ML20199C533

Forwards Nonproprietary & Proprietary Rev 1 to CEN-331-NP & CEN-331-P,respectively, Zion Units 1 & 2 Steam Generator Tube Repair..., Per 860424 Proposed Amends to Licenses DPR-39 & DPR-48.Proprietary Rept Withheld (Ref 10CFR2.790)

ML20199C533
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	06/16/1986
From:	Leblond P COMMONWEALTH EDISON CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML19292F437	List: ML20199C533 ML20199C562
References
1776K, NUDOCS 8606180186
Download: ML20199C533 (8)

Text

. _ _ ._ .-___ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _

- Commonw dth Edison

= .

72 West Adtms Street Chicigo, Illinois Addrtss RIply to: Post Office Dox 767 Chicago, Illinois 60690- 0767 June 16, 1986

=

Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commission Washington, DC 20555 5

~

Subject:

Zion Nuclear Power Station Units 1 and 2 g

Steam Generator Tube Sleeving NRC Docket Nos. 50-295 and 50-304 L

[

Reference:

April 24, 1986 letter from P. C. LeBlond to H. R. Denton.

Dear Mr. Denton:

s '

The referenced letter transmitted a proposed amendment to Facility Operating License Nos. DPR-39 and DPR-48, Appendix A, Section 4.3 - Reactor Coolant System. This change would allow Zion's Steam Generator Tubes to be repaired, if needed, by utilizing an NRC approved sleeving method. This letter transmits for NRC review and approval, Commonwealth Edison's proposed method for sleeving steam generator tubes at Zion Station.

Enclosed with this letter are three copies of Combustion Engineering I

Inc. Report No. CEN-331-P, Revision 1-P and one copy of a nonproprietary E

version of the same report. This report is Commonwealth Edison's proposed

., sleeving method for Zion Station to be utilized subsequent to the approval of both this specific methodology and the referenced technical specification g amendment request. Attachment I describes the inspection, testing, and

= reporting requirements that will be utilized for,all sleeved tubes.

4

_ 7'

.60 k In accordance with 10 CFR 2.790, Commonwealth Edison is requesting i that the proprietary version of the enclosed reports, CEN-331-P, Revision

@ l-P, Zion Units 1 and 2 Steam Generator Tube Repair, June 1906, be withheld I

to o in whole from public disclosure. Attachment 2 to this letter is an affidavit executed by Mr. A. E. Scherer, Director of Nuclear Licensing for Combustion og Engineering Incorporated. This affidavit contains the information discussed 3o in 10 CFR 2.790.b.4.

OQ D Commonwealth Edison Company intends to implement the option for je sleeving steam generator tubes at Zion Station as soon as feasible. The j{ plugging of steam generator tubes that contain defects in the tube sheet c region unnecessarily degrades the heat transfer capability of Zion's steam generators. Thus, the implementation of the sleeving repair option effectively lengthens the useful life of Zion's steam generators.

E M.PRoh a M t.Y E NOT'ILPOR p5Y N9C POR M'

k" M % O "- h g,p.paop

$ (56 -00 f] 3-pe.o?

f Mr. H. R. Denton June 16, 1986 Eion Unit I will undergo a scheduled refueling outage beginning in mid-July of this year. The currently scheduled time period for steam generator plugging / sleeving is from August 12-25. Therefore, commonwealth Edison Company is requesting an expedited NRC review of the proposed sleeving method in order that the sleeving option may be exercised during the upcoming outage. Commonwealth Edison is prepared to support this expedited review in whatever manner may become necessary.

In accordance with 10 CFR 170, a check for $150.00 is enclosed.

Please direct any questions you may have regarding this matter to thir department.

Very truly yours, P. C. LeBlond Nuclear Licensing Administrator in Enclosures cc NRC Resident Inspector - Zion Mr. J. A. Norris - NRR 1776K

o! i- ,

. ,3 AFFIDAVIT PURSUANT TO 10 CFR 2.790 Combustion Engineering, Inc. )

State of Connecticut )

County of Hartford ) SS.:

I, A. E. Scherer, 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 have reviewed the information which is identified as proprietary and referenced in the paragraph immediately below. I am submitting this affidavit in conformance with the provisions of 10 CFR 2.790 of the Commission's regulations and in conjunction with the application of Commonwealth Edison for withholding this information.

The information for which proprietary treatment is sought is contained in the following document:

CEN-331-P, Rev. 1-P, Zion 1 and 2 Steam Generator Tube Repair, June, 1986 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 are

! design, manufacturing, installation and testing of steam generator tube welded sleeve repairs, which is owned and has been held in confidence by Combustion i

Engineering.

2. The information consists of test data or other similar data concerning i a process, method or component, the application of which results in a substantial competitive advantage to Combustion Engineering.

3. The information is of a type customarily held in confidence by l

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 l to determine when and whether to hold certain types of information in l confidence. The details of the aforementioned system were provided to the l

l l Nuctear Regulatory Commission via letter DP-537 from F.M. Stern to Frank Senroeder dated December 2,1974. This system was applied in determining that the subject document herein are 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 i

harm to the competitive position of Combustion Engineering because:

l w . ___

j'

_3 a.- A similar product is manufactured and sold by major pressurized

. water reactor competitors -of Combustion Engineering.

b. Development of this information by C-E required tens of thousands

-of manhours of effort and millions of dollars. To the best of my knowledge and belief'a competitor would have to undergo similar expense in generating equivalent information.

c. In order to acquire such information, a competitor would also require considerable time and inconvenience developing the design, manufacturing, installation and test procedures for steam generator tube welded sleeve repairs.

d. .The information required significant effort and expense to obtain the licensing approvals necessary for application of the information.

Avoidance of this expense would decrease a competitor's cost in applying the information and marketing the product to which the information is applicable.

e. The information consists of design, manufacturing, installation and testing of steam generator tube welded sleeve repairs, 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 or impair the position of Combustion Engineering's product, and avoid developing similar data and analyses in support of their processes, methods or apparatus.

f. 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

U without similar expenditure of resources may enable them to sell at prices reflecting significantly lower costs.

g. Use of the information by competitors in the international 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.

Further the deponent sayeth not.

A.E. Iebr Director Nuclear Licensing Sworn to before me this day of 1 6 b M unt<O( t bCLL 0 Notary Public ERIGID K. MARKS, fl0TARY FUBUC State of Connecticut t{o. 73487 Com mssion Empires March 31, 1990

.t l

ATTAQ99ff 1 TESTING:

Existing Regulatory Guidelines and Plant Technical Specifications do not currently address testing requirements of unique pressure boundary regions such as steam generator tube sleeves.

In accordance with the intent of these documents, Zion Station will conduct examinations using guidance from existing requirements for steam generator tubing inspections.

Technical Specification Basis 3.3.1 will be used for the Steam Generator Surve111ances and Technical Specification Basis 3.3.3.E will be 4 used for leakage. Technical Specification 4.3.1.B will be used for other portions of the testing including Steam Generator sample selection, tube sample inspections, frequency of inspections, inspection results and categories, and reports.

Steam generator sleeves will be considered a unique populations and as such will be augmented steam generator testing program. At least the minimum 3% inspection for steam generator tubing will also be performed for sleeving. Since the sleeve population will initially be relatively small, all rounding for sample size will be to the next higher whole number.

When the inspection plan for a particular outage is prepared, if only the minimum 3% in one steam generator sample size is planned, only sleeves in that steam generator will be inspected. Additional steam generators may or may not be opened solely for the purpose of inspecting sleeves.

1 4

REPOR N

As specified in the Technical Specifications, the Regulatory Agencies will be notified of the number of tubes plugged within 15 days of plugging. This letter will also include the number of tubes sleeved, t

Information concerning the details of the inspections including the inspections performed on the sleeves will be included in the Eddy Current

Special Report.

1776K e . .,_ . - - - - . _; , - - . , - ,.-.,__-_,-,___._.,,__,_,#___m,.. __.-_v.-em.,~.m.,__m_____.,v-,,-m,_ . , _ ,. _ , . ._ . . _,,_ _ . ,-~-- 4

r ATTACHIEDfT 2 AFFIDAVIT OF A.E. SCHERER IN ACCORDANCE WITH 10 CPR 2.790 1776K ,

l i

1 6