ML20098E097

Forwards C-E Nonproprietary & Proprietary Info in Response to NRC 920331 RAI Re Util Response to 1991 PTS Rule, .Proprietary Info Withheld (Ref 10CFR2.790)

ML20098E097
Person / Time
Site:	Calvert Cliffs
Issue date:	05/22/1992
From:	Creel G BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19303E865	List: ML20098E097
References
NUDOCS 9206010262
Download: ML20098E097 (24)

Text

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B ALTIMORE l

GAS AND 1650 CALVERT CLIFFS PARKWAY . LUS8Y, MARYLAND 20657-4702 GEORGE C. CREEL vict PntsiotNT nucle AR E,4mov (4:0)260-4455 htay 22,1992 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATI'ENTION: Document Control Desk

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SUBJEQ Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2: Docket Nos. 50-317 & 50-318 Response to NRC's Request for Additional Information Regarding Baltimore Gas and Electric Company's Response to the 1991 Pressurized Thermal Shock Rule, dated March 31.1992.

REFERENCES:

(a) Letter from hir. D. G. hicDonald, Jr. (NRC) to hir G. C. Creel (BG&E), dated hiarch 31.1992, Request for AdditionalInformation Concerning BG&E's Response to the 1991 PTS Rule (b) Letter from hir. G. C. Creel (BG&E) to NRC Document Control Desk, dated December 13, 1991, Response to the 1991 Pressurized -

Thermal Shock Rule Gentlemen:

By a letter dated htarch 31,1992 (Reference a), you transmitted a request for additional information regarding our December 13,1991 response (Reference b) to the 1991 Pressurized Thermal Shock (PTS) Rule. Accordingly, we hereby provide you with the information contained in the attachments to this letter as our response. Attachment (1) contains the non-proprietary version of the response to Question No.1 and the responses to Questions No. 2 and No. 3. Attachment (2) is an ABB/CE proprietary affidavit for Attachment 3, pursuant to 10 CFR 2.790. Attachment (3) contains the proprietary version of our response to Question No.1. We trust that you will find this information satisfactory.

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Document Control Desk hiay 22,1992 Page 2 Should you have any further quest;ons regarding this matter, we will be pleased to Jiscuss them with you.

Very truly you

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Attachments: (1) Non-Proprietary Respcase to N'RC's hfarch 31,1992 Request for Additional Information Regarding Baltimore Gas and Electric Company's Response to the 1991 Pressurized Thermal Shock Rule, dated December 13,1991 (2) Proprietary Affidavit for Attachment (3)

(3) ABB/CE Proprietary Ruponse to Qu:stion No.1 of NRC's h1 arch 31,1992, Request for Additional Informadon Regarding Baltimore Gas and Electric Company's Response to the 1991 PTS Rule, dated December 13,1991 cc: (With Attachment 1 only)

D. A. Brune, Esquire J. E. Silberg, Esquire R. A. Capra, NRC D. G. AlcDonald, Jr., NRC T. T. hiartin, NRC P. R. Wilson, NRC R. I. h1cIxan, DNR -

J. H. Walter, PSC

- ATTACHMENT (11

- Non-Proprietary Response to NRC's March 31,1992 Request for Additional Ir.rormation

> Regarding Baltimore Gas and Electric Company's Resp (mse to the 1991 Pa rqr((t 9 Thermal Shock Rule, dated December 13,1991 0

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f Baltimore Gas & Electric Company Docket Nos. 30 317 and 50-318 May 22,1992 I

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ATTACIIMENT (1)

Non Proprietary Response to NRC's March 31,1992 Request for Additional laformation Regarding Italtimore Gas and Electric Company's Response to the 1991 Pressurized Thermal Shock Rule, dated December 13,1991 COMBUSTION ENGIN: RING, INC.

ATTACHMENT TO ABB LETTER B-MECH-92-109 RESPONSE TO USNRC QUESTION ON -

DIFFERENCES IN REPORTED NICKEL CONTENT MAY 14, 1992 ABB COMBUSTION ENGINEERING NUCLEAR POWER COMBUSTION ENGINEERING, INC.

WINDSOR, CONNECTICUT l

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NITACHMENT (1)

Non Proprietary Response to NRC's March 31,1992 Request for AdditionalInformation Regarding llattimore Gas and Electric Company's Response to the 1991 l'ressurized Thermal Shock Rule, dated December 13,1991 Combustion Engineering, Inc.

Hay 14, 1992 Attachment to Letter B-MECH-92-109 l

Response to USNRC Question on Differences in Reported Nickel Content

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O y

ouestion 1 y

i section 1.0 of "Calvert Cliffs Unit No. 1 and No. 2 Reactor Vessel Beltline Materials," Revision 2, indicates MIL B-4 Modified weld wire with nickel in the range of 0.6 to 1.1 wt. ? was used to fabricate the reactor vessels.

Heats No. 33A277 and No. 10137 are reported to have 0.23 wt. % and 0.05 wt. %,

respectively. If MIL B-4 Modified weld wire was used to fabricate the welds in the Calvert Cliffs reactor vessels, why do welds using Heats No. 33A277 and No. 10137 wire have less than 0.6 wt. t nickel?

RO SDo:is e t Heats No. 33A277 and No. 10137 were not MIL B-4 Modified, they were designated MIL B-4 (Hi-Mn-Mo) without a specified nickel content. Heat No. A8746 was also a MIL B-4. The following statement in Section 1.0 of "Calvert Cliffs Unit N7. 1 and No. 2 Reactor Vessel Beltline Materials," Revision 2 (Attachment A to BG&E's December 13, 1991 PTS submittal, Reference b) is -

incorrect:

"For the Calvert Cliffs Vessels, CE employed a submerged arc welding process using MIL B-4 Modified (Mn-Mo-NL) wire with nickel in the range of 0.6 to 1.1 wt. %. The MIL B-4 Modified (Mn-Mo-NL) welds were produced with either a Linde 1092, 0091 or 124 flux."

The statement should be replaced in its entirety with:

"For the Calvert Cliffs Vessels, CE employed a submerged arc welding process using wire designated in supplier certifications as MIL B-4 and MIL B-4 Modified. (

1*

• [ ] indicate blanked proprietary information.

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ATTACIIMENT (1)

Non. Proprietary Response to NRC's March 31,1992 Request for Additional Information Regarding Baltimore Gas and Electric Company's Responst. to the 1991 Pressurized Thermal Shock Rule, dated December 13,1991 Combustion Engineering, Inc.

May 14, 1992 Attachment to Letter B-MECH-92-109 (continued)

Discussion BC&E commissioned ABB/CE to review welding electrode purchase specifications between November, 1965 and February, 1971. Weld material certifications and release reports spanning the period between October, 1968 and June, 1971 were '

also reviewed. The electrode specifications were reviewed for terminology and required nickel content. (

)

The weld material certification and release reports functioned to officially release the electrode / flux combinations for use on ASME Code Section III work.

Several identification documents were attached to the reports including CE laboratory tests and the electrode supplier's certifications. (

}

We expect Ni to be low in the Hi-Mn-Mo materials because it was not an intentional alloying addition.

The CCNPP Unita No. 1 and No. 2 beltline welds are listed in Table 1 below.

For each weld seam, the nickel content reported in BG&E's December 13, 1991 PTS submittal, the specified weld wire type (per weld precedure), the wire heat number (s), and the weld wire type given in the supplier certification (where known) are indicated. The reported nickel content and the wire type are consistent in all cases except for Unit No. 2 Welds No. 2-203 A, B, C; for these welds the nickel content was conservatively estimated in the December 13 submittal. Based on the results of this records review and pending QA verification of the records, BC&E expects to revise its estimate of upper bound nickel content for Unit No. 2 Weld Sea.ns No. 2-203 A, B, C to approximately 0.20% Ni.

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• [ ] indicate blanked proprietary information.

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ATTACIIMENT (1) i Non-l'roprietary Resp <mse to NRC's March 31,1992 Request for Additional Information Regarding I

llattimore Gas and Electric Company's Response to the 1991 l'ressurized Thermal Sluxk Rule, dated December 13,1991 Combustion Engineering, Inc.

Hay 14, 1992 Attachment to Letter B-MECll-92-109 (continued)

TABLE 1 CCNPP BELTLINE WELD WIRES Reported Wire CCNPP Nickel Heat Unit Weld Sean Conten' No.

1 2-203 A/C 0.88 12008 20291 3-203 A/C 0.69 21935 1 9-203 0.23 33A277 2 2-203 A/C 1.01 A8746 2 3-203 A/C 0.23 33A277 2 9-203 0.05 1013"

• [ ] indicate blanked proprietary information.

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l NITACilMENT (1)

Non Proprietary Response to NRC's March 31,1992 Request for Additional Information Regarding Italtimore Gas and Electric Company's Response to the 1991 Prenurized Thermal Shock Hule, dated December 13,1991 Question No. 2 Do the test resuhs from the Calvert Cliffs reactor vessel surveillance program indicate that the values of Pressuri:ed Thermal Shock (PTS) calculated using the methodology specified in the PTS nde are applicable to the Calvert Cliff reactor vessels?

For weld wire heats not in the Calvert Chffs reactor vessel surveillance program, do test resuhs from other vessel surveillance programs (NRC data source provided with this RAI) indicate that the values of the PTS calculated using the methodology specified in the PTS nde are applicable to the Calvert Chffs reactor vessels?

RESPONSE

We have reviewed the measured RTyrs shift results for welds in the surveillance programs of the plants identiGed in the NRC data soure' ncvided with the RAI. We have separatec the surveillance program retults into the following categories:

Catego:y 1 - Test results for the Calvert Cliffs reactor vessel surveillance programs.

Category 2 - Test results for the weld wireinux combinations in other plant's surveillance programs that are the same as weld wire / flux combinations in the Calvert Cliffs reactor vessels' beltlines.

Category 3 - Test results for the weld wire / flux combinations in other plant's surveillance programs that are not in the Calvert Cliffs reactor vessels' beltlines.

Category 4 - These are BWR Plants and either no data exists or capsule results are not considered credible for comparison to n PWR because oflow accumulated fluence.

Test results from Category 1 and 2 surveillance programs indicate the values of A RTpi3 calculated using the methodology specified in the PTS rule bound the surveillance measurements.

Test results from Category 3 surveillance programs indicate the values of A RTpu calculated using the methodology specified in the PTS rule bound the surveillance measurements with the exception of Fort Calhoun.

1)1SCUSSION The measured ARTNDT results have been comparco with the predicted ARTPTs plus the two sigma margin term (56aF) to determine if the PTS rule is bounding for welds in the Calvert Cliffs reactor vessels.

Table 2 provides the results of Category 1 and 2 Surveillance programs. Table 3 provides the results of Category 3 Surveillance Programs. Table 4 provides a listing of Category 4 Surveillance Programs.

Figure 1 provides a comparison of Category 1 and 2 Surveihnee results to the PTS rule predictions.

Figure 2 provides a comparison of Category 3 Surveillance results to the PTS rule predictions.

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ATTACllMENT (1)

Non Proprietary Response to NRC's March 31,1992 Request for AdditionalInformation Regarding llaltimore Gus and Electric Company's Response to the 1991 Prenurized Thermal Shmk Rule, dated December 13,1991 The figures compare measured and predicted values of ARTNDT instead of RTPTs. Calculation of rr.. sured values of RTPTs requires application of a margin term. Methodology for choosing a margin term for measured data that do not meet the credibility criteria in Regulatory Guide 1.99, Revision 2 has not been developed. Therefore, we have not determined values of RTPTs based on measurements, for application of other vesse"s sutveillance data to Calvert Cliffs.

13ased on the review of these test results. BG&E believes the values of ARTPTs for the Calvert Cliffs Reactor Vessel Beltlines reported in the Response to the 1991 PTS rule are applicable and probably conservative.

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Non-Proprietary Response to NRC's March 31,1992 Request ihr Additional Infbrmation Regarding Bahimore Gas and Electric Comp ny's -

Response to the 1991 Pressurized Thermal Shock Hule, dated December 13,1991 l 4 i

Table 2 Calvert Cliffs Reactor Vessel Surveillance Program Results (Category 1) and Results from Surveillance Progrants that Contain Weld Wire Heat Used in the Manufacture of Calvert Cliffs Beltline (Category 2)

Measured Shift Predicted Shift Predicted Shift Weld Wire Heat Minus Flux Type Chemistry Fluence (@ 30 ft. - Ibs.) PTS Rule)

Surveillance 2 { F) Measured Shift Program / Category Flux Lot Cu% N1% Factor (x1018 "/cm ) ( F)

Calvert Cliffs 1 0.61 c 59 c 103 44

.24 a .18 a 119 g (Cateaory 1) 33A277b 0091b 3922e w

2 Calvert Cliffs 2 "

91 69d 86 17 (Category 1) 10137b 0091b 3999b .20d .04d .806d U 66 -14 583f 80g h

& Farley 1 1.65 e 2.8 80s 100g 89 99 9

-1 3922g 14 e 19 e 70

< (Category 2) 33A277 9

0091 9 9 160 159 -1 20291 & 414 McGuire 1 229 64 (Category 2) 12008; 1092 3854; .21h .8Sh 210 1.  ; 1 ,

i Note: Subscripts identify references for source documents given at the end of this attaehment l

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Non-Proprietary Response to NRC's March 31,1992 Request for Additional Information Regarding llattimore Gas and Electric Company's Response to the 1991 Pressurized Thermal Shock Rule, dated December 13,1991 Table 3 Resul.s from Surveillance Programs that Do Not Contain Weld Wire -

IIcats Used in the Manufacture of Calvert Cliffs Beltline (Category 3)

I Weld Wire Heat Measured Shift Predicted Shift Predictad Shift Survell!ance Flux Type Chemistry F (@ 30 ft. - Ibs.) (PTS Rule) Minus Program / Category Flux Lot Cu% Ni% Factor (x10gence"/cm2 ) Measured Shift

( F) ( F)

Diablo Canyon 1 (Category 3) 27204j 1092j 3714) .21j .98j 226 .298j. 110 3

151 41 I

Diablo Canyon 2 21935 & .351 174 146 -28 (Category 3) 12008k 1092k 3869k 22k .83k 205 .88f 204I 198 -6  ;

.18 m 8 rn 112 32  !

E- .62 1 m,0 178 13 m

K D. C. Cook Unit 1 1.0d" m 200 m M 9 b

et (Category 3) 13253 n 1092 n 3791 n 27m 74 m 206 1.88m 205 m 242 37 E *

.567 222q 187 -35 U 9 256 Maine Yankee 1.76 270 -14 (Category 3) IP3571 o 1092 o 3958o .31 o .76o 222 7.13 345 325 -20

'< Millstone Unit 2 i (Category 3) 90136 r 0091 r 3998 r .30 r .06r 136 .378 r 76 r 99 23 St. Lucie Unit 1 .55 74 s 92 18 (Category 3) 90136 s 0091 3 3999 s .23 s ll s 110 .71ds 73 s 100 27 Fort Calhoun (Category 3) 305414 u 1092 u 3951 u .351 .60 t 212 .51t 238 t 172 4

.599y 175y 162 13 ,

Kewaunee 2.07 235 y 226 -9 )

(Categ 3ry 3) IP3571 y 1092y 3958y .20y .77y 189 2.89 230 y 2<2 12 Note: Subscripts identify references for source documents given at the end of this attachment

ATTACIIMENT (1)

Non Proprietary Response to NRC's March 31,1992 Request for Additional Information Regarding llaltimore Gas and Electric Company's Response to the 1991 Pressurized Thermal Shock Rule, dated December 13,1991 Table 4 Reactor Vessels Included on the NRC List Provided with the RAI without Applicable Surveillance Results (Category 4)

Vessel Reason for Exclusion from Consideration Cooper BWR Fermi No. 2 BWR Fitzpatrick BWR Hatch No.1 TLWR Hatch No. 2 BWR LaSalle 13WR Pilgrim BWR 9

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FIGURE 1: NRC RAI CATEGORY 1 & 2 SURVEILLANCE DATA lj.s MEASURED RTndt SHIFT VS. PREDICTED RTndt SH!FT 52

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es is FIGURE 2: NRC RAI CATEGORY 3 SURVElLLANCE DATA as a1 MEASURED RTndt SHIFT VS. PREDICIED RTndt SHIFT s2 i? .

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g-Z b~ l i I l l Ti l I t i l 11 l 1 ITT [ t i l I I I I s i s t r i 11 : 111111 l11:270ll41:290 11113 10 1Jtitillill]Illi 330 350 15 0 17 0 19 0 2 10 230 250 50 70 90 110 130 PREDICTED RTndt [^oF) SHIFT

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NITACllMENT (1)

Non Proprietary '8esponse to NHC's March 31,1992 Hequest for AdditionalInformation Regarding

'!;lt!more Gus and Electric Company's Hesponse to the 1991 Preuurized Thermal Shtsk Hule, dated December 13,1991 r

Question 3 How were the embrittlement effects of operating the Calvert Cliffs reactors with the core critical and cold leg temperatures less than 525*F considered? If the reactor vessels nere irradiated (fluence greater than 1016 nkm2) at temperatures less than 525*F, what was the neutron fluence at the various irradiation temperatures? It' hat was the effect of this low temperature  ;

irradiation on the RTFTS valuefw the reactor vessel?

RESPONS,E Calvert Cliffs operates in accordance with a power-depcadent cold leg temperature program ths i

ranges from 532*F at zero uower with the reactor critical to 548aF at 100% power. Consequently, I we did not consider any embrittlement effects that may be realized by operating the Calvert Cliffs reactors with the core critical and coid leg temperature less than 525 + F.

1)lSCUSSION A review of plant operating records verified that, with the exception of flecting excursions during transients at low power, the cold leg temperature has remained above 525aF. We conservatively estimate that no moic than 5 Effective Full Power llours (EFPil) of critical operation has occurred with cold leg temperature below 525aF. Such transitory events correspond to a resultant fluence substantially below 1016 n/cm2, Consequently, the effect of such minimal low temperature irradiation on the RTpu value is negligible. This has been conGrmed by Calvert Cliffs' surveillance capsule results that demonstrate the shift in the reference temperature to be less than predicted.

In addition, BG&E knows of no technical justification supporting 10S n/cm2 as a valid criterion oeyond which embrittlement efferts at low irradiation temperatures must be " considered."

Therefore, until a technical basis is demonstrated,10" rt'em2 does not appear to be an appropriate

" screening criterion" and is not accepted by BG&E.

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ATTACIIMENT (1)

Non l'roprietary Henome to NHC's March 31.1992 Request for Additional Information Hegarding Italthwre Gas and Electric Company's Response to the 1991 Pressurized Thermal Shock Hule, dated December 13,1991 REERENCES a) CENPD 34, " Summary Rer mt on Manufacture at Test Specimens and Assembly of Cap ules for Irrad!ation Surveillance of Calvert Cliffs - Unit 1 Reactor Vessel blaier!als," Fcbruary 4,1972.

b) Creel, G.C, letter dated December 13,1991, " Response to the 1991 Pressurized Thermal 3 hock Rule."

c) Pescin, J. S., E. O. Fromm, D. R. Farmelo, R. S. Denning, and R. G. Jung," Calvert Cliffs Unit 1 Nuclear Plant Reactor Pressure Vessel Surveillance Program Capsule 263," Battelle, December 15,1980.

d) Norris, E. D.,

• Reactor Vessel Material Surveillance Program for Calvert Cliffs Unit 2 Analysis of 263

• Capsule," SwRI 7524, September,1985.

c) Boggs, R. S., S. E. Yanichko, C. A. Cheney, and W. T. Kaiser, " Analysis of Capsule U from Alabama Power Company Joseph M. Farley Unit 1 Reactor Vessel Radiation Serveillance Program," WCAP-10474, February,1984.

f) Yanichko, S. E., E. L Anderson, and W. T. Kaiser, " Analysis of Capsule Y from the l l

Alabama Power Company Parley Unit 1 Reactor Vessel Radiation Surveillance l Program," WCAP 9717, June,1980.

g) Shogan, R. P., L Albertin, S. E. Yanichko, and E. P. Lippencott, " Analysis of

Capsule X from the Alabama Power Company Joseph M. Farley Unit 1 Reactor ,

Vessel Radiation Surveillance Program," WCAP-11561 Rev.1, September,1987.

h) Yanichko, S.E.. T, V. Conj;edo, and W. T. Kaiser, " Analysis of Capsule U from the Duke Power Company EGuire Unit 1 Reactor Vessel Radiation Suiveillance Program," WCAP 10786, February,1985.

i) Yanichko, S. E., S. L Anderson, L Albertin, and N. K. Ray, " Analysis of Capsule X from the Duke Power Company McGuire Unit 1 Reactor Vessel Radiation Surveillance Program," WCAP 12354 August,1989.

j) Yanichko, S. E., S. L Anders ,n, J. C. Schmertz, and L Albertin, " Analysis of Capsule S from the Paciiic Gas & Electric Company Diablo Canyon Unit 1 Reactor Vessel Radiation Suweillance Program," WCAP-11567, December,1987.

k) Yanichko, S. E., S. L Anderson, and L Albertin, " Analysis of Capsule U from the Pacific Gas & Electric Company Diablo Canyon Unit 2 Reactor Vessel Radiation Surveillance Program," WCAP-11851, May,1988,

1) Terck, E., S. L Anderson, and 1 Albertin, " Analysis of Capsule X from the Pacific Gas & Electric Company Diablo Canyon Unit 2 Reactor Vessel Radiation Surveillance Program," WCAP-12811, December,1990.

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A1TACllMENT (1)

Non Proprietary Response to NRC's March 31,1992.4equest for AdditionulInformution Regarding llattimore Gas and Ibetric Compunf 6 Response to the 1991 Pressurized Thermal ShotL llule, dated I)ecember 13,1991 m) Terck, E., S. L. Anderson, L Albertin, and N. K. Ray, " Analysis of Capsule U from the American Electric Power Company D. C. Cook Unit 1 Reactor Vessel Radiation burveillance Program," WCAP-124S3, January,1990.

n) Tillinghast. J., letter to E. G. Case dated November 7,1977, *D. C. Cook Unit 1 Reactor Vessd hiaterial Surveillance Program."

o) Nichols, S. E., letter dated October 28,1991," Update of PTS Assessment to address tLe Revised PTS Rule "

p) Frinic, C. D., letter dated September 30,1991, " Proposed Ch - p No.163: Revision to Combined IIcatup, Cooldown and Pressure Temperature Limitations tr (cflect Analysis of Wall Capsule 253."

q) " Application of Reactor Vessel Suncillance Data for Embrittleme-t hianagement,"

CEOG Task 621, November,1990.

r) " Northeast Utilities Service Company h1illstone Nuclear Unit 2 Evaluation of Irradiated Capsule W-97, Reactor Vessel Materials irradiation Surveillance Program,* Combustion Engineering TibN-MCM-008. April,1982.

s) Chicots, J. M., E. P. Lippincott, L Albertin, and N. K. Ray, " Analysis of the Capsule at 104' from the Florida Power and 1.ight Company St. Lucie Unit 1 Reactor Vessel Radiation Surveillance Program," WCAP-12751, November,1990.

t) Omaha Public Power District Fort Calhoun Station Unit 1 Evaluation of Irradiated Capsule W-225 Reactor Vessel Materials Irradiation Surveillance Program,

" Combustion Engineering TibO.MCM-001, revision 1, August,1980.

u) Shott, T. E., letter to G. E. Lear dated September 8,1977, Docket No. 50-285-813.

v) Yanichko, S. E.. S. L. Anderson, and L. Albertin, " Analysis of Capsule P from the Wisconsin Public bervice Corporation Kewaunce Nuclear Plant Reactor Vessel Radiation Surveillance Program," WCAP-12020, November,1988.

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, l NITACIIMENT (2)

Proprietary Aft 1 davit for Attachment (3) i l

Baltimore Gas & Electric Company Docket Nos. 50-317 and 50-318 May 22,1992

AFFIDAVIT PURSUANT l

TO 10 CFR 2.790 '

Combustion Engineering, Inc. )

State of-ConnecticJ,t )

- County of Hartford ) SS.:

I, S. A. Toelle, depose and say that I am the Manager, Nuclear Licensing, of Combustion Engineering, Inc., duly authorized to make this affidavit, and have reviewed or caused to have reviewed the information which is identified as proprietary and referenced in the. '

paragraph immediately below. I am submitting this affidavit in conformance with the provisions of 10 CFR 2.790 of the Commission's regulations in conjunct.on with Baltimore Gas & Electric Company for withholding this information.

The information for which proprietary treatment is sought is.

contained in the following document:

- Attachment to B-MECH-92-209, " Response to USNRC Question on Differences in Reported. Nickel Content," May 14, 1992.

This document has.been appropriately dcaignated as proprietary.

I have personal knowledge of the criteria and procedures

- utilized by Combustion Ongineering in designating information as a ,

trade secret,-privileged er as confidential commercial of 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

,__,.m. _,,.___.___-.......,.,_..,,,,._,.--,.,,.r..,--.,-__-m

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2-information sought to be withheld from public disclosure, included in the above referenced document, chould be withhold.

1. The information sought to be withhe'd from public disclosure, which is owned and has boon held in confidence by Combustion Engineering, is the fabrication processes for reactor vessel welds.

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2. T' 3 information consists of test data or cther similar data I

concerning a procesc, 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 Combuction Engineering and not customarily disclosed to the public. Combustion Engineering has a rational basis for determining the types of information customarily held in confidence by it and, Jn that connection, utilizes a system to ,

determine when and whether to hold certain types of_information ,

in confidence. The details of the aforementioned system were provided to the Nuclear Regulatory Commission via letter DP-537

=from F. M. Stern to Frank. Schroeder dated December 2, 1974.

This system was applied in determining that the subject document herein is proprietary.

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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 informatjon, 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 i confidence.-

6. Public disclosure of the information is likely to cause substantial harm to the competitive position of Combustion

. Engineering because:

a. A similar product -is manufactured and sold by major pressurized water reactor competitors of Combustion Engineering.

b. Development of this information_by C-E required thousands of manhours and hundreds of thousands of dollars.- To the best of my knowledge and belief, a competitor would have to undergo similar- expense in generating. equivalent information.

-c. In order to acquire such information,_a competitor would also require considerable time and inconvenience to establish the fabrication processes for reactor vessel welds.

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d. The information required significant effort ard expense to obtain the licensing approvals necessary for application of l

the information. Avoidance af this expense would decrease a competitor's cost in applying the information and ,

l marketing the product to which the information is -!

applicable.

e. The information consists of the fabrication processes for l

reactor vessel welds, the application of which provides a

)

competitiv9 nconomic advantage. The availability of such l i

information to competitors would enable them-to modify-their product to better compete with combustion Engineering, take n. ,rketing 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 productr and services, significant research, development, engineering, antil y cical, manuf acturing, licensing, quality assurance and other costs and expenses must be included. The ability of Combustion

!- Engineering's competitors to utilize such information-without similar expenditure of resources may enable them to .

. sell at prices reflecting significantly lower costs.

g. Use of the information by competitors in the international

j. marketplace would increase their ability to market nuclear i

steam supply systems by reducing the costs associated with

their technology development. In addition, disclosure i

would have an adverse economic impact on Combustion Engineering's potential for obtaining or maintaining foreign licenseen.

Further the deponent sayeth not, S. A. L9 S. A. Toelle Manager 11uclear Licensing before me Sworn this /5to/L day of sN,7cfA , 1992 ittl/J.- - -.)

N o't a r y P u b P i c My conmicsion exo'res: d / 9M i

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NITACliMENT Q1 I

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AUB/CE l'niprietary Resgxmse to Question No. I of NRC's March 31,1992, Request for Additional Information Regarding Baltimore Gas and Electric Company's Resixmse to the 1991 PTS Rule, Dated December 13,1991 Italtimore Gas & Electric Company Docket Nos. 50-317 and 50 318 May 22,1992