ML20129B132
| ML20129B132 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 10/17/1996 |
| From: | Wadley M NORTHERN STATES POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19355E473 | List: |
| References | |
| NUDOCS 9610220334 | |
| Download: ML20129B132 (7) | |
Text
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Northern States Power Company Prairie Island Nuclear Generating Plant 1717 Wakonade Dr. East Welch, Minnesota 55089 October 17,1996 10 CFR Part 50 Section 50.90 U S Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 PRAIRIE ISLAND NUCLEAR GENERATING PLANT Docket Nos. 50-282 License Nos. DPR-42 50-306 DPR-60 Supplemental Information Related to Elevated F* Steam Generator Tube Repair Criteria License Amendment Reauest in our September 24,1996 License Amendment Request, which proposed the incorporation of Elevated F* Steam Generator Repair Criteria into the Prairie Island Technical Specifications, we committed to submit a revision to Combustion Engineering Report CEN-620-P which would address rerolling of tubes in the upper region of the steam generator tubesheets. In response to that commitment, a proprietary version of Combustion Engineering Report CEN-620-P, Revision 02-P is provided as Attachment 1 to this submittal. A non-proprietary version of the report is under preparation, and will be submitted when it is received from Combustion Engineering.
As the attached revision to Combustion Engineering Report CEN-620-P contains information proprietary to Combustion Engineering, Inc., it is supported by an affidavit (Attachment 2) signed by Combustion Engineering, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in Paragraph (b)(4) of 10 CFR Part 2, Section 2.790 of the Commission's regulations.
Accordingly, it is respectfully requested that the information which is proprietary to Combustion Engineering be withheld from public disclosure in accordance with 10 CFR Part 2, Section 2.790 of the Commission's regulations.
O ATTACHMENT CONTAINS PROPRIETARY INFORMATION TO BE
'20115 WITHHELD FROM PUBLIC DISCLOSURE IN ACCORDANCE WITH 10 CFR PART 2, SECTION 2.790 f
9610220334 961017 V
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PDR ADOCK 05000282 P
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USNRC NORTHERN STATES POWER COMPANY October 17,1996 Pcg9 2 Please contact Gene Eckholt (612-388-1121) if you have any questions related to the attached information.
I Michael D Wadley Plant Manager Prairie Island Nuclear Generating Plant c: Regional Administrator-Ill, NRC NRR Project Manager, NRC Senior Resident inspector, NRC State of Minnesota, Attn: Kris Sanda (w/o proprietary attachment)
J E Silberg (w/o proprietary attachment)
Attachments:
- 1. Combustion Engineering Report, CEN-620-P, Revision 02-P, " Series 44 & 51 Design Steam Generator Tube Repair Using a Tube Re-Rolling Technique",
October 1996 (Proprietary)
- 2. Combustion Engineering Affidavit i
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ATTACHMENT 2 Combustion Engineering Affidavit
AFFIDAVIT PURSUANT TO 10 CFR 2.790 l, Ian C. Rickard, depose and say that I am the Director, Operations 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 conjunction with the application of Northern States Power and in conformance with the provisions of 10 CFR 2 790 of the Commission's regulations.
The information for which proprietary treatment is sought is contained in the following document:
CEN-620-P, Rev. 02-P, " Series 44 & 51 Design Steam Generator Tube Repair Using a Tube Re-Rolling Technique," October 1996.
This document has been appropriately designated as proprietary.
I have personal knowledge of the criteria and procedures utilized by Combustion Engineering in designating information as a trade sectet, privileged or as confidential commercial or financial information.
i Pursuant to the provisions of paragraph (b) (4) of Section 2.790 of the Commission's regulations, the following is fumished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure, included in the above referenced document, should be viithheld.
1.
The information sought to be withheld from public disclosure, is owned and j
has been held in confidence by Combustion Engineering. It consists of the
i l details concerning the design and development of a tube repair technique involving the re-roll process.
2.
The information consists of test data or other similar data conceming 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 confidence by it and, in 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. Stem to Frank Schroeder dated December 2,1974. This system was applied in determining that the subject document herein is proprietary.
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 information, 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:
a.
A similar product is manufactured and sold by major pressurized water reactor competitors of Combustion Engineering.
b.
Development of this information by Combustion Engineering required tens of thousands of dollars and thousands of i
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. manhours of effort. 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 develop the analyses and testing performed to verify that re-rolling tubes is an acceptable repair technique.
d.
The information consists of the design and development of a tube repair technique involving the re-roll process, the application of which provides a competitive economic advantage. The availability of such information to competitors would enable them to modify their product to better compete with Combustion Engineering, take marketing or other actions to improve their product's position or impair the position of Combustion Engineering's product, and avoid developing similar data and analyses in support of their processes, methods or apparatus.
e.
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 without
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similar expenditure of resources may enable them to sell at prices reflecting significantly lower costs.
f.
Use of the information by competitors in the international
)
marketplace would increase their ability to market nuclear steam supply systems by reducing the costs associated with their technology development. In addition, disclosure would have an adverse economic impact on Combustion
. Engineering's potential for obtaining or maintaining foreign licensees.
Further the deponent sayeth not.
[7 f.
r Ian C Director, Operations Licensing Sworn to before me this / OO day of
.1996 Q
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Notary Public E!3I 99 My commission expires:
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