ML20198Q574

Provides Suppl to Initial 971020 Application for Amend to TS Re SG Tubing Surveillance Requirements,In Response to NRC 971030 Request for Addl Info.Proprietary Rev 3 to BAW-2303P, OTSG Repair Roll Qualification Rept Encl.Rept Withheld

ML20198Q574
Person / Time
Site:	Oconee
Issue date:	11/03/1997
From:	Mccollum W DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML15118A523	List: ML20198Q574
References
NUDOCS 9711120259
Download: ML20198Q574 (11)

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4 Duke Power Company

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$cncca, SC 29679 W. K. Mdanium, Jr. (864) 883-3107wna Wr hnident (h64) 883-3564 m November 3, 1997 U. S. Nuclear Regulatory Commission Attention: Document Control Desk washington, DC 20555

Subject:

Oconee Nuclear Station Docket Nos. 50-269, -270, -287 Request for Technical Specification Amendment Steam Generator Tubing Surveillance In a letter dated October 20, 1997, Duke Energy Corporation (Duke) requected an amendment to the Technical Specificetions for Oconee Nuclear Station Units 1, 2, and 3.

The amendment consisted of proposed changes to the Steam '

Generator Tubing Surveillance reqMrements. In a letter dated October 30, 1997, the NRC requested additional information about the Technical Specification amendment request and associated topical report. ,

In response to several questions in the NRC's request for additional informa*, ion, Duke has prepared a supplement to the Anitial amendment requese which is contained in Attachment 1. The remaining questions are addressed by the information which is provided in Attachment 5. Attachment 2 contains the markup of the current Technical Specifications.

The Technical Justification for the supplement to the amendment request is inclur*ed-in Attachment 3. Attachment 4 contains the revised No Significant Hazards Ccnsideration Evaluation. The Environmental Impact Analysis, which was contained in the letter dated October 20, 1997, is not revised by the amendment supplement.

During the current Oconee Unit 1 refueling outage, the hot leg tubesheet roll areas were inspected by non-destructive examination to determine if tube degradation was present.

The non-destructive examination has discovered indications

.on approximately 1900 tubes in the 1B steam generator.

Oconee has repaired the tubes by utilizing a process which ,

rerolls the upper portion of the tube. The reroll process

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was utilized because plugging the tubes will reduce the ,h. I i a-

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November 3, 1997 thermal efficiency of the 1B steam generator and could approach the current tube plugging limit of 15 percent.

Since the reroll process is not contained in the current Oconee Technical Specifications as an approved' repair method, NRC approval of this submittal must be obtained prior to exceeding 250*F in the Reactor Coolant System on  ;

Oconee Unit 1. Currently, restart of Oconee Unit 1 is expected to occur the last week of November 1997.

Therefore, Duke requests that this submittal be reviewed and approved on an expedited basis to support the restart of Oconee Unit 1.

Duke could not have avoided the need for an expedited review of this proposed license amendment in that the results of the steam generator tube inspections were obtained during .

the currant refueling outage. Duke initiated a conference call with the staff on October 14, 1997, to discuss the inspection results, the rerolling repair option, and the need for a license amendment. Once the neri f or a Technical Specification change was identified, Duke made its best efforts to submit the license amendment and this supplement to the staff in a timely manner.

The Oconee Updated Final Safety Analysis Report has been reviewed and no changes are necessary to support this amendment request.

This Technical Specification amendment request contains a topical report in Attachment 3A which is proprietary to Framatome Technologies, Inc. In addition, several responses to the NRC's request for additional information contain information which is proprietary to Framatome Technologies, Inc. The information which is propriatary is clearly marked as proprietary. An affidavit from Framatome Technologies is included in Attachment 6. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the NRC and addresses the considerations listed in 10CFR2.790 (b) (4) . Accordingly, Duke Energy Corporation requests that the topical report contained in Attachment 3A and the proprietary responses contained in Attachment 5 be withheld from public disclosure. A non-proprietary version of the topical report will be submitted at a later date..

U. S. Nuclear Regulatory Commis, ion Pene 3 November 3, 1997 If there are any questions regarding this submittal, please contact Michael Bailey at (864) 885-4390.

Very truly yours, W. R. McCollum, .

Site Vice President Oconee NucleSr Station MED Attachments (6) cc: L. A. Reyes, Regional Administrator Region II M. A. Scott, Senior Resident Inspector Oconee Nuclear Site D. E. LaBarge, Project Manager NRR M. Batavia, DllEC L

U. S. Nuclear Regulatory Commission Page i November 3, 1997 W. R . 14cCollum, Jr . , being duly sworn, states that he is Vice President of Duke Energy Corporation, that he is authorized on the part of said Company to sign and file with the Nuclear Regulatory Commission this revision to the Oconee Nuclear Station License Nos. DPR-38, DPR-47, and DPR-55; and that all statements and matters set forth therein are true and correct to the best of his knowledge.

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W. R . 14cCollum, Jr.,f ife'Vice President Subscribed and sworn to before me this 3rd day of November, 1997.

04'1Dh Notary Public N/ .

14y Commission Expires:

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FRAMATOME TECHNOLOGIES, INC.

AFFIDAVIT i

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4 AFFIDAVIT OF JAMIIS IL TAYLOR A. hty name is James li. Taylor. I am hianager of Licensing Services for Framatome Technologies, Inc. (ITI), and as such, I am authorized to execute this Affidavit.

B. I am familiar with the criteria applied by FTl to determine whether certain information of ITI is proprietary and I am familiar with the procedures established within ITI to ensure the proper application of these criteria.

C. In determining whethei an 141 document is to be classified as proprietary information, an initial determination is made by the Unit hianager, who is responsible for originating the document, as to whether it falls within the criteria set forth in Faragraph D hereof. If the information falls within any one of these criteria, it is classified as proprietary by the originating Unit hianager.

This initial determination is reviewed by the cognizant Section hianager, if the document is designated as proprietary, it is reviewed again by Licensing personnel and other management within ITI as designated by the hianager of 1.icensing Services to assure that the regulatory requirements of 10 CFR Section 2.790 are met.

D. The following information is provided to demonstrate that the provisions of 10 CFR Section 2.790 of the Commission's regulations have been considered:

(i) The information has been held in confidence by FTI. Copies of the document are clearly identified as proprietary. In addition, whenever FTl transmits the information to a customer, customer's agent, potential customer or regulatory agency, the transmittal requests the recipient to hold the information as proprietary. Also, in order to strictly limit any potential or actual customer's use of proprietary information, the substance of the following provision is included in all agreements entered into by FTI, and an equivalent version of the proprietary provision is included in all of FTI's proposals:

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o AFFIDAVIT OF JAMES H. TAYLOR (Cont'd.)

"Any proprietary information concerning Company's or its Supplier's prtxluets or manufacturing processes which is so designated by Company or its Suppliers and disclosed to Purchaser incident to the performance of such contract shall remain the property of Company or its Suppliers and is disclosed in confidence, and Purchaser shall not publish or otherwise disclose it to others without the written approval of Company, and no rights, implied or otherwise, are granted to produce or have produced any products or to practice or cause to be practiced any manufacturing processes, covered thereby.

Notwithstanding the above, Purchaser may provide the NRC or any other regulatory agency with any such proprietary information as the NRC or such other agency may require; provided, however, that Purchaser shall first give Company written notice of such proposed disclosure and Company shall have the right to amend such proprietary information so as to make it non-proprietary. In the event that Company cannot amend such proprietary information, Purchaser shall prior to disclosing such information, use its best efforts to obtain a commitment from NRC or such other agency to have such hformation withheld from public inspection.

Company shall be given the right to participate in pursuit of such confidential treatment."

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AFFIDAVIT OF JAMPS H. TAYLOR (Cont'd.)

(ii) The following criteria are customarily applied by FTI in a rational decision process to determine whetha the information should be classified as proprietary. Information may be classified as proprietary if one or more of the following criteria are met:

a. Information reveals cost or price information, commercial strategies, production capabilities, or budget levels of FTI, its customers or suppliers,

b. The information reveals data or material concerning FTI research or development plans or programs of present or potential competitive advantage to ITI.

c. The use of the information by a competitor would decrease his expenditures, in time or resources, in designing, producing or marketing a similar product.

d. The information consists of test data or other similar data concerning a process, method or component, the application of which results in a competitive advantage to FTI.

e. The information reveals special aspects of a process, method, component or the like, the exclusive use of which results in a competitive advantage to FTI.

f. The information contains ideas for which patent protection may be sought.

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O AFFIDAVIT OF JAMFS H. TAYLOR (Cont'd.)

i The document (s) listed on Exhibit "A", which is attached hereto and made a part hereof, has been evaluated in accordance with normal FTI precedures with respect to classification and has been found to contain information which falls within one or more of the criteria enumerated above. Exhibit "B", which is attached hereto and made a part hereof, specifically identifies the criteria applicable to the document (s) listed in Exhibit "A".

(iii) The document (s) listed in Exhibit "A", which has been made available to the United States Nuclear Regulatory Commission was made available in confidence with a request that the document (s) and the information contained therein be withheld from public disclosure.

(iv) The information is not available in the open literature and to the best of our knowledge is not known by Combustion Engineering, EXXON, General Electric, Westinghouse or other current or potential domestic or foreign competitors of FT!.

(v) Specific information with regard to whether public disclosure of the information is likely to cause harm to the competitive position of FTI, taking into account the value of the infonnation to FTI; the amount of effort or money expended by FTl oeveloping the information; and the case or difficulty with which the information could be ,

properly duplicated by others is given in Exhibit "B".

E. I have personally reviewed the document (s) listed on Exhibit "A" and have found that it is considered proprietary by FTI because it contains information which falls within one or more of the criteria enumerated in Paragraph D, and it is information which is customarily held in confidence and pmtected as pmprietary information by FTI. This report comprises information ,

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P AEEIDAYILDEJAMFA H. TAYLOR (Cont'd.) -i utilized by FTI in its business which afford FH an opportunity to obtain a competitive advantage .l over those who may wish to know or use the information contained in the document (s).

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! JAMES H. TAYLOR ,

- State of Virginia)  !

) SS. Lynchburg .

City of Lynchburg)

James H. Taylor, being duly sworn, on his oath deposes and says that he is the person who subscribed his name to the foregoing statement, and that the matters and facts set forth in the statement are true.

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. 8/6 . A-F JAMES H. TAYLOR Subscribed and sworn before me '

this $ day of timbe 1997.

c 'Nnrrs . k5tw$

Notary Public in and for the City.

of Lynchburg, State of Virginia, i My Commission Expires Mw3l 2D:>D

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t EXHIBIT A OTSG REPAIR ROLL QUALIFICATION REPORT DOCUMENT #: BAW-2303P, REV. 03 AND RESPONSES TO THE BELOW LISTED QUESTIONS IN THE NRC REQUEST FOR ADDITIONAL INFORMATION QUESTION NO'S: B3, B4, B5, B8,89, AND B12 EXHIBIT B PROPRlETARY CLASSIFICATION CRITERIA: b, c, d '

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