ML20073L701
| ML20073L701 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 09/28/1994 |
| From: | Keaten R GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19304C615 | List: |
| References | |
| 5000-94-0040, 5000-94-40, NUDOCS 9410130252 | |
| Download: ML20073L701 (6) | |
Text
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n GPU Nuclear Corporation i
arsi pan, Ne Jers y07054 201-316-7000 TELEX 136-482 Writer's Direct Dial Number.
September 28, 1994 5000-94-0040 C321-94-2157 U.S. Nuclear Regulatory Commission Att: Document Control Desk Washington, DC 20555 Gentlemen:
Subject:
Oyster Creek Nuclear Generating Station (OCNGS)
Docket No. 50-219 Facility Operating License No. DPR-16 Core Shroud - 15R Outage Contingency Repair In support of the NRC Staff's expedited review of the subject repair, enclosed is GPU Nuclear's interim safety evaluation report, and repair design specifications. The safety evaluation report is considered interim in that some evaluations supporting the conclusions reached in the report are currently being finalized but are not yet complete.
It is GPU Nuclear's intention te ;ubmit a final safety evaluation report upon completion of all supporting evaluations.
The enclosed interim report and repair design drawings conta',.i information determined to be proprietary, and an affidavit as required by 10CFR2.790(b)(1) is attached.
If you have any questions or comments on this submittal, please contact Mr.
Michael Laggart, Manager, Corporate Nuclear Licensing at (201) 316-7968.
Sincerely,
/
R. W. Keaten Vice President and Director Technical Functions c: Administrator, Region 1 Senior Resident Inspector Oyster Creek NRC Project Manager 14000i 941012,0252 940928 PDR ADOCK 05000219 P
,t GPU Nuclear Corporation is a subsidiary of General Pubhc Utilities Corporation
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EiEMPR A S S O C I A T E S I N C.
-ENGINEERS Attachment to GPUN Letter C321-94-2157 September 28,1994 AFFIDAVIT PURSUANT TO 10 CFR 2.790 RELATIVE TO CORE SHROUD REPAIR FOR OYSTER CREEK MPR Associates, Inc.
State of Virginia City of Alexandria I, N.M. Cole, depose and say that I am a Principal of MPR Associates, Inc. duly authorized to make this affidavit, and have reviewed or caused to have reviewed the 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 in conjunction with General Public Utilities Nuclear Corporation (GPUN).
The information for which proprietary treatment is sought is contained in: (1) the
" Safety Evaluation for Oyster Creek Shroud Contingency Repair," dated September 28, 1994, prepared by MPR Associates, Inc. for GPUN; and (2) " Design Specification for Oyster Creek Nuclear Generating Station Core Shroud Repair," Specification No. 083-9403 001, dated September 28,1994, prepared by MPR Associate-s, Inc. for
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GPUN.
These documents have been appropriately designated as proprietary.
l I have personal knowledge of the criteria and procedures utilized by MPR Associates in I
designating information as a trade secret, privileged or as confidential commercial or L
financial information.
Pursuant to the provisions 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.
1.
The information sought to be withheld from public disclosure, which is owned and has been held in confidence by MPR Associations, is the design of the shroud repair system for the Oyster Creek Nuclear Generating Station.
2.
The information consists of design information or other similar data concerning a repair system, method or component, the application of which results in substantial i l
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1 competitive advantage to MM Assocmtes. MPR has a patent application pending for this shroud repair system.
3.
The information is of a type customarily held in confidence by MPR Associates and not customarily disclosed to the public. MPR Associates has a rational basis for determining 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 confidence. This system was applied in determining that the subject document herein is proprietary.
4.
The information is being transmitted 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 the Commission.
5.
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 of the information in confidence.
6.
Public disclosure of the information is likely to cause substantial harm to the competitive position of MPR Associates because:
a.
Other repairs for similar purposes are performed and sold by major light water reactor competitors of MPR Associates.
b.
Development of these repair designs by MPR Associates required thousands of manhours 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.
c.
In order to acquire such information, a competitor would also require considerable time and inconvenience to develop these repair designs.
d.
The information consists of information related to repair of cracked shrouds in the Oyster Creek Nuclear Generating Station and other BWIb as well. The application of which provides a competitive economic advantage. The availability of such information to competitors would enable them to modify their designs to better compete with MPR Associates, take marketing or other actions to improve their position or impair the position of MPR Associates' design, and avoid developing similar data and analyses in support of their design methods or shroud repair system.
e.
In pricing MPR Associates products and services, significant research, development, engineering, analytical, manufacturing, quality assurance and
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other costs and expenses must be included. The ability of MPR Associates' 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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f.
Use of the information by competitors in the intemational marketplace would increase their ability to market such repair designs by reducing the costs associated with their technology development. In addition, disclosure would have an adverse economic impact on MPR Associates' potential for obtaining or maintaining foreign licensees.
Further the deponent sayeth not.
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,7-Noman M. Cole Principal Sworn to before me this /tet day of d.,[w/a
.1994 w
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,dwY k 0 W Notary Publ,icf My commission expires: Al 3 /. / 9 96:,