ML20080N040

Affidavit of Jh Taylor Re Classification Procedures for Proprietary Documentation

ML20080N040
Person / Time
Site:	Three Mile Island
Issue date:	02/15/1984
From:	Taylor J BABCOCK & WILCOX CO.
To:
Shared Package
ML20080N034	List: ML20080N031 ML20080N040
References
NUDOCS 8402220081
Download: ML20080N040 (17)

Text

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AFFIDAVIT OF JAMES H. TAYLOR .

A. My name is James H. Taylor. I am Manager of Licensing in the 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 to de-termine whether certain informa tion 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 & Wilcox document is to be classi-fied as proprietary information, an initial determination is made by khe 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 originating unit manager.

This initial determination is reviewed by the cognizant section manager. If the document is designated as' proprietary, it is re-viewed again by Licensing personnel and other management within

, NPG0 as designated by the Manager of Licensing to assure that the regulatory requirements of 10 CFR Section 2.790 are met.

D.

The following information is provided to demonrtrate that the pro-visions of 10 CFR Section 2.790 of the Commission's regulations have been considered:

(1) The information has been held in confidence by .the Babcock &

Wilcox Company. Copies of the document are clearly identified as proprietary. In addition, whenever Babcock & W.ilcox transmits the information to a customer, customer's agent, potential customer or regulatory agency, the transmittal re-quests 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 8402220081 840215 l PDR G ADOCK 05000289 PDR

Babcock &Wilcox AFFIDAVIT OF JAMES H. TAYLOR (Cont'd) j provision is included' in al-1 proposals submitted -by Babcock l 8 Wilcox, and an applicable version of the proprietary provision is included in all of Babcock 4 Wilcox's contracts:

! " Purchaser may retain Company's Proposal for use in connection with any contract resulting therefrom, and, l for that purpose, make such copies thereof as may be necessary. Any proprietary information concerning

l. Company's or its Suppliers' p.oducts 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 confi-

, i dance, and Purchaser shall not publish or otherwise disclose it to others without.the written approval of Company, and no rights, implied or otherwise, are l

granted to produce or have produced any products or to practice or cause to be practiced any manufacturing i processes covered thereby.

l .

Notwithstanding the above, Purchaser may provide the NRC or any other regulatory agency with any such pro-l prietary information as the NRC or such other agency may require; provided, however, that Purchaser shall firs t 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-pro-prietary. In the event that Company cannot amend such proprietary information, Purchaser shall, prior to disclosing such information, use its be,st efforts to obtain a censitzent from NRC or such other agency to have such information withheld from public inspection.

(2)

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AFf! DAVIT OF JAMES H. TAYLOR (Cont'd)

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

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

Wilcox 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 Babcock & Wilcox, its customers or suppliers.

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b. The information reveals data or material .concerning Babcock

& Wilcox research or development plans or programs of oresent or potential competitive advantage to Babcock &

Wilcox. -

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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 dcta or other similar data concerning a process, method or component, the application of which results in a competitive advantage to Babcock &

Wilcox.

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 Babcock & Wilcox.

f. The information contains ideas for which pttent protection may be sought.

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(3)

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AFFIDAVIT OF J AMES X. TAYLOR (Cont'd)

The document (s) If sted on Exhibit "A", which is attached 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 within one or more of the criteria enumerated above. Exhibit "B", which is attached hereto and made a part hereof, specifically identifies the criteria applicable to the document (s) listed in Exhibit

• A".

(iii) The document (s) listed in Exhibit "A", which has been made avail-able to the United States Nuclear Reguletory Commission or the Atomic Safety and Licensing Board was made available in confidence wf th 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 Combustion Enginee' ring, EXX0N, 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 Itkely to cause harm to the competitive position of Babcock & Wilcox, taking into account the value of the information to Babcock & Wilcox; the amoun*. of effort or money expended by Babcock & Wilcox developing the information; and the i 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) 1sted on Exhibit " A"

. and have found that it is considered proprietary by Babcock 4 i Wilcox because it contains information whi;h falls within one or l

more of the criteria enumerated in Paragraph D, and it is informa-tion which is customarily held in confidence and protected as proprietary information by Babcock & Wilecx. This report com-prises information utilized by Babcock & Wilcox in its business

__ J hich afferd Bab696k 4_Wilcox an ofSortunitJ7 to.obtain_.Q_ _ _ _ _ _ _ _ _ _ _

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Babcock &Wilcox <

those who may wish to know or use the information contained in the docunent(s).

_- 68f &

[ JAMESH.TAY[R State of Virginia)

) SS. Lynchburg City of Lynchburg)

James 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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L A 9' 7t h as

[ JAMESH.TAYLk Subscribed and sworn before me this /r day of 9eArera 1984.

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Notary Public in and for the City of Lynchburg, State of Virginia My Comission Expires ////SA?7 i

, (5)

F i EXHIBIT A

" Assessment of TMI-l Plant Safety for Return to Service Af ter Steam Generator Repair" - GPUN Topical 1<eport No. 008, Rev. 3 l

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EXHIBIT B Description of Material Criteria Figure 1-4, Kinetic Expansion Process, each bracketed entry c,e Section III.D., pg. 25, para. 2, lines 6-10 r,d para 3, lines 11 and 12 c,e para. 3, line 12 c-f pg. 27, first full para., line 6 c-f second para., line 5 c-f third para., line 4 c-f Section V. A.2, pg. 34, lines 6, 7, 9, 10, & 11 c,e pg. 35, line 7 c-f Section V. C.l.a. 6, pg. 38, para. 2, lines 1 & 2 c,e lines 6, 7, 9, & 10 c,d Section V. C. 1.b., pg. 39, para. 3, lines 4 &7 c,d Section V.C.l.c l., pg. 40, para. 2, line 1 c,e Section V.C.l.c.3, pg. 40, para. 2, lines 2, 3, & 4 c,d Section V.C.l.d., pg. 41, para. 2, lines 5 & 6 c,d Section V.C.l.e., pg. 41, para. 2, lines 2 & 3 c,e Section V.C.2.a., pg. 42, para. 2, lines 2 & 3 c,e para. 3, line 7 c-f Section V.C.2.b., pg. 42, para. 2, line 1 c,e para. 3, line 1 c,e l Section V.D., pg. 43, para. 3, line 2 c,e f para. 4, line 2 c,e Section V.D.2., pg. 45, para. 1, lines 3 & 6 c,e pg. 46, carryover para., lines 1-6 c,e para. 1, lines 3 & 4 c,e line 6 c,d para. 2, line 1,5, & 6 c,e para, 3, lines 1, 2, 6, 11, & 12 c,e pg. 47, para. 1, line 1 c,e para 2, lines 1, 2, & 10 c,e para. 3, line 2 c,e

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Refer EXHIBIT A

&enceDocumentNo (f nterrogatorgeg 1

2 3 58-1017613-00 -

4 58-1017505-00 5 58-1017499-01 6 58-1017506-00 7 58-1017507-00 8 58-1017510-00 9 58-1017509-00 IC 58-1017511-00 12 58-1017518-00 19 58-1017517-00 20 58-1017508-00 21 51-114'584-00 22 32-1139261-01 27 58-1017555-00 58-1017556-00 58-1017488-00 l

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EXHIBIT B Reference 1 58-1017513-00 Criteria List of Figures, Fig A7, 5th - 7th words in description c,e List of Figures, Fig A8, 4th - 6th words in description c,e List of Figures, Fig A9, 4th - 6th words in description c,e Section 2.0, Line 6, 1st - 5th words c,e Section 2.0, line 10, 5th - 9th words c,e Section 2.0, line 11,1st - 6th words,14th & 15th words c,e Section 4.3,1st sent, 4th - 13th and 19th words c,e Section 4.4, 2nd sent, 6th - last words c,e Section 6.1, 7 i f nes following " manner" c,e Section 6.1, 2nd paragraph, 1st sentence, 14th word c,e Section 6.2,1st sent 23rd - 27th words c,e Section 6.2.1, last para,1st sent,10th - 14th words c,e Section 6.2.1, last para, 2nd sent, 4th - last words c,e Section 6.2.2,1st sent, 3rd & 4th words Section 6.5, 1st para, 33rd & 34th words c,e Sectior 7.0, 3rd para, 1st sent, 14th & 22nd words c,d Section 7.0, 3rd para, 2nd sent, 8th & 15th words cd Table A-1, " Charge Gr/Ft Inch" column and expansion Procedure c,e l Table A-4, 4th & Sth words of title c,e Table A-7, entire table e,d Table A-8, entire table c,d Figure A-1, Dimensions & Tolerances associated with tube hole spacing including values for ligaments, places b,c Figure A-2, all c,e

! Figure A-8, 4th & Sth words in subtitle c,e l Figure A-9, 4th & Sth words in subtitle c,e I

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Reference 2 EXHIBIT B (continued) 58-1017505-00 (cont.)

Criteria Section 4.3, same as Section 4.3 of Ref 1 above Section 4.4, same ,as Section e 4.4 of r f 1 c,e above Section 6.1, 6 lines following " manner" e,e Section 6.1, 2nd para, last sent c,e Section 6.1, 2nd para, 1st sent , 9th - last words c,e Section 7.0, 1st para, 1st sent , 14th word c,e Section 7.0,1st para,1st sent ,16th - 18th words c,d Section 7.0, 2nd para, 1st sent , 13th - 15th words c,d Section 7.0, 2nd para, 2nd sent , 14th a 22nd wordsc,d Section 7.0, 2nd para, 3rd sent , 8th - 15th words c,d Table B-2, same as Table A-1 of ref 1, 18th -c,e last words above Table B-3, same as Table A-7 of ref I c,e above Table B-4, same as Table A-8 of ref I c,d above Figure B1, same as Figure Al of ref I c,d above Figure B2, same as Figure A2 of ref 1 b,c above Appendix PG 1, columns A & B under " f c,e Appendix PG 9,1st 4 columnseaof ter exp" tabl cd Appendix PG 10, entire table c,d Appendix PG 11, 2nd word, 5th line c,d Appendix PG 14, column labeled "Charunder disposition c,d Expansion Procedure ge Gr/Ft Inch," &

Appendix PG 14, columns A and B abo c,e Reference 3 ve "after exp" 58-1017499-01 c,d Section 4.3, same as Section 4.3 above of ref 1 Section 4.4, same as Section 4 4 c,e Section 6.1, 6 lines following "mann. er" . of ref 1 above c,e

! Section 6.1, 2nd para, 2nd sent ,

c,e Section 7.0, last para 1st sent , 14th word c,e Section 7.0, last para, 2nd sent 14th & 23rd words c,d i

Table C-1, same as Table A-1 of ref 1, 8th & 15th c,d words above Table C-5, same as Table A-7ove of ref 1 ab c,e

\ Table C-6, same as Table A-8 ove of ref 1 ab c,d Figure C-1, same as Figure A-1 above of ref 1 c,6 Figure C-2, same as Figure A-2 above of ref 1 b,c c,e

EXHIBIT B (continued)

Reference 4 58-1017506-00 Criteria Section 4.3, same as Section 4.3 of Ref. I above c,e Section 4.4, same as Section 4.4 of ref 1 above c,e Section 6.1, same as Section 6.1 of ref 3 above c,e Section 7.0, last para,16th & 23rd words of 1 sent c,d Section 7.0, last para, 2nd sent, 8th & 15th words c,d Table D-1, same as Table A-1 of ref 1 above c,e Table D-7, same as Table A-7 of ref 1 above c,d Table D-8, same as Table A-8 of ref 1 above cd Figure D-1. same as Figure A-1 of ref 1 above b,c Figure D-2, same as Figure A-2 of ref 1 above c,e Table 1 in raw data, same as Table D-1 above c,e Table 1 (2nd) in raw data, same as Table D-7 above c,d Last Page in raw data, same as Table D-8 above c,d Reference 5 58-1017507-00 Section 4.3, same as Section 4.3 of ref 1 above c,e Section 4.4, same as Section 4.4 of ref 1 above c,e Section 6.1, same as Section 6.1 of ref 3 above c,e Section 7.0, last para,1st sent,14th & 22nd words c,d Section 7.0, last para, 2nd sent, 8th & 15th words c,d l Table E-1, same as Table A-1 of ref 1 above c,e Table E-5, same as Table A-7 of ref 1 above c,d i Table E-6, same as Table A-8 of ref 1 above c,d Figure E-1, same as Figure A-1 of ref 1 above b,c Figure E-2, same as Figure A-2 of ref 1 above c,e Reference 6- 58-1017510-00 Section 4.3, same as Section 4.3 of ref 1 above c,e Section 4.4, same as Section 4.4 of ref 1 above c,e Section 6.1, same as Section 6.1 of ref 3 above c,e l _ - . - __ __ . _ - - _ _ _ _ . _ _ __ . - - _ . _ _ . _ . -

, .' s EXHIBIT B (continued)

Reference 6 58-1017510-00 Criteria Section 7.0,1st para, 4th sent,14th & 22nd words c,d Section 1.0,1st para, 5th sent, 8th & 15th words c,d Table G-1, same as Table A-1 of ref 1 above c,e Table G-5, same as Table A-7 of ref 1 above c,d Table G-6, same as Table A-8 of ref 1 above c,d Figure E-1, same as Figure A-1 of ref 1 above b,c Figure E-2, same as Figure A-2 of ref 1 above c,e Page.3 of Appendix, same as Table G-1 above c,e Reference 7 58-1017509-00 Section 4.3, same as Section 4.3 of ref 1 above c,e Section 4.4, same as Section 4.4 of ref 1 above c,e Section 6.1, same as Section 6.1 of ref 3 above c,e Section 6.4.1, 3rd para, 2nd sent, 7th word c,d Section 7.0, last para, 1st sent, 13th and 21st words c,d Section 7.0, last para, 2nd sent, 8th and 15th words c,d Section 7.0, last para, 3rd sent,10th - 13th words c,d Table H-1, same as Table A-1 of ref 1 above c,e Table H-6, same as Table A-7 of ref 1 above c,d Table H-7, same as Table A-8 of ref 1 above c,d Figure H-1, same as Figure A-1 of ref 1 above b,c

! Figure H-2, same as Figure A-2 of ref 1 above c,e

! Reference 8 58-1017511-00 1

l l Section 4.3, same as Section 4.3 of ref 1 above c,e Section 4.4, same as Section 4.4 of ref 1 above c,e Section 6.1, same as Section 6.1 of ref 3 above c,e Section 7.0, same as Section 7.0 of ref 5 above c,d l

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EXHIBIT B (continued)

Reference 8 58-1017511-00 Table S-1, same as Table A-1 of Ref 1 above c,e Table S-7, same as Table A-7 of Ref 1 above c,d Table S-8, same as Table A-8 of Ref 1 above c,d Figure S-1, same as Figure A-1 of Ref 1 above b,c Figure S-2, same as Figure A-2 of Ref 1 above c,e Reference 9 58-1017518-00 Section 4.3, same as Section 4.3 of Ref 1 above c,e Section 4.4, same as Section 4.4 of Ref 1 above c,e Section 6.4, Second Sentence c,e Section 7.0, column labeled " Pullout Load" c,d Table AF-1, column labeled " Change Grain /f t" and all c,e six lines in two columns at the bottom of page Figure AF-2, Entire figure c,e Reference 10 58-1017517-00 Section 4.3, same as Section 4.3 of Ref 1 obove c,e Section 4.4, same as Section 4.4 of Ref 1 above c,e l

Section 4.5,1st - 3rd words in title, 7th - 9th and c,e l 14th - 17th words in first sentence and 2nd word in

( second sentence l

Section 6.1,1st paragraph, last sentence, lith - last c,e words Section 6.1, 3rd paragraph, 4th sentence, 3rd - 5th c,e words and last sentence 2nd - last words Section 6.1, 4th paragraph, 6th - lith words c,e Section 7.0, 2nd paragraph, column headed " Pullout Load" c,d Table 1, column labeled " Charge Grain /f t Inches" c,e Figure 1, entire figure c,e 1

EXHIBIT B (continued)

Reference 12 58-1017508-00 Section 4.3,1st sentence, 4th - 13th and 19th words c,e Section 4.4, last snetence,15th - last words c,e Section 4.5,1st - 3rd words in title, 7th - 9th and c,e 14th - 18th words in 1st sentence and 2nd word in 2nd sentence Section 6.7, 4th - last words in title,1st paragraph c,e 3rd word in 1st sentence, 8th - 10th words in 2nd sentence; 2nd paragraph, 7th - 9th words in last sentence Section 6.9, all c,e Section 7.0, cneter 2 columns in Table c,d Section 7.0, center column in 2nd table c,d Figure 1, all c,e Figure 2, data below " Sample Description" and 2nd c,e and 3rd enlumns -

Appendix, 2nd - 5th pages, all c,d,e Reference 19 51-1141584-00 List of Figures, line 2 - 6, 4th word c,e List of Figures, line 2 - 10,1st and 2nd words c-f Page 11, line 20, 7th and 8th word c.e Page 12, line 4, 5th word; 2nd full paragraph, 2nd c,e sentence all and 3rd sentence,1st - 7th wods; indented table, all; 3rd paragraph, last sentence, all Page 13, line 15, 2nd - lith words; line 18, 6th & 7th c,e words; line 20 5th & 6th woerds; line 22, last word through line 23, 4th word Page 14, line 1, last 2 words; line 4, 3rd & 4th words c,e Page 15, line 11,1st - 4th words; line 15, 3rd - 8th c,e words; line 20, last 2 words l

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EXHIBIT B (continued)

Reference 19 51-1141584-00 Criteria Page 16, line 4, last 2 words and line 5 first 3 words c,e Page 16, line 9, first 2 words; line 11, 5th word; line c-f 12, lith word through line 131st word; line 13, 6th &

7th words, line 15, 5th word; line 17, 5th word; line 19 2nd word, last line, 7th word Page 30, line 5, 5th & 12th words; line 6, 9th word c,d Page 31, line 11, 8th word; line 12 4th word; line 16, 9th word Page 32, line 8, 3rd & lith words; line 10, 10th word c,d Page 33, line 2, 3rd & lith words; line 5, 12th word; c,d line 6,1st word; line 14, 9th word; line 15, 3rd word; line 16, 1st word Page 34, line 10, 13th word; line 11, 5th & lith words c,d Page 36, column labeled " Test Results" c,d Page 38, line 9, 3rd & 4th words c-f Page 41, line 21, 1st word; line 22, 13th word c,d Page 42, Equation, value in numerator c,d Page 42, line 15, 7th & 8th words c,e Page 43, line 5, IP.th - 14th words c,d Page 43, line 12, 6th & 7th words c,e Page 45, last para, last sent, 8th - last words c,e Page 53, Table 4-1, lines 6 & 7. Under column "Value" e Page 56, all information associated with tube pitch e Page 62, Figure 2-5, entire figure c,e Page 63, Figure 2-6, entire figure c,e Page 66, Figure 2-9, entire figure c,e Page 67, Figure 2-10, entire figure c-f Page 70, Figure 3-3, entire figure b,c Page 71, Figure 3-4, entire figure c,d Page 74, Figure 4-2, values within tube c,d Reference 20 32-1139261-01 Page 3, all c,d Page 4, lines 14 & 15, all; line 16, 2nd word c,d Page 5, column labeled " Block B" c,d

EXHIBIT B (continued)

Reference 20 32-113926_1-01 Cri teria Page 6, line 3, 3rd word; line 4, 2nd word, line 11, c,d 1st & 3rd words; line 12,1st word; line 13, 2nd word Page 7, if ne 10, 2nd squareroot symbol, 2nd & 4th values c,d parenthesized; line 17, values in 20d set of absolute value symbols Page 8, columa labeled " Block G"; 3rd line below table, c,d 3rd word; 4th line below table 2nd word; next to last line,1st, 3rd, & Sth values to right of 2nd equals symbol; last line, value to right of "Since" Page 9, line 10, 2nd square root symbol, 2nd & 4th values c,d parenthesized; line 12, values in 2nd set of absolute value symbols Page 10, last equation, value between equals symbols c,d Page 11, column below location "8" & to right of "X " - c,d "X "; 2nd to last equation, value to left to "16"; last egn., value to right of "="

Page 12, line 8, value to right of 2nd "=" and value in c,d parentheses; 2nd to last egn., value to right of "="

ar.d value in parenthesis; last egn., 1st value in numerator and value in denominator Page 13, last egn. , value to right of ist & 2nd "=" and c,d value in parentheses; last inequality, value to left of N H i

Page 14, line 8, 2nd square root symbol, 2nd & 4th values c,d i

parenthesized; line 10, values in 2nd abs. value symbols Page 15, column labeled " Block H"; 2nd to last egn. , c,d value in numerator to right of 2nd "=", value to right of 3rd "="; last egn. , value to left of "16" Page 16, line 6, 1st value; line 7, 1st value; line 9, c,d 2nd value Page 17, line 10, 2nd sqr. root symbol, 2nd & 4th values c,d parenthesized; last eqn., values in 2nd abs. value symbol s.

e.... EXHIBIT B (continued)

Reference 20 32-1139261-01 Criteria Page 18, column labeled " Block SP-1"; 1st line af ter c,d table, value in numerator to right of 2nd "=', and value to right of 3rd "="; last eqn., values to right of 2nd & 3rd "=", value in parentheses; 2nd to last line, values to right of "Since" Page 19, same as page 17 c,d Page 26, columns labeled " Sample Mean" and " Calculated c,d Limit" between " Pullout Load" and " Leakage" Reference 21 58-1017555-00 Criteria Section 4.3, same as Section 4.3 of Ref 1 above c,e Section 4.4, same as Section 4.4 of Ref 1 above c,e Section 6.1, six lines following " manner" and 17th word c,e in 2nd sent. of 2nd para.

Table 1, column labeled " Change Gr/f t inch", information c,e on 2 lines following " Explosives From", information af ter " Expand as follows:"

Table 2, same as Table 1 c,e Figure 1, all dimensions relating to hole spacing & b,c ligament thickness (8 places)

Figure 2, entire Figure c,e l

Appendix 2nd page, same as Table 1 c,e Appendix 45th page, same as Table 1 c,e Reference 22 58-1017556-00 Criteria Section 4.3, same as Section 4.3 of Ref 21 above c,e Section 4.4, same as Section 4.4 of Ref 21 above c,e Section 61, six lines following " manner:" and 15th word in 2nd sent. of 2nd para.

Table 1, same as Table 1 of Ref 21 above c,e Figure 1, same as Figure 1 of Ref 21 above b,c l Figure 2, same as Figure 2 of Ref 21 above c,e Appendix, 2nd page same as App., 2nd page of Ref 21 above c,e Reference 27 58-1017488-00 Criteria entire document c,d,e

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