ML20214W703

Requests That Calculation X6CJH.37.1, Thermal Lag Analysis for Eaton Cable, Be Withheld (Ref 10CFR2.790).Affidavit Encl

ML20214W703
Person / Time
Site:	Vogtle
Issue date:	11/21/1986
From:	Marsh F BECHTEL GROUP, INC.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20214W666	List: ML20214W664 ML20214W703
References
BO-232, NUDOCS 8612100374
Download: ML20214W703 (5)

Text

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Bechtel Western Power Corporation Engineers - Constructors 12440 East Imperial Highway Norwalk, California 90650 '

(o]( Tjn,u;N,AgAsseuos ANGRE$ CAUFORNIA 90%0 November 21, 1986 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Georgia Power Company Plant Vogtle - Units 1 &2 Bechtel Job 9510 Application for Withholding Proprietary Information from Public Disclosure File: X7BC35 Log: B0 232

Dear Mr. Denton:

Georgia Power Company has been requested by the NRC to provide certain information concerning Bechtel calculation X6CJH.37.1

" Thermal Lag Analysis for Eaton Cable." The calculational methods used in this calculation are proprietary information of Bechtel Power Corporation. It contains trade secrets which, if publicly available, would substantially impair the competitive position of Bechtel Power Corporation in the industry.

Accordingly, this le"ter will serve as the application of Bechtel Power Corporation, as owner of the information, for an exemption is sought pursuant to 10CFR 2.790 and is supported by the attached affidavit of Robert H. Stone.

Please address inquires or correspondence concerning this application to:

Mr. Fred B. Marsh Project Engineering Manager Bechtel Power Corporation Terminal Annex Los Angeles, CA 90060 8612100374 861121

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Bechtel Western Power Corporation November 21, 1986 Mr. Denton.

l Plant Vogtle - Units 1 & 2 Bechtel Job 9510 Application for Withholding Proprietary Information from Public Disclosure File: X7BC35 Page 2 If you have any questions, please contact us.

Very truly y rs, BECHT RPORATION F. B. Marsh Project Engineering Manager Western Power Division JFB/cac j

Attachment:

Affidavit of Robert H. Stone

State of California )

) ss County of Los Angeles )

AFFIDAVIT OF ROBERT H. STONE Robert H. Stone, being first duly sworn, deposes and says:

1. That I am a Vice President of Bechtel Power Corporation

("Bechtel").

2. That, except for the matters expressly stated to be on information and belief, I have personal knowledge of the facts set forth herein, and could competently testify thereto.

3. That I have been specifically delegated, by Bechtel, the function of reviewing the docut_ats discussed herein and am authorized to apply for their withholding on behalf of Bechtel which is the owner of this information.

4. That, based on my information and belief, the Nuclear Regulatory Commission ("NRC") has requested production of certain documents by Bechtel to be used by NRC personnel.

5. That, based on my information and belief, the following documents are among the documents sought:

Calculation X6CJH.37.1, " Thermal Lag Analysis for Eaton Cables."

6. That the documents identified in Paragraph 5 are Bechtel documents.

7. That the documents identified in Paragraph 5 should not be subject to public inspection and copying because they are Bechtel's procedure describing Bechtel's means and methods for performing calculations relating to the design and construction of nuclear power plants. As such:

. . ~

a. The documents contain trade secrets of Bechtel.

b. The documents contain proprietary and confidential commercial information and data of Bechtel.

c. The documents contain proprietary and confidential discoveries and records of Bechtel.

8. That the following considerations are applicable to the reasons set forth in Parograph 7:

a. The information is held in confidence by Bechtel.

b. The information is of a type customarily held in confidence by Bechtel and there is rational basis for holding the information in confidence as set forth in Paragraph 7 above and in this paragraph.

c. The information is being transmitted to the NRC in confidence.

d. The information is not available in public sources.

e. Public disclosure of the information is likely to cause substantial harm to the competitive position of Bechtel for the following reasons:

1) The information is valuable to Bechtel because it represents unique approaches and capabilities for resolving complex safety, technical, commercial and industry factors to comply with applicable laws, statutes and regulations.

2) Substantial and significant effort and money have been and are being expended by Bechtel to develop, acquire and maintain the necessary expertise and capability in these highly specialized areas.

3) Others would have difficulty in properly acquiring or duplicating the information which represents special applications of theoretical principles, complex analytical procedures and sophisticated design techniques.

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9. For the reasons set forth in this affidavit, Bechtel requests that the documents listed in paragraph 5 be designated as exempt from disclosure pursuant to 10 CFR 2.790.

Robert H. Stone Vice President Bechtel Power Corporation STATE OF CALIFORNIA )

) ss County of Los Angeles )

Subscribed and sworn to before me this Al day of b6Uft(h6bb , 1986 0)) DAM h. l7 s Notary Public

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Ap, OFFICIAL SEAL

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MARIE L AMENDOLA 5 tJOTARY PUBLIC - CAUFORNIA e? LOS ANGELES COUNTY My comm. expires MM 15, 1990

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