ML20070Q211
| ML20070Q211 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 03/26/1991 |
| From: | Taylor J BABCOCK & WILCOX CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19310E691 | List: |
| References | |
| JHT-91-58, NUDOCS 9103280250 | |
| Download: ML20070Q211 (8) | |
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GO BS W NUCLEAR TECHNOLOGIES JHT/91-58 3315 ots rarest Rua March 26, 1991 T'O DN 10935 L ynchburg VA N506 0935 Telephone U033052000 Telecopy 806 385-3063 U.
S.
Nuclear Regulatory Commission Washington, D.C.
20555 Attn:
Document Control Desk
Subject:
BWNS Topical Report BAW-2120P Additional utilities with B&W plants are planning to install Alloy 690 sleeves in their OTSGs.
While the NRC has already approved this activity, the approval status should be clarified.
The NRC has previously approved the use of Alloy 600 (BWNS Topical Report BAW-1823) for sleeving once-through steam generators.
Because of its superior material properties, the NRC has also approved the substitution of Alloy 690 for Alloy 600 as a sleeving material (NRC letter from T.
R. Quay to N.
S.
Carns (AP&L), dated October 16, 1990).
Formalizing the approval of the specific qualification topical report for Alloy 690 will clarify the record on this matter and provide answers to some recent questions which have been raised by the NRC Staff on the Crystal River docket.
In view of the above, please find attached three copics of the proprietary BWNS Topical Report BAW-2120P, "OTSG 80" Mechanical Sleeve Qualification (Alloy 690)", January 1991.
A copy of the report has been sent directly to Messrs. Wichman and Conrad.
This topical report contains a description of the qualification process for Alloy 690 sleeve installation in once-through steam generators.
The affidavit supporting the proprietary classification is attached.
Please review and approve this topical report so that it may be formally referenced in future licensing communications related to OTSG sleeving with Alloy 690.
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9103280250 910326
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l NRC Document Control Desk JHT/91-58 March 26, 1991 Page 2 The review and approval process should be very straightforward and essentially of a confirmatory nature because of the similarity to other aircady approved B&W sleeving processes.
Therefore, it is requested that the approval be issued by June 1,
1991.
Ver rulyg ours, 8,?!
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v II. TayloA', Manager Licensing Services JHT/bcc cc:
w/ Attachments K.
R. Wichman/NRC H.
F.
Conrad/NRC w/o Attachments J.
E. Richardson /NRC C.
Y.
Cheng/NRC V.
H. Wilson /NRC K. Wilson /FPC B.
Elam/GPUN B.
Schrauder/TED 1
N' h* L AFFIDAVIT OF JAMES H. TAYLOR A.
My name is James H. Taylor.
I am Manager of Licensing Services in the B&W Nuclear Service Company (BWNS), which is a part of B&W Nuclear Technologies (BWNT), and as such I am authorized to execute this Affidavit.
B.
I am familiar with the criteria applied by B&W to determine.
whether'certain information of B&W is proprietary and'I am familiar with the precedures established within B&W, particularly the Nuclear Services Company, to ensure the proper application of these criteria.
C.
In determining whether a B&W document is to be classified 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 falls within any one of these criteria, it is classified as proprietary by the criginating Unit Manager.
This initial-determination is reviewed by the cognizant-Section Manager.
If_the document is designated.as proprietary, it is reviewed again by Licensing personnel and other management within BWNS as designated by the Manager of Licensing Services to assure that the. regulatory requirements of 10 CFR Section 2.790 are met.
l D.
The following-information is prov.ided to demonstrate that the provisions of 10 CFR Section 2.790 of the Commission's regulations have been considered:
l.
ll (1)-
The information has been held in confidence by B&W.
I copies of the document are clearly identified as proprietary.
In addition, whenever B&W transmits the l
l
i AFFIDAVIT OF JAMES H. TAYLOR (Cont'd.)
information to a customer, customer's agent, potential customer or regulatory agency, the transmittal requests the recipient to hold the information as proprietary.
Also, in order to strictly limit any potential or actual customer's use of proprietary information, the following provision is included in all proposals submitted by B&W, and an applicable version of the proprietary provision is included in all of B&W's contracts:
" Purchaser may retain Company's proposal for use in connection with any contract resulting therefrom, and, for that purpose, make such copies thereof as may be necessary.
Any proprietary information concerning Company's or its Supplier's products or manufacturing processes which is so designated by Company or its Suppliers and disclosed to Purchaser incident to the performance of such contract shall remain the property of Company or its Suppliers and is disclosed in confidence, and Purchaser shall not publish or otherwise disclose it to others without the written approval of Company, and no rights, implied or otherwise, are granted to produce or have produced any products or to practice or cause to be practiced any' manufacturing processes covered thereby.
Notwithstanding the above, Purchaser may provide the NRC or any other regulatory agency with any such proprietary information as the NRC or such other agency may require; provided, however, that Purchaser shall first give Company written notice of such proposed disclosure and Company shall have the right to amend such proprietary information so as to make it non-proprietary.
In the event that Company cannot amend such proprietary information, Purchaser 2
h ' + !.,*
l AFFIDAVIT OF JAMES H. TAYLOR (Cont'd.)
shall, prior to disclosing such information, use its best efforts! to obtain a commitment from NRC or such other agency to have such information withheld from public inspection.
Company shall be given the right to participate in pursuit of such confidential treatment."
(11)
The following criteria are customarily applied by B&W in a rational decision process to determine whether the information should be classified as proprietary.
Information may be classified as proprietary if one or more of the following. criteria are met:
a.
Information reveals cost or. price information, commercial strategies,. production capabilities, or budget levels of B&W, its customers or suppliers, b.
The information reveals data or material concerning B&W research or development plans or programs of present or potential. competitive advantage to B&W.
c.
The use of the information by a competitor would
' decrease'his expenditures, in time or. resources, in designing, producing or. marketing a similar product.
d.
~The'information consists of test data or other similar dato concerning a process, method or component, the application of which-results in a-competitive advantage to B&W.
e.
The information reveals special aspects of a process, method, component or the like, the exclusive use of which results in a competitive advantage to B&W.
3
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AFFIDAVIT OF JAMES H. TAYLoB (Cont'd.)
f.
The information contains ideas for which patent protection may be sought.
The document (s) listed on Exhibit "A",
which is attached hereto and made a part hereof, has been evaluated in accordance with normal B&W procedures with respect to classification and has been found to contain information which falls within one or more of the criteria enumerated above.
Exhibit "B", which is attached hereto and made a part hereof, specifically identifies the criteria
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applicable to the document (s) listed in Exhibit "A".
(iii)
The document (s) listed in Exhibit "A", which has been made available to the United 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 and to the best of our knowledge is not known by Combertion Engineering, EXXON, General Electric, Westinghouse or other current or potential domestic or foreign. competitors of B&W.
(v)
Specific information with regard to whether public disclosure of the information is likely to cause harm to the competitive position of B&W, taking into account the value of the information to B&W; the amount of effort or money expended by B&W developing the information; and the ease or difficulty with which the information could be properly duplicated by others is given in Exhibit "B".
E.
I have personally reviewed the document (s) listed on Exhibit "A" and have found that it is considered proprietary by B&W because it contains information which falls within one or more of the 4
i J,
AFFIDAVIT OF JAMES H. TAYLOR (Cont'd.)
criteria enumerated in Paragraph D, and it is information which is customarily hold in confidence and protected as propriotary information by B&W.
This report comprises information utilized by B&W in its business which afford B&W an opportunity to obtain a competitive advantage over those who may wish to know or use the information contained in the document (s).
,,,d 76 [
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JAMES H. TAILOR State of Virginia)
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SS. Lynchburg City of Lynchburg)
Jamco H. Taylor, being duly sworn, on his oath deposes and says that he is the person who subscribed his name to the foregoing statement, and that the matters and facts set forth in the statement are true.
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/ JAMES H. TAYLQR'
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Subscribed and sworn before me this M day of
< Ah te h 1991.
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Notary Pu c
n and fo th ity of Lynchb(frg, State of Virginia.
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i EXHIBIT "A" 1.
BWNS Topical Report BAW-2120P, -"OTSG - 80" -Mechanical Sleeve Qualification _(Alloy 690)",l January 1991.
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EX1tLBIT "B" i
APPLICABLE PROPRIETARY CLASSIFICATION CRITERIA ty i
Criteria b,;c, d, and-e of the. attached affidavit.
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