ML17095A387

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Submits Response to 800827 Request Re Questions 1 & 2 Concerning Turbine Disc.Response to 3 & 4 Will Be Made Separately.Affidavit & Proprietary & Nonproprietary Versions of Low Power Turbine Disc Info Encl
ML17095A387
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 10/09/1980
From: Crane P
PACIFIC GAS & ELECTRIC CO.
To: Schwencer A
Office of Nuclear Reactor Regulation
Shared Package
ML16341B428 List:
References
NUDOCS 8010140310
Download: ML17095A387 (28)


Text

9 RE'GULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:8010140310 DOC,DATES 80/10/09 NOTARIZED: YES DOCKET FACIL:50-275 Diablo Canyon Nuclear Power Planti Unit 1i Pacific Ga 05000275 50 323 Diablo Canyon Nuclear Power Planti Unit 2g Pacific Ga 05000323 AUTH INANE AUTHOR AFFIL'IATION CRANEEP ~ AD Pacific Gas 8, Electric Co.

REC IP ~ NAME RECIPIENT AFFILIATION SCHilENCERPA. L.icensing Branch 3

SUBJECT:

Submits response to 800827 request re Questions 1 L 2 concerning turbine disc. Response to 3 L 0 will be made separately'ffidavit 8 proprietary 8 nopproprietary versions of "Low Power Turbine Disc Info" encl, Sam DISTRIBUTION CODE: PB01S COPIES RECEIVED;LTR TITLE: Proprietary Info Re PSAR/FSAR j

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PA.C I P IC GA.S AND ELECTRIC C 0M'.NY

~~~LE MALCOLM H. FUR BUSH

~ 77 BEALE STREET, 31ST FLOOR ~ SAN FRANCISCO, CALIFORNIA 94106 OILSEST L HA1IIISK OLENN WE ~ T, Ja

~ (415) 781.4211 COWASD 4 HOOAHNCY OAN OSAYSDN LU ~ SDDK YICC PRESIDENT AND OENESAL COUNSEL October 9, 1980 JOSE ~ 'H I KELLY HONASD V OOLV ~

JANET O I.OD ~ DON JACK IALLIN SEANASD 4, OELLASANTA JO ~ HUA SAS LCV RO ~ CST L SOSDON JO ~ EVH S CNOLE1T Ja ROBERT OHLBACH PETESW HAN ~ SHEN TNEOOO1C I. ~ LINOSE1D Ja RO ~ EST L HASSI ~

RIONASD I', LOCKE ACCOCIATE DEN CRAL COUNCCL DOVOLA~ A OSLE ~ SY DAVID L LUDVIO~ ON

~ EHIOS COUN ~ EL CHAR I SS T. VAN DEUS EN OAVIOW ANDE ~ SON DIANA SESONAUSEH J, Pttta SAUNOA1TNE1 STEVCN P, SNAKC PHILIP A, CRANE JR. ~ LEIOH S OASSIDY PANtLA CNAAAELLC HCATHES ~ OISSNA AUDatV OAINta HENRY J. LaPLANTE SSIAN S, DENTOH HIOHAEL O OESNASAI ~

WILLIANH CDWASDS OASY P CNSINAS JOHN S. SISSON DONALD D CSISESON JOHN H raVC

~ ATSICK 0 SOLDER DAVIDO ~ OIL ~ E1T ARTHVR L HILLMAN.JR

~ ~ JUAH H JAYO r, RONALD LAVSHEINt1 KtaNIT R KU ~ ITE HESEK C, LI ~ SON CHARLES W. THISS EL L HA11YW LONO 41 JONN R LOW

~ AULAV, HAIN~ A. Klat HCKtNEIE OANISL S OISSON RO ~ EST S HSLENNAN RICHA10 L HEI ~ 1 RISNASD H, HOS ~ ROSES 4 PETES ~

AIEIITANTCENCKAL CDUNEEL 4 MISNA~ L REIDENSACH ROSE!T R RIDKCTT IVO1 C SAN ~ ON SHISLEY* SANDt1 ~ ON S U ~ AN H LCVI1 ~ D Hl I r JO ANN SHAT TEN Mr. A. Schwencer, Acting Chief JADKW ~ NUDE DAVIDJ,WILLIANSOH S1VDE R WOIITHINOTON LONI~ C VINDENT SNI1LCVA WOO KtNHCTH SANO Licensing Branch No. 3 DANCES Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Re: Docket No. 50-275 Docket No. 50-323 Diablo Canyon Units 1 & 2

Dear Mr. Schwencer:

In a letter dated August 27, 1980 you requested information regarding Diablo Canyon Units 1 and 2. Questions 1 thxu 4 addressed the turbines. The following is our response to those items:

Res onse 1A Diablo Canyon utilizes four casing (one HP and three LPs),

tandem compound, sextuple flow, 1800 RPM condensing turbines manu-factured hy Westinghouse Electric Corporation.

Res onse 1B Plant, Specific LP turbine disc information has been provided by Westinghouse and is submitted as an enclosure. The enclosure is ting Westinghouse Proprietary LP Turbine Disc Information.

Res onse 2 A UT examination of the Unit 2 disc keyways was conducted during December 1979 by Westinghouse while the LP rotors were removed for pre-operational modifications. The results are summarized in the Unit 2 portion of Enclosure l. Inspection of the Unit 1 rotor will he accomplished in accordance with the Westinghouse schedule for units o'i which have not, yet seen operation.

Res onse 3 and 4 i"+ 0 1

The response to questions 3 and 4 will 'be made under sepa-rate cover.

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Mr. A. Schwencer October 9, 1980 Enclosed with the Westinghouse Turbine Discs Proprietary Information is an application for Withholding Proprietary Informa-tion From Public Disclosure and supporting letters from Westinghouse.

Also enclosed are 40 copies of Westinghouse Non-Proprietary LP Turbine Disc Information.

Five copies each of the Proprietary and Non-Proprietary Information have been sent to Mr. Bart Buckley today by courier.

Kindly acknowledge receipt of the above material on the enclosed copy of this letter and return addressed envelope.

it to me in the enclosed Very truly yours, Enclosures 40 copies Proprietary Information 40 copies Non-Proprietary Information CC w/Non-Proprietary Information: Service List

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Ref: AW-80-29 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF DELAWARE:

Before me, the undersigned authority, personally appeared R. W. Gaul, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Elec-tric Corporation (nWestinghouse") and that the averments of fact set forth in this Affidavit are true and correct to the best of his know-ledge, information, and belief:

R. W. Gaul, Manager Low Pressure Disc Task Force Subscribed and attested before me on the 3rd day of October, 1980.

ROSEMAR(E T. SAFKA, kOTAITY PUBLIC TINICUM TRIP., DEL'AWARE COUNTY MY COMMISSION EXPIRES )ULY III, 1883 hremher, Pennsylvania Assaciafion of kafaries

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steam Turbine Division Westinghouse Power Generation ElecTric Corporation Group tester Branch Box 9175 Philadelphia Pennsylvanla19113 AW-80-29 October 3, 1980 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation Attn: A. Schwencer, Acting Chief Licensing Branch 83 Division of Licensing Office of Nuclear Reactor Regulation US NRC Washington, D.C. 20555 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

SUBJECT:

Pacific Gas 8 Electric Co.

Diablo Canyon 1 Docket $ 50-275 Diablo Canyon 2 Docket 850-323 Turbine Disc Material Properties

Dear Mr. Schwencer:

This application for withholding is submitted by Westinghouse Electric Corporation ("Westinghouse" ) pusuant to the provisions of paragraph (b)

(1) of Section 2.790 of the Commission's regulations. Withholding from public disclosure is requested with respect to the subject information which is further identified in the affidavit accompanying this appli-cation.

The under signed has reviewed the information sought to be withheld and is authorized to apply for its withholding on behalf of Westinghouse, STG.

The affidavit accompanying this application 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; Correspondence with respect to this application for withholding or the accompanying affidavit should be addressed to the undersigned.

R. W. Gaul Low Pressure Disc Task Force 4C0401a

Ref: AW-80-29 (1) I am Manager, in the Steam Turbine Generator Division of Westing-house Electric Corporation and as such, I have been specifically delegated the function of reviewing the proprietary information sought,to be withheld from public disclosure in connection with nuclear power plant licensing, and am authorized to apply for its withholding on behalf of the Westinghouse Power Generation Divi-sions.

(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.790 of the Commission's regulations and in conjunc-tion with the Westinghouse. application for withholding accompanying this Affidavit.

(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse Power Generation Divisions in designating informa-tion as a trade secret, privileged or as confidential commercial or fi nanc i al i nf ormati on.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.790 of the Commission s regulations, the following is furnished for con-.

.sideration by the Commission in determi ning whether the information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.

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The information is of by Westinghouse and a

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type customarily held in confidence 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 sub-stance of that system constitutes Westinghouse policy and provides the rational basis required.

Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential compet-itive 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 competitive economic advantage, e.g., by optimization, or improved marketability.

(c Its use by a competitor would reduce his expenditure or 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 capac-ities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westing-house or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protec-tion 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.

(h) Public disclosure of this information would allow unfair and untruthful judgments on the performance and reliability of Westinghouse equipment components and improper comparison with similar components made by competitors.

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 competi-tors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

(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 infor-mation.

(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 com-petitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advan-tage.

1 (9 Unrestricted disclosure wou1opardize 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 maintaining a competitive advantage.

(iii) The information is being transmitted to the Commission in confidence and, u~der the provisions of 10 CFR Section 2.790, it is to be received in confidence by the Commission.

(iv) The information is not available in public sources 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 as Enclosure 1 to letter from Phillip A. Crane to Schwencer, dated October 8, 1980 concerning information in response to NRC request for information relative to low pressure turbine disc integrity.

The information enables Westinghouse to:

(a) Develop test inputs and procedures to satisfactorily verify the design of Westinghouse supplied equipment.

(b Assist its customers to obtain icenses.

Further, the information has substantial commercial value as foll ows:

(a) Westinghouse can sell the use of this information to customers.

(b) Westinghouse uses the information to verify the design of equipment which is sold to customers.

(c) Westinghouse can sell services based upon the exper-ience gained and the test equipment and methods devel-oped.

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 design, manufacture, verify, and sell electrical equipment for commercial turbine-generators without commensurate expenses. Also, public disclosure of the information would enable others having the same or similar equipment to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the infor-mation.

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of the equipment described in part by the information is the result of many years of development by Westinghouse and the expenditure of a considerable sum of money.

This could only be duplicated by a competitor if he were to invest similar sums of money and provided he had the appro-priate talent available and could somehow obtain the requi-site experience Further the deponent sayeth not.

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Wp UNITED STATES NUCLEAR REGULATORY COMMlSSlON WASHINGTON, D. C. 20555 se MEMORANDUM FOR: TERA CORPORATION FROM: US NRC/TIDC/DOClSKNT MANAGEiiENT BRANCH

SUBJECT:

Special Document Handling Requirements Cjt.. Please use the following special distribution list for the attached document.

2. The attached document requires the following special considerations:

2 Do not send. oversize enclosures to the NRC PDR.

CI Only one oversize enclosure was received please return for Regulatory File storage.

Proprietary information send only non-proprietary portions to the NRC PDR.

CI Other: (specify) cc: DMB Files TIDC DMB Authors.z xgnature

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