ML20234E957
| ML20234E957 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 09/17/1987 |
| From: | Bailey J GEORGIA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML19304B467 | List: |
| References | |
| GN-1397, NUDOCS 8709220581 | |
| Download: ML20234E957 (9) | |
Text
I Ghorgia Fower Company Post Ofhce Box 282 Waynssboro, Georgia 30830 Telephone 404 554-9%1 404 724-8114 l.
Southern Company Services, Inc.
Fbst Othee Box 2625 '
b Birmingham, Alabama 35202 Telephone 205 870-6011 VOgtle Project September 17, 1987 U. S. Nuclear Regulatory Commission Document Control Desk File:
X7BC35 Washington, D. C.
20555 Log:
GN-1397
References:
- 1) GPC Letter to NRC, April 29, 1987
- 2) Vogtle FSAR Secticn 5.2.5
- 3) Analysis of Experiments on Stainless Steel Flux Welds, NUREG/CR-4878, BMI-2151, April 1987
- 4) GPC Letter to NRC, July 15, 1987
- 5) NRC Letter to GPC, August 6, 1987
- 6) GPC Letter to NRC, August 19, 1987
- 7) NRC Letter to GPC, September 9, 1987 NRC DOCKET NUMBER 50-425 CONSTRUCTION PERMIT NUMBER CPPR-109 V0GTLE ELECTRIC GENERATING PLANT - UNIT 2 AUXILIARY LINE PIPE BREAK ELIMINATION PROGRAM Gentlemen:
Enclosed are:
1.
Five (5) copies of WCAP-11531, Addendum 2,
" Additional Information in Support of the Elimination of Postulated Pipe Ruptures in the Pressurizer Surge Line of Vogtle Unit 2"
(Proprietary).
2.
Five (5) copies of WCAP-11532, Addendum 2,
" Additional Information in Support of the Elimination of Postulated Pipe Ruptures in the Pressurizer Surge Line of Vogtle Unit 2"
(Non-Proprietary).
The above enclosures are in response to the request for additional information contained in reference 7 above.
Also enclosed is a
Westinghouse Application for Witholding, CAW-87-088, Accompanying Affidavit, and Proprietary Information Notice.
As this submittal contains information proprietary to Westinghouse i
Electric Corporation, it is supported by an affidavit signed by j
Westinghouse, the owner of the information.
The affidavit sets
)
forth the basis on which the information may be withheld from public l
disclosure by the Commission and addresses with specificity the l
considerations listed in paragragh (b) (4) of Section 2.790 of n/
Mr he k the Commission's regulation.
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B709220581 870917 PDR ADOCK 0500 5
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File:
X7BC35 Log:
GN-1397 Page two Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10CFR Section 2.790 of the Commission's regulations.
Correspondence with respect to the proprietary aspects i
of the Application for Withholding or the supporting Westinghouse affidavit should reference CAW-87-088 and should be addressed to R.
A.
Wiesemann, Manager Regulatory and Legislative Affairs, Westinghouse Electric Corporation, P.
O.
Box 355, Pittsburgh, Pennsylvania 15230.
Should you need additional information, please inquire.
Sincerely,
, (k.
J. A. Bailey Project Licensing Manager JAB /wkl xc: NRC Regional Administrator NRC Resident Inspector J. P. O'Reilly R. E. Conway P. D. Rice L. T. Gucwa i
R. A. Thomas J. E. Joiner, Esquire M. A. Miller (2)
G. Bockhold, Jr.
R. Goddard, Esquire D. Feig R. W. McManus Vogtle Project File l
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i, Westinghouse PowerSystems Nuclear Technology 3"*S D"'iSi "
Electric Corporation Box 355 Pmsburgh PennsyWania 15230 0355 September 17, 1987 CAW-87-088 Dr. Thomas Murley, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.
20555 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
" Additional.Information in Support of the Elimination of Postulated Pipe Ruptures in the Pressurizer Surge Line of Vogtle Unit 2."
Dear Dr. Murley:
i The proprietary material for which withholding is being requested in the reference letter by Georgia Power Company is further identified in an affidavit j
signed by the owner of the proprietary information, Westinghouse Electrie
?
Corporation. The affidavit, which accompanies this lette', sets forth tne 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 10CFR Section 2.790 of the Commission's regulations.
The proprietary material for which withholding is being requested is of the same technical type as that proprietary material previously submitted as Affidavit CAW-84-102.
i Accordingly, this letter authorizes the utilization of the accompanying affidavit by Georgia Power Company.
Correspondence with respect to the proprietary aspects of the application for withholding or the ~ Westinghouse affidavit should reference this letter, CAW-87-088 and should be addressed to the undersigned.
Ver uly yours, j
WL~
/ert A.
lesemann, Manager
/dmr Regulatory & Legislative Affairs Enclosure (s) cc: E. C. Shomaker, Esq.
i Office of the General Council, NRC 1
l PROPRIETARY INFORMATION NOTICE l:
~
i TRANSFJTTED HENITH ARE PROPRIETARY AND/OR WON-PROPRE s
D0QJMEhTS FURNISHED 70 THE NRC IN CONNECTION WIT PLAhT SPECIFIC REVIEW AND APPROVAL.
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IN ORDiR TO C0hTORM TD THE REQUIRDEhTS OF 10CFR2.790 0 REGULATIONS CONCERNING THE PROTECTION OF PROPRIETA TO THE NRC, THE INFORMATION WHICH IS PROPRIETARY IN THE PROPRIE CONTAINED WITHIN BRACKETS AND WHERE THE PROPRIETARY I DEI.ETED IN THE NON-PROPRIETARY VDSIONS OG.Y THE BRACKEIS REMAIN, T i
. IhTORMTION THAT WAS CONTAINED WITHIN THE BRACKETS HAVING BEEN DELETE.
THE JUSTIFICATION FDR CI. AIMING THE INFORMATION SO DESIDNATED AS PROPRIETARY IS' INDICATE IN B01H VERSIO LETTERS (a) THROUGH (g) CohTAING WITHIN PARENTHI3ES LOCATED AS A S IMMEDIATELY FOLLOWING THE BRACKETS DiCI.05ING EACH ITE IDENTIFIED AS PROPRIETARY OR IN THE MARGIN OPPOSITE S LO4ER CASE LEITERS REFER 70 THE TYPES OF INFORMATION 3
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HOLDS IN CONFIDENCE IDENTIFIED IN SECTIONS (4)(ii)(a) through (4)(ii)(g) 0 AFTIDAVIT ACCOMPAhTING THIS TRANSMITTAL PURSUAh7 7010 l
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i CAW-84-102 1
AFFIDAVIT' i
COMMONWEALTH OF PENNSYLVANIA:
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COUNTY OF ALLE6HENY:
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Before me, the undersigned authority, personally appeared John D. McAdoo,,
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who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Corporation (" Westinghouse") and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge,.information, and belief:
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Joh D. McAdoo, Assistant Manager clear Safety Department 1
Sworn to and subscribed before me this 7.lf day
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9 1984.
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1 4 Notary Public LORRAINI M. PlPLICA, NOTARY PUBLIC NONR0!VILLE BORD. ALLECHINY COUNT 7 NY COMMl!! ION EXPlRIS Dlc 14,1H7 Nember. Pennsylvania Association of hotares i
HFC/0162n/11-20-R4
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4 C AW-84-102 (1)
I am. Assistant Manager, Nuclear Safety Department, in the Nuclear Technology Division, of Westinghouse Electric Corporation and as such, I i
have been specifically delegated the function of reviewing.the proprietary information sought to be withheld from public disclosure in
' connection with nuclear power plant licensing or rulemaking proceedings, r
and am authorized to' apply for its withholding on behalf of the j
l Westinghouse Water Reactor Divisions.
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'(2)
I am making this Affidavit in conformance with the provisions of 10CFR Section 2.790 of the Commission's regulations and in conjunction with the Westinghouse application for withholding accompany this Affidavit.
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(3)
I have personal knowledge of the criteria and procedures utilized by Westinghouse Nuclear Energy Systems in designating information as: a trade secret, privileged or as-confidential commercial or financial information.
1
.(4). Pursuant to the provisions of paragraph (b)(4) of Section 2.790 of the
. Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.
1 (i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.
(ii) The information is of a type customarily held in confidence by i
Westinghouse and not customarily disclosed to the public.
Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizr,s a system to determine when and whether to hold certain types of information in confidence.
The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.
HFC/0162n/11-20-84
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. CAW-84-102 under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:
(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.
I (b)
It consists of supporting data, including test data, relative to process (or component, structure, tool, pethod, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.
(c)
Its use by a competitor would. reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.
(d)
It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.
(e)
It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential connercial value to Westinghouse.
(f)
It contains patentable ideas, for which patent protection may be desirable.
(g)
It is not the property of Westinghouse, but must be treated as proprietary by Westinghouse according to agreements with the owner.
-HFC/0162n/11-20-84
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! CAW-84-102 There are sound policy reasons behind the Westinghouse system which include the following:
(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors.
It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.
(b)
It is information which is marketable in many ways.
The extent to which such information is available to competitors j
diminishes the Westinghouse ability to sell products and services involving the use of the information.
(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.
(d) Each component of proprietary information pertinent to a
)
particular competitive advantage is potentially as valuable as the total competitive advantage.
If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.
(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world inarket, and thereby give a market advantage to the competition in those countries.
(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.
(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10CFR Section 2.790, it is to be received in confidence by the Commission.
HFC/0162n/11-20-84
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i CAW-84-102 (iv) The information sought to be protected is not available in public sources to the best of our knowledge and belief.
(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP-10489,
" Technical Bases for Eliminating Pressurizer Surge line Ruptures as the Structural Design Bases for South Texas Project," dated February 1984, and " Additional Information - South Texas Surge Line."
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The subject information could only be duplicated by competitors if they were to invest time and effort equivalent to that invested by Westinghouse provided that they have the requisite talent and experience.
Public disclosure of this information is likely to cause substantial harm to the competitive position of Westinghouse i
because it would simplify design and evaluation tasks without
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requiring a commensurate investment of time and effort.
Further the deponent sayeth not.
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I HFC/0162n/11-20-84
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