ML20033C039
| ML20033C039 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 11/13/1981 |
| From: | Wiesemann R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | |
| References | |
| NUDOCS 8112020600 | |
| Download: ML20033C039 (14) | |
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C0tXETED UNITED STATES OF AMERICA USf,PC NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensina Board 81 NOV 30 P2:22 In the Matter of
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WISCONSIN ELECTRIC POWER COMPANY
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Docket Nos. 50-266 1
(OL Amendment) 50-301 (Point Beach Nuclear Plant, Units 1 and 2)
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4 AFFIDAVIT OF R. A. WIESEMANN County of Allegheny
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. dX R. A. WIESEMANN, being duly sworn according to law, depo sc says:
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I am Manager of Regulatory and Legislative Affairs in the Nuclear Technology Division of the Westinghouse Electric Corporation (Westinghouse).
I have been delegated specifically the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing l
or rulemaking proceedings, and am authorized to apply for'its with-holding on behalf of the Westinghouse Water Reactor Divisions.
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The supplement to this affidavit ccntains Westinghouse proprietary information, relating to why information already furnished is proprietary, and is hereby so claimed, pursuant to 10 CFR2.790(b)(1)(ii)(1981).
I have indicated the same on each sheet thereof.
It is being furnished only to the three mem'bers of the Atomic Safety and Licensing Board assigned to this proceeding and to the staff counsel.
3.
The information in this document and supplement is true and correct to the best of my information, knowledge and belief.
4.
Further Affiant sayeth not.
R. A. WlESEMANN Subscribed and sworn to before me this 13th day of November, 1981 O,'/?
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' NGTARY PUBLIC-My Commission expires:
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! E n !.II3 c:.r.:.. ::':2 SUPPLEMENT TO AFFIDAVIT I
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OF R. A. WIESEMANN GMC THE NATURE OF THE COMPETITION
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1.
Pressurized Water Reactors utilize a closed-cycle reactor coolant
..G 3svics system in which the steam generator tubes separate the reactor coolant system from the open-cycle system which provides steam to drive the turbine-generator and produce electricity.
2.
Steam generatoh ubes are subject to inspection and maintenance to
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ensure safe'op~eration.
Steam generator tubes which exceed conserva-tive tube-plugging criteria set by the NRC are taken out of service by plugging the ends of the tubes and thereby isolating them from the reactor coolant.
3.
There is no safety problem, however, if a sufficient number of tubes are plugged, the operating flexibility and power output of the plant may be limited.
4.
In this situation, the alternatives to operating with these attendant limitations are'either to replace or to repair the steam generators.
5.
All pressurized water reactors are subject. to long-term effects of corrosion and thus have the potential for requiring repair or replacement of steam generators at some time during plant life.
6.
There are currently 390 steam generators in plants operating or under construction in the United States.
There are another 433 steam generators in plants in the rest of the world excluding the USSR.
7.
The advantages of steam generator repair over replacement is shorter plant down -time and lower cost.
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SUPPLEMENT TO AFFIDAVIT OF R. A. WIESEMANN (Continued)
Paragraphs 8 through 11 identify potential domestic and international competitors of Westinghouse and some repair work Westinghouse believes has been performed by them.
This demonstrates their potential viability in the marketplace.
12.
The Investment by Westinghouse in developing the technology of steam generator tube repair can only be recovered if Westinghouse is able to retain the udvantages of this technology over its competitors for steam generator tube repair business or if it is able to license others to use the technology.
This can only be done if the information is not publicly available.
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,l 1-SUPPLEMENT TO AFFIDAVIT
_OF R. A. WIESEMANN (Continued)
EFFECT OF RELEASE OF INFORt1ATION ON WESTINGHOUSE COMPETITIVE POSITION Paragraphs 1, 2 and 3 describe the Westinghouse judgment of the altered nature of the market should the proprietary information at issue be released.
WHAT WESTINGHOUSE SEEKS TO PROTECT 1.
Westinghouse seeks to protect its ability to recover its investments in:
A.
Test methods and basic data resulting from research and
. development.
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SUPPLEMENT TO AFFIDAVIT OF R. A. WIESEMANN (Continued)
B.
Analytical methods and models.
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Processes.
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Details of our designs including margins, tolerances, etc.
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The knowledge of what data to present and how to present the i
data to satisfy NRC licensing requirements.
NOTE:
In the current' ~ licensing environmen't, the capability to obtain licensing approval has become very important in the marketplace.-
2.
The above identified information is of considerable comercial advantage to the competitors of Westinghouse to the extent that it eliminates the need for similar investments in technology.
RELATIONSHIP OF INFORMATION SOUGHT TO BE WITHHELD FROM PUBLIC DISCLOSURE TO WHAT IS SOUGHT TO BE PROTECTED The release of this information would result in the following competitor benefits:
POTENTIAL ADVANTAGES TO COMPETITORS 1.
It would reduce or eliminate the amount of analysis, research and development work competitors would have to do by providing specific data which, by normalization to other information, whether it be their own or that which is made publicly available, would enable competitors to derive the results of research and development work with a smaller investment of their own resources.
2.
It would allow competitors to justify their own methods and processes using comparative analysis arguments and with a much smaller investment of resources.
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0F R. A. WiESEMANN
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It would enable competitors to define and justify,'the scope and-
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contents of their development program based on a t6mhprison with an n
accepted program and reduce their costs.
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It would provide competitors the opportunity totdavelop-a simiT?n.
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design and supporting analyses on a time schedule which would allow.
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It would reveal advanced processes, methods antanalysistand -
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license costs.
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U INVESTMENT BY WESTINGHOUSE IN WHAT IS SOUGHT TO BE PROT:CTED
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A considerable amount of highly qualified development effort has 4 Y
beenexpendedinexploringalternativesandindeveloping,. demonstrating [
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and verifying processes, methods and analyses associated with v
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The investment to date in
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Westinghouse, exclusive of facilities, is 3
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Competitors could obtain the equivalent information, with difficulty, g:t by performing the same development work as was done by Westinghouse,
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P0TENTIAL HARM TO WESTINGHOUSE N
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We believe there is a likelih6od of substantial harm to the competitive sN
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position of Westinghouse in providing steam generator repair services g
if th'e information sought to be withheld is publicly disclosed.
Such disclosure could result in a loss of future revenue to Westinghouse..
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R2. T Westinghouse is associated with,.or licenses technology to, manu-v t
i s factucing and servii:e organizations in other countries.
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licensing terms could be seriously affected.
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Our competitors are similarly engaged so every improvement they
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On ~the other hand, they could also attempt to undersell s.
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sThusbthe reitglation o.f information about Westinghouse technology s.
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