JPN-94-055, Forwards Proprietary Vols 1,2 & 3 of Rev 0 to MPR-1560, Ja FitzPatrick Nuclear Plant Core Shroud Repair - Design Rept. Proprietary Rept Withheld (Ref 10CFR2.790)
| ML20076K775 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 10/27/1994 |
| From: | William Cahill POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19312B524 | List: |
| References | |
| JPN-94-055, JPN-94-55, NUDOCS 9411020107 | |
| Download: ML20076K775 (5) | |
Text
9
- o -
123 Man Street White PWns New York 10601 l
914 681 0200 A NewYorkPower 4# Authority October 27,1994 JPN-94-055 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, DC 20555
Subject:
James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 EitzP_atrick_ Core _ShroudJ1epair-DesistLBeport
References:
1.
" James A. FitzPatrick Nuclear Plant Core Shroud Repair -Design Report,"
Three Volumes, ptepared by MPR Associates, Inc., MPR-1560, Rev. O, dated October 1994.
2.
NYPA letter, W. J. Cahill, Jr. to NRC (JPN-94-053), " Request for NRC Approval of the FitzPatrick Core Shroud Repair," dated October 21,1994.
s
Dear Sir:
This letter transmits the detailed engineering evaluations (Reference 1) that support the core shroud preemptive repair described in a previous submittal to the NRC (Reference 2). The preemptive repair will be installed in the James A. FitzPatrick Nuclear Plant during the refueling outage starting on November 29,1994. The Reference 2 letter requested NRC approval, pursuant to 10 CFR 50.55a(a)(3), of the core shroud preemptive repair.
The enclosed document (Reference 1) is considered proprietary by MPR Associates inc.
In accordance with the provisions of 10 CFR 2.790(a)4 and 10 CFR 2.790(b), the required information and affidavit are enclosed.
The Authority requests that the NRC review of the repair be expedited to support its installation during the FitzPatrick refueling outage starting on November 29,1994. The Authority is prepared to meet on short notice with the NRC staff, or expeditiously provide additional information, if needed.
k i,
s y r Q J j
e _ m.
9411020107 941027 PDR ADOCK 05000333 J
P PDR
l I
If you have any questions, please contact J. A. Gray, Jr.
Very truly yours, M
William J. Cahill, Jr.
Executive Vice President and Chief Nuclear Officer Nuclear Generation
Attachment:
as stated cc:
Regional Administrator U.S Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. John E. Menning Project Directorate 1-1 Division of Reactor Projects - 1/11 U.S. Nuclear Regulatory Commission Mail Stop 14 B2 Washington, DC 20555 Office of the Resident inspector U.S. Nuclear Regulatory Commission P.O. Box 136 Lycoming. NY 13093
MMPR A S S O C I A T E S IN C.
October 25,1994 E N G f N E E R 5-AFFIDAVIT PURSUANT TO 10 CFR 2.790 RELATIVE TO CORE SIIROUD REPAIR FOR FITZPATRICK MPR Associates, Inc.
The Commonwealth of Virginia City of Alexandria I, Noman M. Cole, depose and say that I am a Principal of MPR Associates, 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 in conjunction with New York Power Authority.
The information for which proprietary treatment is sought is contained in the attached report, MPR-1560, " James.A. FitzPatrick Nuclear Power Plant Core Shroud Repair -
Design Report," dated October 1994. This report contains information detailed on the design of the shroud repair system for the James A. FitzPatrick Nuclear Power Plant.
This document has been appropriately designated as proprietary.
I have personal knowledge of the criteria and procedures utilized by MPR Associates 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, which is owned and has been held in confidence by MPR Associations,is the design of the shroud repair system for the James A. FitzPatrick Nuclear Power Plant.
2.
The information consists of design information or other similar data concerning a repair system, method or component, the application of which results in substantial competitive advantage to MPR Associates. MPR has a patent application pending for this shroud repair system.
3.
The information is of a type customarily held in confidence by MPR Associates and not customarily disclosed to the public. MPR Associates 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. 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 j
sources, and any disclosure to third parties has been made pursuant to regulatory i
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 MPR Associates because:
a.
Other repairs for similar purposes are performed and sold by major light water reactor competitors of MPR Associates.
b.
Development of these repair designs by MPR Associates required thousands of manhours and hundreds of thousands 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 to develop these repair designs.
d.
The information consists ofinformation related to repair of cracked shrouds in the James A. FitzPatrick Nuclear Power Plant and other BWRs as well. The application of which provides a competitive economic advantage. The availabHity of such information to competitors would enable them to modify their designs to better compete with MPR Associates, take marketing or other actions to improve their position or impair the position of MPR Associates
- design, and avoid developing similar data and analyses in support of their design methods or shroud repair system.
e.
In pricing MPR Associates products and services, significant research, development, engineering, analytical, manufacturing, quality assurance and other costs and expenses must be included. The ability of MPR Associates' 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 international marketplace would increase their ability to market such repair designs by reducing the costs associated with their technology development. In addition, disclosure would have an adverse economic impact on MPR Associates' potential for obtaining or maintaining foreign licensees.
Further the deponent sayeth not.
Nofnan M. Cole A Principal Sworn to before me this A@ day of Othbu -
.1994 dubs O CSlnfmSado
~
Notary Public My commission expires: TGcu ch St; \\9%
i i
1