ML20196E210
| ML20196E210 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 11/30/1998 |
| From: | Cruse C BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20138L913 | List: |
| References | |
| NUDOCS 9812030061 | |
| Download: ML20196E210 (20) | |
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CHAntxs H. CaesE Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant Vice President Nuclear Energy 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 410 495-4455 November 30,1998 j
U. S. Nuclear Regulatory Commission Washington,DC 20555 m
i ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 License Amendment Request: Steam Generator Tube Repair Using Leak Limiting Alloy 800 Sleeves Pursuant to 10 CFR 50.90, the Baltimore Gas and Electric Company hereby requests an Amendment to Operating License Nos. DPR-53 and DPR-69 to allow the repair of defective steam generator tubes with leak-limiting Alloy 800 repair sleeves.
Currently, the Calvert Cliffs Technical Specifications allow defective tubes to be plugged and removed from service, or to be repaired by either the laser-welded sleeving technique developed by Westinghouse Electric Corporation or by using leak-tight, tungsten inert gas-welded sleeving developed by Combustion Engineering, Inc. (ABB-CE).
The proposed amendment will revise the appropriate Technical Specifications to permit the use ofleak-limiting Alloy 800 repair sleeves developed by ABB-CE to be used at Calvert Cliffs. Combustion Engineering provides two types ofleak-limiting Alloy 800 repair sleeves. The first type of repair sleeve spans the expansion transition zone of the tube at the top of the tubesheet. The second type of repair sleeve spans the degraded areas at an eggerate support elevation or in a free span section.
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The summary description and safety analysis for the proposed sleeve repair is provided in Attachment (1). Baltimore Gas and Electric Company has evaluated the proposed revision to the Calvert Cliffs Technical Specifications and has determined that it does not involve a significant hazards 9,
consideration as defined in 10 CFR 50.92 (refer to Attachment 2 for a complete discussion).
Attachment (3) provides the Technical Specifications marked-up pages. The detailed report on the specific qualifications of the repair sleeve for Calvert Cliffs application is contained in the proprietary report ABB-Combustion Engineering Report CEN-633-P, Revision 02-P; " Steam Generator Tube Repair For Combustion Engineering Designed Plants with 3/4.048 Inch Wall Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves,"(Attachment 5). The proprietary affidavit for Attachment (5) appears in Attachment (4). The non-propriety version of this report is included as Attachment (6).
9812030061 981130 PDR ADOCK 05000317 P
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Document Control Desk November 30,1998 Page 2 Baltimore Gas and Electric Company has determined that operation with the proposed amendment would not result in any significant change in the types, or significant increases in the amounts, of any effluents that may be released offsite, nor would it result in any significant increase in individual or cumulative occupational radiation exposure. Therefore, the proposed amendment is eligible for categorical exclusion as set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR St.22(b), no environmental impact statement or environmental assessment is needed in connection with the approval of the proposed amendment.
These proposed changes to the Technical Specifications and our determination of no significant hazards have been reviewed by our Plant Operations and Safety Review Committee and Offsite Safety Review Committee, and they have concluded that implementation of these changes will not result in an undue risk to the health and safety of the public.
Baltimore Gas and Electric Company wishes to have approval to use leak limiting Alloy 800 repair sleeves during the 2000 Unit 1 Refueling Outage. In order to allow time to prepare for use of this new sleeving technique, Baltimore Gas and Electric Company requests that the Nuclear Regulatory Commission review and approve the proposed amendment and attached proprietary document on or before October 1,1999.
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November 30,1998 Page 3 Should you have questions regarding this matter, we would be pleased to discuss them with you.
Very truly yours, x
STATE OF MARYLAND
- TO WIT:
COUNTY OF CALVERT I, Charles H. Cruse, being duly sworn, state that I am Vice President, Nuclear Energy Division, Baltimore Gas and Electric Company (BGE), and that I am duly authorized to execute and file this License Amendment Request on behalf of BGE. To the best of my knowledge and belief, the stat:.nents contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other BGE employees and/or i
consultants. Such information has been reviewed in accordance with company practice and I believe it to be reliable.
. &n,bf s w Subscyjbed and s 'orn before me, a Notary P blic in and for the State of Maryland and County of 3
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.this 30 day of f/ct % h,1998.
WITNESS my lland and Notarial Scal:
Notary Public
[O@2 My Commission Expires:
er o ar op CHC/JPW/bjd Attachments: (1)
Summary Description and Safety Analysis (2)
Determination of No Significant flazards (3)
Technical Specification Marked-Up Pages (4)
ABB Combustion Engineering Proprietary Affidavit for Attachment 5, Pursuant to 10 CFR 2.790 (5)
Proprietary ABB Combustion Engineering Report CEN-633-P, Revision 03-P; l
" Steam Generator Tube Repair For Combustion Engineering Designed Plants with l
3/4.048 Inch Wall Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves,"
i October 1998 I
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Non-Proprietary ABB Combustion Engineering Report CEN-633-NP, I
Revision 03-P; " Steam Generator Tube Repair For Combustion Engineering Designed Plants with 3/4.048 inch Wall Inconel 600 Tubes Using Leak Limiting I
Alloy 800 Sleeves," October 1998 l
i Document Control Desk i
November 30,1998 l
Page 4 cc:
(With all Attachments)
A. W. Dromerick, NRC r
(Without Attachments)
R. S. Fleishman, Esquire Resident inspector,NRC J. E. Silberg, Esquire R. I. McLean, DNR S. S. Bajwa, NRC J.11. Walter, PSC II. J. Miller, NRC E. P. Kurdziel, ABB-CE i
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ATTACHMENT (1)
SUMMARY
DESCRIPTION AND SAFETY ANALYSIS Baltimore Gas & Electric Company Docket Nos. 50-317 and 50-318 November 30,1998
l ATTACHMENT m l
SUMMARY
DESCRIPTION AND SAFETY ANALYSIS A.
BACKGROUND l
Pressurized water reactor steam generators have experienced tube degradation related to corrosion phenomena, such as wastage, pitting, intergranular attack, stress corrosion cracking, ud crevice corrosion, along with other phenomena such as denting and vibration wear. Tubes that experience excessive degradation reduce the integrity of the primary-to-secondary pressure boundary. Eddy l
current examination is used to measure the extent of tube degradation. When the reduction in tube wall thickness reaches a calculated value commonly known as the plugging criteria or when a crack is found, the tube is considered defective and corrective action is taken.
Currently, the Calvert Cliffs Technical Speci0 cations allow defective tubes to be plugged and l
removed from service. Technical Specifications also allow tubes to be repaired by the laser-welded sleeving technique developed by Westinghouse Electric Corporation, or by using leak-tight, tungsten inert gas-welded sleeving developed by Combustion Engineering, Inc. (ABB-CE). The laser-welded sleeving option was approved by the Nuclear Regulatory Commission for Calven i
Cliffs on March 22,1996. Use of the ABB-CE tube sleeving technique at Calvert Cliffs was approved on November 18,1997. Neither of the two sleeve types have been used to repair defective steam generator tubes at Calven Cliffs. The most widely used repair technique at many pressurized water reactors, including Calvert Cliffs, is removal of the degraded tube from service by installing plugs at both ends of the tube. The installation of steam generator tube plugs removes the heat transfer surface of the plugged tube from service, and leads to a reduction in the primary coolant flow available for core cooling.
The proposed amendment will revise the appropriate Technical Specifications to permit the use of leak-limiting Alloy 800 tube sleeves developed by ABB-CE to be used at Calvert Cliffs. ABB-CE provides two types of leak-limiting Alloy 800 repair sleeves. The first type of sleeve spans the expansion transition zone (ETZ) of the steam generator tube at the top of the tubesheet. The ETZ repair sleeve is expanded into the tube at the upper end and is hard rolled into the tube within the steam generator tubesheet. The length of the ETZ slceves permits the sleeve to span the degraded tube section at the top of the tubesheet and generally places the expansions above the sludge pile.
The second type of repair sleeve spans degraded areas of the tube at an eggerate support elevation or in a free span section and is expanded into the degraded tube near each end of the sleeve.
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There are two distinct advantages associated with the Alloy 800 repair sleeves. First, no welding,
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brazing, or heat treatment is required during sleeve installation, significantly reducing the time and cost associated with sleeve installation. Secondly, the strain within the tube is low, thereby reducing the likelihood of future degradation due to stress-influenced mechanisms. Although the Alloy 800 repair sleeves allow slight leakage past the sleeve (assuming the parent tube is leaking), the leakage is well within Technical Specification limits.
The ABB-CE analysis was performed for Combustion Engineering-designed plants with 3/4-inch outer diameter,0.048-inch wall, Alloy 600 steam generator tubes, and addresses a combination of one ETZ sleeve and/or up to two eggerate support sleeves that may be installed in a single steam generator tube. Acceptable sleeve locations covered by the analysis are from the fourth eggerate support down to the top of the tubesheet. Attachment (5) provides a detailed description of the design, installation, and testing associated with the Alloy 800 leak limiting tube sleeves.
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ATTACHMENT m i
SUMMARY
DESCRIPTION AND SAFETY ANALYSIS B.
DESCRIPTION OF AMENDMENT REOUEST The proposed amendment revises the Technical Specifications for the Calvert Cliffs Nuclear Power Plant steam generator tubing (Technical Specification Section 5.5.9). This revision will allow the use of ABB-CE leak-limiting Alloy 800 repair sleeves to repair defective steam generator tubes.
The marked-up Technical Specification pages appear in Attachment (3).
C.
SAFETY ANALYSIS The principal accident associated with this proposed change is the steam generator tube rupture (SGTR) accident. The consequences associated with a SGTR event are discussed in Calvert Cliffs Updated Final Safety Analysis Report Section 14.15," Steam Generator Tube Rupture Event." The SGTR event is a breach of the barrier between the Reactor Coolant System and the Main Steam System. The integrity of this barrier is significant from the standpoint of radiological safety in that a leaking steam generator tube allows the transfer of reactor coolant into the Main Steam System.
In the event of a SGTR, radioactivity contained in the reactor coolant mixes with water in the shell side of the affected steam generator. This radioactivity is transported by steam to the turbine and then to the condenser, or directly to the condenser via the turbine bypass valves, or directly to the atmosphere via the atmospheric dump valves, main steam safety valves, or the auxiliary feedwater pump turbine exhaust. Noncondensible radioactive gases in the condenser are removed by the condenser air removal system, and discharged to the plant vent. The use of ABB-CE leak-limiting Alloy 800 repair sleeves will allow the repair of degraded steam generator tubes such that the function and integrity of the tube is maintained; therefore, the SGTR accident is not affected.
i The consequences of a hypothetical failure of a leak-limiting Alloy 800 repair sleeve and/or associated steam generator tube would be bounded by the current SGTR analysis described above.
Due to the slight reduction in diameter caused by the sleeve wall thickness, primary coolant release rates would be slightly less than assumed for the SGTR analysis and, therefore, would result in lower total primary fluid mass release to the secondary system. A main steam line break (MSLB) or feed line break (FLB) will not cause a SGTR since the sleeves are analyzed for a maximum accident differential pressure greater than that predicted in the Calvert Cliffs safety analysis. The impact of repair sleeving on steam generator performance, heat transfer, and flow restriction is minimal and insignificant compared to plugging. The proposed Technical Specification change to allow the use ofleak-limiting Alloy 800 repair sleeves does not adversely impact any other previously evaluated design basis accident.
Evaluation of the proposed leak-limiting Alloy 800 repair sleeves indicates no detrimental effects on the sleeve or sleeved-tube assembly from reactor system flow, primary or secondary coolant chemistries, thermal conditions or transients, or pressure conditions as may be experienced at Calvert Cliffs. The minimal leakage which maybe experienced during normal operation is well l
within the established leakage limits. Under worst-case conditions, over 3,000 repair sleeves could be installed and still not exceed Technical Specification steam generator leakage limits. Data concerning the reduction in primary coolant flow rate and sleeve-to-plug equivalency ratios is contained in Section 10 of Attachment (5). Table 1 provides a comparison of loading conditions assumed in Attachment (5) with respect to Calvert Cliffs' corresponding operating and accident values. The values assumed in Attachment (5) are either equivalent or more conservative than Calvert Cliffs' plant-specific values.
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ATTACHMENT (1)
SUMMARY
DESCRIPTION AND SAFETY ANALYSIS TABLE 1 LOADING CONDITION COMPARISON Calvert Cliffs CEN-633 T Primary Actual 604*F 608.6*F Design 650 F 650 F T Secondary Actual 503*F 505.8'F Design 550 F 560'F AT 10l*F 102.8 F P Primary Actual 2250 psia 2250 psia Design 2500 psia 2500 ps;a P Secondary Actual 850 psia 790 psia Design 1000 psia 1100 psia AP 1400 psid 1460 psid MSLB/FLB 2560 psid 2560 psid LOCA 1000 psid 1170 psid The detailed report describing the specific qualifications of Alloy 800 repair sleeves is contained in the Proprietary ABB-Combustion Engineering Report CEN-633-P, Revision 03-P; " Steam Generator Tube Repair For Combustion Engineering Designed Plants with 3/4.048 Inch Wall Inconel 600 Tubes Using Leak Limiting Alloy 800 Sleeves," dated October 1998 (Attachment 5).
The summary of the results from the report are discussed below.
General Structural Assenment The Alloy 800 tubing, from which the repair sleeves are fabricated, is procured to the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section II, Part B, SB-163, NiFeCr Alloy UNS N08800, and Section III, Subsection NB-2000.
Fatigue and stress analyses of the sleeved-tube assemblies have been completed in accordance with the requirements of Section III and Nuclear Regulatory Commission Regulatory Guide 1.121,
" Bases for Plugging Degraded PWR Steam Generator Tubes." Steam generator tubes with installed Alloy 800 repair sleeves meet the structural integrity requirements of tubes that are not degraded.
Even in the event of the severance of the steam generator tube in the region behind the sleeve, the repair sleeve will provide the required structural support and acceptable leakage between the primary and secondary systems for normal operating and accident conditions. The selected design criteria for the repair sleeves ensure that all design and licensing requiremenis are considered.
Extensive testing and analysis have been performed on the repair sleeve and sleeve-to-tube joints to demonstrate that these design criteria are met.
Mechanical testing has been performed to support the analyses prepared using ASME Code stress allowables. Corrosion testing of sleeve tube assemblies has been performed in Belgium (Laborelec) and the U.S. (ABB-CE) with satisfactory results. These results, when analyzed in conjunction with corrosion test results from the tungsten inert gas-welded sleeve program, confirm the adequery of the sleeve joint design. The Alloy 800 sleeve material showed no signs of degradation under high temperature and pressure conditions in a caustic environment, while the sleeve / tube specimens 3
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ATTACHMENT (1)
SUMMARY
DESCRIPTION AND SAFETY ANALYSIS maintained primary side pressure and exhibited no leakage through the duration of the test program.
Earlier design variations of this sleeve (larger diametrical expansion) are currently in use at KORI 1 (South Korea) and Tihange 3 (Belgium) steam generators, and the current design is in service in the KRSKO (Slovenia) steam generators.
Regulatory Guide 1.121 is used to develop the plugging limit of the repair sleeve should sleeve wall degradation occur. Alloy 800 leak-limiting repair sleeves are shown (by test and analysis) to retain 1
i burst strength in excess of three times the normal operating pressure differential at end of cycle l
conditions. No credit for the presence of the parent tube behind the sleeve is assumed when I
performing the minimum wall / burst evaluation.
The plugging limit imperfection depth is determined to be 55% nominal sleeve wall thickness, and bounds both normal and accident conditions. An additional 20% allowance is applied to account for non-destructive examination uncertainty and flaw growth. Thus, the imperfection depth operational limit (Attachment 3) is l
established at 35% of nominal sleeve wall thickness l
Corrosion Assessment Historically, Alloy 800 has been used successfully for steam generator tubes and tube plugs, primarily in western Europe. Over 200,000 Alloy 800 tubes have been used for up to 19 years with only minimal tube failures. No evidence of primary or secondary side stress corrosion cracking has been identified. Accelerated corrosion testing of Alloy 800 repair sleeves has been performed in simulated primary and secondary side steam generator environments. The specific details of Alloy 800 repair sleeve corrosion performance are contained in Section 6 of Attachment (5).
MechanicalIntecrity Assessment Mechanical testing of Alloy 800 repair sleeves was performed using mock-up steam generator tubes. The tests determined axial load, collapse, burst, leak rates, and thermal cycling capability.
The loading conditions developed in Section 8 of Attachment (5) were used to develop the conditio.'s that were tested in Section 7 of Attachment (5).
The temperature and pressure differentitis described in Section 8 of the report are conservative with respect to Calvert Cliffs' operating and accident conditions.
Leakape Rate Assessment The Alloy 800 ETZ and eggerate support repair sleeve leakage characteristics were evaluated at room and operating temperatures so that all possible plant conditions would be enveloped by the test results. Based on the worst-case leakage, over 3,000 repair sleeves could be installed and still meet the Technical Specification leakage limits of 100 gallons per day for a single steam generator and I gallon per minute for all steam generators. Details of the leakage assessment are contained in Section 7 of Attachment (5).
Sleeve Examination A post-installation examination will be performed using eddy current testing techniques. This l
examination will establish inservice inspection baseline data and initial installation acceptance data on the primary pressure boundary of the repair sleeve tube assembly. Subsequent examinations ~.ill l
be based on a sampling program consistent with currently approved inspection requiremw.s.
Section 5 of Attachment (5) describes repair sleeve examination methodology.
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ATTACHMENT c)
SUMMARY
DESCRIPTION AND SAFF.TY ANALYSIS
. D.
CONCLUSION l
Based on past usage and extensive testing, the ABB-CE Alloy 800 leak-limiting repair sleeves provide satisfactory repair of defective steam generator tubes. Design criteria were established based on the requirements of the ASME Code and Regulatory Guide 1.121.
Qualified nondestructive examination techniques will be used to perform necessary repair sleeve and tube inspections for defect detection, and to verify proper installation of the repair sleeve.
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ATTACHMENT (2) i 4
DETERMINATION OF NO SIGNIFICANT HAZARDS l
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Baltimore Gas & Electric Company L
Docket Nos. 50-317 and 50-318 November 30,1998
ATTACHMENT (2)
DETERMINATION OF NO SIGNIFICANT HAZARDS The proposed change has been evaluated against the standards in 10 CFR 50.92 and has been determined to not involve a significant hazards consideration, in that operation of the facility in accordance with the proposed amendments:
1.
The proposed amendment would not involve a significant increase in the probability or consequences ofan accident previously evaluated.
The ABB CE Alloy 800 leak-limiting repair sleeves are designed using the applicable American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code and, therefore, meet the design objectives of the original steam generator tubing. The applied stresses and fatigue usage for the repair sleeves are bounded by the limits established in the ASME Code. Mechanical testing has shown that the structural strength of repair sleeves under normal, upset, and faulted conditions provides margin to the acceptance limits. These acceptance limits bound the most limiting (three times normal operating pressure differential) burst margin recommended by Regulatory Guide 1.121. Burst testing of sleeved tubes has demonstrated that no unacceptable levels of primary-to-secondary leakage are expected during any plant condition.
The Alloy 800 repair sleeve Technical Specification depth-based plugging limit is determined using the guidance of Regulatory Guide 1.121 and the pressure stress equation of ASME Code, Section Ill. A bounding tube wall degradation growth rate per cycle and a nondestructive examination uncertainty has been assumed for determining the repair sleeve plugging limit.
Evaluation of the repaired steam generator tubes indicates no detrimental effects on the sleeve or sleeve-tube assembly from reactor system flow, primary or secondary coolant chemistries, thermal conditions or transients, or pressure conditions as may be experienced at Calvert Cliffs. Corrosion testing of sleeve-tube assemblies indicates no evidence of sleeve or tube corrosion considered detrimental under anticipated service conditions.
The implementation of the proposed amendment has no significant effect on either the configuration of the plant, or the manner in which it is operated. The consequences of a hypothetical failure of the sleeved tube is bounded by the current steam generator tube rupture analysis described in Calvert Cliffs Updated Final Safety Analysis Report, Section 14.15. Due to the slight reduction in diameter caused by the sleeve wall thickness, primary coolant release rates would be slightly less than assumed for the steam generator tube rupture analysis and, therefore, would result in lower total primary fluid mass release to the secondary system. A main steam line break or feed line break will not cause a SGTR since the sleeves are analyzed for a maximum accident differential pressure greater than that predicted in the Calvert Cliffs safety analysis. The minimal repair sleeve leakage that could occur during plant operation is well within the Technical Specification leakage limits.
l Therefore, BGE has concluded that the proposed change does not involve a significant increase in l
the probability or consequences of an accident previously evaluated.
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Would not create the possibility of a new or different kind of accidentfrom any other accident l
previously evaluated.
As discussed above, the Alloy 800 repair sleeves are designed using the applicable ASME Code as i
guidance; therefore, it meets the objectives of the original steam generator tubing. As a result, the functions of the steam generators will not be significantly affected by the installation of the proposed sleeve. The proposed repair sleeves do not interact with any other plant systems. Any 1
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DETERMINATION OF NO SIGNIFICANT HAZARDS accident as a result of potential tube or sleeve degradation in the repaired portion of the tube is bounded by the existing tube rupture accident analysis. The continued integrity of the installed sleeve is periodically verified by the Technical Specification requirements.
i The implementation of the proposed amendment has no significant effect on either the configuration of the plant, or +
in which it is operated. Therefore, BGE concludes that "rm this proposed change does r<
pssibility of a new or different kind of accident from any previously evaluated.
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Would not involve a sigmjicant reauction in a margin ofsafety.
t The repair of degraded steam generator tubes with Alloy 800 leak-limiting repair sleeves restores the structural integrity of the degraded tube under normal operating and postulated-accident conditions. The design safety factors utilized for the repair sleeves are consistent with the safety factors in the ASME Boiler and Pressure Vessel Code used in the original steam generator design.
The portions of the installed sleeve assembly that represent the reactor coolant pressure boundary can be monitored for the initiation and progression of sleeve / tube wall degradation. Use of the previously identified design criteria and design verification testing assures that the margin to safety is not significantly different from the original steam generator tubes.
Therefore, BGE concludes that the proposed change does not involve a significant reduction in a margin of safety.
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ABB COMBUSTION ENGINEERING PROPRIETARY AFFIDAVIT FOR ATTACHMENT (5),
PURSUANT TO 10 CFR 2.790 1
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i Baltimore Gas & Electric Company Docket Nos. 50-317 and 50-318 November 30,1998 l,
t AFFIDAVIT PURSUANT i
TO 10 CFR 2.790 I, l.C. Rickard, depose and say that I am the Director, Nuclear Licensing, of Combustion j
l 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 i
application of Baltimore Gas and Electric Company, and in conformance with the
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provisions of 10 CFR 2.790 of the Commission's regulations.
The information for which proprietary treatment is sought is contained in the following i
document:
CEN-633-P, Rev 03-P, " Steam Generator Tube Repair for Combustion Engineering Designed Plants with 3/4.048 Inch Wall Inconel 600 Tubes Using j
Leak Limiting Alloy 800 Sleeves," October 1998 l
This document has been appropriately designated as proprietary, I have personal knowledge of the criteria and procedures utilized by Combustion Enginoering in designating information as a trade secret, privileged or as confidential i
commercial or financial information.
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 l.
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 i
has been held in confidence by Combustion Engineering. It consists of information concerning the design, qualification, installation tooling, and
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installation process for the Alloy 800 steam generator tube sleeve.
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2.
The information consists of test data or other similar data concerning a process, method or component, the application of which results in l
substantial competitive advantage to Combustion Engineering.
3.
The information is of a type customarily held in confidence by Combustion 1
Engineering and not customarily disclosed to the public. Combustion 1
i Engineering has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a l
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.
4.
The information is being transmitted to the Commission in confidence under l
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 l
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.
l 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 j
pressurized water reactor competitors of Combustion l
Engineering.
I b.
Development of this information by Combustion Engineering required millions of dollars and thousands of manhours of l
effort. A competitor would have to undergo similar expense in generating equivalent information.
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In order to acquire such information, a competitor would also require considerable time and inconvenience to develop an equivalent steam generator tube repair technique and the supportirg analyses and test data, d.
The information consists of the design, qualification, installation tooling, and installation process for the Alloy 800 steam generator tube sleeve, 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 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 i
licensees.
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l-Further the deponent sayeth not.
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Director Nuclear Licensing i
sworn to before me L -
'this/M day of'
.1998
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. Notary Public My commission expires: 8 8/ f 7
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ATTACHMENT (5)
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PROPRIETARY ABB COMBUSTION ENGINEERING REPORT CEN-633-P, REVISION 03-P; " STEAM GENERATOR TUBE REPAIR FOR COMBUSTION ENGINEERING DESIGNED PLANTS WITH 3/4.048 INCH WALL INCONEL 600 TUBES USING LEAK LIMITING ALLOY 800 SLEEVES,"
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OCTOBER 1998 i
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Baltimore Gas & Electric Company Docket Nos. 50-317 and 50-318 Ncvemher 30,1998
ATTACHMENT (6) l NON-PROPRIETARY ABB COMBUSTION ENGINEERING REPORT CEN-633-P, REVISION 03-P; " STEAM GENERATOR TUBE i
REPAIR FOR COMBUSTION ENGINEERING DESIGNED PLANTS WITH 3/4.048 INCH WALL INCONEL 600 TUBES l
USING LEAK LIMITING ALLOY 800 SLEEVES,"
OCTOBER 1998 I
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4 Baltimore Gas & Electric Company
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Docket Nos. 50-317 and 50-318 November 30,1998
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