ML20056C923
| ML20056C923 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 07/23/1993 |
| From: | Hutchinson C ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19310D630 | List: |
| References | |
| GL-89-10, GNRO-93-00078, GNRO-93-78, NUDOCS 9307270153 | |
| Download: ML20056C923 (6) | |
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1 CORRECTED COPY TO IDENTIFY ATTACHMENT A2 AS
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PROPRIETARY INFORMATION Entergy Operations,Inc.
ENTERGY 4
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July 23, 1993 U.S. Nuclear Regulatory Commission Mail Station P1-37 Washington, D.C.
20555 I
t Attention:
Document Control Desk i
Subject:
Grand Gulf Nuclear Station Docket No. 50-416 i
License No. NPF-29 l
Generic Letter 89-10:
Safety Related Motor-l Operated Valve Testing and Surveillance Program for Grand Gulf Nuclear Station (GGNS)
GNRO-93/00078 Gentlemen:
As you recall, Grand Gulf met with NRC staff on April 20, 1993 to present'the current status of our Generic Letter 89-10 i
program for MOV testing.
We were quite pleased by the wide interest in our program shown by the staff both during and after the meeting and, particularly, the constructive atmosphere of the meeting.
As we noted'at the time, the NRC's efforts in bringing MOV concerns to the industry's attention have resulted in a significant reduction in risk.
Now that MOV program implementation is well advanced, we are encouraged by staff efforts to bring closure to the program.
In addition to a technical briefing on our basis for grouping families of MOVs,.we took the. opportunity during the April'20 meeting to present a detailed discussion of the scope, boundaries and closure criteria of our MOV program.- In the course of our presentation, we addressed many of the questions that the industry and NRC have been struggling with recently such as periodic testing and the relationship of emergent issues to Generic Letter'89-10.
The topics discussed in the presentation are covered in GL 89-10 recommended actions b, c,
f, and j.
We also indicated our intent to submit to you the substance of our presentation in the form on an updated MOV program description with respect to these areas.
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July 23, 1993 I
GNRO-93/00078 Page 2 of 4 j
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The enclosed description covers these elements of the Grand Gulf MOV program.
It is intended to consolidate, expand upon i
and replace previous responses to Generic Letter 89-10 and its j
supplements.
Therefore this submittal constitutes the Grand Gulf license basis (including commitments) with respect to previous submittals in all materia' vespects.
In accordance with 10CFR2.790, we request that Attachment A2 be withheld from public disclosure.
The material contained in i
Attachment A2 is of a proprietary and confidential nature and is of the type customarily held in confidence by Siemens Power i
Corporation (SPC) and not held available to the public.
The information contained in Attachment A2 is considered i
proprietary because it reveals certain distinguishing aspects l
of SPC methodology which secure competitive advantage to SPC for conducting similarity analysis of valves, and includes information utilized by SPC in its business which affords SPC an opportunity to obtain a competitive advantage over its competitors.
Although methodologies and equations are not j
discussed, a list of input parameters could be used to deduce i
the methods used.
Therefore, free access to this material could be detrimental to the business interests of SPC.
The i
basis for withholding from public disclosure has been provided i
by SPC in the attached signed affidavit.
i As our program progresses, we intend to continue our dialogue with the staff and keep you apprised of major developments.
Should there be additional programmatic information that you would find helpful, please contact Doug Jones (601-437-6266) or Je el Summers (601-437-2149) for assistance, j
i You
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a achment:
GL 89-10, MOV Program for GGNS cc:
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G9308121 - 2 l
July 23, 1993 GNRO-93/00078 Page 3 of 4 cc:
Mr.
R. H. Bernhard (w/a)
Mr.
H. W. Keiser (w/a)
Mr.
R. B. McGehee (w/a)
Mr.
N.
S. Reynolds (w/a)
Mr. H. L. Thomas (w/o)
Mr. Stewart D. Ebneter (w/a)
Regional Administrator U.S. Nuclear Regulatory Commission Region II 101 Marietta St.,
N.W.,
Suite 2900 Atlanta, Georgia 30323 Mr.
P. W.
O'Connor, Project Manager (w/2)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 13H3 Washington, D.C.
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1 1, Dr. N. Schauki being duly swom, hereby say and depose:
f 1.
I am Manager Technology Applications and Valve Engineering Services, for l
Siemens Power Corporation, ("SPC"), and as such I am authorized to execute this Affidavit.
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2.
I am familiar with SPC's detailed document control system and policies which govem the protection and control of information.
L 3.
I am familiar with the following reports: 6300/92/105 Thrust and Function Verification of MOV - Similarity Analysis of Gate Valves, 6300/92/106 Thrust and Function Verification of MOV - Similarity Analysis Gate Valves, 6300/92/109 Butterfly Technical Report, 6300/93/001 Thrust and Function Verification of Safety-Related MOV's - Globe Valves, j
6300/92/114 Thrust and Function Verification of MOV - Similarity Analysis Gate Valves - Type 1
Anchor Darling,6300/92/117 Analysis of Valve intemals - Globe Valves Tech Report,6300/92/118 Torque and Function Verification of Safety-Related MOV's - Butterfly Valves, 6300/92/002 1
Methodology - Thrust and Function Verification for Safety-Related MOV's,6300/92/100 Analysis of Gate Valve intemais,6300/92/103 Thrust and Function Verification of MOV-Similarity Analysis Gate Valves, 6300/92/104 Thrust and Function Verification of MOV - Similarity Analysis Gate i
Valves, herein after referred to as ' Documents". Information contained in these Documents have been classified by SPC as proprietary in accordance with the control system and policies l
established by SPC for the control and protection of information.
I I
4.
These Documents contain information of a proprietary and confidential nature and is of the type customarily held in confidence by SPC and not made available to the public.
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Based on my experience, I am aware that other companies regard information of the kind l
l contained in the Documents as proprietary and confidential.
i 5.
The Documents have been made available to Entergy Operations in l
l confidence, with the request that the information contained in the Documents will not be j
disclosed or divulged.
6.
The Documents contain information which is vital to a competitive advantage i
of SPC and would be helpful to competitors of SPC when competing with SPC.
7.
The information contained in the Documents is considered to be proprietary l
by SPC because it reveals certain distinguishing aspects of SPC methodology which secure j
competitive advantage to SPC for conducting Similarity Analysis of Valves, and includes information utilized by SPC in its business which affords SPC an opportunity to obtain a competitive advantage over its competitors who do not or may not know or use the information contained in the Documents.
l 8.
The disclosure of the proprietary information contained in the Documents to I
a competitor would permit the competitor to reduce its expenditure of money and manpower and j
to improve its competitive position by giving it valuable insights into SPC Methodology for l
Similarity Analysis of Valves and would result in substantial harm to the competitive position of j
SPC.
i 9.
The Documents contain proprietary information which is held in confidence by i
SPC and is not available in public sources.
- 10. In accordance with SPC's policies governing the protection and control of information, proprietary information contained in the Documents has been made available, on a limited basis, j
f
m to others outside SPC only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 11. SPC policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.
- 12. Information in these Documents provides insight into SPC methodology developed by SPC. SPC has invested significant resources in developing the methodology as well as the strategy for this application. Assuming a competitor had available the same background data and incentives as SPC, the competitor might, at a minimum, develop the information for the same expenditure of manpower and money as SPC.
THAT the statements made hereinabove are, to the best of my knowledge, information, and belief, truthful and complete.
FURTHER AFFIANT SAYETH NOT.
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SUBSCRIBED before me this /E l
day of 22 dl b 1993.
r~afSR WY Lori J./Grauso e NOTARY PUBUC, STATE OF TENNESSEE l
MY COMMISSION EXPIRES: 11/4/96 l
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