ML17298B188
| ML17298B188 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 08/15/1984 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Knighton G Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML17298B189 | List: |
| References | |
| ANPP-30240-EEVB, NUDOCS 8408170348 | |
| Download: ML17298B188 (14) | |
Text
V C.'EGULATORY INFORMATION DISTRIBUTION S TEM (RIDS)
I ACCESSION NBR 8 l08170348, DOO ~ DATE! 84/08/15 NOTARIZED YES FACIL:STN 50<<528 'Pa,lo Verde Nuclear Stations Uni't 1i Arizona Publi STN 50 529 Palo Verde Nuclear Stations Unit 2i Arizona Publi STN-50<<530 Palo Verde Nuclear Station~
Unit 3i Arizona Publi AUTH ~ NAME, 'UTHOR AFFILIATION VAN, BRUNTgE ~ E; Arizona Public,Service Co.
REC IP, NAME~
RECAP IEPJT AFFILIATION KNIGHTONiG~
Licensing. Branch "3>>
DOCKET 0
05000528 05000529 05000530 05000528 05000529 05000530
SUBJECT:
Forwards addi fabrication info on Unit 1,control element assembly shroud assembly<per 840627 request, Seventeen propr eitary oversize drawings encl'rawings
- withheld, (ref
10CFR2,790).Aperture card available" in Central Files",
DISTRIBUTION CODE:
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TITLE! Proprietary RevieW Distribution - Pre OL'OTES:Standardized plant ~
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Arizona Public Service Company ANPP-30240-EEVBJr/KLM August 15, 1984 Director of Nuclear Reactor Regulation Attention:
Mr. George Knighton, Chief Licensing Branch No.
3 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.. C.
20555
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2, and 3
Palo Verde CEA Shroud Assembly Designation.
Docket Nos.
STN 50-528/529/530 File:
84-056-026 G.l.01.10
Reference:
Letter from G.
W. Knighton, NRC, to E. E.
Van Brunt, Jr.,
APS, dated June 27, 1984;
Subject:
Request for Information Palo Verde CEA Shroud Assembly.
Dear Mr. Knighton:
- Enclosed, please find the additional fabrication information on the Palo Verde Unit 1
CEA Shroud Assembly you requested in the referenced letter.
The information provided in the attachment is considered by Combustion Engineering to be proprietary information as described in and covered by the enclosed affidavit; Please contact me if you have any questions on this matter.
Very truly yours, E&3~~k/~
,8408i70348 8408i5 PDR ADOCK 05000528
A PDR EEVBJr/KLM/mb Attachment APS Vice President Nuclear Production ANPP Project Director cc:
E. A. Licitra A. C. Gehr
A b ',y g
.I 4
I
t ANPP-30240 August 15, 1984 STATE OF ARIZONA
)
) ss
~
COUNTY OF MARICOPA)
Donald
- Karner, represent that I am Assistant Vice President, Nuclear Production of Arizona Public Service
- Company, that the foregoing document has been signed by me on behalf of Arizona Public Service Company with full authority to do so, that I have read such document and know its
- contents, and that to the best of my knowledge and belief, the statements made therein are true.
Donald Karner Sworn to before me thde~kdey of
, 1984.
\\
Ql My Commi'ssion Expires:
lay CommIssfon EqHros April6, TS87 Notary Pu lic
-'L P
1 I
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AFFIDAVIT PURSUANT TO 10 CFR 2.790 Combustion Engineering, Inc.
State of Connecticut County of Hartford I, P. L. NcGill, depose and say that I am the Vice President, Commercial, 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 provi sions of 10 CFR 2.790 of the Commission's regulations and in conjunction with the construction permit of Arizona Public Service Company for withholding this information.
The information for which proprietary treatment is sought is contained in the following documents:
Drawings:
E-14273-164-846 E-14273-164-849 STD-002-1583 STD-002-1580 STD-002-1581 STD-002-1582 STD-002-1579 STD-002-1577
, STD-lI02-1578 STD-002-.1576 STD-002-157 5 STD-002-1519 Rev.
Rev.
Rev.
Rev.
Rev.
Rev.
,Rev.
Rev.
Rev.
Rev.
Rev.
Rev.
07 05 02 2 shts 01 01 01 01 01 01, 01 01 00 STD-002-1518 STD-002-1508 STD-002-1517 907-1511 907-1512 907-1513 907-1509
," 907-1515
'07-1516 907-1510 STD-002-1514 STD-002-1528 Rev.
00 Rev.
00 Rev.
00 Rev.
00 Rev.
Ol Rev.
00 Rev.
01 Rev.
01 Rev.
01 Rev.
01 Rev.
00 Rev.
Ol DCR No. 9330905-88 Reactor Internals Cleaning Procedure PFAC-CP-001 DWPs:
I-35-8.8-18 VI-35-8.8-13 RP-35-2 I-25-8.8-7 I-35-8.8-19 Rev.
02 Rev.
00 Rev.
02 Rev.
03 Rev.
01 II-35-8.8-1 VII-25-8.8-5 VII-25-8.8-7 VII-25-8-8-7 RP-35-2 Rev.
00 Rev.
01 Rev.
01 (pg.
1 of 2)
Rev.
01 (pg.
2 of 2)
Rev.
02
I l.
These documents have 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 documents, should be withheld.
1.
The information sought to be withheld from public disclosure is design, construction, and manufacturing information for the Palo Verde Unit g1 Control Element Assembly
- Shroud, 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 a 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 iJI determining that the subject document herein are proprietary.
I( f 11 N
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 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 equi valent information.
c.
In order to acquire such information, a competitor would also require considerable time and inconvenience related to the design, construction, and manufacturing of the Control Element Assembly Shroud.
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 and manufacturing drawings and cleaning procedures for the Palo Verde Unit gl Control Element Assembly Shroud, the application of which provides a competitive economic advantage.
The availability of such information to competitors would enable them to modify
t 5
N S
I
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 thei r 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.
P. L. McGill Vice President Commercial Sworn to before me this %h.day
.'ot QyM i>>+
c o
N ary Publi'c I-XI-Nb HMTH<NOTARY>PUBLIq STATE OF CONNECTlCUT No. 68542 COMMfSSION EXPIRES MARCH 31, 1989
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