ML20092K980

Requests That Repair Plan Info for Pbaps,Units 2 & 3 Be Reviewed & Approved by 950801 in Order to Support Contingency Repair Option for Upcoming Outage Scheduled for Sept 1995.Repair Plan,Encl

ML20092K980
Person / Time
Site:	Peach Bottom
Issue date:	06/22/1995
From:	Hunger J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20092K955	List: ML20092K980 ML20092K987
References
NUDOCS 9509260225
Download: ML20092K980 (10)

Text

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_ddhw 10 CFR 50. 55a(c) (3)

=sgre 1 PECO ENERGY 2l 270.,. l 965 Chesterbrook Boulesard j Wayne. PA 19087-5691  ;

June 22, 1995 Docket Nos. 50-277 50-278 License Nos. DPR-44 i DPR-56 i

U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555  :

Subject:

Peach Bottom Atomic Power Station, Units 2 and 3 Submittal of Proposed Alternative Repair Plan In Accordance with 10 CFR 50.55a(a) (3) l l

Dear Sir:

In our letter from G. A. Hunger, Jr. (PECO Energy Company) to U. S. Nuclear Regulatory Commission (USNRC), dated September 16, 1994, PECO Energy Company requested review and i approval of the proposed repair plan for the Peach Bottom Atomic Power Station (PBAPS), Unit 2 core shroud, in accordance with 10 CFR 50.55a(a) (3), in the event that such '

a repair is determined to be necessary. Supplemental t

information regarding the PBAPS, Unit 2 repair was provided L in our letter dated September 26, 1994. In our letter dated i

February 14, 1995, PECO Energy Company supplied revised ,

repair plan information. This information was revised, in part, to include applicability to PBAPS, Unit 3.

In order to incorporate changes and improvements identified since the last submittal, and to demonstrate the acceptability of the repair design considering assumed complete cracking of weld H-8, Attachment 1 contains further revisions to the repair plan information. Additionally, attached are responses to questions that have been asked of similar Boiling Water Reactors. These responses are being submitted in anticipation of the same questions being asked of the PBAPS shroud repair plan.  ;

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We request that the attached repair plan information for PBAPS, Units 2 and 3 be reviewed and approved by August 1, 1995 in order to support a contingency repair option for the upcoming PBAPS, Unit 3 outage currently scheduled for September 1995.

Faclosure 3 9509260225 950915 PDR ADOCK 05000277 P PDR ,

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Jun3-22, 1995 pig 3 2 Due to the requested expediency in the review of the i package, PECO Energy Company welcomes a meeting.with the '!

USNRC to. discuss the repair package and respond to any )

further questions.

Attachment 2 contains information proprietary to. General Electric._ General Electric requests that the Attachment 2 information be withheld from public disclosure in accordance  !

= with 10 CFR 2.790(a) (4) . In accordance with 2.790(b) (1), an affidavit supporting this request is provided in Attachment 2.

If you have any questions, please contact us.

l very truly yours, fe G. A.-Hunger, Jr.,

Director - Licensing .

Attachments )

cc: _T. T. Martin, Administrator, Region I, USNRC  !

W. L. Schmidt, USNRC Senior Resident Inspector, PBAPS  ;

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General Electric Company AFFIDAVIT f.

I, George B. Stramback, being' duly sw6rn, depose and state as fbliows:

. (1) I am Project Manager, Licensing Services, General Electric Company ("GE") and .

have ben 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 reports GENE-771-60-0994, "ShroudMechanicalRepair Program Peach Bottom Units 2 &

3 Seismic Analysis", Revision 2, (GE Proprietary), June,1995, GENE-771-58-0994,

" Shroud Mechanical Repair Program Peach Bottom Units 2 & 3 Shroud and Shroud Repair Hardware Stress Analysis ", Revision 4, (GE Proprietary), June,1995 -

and drawings 105E1455, Rev. 2, " Reactor Modification & Installation Drawing" and those listed in the Attachment. These documents, taken as a whole, constitutes a proprietary compilation ofinformation, some ofit also independaatly proprietary,

. prepared by the General Electric Company. The independently proprietary elements that are drawings are delineated by the GE drawings being marked as proprietary information and the independently proprietary elements that are in reports are -

' delineated by bars marked in the margin adjacent to the specific material.

(3) .. In making this application for withholding of proprietary information of which it is -

the owner, GE relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"),5 USC Sec. 552(b)(4), and the Trade Secrets Act,18 USC Sec.1905, and NRC regulations 10 CFR 9.17(a)(4), 2.790(a)(4), and

- 2.790(d)(1) for " trade secrets and commercial or financial information obtained from a person and privileged or confidential" (Exemption 4). The material for which exemption from disclosure is here sought is all " confidential commercial information", and some portions also qualify under the narrower definition of " trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Ma== Fnerav Project v. Nuclear Remdaenry e

< Comminion. 975F2d871 (DC Cir.1992), and Public Citiven Health Recanech Groun

v. FDA,704F2dl280 (DC Cir.1983).

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

GBS-95 7-afPBmod3. doc Affidavit Page 1 e

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

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

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

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

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

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

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

That information (both the entire body ofinformation in the form compiled in these drawings, and the marked individual proprietary elements) is of a sort customarily ,

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 corfidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.

(6) Initial approval of proprietary treatment of a document is made by the manager of  !

the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to such documents within GE is limited on a "need to know" basis.

(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical' content, competitive effect, and determination GBS-95-7-afPBmod3. doc Afridavit Page 2

i of the accuracy of the proprietary designation. Disclosures outside GE are limited to I regulatory bodies, customers, and potential customers, and their agents, suppliers, j 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 of information, including reports and detailed design drawing results of a hardware design modification (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 of the supporting processes was at a significant additional cost to GE, in excess of a million dollars, over and above the large cost of developing the underlying individual proprietary reports 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 includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

GE's competitive advantage will be lost if its 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. ,

1 While some of the underlying analyses, and some of the gross structure of the l process, may at various times have been publicly revealed, enough of both the l 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

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the context and level of detail provided in the subject GE drawings, were to be l disclosed to the public. Making such information available to competitors without l their having been required to undertake a similar expenditure would unfairly provide l

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", 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. l 1

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s STATE OF CALIFORNIA ) -

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COUNTY OF SANTA CLARA ) /

George B. Stramback, being duly sworn, deposes afid 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 /4 S day of 1995.

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' ~ 'Gedrge B.stramback l General Electric Company  ;

Subscribed and sworn before me this day ofU SW 1995.

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{ Notory Ptenc - c8* Notary Public, State of CaliforniaD j

. SANTA CLARA ColsNTY My Comm. Edes DEC 1.M8 y f

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1 Attxchment Drawing Numher B. I12D6348 Rev.3 Stabilizer Support Assembly D. I12D6350 Rev.3 Rod, Tie "

I. 112D6353 Rev.2 Support, Upper AAA. I12D6752 Rev.O Spacer, Upper Support I BBB. I12D6777 Rev.0 Nut, Tie Rod w

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8 7,8,9 S"ASILIZER CODE, DESIGN SPEC. 25A5580 FABRICATION SPEC, 25A5001 1 1 1 CL EANING AND CLEANLINESS CONTROL 21A2040 1 1 1 IN!TALLATION SPECIFICATION 25A5581 0 2 8,9 REACTOR VEN! STfiEBS REPORT 25A5407 2 4 7.9 SHROUD & REPAIR HARDWARE STRESS ANALYSIS 771 56-0004 2 4 7,9 STA9U75R INSTALLATION , DES 4GN REPORT 771-56-0994 2 4 7,9 SEISMIC ANALYSIS 771 60-0094 1 2 7 FIELD DISPOSITION INSTRUCTION 0257 71067 1 1 1 PL112D6347 1 1 1 PARTS LIST PARTS LIST PL11206348 0 1 1 PARTS LIST PL1120".,349 0 0 1 "P4MTS LIST PL112D6358 0 0 1 PARTS LlST PL11206350 0 0 1 PARTS LIST PL112D6360 0 0 1 PARTS LIST PL112D6495 0 0 1 PARTS LlST PL105E1455 1 2 8 NUT, TIE ROD 11206313 0 0 1 NUT, TOP SUPPORT 11206321 3 3 1 BOLT, TOP SUPPORT 112D6322 0 0 1 NUT, TOP SUPPORT 112D6323 0 0 1 RETAINER 112D6324 1 1 1 SPRING, RETAINER 112D6325 1 1 1 SLEEVE, JACK 11206327 0 0 1 WASHER, JACK 112D6328 0 0 1 RING, MID SUPPORT 112D6331 2 2 1 SCREW, MID SUPPORT 112D6332 0 0 1 LATCH 112D6338 'O 0 1 UPPER STABILIZER 112D6347 2 2 1 STABIL12ER SUPPORT ASSEMBLY 11206348 2 3 8 TIE ROD ASSEMBLY 112D6349 1 1 1 112D6350 2 3 8 ROD. TIE SPRING, LOWER 11206351 1 1 1 SPRING, UPPER '11206352 2 2 1 SUPPORT, UPPER 11206353 1 2 8 SUPPORT 112D6354 2 2 1 CONTACT, LOWER 112D6355 1 1 1 SUPPORT, MID 11206356 1 1 1 CONTACT, UPPER 112D6357 1 1 1 TIE ROD / SPRING ASSEMBLY 11206358 1 1 1 MID SUPPORT 11206350 1 1 1 LOWER STABlu2ER 112D6360 1 1 1 BOLT, TOGGLE 112D6489 2 2 1 )

SUPPORT, LOWER 112D6490 2 2 1  :

TOGGLE 11206491 2 2 1 PIN, TOGGLE BOLT 11206492 1 1 1 WASHETTOGGLE BOLT 112D6493 1 1 1 NUT, TOGGLE BOLT 112D6494 2 2 1 TOGGLE BOLT ASSEMBLY 11206495 1 1 1 BOLT, JACK 112D6496 1 1 1 SPRING, RETAINER 112D6497 1 1 1 ,

BRACKET, UPPER SPRING 11206498 2 2 1 l 112D6501 1 SCREW, TOP SUPPORT BOLTING 1 1

~ COUPLING, TOP SUPPORT BOLTING 112D6502 2 2 1 EXTENSION, LOWER SPRING 11206503 1 1 1 112D6504 1 1 1 PIN PIN, CLEVIS 11206505 1 1 1 1 ARM, TORSION 112D5242 1 1 1 l

1 BOLT, TORSION ARM 11205243 1 1 NUT, LOCK 11205244 0 0 1 105E1455 1 2 8 MODIFICATION DRAWING SP ACER, UPPER SUPPORT 112D6752 N/A 0 8 NUT, TIE ROD 11206777 N/A 0 8 DRF B13-01732 N/A 0 N/A GE RESPONCES TO NRC QUESTIONS I