ULNRC-04004, Forwards Proprietary Thermal Stability Background Data Along with Time/Temp Graph Requested in 990402 Telcon with NRC & Contractor,Argonne Natl Lab.Proprietary Info Withheld

Forwards Proprietary Thermal Stability Background Data Along with Time/Temp Graph Requested in 990402 Telcon with NRC & Contractor,Argonne Natl Lab.Proprietary Info Withheld

ML20205K352
Person / Time
Site:	Callaway
Issue date:	04/07/1999
From:	Passwater A UNION ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20137H296	List: ULNRC-04004, Forwards Proprietary Thermal Stability Background Data Along with Time/Temp Graph Requested in 990402 Telcon with NRC & Contractor,Argonne Natl Lab.Proprietary Info Withheld
References
TAC-MA3954, ULNRC-04004, ULNRC-4004, NUDOCS 9904130139
Download: ML20205K352 (10)

Text

7 Union EI:ctric One Ameren Ylaza p 1901 Chouteau Avenue a'

PO Box 66149 St. Iouis, MO 63166-6149 April 7,1999 3runazu U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station PI-137 Washington, DC 20555-0001 ULNRC-04004 Gentlemen: TAC No. MA 3954 CALLAWAY PLANT gf4, UNION ELECTRIC COMPANY 77f DOCKET NUMBER 50-483 O REVISION TO TECHNICAL SPECIFICATION 3/4.4 UE REACTOR COOLANT SYSTEM

References:

1) ULNRC-3910 dated October 27,1998

2) ULNRC-3920 dated November 13,1998

3) ULNRC-3948 dated January 11, ~.999

4) ULNRC-3955 dated January 29,1999

5) ULNRC-3970 dated Febmary 25,1999 The referenced letters transmitted an amendment request to revise Callaway Technical Specifications to use Electrosleeves to repair steam generator tubes.

In February,1999 NRC contacted AmerenUE personnel concerning evaluation of Electrosleeve material at high temperature severe accident conditions. Although AmerenUE considers the performance ofElectrosleeves in high temperature severe accident conditions to be beyond the licensing and design basis for Cal! say Plant we are providing this additional information to facilitate the timely approval of the requested amendment.

This letter transmits thermal stability background data along with a time / temperature graph requested in a phone call with NRC and their contractor, Argonne National Laboratory (ANL), on April 2,1999. It is our understanding that the information provided will be sent to ANL in support of analytical modeling performed at the request of the NRC. Additionally, the Materials Handbook Ninth Edition, Vol. 3 Properties and Selection: Stainless Steels, Tool Materials and Special-Purpose Metals was used as reference material.

Framatome Technologies, Inc. (FTI) has determined that all of the attached information associated with the installation process for electrosleeves is

" Proprietary," and is thereby supported by an amdavit signed by J. J. Kelly, i Framatome Technologies, Inc. (the owner of the information). This af6 davit sets i b#

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9904130139 990407 /

DR ADOCK 050004 3

< 0 g- jg  ; )yg y QJ s subsidsary of Amaren Corporation I

q U.S. Nuclear Regulatory Commission

.* April 7,1999 Page 2 i I

forth the basis on which the information may be withheld from public disclosure by the Commission and addresses specifically the considerations listed in i l

10CFR2.790. Accordingly, please submit this affidavit with your transmitt I material and request that in accordance with 10CFR2.790, the NRC withhold  ;

from public disclosure the information which is Proprietary to Framatome 1 Technologies. i Since FTl has determined that all of the attached information is proprietary, a non-proprietary version is not provided.

If you have any questions please contact us.

Sincerely,

,A.~:3 [l~

Alan C. Passwater l Manager, Corwrate Nuclear Services  !

DES /pir Attainments: Affidavit ofJoseph J. Kelly Exhibits A and B

" Thermal Stability Assessment - Electrosleeved Tubes" l l

STATE OF MISSOURI )

) SS CITY OF ST. LOUIS )

David Shafer, of lawful age, being first t y

sworn upon oath says that he is Supervising Engineer, Corporate Nuclear Services, Regulatory Operations for Union Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed the name for and on behalf of said company with full power and authority to do so; and that the facts therein stated are true'and correct to the best of his knowledge, information

.and belief.

By -> Mib David Stiefer' Supervising Engineer, Regulatory Operations, Corporate JP2 clear Services SUBSCRIB D and sworn to before me this 7//) day of

)/K/ , 1999.

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[h PATRICIA L REYNOLDS NOTARI PUBUC-STATE OF MISBOUN ST. LOUIS COUNTY MY COMMtS6&ON EXPIMS DEC.22,IMO i

I cc: M. H. Fletcher Professional Nuclear Consulting, Inc.

19041 Raines Drive Derwood, MD 20855-2432 Regional Administrator M/*-

-U.S. Nuclear Regulatory Commission Region IV 611 Rjan Plaza Drive Suite 400 Arlington, TX 76011-8064 Senior Resident Inspector dJ/a Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Mel Gray (2) W/k Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 1 White Flint, North, Mail Stop 13E16 11555 Rockville Pike Rockville, MD 20852-2738 Manager, Electric Department l Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102 Ron Kucera Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102 Denny Buschbaum TU Electric P.O. Box 1002 Glen Rose, TX 76043 Pat Nugent Pacific Gas & Electric Regulatory _ Services P.O. Box 56 Avila Beach, CA 93424 b

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AFFIDAVIT OF JOSEPH J. KELLY A. My name is Joseph J. Kelly. I am Manager of B&W Owners Group Services for Framatome Technologies, Inc. (FTI), and as such, I am authorized to execute this Affidavit.

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

C. In determining whether an FTI document is to be classified as proprietary information, an initial determination is made by the Unit Manager, who is responsible for originating the document, as to whether it falls within the criteria set forth in Paragraph D hereof. If the information falls within any one of these criteria, it is classified as proprietary by the originating Unit Manager. This initial determination is reviewed by the cognizant Section Manager. If the document is designated as pr , ietary, it is reviewed again by me to assure that the regulatory requirements of 10 CFR Sation 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:

e (i) The information has been held in confidence by FTI. Copies of the document are clearly identified as proprietary. In addition, whenever FTI 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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L l MFIDAVIT OF JOSEPH J. KELLY (Cont'd.)

"Any proprietary information concerning Company's or its Supplier's products 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 ofCompany or its Supphers 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.

i 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 information withheld from public inspection.

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

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l AFFIDAVIT OF JOSEPH J. KELLY (Cont'd.)

)

(ii) The following criteria are customarily applied by FfI in a rational decision process to determine whether the information should be classified as proprietary.

Information may be classified as proprietag ifone or more of the following criteria I

are met:

I

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 FTI.

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 l

process, method or component, the application of which results in a competitive advantage to FTI.

l 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.

3 L

l AFFIDAVIT OF JOSEPH J. KELLY (Cont'd.)

The document (s) listed on Exhibit "A", which is attached hereto and made a part 1 hereof, has been evaluated in accordance with norme.1 FTI procedures 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 availabic 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, Wr.stinghouse or other current or potential domestic or foreign competitors of FTI.

-(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 l value of the information to FTI; the amount of effort or money expended by FTl developing the information; and the case or difficulty with which the information j could be properly duplicated by others is given in Exhibit "B".

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

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AFFIDAVIT OF JOSEPH J. KELLY (Cont'd.)

Infonnation utilized by FTI in its business which afford FTI an opportunity to obtain a competitio advantage over those who may wish to know or use the information contained .

i in the document (s).

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\ \

K%2PH J. KELLY State of Virginia)

) SS. Lynchburg City of Lynchburg)

Joseph J. Kelly, 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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$bH J. KEL 4

l Subscribed and swprn before me this $4 day of(l/ NIL 1999.

A O. U -

Notary Public in and fer the City ofLynchburg, State of Virginia.

My Commission ExpiresOd 31 lM')

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EXillHITS A & H EXIIIBIT A I

" Thermal Stability Assessment - Electrosleeved Tubes ".

EXIIIBIT H The above listed document contains information which is considered Proprietary in accordance with Criteria b, d, and e of the attached aindavit.

I