ML20058L944
| ML20058L944 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 12/06/1993 |
| From: | ENTERGY OPERATIONS, INC. |
| To: | |
| Shared Package | |
| ML19311B243 | List: |
| References | |
| NUDOCS 9312200077 | |
| Download: ML20058L944 (28) | |
Text
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3/4.4.4 STEAM GENERATORS LIMITING CONDITION FOR OPERATION I
3.4.4 Each steam generator shall be OPERABLE.
APPLICABILITY:
MODES 1, 2, 3, and 4.
ACTION:
I With one or more steam generators inoperable, restore the inoperable generator (s) to OPERABLE status prior to increasing T,,, above;200*F.
SURVEILLANCE REQUIREMENTS 4.4.4.0 Each steam generator shal'1 be' demonstrated OPERABLE by performance:of the following augmented inservice inspection program.
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4.4.4.1 Steam Generator Sample Selection and Inspection - Each steam generator shall be determined OPERABLE during shutdown by selecting and inspecting at
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least the minimum number of steam generators specified in Table' 4.4-1.'
4.4.4.2 Steam Generator Tube Sample Selection and Inspection The steam generator tube minimum sample size, inspection result classification, and the corresponding action required shall be as specified in Table 4.4-2.. The inservice inspection of steam generator tubes shall be performed at the frequencies specified in Specification 4.4.4.3 and the inspected tubes shall be verified acceptable per the ~ acceptance criteria of Specification 4.4.4.4.
1 The tubes selected for each inservice inpection shall' include at least 3% of-the total number of tubes in all s' team generators; the tubes selected for-these inspections shall be selected on a random basis except:
Where experience in similar plants with similar water chemistry' a.
indicates critical areas to be inspected, then at'least'50% of-the tubes inspected shall be from these critical areas.-
l b.
The first sample of tubes selected for each inservice inspection t
(subsequent to the preservice inspection) of each steam generator.
shall include:
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l SURVEILLANCE REQUIREMENTS (Continued)
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All nonplugged tubes that previously had detectable wall i
>enetrations (greater than 20%).
1 2.
Tubes in those areas where experience has indicated potential
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problems.
3.
A tube inspection (pursuant to Specification 4.4.4.4a.8.).shall f
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 j
be selected and subjected to a tube inspection.
The tubes selected as the second and. third samples (if require'd by c.
Table 4.4-2) during each inservice inspection may be subjected to a
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partial tube inspection provided:
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.
l 2.
The inspections include those portions of the tubes where I
imperfections were previously found.
i The results of each sample inspection shall-be classified into one of the 1
following three categories:
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l Category
. Inspection Results C-1 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 the inspected l
tubes are defective.
Note:
In all inspections, previously degraded tubes must exhibit significant (greater than 10%) further wall penetrations to be included in the above percentage calculations.
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WATERFORD - UNIT 3 3/4 4-11 i
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1 REACTOR COOLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)-
4.4.4.3 Inspection Frequencies - The above required inservice inspections.of steam generator tubes shall be performed at.the following frequencies:
a.
The first inservice inspection shall be performed after 6 Effective Full Power Months but within 24 calender months of initial crit-icality.
Subsequent inservice-inspections shall be~ performed at j
intervals of not less than 12 nor more than 24' calendar months after the previous inspection.
If-two-consecutive inspections following service under AVT conditions, not including the preservice inspection.
result in all inspection results falling'into the C-1 category or if two consecutive inspections demonstrate that previously. observed degradation has not continued and no additional degradation has occurred, the inspection interval may be extended to a' maximum of once per 40 months.
l b.
If the results of the inservice inspection;of a steam generator conducted in accordance with Table 4.4-2 at 40-month intervals fall into Category C-3, the inspection frequency shall be increased to:at '.
least once per 20 months.
The' increase in inspection frequency shall apply until the subsequent inspections satisfy the criteria of Specification 4.4.4.3a.; the interval may.then be extended'to a maximum of once per 40 months.-
Additional, unscheduled inservice inspections-shall-be performed on i
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each steam generator in accordance with the first sampletinspection -
l specified in Table 4.4-2 during the shutdown ~ subsequent to any of the following conditions:
1.
Primary-to-secondary tubes leaks-(not-including leaks '
l originating from tube-to-tube sheet welds).in excess of the limits of Specification 3.4.5.2.
2.
A seismic occurrence greater than the Operating Basis Earthquake.
3.
A loss-of-coolant accident requiring actuation of the-engineered safeguards.
4.
A main steam line or main fcadwater'line break.
i WATERFORD - UNIT 3 3/4 4-12 n.,
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l REACTORCOOLANTSWp SURVEILLANCE REQUIREMENTS (Continued)
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4.4.4.4 Acceptance Criteria a.
As used in this Specification I
1.
Imperfection means an exception to the dimensions, finish or contour of a tube from that required by fabrication drawings-or-1 specifications.
Eddy-current testing indications below 20% of..
the nominal tube wall thickness, if detectable, may be considered.
1 as imperfections..
2.
Degradation means a service-induced cracking," wastage, wear, or general corrosion occurring on either inside or outside of a
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tube.
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3.
Decraded Tube means a tube containing imperfections greater than or equal to 20% of the nominal wall thickness caused by -
degradation.
j 4.
% Dearadation means the percen M of the tube wall thickness l
affected or removed by degradation.
1 5.
Defect means an imperfection of such severity that it exceeds j
the plugging limit. A tube containing a defect is defective.
i 6.
Pluagina Limit means the imperfection depth at or beyond which-the tube shall be removed'from service and is: equal to 40% of the nominal tube wall thickness.
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7.
Unserviceable describes the condition of a tube if it leaks or-contains a defect large enough to affect itsistructural 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 4.4.4.3c., above.
8.
Tube Inspection means an inspection of the steam generator tube from the point of entry (hot leg side) completely around the U-bend to the top support of the cold leg...
9.
Preservice Inspection means. an inspection of the full length of each tube in each steam generator performed by eddy current.
techniques prior to service to establish.a baseline condition of the tubing. This inspection was performed.
prior to field hydrostatic test and prior to initial POWER-OPERATION using the equipment and techniques expected to be used during subsequent inservice inspections.
WATERFORD - UNIT 3 3/4 4-13
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SURVEILLANCE REQUIREMENTS (Continued) b.
The steam generator shall be determined OPERABLE after completing l
the corresponding actions (plug all tubes exceeding the plugging limit and all tubes containing through-wall cracks) required by i
Table 4.4-2.
4.4.4.5 Reports a.
Within 15 days following the completion of each inservice inspection 5
of steam generator tubes, the number of tubes plugged in each steam generator shall be reported to the Commission in a Special Report-pursuant to Specification 6.9.2.
l b.
The complete results of the steam generator. tube inservice inspection I
shall be submitted to the Commission in a Special Report pursuant to j
Specification 6.9.2 within 12 months following completion of the inspection. This Special Report shall include 1.
Number and extent of tubes inspected.
2.
Location and percent of wall-thickness penetration for each 1
indication of an imperfection.
3.
Identification of tubes plugged.
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c.
Results of steam generator tube inspections which fall into-l Category C-3 shall be reported in a Special-Report to the Commission pursuant to Specification 6.9.2 within 30 days and prior to resump-tion of plant operation. This report shall provide a description of investigations conducted to detemine cause of the tube degradation -
and corrective measures taken to prevent recurrence.
WATERFORD - UNIT 3 3/4 4-14 J
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.TA8LE 4.4 MINIMUM NUMBER OF STEAM GENERATORS TO BE INSPECTED DURING INSERVICE INSPECTION The inservice inspection may be limited to one steam generator on a rotating-schedule encompassing EE of the tubes if the results of the first'or previous inspections indicate that all steam' generators are performing in a like-manner. Note that under some circumstances, the operating conditions in one j
or more steam generators may be found to be more severe'than those in other j
Under such circumstances the sample sequence shall be modified to inspect the most severe conditions.
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WATERFORD - UNIT 3 3/4 4-15
TABLE 4.4-2 i
e STEAM GENERATOR TUBE INSPECTION Y
h IST SAMPLE INSPECTION 2ND SAMPLE INSPECTION 3RD SAMPLE INSPECTION m
Sample Size Result Action Required Result Action Required Result Action Required c-$
A minimum of C-1 None N. A.
N. A.
N. A.
N. A.
H S Tubes per C-2 Plug defective tubes C-1 None N. A.
N. A.
and inspect additional Plug defective tubes C-1 None 2S tubes in this S. G.
C-2 and inspect additional C-2 Plug defective tubes 4S tubes m this S. G.
Perform action for C-3 C-3 result of first sample Perform action for C-3 C-3 result of first N. A.
N. A.
J sample M
C-3 Inspect all tubes in All other this S. G., plug de.
S. G.s are None N. A.
N. A.
i fective tubes and.
C-1 5;
inspect 2S tubes in Some S. G.s Perform action for N. A.
N. A.
each other S. G.
C-2 but no C-2 result of second additional seenple Notification to NRC S. G. are pursuant to 650.72 C-3 (b)(2) of 10 CFR Additional Inspect all tubes in -
Part 50 S. G. is C-3 each S. G. and plug defective tubes.
Notification to NRC N. A.
N. A.
pursuant to 650.72 (b)(2) of 10 CF R Part 50 S=-hWherenisthenumberofsteamgeneratorsinspectedduringaninspection
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BASES i
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STEAM GENERATORS (Continued) 4 based on a modification of Regulatory Guide 1.83, Revision 1.
' Inservice-inspec', ion of steam generator tubing is essential in order to maintain surveil-lance of the concitions of the tubes in the event that there>is evidence of.
mechanical damage or progressive degradation due to design, manufacturing-errors, or inservice conditions that lead to corrosion; Inservice-inspection i
of steam generator tubing also provides a means of characterizing the nature and cause of any tube degradation so that corrective measures can be taken.
The plant is expected'to be operated in a manner such that the secondary I
coolant will be maintained within those chemistry limits found to result in:
j negligible corros. ion of the steam generator tubes.
If the secondary. coolant chemistry is not maintained within these limits, localized corrosion may :
i likely result in stress corrosion cracking.
The extent of cracking during
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plant operation would be limited by the limitation of. steam generator tube I
leakage between the primary coolant system and~the secondary coolant system i
(primary-to-secondary leakage = 0.5 gpa per steam generator)., Cracks having -
a primary-to-secondary leakage less than this limit during operation will have l
an adequate margin of safety to withstand the loads-imposed during' normal j
operation and by postulated accidents. Operating plants have' demonstrated i
that primary-to-secondary leakage of 0.5 gpa per. steam generator can readily:
j be detected by radiation monitors of. steam generator blowdown.- Leakage in~
.J excess of this limit will require plant shutdown and'an unscheduled inspection, j
during which the leaking tubes will be located and plugged.
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Wastage-type defects are unlikely with proper chemistry treatment of the secondary coolant.
However, even if a defect should develop.in service, it j
will be found during scheduled inservice steam generator tube examinations.
Plugging will be required for all tubes with' imperfections exceeding the i
plugging limit of 40% of the tubs nominal wall thickness.. Steam generator
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tube inspections of operating plants have' demonstrated the capability to j
j reliably detect degradation that has penetrated 20% of,the original-tube wall 1
thickness.
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i Whenever the results of any steam generator tubing inservice inspection-l t
fall into Category C-3, these results will be promptly reported to the 1
Cnemission pursuant to Specification 6.9.1 prior the resumption of. plant operation. Such cases will be considered by the Commission on a case-by-case
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basis and may result in a requirement for analysis, laboratory examinations,.
j tests, additional eddy-current inspection, and revision of the Technical
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Specifications, if necessary.
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4 WATERFORD - UNIT 3 8 3/4 4-3 5
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REACTOR COOLANT SYSTEH i
3/4.4.4 STEAM GENERATORS LIMITING CONDITION FOR OPERATION h
I 3.4.4 Each steam generator shall be OPERABLE.
1 APPLICABILITY : H0 DES 1, 2. 3, and 4.
1 ACTION:
With one or more steam generators inoperable, restore the inoperable generator (s) to above 200*F.
OPERABLE status prior to increasing Tavg SURVEILLANCE REQUIREMENTS 4.4.4.0 Each steam generator shall be demonstrated OPERABLE by performance of the following augmented inservice inspection program.
4.4.4.1 Steam Generator Sample Selection and Inspection - Each steam generator shall be determined OPERABLE during shutdown by selecting and inspecting at least the minimum number of steam generators specified in Table 4.4-1.
4.4.4.2 Steam Generator Tube Sanple Selection and Inspection - The steam generator tube minimum sample size, inspection result classification, and the corresponding action required shall be as specified in Table 4.4-2. The inservice inspection of steam generator tubes.
shall be performed at the frequericies specified in Specification 4.4.4.3 and the inspected tubes shall be verified acceptable per the acceptance criteria of Specification 4.4.4.4.
l The tubes selected for each inservice inspection shall include at least 3% of the total number of tubes in all steam generators: the tubes selected for these inspections shall be salected on a random basis except:
a.
Where experience in similar plants with similar water chemistry indicates critical areas to be inspected, then at least 50% of the tubes inspected shall be from these critical areas.
l b.
The first sample of tubes selected for each inservice inspection (subsequent to the preservice inspection) of each steam generator shall include.
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WATERFORD - UNIT 3 3/4 4-10
REACTOR COOLANT SYSTEM SURVEILLANCE REQUIREMENTS (Continued) 1.
All nonplugged tubes that previously had detectable wall penetrations (greater than 20%).
2.
Tubes in those areas where experience has indicated potential problems.
i 3.
A tube inspection (pursuant to Specification 4.4.4.4a.g.) shall be l
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.
t c.
The tubes selected as the second and third samples (if required by Table I
4.4 2) during each inservice inspection may be subjected to a partial tube inspection provid?d:
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.
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2.
The inspections include those portions of the tubes where imperfections were previously found.
The results of each sample inspection shall be classified into one of the following three categories:
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Category Inspection Results C1 Less than 5% of the total tubes inspected are degraded tubes and none of the inspected tubes are defective.
C-2 One or nore 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.
C3 Hore than 10% of the total tubes inspected are degraded tubes or nore than 1% of the inspected tubes are defective.
Note:
In all inspections, previously degraded tubes must exhibit significant (greater than 10%) further wall penetrations to be i
included in the above percentage calculations.
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WATERFORD - UNIT 3 3/4 4-11 i
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SURVEILLANCE REQUIREMENTS (Continued) l 4.4.4.3 Inspection Frequencies The above required inservice inspections of steam generator tubes shall be performed at the following frequencies:
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a.
The first inservice inspection shall be performed after 6 Effective Full Power Months but within 24 calendar months of initial criticality. Subsequent inservice inspections shall be performed at intervals of not less than 12 nor more than 24 calendar months after the previous inspection. If two consecutive inspections following service under AVT conditions, not including the preservice inspection, result in all inspection results falling into the j
C-1 categcry or if two consecutive inspections demonstrate that previously' observed degradation has not continued and no additional degradation has occurred, the inspection interval may be extended to a maximum of once per 40 months.
j b.
If the results of the inservice inspection of a steam generator conducted in
-l accordance with Table 4.4-2 at 40 month intervals fall into Category C 3, the -
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inspection frequency shall be increased to at least once per 20 months. ' The increase in inspection frequency shall apply until the subsequent inspections.
satisfy the criteria of Specification 4.4.4.3a.: the interval may then be' extended to a maximum of once per 40 months.
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c.
Additional, unscheduled inservice inspections shall be performed on each steam generator in accordance with the first sample inspection specified in Table -
4.4-2 during the shutdown subsequent to any of the following conditions:
1.
Primary-to-secondary tubes leaks (not including. leaks originating 'from tube-to-tube sheet welds) in excess of the limits of Specif1 cation l!
3.4.5.2.
1 2.
A seismic occurrence greater than the Operating Basis Earthquake.
i 3.
A loss-of coolant accident requiring actuation of the engineered -
safeguards.
4.
A main steam line or main feedwater line break.
WATERFORD - UNIT 3 3/4 4-12
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REACTOR C00LANI SYSTEM i
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SURVEILLANCE REQUIREMEldS (Continued) 4.4.4.4 Acceptance Criteria a.
As used in this Specification 1.
Tubing or tube means that portion of the tube or sleeve which forms the primary system to secondary system pressure boundary.
l L
Imperfection means an exception to the dimensions, finish or contour of l a tube from that required by fabrication drawings or specifications.
Eddy-current testing indications below 20% of the nominal tube wall thickness, if detectable, may be considered as imperfections, g
Degradation means a service induced cracking, wastage, wear, or general l corrosion occurring on either inside or outside of a tube.
L Degraded Tube means a tube containing inperfections greater than or l
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l equal to 20% of the nominal wall thickness ccused by degradation, g
- Degradation means the percentage of the tube wall thickness affected l
or removed by degradation.
L Defect means an inperfection of such severity that it exceeds the plugging or repair limit. A tube containing a defect is defective.
1 L
Plugging or Repair Limit means the inperfection depth at or beyond which the tube shall be removed from service by plugging or repaired by sleeving because it may become unserviceable prior tn the next inspection and is equal to 40% of the nominal tube wall thickness.
g Unserviceable describes the condition of a tube if it leaks or contains l a defect large enough to affect its structural integrity in the event of an Operating Basis Earthquake, a loss-of coolant accident, or a j
steam line or feedwater line break as specified in 4.4.4.3c., above, i
g Tube Inspection means an inspection of the steam generator tube from l
the point of entry (hot leg side) coupletely around the U bend to the top support of the cold leg.
g Preservice Inspection means an inspection of the full length of each l
tube in each steam generator performed by eddy current techniques prior to service to establish a baseline condition of the tubing. This inspection was performed prior to field hydrostatic test and prior to initial POWER OPERATION using the equipment and techniques expected to be used during subsequent inservice inspections.
WATERFORD - UNIT 3 3/4 4-13
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1 SURVEILLANCE REQUIREMENTS (Continued) j i
b.
The steam generator shall be' determined OPERABLE after completing the-corresponding actions (plug or repair all tubes exceeding the plugging or repair limit and all tubes containing through-wall cracks) required by Table 4.4-2.
Defective tubes may be repaired in accordance with CENS Report CEN-605-P, "Waterford 3 Steam Generator Tube Repair Using Leak Tight Sleeves,"
Revision 00 P, dated December, 1992; WES Report WCAP-13698, " Laser Welded i
Sleeves For 3/4 Inch Diameter Tube Feedring-Type and Westinghouse Preheater I
Steam Generators," Revision 1, dated May, 1993: or BWNS Report 51-1223750 00j 4
4.4.4.5 Reports l
l a.
Within 15 days following the completion of each inservice inspection of steam-l generator tubes, the number of tubes plugged or ' sleeved in each steam l
'l generator shall be reported to the Comission in a Special Report pursuant to t
Specification 6.9.2.
b.
The complete results of_ the steam generator tube. inservice inspection shall be f
1 submitted to the Comission 1.n a Special Report pursuant.to Specification 6.9.2 within 12 months following conpletion of the. inspection.' - This Special y
Report shall include:
1.
Number and extent of tubes inspected.
l 2.
Location and percent of wall thickness penetration for each' indication q
of an imperfection.
j
'i 3.
Identification of tubes plugged or sleeved.
l c.
Results of steam generator tube inspections which fall into Category C-3 shall.
be reported in a Special Report to the Comission pursuant to Specification 6.9.2 within 30 days and prior to resumption of plant operation. This report shall provide a description of investigations conducted to determine cause of l
the tube degradation and corrective measures taken to prevent recurrence.
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WATERFORD UNIT 3 3/4 4-14
TABLE 4.4 1 HINIMUM NUMBER OF STEAM GENERATORS TO BE INSPECTED DURING INSERVICE INSPECTION The inservice inspection may be limited to one steam generator on a rotating schedule encompassing 6% of the tubes if the results of the first or previous inspections indicate that all steam generators are performing in a like manner. Note that under some circumstances the operating conditions in one or mre steam generators may be found to be '
more severe than those in other steam generators. Under such circumstances the sample sequence shall be mdified to inspect the most severe conditions.
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WATERFORD - UNIT 3 3/4 4-15 i
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l TABLE 4.4 2 STEAM GENERATOR TUBE INSPECTION IST SMPLE INSPECTION 2ND SMPLE INSPECTION 3RD SMPLE INSPECTION Sample Site Result Action Required Result Action Required Result Action Required A minimum of S C1 None N. A.
ti. A.
N. A.
N. A.
Tubes per S. G.
C2 Plug or sleeve defective C-1 None N. A.
N. A.
l tubes'aRd inspect additional 25 tubes in this S.G.
C-2 Plug or sleeve defective C-1 None l
tubes and inspect additional 45 tubes in this S.G.
C2 Plug or sleeve defective -
l tubes C-3 Perfom action for C-3 result of first sample C3 Perform action for C 3 N. A.
N. A.
result of first sample C.3 Inspection all tubes in All other None N. A.
N. A.
this S.G. plug or sleeve S.G.s are C-1 l
defective tubes and inspection 25 tubes in each other S.G.
Notification to NRC pursuant to $50.72(b)(2) to 10CFR Part 50 Some S.G.s C Perfom action for C-2.
N. A.
N. A. -
but no.
result.of second sample additional S.G. are C-3 Mditional Inspect all tubes in each :
. N. A.
N. A.
S.G..is C-3 5.G. and plug or sleeve l
defective tubes.
Notification to NRC pursuant to $50.72(b)(2) of 10CFR -
Part 50 6-
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S = -t Where n is the number of steam generators inspected during an. inspection il WATERFORD - UNIT 3 3/4 4-16
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REACTOR COOLANT SYSTEM BASES STEAM GENERATORS (Continued) based on a modification of Regulatory Guide 1.83, Revision 1. Inservice inspaction of steam generator tubing is essential in order to maintain surveillance of the conditions of the tubes in the event that there is evidence of mechanical damage or progressive degradation due to design, tr.anufacturing errors, or Inservice conditions that lead to corrosion. Inservice inspection of steam generator tubing also provides a means of characterizing the nature and cause of any tube degradation so that corrective measures i
can be taken.
The plant is expected to be operated in a manner such that the secondary coolant will be maintained within those chemistry limits found to result in negligible corrosion of the steam generator tubes. If the secondary coolant chemistry is not maintained within these limits, localized corrosion may 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 system and the secondary coolant system (primary-to-secondary leakage - 0.5 gpm per steam generator). Cracks having a l
primary-to-secondary leakage less than this limit during operation will have an adequate margin of safety to withstand the loeds inposed during normal operation and by postulated accidents. Operating plants have demonstrated that primary to-secondary leakage of 0.5 gpm per steam generator can readily be detected by radiation monitors of steam generator blowdown. Leakage in excess of this limit will require plant shutdown and an unschedulei inspection, during which the leaking tubes will be located and plugged or repaired.
l Wastage-type defects are unlikely with proper chemistry treatment of the secondary coolant. However, even if a defect should develop in service, it will be found during scheduled inservice steam generator tube examinations. Plugging or sleeving will be required for all tubes with imperfections exceeding the plugging or repair limit as defined in Surveillance Requirement 4.4.4.4.
Defective tubes may be repaired by sleeving in accordance with LENS Report CEN 605 P, "Waterford 3 Steam Generator Tube Repair Using Leak Tight Sleeves," Revision 00 P dated December, 1392: WES Report WCAD-13698, " Laser Welded Sleeves For 3/4 Inch Diameter Tube Feedring-Typ and Westinghouse Preheater Steam Generators," Revision 1, dated May, 1993: or BWNS Report 51-1223750 00, *BWNS Kinetic Sleeve Design for CE SGs with 0.048" Wall Tubes," Revision 00, dated June 29, 1993.
Steam generator tube inspections of operating plants have demonstrated the capability to i
reliably detect degradation that has penetrated 20% of the original tube wall thickness. Sleeved tubes will be included in the periodic tube inspections for the inservice inspection program..
Whenever the results of any steam generator tubing inservice inspection fall into Category C 3, these results will be promptly reported to the Comission pursuant to Specification 6.9.1 prior the 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 j
analysis, laboratory examinations, tests, additional eddy-current inspection, and revision of the Technical Specifications, if necessary.
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l WATERFORD - UNIT 3 8 3/4 4 2
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AFFIDAVIT PURSUANT j
TO 10 CFR'2.790 I
l Combustion Engineering, Inc.
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l State of Connecticut
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County of Hartford
)
SS.:
I, S. A. Toelle, depose and.say that I am the Manager, NuclearL j
Licensing, of Combustion Engineering, Inc., duly authorized-to make f
this affidavit, and have reviewed : or caused to have reviewed. the f
information which is ident.ified as proprietary and referenced in the paragraph immediately below.
I am submitting this affidavit in 1
s conformance with the provisions of 10 CFR 2.790 of the Commission's i
regulations in conjunction with Entergy ' Operations, Inc. 'for-
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withholding this information.
j The information for which proprietary treatment is sought '. is f
contained in the following document:
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CEN-605-P, Revision 00-P, "Waterford'3' Steam. Generator Tube. Repair i
Using Leak Tight Sleeves, FINAL REPORT," December 1992.-
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l This document has been appropriately designated 4 *roprietary.
I have personal knowledge of the criteria and -procedures utilize.1 by Combustion Engineering in designating information as a
- j J
j trade secret, privileged or as confidential commercial of financial j
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 ' whethe:-
the 1
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I informr. tion sought to be withheld from public disclosure, included in
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the above referenced document, should be withheld.
1.
The information sought to be withheld from public disclosure, which is owned an. has been held in confidence by combustion r
Engineering, is the design, manufacture, installation, and testing of the steam generator tube welded sleeve for' repairing
]
degraded tubes.
2.
The information consists of test data or other similar data concerning a process, method or component, the application of which results in substantial competitive 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.
Combustion Engineering has a rational basis for determining the types of information customarily held in i
confidence by it and, in that connection, utilizes.a system-to i
determine when and whether to hold certain-types of information in confidence.
The details of the aforementioned system were l
provided to the Nuclear Regulatory Commission v'ia 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 is proprietary.
1'l
i '
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 infornation, 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.
?
6.
Public disclosure of the' information is-'likely to cause-substantial harm to the competitive position " of. Combustion Engineering because:
i a.
A similar product is manufactured and sold -by major l
pressurized water reactor competitors:. of.
Combustion I
i Engineering.
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b.
Development of this information by C-E required. thousands of manhours and'. millions'of dollars.-.ToJthe_best'of my
-l knowledge and belief, a competitor'would have to undergo j
similar expense in generating equivalent"information.
c.
In order to acquire such'information, a competitor would l
i also require. considerable time and inconvenience to' develop l
I a similar method for steam generator. tube repair using leak l
tight sleeves for-degraded tubes.
d.
The information required significant effort and expense to.
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4-1 obtain the licensing approvals necessary for application of j
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' I
applicable.
e.-
The-information consists of-the methodology used to repair.
steam generator tubes using. leak. tight sleeves,. the application of which provides a -' competitive economic:
advantage.
The : availability oft =such information 'to
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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 Eltgineering's product,
-J and avoid developing similar data and analyses in support i
of their processes, methods or apparatus.
f.
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
-l 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 4
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5-1 would have an adverse economic impact on Combustion i
Engineering's potential for obtaining or' maintaining foreign licensees.
Further the deponent sayeth not.
A
.i S. A. Toelle t
Manager l
Nuclear-Licensing b
i dy f
, 1992 Olla ot'ary Publig 3f3If94 My coraission expires:
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l AFFIDAVIT OF JAMES H. TAYLOR A.
My name is James H. Taylor.
I am Manager of Licensing Services for B&W Nuclear Technologies (BWNT), and as such I am authorized to execute this Affidavit.
B.
I am familiar with the criteria applied by BWNT to determine whether certain information of BWNT is proprietary and I am familiar with the procedures established within BWNT to ensure the proper application of these criteria.
l C.
In determining whether a BWNT document is to be classified as proprietary information, an initial determination is made by the Unit Manager, who is responsible for originating the document, as to whether it falls within the criteria set forth in Paragraph D hereof.
If the information falls within any one of these criteria, it is classified as proprietary by 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 personnel and other management within BWNT 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:
(i)
The information has been held in confidence by BWNT.
l Copies of the document are clearly identified as proprietary.
In addition, whenever BWNT transmits the 4
o 1
AFFIDAVIT OF JAMES H. TAYLOR (Cont'd.)
information to a customer, customer's agent, potential customer or regulatory agency, the transmittal requests the recipient to hold the information as proprietary.
Also, in order to strictly limit any potential or actual customer's use of proprietary information,_the following provision is included in all proposals submitted by BWNT, and an applicable version of the proprietary provision is included in all of BWNT's contracts:
" Purchaser may retain Company's proposal for use in connection with any contract resulting therefrom, and, for that purpose, make such copies thereof as may be necessary.
Any proprietary information concerning Company's or its Supplier's products or manufacturing processes which is so designated by l
Company or its Suppliers and disclosed to Purchaser I
incident to the performance of such contract shall l
l remain the property of Company or its Suppliers and is disclosed in confidence, and Purchaser shall not 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 NRC or any other regulatory agency with any such proprietary information as the NRC or such other-agency may require; provided, however, that 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 cannot amend such proprietary information, Purchaser l
l 2
AFFIDAVIT OF JAMES H. TAYLOR (Cont'd.)
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.
I Company shall be given the right to participate in l
pursuit of such confidential treatment."
I l
(ii)
The following criteria are customarily applied by BWNT in a rational decision process to determine whether the information should be classified as proprietary.
Information may be classified as proprietary if one or more of the following criteria'are met:
a.
Information reveals cost or price information, commercial strategies, production capabilities, or budget levels of BWNT, its customers or suppliers.
l i
b.
The information reveals data or material concerning l
bdNT research or development plans or programs of 1
l present or potential competitive advantage to BWNT.
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.
d.
The information consists of test data or other l
similar data concerning.a process, method or component,-the application of which resultsfin'a competitive advantage to BWNT.
l e.
The information reveals special aspects of a process, method, component or the like,.the.
l exclusive use of which results'.in a competitive advantage to BWNT.
i 3
i i
-,l
l.-
AFFIDAVIT OF JAMES H. TAYLOR (Cont'd.)
f.
The information contains ideas for which patent protection may be sought.
The document (s) listed on Exhibit "A", which is attached hereto and made a part hereof, has been evaluated in accordance with normal BWNT procedures with respect to classification and has been found to contain information which falls within one or more of the 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 contained therein be withheld from public disclosure.
(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, Westinghouse or other current or potential domestic or foreir-competitors of BWNT.
(v)
Specific information with regard to whether public disclosure of the information:is likely to cause harm to the competitive position of BWNT, taking.into account the-value of the information to BWNT; the amount of effort or money expended by BWNT developing the information;'and the ease or difficulty _with which the information could be properly duplicated 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 BWNT because,
it contains information which falls within one or more of the 4
i i
AFFIDAVIT OF JAMES H. TAYLOR (Cont'd.)
criteria enumerated in Paragraph D, and it is information which i
is customarily held in confidence and protected as proprietary information by BWNT.
This report comprises information utilized by BWNT in its business which afford BWNT an opportunity to obtain a competitive advantage over those who may wish to know or use the information contained in the document (s).
)
AfA&
6+
/rJAMES H.
TAY R
i l
State of Virginia)
)
SS. Lynchburg City of Lynchburg)
James H. Taylor, being duly sworn, on his oath deposes and says l
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.
bA 7 aAMzS ii.' TAv,tfR
~
Subscribed and sworJ1 before me this Sl"J day of 6 e t e tu d 1993.
mf.
Notary Public in and for the City of Lynchburg, State of Virginia.
MyCommissbn EniresJuly31,1995 i
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