ML20078C020

Forwards Proprietary Rev 0 to Vols 1 & 2 of Oyster Creek... Generating Station Core Shroud Repair - Design Rept, in Support of NRC Expedited Review of Subj Enhancement Noted in Ref Rept.Encl Proprietary Rept Withheld

ML20078C020
Person / Time
Site:	Oyster Creek
Issue date:	10/25/1994
From:	Keaten R GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19311B422	List: ML20078C020
References
5000-94-0043, 5000-94-43, C321-94-2185, NUDOCS 9410280003
Download: ML20078C020 (5)

Text

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GPU Nuclear Corporation G !J Nuclear = = 1" = ezoe4 201-316-7000 TELEX 136-482 Writer's Direct Dial Numbet October 25, 1994 C321-94-2185 5000-94-0043 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:

Subject:

Oyster Creek Nuclear Generating Station (OCNGS)

Docket No. 50-219 Facility Operating License No. DPR-16 Core Shroud - ISR Outage Enhancement

References:

(1) GPU Nuclear Ltr. C321-94-2157, " Core Shroud - 15R Outage Contingency Repair", dated September 28, 1994.

In support of the NRC Staff's expedited review of the subject enhancement, Reference 1 provided GPU Nuclear's interim safety evaluation report, and repair design specifications. This submittal provides Revision 0 of the "0yster Creek Nuclear Generating Station Core Shroud Repair - Design Report", dated October, 1994. This first phase of the design report covers more than 80*/. of the analysis associated with the core shroud enhancement. Submittal of the remaining calculations and final safety evaluation report is anticipated to occur by November 2, 1994.

The enclosed design report contains 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.

Ver truly ours, bR. W. Keaten L Vice President and Director Technical Functions r 4 (

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c: Administrator, Region 1, w/o Proprietary Report Senior Resident Inspector, w/o Proprietary Report - I Oyster Creek NRC Pro.iect Manager, w/ Proprietary Report 9410280003 941025 -- f O 'I J PDR ADOCK 05000219 ,

GPd Nuc Uorporation is a substa;a y 0 Ueneral Pubhc Utilitres Corporation

ATTACHMENT

" Oyster Creek Nuclear Generating Station Core Shroud Repair - Design Report",

Rev. O, dated October 1994.

This attachment contains Proprietary information as defined in 10CFR2.790(a)(4).

An affidavit as required by 10CFR2.790(b)(1) to support this determination follows.

GilMPR

^550c' m S E c- October 24,1994 FNGiNEERS AFFIDAVIT PURSUANT TO 10 CFR 2.790 RELATIVE TO CORE SIIROUD REPAIR FOR OYSTER CREEK MPR Associates, Inc.

State of Virginia City of Alexr. aria I, Noman 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 the attached MPR report titled," Oyster Creek Nuclear Generating Station Core Shroud Repair -

Design Report," dated October 1994. This report contains detailed design information and data on the design of the shroud repair system for the Oyster Creek Nuclear Generating Station.

This document has been appropriately designated as proprietary.

I have personal knowledge of the criteria and procedures utilized by MPR Associates in designating information as a trade secret, privileged or as confidential commercial or financial information.

Pursuant to the provisions of paragraph (b) (4) of Section 2.790 of the Comraission'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 competitive advantage to MPR Associates. MPR has a patent epnlication pending for this shroud repair system.

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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 BWRs as well. The l application of which provides a competitive econom'c advantage. The availability of such information to competitors woul enable them to modify their designs to better compete with MPR Acsociates, 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. l

c. In pricing MPR Associates products and services, significant research, development, engineering, analytical, manufacturing, quality assurance and 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 international marketplace would increase their ability to market such repair designs by reducing the costs l l

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associated with their technology development. In addition, disclosure would l have an adverse economic impact on MPR Associates' potential for obtaining l or maintaining foreign heensees.  :

l Further the deponent sayeth not.

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Noman M. Cole Principal Sworn to before me this 24thday of October .1994 UhNGO- O C 90 ane Y\ h3 Notary I'ublic My commission expires: March 31, 1996 t