ML20215D474

Requests Withholding of Proprietary Calculations Re Limitorque Thermal Lag Transient Analysis Inside Containment from Public Disclosure (Ref 10CFR2.790)

ML20215D474
Person / Time
Site:	Vogtle
Issue date:	12/05/1986
From:	Marsh F BECHTEL GROUP, INC.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML19292G454	List: ML20215D455 ML20215D474
References
BO-233, NUDOCS 8612160373
Download: ML20215D474 (5)

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Bechtel Power Corporation Engineers - Constructors 12440 East Imperial Highway Norwalk, California 90650 MAIL ADDRESS P O. BOX 60060 - TERMINAL ANNEX. LOS ANGELES. CAUFORNIA 90000 TELEPHONE:(2131807-2000 December 5,1986 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: BO 233 l

Dear Mr. Denton:

Georgia Power Company has been requested by the NRC to provide certain information concerning Bechtel calculations X6CJH.49, "Limitorque Thermal Leg Transient Analysis Inside Containment" and X6CJH.51, " Thermal Lag Transient Analysis on Equipment Inside Containment." The calculational methods used in these calculations are proprietary information of Bechtel Power Corporation. They contain trade secrets which, if publicly available, would aubstantially impair the competitive position of Bechtel Power Corporation in the industry.

Accordingly, this letter will serve as the application of Bechtel Power Corporation, as ouner of the information, for an exemption is sought pursuant to 10CFR 2.790 and is supported by the attached affidavit of Donald J. Stoker.

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 8612160373 861205 T PDR ADOCK 05000424  !

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- ' Becht'sl Powar Corporation December 5, 1986 LMr. Denton 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 tru y rs[

BECH EL - E RPORATION F. B. Marsh Project Engineering Manager Western Power Division JFB/cac

Attachment:

Affidavit of Donald J. Stoker xc: P..D. Rice w/att.

J. A. Bailey w/att. (ECS)

NORMS w/att.

State of California )

) ss County of Los' Angeles )

AFFIDAVIT OF DONALD.J. STOKER Donald J. Stoker, being first duly sworn, deposes and says:

1. That I an 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 documents 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 (" ) has requested production of certain documents by Bechcel to be used by NRC personnel.

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

Calculation X6CJH.49.1, "Limitorque Thermal Lag Transient Analysis Inside Containment" and Calculation X6CJH.51.0

" Thermal Lag Transient Analysis on Equipment Inside l Containment."

, 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:

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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 Paragraph 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 i design techniques.

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

vJ Donald J. Stoket Vice President Bechtel Power Corporation STATE OF CALIFORNIA )

) ss County of Los Angeles )

Subscribed and sworn to before me t.his 34d day of Od ' 1986* E fr ####'"""####'7,,

OFF:CIAL SEAL

2. MARIE L AMENDOLA

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4 LCS ANG:LES COUNTY k My comm. expires MAY 15, 1990 /

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Notary Public f

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