ML20078D832

Forwards Mod Design Documents & Core Shroud Insp Plan Info in Response to GL 94-03, IGSCC of Core Shrouds in Bwrs

ML20078D832
Person / Time
Site:	Quad Cities
Issue date:	01/16/1995
From:	Schrage J COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19311B683	List: ML20078D832 ML20078D840 ML20078D843 ML20078D851 ML20078D853 ML20078D861
References
NUDOCS 9501310013
Download: ML20078D832 (13)

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~ ) Commonwealth 1400 Opus Plac) Edison Downers Grovn. Ilkncis 60515

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January 16,1995 ,

h U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Document Control Desk l

Subject:

Quad Cities Nuclear Station Units 1 and 2, Core Shroud Modification Design Documents and Unit 2 Core Shroud '

Inspection Plan i NRC Docket Nos. 50-254 and 50-265  !

Reference:

G. Benes (Comed) to W. Russell letter dated August 23,1994,.  ;

i In the referenced letter, Commonwealth Edison (Comed) provided a response to .

Generic Letter 94-03, "Intergranular Stress Corrosion Cracking of the Core l Shrouds in Boiling Water Reactors." In that letter, Comed committed to provide I the inspection plan for the Quad Cities Unit 2 core shrouds (GL 94-03 Item 2.(a))

and the plans for the repair of the Quad Cities Unit I and Unit 2 core shroud (GL 94-03 Item 2.(b)). This letter provides the Design Documents for the repair of the Quad Cities Station Unit I and Unit 2 core shrouds as Attachment A (with Enclosures 1 through 9), and the Quad Cities Station Unit 2 Core Shroud i Inspection Plan as Attachment B.

The Unit 1 and Unit 2 Core Shroud repair was developed in accordance with ASME Section XI repair and replacement program requirements. This modification does not remove the existing flaws, nor replace the flawed components, but rather structurally replaces the core shroud horir ,tal circumferential welds H1 through H7, and accounts for cracking W the H8 weld.

The design has been developed considering through-wall 360 degree circumferential cracks at the H1 through H7 welds. The repair will be performed j as an alternative tc the ASME Section XI Code as permitted by 10 CFR l 50.55a(a)(3). In accordance with requirements of the above reference, Comed is j submitting this alternative code repair for your review and approval, kinla s quad 11695.wpf 1 9501310013 950116 PDR ADOCK 05000254 h, y//1 -

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U.S. NRC January 16,1995 Upon completion of the Unit 2 core shroud repair installation package, Comed will provide the 10CFR50.59 safety evaluation as a supplement to the design packag,e. Comed is presently planning to install the core shroud repair hardware into Quad Cities Unit 2 on April 26,1995 during the Q2R13 refueling outage. The Quad Cities Unit 2 inspection plan (Attachment B) has been integrated with the design of the modification. The Quad Cities Unit 1 installation will be performed during the Q1R14 refuel outage.

This submittal contains items which are proprietary in nature to the General Electric Nuclear Company. These proprietary items are contained in Enclosures 5 and 8 of Attachment A. Comed has specifically marked the portions of the submittal that are considered proprietary and requests that ell material within Enclosures 5 and 8 which is specifically marked as proprietary be withheld from public disclosure. To that end, Comed has provided non-proprietary versions of Enclosures 5 and 8 as Attachment D. Comed has included, as Attachment C, an aflidavit per the requirements of 10CFR 2.790(b) explaining the reasons and circumstances for withholding the applicable information from public disclosure.

To the best of my knowledge and belief, the analyses and evaluations contained in l

these documents are true and correct. In some respects these documents are not based on my personal knowledge, but on information furnished by other Commonwealth Edison employees, contractor employees, and/or consultants. Such information has been reviewed in accordance with company practice, and I believe it to be reliable.

If there are any questions concerning this matter, or need for further clarification, l please contact this office. .,,....,.,.,,..,,__,,,,,..,...

! OFFICIAL SEAL l:

Sincerely,

/

f ll MARY JO YACK l,> NOTARY PUBuc SuTE OF GNotSl

- 'l YY coy,ylSS0N}{Rf S] }/2p Nuclear Licensing Administrator  %,,y 4 gj gg

/- /, /)

Attachment A Quad Cities Station Unit 1 and Unit 2 Core Shroud Repair Design Documents (includes Enclosures 1 through 9)  ;

Attachment B Quad Cities Station Unit 2 Core Shroud Inspection Plan Attachment C Quad Cities Station Unit 1 and Unit 2 Selected Core Shroud ,

Repair Design Documents - General Electric Company Affidavit Attachment D Quad Cities Station Unit 1 and Unit 2 Selected Core Shroud Repair Design Documents; Non-Proprietary Version -

Enclosures 5 and 8 i cc: J. Martin, Regional Administrator - RIII R. Pulsifer, Project Manager - NRR C. Miller, Senior Resident Inspector - Quad Cities Office of Nuclear Facility Safety - IDNS k:nla: quad:11695 wpf:2

t ATTACIIMENT C Quad Cities Station Unit 1 and Unit 2 Selected Core Shroud Repair Design Documents General Electric Company Affadavit l

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i General Electric Company l

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

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

(2) The information sought to be withheld is contained in the GE proprietary report GENE-771-71-1094, Revision 1, " Quad Cities Units 1 & 2 - ShroudRepair Seismic Analysis", (GE Proprietary), January 5,1995 and drawings 107E5487, Rev.1,

" Reactor Modification / Installation Drawing", including a color piutare of the 107E5487 modification and those drawings listed in the Afmehmen'. These documents, taken as a whole, constitutes a proprietary compilation ofin'brmation, some ofit also independently proprietary, prepared by the General Electric Company.

The indept ndently proprietary elements that are drawings or a picture are marked as proprietary :.nformation and the independently proprietary elements that are in reports are delineat d by hars marked in the margin adjacent to the specific material.

(3) In making this application for withholding of proprietary information of which it is the owner, GE relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act,18 USC Sec.1905, and NRC regulations 10 CFR 9.17(a)(4), 2.790(a)(4), and 2.790(d)(1) for " trade secrets and commercial or financial information obtained from a person and privileged or confidential" (Exemption 4). The material for which  !

exemption from disclosure is here sought is all " confidential commercial information",

l and some portions also qualify under the narrower definition of " trade secret", within j the meanings assigued to those terms for purposes of FOIA Exemption 4 in, i respectively, Critical Mass Enerav Project v. Nuclear Reculatory Commission.

975F2d871 (DC Cir.1992), and Eublic Citign Health Research Group v. FDA, 704F2dl280 (DC Cir.1983).

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

a. Information that discloses a process, method, or apparatus, including supporting l data and analyses, where prevention ofits use by General Electric's competitors afQCmod. doc Aflidavit Page 1

without license from General Electric constitutes a competitive economic advantage over other companies; i

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b. Information which, if used by a competitor, would reduce his expenditure of 1 resources or improve his competitive position in the design,- manufacture, i shipment, installation, assurance of quality, or licensing of a similar product;

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

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

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

Both the compilation as a whole and the marked independently proprietary elements incorporated in that compilation are considered proprietary for the reason described i in items (4)a., (4)b. and 4(e), above.

l (5) The information sought to be withheld is being submitted to NRC in confidence. l l That information (both the entire body ofinformation in the form compiled in these drcwings, tnd the mrked individua l p-oprietary elements) is of a sort customarily l held in confidence by GE, and has, to the best of my knowledge, consistently been l held in confidence by GE, has not been publicly disclosed, and is not available in I public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or  !

proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent i steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6)

, and (7) following.

(6) Initial approval of proprietary treatment of a document is made by the manager of the l originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to such ,

l documents within GE is limited on a "need to know" basis.

l (7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination  !

of the accuracy of the proprietary designation. Disclosures outside GE are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, afQCmod doc Affidavit Page 2 l

and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

(8) The information identified in paragraph (2) and the Attachment, above, is classified as proprietary because it constitutes a confidential compilation ofinformation, including a report and detailed design drawing results and a picture of a hardware design modi 6 cation (stabilizers for the shroud horizontal welds) intended to be installed in a reactor to resolve the reactor pressure vessel core shroud weld cracking concern.

The development and approval of this design modification utilized systems, components, and models and computer codes that were developed at a significant cost to GE, on the order of several hundred thousand dollars.

The detailed results of the analytical models, methods, and processes, including computer codes, and conclusions from these applications, represent, as a whole, an integrated process or approach which GE has developed, and applied to this design modification. The development cf the supporting processes was at a significant i additional cost to GE, in excess of a million dollars, over and above the large cost of i developing the underlying individual proprietary report and drawings information.

(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GE's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GE's comprehensive BWR ,

technology base, and its commercial value extends beyond the original development ,

cost. The value of the technology base goes beyond the extensive physical database and analytical methodology and indudes development of the expertise to determine and apply the appropriate evaluation process. In addition, the achaalcgy b:.n  ;

includes the value derived from providing analyses done with NRC-approved methods.

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

While some of the underlying , analyses, and come of the gross structure of the i process, may at various times have been publicly revealed, enough of both the analyses and the detailed structural framework of the process have been held in ,

confidence that this information, in this compiled form, continues to have great competitive value to GE. This value would be lost if the information as a whole, in i the context and level of detail provided in the subject GE drawings, were to be disclosed to the public. Making such information available to competitors without their having been required to undertalce a similar expenditure would unfairly provide competitors with a windfall, and deprive GE of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing its analytical process.

afQCmod. doc Affidasit Page 3

STATE OF CALIFORNIA )

) ss:

COUNTY OF SANTA CLARA )

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

That he has read the foregoing affidavit and the matters stated therein are true and correct to the best of his knowledge, information, and belief.

Executed at San Jose, California, this /2 day of m 1995.

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'" - Ge6rg/BT Stramback '

General Electric Company Subscribed and sworn before me this ,. , day ofhW4.{3(_ _.1995.

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ukceW l 6ML Notary Public, State of C$llfdrnia

. . . - PAULA F. HUSSEY q m COM!A #1046120

. Notary PWie - Cohfornio 3

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{ - [f - $ANTA CLARA COUNTY y 1

j Mr Comm. Experos DEC 1,1098 )

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afQCmod. doc Affidavit Page 4 I

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Attachm:nt i

Drawing No. Revision Identification A 112D5256 1 BRACKET YOKE ASSY B 112D5264 1 LOCK, BOLT C 112D6506 1 LOWER STABILIZER ASSY D 112D6508 1 TOGGLE BOLT ASSY E 112D6509 1 TlE ROD ASSY F 112D6510 1 STABILIZER SUPPORT ASSY G 112D6511 1 UPPER STABILIZER ASSY H 112D6512 1 LATCH I 112D6513 1 SCREW, MID SUPPORT J 112D6514 1 RING, MID SUPPORT K 112D6515 1 WASHER, JACK BOLT L 112D6516 1 SLEEVE, JACK BOLT M 112D6518 1 RETAINER N 112D6519 1 NUT, TOP SUPPORT O 112D6520 1 BOLT, TOP SUPPORT P 112D6521 1 PIN O 112D6522 1 NUT, TIE ROD R 112D6523 1 PIN, CLEVIS S 112DS525 1 8:

.XTENSION, LOWER SPRING T' 112D6527 1 SCREW, YOKE U 112D6528 1 BRACKET, UPPER SPR'NG V 112D6529 1 CLIP, RETAINER W 112D6530 1 BOLT, JACK X 112D6531 1 NUT, TOGGLE BOLT Y 112D6532 1 WASHER, TOGGLE BOLT Z 112D6533 1 PIN, TOGGLE BOLT AA 112D6534 1 TOGGLE BB 112D6535 1 SUPPORT, LOWER CC 112D6536 1 BOLT, TOGGLE DD 112D6537 1 CONTACT, UPPER EE 112D6539 1 CONTACT, LOWER FF 112D6540 1 SUPPORT GG 112D6541 1 UPPER SUPPORT, LONG aIQCmod doc Affidavit Page 5

Att: chm:ct (c:nt'd) >

HH 112D6542 1 SPRING, UPPER 11 112D6543 1 SPRING, LOWER JJ 112D6544 1 ROD, TIE KK 112D6545 1 TIE ROD SPRING ASSY LL 112D6594 1 SPRING, RETAINER MM 112D6595 1 BRACKET YOKE NN 112D6596 1 UPPER SUPPORT SHORT 00 112D6597 1 NUT, LOCK PP 112D6598 1 BOLT, TENSION ARM QQ 112D6599 1 ARM, TORSION RR 112D6607 1 MID SUPPORT ASSY SS 112D6612 1 SUPPORT, MID SHROUD l

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afQCmod. doc Affidavit Page 6 l i

ATTACHMENT A Quad Cities Station Unit I and Unit 2 Core Shroud Repair Design Documents l f

I Enclosures I through 9 '

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l ATTACHMENT A I

The Quad Cities Unit I and Unit 2 core shmud repair Design Documents are pmvided in the following l

Enclosures:

l Enclosure 1. GENE Design Specification,25A5668 Revision 2, "Shmud Stabilizer Hardware - r Quad Cities Units 1 & 2" Enclosure 2. GENE Code Design Specification,25A5669, Revision 2, " Reactor Pressure Vessel -  ;

Quad Cities Units 1 & 2"  !

Enclosum 3. GENE Fabrication Specification,25A5670, Revision 2. " Fabrication of Shroud Stabilizer" l Enclosure 4. GENE Installation Specification,25A5615, Revision 0, "Shmud Stabilizer Installation- Quad Cities Units 1 & 2" t Enclosure 5. GENE 771-7l-1094, Revision 1, " Quad Cities Units 1 & 2 - Shroud Repair Seismic Analysis" Enclosure 6. GENE 771-68-1094, Revision 2, "Shmud and Shmud Repair Hardware Stress Analysis -

Shmud Repair for Hi Thmugh H7 Welds for Commonwealth Edison Quad Cities Nuclear  ;

Power Station Units 1 and 2" i Enclosure 7. GENE Stress Repon,25A5672. Revision 1. " Pressure Vessel - Quad Cities I and II" l Enclosure 8. One color picture of a computer model of the core shmud sepair installed at Quad Cities.

Enclosure 9. Construction dmwings of the core shmud hardware, as listed below.

Construction Drawings  ;

! l. Reactor Modification / Installation Drawing 107E5487 Sheet I of 3, Revision 1 ,

Rextor Assembly  ;

2. Reactor Modification / Installation Drawing 107E5487 Sheet 2 of 3 Revision 1 Reactor Assembly

3. Rextor Modification / Installation Drawing 107E5487 Sheet 3 of 3 Revision 1 ,

Reactor Assembly ,

4. Assembly Dmwing 112D6506, Revision 1, Sheet I of 1, Lower Stabilizer Assembly [

l 5. Assembly Dawing i12D6508, Revision 1, Sheet 1 of 1, Toggle Bolt Assembly  !

6. Assembly Dmwing i12D6509, Revision 1, Sheet I of 1, Tie Rod Assembly l 7. Assembly Dmwing i12D6510 Revision 1, Sheet I of 1, Stabilizer Support Assembly i l 8. Assembly Dmwing 112D6511, Revision 1, Sheet 1 of 1, Upper Support Assembly )

9. Detail Drawing Il2D6512, Revision 1 Sheet 1 of 1 Latch

10. Detail Dmwing 112D6513, Revision 1, Sheet 1 of 1, Screw, Mid Suppon

11. Detail Drawing il2D6514, Revision 1, Sheet I of 1 Ring, Mid Suppon i

12. Detail Dmwing Il2D6515, Revision 1, Sheet 1 of 1 Washer, Jack Bolt

13. Detail Dmwing Il2D6516, Revision 1, Sheet 1 of 1, Sleeve, Jack Bolt

14. Detail Drawing Il2D6518, Revision 1 Sheet 1 of 1, Retainer

15. Detail Dmwing Il2D6519, Revision 1, Sheet 1 of 1, Nut, Top Suppon

16. Detail Drawing 112D6520, Revision 1, Sheet I of 1, Bolt, Top Suppon

17. Detail Drawing ll2D6521, Revision 1, Sheet 1 of 1, Pin

18. Detail Drawing 112D6522, Revision 1, Sheet 1 of 1, Nut, Tie Rod

19. Detail Dmwing 112D6523 Revision 1, Sheet 1 of 1 Pin, Clevis

20. Detail Drawing Il2D6525. Revision 1, Sheet 1 of 1, Extension, Lower Spring I

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ATTACHMENT A (continued)

Quad Cities Units 1 and 2 Cose Shroud Design Modification Document List:

Construction Drawines (continued)

21. Detail Drawing i12D6527, Revision 1, Sheet 1 of 1 Screw, Yoke

22. Detail Dmwing 112D6528, Revision 1, Sheet 1 of 1, Bmcket, Upper Spring

23. Detail Drawing Il2D6529, Revision 1, Sheet 1 of 1, Clip, Retainer

24. Detail Dmwing 112D6530, Revision I, Sheet 1 of 1, Bolt, Jack

25. Detail Drawing 112D6531, Revision 1, Sheet 1 of 1, Nut, Toggle Bolt

26. Detail Dmwing 112D6532, Revision 1, Sheet 1 of 1 Washer, Toggle Bolt

27. Detail Drawing 112D6533, Revision 1, Sheet I of 1, Pin, Toggle Bolt J 1

28. Demil Drawing 112D6534, Revision 1, Sheet 1 of 1, Toggle

29. Detail Drawing i12D6535, Revision 1, Sheet 1 of 1, Suppon, Lower

30. DetailDrawing 112D6536, Revision 1, Sheet 1 of 1, Bolt, Toggle ,

31. Detail Drawing 112D6537, Revision 1 Sheet 1 of 1, Contxt, Upper

32. Detail Dmwing Il2D6539, Revision 1, Sheet 1 of 1, Contact, Lower ];

33. Detail Dmwing 112D6540, Revision 1, Sheet 1 of 1, Suppon

34. Detail Drawing 112D6541, Revision 1, Sheet I of 1, Upper Suppon, Long

35. Detail Dmwing 112D6542, Revision I, Sheet I of 1, Spring, Upper l

36. Detail Drawing Il2D6543, Revision 1, Sheet 1 of 1, Spring, Lower i

37. Detail Drawing ll2D6544, Revision 1, Sheet I of 1, Rod, Tie

38. Assembly Drawing Il2D6545, Revision 1 Sheet 1 of 1, Tie Rod-Spring Assembly ,

l 39. DetailDrawing Il2D6594, Revision 1, Sheet i of 1, Spring, Retainer i l

40. Detail Drawing i12D6595, Revision 1, Sheet 1 of 1, Bracket Yoke l

41. Detail Dmwing 112D6596, Revision 1, Sheet 1 of 1, Upper Suppon Shon I l

42. Detail Drawing Il2D6597 Revision 1, Sheet 1 of 1, Nut, Lock

43. Detail Dmwing i12D6598, Revision 1, Sheet 1 of 1, Bolt, Torsion Ann l 44. Detail Drawing 112D6599, Revision 1, Sheet I of 2, Arm, Torsion i 45. Detail Dmwing i12D6599, Revision 1, Sheet 2 of 2, Ann, Torsion l 46. Assembly Dmwing 112D6607, Revision 1, . Sheet 1 of 1, Mid Suppon Assembly 112D6612 Revision 1, Sheet 1 of 1

47. Detail Drawing Suppon, Mid-Shroud

48. Assembly Drawing 112D5256, Revision 1 Sheet I of 1, Bracket Yoke Assembly

49. Detail Drawing Il2D5264, Revision 1, Sheet I of 1, Lock, Bolt 1

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Enclosure 1 GENE Design Specification,25A5668, Revision 2

" Quad Cities Units 1 & 2 - Shmud Stabilizerliardware" )

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