ML20082F160

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Forwards Rev 5 to Beaver Valley Power Station Q*5 - List Rules, Per 831104 Response to Generic Ltr 83-28,Position 2.2.1.2.Affidavit Encl.Rept Withheld (Ref 10CFR2.790)
ML20082F160
Person / Time
Site: Beaver Valley
Issue date: 11/21/1983
From: Carey J
DUQUESNE LIGHT CO.
To: Eisenhut D
Office of Nuclear Reactor Regulation
Shared Package
ML19274C138 List:
References
GL-83-28, NUDOCS 8311280451
Download: ML20082F160 (3)


Text

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'Af Telephone (412) 393-6000 Nuclear Division P.O. Box 4 Shippingport, PA 15077-0004 November 21, 1983 firector of Nuclear Reactor Regulation United States fiuclear Regulatory Commission Attn: fir. D. G. Eisenhut, Director Divisior, of Licensing Washingtor., DC 20555

Reference:

Beaver Valley Power Station, Unit No.1 Docket No. 50-334, License No. DPR-66 Applicaticn for Withholding Proprietary Infomation from Public Disclosure Gentlemen:

Enclosed is the Beaver Valley Power Station Q*5 - List Rules ref erenced as an attachment in our response to Generic Letter 83-28 Pos16:en 2.2.1.2 dated November 4,1983.

This document is proprietary to the (uadrex Corporation, and accordingly, it is respectfully requested that this infomation which is further identified in the enclosed affidavit be withheld from public disclosure in accordance with 10CFR Section 2.790 as amended.

Ver uly yours, s

. J. Carey Vice President, Nuclear cc:

U. S. Nuclear Regulatory Commission Division of Licensing Attn: Mr. Steven A. Varga, Chief Operating Reactors Branch No. 1 Division of Licensing Washington, DC 20555 Mr. W. fl. Troskoski, Resident Inspector U. S. Nuclear Regulatory Commission Beaver Valley Power Station Shippingport, PA 15077 8

I 8311280451 831121 PDR ADOCK 05000334 P

PDR

STATE OF CALIFORNIA

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COUNTY OF-SANTA CLARA) SS RONALD L.-NAYMARK, being duly sworn, deposes and says:

1.

He is Vice President of Quadrex Corporation and, among other responsibilities, has been delegated the responsi-bility of-reviewing, identifying and establishing procedures for protecting confidential and proprietary information.

He has the authority to make application for the withholding of the information referred to below from public disclosure; and 2.

The information sought to be withheld from public disclosure is that certain document entitled Q*5 List Rules for the Beaver Valley Power Station dated July 26, 1983.

The basis for withholding such information is that it is proprietary and confidential to Quadrex Corporation; and 3.

The data contained in such document was developed using-Quadrex' independent research and development funds.

The information is not available publically.

It consists of the basic methodology used by Quadrex for quality analysis of.

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components in nuclear power plants.

The methodology involves systematically identifying, analyzing and classifying plant components, according to their safety-relatedness, in much more detail than in conventional Q-Lists.

As a tool for this process, Q*5 rules are based en NRC dtandards and requirements in a format'applicabic and readily usable for the specific Q*5 methodology.

The results of classification are presented in reports and computer outputs.

Q* is a registered service mark of

-Quadrex.

Disclosure of Quadrex' Q*5 methodology would cause substantial harm to Quadrex' corporate position.

Such disclosure would permit others to offer services similar to the services 2

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offered by Quadrex without th'e need for the expenditure of

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research and development funds and unnecessarily deprive Quadrcx of its competitive position in the marketplace.

The withholding of the confidential information will not deprive the NRC of its need to review the information.

4.

Quadrex Corporation holds this information in confidence and it is of the type generally held as confidential by Quadrex.

Quadrex has an established procedure for the identification, labelling and protection of its confidential

'information and trade secrets..Once particular information is identified as confidential, Quadrex controls its distribution to its own employees on a need-to-know basis and does not disclose the information to any third party or to its customers without first having a' written nondisclosure agreement.

The information sought to be withheld has been so treated and is or will be furnished to the NRC in confidence.

5.

Based on the foregoing, Quadrex Corporation requests that the Q*5 List Rules for the Beaver Valley Power Station dated July 26, 1983 be treated as proprietary and confidential information and that the information be withheld from public disclosure.

/ J[

RONALb L. N ARK f

Subscribed and sworn to before me on this lith day of November, 1983.

i CM NA CY V/

IFFIN

%If NEYY[A Not hy PubliE for the

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A LA comm. en. u, 2s,19s7 State of California eeee4,wacace+e+++++++4ee _- - - -

My Commission expires:

July 28, 1987 i