ML20063F228

Forwards, TMI-1 Once-Through Steam Generator Repair Safety Analysis, Supplementing 811208 & 820216 Responses. Affidavit Requesting Withholding Encl.Evaluation Withheld (Ref 10CFR2.790)

ML20063F228
Person / Time
Site:	Three Mile Island
Issue date:	08/20/1982
From:	Hukill H GENERAL PUBLIC UTILITIES CORP.
To:	Eisenhut D Office of Nuclear Reactor Regulation
Shared Package
ML19297F540	List: ML20063F228
References
5211-82-200, NUDOCS 8208310177
Download: ML20063F228 (6)

Text

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GPU Nuclear hh g g{ P.O. Box 480 Middletown, Pennsylvania 17057 717-944-7621 Writer's Direct Dial Number:

August 20, 1982 5211-82-200 Office of Nuclear Reactor Regulation Attn: D. G. Eisenhut Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Sir:

Three Mlle Island Nuclear Station, Unit 1 (TMI-1)

Operating License No. DPR-50 Docket No. 50-289 OTSG Tube Repair Program Enclosed please find a copy of the "Dil-1 Steam Generator Repair Safety Evaluation" which supplements our responses of December 8,1981 (LER 81-13) and February 16, 1982. This document descrioes the summary analysis of safety considerations for the TMI-l OTSG tube repair process. The repair process has been evaluated against the criteria of 10 CFR 50.59 and does not represent an unreviewed safety question or require Technical Specifi-cation changes. Due to the proprietary nature of the information contained in this enclosure, it is requested that it be withheld from public disclosure in accordance with 10 CFR 2.790a(4).

Sincerely, H. D. Ilukill Director, TMI-l llDll: CWS : vj f

Enclosures:

1) Affidavit

2) TMI-1 Once Through Steam Generator Repair Safety Analysis cc: R. C. Ilaynes _

J. F. Stolz R. Jacobs g

M.

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F GPU Nuclear is a part of the General Pubhc Utilities System

Babcock &Wilcox AFFIDAVIT OF JAMES H. TAYLOR A. My name is James H. Taylor. I am Manager of Licensing in tne Nuclear Power Generation Division of Babcock & Wilcox, and as such I am authorized to execute this Affidavit.

B. I am familiar with the criteria applied by Babcock & Wilcox te de-termine wnether certain information of Babcock & Wilcox is proprietary and I am familiar with the procedures established within Babcock & Wilcox, particularly the Nuclear Power Generation Division (NPGD), to ensure the proper application of these criteria.

C. In determining whether a Babcock & Wilecx document is to be classi-fied as proprietary information, an initial determination is made by the unit manager who is responsible for originating the document as to whether it falls within the criteria set forth in Paragraph D hereof. If the information f alls within any one of these criteria, it is classified as proprietary by the originating unit manager.

This iniiial determination is reviewed by the cogni: ant section manager. If the document is designated as proprietary, it is re-viewed again by Licensing personnel and c her management within NPGD as designated by the Manager of Licensing to assure that the

. regulatory requirements of 10 CFR Section 2.790 are met.

D. The fc11owing information is provided to demonstrate that the cro-visions of 10 CFR Section 2.790 of the Commission's regulations have been considerec:

(i) The information has oeen held in confidence by the Babcock 5 Wilecx Comoany. Cocies of tne document are clearly identifiec as proprietary. In addition, wnenever Sabcock & Wilecx tran smi ts tne inf orma tion to a cus:ccer, customer's agent, potential customer or regulatory agency, the transmittal re-quests the recioient to hold the informacion as proprietary.

Also, in order to s trictly limi t any potential or actual cus tomer's us e of proprie tary inf orma tion, the following j _

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Babcock &Wilcar AFFIDAVIT OF JAMES H. T_AYLOR (Cont'd) provision is incluced in all proposals submitted by Sabcock

& Wilcox, and an epplicable version of the proprietary provision is included in all of Babcock & Wilcox's contracts:

" Purchaser may retain Company's Proposal for use in connection with any contract resulting theref rom, and, for that purpose, make such copies thereof as may be necessary. Any proprietary information concerning Company's or its Suppliers' products or manufacturing p

'rocesses which is so designated by Company er its Suppliers and disclosed to Purchaser incident to tne performance of such contract shall remain the property of Company or its Suppliers and is disclosed in confi-dance, and Purtnaser shall not publish or otherwise disclose it to others without the wri tten approval of Company, and no rights , implied er otherwise, a re granted to produce or have procuced any procucts or to practice or cause to be tracticec any manuf acturing processes covered thereby.

Notwithstanding the above, Purchasar may provide the NRC or any other regulatory agency with any such pro-prietary information as the NRC or such other agency may require; provided, however, that Purchaser snall first give Company written no tice of such proposed i disclosure and Company shall nave the right to amend such proprietary information se as to make it non-pro-prietary. In the event that Company cannot amend such proprietary information, Purchaser shall, prior to disclosing such information, use its best efforts l

to obtain a commi tment from NRC cr sucn other agency to nave such information witnheid from oublic inspection.

I (2) 1 - -

. AFFIDAVIT OF JAMES H. TAYLOR (Cont'd)

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Company shall be given the right to participate in pursuit of such confidential treatment."

(ii) The following criteria are customarily applied by Babcock &

Vilcox in a rational decision process te cetermine wnether the information should be classified as proprietary. Info rma ti on may be classified as proprietary if one or more of the fcilowing f criteria are met.

a. Information reveals cost or price information, commercial strategies, production capabilities, or oudget levels of Babcock & Wilcox, its cus tomers or suppliers,

b. The informa tion reveals data or material concerning Eabcock

& Wilcox research or development plans or programs of present or potential competitive advantage to 5.abcock &

Wilcox.

c. The use of the information by a competitor would cecrease his expenditures, in time or resources, in designing, producing or marketing a similar orocuet.

d.

The information consists of test data or other similar data concerning a process, method or component, the apolication ,

er whien results in a competitive acvantage :: Sabcock &.

Wilcox.

e. The

formation reveals special asoects of a process, method, i

comoonent or the like, the exclusive use of wnich resul ts in a competitive advantage to Sabcock & Wilcox, f.

The 19 formation contains ideas for wnich patent protection may oe sought, i

i

Babcock &Wilcox AFFIDAVIT Of JAMES H. TAYLOR (Cont'd)

The document (s) listed on Exhibit "A", which is a ttached hereto and made a part hereof, has been evaluated in accordance with normal Babcock & Wilcox procedures with respect to classification and has been found to contain information which falls wi-hin one or more of the criceria enumerated above. Exhibit "B", which is attached nereto anc made a part hereof, specifically identifies the criteria apolicable to the document (s) listed in Exhibit "A".

(iii) The document (s) '*d in Exhibit "A", which has been made avail-able to tne Unittu states Nuclear Regulatory Commission was made available in confidence with a request that the document (s) and the information contained therein be withheld from public disclosure.

(iv) The information is not available in the open literature anc to the best of our knowledge is not known by Combus tion Engineering, EXXON, General Electric, Westingneuse or other current or potential domestic or foreign competitors of B&W.

(v) Soecific information with regard to whether puolic cisclosure of the information is likely to cause harm to the comoetitive l

position of Babcock & Wilcox, taking into account the value of the information to Babcock & Wilcox; the amount of effort or money '

expendeo oy Babcock & Wilcox coveloping the information; and the ease or difficulty with which tne information could be procerly duplicated by others is given in Exhibit "B".

E.

I have personally revi*wed the document (s) listed on Exnioi: "A" and have founc that it is considered proprietary by Saccock & Wilcox because it contains infor?.ation whien falls witnin one or more of tne criteria enumerated in Paragraph 0, and it is informa tion which is customarily held ' confidence and protectec as proprietary in-formation by Baccoch 6 Wilcox. This report comprisas information utilized by Baocock & Wilcox in its business whien afford Baccotk

& Wilcox an opoortunity to obtain a competi tive advantage over (4)

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Babcock &WHcox those who may wish to know or use the information contained in the document (s).

W

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/JAMESH.IAYLO[

State of Virginia 55, 1.yn chbu rg City of Lynchburg James H. Taylor, being duly sworn, on his oatn deposes and says tha ment, t he is tne person who substribed his name to the foregoing state-trum. and that the matters and facts set fortn in the statement are

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/ JAMES H. fAYLOR [

t Suescribef and sworn before me, this /3 day of t & cn:.4 1982.

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Notary Public in and for the City of l'~'~

Lynchburg, State of Virginia n* .> N u r m './ t h 3rn. . s l) SL .x,,,y t

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