ML20062L275
| ML20062L275 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 01/19/1981 |
| From: | Trimble D ARKANSAS POWER & LIGHT CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19260G495 | List: |
| References | |
| 1-011-17, 1-11-17, NUDOCS 8101260384 | |
| Download: ML20062L275 (1) | |
Text
ARKANSAS POWER & LIGHT COMPANY POST OFFICE BOX 551 UTTLE ROCK. ARKANSAS 72203 (501) 371-4000 January 19, 1981 0
1-011-17 d
N Mr. Darrell G. Eisenhut, Director T;
Division of Licensing a
Office of Nuclear Reactor Regulation Eij d
U. S. Nuclear Regulatory Conmission
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'n Washington, D. C.
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Subject:
Arkansas Nuclear One - Unit I'd 7
Docket No. 50-313 License No. DPR-51 Westinghouse Low Pressure Turbine Rotor Information Resubmittal (File:
0285,1510.1)
Gentlemen:
Your letter of February 25, 1980, requested information concerning our Low Pressure (LP) Turbine Rotor.
Our letter of March 19, 1980, supplied the requested information.
However, we have received revised site specific responses on question 1-d from that supplied on March 19, 1980 from Westinghouse.
The new information results from employing a more sophisticated calculational model, which now accounts for themal and steam bending stresses, and a revised correlation for calculating the crack growth rate.
The results of these calculations are presented in the attachments which constitute a revision to what was previously labeled Attachment 3 Appendix A (proprietary) and Appendix B (non-pro-prietary).
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. Attachment 2 is an Affidavit which sets forth the basis for withholding the information.
Very truly yours,
.6w c.74 David C. Trimble Manager, Licensing DCT:LY:sl
@b Attachments 810 126 0 ?@t -p ueveen ucote soum uritmcs s,sreu
.o March 14, 1980 Darrell G. Eisenhut Division of Operating Reactors Office of Nuclear Reactor Regulation US Nuclear Regulatory Connission i
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 for Inf omation of February 25, 1980, Relative to Low Pressure Turbine Disc Integrity.
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Reference:
Appendix A letter from D. Trimble to Eisenhut,. dated 3/19/80
Dear Mr. Eisenhut:
This application for withholding is submitted by Westinghouse Electric Corporation (" Westinghouse") pursuant to the provisicas of paragraph (b)(1) of Section 2.790 of the Commission'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.
4 The affidavit accocpanying this application sets forth the basis on which the information may be withheld from public disclosure by the Cocsission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.790 of the Commission's regulations.
Accordingly, it is respectfully requested that the subj ect inf ormation which is proprietary to Westinghouse and which is further identified in the affi-davit be withheld f rom public disclosure in accordance with 10CFR Section 2.790 of the Co= mission's regulations.
Correspondence with respect to this application for withholding or the accom-panying affidavit should be addressed to the undersigned.
i Very truly yours, o 3 R. Williamson, Manager a
Customer Order Engineering Westinghouse Electric Corporation t
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Reff: AW-80-14 ATTACHMENT 2 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY.OF DELAWARE:
Before me, the undersigned authority, personally appeared Robert Williamson, who, being by me duly sworn according to las, deposes and
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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:
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Robert Williamson, Manager Custonier Order Engineering S,,etr. to and :, " 7.bd M0" '"
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HENRY E. SQUILLACE Noury Mii:, verple Trip., DC4=are Co.
My Commission boires Oct. 18.1980 e
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(1) I am Manager, Customer Order Engineering in the Steam Trrbine Generator Technical Operations Division of Westinghouse Electric f
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 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 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 informa-tion as a trade secret, privileged or as confidential commercial or financial information.
(4) Pursuant to the provisions cf paragraph (b)(4) of Section 2 790 of the Commission'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 frem public disclosure is owned and has been held in confidence by Westinghouse.
(ii)
The information is of a type customarily held in confidence C
by Westinghouse and not customarily disclosed to the pub-lic.
Westinghouse has a rational basis for determining the types of infor=ation 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.
'o 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 com-petitive 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 consti-tutes a competitive economic advantage over other companies.
(b)
It consists of supporting data, including test data, relative to a process (or ccmponent, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g.,
by optimization or improved marketability.
(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 similar product.
(d) 7t reveals cost or price information, production capac-ities, budget levels, or commercial strategies of West-inghouse, its customers or suppliers.
(e)
It reveals aspects of past, present, or future Westing-house or customer funded development plans and programs
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of potential commercial value to Westinghouse.
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(f)
It contains patentable ideas, for which patent ~protec-tion may be desirable.
l (g)
It is not the property of Westinghouse, but must be treated te / oprietary by Westinghouse according to agreements with the owner.
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(h) Public disclosure of this information would allow un-fair and untruthful judgments' on the perforcance and reliability of Westinghouse equipment components and improper comparison with similar co=ponents made by competitors.
There are sound policy reasons behind the Westinghouse system which include the following:
(a) The use of such information by Westinghcuse gives West-inghouse a competitive advantage over its 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 com-petitive disadvantage by reducing his expenditure of resources at our expense.
(d)
Each component of proprietary informaticn pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage.
If com-petitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.
(e)
Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition in those countries.
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( f) The Westinghouse capacity to invest corporate assets in research and developoent depends upon the success in obtaining and maintaining a competitive advantage.
(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 20 CFR Sec-tion 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 infor=ation sought 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 infor-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) Develop 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 gained and the test equipment 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, canufacture, verify, and sell electrical equipment for commercial turbine-Generators uithout commensurat2 expenses. Also, public disclosure of the information would enable others having the same or similar equipcent 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 cf development by Westinghouse and the expenditure of a considerable sum of 3-money.
4 This could only be duplicated by a competitor 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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