ML20070K851
| ML20070K851 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/27/1982 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19262G887 | List: |
| References | |
| NUDOCS 8212300293 | |
| Download: ML20070K851 (9) | |
Text
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.b TENNESSEE VALLEY AUTHORITY CH ATTANOOGA, TENNESSEE 37401 400 Chestnut Street Tower II December 27, 1982 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Conunission Washington, D.C.
20555
Dear Mr. Denton:
In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
)
50-328 Enclosed for your information and review are drawings referenced in our Sequoyah Nuclear Plant operating license amendment request for a volume reduction system, submitted under separate letter. As indicated in the amendment package, in accordance with 10 CFR 2.790(b), these drawings have been determined by the suppliers, Aerof it Energy Conversion Company and Stock Equipment Company to contain proprietary material.
Also enclosed are copies of the affidavits regarding proprietary information required by 10 CFR 2.790(b).
If you have any questions regarding this submittal, please get in touch with Ken Parr at FTS 858-2685.
Very truly yours, TENNESSEE VALLEY AUTHORITY L. M. Mills,' Manager Nuclear Licensing y
Sworn subscrib before me 1
this day of 1982 Gaoh& WQkA&
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U.S, Nuclear Regulatory Commission Region II h
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Mr. James P. O'Reilly, Administrator 4'h,\\g 101 Marietta Street, Suite 3100 (f
Atlanta, Georgia 30303 82123g30 0
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An Et ual ( pportunity Employer
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p tie, wsct26C-K Mr..lohn A. Raulaton L's M&
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Chief Nuclear Engineer
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SWCK Radwaste Solidification System TVA Contract 81K68-827379-I STOCK Ref:
S.O. 5909 - Sequoyah S.O. 5910 - Wat.tc Bar Proprietary Statement Gent.lemen :
On Novet5er 18, 1982 TVA advised STOCK that. TVA v'as about to submit license amendment. documents to the Imc for the Sequoyah and Wat.ts Bar Nuclear Plants.
Pursuant to the requirements of 10CFR 2.790, " Availability of Official Recotda", STOCK has ' evaluated nubmittals tnade to TVA under contract 81K63-827379-1 and has determined that proprietary information is con-tained in specific STOCK Solidification System Piping and Information Drawings and Process Flor Diagrann and that. they should not be repro-duced or used in any way detritnental to the interest of Stock Equipment Company. These documents define in schematic form systems and/or equip-nent currently in research or development. These documents are current-ly being utilized to obtain patents, bot.h U.S. and f oreign.
A.
The following is a list of Piping and Instrumentation Drawinga..and Process Plow Diagrams submitted to TVA that are proprietary in nature ',
and are currently being used to apply for patents. These document a j
are all applicabic to the Polymer Solidification System.
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Stocl(Eqsipthent Coinpany Mr. John A. 5taulston November 19. 1982 Proprietary Statement Page 2 Drawing No.
Title D17467-0 Sheet 4 P&ID - Drumming Station
. Dry Salt D17467-A Sheet 4 D18699-0 Sheet 1 D18699-0 Sheet 2 D17467 -O Sheet 5 76ID - Polymer Pill Station & Storage Tank D17467-A Sheet 5 D17467-B Sheet 5 C12421-A Sheet 1 Process Plow Diagram - Identification & Symbology C12421-A Sheet 7 Process Plow Diagram - Polymer' Pilling Station i
and Storage Tank C12735-0 Sheet 1 Process Plow Diagram - Dry Product Druccning Station & Transfer System C12735-0 Sheet. 2 Satos as above C12735-0 Sheet 3 C12735-0 Sheet 4 LD18183-0 Sheet 1 P&ID - Dru=ning Station - Polyrner (Dry)
Transfer System Dry Product LD18183-0 Shect'2 Sarne as above LD18183-0 Sheet 3 LD18183-0 Sheet 4 D.
Contact Dose Rate Study On November 4,1981 STOCK subrnitted a Contact Dose Rate Study to TVA attached to Ictter SST-034. We havo dotermined that since t.he data was developed by the STOCK Engineering Group, it should be considered as proprietary information and should not be disclosed to the general public. Proprietary information concerning shielding capabilitics of STOCK manufactured components can be derived frr,m this do'cun.ent.
C.
The following is a list of Piping and Instrumentation Drawings and Process Flow Diagrams submitted to TVA for review or approval that are not of a proprictory nature and, therefore, contain information that can be made available to the general public:
Drawing No.
Titic D17467-0 Sheet 1 P&ID - Symbol'ogy D17467-A Sheet 1 D17467-D Sheet 1 D17467-C Sheet 1 D17467-0 Sheet 2 P&ID - 5000 Gallon Storage Station "A"-
D17467-A Sheet 2 D17467-B Sheet 2 D17467-C Sheet 2 e
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StoEk EfqIsip' ment Company s
Mr. John A. Raulston November 19. 1982 Proprietary Statetnent Page 3 Drawing No.
Titic D17467-0 Sheet 3 P&ID - 5000 Callon St.orage, Station "B"
D17467-A Sheet 3 D17467-B Sheet 3 E812-0 P&lD - Drumming Station - Cement E812-A E812-B E812-C E813-0 P61D - Decanting Station - $00 callon EB13-A
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E813-B E813-C B1005-0 Sheet 1 P&ID - Cement Storage Silo E1005-A'Shoct 1 E1005-0 Sheet 2 P61D - Cement P131 Station E1005-A Sheet 2 C12421-0 sheet. 2' Proccca Plow Diagram - Liquid & Slurry Process System C12421-0 Sheet 3 Same as above C12421-O Sheet 4 C124B1-0 Sheet 5 C12421-0 Sheet 6 If you have any comments or questions concerning this inaue, please advise.
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Very truly yours, STOCK EQUIPHENT 00MPAhT P-Paul S. Ilunt Vice Prcoident, Engineering PSH:JRL:ck cc: David Marka
' State of Ohio
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County of Geauga) 33 Beforo me 11'y came Paul S. Hunt, to rne personally known, who swore that th!:
above stat Mgarding proprietary Infortretion are true and correct to tifin best of his kmm gpe.?
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navember) ?, l582
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O carol.YN H. GANNON, Nobny Pubne cour.coaw. si.te a oso 1.5 Curahsia Expirer August 24, IE
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NOV 2 41982 Aeroiet
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INFO l DUE P.O. Box 13222 EnergyConversion
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REPLY COPY Copy I DATE SCOTCmen?O.CChfornia 95813 Company
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Attention: Mr. T. G. Chapman g
Subject:
Volume Reduction System Contract 81K68-827379, Sequoyah 3': -
Nuclear Plant; Licensing Amendment for Volume Reduction cn M,
I System H 5 t, a1
(_n Gentlemen:
Sg-Confirming the telephone conversation this date between Mr. R. W. Marshall y-and the undersigned, there is enclosed the affidavit required by 10 CFR u-
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2.790(b).
The affidavit applies to our Piping and Instrumentation Diagrams (Drawing 1193002), and to the Material Balance Flow Diagram (Drawing 1193003).
If additional information is required, please contact the undersigned or Mr. J. L. Dooling at 916-355-2047.
Very truly yours, K. F. Royer Program Manager VR Systems cc:
D. H. Marks
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Enclosure (1)
AFFIDAVIT PURSUANT TO 10 CFR 2.790 f
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Aerojet Energy Conversion Company l
State of California
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County of Sacramento l
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I, Stanley P. Ferreira, am the Manager, Contracts and Business Administration, of Aerojet Energy Conversion Company, duly authorized to make this affidavit, and have reviewed or. caused to have reviewed the l
information which is identified as proprietary and referenced in the paragraph immediately below.
I am. submitting this affidavit in conformance with the provisions of 10 CFR 2.790 of the Commission's regulations for withho'lding this information.
The infonnation for which proprietary treatment is sought is contained in the following document:
Aerojet Energy Conversion Company Topical Report No. AECC 3-P, entitled, " Radioactive Waste Volume Reduction System,"
~ December 15, 1981.
This document has been appropriately designated as proprietary.
I have personal knowledge of the criteria and procedures utilized by Aerojet Energy Conversion Company in designating information as a trade secret, privileged or as confidential commercial or financial information.
Pursuant to the prov'isions of paragraph (b) (4) of Section 2.790 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure, included in the above referenced document, should be withheld.
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The information sought to be withheld from public disclosure is (1) Piping and Instrumentation Diagrams (Dwg 1193002), for the Aerojet Energy Conversion Company Radioactive Waste Volume Reduction System, and (2) Material Balance Flow
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Diagram (Dwg 1193003), for the Aerojet Energy Conversion Company Radioactive Waste Volume Reduction System, both of which are owned and have been held in confidence by the Aerojet Energy Conversion. Company.
2.
The Piping and Instrumentation Diagrams contain information relating to the' type, placement, and number of process instruments required for control of the process.
These diagrams also contain information on the various control loops and control logic and repres nt the control system design. The Material
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Balance Flow Diagram-contains the ' pressures, temperatures, and flow rates
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existing throughout the system and represents the process design.
Applicatiion of this information re,sults in.a substantial competitive advantage to Aerojet Energy Conversion Company.
3.
The information 'is of a type customarily held in confidence by Aerojet Energy Conversion Company and not customarily disclosed to the public.
Aerojet Energy Conversion Company has a rational basis for dete'rmining the types of information 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 conf,idence.
This system was applied in determining that the subject document herein is proprietary
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4.
The information is being transmitted to the Tennessee Valley Administration and to the Commission in confidence under the provisions of 10 CFR 2.790 with the understanding that it is to be received in confidence by TVA and the Commission.
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The information, to the best of my knowledge and belief, is not available in public sources, and any disclosure to third parties has been made pursuant to regulatory provisions or proprietary agreements which provide for maintenance
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of the information in confidence.
Public disclosure of the information is likely to cause substantial harm 6.
to the competitive position of Aerojet Energy Conversion Company because:
A similar product is manufactured and sold by a major competiter of AECC.
a.
Development of this information by AECC required thousands of man-hours b.
of effort and hundreds of thousands of dollars. To the best of my knowledge and belief, a competitor would have to undergo similar expense in generating equivalent information.
In order to acquire such information, a competitur would also require c.
considerable time and inconvenience related to develor.nent of experimental and demonstration test facilities.
d.
The information represents the control system design and the prqcess design, the application of which provides a competitive economic advantage.
The availability of such information to competitors would enable them to modify their product to better compete with AECC, take marketing or other actions to improve their product's position or impair the position of AECC': product, and avoid developing similar infonaation in support of their processes, methods, or apparatus.
In pricing AECC's products and services, significant research, develop-e.
ment, engineering, analytical, manufacturing, licensing, quality assurance, and -
other costs and expenses must be included. The ability of AECC's competitors to utilize such information without similar expenditure of resources may enable them to sell at prices reflecting significantly lower costs.
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the of the information by competitors in the international marketplace g ;...
would increase their. ability to market radioactive waste volume reduction systems
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by reducing the costs associated with their-technology development.
In addition, disclosure would have an adverse economic impact on AECC's potential for obtain-ing or maintaining foreign licenses.
$W S. P. Ferreira, Manager Contracts & Business Administration STATE OF CALIFORNIA
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County of Sacramento
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On this 19th day of November,1982 before me, the undersigned, a Notary Public in and for said State, personally appeared STANLEY P. FERREIRA, per-T.]. l.'.
sonally known to me or proved to me on the basis of satisfactory evidence to be the person whose name is subscribed to the foregoing Affidavit and acknowledged that he executed the same.
WITNESS my hand and official seal.
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MARYANN LKOCH y
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Principal Office in Srcramento County My Commission Expires Feb.1.1985 r
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