ML20150F805
| ML20150F805 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 07/11/1988 |
| From: | Kingsley O SYSTEM ENERGY RESOURCES, INC. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML19292J072 | List: |
| References | |
| NUDOCS 8807190067 | |
| Download: ML20150F805 (6) | |
Text
f EYSTEM ENERGY RE50tJRCES, INC.
Co.to D V w a n D July 11, 1988 vu.nmow weicw=ws U. S. Nuclear Regulatory Commission Mail Station P1-137 Washington, D. C.
20555 Attention: Document Control Desk Gentlemen:
SUBJECT:
Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-29 Low Pressure Turbine Inspection AECM-88/0125 Information on the Low Pressure Turbine Inspection was requested on March 7, 1988 in a telephone conversation with L. L. Kintner of the NRC Staff.
?his inspection was performed at refueling outage 2 in accordance with Grand Gulf Nuclear Station Facility Operating License 2.C.(26).
The following information on the Low Pressure Turbine Inspection is provided as an attachment to this letter:
o Personnel Qualification o
Equipment o
Rotor Disk Preparation for Inspection o
Calibration o
Scanning Speed o
Inspection Techniques o
Data Recording o
Evaluation of Techniques and Procedures o
Inspection Results The personnel qualifications of inspectors are summarized in the introduction to the attached report.
The Level III inspector's certification is provided and is translated from German into English. However supporting documents for this inspector are in German.
The attached report is cersidern praprietary to Utility Power Corporation, and System Energy Resources Inc. rLquests that the reports be processed accordingly.
In accordance with 10CFR2.790 please find the attached affidavit attesting to the appropriateness of proprietary treatment of the report entitled, "Number 3 Low Pressure Turbine Rotor Ultrasonic Inspection Summary."
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t AECM-88/0125-Page 2 If. additional information is required, please contact this office.
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g ODK:wjb Attachment cc: Mr. T. H. Cloninger (w/a)
Mr. R. B. McGehee (w/a))
Mr. N. S. Reynolds (w/a Mr. H. L. Thomas (w/o)
Mr.R.C. Butcher (w/a)
Dr. J. Nelson Grace, Regional Administrator (w/a)
U. S. Nuclear Regulatory Commission Region II 101 Marietta St., N. W., Suite 2900 Atlanta, Georgia 30323 Mr. L. L. Kintner, Project Manager (w/a)
Oft' ice of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 14820 1
Washington, D.C.
20555 t
J14AECM880614 - 2 L.
4 AFFIDAVIT UNDER 10 CFR 2.790 State of Florida
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County of Manatee
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I, Thomas E. Arneson, been duly sworn, depose and say as follows:
1.
I am Manager of Administrative Services for the Utility Power Corporation, a corporation of the State of Delaware having offices at Bradenton, Florida, and have been delegated the function of reviewing the information described in Paragraph 2 hereof, which is sought be withheld, and been authorized to apply for itu withholding on behalf of Utility Power Corporation.
2.
The information which is sought to be with.a A pertains to proprietary information in an innpoetion repcrt termed the "Grand Gulf LP3 Rotor Disc Inspection" for a steam turbine generator, otherwise known as TWQ 1900/87 and dated March 3, 1988; 3.
In designating this material as confidential, Utility Power Corporation utilizes and hereby refers to the definition of proprietary information and trade secrets which is set forth in the Restatement of Torts, Section 757 published by the American Law Institute.
This definition provides, among other things, as follows:
"A trade secret may consist of any formula, pattern, device, or compilation of information which is used in one's business and which gives him an opportunity to obtain an advantage over competitors who do not know or use it..."
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Factors utilizCd by Utility PoWor Corporction in dotormining wh2 thor specific information should be characterized are:
a) the extent to which the information is known outside of its business; b) the extent to which the information is known to employees and others involved in its business; c) the extent of measures taken by it to guard the secrecy of the information; d) the value of the information to it and its competitors:
e) the amount of effort or money expended by it in developing the information; and f) the ease or difficulty with which the information could be properly acquired or duplicated by others.
4.
Types of information which are considered by Utility Power Corporation to come within the above definitions include procedures; applied inspection techniques; test instruction; specifics of a test device, i;..iuding manipulator and ultrasonic test devices, recorders and associated magnetic tape data storage; test probe information; and the adjustments, measuring and controls which are associated with the observation and recording of data.
Specifically critical propriesary information in the subject Grand Gulf LP3 Rotor Disc Inspection report includes information relative to the inspection zone of the LP discs; the positioning of the measuring equipment; the ultrasonic probe and type selection; corrections made for measurements; and calibrations specifications.
- 5. Utility Power Corporation is a licensee of Siemens Aktiengesellschaft of West Germany.
Siemens AG along with a related corporation, Kraftwerk Union Aktiengesellschaft (which has been merged into Siemens AG) have long been active in the development of highly confidential, unique and proprietary technical and business information, including information with respect to steam turbines and tutbine generators.
Siemens AG (and formerly Kraftwerk Union) have
(
I in piece extensive programs and regulations for maintaining the secrecy and proprietary nature of such information.
As a licensee of Siemens AG and/or Kraftwerk Union, Utility Power Corporation is obligated to maintain the secret nature of such information.
Further, review of and approval for proprietary treatment of document and other media bearing confidential and proprietary information is nade by Pritam Bhavna'.41, General Manager of the Product Service Divsion of Utility Tower Corporation who is likely to be acquainted with the value, applicability, and sensitivity of the information, along with its value to the industry Access to such documents both within and without the company is limited on a "need-to-know" basis and such documents are clearly identified as proprietary.
Utility Power Corporation further regularly requires confidentiality agreements of its suocontractors, customers, potential customers, and vendors in order to maintain the trade secret and strictly confidential status of these materials.
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- 6. The document referred to in Paragraph 2 above has been evaluated in accordance with the above criteria and has been found by the undersigned to contain information which proprietary to and is held in confidence by Utility Power Corporation.
7.
The information referred to herefn L.o come to the best of my knowledge and belief '.een consistently held in confidence by Siemens AG (previously Kraftwerk Union) and by Utility Power Corporation and no public disclosure thereof has been made; and it is not available to the public from any known source.
All disclosures to third parties insotar as I know of them have been made pursuant to Proprietary agreements which provide for the maintainence of the information in confidence.
l 8.
Public disclosure of the information sought to be withheld is likely j
to cause substantial harm to the competitive position of Utility Power Corporttion and/or Siemens AG and deprive them of or reduce the availability of profit making opportunities to these corporations.
This is demonstrated, at least in part, by the fact that the test
equipment, of which specifics a"e available from the report mentioned in Paragraph 2 hereof, took six years to develop at a cost of approximately U.S.
$2,500,000.
9.
Public availability of this information would deprive Utility Power Corporation (and Siemens AG) of the ability to seek reimbursement 'or its use or disclosure and would permit competitors to utilize this information and/or replicate the equipment referred to, to the detriment of Utility Power Corporation and/or Siemens AG.
- 10. I have read the foregoing affidavit and the matter stated therein are true and correct to the best of my knowledge, information, and belief.
Further deponent sayeth not.
Auc.i
- w-W Thoman E.
Arneson Manager, Administrative Services i
Utility Power Corporation da StuteofFpo County of z#
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