ML20138H084
| ML20138H084 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/29/1997 |
| From: | Jain S DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9705070067 | |
| Download: ML20138H084 (5) | |
Text
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j Beav Valley Power Statnon l
SNppingport. PA 15077-0004 l
SUSHIL C. JAIN (412) 393 5512 Sa"rIrvic7. *"
April 29, 1997 Nuclear Power Division U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001
Subject:
Beaver Valley Power Station, Unit No. I and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Proposed Operating License Change Request Nos. 237 and 111 Revised Affidavit Attached is a revised affidavit in support of Technical Specification Change Nos.
237 and 111 for Beaver Valley Power Station, Unit Nos. I and 2, respectively.
Proprietary information and an affidavit were submitted with the proposed amendment 1
by letter dated March 10, 1997. Combustion Engineering, the owner of the proprietary information, has provided a revised affidavit to correct the date referenced for the proprietary information provided with the proposed amendment.
Therefore, it is I
requested that the affidavit provided in the original submittal de replaced with the l
attached revised copy.
t Sincerely, l
0, Sushil C. Jain c:
Mr. D. M. Kern, Sr. Resident Inspector Mr. H. J. Miller, NRC Region I Administrator Mr. D. S. Brinkman, Sr. Project Manager Mr. W. P. Dornsife, Director BRP/DEP Mr. M. P. Murphy (BRP/DEP) 9705070067 970429 7
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AFFIDAVIT PURSUANT
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j TO 10 CFR 2.790 l
1, Ian C. Rickard depose and say that I am the Director, Operations Licensing, of Combustion Engineering, 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 conjunction with the application of Duquesne Light Company and in conformance with the provisions of 10 CFR 2.790 of the Commission's regulations.
The information for which proprietary treatment is sought is contained in the following j
documents:
1.
CEN-629-P, Rev. 02, " Repair of Westinghouse Series 44 and 51 Steam Generator Tubes Using Leak Tight Sleeves," January 1997.
2.
Addendum 1 to CEN-629-P, " Repair of Westinghouse Series 44 and 51 Steam i
Generator Tubes Using Leak Tight Sleeves," January 1997.
These documents have been appropriately designated as proprietary.
1 i
I have personal knowledge of the criteria and procedures utilized by Combustion Engineering in designating information as a trade secret, privileged or as confidential l
commercial or financial information.
l Pursuant to the provisions of paragraph (b) (4) of Section 2.790 of the Commission's regulations, the following is fumished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure, included in the a
above referenced document, should be withheld.
I b
l 4
i i
l 1.
The information sought to be withheld from public disclosure, is owned and l
has been held in confidence by Combustion Engineering. It consists of f
information concerning the steam generator tube repair process of sleeving, including qualification program results and analyses.
2.
The information consists of test data'or other similar data concerning a process, method or component, the application of which results in i
l substantial competitive advantage to Combustion Engineering.
(
3.
The information is of a type customarily held in confidence by Combustion l
l Engineering and not customarily disclosed to the public. Combustion Engineering has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a t
system to determine when and whether to hold certain types of information in confidence. The details of the aforementioned system were provided to L
the Nuclear Regulatory Commission via letter DP-537 from F. M. Stern to Frank Schroeder dated December 2,1974. 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.
1 l
6.
Public disclosure of the information is likely to cause substantial harm to the t
l competitive position of Combustion Engineering because:
4 i
a.
A similar product is manufactured and sold by major i
i pressurized water reactor competitors of Combustion Engineering.
I.
i
-3 i
l b.
Development of this information by Combustion Engineering required millions of dollars and thousands of manhours of effort. A competitor would have to undergo similar expense in 4
generating equivalent information.
c.
In order to acquire such information, a competitor would also require co$siderable time and inconvenience to develop an understanding of welded steam generator tube sleeve f
installation problems and evaluate specific examples based i
on test or pulled steam generator tube data and develop and qualify a steam generator tube sleeving program, j
d.
The information consists of a description of the steam generator tube repair process of sleeving, including j
qualification program results and analyses, the application of which provides a competitive economic advantage. The availability of such information to competitors would enable them to modify their product to better compete with Combustion Engineering, take marketing or other actions to improve their product's position or impair the position of Combustion Engineering's product, and avoid developing
- imilar data and analyses in support of their processes, methods or apparatus.
e.
In pricing Combustion Engineering's products and services, significant research, development, engineering, analytical, manufacturing, licensing, quality assurance and other costs and expenses must be included. The ability of Combustion Engineering's competitors to utilize such information without similar expenditure of resources may enable them to sell at prices reflecting significantly lower costs.
f.
Use of the information by competitors in the international marketplace would increase their ability to market nuclear steam supply systems by reducing the costs associsted with their technology development. In addition, disclosure would have an adverse economic impact on Combustion Engineering's. *ential for obtaining or maintaining foreign licensees.
Further the deponent sayeth not.
w&J lan ector Operations Licensing Swom to before me this /<f day of M-
.1997
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Notary Public 3/!79 My commission expires: