ML17342A424

Requests Withholding of Encl Rev 1 to 83-185, Evaluation of Toughness of Irradiated Welds at 200 C & 288 C for Turkey Point Unit 4 Beltline Weld, Per 10CFR2.790.Affidavit Encl

ML17342A424
Person / Time
Site:	Turkey Point
Issue date:	10/02/1984
From:	Cotter K FRACTURE PROOF DESIGN CORP.
To:	Office of Nuclear Reactor Regulation
Shared Package
ML17342A423	List: ML17342A422 ML17342A424
References
NUDOCS 8603310208
Download: ML17342A424 (5)

Text

fracture proof design corporation Octobor 2, 1984 Diroctor of Nuclear Reactor Rogulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Subjoot: Application for Withholding From Public Disclosuxo Gentlemen:

We are transmitting herewith, five (5) copies of a report entitlod "Evaluation of tho Toughness of Irradiatod Voids at 200C and 288C for the Turkey Point Unit 4 Beltllno Weld" (PROPRIETARY),

FPDC Roport 83-185, Rev. 1, September 9, 1984. Pursuant to 10CFR 2.790, as amendod, of the Rulos and Regulations of tho Commission, we hereby roquest that the information oontained in tho roport be withhold from publio disclosure for the following reasons.

i. The methodology usod to perform tho analysis in the subject report <<as developed solely at tho oxpense of Fracture Proof Design Corporation (FPDC) .

2. Tho methods of analysis used are propriotary to FPDC and have not boon disclosed to the public or Florida Powor and Light Company except for those persons who have compliod with Paragraph 4 below.

3. The development of cortain of the methods of analysis involving the tochniques used in this report aro not published elsewhero in the literaturo.

4. Any person who has aooess to this information, including employees of FPDC, has'signed agroements of non-disclosure and confidontial treatment of said proprietary information.

5. FPDC is presontly in a voxy strong compotitivo position bocause of its exclusive knowledge of those methods of analysis and disclosure of information in the subject report would irreparably damago the competitivo position of FPDC.

6. Florida Power and Light Company has not paid fees equivalent to the cost of development of the technology used in preparation of the subject report. The total fees received for the analysis represent loss than ten pexcont of the value, to FPDC, of the methodology.

7. One (1) copy of the report has been given to a Florida Power and 'Light Company employee who has complied with Paragraph 4 above.

860SSla208 05000250 ah0325'DR ADOCK P PDR 77 MARYLANDPLAZA ~ ST. LOUS, MISSOURI 63108 ~ 3144614200 ~ TELEX: 469259

Director of Nuclear Reactor Regulation October 2, 1984 Page 2 regarding this matter to Keyren 4

Please address any questions H..Cotter, President, FPDC at the above address.

Sincerely, FRACTURB PROOF DBSIGN CORPORATION Keyren H. Cotter, President KHC:plo Bnclosures

fracture proof design corporation STATE OF MISSOURI )

)

CITY OF ST. LOUIS )

gg>IDAVIT Koyren H. Cotter, boing duly sworn, deposos and says tho following:

1. Fraoture Proof Design Corporation ('FPDC") is a duly organixod and existing oorporation under tho laws of tho State of Missouri.

2. Ho is tho president of FPDC, and ho has exooutod this Application for Withholding From Publio Disolosure and this Affidavit with the approval and authority of FPDC.

3. A oortain roport entitled "Evaluation of tho Toughness of Irradiated Wolds at 200C and 288C for the Turkoy Point Unit 4 Beltlino Weld" (PROPRIETARY), FPDC Report 185, Rev. 1, Soptembor 9, 1984, submitted, together with this Affidavit and Application for Withholding From Public Disolosuro, is the sole and exclusive property of FPDC.

4. Tho methodology .usod to perform tho analysis in the subject report was doveloped solely at the expense of FPDC; S. The methods of analysis used are proprietary to FPDC and have not been disolosed to tho public, or to the Florida Power

- and Light Company except as provided in Paragraph 7 below.

6. The development of cortain of the methods of analysis involving tho techniques usod in this report are not published olsewhore in the literature.

7. Any porson who has aocoss to this information, including employees of FPDC, have signed agreements of non-disclosure and confidential treatment of said proprietary information.

8. FPDC is presently in a very strong competitive position because of its exolusive knowledge of these methods of analysis and disclosure of information in the subjeot report would irreparably damage tho competitive position of FPDC.

9. Florida Power and Light Company has not paid foes equivalent to the cost of development of toohnology usod in preparation of the subject report. Tho total foos reoeived for the analysis ropresont loss than ten percent of the value, to FPDC, of the methodology.

77 MARYLANDPLAZA ~ ST. LOUIS, MISSOURI 63106 ~ 3144614200 ~ TELEX: 469269

10. One (1) copy of the report has been given to a Florida Power and Light Company's employee who has complied <<ith the provisions of Paragraph 7 above.

hffiant further states that the foregoing statements are true and accurate to the best of his knorledge and belief, and he hereby acknowledges that he has executed this Affidavit as his own free act and deed.

Keyren H. Cotter Subscribed and sworn to before me this 2nd day of October, 1984.

Notary Public My Commission Respires: BETTIE HARRIS NOTARY PUBLIC, STATE OF MISSOURI MY COMMISSION EXPIRES SII.7IGS

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