NOC-AE-03001561, Supplemental Response to Request for Additional Information Regarding Request for Alternative RR-ENG-2-32, for South Texas Project, Unit 1

Supplemental Response to Request for Additional Information Regarding Request for Alternative RR-ENG-2-32, for South Texas Project, Unit 1

ML031950422
Person / Time
Site:	South Texas
Issue date:	07/03/2003
From:	Thomas S South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-03001561, RR-ENG-2-32, TAC MB9696
Download: ML031950422 (5)

Text

Nuclear Operating Company so Mr AN South 7ems /ect Eledrfc Generating Station P Bo 259 Wadsorh. Teas 77483 A July 3, 2003 NOC-AE-03001561 10CFR50.55a U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 South Texas Project Unit 1 Docket No. STN 50-498 Supplemental Response to Request for Additional Information Regarding Request for Alternative RR-ENG-2-32 (TAC No. MB9696)

Reference:

Letter, S. E. Thomas to NRC Document Control Desk, "Response to Request for Additional Information Regarding Request for Alternative RR-ENG-2-32 (TAC No. MB9696)," dated July 3,2003 (NOC-AE-03001559)

The referenced letter stated that proprietary Framatome drawing 5027547E, Rev. 2 would be submitted under separate cover in response to an NRC informal request for additional information. The proprietary drawing is enclosed with this letter.

Because Framatome drawing 5027547E, Rev. 2 contains information proprietary to Framatome ANP, it is supported by an affidavit signed by Framatome, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the NRC and addresses with specificity the considerations listed in Section 10 CFR 2.790(b)(4).

Accordingly, it is respectfully requested that the information that is proprietary to Framatome be withheld from public disclosure in accordance with 10 CFR 2.790.

Correspondence with respect to the proprietary aspects of Framatome drawing 5027547E, Rev. 2 or the supporting Framatome affidavit should be addressed to James F. Mallay, Director, Regulatory Affairs, Framatome ANP, 3315 Old Forrest Road, Lynchburg, VA 24506.

STI: 31627536

NOC-AE-03001561 Page 2 If there are any questions regarding this response, please contact Mr. Michael Lashley at 361-972-7523 or me at 361-972-7162.

Steven E. Thomas Manager, Plant Design Engineering jtc

Enclosures:

1. Framatome Affidavit

2. Framatome Drawing 5027547E, Rev. 2 (Proprietary) cc:

(paper copy) w/o proprietary drawing except * (electronic copy) w/o proprietary drawing Ellis W. Merschoff A. H. Gutterman, Esquire Regional Administrator, Region IV Morgan, Lewis & Bockius LLP U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 L. D. Blaylock Arlington, Texas 76011-8064 City Public Service

• U. S. Nuclear Regulatory Commission Mohan C. Thadani Attention: Document Control Desk U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike R. L. Balcom Rockville, MD 20852 Texas Genco, LP Richard A. Ratliff A. Ramirez Bureau of Radiation Control City of Austin Texas Department of Health 1100 West 49th Street C. A.Johnson Austin, TX 78756-3189 AEP Texas Central Company Cornelius F. O'Keefe Jon C. Wood U. S. Nuclear Regulatory Commission Matthews & Branscomb P. 0. Box 289, Mail Code: MN1 16 Wadsworth, TX 77483 C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704

• Mohan C. Thadani Project Manager U. S. Nuclear Regulatory Commission One White Flint North, Mail Stop: 0-7D1 11555 Rockville Pike Rockville, MD 20852-2738

AFFIDAVIT COMMONWEALTH OF VIRGINIA )

) ss.

CITY OF LYNCHBURG )

1. My name is James F. Mallay. I am Director, Regulatory Affairs, for Framatome ANP ("FANP"), and as such I am authorized to execute this Affidavit.

2. 1am familiar with the criteria applied by FANP to determine whether certain FANP information is proprietary. I am familiar with the policies established by FANP to ensure the proper application of these criteria.

3. 1am familiar with the FANP drawing, 5027547-02, Bottom Monitoring Instrumentation Nozzle Repair, that is being sent to the NRC by the South Texas Project Nuclear Operating Company related to the repairs made on its reactor vessel. This drawing is referred to herein as "Document." Information contained in this Document has been classified by FANP as proprietary in accordance with the policies established by FANP for the control and protection of proprietary and confidential information.

4. This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by FANP and not made available to the public.

Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.

5. This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in the Document be withheld from public disclosure.

6. The following criteria are customarily applied by FANP to determine whether information should be classified as proprietary:

(a) The information reveals details of FANP's research and development plans and programs or their results.

(b) Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.

(c) The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for FANP.

(d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for FANP in product optimization or marketability.

(e) The information is vital to a competitive advantage held by FANP, would be helpful to competitors to FANP, and would likely cause substantial harm to the competitive position of FANP.

7. In accordance with FANP's policies governing the protection and control of information, proprietary information contained in this Document has been made available, on a limited basis, to others outside FANP only as required and under suitable agreement providing for nondisclosure and limited use of the information.

8. FANP policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.

9. The foregoing statements are true and correct to the best of my knowledge, information, and belief.

./7~~~~~~~~~~~0 SUBSCRIBED before me this day of , 2003.

Ella F. Carr-Payne NOTARY PUBLIC, STATE OF VIRGINIA MY COMMISSION EXPIRES: 8/31/05 ELLA F.CARR-PAYNE i I Notary Public I EL Commonwealth of Virginia 1_ 4 My con Ep. Aug. 31.2005