ML19262C364

Forwards Jp Novarro 800206 Affidavit Supporting Util 800117 Request That Weld Procedure & Qualification Records Be Withheld (Ref 10CFR2.790)

ML19262C364
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	02/06/1980
From:	Novarro J LONG ISLAND LIGHTING CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
SNRC-461, NUDOCS 8002110377
Download: ML19262C364 (3)

Text

. .

LONG ISLAND LIGHTING COM PANY

/Ld'O g.way,mg SHOREHAM NUCLEAR POWER STATION P.O. BOX 618, NORTH COUNTRY RO AD

• WADING RIVER, N.Y.11792 SNRC-461 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Shoreham Nuclear Power Station - Unit 1 Docket No. 50-322 Deal Mr. Denton:

During the course of a site meeting with the NRC on January 17, 1980, LILCO provided a copy of certain weld procedures and weld procedure qualification records to a member of your Staff. That information was associated with the fabrication of selectad portions of the primary containment equipment and personnel hatches, the containment dome, and the main steam line penetrations at Shoreham.

At that time we (1) requested the Staff withhold the information from public disclosure because it contained confidential commercial information and trade secrets, and (2) stated that an affidavit in support of that request would be forwarded under separate cover.

The enclosed Affidavit of Joseph P. Novarro, prepared in accordance with 10CFR @ 2.790(b), fulfills that commitment.

Very truly yours, 0 0 Q, L) <

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. P. Nov- ro, 1946 152

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Enclosure j cc: J. Higgins (NRC)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

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LONG ISLANC LIGHTING COMPANY )

                                      )          Docket No. 50-322 (Shoreham Nuclear Power Station,    )

Unit 1) ) AFFIDAVIT OF JOSEPH P. NOVARRO JOSEPH P. NOVARRO, being duly sworn, states as follows:

1. I am Project Manager of the Shoreham Nuclear Power Station, Unit 1, of Long Island Lighting Company (LILCO).

2. I have the responsibility to review and protect the confidential commercial information contained in the fabrication and construction records associated with the Shoreham Nuclear Power Plant.

3. The NRC has requested and received detailed welding procedures and weld procedure qualification records pertaining to our construction effort. This information was provided with the under-standing that it is considered proprietary. The information contains trade secrets and confidential commercial information for the following reasons:

a. The weld procedures and weld procedure qualifications were developed at considerable expense to our vendors. The services that are provided by these vendors are competitive and firms that engage in steel fabrication for nuclear plants compete on the basis of the integrity of their efforts.

1946 153

b. The weld procedures and their qualification records are of substantial value to the vendors who contributed to the Shoreham effort. If a competitor obtained the records, the amount of resources that it would have to expend to develop a similar product would be greatly reduced. Thus, obtaining a copy of the information would improve the recipients competitive positien. Furthermore, a competitor would derive an unfair advantage in knowing the precise nature of the fabrication techniques employed by our vendors.

c. LILCO has received the information under contract with an understanding that LILCO has used the information on a need-to-know basis, with its employees, its consultants, and the NRC in connection with the construction and licensing of Shoreham.

d. The weld procedure and weld qualification information developed by our vendors is of the type usually held secret and confi-dential. LILCO has maintained that information secret and confidential.

4. To the best of my knowledge and belief, the weld procedures and qualifications are not available from any other source and has not been made available to third parties, except in confidence.

For the above reasons, the information provided is believed to contain trade secrets and confidential commercial information, and therefore should be withheld from public disclosure. s N

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                                               ,&2 V l             CW~WVbc j  Joseph P. Novarro Subscribed and Sworn To Before Me 1946 154 This 6th Day of February 1980
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