ML19322E411
| ML19322E411 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 03/19/1980 |
| From: | Trimble D ARKANSAS POWER & LIGHT CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8003270484 | |
| Download: ML19322E411 (8) | |
Text
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ARKANSAS POWER & LIGHT COMPANY POST CrFICE BOX 551 UTTLE ROCK, ARKANSAS 72203 (501) 371-4000 March 19, 1980 1-030-10 Director of Nuclear Reactor Regulation ATTN: Mr. Darrell G. Eisenhut, Acting Director Operating Reactors U. S. Nuclear Regulatory Conmission Washington, D. C.
20555
Subject:
Arkansas Nuclear One - Unit 1 Docket No. 50-313 License No. DPR-51 Westinghouse Low Pressure Turbine Rotor Information (File: 0285, 1510.1)
Gentlemen:
Your letter of February 25, 1980, requested information concerning our Low Pressure (LP) Turbine Rotors.
Attached are our responses to the site specific questions.
We were informed on March 18 by your Mr. Guy Vissing that an extention had been granted until March 24 for the gen-eric questions. We will respond to those questions by the due date.
Much of the data presented in our responses is Westinghouse proprietary information. Westinghouse has, therefore, requested that the affected information be withheld from public disclosure. is an Application for Withholding Proprietary Information From Public Disclo-sure from Westinghouse. is an Affidavit which sets forth the basis for withholding the information. provides our response to the site specific questiens. Appen-dix A contains the proprietary information while Appendix B is a copy of the same information minus that which is proprietary.
Tables 2 and 3 also contain proprietary infonnation and should be withheld from public disclosure.
We would like to emphasize that the cracks found in the LP-2 rotor at ANO-1 were not keyway cracks.
There is no evidence that the ciacks which were found increased the probability for incurring unacceptable damage from a turbine missile.
Due to reliability concerns, the affec-p-
ted discs were, however, removed from the rotor.
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Very truly yours, C9b9t. k Ag D. C. Trimble
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Manager, Lic sing c,gA M.'c g PDf I %
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AW-80-14 TTACHMENT 1 March 14 1980 9
Darrell G. Eisenhut Division of Operating Reactors Office of Nuclear Reactor Regulation US Nuclear Regulatory Comission Washington DC 20555 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
Arkansas Nuclear Unit #1 Docket #50-313 Inf ormation in Response to NRC Request f or Inf ormation of February 25, 1980, Relative to Low Pressure Turbine Dise In tegrity.
Reference:
Appendix A letter from D. Trimble to Sisenhut, dated 3/19/80
Dear Mr. Eisenhut:
This application for withholding is submitted by Westinghouse Electric Corporation ("We stinghouse") pursuant to the provisions of paragraph (b)(1) of Section 2.790 of the Comission's regulations. Withholding from public disclosure is requested with respect to the subj ect inf ormation which is further identified in the affidavit accompanying this application.
The undersigned has reviewed the inf ormation sought to be withheld and is authorized to apply for its withholding on behalf of Westinghouse, STG-TOD.
The affidavit accompanying this application se es forth the basis on which the information may be withheld from public disclosure by the Comission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.790 of the Comission's regulations.
Accordingly, it is respectfully requested that the subj ect information which is proprietary to Westinghouse and which is further identified in the affi-davit be withheld from public disclosure in accordance with 10CFR Section 2.790 of the Commission's regulations.
Correspondence with respect to this application for withholding or the accom-panying affidavit should be addressed to the undersigned.
.Very truly ycurs, h'Y.
a R. Williamson, Manager Customer Order Engineering Westinghouse Electric Corporation
ATTACHMENT 2 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF DELAWARL Before me, the undersigned authority, personally appeared Robert Williamson, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Corporation (" Westinghouse") and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:
b bo Robert Williamson, Manager Customer Order Engineering swern a a M vt sitd fare me ws..).s.... car 26#.4D19 E-W 41x.A, e
HENRY E. SQUILLACE N:wy Mi:. Ma sie Tr.p., De!aas e Co.
vy r.eesssien b: ires Oct. 18. 1980
O (1) I am Manager, Custcmer Order Engineering in the Steam Turbine Generator Technical Operations Division of Westinghouse Electric Corporation and as such, I have been specifically delegated the function of reviewing the proprietary informatien 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 Divisions.
(2)
I am making this Affidavit in conformance with the provisions of 10 CFR Section 2 790 cf the Commission's regulations and in conjunction 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 ccccercial or financial information.
(4)
Pursuant to the provisions of paragraph (b)(4) of Section 2.790 of the Commissien's regulations, the following is furnished for con-sideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.
(i)
The information sought to be withheld fr:1 public disclosure is owned and has been held in confidence by Westinghouse.
(ii)
The information is of a type customarily held in ecnfidence by Westinghouse and not customarily disclosed to the pub-lic.
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 confi-dence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational' basis required.
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e Under that system, information is hel:1 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 com-petitive advantage, as follows:
(a)
The information reveals the distinguishing aspects of a process (or component, structure, teol, 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 pro:ess (or component, structure, toc 1, cethed, etc.), tht application of which data secures a competitive economic advantage, e.g.,
by optimization er improved marketability.
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(c)
Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a slailar product.
(d)
It reveals cost or price information, production capac-ities, budget levels, er commercial strategies of West-inghcuse, its customers er suppliers.
(e)
It reveals aspects of pa't. present, or future Westing-s 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 accceding to agreements with tne owner.
)
(h)
Public disclosure of this information would allow un-fair and untruthful judg=ents on the perfor:ance and reliability of Westinghouse equipment eccponents and improper comparison with similar cc=ponents 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 West-inghcuse a co=petitive advantage over its competitors.
It is, therefore, withheld from disclosure to protect the Westinghouse cocpetitive positien.
(b)
It is information which is marketable in many ways.
The extent to which such information is available to competitors diminishes the Westinghcuse ability to sell products and services involving the use of the information.
(c)
Use by our competitor would put Westinghouse at a ecm-petitive disadvantage by reducing his expenditure of resources at our expense.
(d)
Each component of proprietary infor:atien pertinent to a particular competitive advantage is pctentially as valuable as the total competitive advantage. If com-petitors acquire compone'nts of proprietary information, any one component may be the key to the entire pu::le, thereby depriving Westinghouse of a ec=petitive advantage.
(e)
Unrestricted disclosure would jeepardize the position cf preminence of Westinghouse in the world market, and thereby give a carket advantage to the cc petition in those countries.
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( f)
The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a ccmpetitive advantage.
('iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Sec-tion 2.790, it is to be received in confidence by the Cecmission.
(iv)
The information is not available in public scurces to the best cf our knowledge and belief.
(v)
The proprietary information scught to be withheld in this submittal is that which is appropriately marked in Appen-dix A to letter from D. Trimble to Eisenhut, dated March 19, 1980 concerning' in fer-mation in response to NRC request for information of February 25, 1980, relative to low pressure turbine disc integrity.
The information enables Westinghouse to:
(a)
Develcp test inputs and procedures to satisfactorily verify the design of Westinghouse supplied equipment.
(b)
Assist its customers to obtain licenses.
Further, the information has substantial commercial value as follows.
(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 gaineo and the test equipment and methods developed.
Public disclosure of this information is likely to cause substantial harm to the ccmpetitive position of Westinghouse because it would enhance the ability of competitors to design, manufacture, verify, and sell electrical equipment for co=mercial 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 information.
The development 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 mency.
This could only be duplicated by a ecmpetitor 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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