View source for TXX-6112, Forwards Advance Copy of FSAR Rev Re Heat Treatment & Shotpeening on Unit 1 Steam Generator Tubes,Nonproprietary WCAP-11128 & Proprietary WCAP-11175 & WCAP-11127.W/o WCAP- 11174.Proprietary Repts Withheld (Ref 10CFR2.790)

{{Adams
| number = ML20214J921
| issue date = 11/24/1986
| title = Forwards Advance Copy of FSAR Rev Re Heat Treatment & Shotpeening on Unit 1 Steam Generator Tubes,Nonproprietary WCAP-11128 & Proprietary WCAP-11175 & WCAP-11127.W/o WCAP- 11174.Proprietary Repts Withheld (Ref 10CFR2.790)
| author name = Counsil W
| author affiliation = TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
| addressee name = Noonan V
| addressee affiliation = NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
| docket = 05000445, 05000446
| license number = 
| contact person = 
| document report number = TXX-6112, NUDOCS 8612020053
| package number = ML19292G307
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 13
}}

=Text=
{{#Wiki_filter:y           --
                 ,.                                                                                                      1 Log # TXX-6112 i *-
File # 10010 905.4 TEXAS UTILITIES GENERATING COMPANY SKYWAY TOWER . 488 NORTH OtJVE STREET,1.B. el . DA11AS. T9'XAS 7&301 November 24, 1986 721".hff.U E Director of Nuclear Reactor Regulation Attn: Mr. Vince S. Noonan, Director Comanche Peak Project Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C. 20555

==SUBJECT:==
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 and 50-446 HEAT TREATMENT AND SH0TPEENING 0F UNIT 1 STEAM GENERATOR TUBES

==Dear Mr. Noonan:==

Attached is an advance copy of a FSAR revision, scheduled for a future FSAR amendment, incorporating a description of the heat treatment and shotpeening processes performed on the Unit I steam generator tubes to reduce their susceptibility to inner diameter primary water stress corrosion cracking.
Enclosed are copies of the following Westinghouse reports which have been referenced in the above FSAR revision:
: 1. WCAP-11175, " Row I and 2 U-Bend Heat Treatment Licensing Report for Comanche Peak Unit 1" (Proprietary).
: 2. WCAP-11174, " Row I and 2 U-Bend Heat Treatment Licensing Report for Comanche Peak Unit 1" (Non-Proprietary).
: 3. WCAP-11127, "Shotpeening Licensing Report for Comanche Peak Unit 1" (Proprietary).
: 4. WCAP-11128, "Shotpeening Licensing Report for Comanche Peak Unit 1" (Non-Proprietary).
Also enclosed are Westinghouse Applications For Withholding, CAW-86-063 and CAW-86-043, accompanying affidavit, and Proprietary Information Notice.
As this submittal contains information proprietary to Westinghouse Electric Corporation, it is supported by an affidavit signed by Westinghouse, the owner of the information. The affidavit sets forth the basis on which the 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.
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Accordingly, it is respectfully requested that information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10CFR Section 2.790 of the Commission's regulations. Correspondence with respect to the proprietary aspects of the Applications for Withholding or the supporting Westinghouse affidavit should reference CAW-86-063 and/or CAW-86-043 and should be addressed to R. A. Wiesemann, Manager Regulatory and Legislative Affairs, Westinghouse Electric Corporation, P. O. Box 355, Pittsburgh, Pennsylvania 15230.
Very truly yours, i?
W. G. Counsil BSD/amb Attachment Enclosures c - NRC (letter, attachment and enclosures - 8 copies)
C. Trammell (w/o enclosures)
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u x 5112 Enclosure November 24, 1986 PROPRIETARY INFORMATION NOTICE TRANSMITTED HDEWITH ARE PROPRIETARY AND/OR NON-FROP DOCUMENTS FURNISHE TO 1HE NRC IN CONNECTION WITH PLAhT SPECIFIC REVIEW AND APPROVAL.
IN ORDER 10 CONFORM TD 1HE RIQUIREMENTS E 10CFR2.790 W RIIiULATIONS CONCERNING THE PROTECTION & PROPRIETA TO THE NRC,1HE INFORMATION WHICH IS PROPRIETARY IN THE PROPRIET CONTAINED WITRIN BRACKE73 AND WHERE 1HE PROPRIETARY I
* DII.ETED IN THE NON-PROPRIETARY VERSIONS GILT THE BRACKETS REMAIN,            -
IhTORMATION THAT WAS CONTAINE WITHIN 1HE BRACKETS HAVING BEDI DE.ETE. THE JUSTIFICATION FDR Q.AIMDiG                  ;N 30 THE D.'
DESIGNATED AS PROPRIETARY IS INDICATE IN BCTIH VERSIO LETTERS (a) THROUGH (g) C0hTAINE WITHIN PARENTHESES LOCATE AS A S IMMEDIATELY FOU.0 WING THE BRACXETS DCI.CSING EACH ITE DENTIFIED AS PROPRIETARY OR IN THE MARGIN OPPOSITE                                    SUCH t
THESE LOWER CASE LETTERS REFER 10 THE TYPES & INFORMATION HOLDS IN CONFIDENCE IDEhTIFIED IN SECTIONS (4)(ii)(a) through (4)(11)(g) 0 AFFIDAVIT ACCOMPAhTING 1HIS TRANSMITTAL PURSJAhT TD 10
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[""-*~~~~                                                             TXX-6112 Attachment
         -                                  CPSES/FSAR                November 24, 1986 cay be expected to accurulate. Continuous blowdown provides maximum 7
protection against inleakage of impurities from the condenser.
Thermal treatment of Inconel tubes to reduce residual tensile stresses has been shown to be effective in limiting stress corrosion cracking, especially in the U-bend region and the expanded region at the tubesheet. Tubing used in the Model D5 steam generators (Unit 2) have been thermally treated at the factory. The earlier Model D4 steam generators (Unit 1) were not thermally treated. To reduce the                  Rev.
residual tensile stresses in the Model D4 tubing, Row I and Row 2 U-bends have been stress relieved using an in situ thermal process [5],
and the hot and cold legs of all active tubes have been shotpeened within the tubesheet region [6]. Application of these processes provides additional margin against inner diameter primary water stress corrosion cracking.
Operating experience, verified in numerous steam generator inspections, indicates that the tube degradation associated with phosphate water treatment is not occurring where only AVT has been 7
utilized. Adherence to the AVT chemical specifications and close monitoring of the condenser integrity will assure the continued good performance of the steam generator tubing.
Additional extensive operating data is presently being accumulated with the conversion to AVT chemistry. A comprehensive program of steam generator inspections, including the requirements of Regulatory Guide 1.83, with the exceptions as stated in Appendix 1A(N) will ensure detection and correction of any unanticipated degradation that might occur in the steam generator.
5.4.2.1.4     Monitoring of Secondary Side Water Chemistry The chemistry of the steam generator water and condensate is
,          continuously monitored as described in Section 9.3.2 and 10.4.16               1 i                                                                                         Q122.2 i
respectively. The conductivity and pH of the secondary side are continuously measured as are dissolved oxygen, sodium and hydrazine content. Addition rates of secondary side chemicals are controlled by l                                            5.4-18a l
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TXX-6112 Attachment
* CPSES/FSAR                    liovember 24, 1986 public health and safety. The metheds ustd for the analysis of the Safe Shutdown Earthquake and LOCA conditions are given in Section 3.9N.I.
5.4.14.4      Tests and Insoections Weld inspection and standards are specified in accordance with Section V of the ASME Code. Welder qualifications and welding procedures are specified in accordance with Section IX of the ASME Code.
REFERENCES
: 1.      " Reactor Coolant Pump Integrity in LOCA," WCAP-8163, September 1973.
: 2.      Shabbits, W. O., " Dynamic Fracture Toughness Properties of Heavy Section A533 Grade B Class 1 Steel Plate," WCAP-7623, December 1970.
: 3.      " Evaluation of Steam Generator Tube, Tubesheet and Divider Plant Under Combined LOCA Plus SSE Conditions," WCAP-7832, December 1973.
: 4.      Westinghouse Report "Counterflow Preheat Steam Generator Tube          41 Expansion Report," June 1983
: 5.      WCAP-11175 (Proprietary), WCAP-11174 (Non-Proprietary)," Row I and Row 2 U-Bend Heat Treatment Licensing Report for Comanche Peak Unit 1", July 1986.
Rev.
: 6.      WCAP-lll27 (Proprietary), WCAP-11128 (Non-Proprietary),
!               "Shotpeening Licensing Report for Comanche Peak Unit 1" May 1986.
5.4-87 l
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       . , .                                                                       TXX-5112 Enclosure
                                                                                  - flovember 24, 1985 CAW-81-79 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF ALLEGHENY:
Before me, the undersigned authority, personally appeared Robert A. Wiesemann, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Corporation (" Westinghouse") and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:
dA 4  A Robert A. Wiesemann, Manager Regulatory and Legislative Affairs l
l Sworn to and subscribed before me this e day of Dur./w              1981.
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I CAW-81-79 (1) I am Manager, Regulatory and Legislative Affairs, in the N0 clear Technology Division, of Westinghouse Electric Corporation and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public dis-closure in connection with nuclear power plant licensing or rule-making proceedings, and am authorized to apply for its withholding on behalf of the Westinghouse Water Reactor Divisions.
(2) I am making this Affidavit in conformance with the provisions of 10CFR Section 2.790 of the Commission's regulations and in con-junction with the Westinghouse application for withholding ac-companying this Affidavit.
(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse Nuclear Energy Systems in designating information as a trade secret, privileged or as confidential commercial or financial information.
(4) Pursuant to the provisions of p'aragraph (b)(4) of Section 2.790 I
of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the in-
!                  formation sought to be withheld from public disclosure should be withheld.
l (i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.
i i
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1                                                              CAW-81-79 1
(ii) The information is of a type customarily held in confidence         j by Westinghouse and not customarily disclosed to the public.
Westinghouse 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 application of that system and the substance of that system constitutes Westinghouse policy and provides the           !
rational basis required.                                          ;
Under that system, information is held in confidence if it        I falls in one or more of several types, the release of which might result in the loss of an existing or potential com-petitive advantage, as follows:
(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.)
where prevention of its use by any of Westinghouse's competitors without license from Westinghouse consti-tutes a competitive economic advantage over other companies.
(b)   It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.
2

CAW-81-79 (c)   Its use 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 a similar product.
(d)   It reveals cost or price information, production cap-acities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.
(e)   It reveals aspects of past, present, or future West-inghouse or customer funded development plans and pro-grams of potential commercial value to Westinghouse.
(f) It contains patentable ideas, for which patent pro-tection may be desirable.
(g)    It is not the property of Westinghouse, but must be treated as proprietary by Westinghouse according to agreements with the owner.
There are sound policy reasons behind the Westinghouse system which include the following:
(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its com-petitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

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CAW-81-79 (b)  It is information which is marketable in many ways.
The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.
(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.
(d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary infor-mation, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.
(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition in those countries.
(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

f CAW-81-79      l l
(iii) The information is being transmitted to the Comission-in confidence and, under the provisions of 10CFR Section 2.790, it is to be received in confidence by the Comission.
(iv) The information sought to be protected is not available in public sources or available information has not been pre-viously employed in the same original manner or method to the best of our knowledge and belief.
(v) The proprietary information sought to be withheld in this submittal'is that which is appropriately marked in " Steam Generator Tube Plugging Margin Analysis" for the Virgil C.
Summer Nuclear Power Plant Unit No.1, WCAP-0912, Revi-sion 2 (Proprietary) being transmitted by South Carolina Electric and Gas Company letter Application for Withholding Proprietary Information from Public Disclosure, Nichols to Denton, November 1981. The proprietary information as sub-mitted for South Carolina Electric and Gas Company, Virgil C.
Sumer Nuclear Station use is expected to be applicable in other licensee and applicant submittals in response to cer-tain NRC requirements for justification of the steam generator tube plugging margin.
This infonnation is part of that which will enable Westing-house to:
(a) Provide documentation of the analyses, method and test-ing for determining plugging margin.

4 l .
CAW-81-79 (b)  Establish the minimum wall thickness in compliante with Regulatory Guide 1.121.
(c)   Establish the stress limits versus thinning of the remaining tube wall.
(d)   Establish the maximum allowable leakage in support of the leak-before-break criteria.
(e) Assist the customer to obtain NRC approval.
Further this information has substantial comercial value as follows:
(a) Westinghouse plans to sell similar information to its customers for purposes of meeting NRC requirements for licensing documentation.
(b) Westinghouse can sell support and defense of the tech-nology to its customers in the licensing process.
Public disclosure of this information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to pro-vide similar analytical documentation and licensing defense services for comercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC require-ments for licensing documentation without purchasing the right to use the infonnation.

1   .
1 CAW-81-79 The development of the technology described in part b'f the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.
In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended for system design software development.
Further the deponent sayeth not.
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