARYLAND.
)
)
MOINGOMERY COUNTY
)
as Diethelm Kooedler, beira first duly swornf says:
t 1.
I am President of Universal Testing Laboratories.
Universal Testing Laboratories is the owner of information contained in a documer.t entitled " Topical Report: Repair of Defective Steam Generator Tubes by Sleeving" dated Februari 1"R9, which Universal Testing Laboratoriac seeks to have withheld from public disclosure.
2.
I am making this Affidavit pursuant to the provisiens of the i
Nuclear Regulatory Commission's rules and regulations, including 10 CFR 2.790.
3.
I have personal knowledge of the criteria and procedures utilized by Universal Testing Laboratories in determining and designating information as a trade secret or privileged or confidential commercial or financial information.
Under that system, information is customarily designated confidential and held in confidence if the release of that information might-result in the loss of an existing or potential competitive advantage.
Information which falls in one or more of the following categories is designated confidential a.
Information which reveals the distinguishing aspects of a process (or component, structure, toel, method, e
etc.) where prevention of its use by a competitor without license from Universal Testing Laboratories constitutes a competitive economic advantage over other companies.
b.
Information in the form 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.
Information which, if available to a competitor would reduce his expenditure or resources or improve his competitive position in the design, manufacture, shipment installation, assurance of quality, or licensing a similar product, d.
Information concerning or relating to price, production capacities, budget levels, or commercial strategies of Universal Testing Laboratories, its customers or suppliers.
1
LCA 187 Attachment D Page 3 of 4 e.
Information which reveals aspects of past, present, or future Universal Testing Laboratories or customer funded development plans and programs of potential commercial value to Universal Testing Laboratories.
f.
Information which contains patentable ideas or for which patent protection'may be desirable.
g.
Information relating to an invention.
4.
The document " Topical Report: Repair of Defective Steam Generator Tubes by Sleeving" is marked " Proprietary" and is transmitted to the Nuclear Regulatory Commission in confidence.
5.
The document " Topical Report: Repair of Defective Steam Generator Tubes by Sleeving" contains confidential commercial information consisting of test data or other similar data concerning a process, method or component, the application of which results in'a substantial competitive advantage to Universal Testing Laboratories.
6.
The document " Topical Report: Repair of Defective Steam Generator Tubes by Sleeving", as well as the information which it describes has been held in confidence by Universal Testing Laboratories and has been disclosed only after each proposed i, '
recipient of the information has executed an appropriate agreement if such agreement has been deemed necessary.
7.
The information contained in the document " Topical Report Repair of Defective Steam Generator Tubes by Sloeving" is not available in public sources and can not be preparly acquired without the execution of an appropriate agreement maintaining the proprietary nature of the information from Universal Testing Laboratories.
8.
Public disclosure of the document and the information contained there.n is likely to cause substantial harm to the competitive position of Universal Testing Laboratories because:
a.
The information contained in the document consists of the design, manufacturing, installation and testing relating L
to the repair of steam generator tubes by sleeving, the application of which provides a competitive advantage to Universal Testing Laboratories in the nuclear marketplace.
Development of this information by Universal Testing Laboratories involved a substantial investment of effort and money.
b.
The information required significant effort and expense to obtain the licensing approvals necessary for application of the information.
2 sw.
O' LCA 187 Attachmtnt D Page 4 of 4 c.
The infcrmatien contain d in tho docunont connot ba otherwise be duplicated by others without a substantial i
investment of effort and money by them.
L d.
In order to acquire such information, another party j
would also incur considerable expense and inconvenience in j
L developing the design, manufacturing and test procedures relating to the information contained in the document.
]
e.
The availability of such information to others would i
enable them to modify or create products without incurring significant research, development, engineering, 3
manufacturing, licensing, quality assurance and other costs incurred by Universal Testing Laboratories.
)
l
- f. The disclosure of the information may enable such parties to provide such services while avoiding the forgoing costs
)
thereby significantly impairing the position of Universal Testing Laboratories in the nuclear marketplace.
]
9.
Because of both the substantial investment.of effort and noney by Universal Testing Laboratory in conceiving and i
developing the information described in the document "Topicel i
Report: Repair of Defective Steam Generator Tubes by Sleeving" and' Universal Testing Laboratories' expectation that this information will substantially enhance its competitive position
'in the nuclear industry, Universal Testing Laberatories has a i
rational basis for holding this information in confidence.
Further the Affiant sayeth not.
W #4L.,.
Q ef Diethelm Mfioedler Subscribed and sworn to befora me this /
day of d6.,1989.
.ESA n Y Rotary Public
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My Commission expires: a4- /
/Ffd p Comm e Lw n hw 4_;gg l
3
LCA 187 e
Attachmtnt E Page 1 of 5 l
M November 27, 1989 l
ESE 89 433 i
I Portland General Electric Company Nuclear Safety and Regulation Dept.
121-SW Salmon Street Portland, Oregon 97204 ATTENTION: Mr. R. M. Nelson I
r
SUBJECT:
Transmittal of Combustion Engineering Steam Generator Tube Sleeve
' Licensing Report CEN-395 P and Relatest Affidavit for Trojan
{
l
REFERENCE:
Portland General Electric Company Pt rchass Order No. NQ 53185 l
s
Dear Mr. Nelson:
l
.This is provided as the transmittal letter for four (4) costes, Serial Numbers 00001 through 00004 inclusive of the subject report as aut1orized by the reference document. Due to the proprietary nature of much of the content of i
this report, we ask that Portland General Electric Company handle the report i
in accordance with the proprietary statement noted on the cover of the l'
reference report.
As verbally requested, a copy of the NPS Document i
Distribution /Approva'l sheet showing the review process is included for PGE internal use, e
Attached is the affidavit signed by Mr. A. E. Scherer referencing the Licensing
-Report for use in your submittal to the Commission.
[
If you have any questions or comments regarding the report please do not hesitate to call me.
4 Sincerely, COMBUSTION ENGINEERING, INC.
- h. 0 s=
A. D. DePeau Task Manager r
ADD /kut Enclosures Power Systems 1000 Prospect Hill Roao (203) 688 1911 Combustion Engineenng, Inc.
Post Office Box 500 Telex: 99297 Windsor, Connecticut 06095 0500
=_
LCA 187 Attachment E Page 2 of 5 l'
i AFFIDAVIT PURSUANT i
f TO 10 CFR 2.790 L
Combustion Engineering Inc.
)
State of Connecticut
)
County of Hartford
)
SS :
L I, P. L. McGill, depose and say that I am the Vice President of Nuclear l
4 -
Fuel of Combustion Engineering, Inc., duly authorir.ed to make this affidavit, 1
and have reviewed or caused to have reviewed the information which is
]
1 identified as proprietary and referenced in the paragraph immediately below.
l I am submitting thia affidavit in conformance with the provisions of 10 CFR l
2.790 of the Commission's regulations and in conjunction with the application j
of Portland General Electric Company for withholding this information.
]
The information for which proprietary treatment is sought is contained in g
the following document:
CEN-395-P, " Trojan Steam Generator Tube Repair Using Leak Tight Sleeves" This document has been appropriately designated as proprietary.
I have personal knowledge of the criteria and procedures utilized by j
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.
LCA 187 Attachment E Page 3 of 5 1 j
)
-1.
The information sought to be withheld from public disclosure concerns
)
the design, manufacture, installation and testing of the steam generator tube welded sleeve for repairing degraded tubes, which is owned and has been I
held in confidence by Combustion Engineering.
2.
The information consists of test data or other similar data concerning a process, method or component, the application of which results in substantial compedtive advantage to Combustion Engineering.
3.
The information is of a type customarily held in confidence by Combustion Engineering and not customarily disclosed to the public.
1 Combustion Engineering has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilises 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.
This system was applied in determining that the subject document herein are proprietary.
4.
The information is being transndtted to the Commission in confidence i
under the provisions of 10 CFR 2.790 with the understanding that it is to be f
received in confidence by the Commission.
5.
The information, to the best of my knowledge and belief, is not available i
I.
in public sources, and any disclosure to third parties has been made pursuant to regulatory provisions or proprietary agreements which' provide l
I for maintenance of the information in confidence.
1 6.
Public disclosure of the information is likely to cause substantial harm to
[
the competitive position of Combustion Engineering because:
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r
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LCA 187 Attachm2nt E Page 4 of S 3
l
)
a.
A similar product is manufactured and sold by major pressurized water reactor competitors of Combustion Engineering.
b.
Development of this information by C-E required tens of thousands of manhours of effort and millions 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 developing the methodology for steam generator tube repair using leak tight sleeves for degraded tubes.
d.
The information required significant effort and expense to obtain the lleensing 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 appilcable, e.
The information consists of analyres of the methodology used to repair steem generator tubes using leak tight sleeves, the application of which provides a competitive 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, f.
In pricing Combustion Engineering's products and services, I
significant research, development, engineering, analytical, manufacturing, licensing, quality assuranco and other costs and expenses must be included.
The ability of Combustion Engineering's competitors to utilize such
LCA 187 Attachmtnt E Page 5 of 5
,4, information without similar expenditure of resources may enable them to sell at prices reflecting significantly lower costs.
g.
Use of the information by competitors in the international marketplace would increase their ability to 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 for obtaining or maintaining foreign licensees.
Further the deponent sayeth not, bl k L. McGiff Vice President Nuclear Fuel i
Sworn to before me thia R day of AW sd+
, 19,1 2 1-l
%+d LLJ hotag Public My Commission Expires: / k A 3/,/99y I
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9
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l
i In the Matter of
)
)
PORTLAND CENERAL ELECTRIC COMPANY,
)
Docket 50-344 THE CITY OF EUGENE, OREGON, AND
)
Operating License NPF-1 PACIFIC POWER & LIGHT COMPANY
)
)
(TROJAN NUCLEAR PLANT)
)
CERTIFICATE OF SERVICE I hereby certify that copies of License Change Application 187 (without proprietary enclosures) to the Operating License for Trojan Nuclear Plant, dated November 30, 1989, have been served on the following by hand delivery or by deposit in the United States mail, first class, this 30th day of November 1989:
State of Oregon Department of Energy 625 Marion St NE Salem OR 97310 Mr. Michael J. Sykes Chairman of County Commissioners Columbia County Courthouse St. Helens OR 97051 d.
S. A. Bauer, Manager Nuclear Regulation Branch Nuclear Safety & Regulation Subscribed and sworn to before me this 30th day of November 1989.
OMyCommission LA N Notary Public of Ot~egon bz<d [ [ !/
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