ML20212K194
| ML20212K194 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 03/06/1987 |
| From: | Musolf D NORTHERN STATES POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19292G883 | List: |
| References | |
| NUDOCS 8703090239 | |
| Download: ML20212K194 (6) | |
Text
,_
Northem States Power Company 414 Nicollet Mall Minneapohs. Minnesota 55401 Telephone (612) 330-5500 March 6, 1987 U S Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 PRAIRIE ISLAND NUCLEAR GENERATING PIANT Docket Nos. 50-282 License Nos. DPR-42 50-306 DPR-60 Revision to Combustion Engineering Steam Generator Tube Sleeve Licensing Report License Amendments 76 (DPR-42) and 69 (DPR-60), dated October 11, 1985, authorized the use of sleeving as a method for repair of the Prairie Island steam generator tubes. One of the sleeve designs found acceptable was described in Combustion Engineering Report CEN 294-P, " Prairie Island Steam Generator Tube Repair Using Leak Tight Sleeves", January 15, 1985.
Report CEN-294-P has been revised to incorporate the following changes:
- 1. Analyses which specifically address 27 inch sleeves.
- 2. Clarification of the sleeve installation inspection.
- 3. Updates to equipment operation to incorporate field experience.
- 4. Revised repair weld procedure.
- 5. Updates to the sleeving history to include the latest experience.
- 6. Updated figures.
The sleeve d3 sign has not been changed. The purpose of this letter is to provide, for the information of the Commission, copies of the revised Combustion Engineering Report CEN-294-P.
Enclosed are five copies of Combustion Engineering Report CEN-294-P, Revision 2-P, " Prairie Island Steam Generator Tube Repair Using Leak Tight Sleeves", January 29, 1987.
8703090239 8703%
PDR ADOCK 05000282 p
PDR PAol CONTAINS PROPRIETARY INFORMATION TO BE WITilllELD FROM PUBLIC DISCLOSURE IN ACCORDANCE WITil 10 CFR SECTION 2.790 II l
c U S Nu le Reglatory Commission
-Page 2 Also enclosed is an affidavit. executed by Combestion Engineering. Report CEN-294-P, Revision 2-P, contains information proprietary to Combustion Engineering Incorporated, as supported by the affidavit signed by
~
Combustion Engineering, the owner of=the information.
The affidavit sets forth the basis on which thc information may be withheld from public
- disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 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 Section 2.790.
d (N -.
David Musolf Manager.- Nuclear Support Services DMM/EFE/efe c: Regional Administrator-III, NRC (w/o attachment)
NRR Project Manager, NRC (w/o attachment)
Resident Inspector, NRC (w/o attachment)
G Charnoff (w/o attachment) i i
l CONTAINS PROPRIETARY INFORMATION TO BE WITilflELD FROM PUBLIC DISCLOSURE IN ACCORDANCE WITil 10 CFR SECTION 2.790 l
I
AFFIDAVIT PURSUANT TO 10 CFR 2.790 Combustion Engineering, Inc.
)
State of Connecticut
)
County of Hartford
)
SS.:
I, A.E. Scherer, 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 paragraph immediately below.
I am submitting this affidavit in conformance with the provisions of 10 CFR 2.790 of the Commission's regulations and in conjunction with the application of Northern States Power Company for withholding this information.
The information for which proprietary treatment is sought is contained in the following document:
CEN-294-P, Revision 2-P, Prairie Island Steam Generator Tube Repair Using Leak Tight Sleeves, January 29, 1987.
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 secret, privileged or 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 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 concerns design and development work for the repair of degraded steam generator tubes using welded leak tight sleeves, which is owned and has been held in confidence by Combustion Engineering.
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. Stern to Frank Schroeder dated December 2, 1974. This system was applied in determining that the subject document herein are 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 ma r,tenance of the information in confidence.
i 6.
Public disclosure of the information is likely to cause substantial harm to the competitive position of Combustion Engineering because:
1
l
- 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 hundreds of l
thousands of dollars and tens of thousands of man-hours of effort. To the best of my knowledge and belief a competitor would have to undergo similar expense in generating equivalent information.
l c.
In order to acquire such information, a competitor would also require considerable time and inconvenience in developing the design of a leak i
tight steam generator sleeve.
d.
The information required significant effort and expense to obtain the licensing approvals necessary for application of the information.
Avoidance of this expense would decrease a competitor's cost in applying the information and marketing the product to which the information is applicable.
l e.
The information consists of design and development work on leak tight steam generator sleeves, 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 1
apparatus, f.
In pricing Combustion Engineering's products and services, significant research, development, engineering, analytical, manufacturing, 1
licensing, quality assurance and other costs and expenses must be included.
The ability of Combustion Engineering's competitors to utilize such l
3 4-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 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.
l na3 T. E. fWh@eF - -
Director Nuclear Licensing Sworn to before m thisflg*%ay of (, ui.uct.1 j /9Q uc,t sJ nt Notary Public SUSANNE SMITH, NOTARY PUBLIC State of Connecticut No.14148 Commission Empires Wrch 31,1990