ML19331C200
| ML19331C200 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 08/06/1980 |
| From: | Clayton F ALABAMA POWER CO. |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19268C992 | List: |
| References | |
| NUDOCS 8008140316 | |
| Download: ML19331C200 (10) | |
Text
Alabama Power Company 600 North 18th Street Post office Box 2641 Birmingham. Alabama 35291 Telepnone 205 250-1000 F. L CLAYTON, JR.
Senior Vice Presscent ggh3gg g the soutem electrc syvem August 6, 1980 Docket No. 50-364 Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Attention:
Mr. A. Schwencer JOSEPH M. FARLEY NUCLEAR PLANT-UNIT 2 INFORMATION CN LOW PRESSURE TURBINE DISC PROPERTIES Gentlemen:
This letter is in response to your recent telephone request for information concerning the potential of turbine-disc cracking in near term operating licensee's with Westinghouse turbines.
In response to site specific questions in your inquiry, Alabama Power Company submits the enclosed.
The enclosure contains proprietary information of the Westinghouse Electric Corporation.
In conformance with the requirements of 10CFR2.790, as amended, of the Commission's regulations, an application for tithholding from public disclosure and an affidavit are enclosed.
The affi-davit sets forth the basis on which the information may be with-held from public disclosure by the Commission.
Correspondence with respect to the affidavit or application for withholding should reference AW-80-25 and should be addressed to Mr.
R. A.
Gaul, Manager, Low Pressure Turbine Disc Task Force, Westinghouse Electric Corporation, Steam Turbine Divisions, Lester Branch, Box 9175, Philadelphia, Pennsylvania.
Respectfully,
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F. L.
Clayton, Jr.
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=mxwm,.awsn3 AW-80-25 August 1, 1980 A. Schwencer Reactor Regulations-US NRC Washington, D.C.
20555 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
SUBJECT:
Alabama Power - Farley f2 Docket f50-364 Turbine Disc Material Properties
Dear Mr. Schwencer:
This application for withholding is submitted by Westinghouse Electric Corporation (" Westinghouse") pusuant to the provisions of paragraph (b)(1) of Section 2.790 of the Consnission's regulations. Withholding from public disclosure is requested with respect to the subject infomation which is further identified in the affidavit accompanying this application.
The undersigned has reviewed the infomation sought to be withheld and is authorized to apply for its withholding on behalf of Westinghouse, STG.
l The affidavit accompanying this application sets forth the basis on which the infomation may be withheld from public disclosure by the l
Commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.790 of the Conunission's regulations.
t Accordingly, it is respectfully requested that the subject infomation which is further identified in the affidavit be withheld from public disclosure in accordance with 10CFR Section 2.790 of the Consnission's regulations.
Correspondence with respect to this application for withholding or the accoinpanying affidavit should be addressed to the undersigned.
l Very truly yours, l
3R. W.-Gaul, Manager l
Low Pressure Disc Task Force
R:f: AW-80-25 AFFIDAVIT C0lWONWEi.LTH OF PENNSYLVANIA COUNTY OF DELAWARE:
Before me, the undersigned authority, personally appeared R. W. Gaul, 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, infonnation, and belief:
R. W. Gaul, Manager Low Pressure Disc Task Force Subscribed and attested before me on the 1st day of August,1980 kowk$
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(1) I as Manager, in the Steam Turbine Generator Division of Westinghouse Electric Corporation and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing, and an authorized to apply for its withholding on behalf of the Westinghouse Power Generation Divisions.
(2) I am makir.g this Affidavit in conformance with the provisions of 10 CFR Section 2.790 of 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 information as a trade secret, privileged or as confidential commercial or financial information.
(4) 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 infonnation sought to be withhe'd from public disclosure should be withheld.
(i)
The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.
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(ii)
The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has e estional 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 infonnation in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.
Under that system, information is held 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 competitive advantage, as follows:
(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.)
where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a canpetitive economic advantage over other companies.
(b)
It consists of supporting data, including test data, relative to a process (or compenent, structure, tool, method, etc.), the application of which data secures competitive economic advantage, e.g., by optimization or improved marketability.
(c)
Its use by a competitor would reduce his expenditure or resources or improve his competitive position in the design, manufacture, shipment, inst-11ation, assurance of quality, or licensing a similar product.
(d)
It reveals cost or price information, production capacities, budget leve'.3, or commercial strategies of Westinghouse, its customers or suppliers.
(e)
It reveals aspects of past, present, or future Westinghouse or customer funded. development plans and programs of potential commercial valu'e to Westinghouse.
(f)
It contains patentable ideas, for which patent protection may be desirable.
(g)
It is not the property of Westinghouse, but must be treated as proprietary by Westinghouse according to agreements with the owner.
(h) Public disclosure of this information would allow unfair and untruthful judgments on the performance and reliability of Westinghouse equipment components and improper comparison with similar components made by l
competitors.
There are sound policy reasons behind the Westinghouse system which include the following:
(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its
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competitors.
It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.
(b)
It is information which is marketable in many ways.
The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.
(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.
(d) Each component of. proprietary information pertinent to a particular competitive advantage is potentially as l
valuable as the total competitive advantage.
If I
competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.
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(e) Unrestricted disclosure would jeopardize the pos'ition of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition in those countries.
(f) The Westinghouse capacity to invest corporate assets in research and maintaining a competitive advantage.
(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.790, it is to be received in confidence by the Commission.
(iv)
The information is not available in public sources to the best of our knowledge and belief.
(v)
The proprietary information sought to be withheld in this submittal is that which is appropriately marked as Enclosure 1 to letter from F. L. Clayton, Jr. to Schwencer, dated 8/4/80 concerning information in response to NRC request for information relative to low pressure turbine disc integrity.
The information enables Westinghouse to:
l (a) Develop test inputs and procedures to satisfactorily verify the design of Westinghouse supplied equipment.
1 (b) Assist its customers to obtain licenses.
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Further, the information has substantial commercial v'alue as follows:
(a) Westinghouse can sell the use of this information to
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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 experience gained and the test equipnent and methods developed.
Public disclosure of this information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to design, manuf acture, verify, and sell electrici equipment for commercial turbine-generators without commensurate l
expenses. Also, public disclosure of the information would enable others having the samt or similar equipment to use the infonnation to meet NRC requirements for licensing doctmentation without purchasing the right to use the information.
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r 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 r.cney.
This could only be ~ duplicated by a competitor-if he were to invest similar sums of money and provided he had the appropriate talent' available and could somehow obtain the requisite experience Further the deponent sayeth not.
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