ML20133E257
| ML20133E257 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 01/03/1997 |
| From: | Wadley M NORTHERN STATES POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19310E968 | List: |
| References | |
| NUDOCS 9701100268 | |
| Download: ML20133E257 (8) | |
Text
_c e
A.
h,.
Northern States Power Company Pralrie Island Nuclear Generating Plant 1717 Wakonade Dr. East Welch, Minnesota 55089 January 3,1997 10 CFR Part 50 Section 50.90 U S Nuclear Regulatory Commission Attn: Dccument Control Desk Washi:!gton, 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 was submitted by letter Dated October 17,1996. Since that submittal, Combustion Engineering Report CEN-620-P has been revised. Revision 03-P to Combustion Engineering Report CEN-620-P, dated December,1996 documents the completion of qualification testing using the 2 inch rollers and incorporates additional analyses related to the differential thermal expansion between the tube and tubesheet.
The qualification testing results discussed in Revision 03-P of CEN-620-P support the
[j expectation presented in Section 7.2 of Revision 02-P that "Similar values are expected with the 2 inch effective 13ngth roll and these values will be verified prior to actual riaam generator work."
g/)
During continuing reviews of the E:* criteria at NSP, an issue was raised concerning differential thermal expansion forces. Combustion Engineering was requested to ATTACHMENT CONTAINS PROPRIETARY INFORMATION TO BE WITHHELD FROM PUBLIC DISCLOSURE IN ACCORDANCE
]00non WITH 10 CFR PART 2, SECTION 2 7,9g'-
c k
D 9701100268 970103 N g{ rD(g/
PDR ADOCK 03000282 I
[ d VT ff0Q.
P PDR
5' 1
USNRC NORTHERN STATES POWER COMPANY January 3,1997 Page 2 calculate forces in a tube without tube support plate lockup. Upon considering the combination of pressure and thermal expansion forces without tube support plate i
lockup, the maximum axial force was determined to be present in a tube which is not locked at the first support plate. This raised the calculated maximum axial loading for j.
cyclic testing from 1905 pounds to 1994 pounds. The cyciic testing was conducted at 2000 pounds and, therefore, bounds the new value.
e Although not specifically explained in WCAP-14225, the thermal expansion forces are i
not included in the calculation of the EF* distance since the EF* distance is based on a j
sliding coefficient of friction which means the holding force of the joint would still be present even if the joint moved slightly. The force due to thermal expansion can not then cause the tube to escape from the tubesheet region.
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.
A non-proprietary version of Revision 03-P of the report is under preparation, and will be submitted when it is received from Combustion Engineering. Please contact Gene Eckholt (612-388-1121) if you have any questions related to the attached information.
/$
bbYO Michael D Wadley
(
Plant Manager Prairie Island Nuclear Generating Plant 2
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 03-P, " Series 44 & 51 Design Steam Generator Tube Repair Using a Tube Re-Rolling Technique",
December 1996 (Proprietary)
- 2. Combustion Engineering Affidavit
l ATTACHMENT 2 i
Combustion Engineering Affidavit
1 AFFIDAVIT PURSUANT TO 10 CFR 2.790 I, C. B. Brinkman depose and say that I am the Director, 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 i
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 for withholding this information.
The information for which proprietary treatment is sought is contained in the following j
document:
j CEN-620-P, Rev. 03-P, " Series 44 & 51 Design Steam Generator Tube Repair Using 1
a Tube Re-Rolling Technique," December 1996.
This document has been appropriately designated as proprietary.
i I have personal knowledge of the criteria and procedures utilized by Combustion j
Engineering in designating information as a trade secret, privileged or as confidential commercial or 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 information sought to be withheld from public disclosure, included in the above referenced document, should be withheld.
1.
The information sought to be withheld from public disclosure, is owned and has been held in confidence by Combustion Engineering. It consists of the 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 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 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 manhours of effort. A competitor would have to unocrgo similar expense in generating equivalent information.
1 i i 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 l.
tube repair technique involving the re-roll process, the s
application of which provides a competitive economic j
advantage. The availability of such information to competitors i
1 would enable them to modify their product to better compete with Combustion Engineering, take marketing or other actions 4
to improve their product's position or impair the position of
]
Combustion Engineering's product, and avoid developing l
similar data and analyses in support of their processes, l
methods or apparatus.
i e.
In pricing Combustion Engineering's products and services, significant research, development, engineering, analytical, manufacturing, licensing, quality assurance and other costs i
i and expenses must be included. The ability of Combustion Engineering's competitors to utilize such information without i
similar expenditure of resources may enable them to sell at 1
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 I
have an adverse economic impact on Combustion Engineering's potential for obtaining or maintaining foreign licensees.
g l
4 4
I 4_
Further the deponent sayeth not.
ne:
C. B. Brinkman Director, Nuclear Licensing l
Swom to before me A
this b day of
.1996 W
A
)
y Notary Public
<I/3/ jj /99 My commission expires:
i
4 i
ATTACHMENT 1 i
)
i Combustion Engineering, Inc.
Report CEN-620-P Revision 03-P j
Series 44 & 51 Design 3
Steam Generator Tube Repair Using a Tube Re-Rolling Technique December 1996 i
4 i
(65 Pages)
Proprietary i
t I
1 a
l l
d i
i
,