ML20096F292

Forwards non-proprietary Rev 0 to CEN-627-NP & Proprietary Rev 0 to CEN-627-P, Verification of Installation Process & Operating Performance of Abb Ceno SG Tube Sleeve for Use at Comm Ed... Proprietary Rept Withheld (Ref 10CFR2.790)

ML20096F292
Person / Time
Site:	Byron, Braidwood
Issue date:	01/17/1996
From:	Saccomando D COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19317C267	List: ML20096F292 ML20096F299
References
NUDOCS 9601230311
Download: ML20096F292 (8)

Text

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Ri , Commonwealth FAison Q>mpany 1400 Opus Place 5

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Downen Grove. IL 63515-5701 x

January 17,1996 Nuclear Regulatory Commission W'shington, D.C 20551 Attn: Document Control Desk

Subject:

Additional Information Pertaining to the Application is Amendment to Facility Operating Licenses for Steam Generator Tube Sleeves Byron Nuclear Power Station, Units 1 and 2 Braidwood Nuclear Power Station, Units 1 and 2 NRC Docket Numbers- 50: 454. 455. 456 and 457

References:

1. H. Pontious letter to the Nuclear Regulatory Commission dated May 17,1995, transmitting Application for Amenndment to Install ABB/CE TIG Sleeves into Steam Generator Tubes

2. C. Patel letter to R. Barkhurst ( Entergy Operations) dated July 11,1995, transmitting Request for Additional Information

3. C. Patel letter to R. Barkhurst (Entergy Operations) dated September 1,1995, transmitting Request for Additional Information

4. C. Patel letter to R. Barkhurst (Entergy Operations) dated December 14,1995, transmitting Safety Evaluation

Reference 1 transmitted Commonwealth Edison Company's (Comed) request to amend the Byron and Braidwood Units 1 and 2 Technical Specification to permit the steam generator tubes to be repaired using the tungsten inert gas (TIG) welded sleeve installed by Combustion Engineering (ABB/CE). Concurrent with Comed's submittal, the Nuclear Regulatory Commission (NRC) was also reviewing the same request for approval of the sleeve for Waterford 3. As a result of the Staffs review of Waterford's request, the Referenced RAls

, were issued. Subsequent to their issuanee, Waterford submitted to the StafT CEN 625-P,

" Verification of the ABB-CENO Steam Generator Tube Sleeve Installation Process and .

Operating Performance." Per conversations with the Staff, Comed is submitting a similar document that addresses Byron and Braidwood specifics of the sleeving process. Attached you will find: .

9601230311 960117

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Document Control Desk January 17,1996 Attaclunent 1. CEN-627-P: " Verification of the Installation Process and Operating Performance of the ABB CENO Steam Generator Tube Sleeve for use at Commonwealth Edison Byron and Braidwood Units 1 & 2,"

and Attachment 2. CEN-627-NP(non proprietary): " Verification of the ABB-CENO Steam Generator Tube Sleeve Installation Process and Operating Performance."

On December 14,1995, the NRC found the Waterford submittal acceptable and issued a Safety Evaluation Report which permits the use of the ABB/CE sleeve.

As CEN-627-P, contains information proprietary to ABB Combustion Engineering, Inc., it is supported by an affidavit (Attachment 3) signed by ABB Combustion Engineering, Inc., 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.

Accordingly, it is respectfully requested that the information which is proprietary to ABB Combustion Engineering, Inc. be withheld from public disclosure in accordance with 10 CFR 2.790 of the Commission's regulations.

Correspondence with respect to the proprietary aspects of the items listed above or the supporting ABB Combustion Engineering, Inc. Affidavit should reference CEN-627-P and should be addressed to W.R. Gahwiller, Director, Operations Licensing, ABB Combustion Engineering, Inc.,1000 Prc.nect llill Road, P. O. Box 500, Windsor, Connecticut, 06095-0500.

To the best of my knowledge and belief, the statements contained in this document are true and correct. In some respects these statements are not based on my personal knowledge, but on information furnished by other Comed employees, contractor employees, and/or consultants. Such information has been reviewed in accordance with company practice, and I believe it to be reliable.

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l Document Control Desk January 17,1996 l If you have any questions concerning this correspondence please contact this office.  ;

Sincerely,  !

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Senior Nuclear Licensing Administrator J

'0 h N b %2- Y7 96 Attachments cc: D. Lynch, Senior Project Manager-NRR G. Dick, Byron Project Manager-NRR R. Assa, Braidwood Project Manager-NRR l C. Phillips, Senior Resident Inspector-Braidwood H. Peterson, Senior Resident Inspector-Byron II. Miller, Regional Administrator-RIII Office of Nuclear Safety-IDNS 1

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AFFIDAVIT PURSUANT TO 10 CFR 2.790 l, Ian C. Rickard, depose and say that I am the Director, Operations Licensing, of Combusbon Engheering, Inc., duly authorized to make this amdavit, and have reviewed or caused to have  ;

reviewed the information which is identified as proprietary and referenced in the paragraph .

i immediately below, I am submitting this amdavit in conformanm with the provisions of 10 CFR i 2.790 of the Commission's regulations and in conjunction with the application of Commonwealth Edison for withholding this informahon The information for which proprietary treatment is sought is contained in the following document:

i CEN427-P, Rev. 00-P, 'Verificabon of the installabon Process and Operating Performance of the ABB CENO Steam Generator Tube Sleeve for Use at Comnxx1 wealth Edison Byron and Braidwood Units 1 & 2," January 1996.

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This document has been appropriately designated as propnetary.

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 financialinformation.

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l 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 design and development information mgarding ABB CENO welded steam generator tube sleeves.

2. The information is of a type customarily held in confidence by Combustion Engineenng and not customarily disclosed to the public. Combustion Enginsonng 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 systam 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 propnetary.

3. 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.

4. The information, to tha 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.

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5. - Public disclosure of the information is likely to cause substantial harm to the corrpoldive position of Combustion Engineering because.

a. A similar product is manufactured and sold by major pressurized water reactor i coinpetitors of Combustion Engineering

b. Development of this iniv6Tistion by Combuston Engineenng required millions of dollars and thousands of manhours of effort. A competitor would have to  :

undergo similar expense in generating equivalent information.

c. In order to acquire such iniviiristion, a cou9.titor would also require  :

considerable time and inmnvenience to design and develop welded steam generator tube sleeves.

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d. The information consists of design and development information regarding ABB  ;

CENO welded steam generator tube sleeve, the application of which provMes a competitive economic advantage. The availability of such infunrietion 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 apparatus.

e. In pricing Combustion Engineenng'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 sinilar

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expenditure of resources may enable them to sell at pnoes reflecting significantlylower costs.

f. Use of the information by competitors in the international marketplace would l

increase their ability to market nuclear steam supply systems by reducing the l

costs associated with their tedinciogy development. In addition, disclosure would have an adverse economic impact on Combustion Engineering's potential 1

for obtaining or maintaining foreign licensees. j Further the deponent sayeth not.

W Operations Licensing Sworn to before me ,

this /M dayof .1996 l O' 0 011ALL a '

l 414ary Public [/

l My commission expires: 6/3/b9 t ' I

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4' ATTACHMENT 2 l CEN-627-NP l

Verification of the Installation Process and Operating Performance of the ABB CENO Steam Generator Tube Sleeve for use at Commonwealth Edison Byror, l and Braidwood Units 1 & 2 l

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