ML17251A359
| ML17251A359 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 11/18/1988 |
| From: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| To: | Stahle C NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML17251A360 | List: |
| References | |
| NUDOCS 8811290226 | |
| Download: ML17251A359 (8) | |
Text
AP.,CEJZRATZB DISI'RIBUTJON DEMONSTRATE 8 SYSTEM INTERNAL: AEOD/DOA NUDOCS-ABSTRACT
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NRC PDR REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR.8811290226 DOC.DATE: 88/11/18 NOTARIZED: YES DOCKET g',"[
FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit, 1, Rochester G
05000 44",,
AUTH.NAME AUTHOR AFFILIATION MECREDY,R.C.
Rocllester Gas 6 Electric Corp.
~C6 RECIP.NAME RECIPIENT AFFILIATION g P ~W PZ+
STAHLE,C.
Project Directorate I-1
SUBJECT:
Forwards proprietary Addendum 2-P to CEN-320-P, "Steam Generator Tube Repair Using Leak Tight Sleeves."
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SIZE: W+ /4 TITLE: Proprietary Review Distribution Operating Reactor NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72).
05000244
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~ll~erIl/lieu ROCHESTER GAS 8F,::::
AND ELECTRIC CORPORATION o 89 EAST AVENUE, ROCHESTER, N. Y. 14649-0001 November 18, 1988" <<<.'"~"'7QQ U.S. Nuclear Regulatory Commission Document Control Desk Attn:
Mr. Carl Stahle PWR Project Directorate No.
1 washington, D.C.
20555
Subject:
Installation of St:earn Generator Peripheral Sleeves R.E.
Ginna Nuclear Power Plant Docket No. 50-244
Dear Mr. Stahle:
By letter dated'ctober 12,
- 1988, RG&E provided a
response to NRC questions regarding our proposal to install steam generator peripheral sleeves during the 1989 refueling outage.
In the attached "Addenda 2-P t:o CEN-320-P",
RG&E is providing the formal document to be reviewed by the NRC to establish use of these peripheral sleeves.
Because of the proprietary nature of this information, an affidavit from A.E. Scherer of Combustion Engineering is attached.
This information should be withheld from public disclosure.
RG&E is planning, as part of this review effort, to incorporate steam generator repair limits into the Ginna Station Technical Specifications.
A proposed Amendment to.
this effect will be submitted. in conjunction with the NRC review of this issue.
Very truly yours, Robert.
C. Mecredy General Manager Nuclear Production Attachment zc:
U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Ginna Senio Resident Inspector 33ii290226 33iii3 PDR ADOCK 05000244 P.
AFFIDAVITPURSUANT 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 Rochester Gas and Electric Corporation for withholding this information.
The information for which proprietary treatment is sought is contained in the following document:
CEN 320-P, Addenda 2-P, "R. E. Ginna Unit 1 Steam Generator Tube Repair Using Leak Tight Sleeves" 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 concerns the analysis of the steam generator tube repair methodology of using leak tight sleeves for tubes in the peripheral area, which is owned and has been held in confidence by Combustion Engineering.
2.
The information consists of test data or other similar data concerning a
- process, method or component, the application of which results in substantial competitive advantage to Combustion Engineering.
3.
The information is of a type customarily held in confidence by 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 to determine when and whether to hold certain types of information in confidence.
The details of the aforementioned system were provided to the Nuclear Regulatory Commission via letter DP-537 from F. M. Stern to Frank Schroeder dated December 2, 1974.
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 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 harm to the competitive position of Combustion Engineering because:
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 man-hours of effort and millions of dollars.
To the best of my knowledge and belief a competitor would have to undergo similar expense in generating
'quivalent information.
c.
In order to acquire such information, a competitor would also require considerable time and inconvenience developing the methodology for steam generator tube repair using leak tight sleeves for tubes in the peripheral area.
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 an analysis of the methodology used to repair steam generator tubes using leak tight sleeves for tubes in the peripheral area, 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 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. ~cherer Director Nuclear Licensing Sworn to before me this 2lstday of
- October, 1988 Notary Public
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