ML20038C016

Requests That Fault Trees Submitted on 810317 Be Withheld (Ref 10CFR2.790) as Proprietary Info

ML20038C016
Person / Time
Site:	Limerick
Issue date:	11/24/1981
From:	Conner T CONNER, MOORE & CORBER, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Harold Denton Office of Nuclear Reactor Regulation
References
NUDOCS 8112090422
Download: ML20038C016 (2)

Text

LAW OFFICT.S CONNER d MOORE 1747 PENNSYLVAN!1 AVENUE. N. W. ' -

TROY D. CONNER JR. WASIUNGToN. D. C. 20006 ARCH A. MOORZ. JR.'

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'o N ' . s Mr. Harold R. Denton l 6 fi'n p.;j '

Director, Office of A" r Nuclear Reactor Regulation g{C3 ,,

U.S. Nuclear Regulatory ,

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• Commission '

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Washington, D.C. 20555 -

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Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2)

Docket Nos. 50-352 and 50'353 Application for withholding Proprietary Information from Public Disclosure

Dear Mr. Denton:

By letter dated March 17, 1981, Philadelphia Electric Company transmitted to you, inter alia, copies of certain detailed fault trees prepared in connection with the Probabilistic Risk Assessment (" fault trees") which were submitted at the same time as Amendment No. 25 to the imerick License Application. At that time, the document was submitted in confidence and it was requested that the fault trees be withheld from public disclosure, pursuant to 10 C.F.R. S2.790(d), for security reasons, as routinely done under existing policy. There was no reason for raising other existing grounds for withholding at that time.

Not only is the information proprietary from the security standpoint, it is also proprietary from the compe-titive standpoint. General Electric Company has advised that it would suffer significant competitive harm if the informa-tion were to be released, as detailed in the enclosed affidavit.

) .

As more fully set.forth in my letter to Mr. William J.

Dircks dated November 9, 1981, because of intervening circum-stances, I requested that all copies of the fault trees be

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. / [D 8112090422 811124 PDR ADOCK 05000352 A PDR

Mr. Harold R.-Denton r' November 24, 1981 Page 2 -

. returned to me.

The letter also notes that the fault trees were proprietary to the General Electric Company. A copy of the letter is attached for your convenience.

Without prejudice to the request ~that all copies _of the document be returned, as a result of-my telephone conver-sation with Stephen Lewis, Staff attorney in the Limerick proceeding, this letter sets forth the request that the fault trees be withheld in their entirety from public disclo-sure, pursuant to 10 C.F.R. S2.790, as proprietary informa-tion. The attached affidavit of Joseph F. Quirk, Manager, BWR Syste,ms Licensing, Nuclear Energy Business Operations, General Electric Company, sets forth the basis on which the information should be withheld from public disclosure by the Nuclear Regulatory Commission in accordance with 10 C.F.R. 52. 790 (b) (4) , and is hereby incorporated by refere~nce herein.

Sincerely,

'\

. . Y.

T7 . Conner, Jr.

Counsel for Philadelphia Electric Company cc: Joseph M. Felton William J. Dircks Stephen H. Lewis, Esq.

Charles W. Elliott, Esq.

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