ML20248M054
| ML20248M054 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 06/08/1998 |
| From: | Sorensen J NORTHERN STATES POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20036E425 | List: |
| References | |
| NUDOCS 9806120299 | |
| Download: ML20248M054 (8) | |
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Northern States Power Company Prairio Island Nuclear Generating Plant 1717 Wakonade Dr. East Welch. Minnesota 55089 l
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June 8,1998 U S Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 PRAIRIE ISLAldD NUCLEAR GENERATING PLANT Docket Nos.50-282 License Nos. DPR-42 50-306 DPR-60 Transmittal of Generic Licensing Report on Steam Generator Tube Repair Using Rero!Iing Per our teleconference of April 14,1998, NSP is submitting the following:
Non-proprietary ABB Combustion Engineering Report," Series 44 & 51 Design l
Steam Generator Tube Repair Using a Tube Rerolling Technique," Revision 05-NP
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(Attachment 3) l Proprietary ABB Combustion Engineering Report," Series 44 & 51 Design Steam l
Generator Tube Repair Using a Tube Rerolling Technique," Revision 05-P (Attachment 2)
ABB Combustion Engineering Affidavit Pursuant to 10 CFR 2.790 (Attachment 1)
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Acceptance criteria and the reroll of the original hard roll have been included (Sections jj 2.2 and 9.0 and Section 5.1)in the enclosed ABB Combustion Engineering Report CEN-620-P Revision 05-P (Attachment 2).
In this letter we have made no new Nuclear Regulatory Commission commitments.
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ATTACHMENT CONTAINS PROPRIETARY INFORMATION TO BE WITHHELD FROM PUBLIC DISCLOSURE IN ACCORDANCE WITH 10 CFR PART 2, SECTION 2.790 9806120299 980600 PDR ADOCK 05000282 P
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y-USNRC NORTHERN STATES POWER COMPANY June 8,1998 Page 2 Please contact Richard Pearson (612-388-1121) if you have any questions related to this letter, e
Joel P Sorensen 1
Plant Manager Prairie Island Nuclear Generating Plant c: Regional Administrator - Region Ill, NRC Senior Resident inspector, NRC NRR Project Manager, NRC J E Silberg Attachments:
- 1. Affidavit Pursuant to 10 CFR 2.790
- 2. ABB Combustion Engineering Report CEN-620-P, " Series 44 & 55 Design Steam Generator Tube Repair Using a Tube Rerolling Technique," Revision 05-P, May 1998.
- 3. ABB Combustion Engineering Report CEN-620-NP, " Series 44 & 55 Design Steam Generator Tube Repair Using a Tube Rerolling Technique," Revision 05-NP, May 1998.
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I CEteport. DOC l
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y ATTACHMENT 1 ABB Combustion Engineering Affidavit Pursuant to 10 CFR 2.790 i
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AFFIDAVIT PURSUANT 1
TO 10 CFR 2.790 l, l. C. Rickard, 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
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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 application of Northern States Power Company, and in conformance with the provisions of 10 CFR 2.790 of the Commission's regulations.
The information for which proprietary treatment is sought is contained in the following document:
Report CEN-620-P, Rev. 05-P, " Series 44 & 51 Design Steam Generator Tube Repair Using a Tube Rerolling Technique," May,1998 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 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 a
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details and supporting test data related to a tube rerolling technique for retuming steam generator tubes to service.
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 hundreds of L
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.q. ' manhours of effort. A competitor would have to undergo similar expense in generating equivalent information.
c.
In order to acquire s'uch information, a competitor would also require considerable time and inconvenience to develop and validate a similar tube rerolling repair technique.
d.
The information consists of det' ails and supporting test data related to a tube rerolling technique for retuming steam generator tubes to service, 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 i
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 intemational 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.
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Further the deponent sayeth not.-
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ctor Nuclear Licensing Sworn to before me this /5 "*
day of thL
,1998 daO,bd c/ c Notary Public
~ My commission expires:- 8 3/ 79 7
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ATTACHMENT 3 l
l ABB Combustion Engineering Report i
CEN-620-NP Series 44 & 51 Design Steam Generator Tube Repair Using a Tube Rerolling Technique Revision 05-NP 7
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