ML20210T795

Forwards Proprietary Info in Support of Plant'S Amend Application That Proposes Installation of Electrosleeves in Callaway Plant Sgs.Encl Withheld,Per 10CFR2.790

ML20210T795
Person / Time
Site:	Callaway
Issue date:	09/10/1997
From:	Naslund C UNION ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19317C716	List: ML20210T795
References
TAC-M95204, ULNRC-3644, NUDOCS 9709160104
Download: ML20210T795 (9)

Text

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. INION b,ish{CTlHC September 10,1997

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U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop Pl 137 Washington, DC 20555 0001 ULNRC 3644 TAC No. M95204 Gentlemen:

CALLAWAY PLANT DOCKET NUMDER 50-483 REVISION TO TECIINICAL SPECIFICATION

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3/4.4 - REACTOR COOLANT SYSTEM

References:

1) ULNRC-3358 dated April 12,1996

2) ULNRC-3451 dated September 24,1996

3) ULNRC-3596 dated June 9,1997

4) ULNRC-3597 dated June 9,1997

5) ULNRC-3629 dated August 8,1997 This letter provides additional infonnation in support of the Callaway Plant amendment application that proposes the installation of electrosleeves in the Callaway Plant steam generators. This information was requested by the NRC staffin a meeting on August 13,1997.

Framatome Technologies Inc. has determined that information associated with the installation process for electrosleeves is proprietary, and is thereby supported by an amdavit signed by Framatome, the owner of the information. The amdavit sets fonh 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 f 10CFR2.790. Accordingly, it is respectfully requested that the infonnation which is proprietary to Framatome be withheld from public disclosure in accordance with [,( gf '[ /

10CFR2.790.

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ULNRC 3644 Page 2 If you have any questions concerning this information, please contact us.

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6 C. p. Naslund' I Manager, Nuclear Engineering CDNAVEK/kkm

Enclosure:

ProprietaryInformation Allidavit Attachments: 1) Response to NRC issues / Concerns (Proprietary)

2) NRC'S Presentation (Proprietary)

3) Lab Grown Axial /Circumferential ODSCC Data Sub-Set

4) FTl Document 321264476-00 (Proprietary) l

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l Enclosure to ULN.RC-3644 1

i Proprietary Information Affidavit i

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AFFIDAVIT OF JAMPS It TAYLOR A. hty name is James 11. Taylor. I am hianager of Licensing Services for Framatome Technologies, Inc. (FTI), and as such, I am authorized to execute this Affidavit.

11. I am familiar with the criteria applied by FTl to determine whether certain information of FTI is proprietary and I am familiar with the procedures established within FTl to ensure the proper application of these criteria.

I C. In determining whether an FTI document is to be classified as proprietary information, an initial l determination is made by the Unit hinnager, who is responsible for originating the document, as to whether it falls within the criteria set forth in Faragraph D hereof, if the information falls

, within any one of these criteria, it is classified as proprietary by the originating Unit hianager.

This initial determination is reviewed by the cognizant Section hianager, if the document is designated as proprietary, it is reviewed again by Licensing personnel and other management within FTI as designated by the hianager of Licensing Services to assure that the regulatory requirements of 10 CFR Section 2.790 are met.

D. The following information is provided to demonstrate that the provisions of 10 CFR Section 2.790 of the Commission's regulations have been considered:

(i) The information has been held in confidence by FTI. Copies of the document are clearly identified as proprietary. In addition, whenever FTI transmits the information to a customer, customer's agent, potential customer or regulatory agency, the transmittal requests 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 substance of the following provision is included in all agreements entered into by FTI, and an equivalent version of the proprietary provision is included in all of FTI's proposals:

AFFIDAVIT OF JAMM It TAYLOR (Cont'd.)

"Any proprietary information concerning Company's or its Supplier's products or manufceturing 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 confidence, and Purchaser shall not publish or otherwise disclose it to others without the written approval of Company, and no rights, implied or otherwise, are granted to produce or have produced any products or to practice or cause to be practiced any manufacturing processes covered thereby.

Notwithstanding the above, Purchaser may provide the NRC or any other regulatory agency with any such proprietary information as the NRC or such other agency may require; provided, however, that Purchaser shall first 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-proprietary. In the event that Company cannot amend such proprietary information, Purchaser shall prior to disclosing such information, use its best efforts to obtain a commitment from NRC or such other agency to have such information withheld from public inc.pection.

Company shall be given the right to participate in pursuit of such cornidential treatment."

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l AFFIDAVIT OF JAMPS H. TAYLOR (Cont'd.)

(ii) The following criteria are customarily app!!ed by FTI in a rational decision process l to determine whether the information should be classified as proprietary. Information  ;

t may be classified as proprietary if one or more of the following criteria are met:  !

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a. Information reveals cost or price information, commercial strategies, production capabilities, or budget levels of FTI, its customers or suppliers, i

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b. The information reveals data or material concerning FTI research or development plans or programs of present or potential competitive advantage

to FTI.

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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. l

! d. The information consists of test data or other similar data concerning a process, method or component, the application of which results in a

, competitive advantage to FTI.

c. The infortnation reveals special aspects of a process, method, component or the like, the exclusive use of which results in a competitive advantage tr FTI.

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

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AFFIDAVIT OF JAMPR H. TAYLOR (Cont'd.)

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The document (s) listed on Exhibit "A", which is attached hereto and made a part '

hereof, has been evaluated in accordance with normal FTl 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". I (111) 1he document (s) listed in Exhibit "A", which has been made available to the United - ,

States Nuclear Regulatory Commission was made available in confidence with a i request that the document (s) and the information contained therein be withheld from public disclosure.

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(iv) The information is not available in the open literature and to the best of our  !

knowledge is not known by Combustion Engineering, EXXON, General Electric, l Westinghouse or other current or potential domestic or foreign competitors of FTI.

(v) Specific information with regard to whether public disclosure of the information is f likely to cause harm to the competitive position 'of FTI, taking into account the value ,

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of the information to FTI; the amount of effort or money expended by FTl developing. .

the information; and the case 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) listed on Exhibit "A" and have found that it is

_ considered proprietary by FTI because it contains information' which falls within one or more 1 of the criteria enumerated in Paragraph D, and it is information which is customarily held in

confidence and protected as proprietary information by FTI. This report comprises information o

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1 AFFIDAVIT OF JAMRt H. TAYLOR (Cont'd.)  ;

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utilized by FTl in its business which afford Fil an opportunity to obtain a competitive advantage  !

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

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-e f JAMES H. TAYL R i '

! State of Virginia) l ) SS. Lynchburg j - City of Lynchburg) f James H. Taylor, being duly sworn, on his oath deposes and says that he is the person who j- subscribed his name to the foregoing statement, and that the matters and facts set forth in the statement '

are true, i

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l f ' JA MES H. TAYLOR i-i Subscribed and sworn before me -

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.. thisd day ofdtt 'd<v h 1997.

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@,A C. O lL-Notary Public in and for the City x

of Lynchburg, State of Virginia.

- My Commission ExpiresNdfl.1999 i- / '

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EXilllllTS A & 11 EXililllT A

1. Attachment 1,Itesponses to NitC Concerns Dated August 13,1997.

2. Attachment 2, NitC's presentation material, portions FTl proprietary.

3. Attachment 3. Discussion of Lab Grown ODSCC Samples.

4. " Estimated 100% TW l.imits for a Circumferential 1: law", FTl Document 32-1264476 00, August ,1997.

EXIllillT 11 The above listed documents contain infonnation which is considered Proprietary in accordance with Criteria b, c, and d of the attached affidavit.

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