ML20215C811
| ML20215C811 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/08/1986 |
| From: | Cooney M PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Muller D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19292G000 | List: |
| References | |
| NUDOCS 8610100455 | |
| Download: ML20215C811 (6) | |
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PHILADELPHIA ELECTRIC COMPANY 23ol MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 I * "I *
- op_av October 8, 1986 u.
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Docket No. 50-278 Mr. Daniel R. Muller, Director BWR Project Directorate #2 Division of Boiling Water Reactor Licensing U.S. Nuclear Regulatory Commission Washington, DC 20555
SUBJECT:
Peach Bottom Atomic Power Station Unit 3 Mid-Cycle Examination Of Five Welds
REFERENCES:
1)
Letter, D. R. Muller, USNRC, to E. G.
Bauer, PECo, dated March 20, 1986 (Confirmatory Orders) 2)
- Letter, M. J. Cooney, PECo, to D. R.
Muller, USNRC, dated June 9, 1986
Dear Mr. Muller:
In the reference (1) letter, the NRC issued Confirmatory Orders to Philadelphia Electric Company (PECo) concerning Cycle 7 operation of Peach Bottom Atomic Power Station Unit 3 with ultrasonic indications in several welds.
One of the items specified in the Orders requires a mid-cycle inspection of three unrepaired pipe welds (RHR weld 10-0-3, recirculation piping welds 2-AS-08 and 2-BD-12) and two recirculation system inlet safe ends (F and J).
In the reference (2) letter, PECo identified the details for the mid-cycle inspection.
The Confirmatory Orders provide that the Director, Division of Boiling Water Reactor Licensing, may relax or terminate any of the provisions specified in the Orders upon request from the Licensee, if the request is timely and provides good cause for the requested action.
The purpose of this letter is to request that the Orders be modified to allow continued I
operation until the end of the current fuel cycle without a mid-cycle examination of the welds and safe ends identified above.
l stAo2R888R*t!8ll;e Ift P
s Mr. D. R. Muller, Director October 8, 1986 Page 2 New field data and experimental / analytical results obtained from the Crack Arrest Verification System (CAVS) installed on Peach Bottom Unit 3 show that the actual crack growth rates are t
significantly below tha,t which was projected earlier by analysis.
Crack growth rates from the CAVS can be directly applied to predict crack growth in the Peach Bottom Unit 3 safe ends and pipe welds.
Based upon the CAVS data, the cracks in the safe ends and pipe welds can be shown to be acceptable "as-is" for more than 18 months of l
continued plant operation without the assumption of a plateau crack growth rate.
This new evidence addresses the NRC concerns raised during review of the earlier analyses and justifies continued operation of the Peach Bottom Unit 3 plant until the end of the current fuel cycle without a mid-cycle inspection.
The facts that the 4
additional benefits of water chemistry improvements were not included in the earlier crack growth analyses, that all crack lengths were assumed to be 360 degrees, and that more stringent leakage limit requirements have been imposed, all further add support to this request.
PECo's commitment to good chemistry on Unit 3 has significantly reduced the crack growth rate as indicated by the CAVS data.
The impurity level in the primary coolant has been proven to have a powerful and predictable effect on crack growth rates.
PECo has taken a number of actions to reduce the impurity level as measured by conductivity in the primary coolant during the first part of the I
fuel cycle.
In addition to these actions, a program is underway to further reduce the remaining impurities, if possible, during the i
remainder of the fuel cycle.
PECo believes that the average primary
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coolant chemistry on Unit 3 will remain low (less than 0.3 uS/cm) for the remainder of the fuel cycle, thus maintaining low crack growth rates.
The enclosed report entitled " Technical Basis for Operation of Peach Bottom Unit 3 through Cycle 7 with certain Recirculation Inlet Safe End and Fiping Weld Ultrasonic Indications" (SASR 86-49 Revision 2;DRF 137-0010) provides the technical basis justifying continued operation without a mid-cycle examination of the two inlet safe ends and the three pipe welds.
This report contains information which General Electric Company has advised us is confidential and Proprietary.
Accordingly, pursuant to Section 2.790 of the Commission's regulations it is hereby requested that the enclosed report be withheld from public disclosure.
An affidavit of Rudolph Villa of General Electric Company which sets forth the grounds for this request is attached.
Philadelphia Electric Company estimates that an outage to support the mid-cycle inspection would require a minimum of 15 days, and more likely 21-25 days based on past experience.
The replacement power costs for three weeks would be approximately 7 million dollars.
4 Total radiation dose to personnel associated with the weld inspections 3
is estimated to be 34 man-rem.
Considering the technical bases I
i
s Mr. D. R. Muller, Director Octob3r 8, 1986 Page 3 provided in this submittal, the economic penalties and the additional radiation doses associated with the mid-cycle examination do not appear to be warranted.
Currently, the mid-cycle examination is scheduled to begin'on January 3, 1987; therefore, prompt attention to this matter would be appreciated.
If we can provide any additional information, please do not hesitate to contact us.
Very truly yours, Attachments cc:
Dr. T. E. Murley, Administrator, Region I, USNRC T.
P. Johnson, Resident Site Inspector l
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GENERAL ELECTRIC C0MPANY AFFIDAVIT I, Rudolph Villa, being duly sworn, depose and state as follows:
1.
I am Manager, Products Licensing, General Electric Company, and have been delegated the function of reviewing the information described in paragraph 2 which is sought to be withheld and have been authorized to apply for its withholding.
2.
The information sought to be withheld is contained in the General Electric Report titled " Technical Basis for Operation of Peach Botton Unit 3 Through Cycle 7 with Certain Recirculation Inlet Safe End and Piping Wald Ultrasonic Indications", August 1986.
3.
In designating material as proprietary, General Electric utilizes the def-inition of proprietary information and trade secrets set forth in the American Law Institute's Restatement of Torts, Section 757.
This definition provides:
"A trade secret may consist of any formula, pattern, device or compilation of information which is use'd in one's business and which gives him an opportunity to obtain an advantage over competitors who do not know or use it....
A substantial element of secrecy must exist, so that, except by the use of improper means, there would.be difficulty in acquiring information....
Some factors to be considered in determining whether given information is one's trade secret ares (1) the extent to which the information is known outside of his business; (2) the extent to which it is known by employees and others involved in his business; (3) the extent of measures taken by him to guard the secrecy of the information; (4) the value of the information to him and to his competitors; (5) the amount of effort or money axpanded by him in developing the information; (6) the ease or difficulty with the which the information could be properly acauired or duplicated by others."
4.
Some examples of categories of information which fit into the definition of proprietary information are Information that disclosed a process, method or apparatus where a.
prevention of its use by General Electric's competitors without license from General Electric constitutes a competitive economic advantage over other companies; b.
Information consisting of supporting data and analyses, including test data, relative to a proce.ss, method or apparatus, the application of which provide a competitive economic advantage, e.g.,
by optimization or improved marketability; 1
j c.
Information which if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality or licensing of a similar product; d.
Information which reveals cost or price information, production capacities, budget levels or commercial strategies of General Electric, its customers or suppliers; e.
Information which reveals aspects of past, present or future General Electric customer-funded development plans and programs of potential commercial value to General Electric:
f.
Information which discloses patentable subject matter for which it may be desirable to obtain patent protection; g.
Information which General Electric must treat as proprietary according to agreements with other parties.
5.
Initial approval of proprietary treatment of a document is typically made by the Subsection manager of the originating component, the person who is most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to'such documents within the Company is limited on a "need to know" basis and such documents are clearly identified as proprietary.
6..
The procedure for approval of external release of such a document typically requires review by the Subsection Manager, Project Manager, Principal Scientist or other equivalent authority, by the Subsection Manager of the cognizant Marketing function (or delegate) and by the Legal Operation for technical content, competitive effect and determination of the accuracy of the proprietary designation in accordance with the standards enumerated r
above. Disclosures outside General Electric are generally limited to I
regulatory bodies, customers and potential customers and their agents,,
suppliers and licensees then only with appropriate protection by applicable regulatory provisions or proprietary agreements.
7.
The document mentioned in paragraph 2 above has been evaluated in accordance with the above criteria and procedures and has been found to contain information which is proprietary and which is customarily held in confidence by General Electric.
8.
The information in the document mentioned in paragraph 2 includes significant excerpts from GE proprietary documents and discloses methodology, supporting test data, and analyses that form a basis for crack arrest determination as a function of water chemistry in BWR's.
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9.
The information to the best of my knowledge and belief has consistently teen held in confidence by the General Electric Company, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties have been made pursuant to regulatory provisions of proprietary agreements which provide for maintenance of the information in confidence.
10.
Public disclosure of the information sought to be withheld is likely to cause substantial harm to the competitive position of the General Electric Company and deprive or reduce the availability of profit making opportunities.
STATE OF CALIFORNIA
) ss:
COUNTY OF SANTA CLARA
)
Rudolph Villa, being duly sworn, deposes and says:
That he has read the foregoing affidavit and the matters stated therein are true and correct to the best of his knowledge, information, and belief.
Executed at San Jose, California, this I
ay of
,198_[.
M/ak.
Rudolph Villa' General Electric Company Subscribed and sworn before me thi y of
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'C-PAULA F HUSSEY l,
NOTARY PUBLIC, STATE OF CAI(1TORNIA j(yl2 ;e rioTARY PUBUC - CAu?CRMA
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