ML20126A265

Requests That Proprietary WCAP-10756, Prairie Island Units 1 & 2 Steam Generator Sleeving Rept (Mechanical Sleeves), Be Withheld from Public Disclosure (Ref 10CFR2.790). Affidavit Encl

ML20126A265
Person / Time
Site:	Prairie Island
Issue date:	03/07/1985
From:	Wiesemann R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML19344C015	List: ML20126A251 ML20126A265
References
CAW-85-022, CAW-85-22, TAC-57847, TAC-57848, NUDOCS 8506130287
Download: ML20126A265 (10)

Text

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.J Water Reactor Nuclear Tei.hnc!cgy Division Westinghouse Electric Corporation Divisions sax 353 PittsburghPennsylvarua15230 March 7,1985 CAW-85-022 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 APPLICATION FOR WITHH0LDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

SUBJECT:

Prairie Island Units 1 and 2 Steam Generator Sleeving Report-WCAP 10756 Refe rence : Le tte r_ f rgm_No rthe rn,S ta te s _Pgwe r _Ag 2 r i l _19@@___ ___ _ _______ ___ _______ __ _

Dear Mr. Denton:

The proprietary material for which withholding is being requested in the reference letter by Northern States Power is further identified in an affidavit signed by the owner of the proprietary information, Westinghouse Electric Corporation. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b) (4) of 10CFR Section 2.790 of the Commission's regulations.

The proprietary material for which withholding is being required is of the same technical type as the proprietary material previously submitted with Application for Withholding CAW-83-48.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Northern. States Power.

Corresonpdence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-85-022,and should be addressed to the undersigned.

Ver truly yo rs,,

Ro ert A. Wiesemann, Manager Regulatory & Legislative Affiars

/ jag Enc 1 cc: E. C. Shomaker, Esq.

Office of the Executive Legal Dir. NRC 8506130287 850603 PDR ADOCK 05000282 P PDR

y fW) o Water Reactor Nuclear Technology Divis:cn Westinghouse Electric Corporation Divisions 80, 333 PittsturgnPennsylvania15230 March 25,1985 CAW-85-027 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC OISCLOSURE SUB. LECT: Prairie Island Units 1 and 2 Steam Generator Sleeving Report WCAP 10815

Reference:

Letter from Northern States Power. April 1985

Dear Mr. Denton:

The proprietary material for which withholding is being requested in the reference letter by Northern States Power is further identified in an affidavit signed by the owner of the proprietary information, Westinghouse Electric Corporation. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Consnission and addresses with specificity the considerations listed in paragraph (b) (4) of 10CFR Section 2.790 of the Commission's regulations.

The proprietary material for which withholding is being required is of the same technical type as the proprietary material previously submitted with Application for Withholding CAW-83-48.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Northern States Power.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter CAW-85-027 and should be addressed to the undersigned.

V ly yours,

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l l R. A Wiesemann, Manager Reg atory & Legislative Affairs

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! cc: E. C. Shomaker, Esq.

Of fice of the Executive legal Dir. NRC

-LAC /0264n/3-85 I:

PROPRIETARY INFORMATION NOTICE TRANSMITTED HEREWITH ARE PROPRIETARY AND/OR NON-PROPRIETARY VERSIONS OF DOCUMENTS FURNISHED TO THE NRC IN CONNECTION WITH REQUESTS FOR GENERIC AND/OR PLANT SPECIFIC REVIEW AND APPROVAL.

IN ORDER 70, CONFORM TO THE REI)UIREMENTS OF 10CFR2.790 0F THE COMMISSION'S RESULATIONS CONCERNING EE PROTECTION OF PROPRIETARY INFORMATION SO SUBMITTED TO THE NRC, THE INFORMATION WHICH IS PROPRIETARY IN THE PROPRIETARY VERSIONS IS CONTAINED WITHIN BRACKETS AND WHERE THE PROPRIETARY INFORMATION HAS BEEN DELETED IN THE NON-PROPRIETARY VERSIONS ONLY THE BRACKETS REMAIN, THE INFORMATION THAT WAS CONTAINED WITHIN THE BRACKETS IN THE PROPRIETARY VERSIONS HAVING BEEN DELETED. THE JUSTIFICATION FOR CLAIMING THE INFORFATION SO DESIGNATED AS PROPRIETARY IS INDICATED IN BOTH VERSIONS BY MEANS OF LOWER CASE LETTERS (a) THROUGH (g) CONTAINED WITHIN PARENIHESES LOCATED AS A SUPERSCRIPT IMMEDIATELY FOLLOWING THE BRACKETS ENG.0 SING EACH ITEM OF INFORMATION BEING IDENTIFIED AS PROPRIETARY OR IN THE MARGIN OPPOSITE SUCH INFORMATION. THESE LOWER CASE LETTERS REFER TO THE TYPES OF INFORMATION WESTINGHOUSE CUSTOMARILY

! HOLDS IN CONFIDENCE IDENTIFIED IN SECTIONS (4)(ii)(a) throu6h (4)(ii)(g) 0F THE AFFIDAVIT ACCOMPANYING THIS TRANSMITTAL PURSUANT 1010CFR2.790(b)(1).

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.Sefere me, the undersigned authority, personally appeared Robert A. Wiesemann, who, being by me duly sween ac: ceding to law, deposes and says that he is authorized to executa tais Affidavit on -

behalf of Westinghouse ElectMc ,Carporation ("Westingneuse") and : hat the avennants of fact set forth in this Affidavit are true and correct to the best of his knowledge, infennation, and belief:

4 b. GUHiN4L G Rccert A. Wiesemann, Manager Regulatory and Legislative Affairs f

Sworn to and subscM bed before se this [ day of m b [ d - 1980. '

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Notary Nol;i,'c

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r (1) I am '4anagar of Requianry anc Lagislative Af" airs in one .'luclear Tecnnciogy Jivisicn of 'Jestingneusa Elect-ic Cceparaden, and as suen, I have been s:acifically ca!egatad the func:icn of. reviewing.

the prcprietary infcmatica scught .s be withheld fica 'pu:lic dis-closure in c:nnec:4cn with nuclear pcwer plant Ticanning er rule-making precandings, and am authertzad := apply for its witanciding on behalf of the Wesdnghouse 'datar Reac=r Divisions.

(1) I am making this Af'idavit in c nfcmanca with i:he previsiens of 10CFR Section 2.790 of the Ccmissien's regulations and in c:njunc-tion w4th the Westingneuse applicaden for withholding ac=meanying this Affidavit. .

(2) I have personai knowledge of the criteria and procadures utilized by Westinghouse Nuclear En$rgy Systams in designating information as a t.tde secret, privileTed or as c:nfidential c:mercial or .

f4nancial informat4cn.

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(4) Pursuant to the previsicris of parsgraph (b)(4) of Secden 2 ;790 of

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taa-Ccmission's regulations, the fcilowing is furnished for c:n- .

sid5 ration by the Ccmmission in datarmining whether the infomation sought t: be withheld frem public disclosure should be withheld.

(.1 ) The infernation scught t: be withheld frem public dis- -

l closure is owned and has been he'id in c:nfidenca by l Westinghouse.  ;

j (ii) The infer =ation is of a type cusmrily held in c:nfi-danca by Wesdnghcuse and not cust:marily disclosed u the l

public. Wesdnghcuse has a rational basis for detar-nining the types of infernaden cust:marily held in c:nfidenca by it and, in that c:nnecticn , utili:ss a systam :: detarmine i when and wnerner a nold car. sin :yces of infoma:icn in l

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c:nfidenca. Tne acclicaden of cat systam and .he suc-tunca Of dat systam.c:nsttutas Wesdnghcusa ;clicy anc :rovices tne radenai hasis required.

l (Jacer that systam,. infomaten is held. in c=nfidenca if it falls in one or more of several types, the releasa of which might resuit in the Toss of an eMsting er potantial c=mmetitive advantag's, as fc11cws:

. (a) The infomation reves.ls the distinguishing aspec.s of a precass (or c=mponent, structure, t:cl, matted, etc.) where prevention of its use by any of Wesdngneuse's l ,

, c=mpetitors without license from Westinghouse c:nsti-tutes a c=mpetitive econcaic advantage over other -

companies. - -

4 It consists cf suaperting data. including test data, I

(h) ..'

relativ.e to a. process '(or component, structure, tact ,

method, etc.), the applicaden of which data secures

., a. c=mpetitive economic advantage, e.g. , by optimi:ation f _

or improved. marketability.'

(c) Its use by a. c=mpetitar would reduca his expenditure of resourcas or improve his c=mpetitive positien frf'

- the design, manufacture, shipment, instal 1ation, assur.'

ance of quality, or licensing a similar pecduct. .

(d) It reveals cost or price infomatica, producten cacac-

- ities, budget levels, or c=nnerdal strategies of Wesdnghouse, its cust:mers or suppliers.

(e) It reveals aspects of past, present, or future Westingneuse or cus :r er fundec develecant plans anc cr$r?-s of pacancial c:r=arcial value :s *!astingncuse.

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{i,, .4. AW-80-U (f) It c:nuins ;a anucle' iceas, for wnich ;atant pre-tacticn may be desiramie.

(g) It it not the ;ropen/ cf Wesdnghcuse, but must be trattad as procrieury by Westinghcuse ac:=rdng t=

agreements with the cwner.-

There are scund ;citey reascnt behind ete Westingneuse systam which include the felicwing:

The use of such infomation by Wesdnghouse gives (a)

Wesdngneuse a c:mpe:1tive advantage over its competitors.

It is, therefore, withheld from disclosure to protect the Westinghouse c=mpedtive position.

(b) It is infomatierr which is marketable in many ways.

. The extent to which such indemation is a'vailahle tc c=mpetttars diminishes the Westingneuse ability a sail pr: ducts and services involving the use of :ne infomadon.

l (c) Use by our c=mpetitor would .ut Westingneuse at a j competitive disadvantage by . :. ucing his excenditure of resources at our expense.

(d) Each c=mpenent of preprietary infomedon pertinent to a'particular c:mcatitNe advantage is potentially as valuable as the tstal c=mmetitive advantage. If concetitors ac:;uire c mpenents of proprietary inferr.a-tien, any one c=mcenent may be the key to the entire pu::le, thereby deceiving Westingneuse of a ec=cetitive advantage.

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.- n.-ou-:.s 1 (e) UnrestMc ad disclosure wculd jaccarti:e the ;csition of prominenca of Westinghcusa in the world marxat, and theracy give a market advanuge to the c,::mcatition in those countM es.,.,

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(f) The Westinghouse capacity to invest corporata assats.

in research and development decends upon the succass

, in obtaining and maintaining a c::meetitive advanuge.

(iii) The infonnation is being transmittad ts the Commission in confidenca and, under the previsions of 10CFR Section 2.790, it. is to be recaived in confidenca by the Ccmission.

(iv) The infonnation sought to be protectad is not availacle in ,

public sourcas to the best of our knowled:;e and belief.

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s (v) The proprietary information sought to be withh' eld in this submittal is that whictr is appropriataly marked Sii-57-'0(20)

"Scuthern California Edison Repair.Recort" (Proprietary).

This report has been prepared for an,d is being submittad to the Staff at tha request of Southern California Edisen.

The resc're details the design of the sleeves that are to be -

installed in the San Onofre Unit I staam generators. The report. also includes the design analysis, the cast verifica,-

tion program and descriptions of the expanded mechanical plug, the rolled plug and the channel head decantaminatien precass.

This infennatien is part of that which will' enable Westingneuse to:

(a) Acply for parant protection.

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(b) Opti:ni:n s.aam genert::r escair technicues : ex.and ce servica life of s aam generst:rs.

(c) Assist its cust:mers .d catain NRC appreval.

(d) Justtfy the design basis for the staam generat:r repairs and installation macods.

Further, this information has substantial c:mercial value

. as follows: '

(a) Westinghouse plans to sell the repair tachnicues and equipment described. in part by the infonnation.

(b) Westinghouse ca,n sail repair services based upon the experience gained' and ca. installation equipment '

and methods developad.

Public d.fsclosure of this infernation is likely to cause sUhstantial har.n to the c=mpetitive position of Westinghouse becausa (1) it would result in the loss of valuable patent Mghts, and (2) it would enhanca the ability of c:mpetitors i

to design, manufacture, verify and sell steam generator repair techniques for c=mercial power reacters without <

comensurata expenses.

l The development of the methods and ecuipment described in 7

part by ce information is the result of applying ne results i of many years of expeMenca in an intansive Westingneuse effort and the expenditure of .4 c:nsiceracle sum of =cney.

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7 AW-40 52 In crder for c:=caticrs of Westinghcusa .s du:lica a. dis infer.::stien, similar engineering ::regrams would have .: be

erd er.ried and a significant mancewer effort, having . e requistte talent and ext

erienca, would have om be ex;: ended for stana generatar regair tac ~.niques.

Furcer de descnent sayeth not.

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