ML20115J061

Submits Supporting Affidavit to Keep Proprietary Info Presented in 960702 Electrosleeving Meeting Withheld. Proprietary Presentation Matl Withheld

ML20115J061
Person / Time
Site:	Callaway
Issue date:	07/18/1996
From:	Taylor J FRAMATOME
To:	Thomas K NRC (Affiliation Not Assigned)
Shared Package
ML19311C119	List: ML20115J061
References
JHT-96-45, NUDOCS 9607230439
Download: ML20115J061 (7)

Text

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[ ime X FRAMATOME TECHNOLOG1ES July 18,1996 Integrated Nuclear Services JHT/96-45 DC- % S Ms. Kristine M. Thomas, Project Manager Project Directorate IV-2 Division of Reactor Projects III/IV U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Mail Stop OWFN-13E16 Washington, DC 20555 0001

Subject:

" Proprietary" Presentation Material from July 2,1996 Meeting in Lynchburg, VA on Electrosleeving.

References:

(1) Union Electric Company, Technical Specification Amendment, Docket 50-483, Meeting Notice dated June 17, 1996.

(2) Topical Report BAW-10219P, Rev.1, "Electrosleeving Qualification for PWR Recirculating Steam Generator Tube Repair," March 1996.

Dear Ms. Thomas:

On July 2,1996, representatives of the NRC Staff met in Lynchburg, Virginia to witness a demonstration of Framatome Technologies' steam generator electrosleeving process and to participate in discussions supporting the NRC review and approval of Topical Report BAW-10219P, Rev.1. Portions of the information presented are " Proprietary" and, therefore, require a supporting affidavit. Please fm' d the appropriate affidavit attached.

The information presented in the meeting has been supplemented to provide discussion for some of the overheads included in your handouts. The attachments address the specifiw discussion topics identified in the NRC letter. All of the pertinent handout material has been incorporated into the attachments and should, therefore, be considered a replacement for the meeting handouts.

The Non-Proprietary version of that information will follow within a few days.

Very truly yours, 930095

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J. H. Taylor, A ager JHT/bec -

Licensing Services 9607230439 960718 PDR ADOCK 05000483 kb ,// /

p PDR 3315 Old Forest Road, P.O. Box 10935, Lynchburg, VA 24506-0935 fi1A Eu.k Teleohone: 804-832-3000 Fax: 804-832-3663 .>

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I l . Attachments: (1) Agenda for Meeting (July 2,1996) l l (2) Discussion Topics (Reprint of NRC I2tter) l (3) Attachment 1: Thermal Stability (9 pages) .

I (4) Attachment 2: Creep Data Overview (13 pages)  !

f (5) Attachment 3: Fractography (10 pages) l (6) Attachment 4: Electrosleeve Experience (18 pages) i I

l (7) Attachment 5: " Sample" Fabrication (2 pages)

(8) Attachment 6: NDE Methods (16 pages)

(9) Attachment 7: Severe Accident (4 pages) c: E. Kahl -

Union Electric l

E. J. Sullivan -

NRC  !

G. P. Hornseth - NRC J. E. Galford -

FTI/MRll ,

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AFFIDAVIT OF JAMES H. TAYLOR I

i l A. My name is James H. Taylor. I am Manager of Licensing Services for Framatome Technologies, Inc. (FTI), and as such, I am authorized to execute this Affidavit.-

B. I am familiar with the criteria applied by FTI to determine whether certain information of FTI is proprietary and I am familiar with the procedures established within FTI to ensure the proper application of these criteria. f C. In determining whether an FTI document is to be classified as proprietary information, an initial determination is made by the Unit Manager, who is responsible for originating the document, [

as to whether it falls within the criteria set forth in Paragraph D hereof. If the information falls within any one of these criteria, it is classified as proprietary by the originating Unit Manager. l This initial determination is reviewed by the cognizant Section Manager. If the document is designated as proprietary, it is reviewed again by Licensing personnel and other management

[ within FTI as designated by the Manager of Licensing Services to assure that the regulatory t

l requirements of 10 CFR Section 2.790 are met. '

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l 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:

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l- (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 i information, the substance of the following provision o included in all agreements i

! entered into by FTI, and an equivalent version of the proprietary provision is l included in all of FTI's proposals:

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AFFIDAVIT OF JAMES H. TAYLOR (Cont'd.) i I

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"Any proprietary information concerning Company's or its Supplier's j 1

l products or manufacturing processes which is so designated by Company or  ;

l its Suppliers and disclosed to Purchaser incident to the performance of such I contract shall remJn the property of Company or its Suppliers and is 1

disclosed in confidence, and Purchaser shall not publish or otherwise disclose ,

it to others without the written approval of Company, and no rights, implied j or otherwise, are granted to produce or have produced any products or to l ]

l practice or cause to be practiced any manufacturing processes covered l

l thereby.  !

Notwithstanding the above, Purchaser may provide the NRC or any other  !

i J regulatory agency with any such proprie'.ary information as the NRC or such i other agency may require; provided, however, that Purchaser shall first give Company written notice of such proposed disclosure and Company shall have l the right to amend such proprietary information so as to make it non-t propnetary. In the event that Company cannot amend such proprietary information, Purchaser shall prior to disclosing such information, use its best i

! efforts to obtain a commitment from NRC or such other agency to have such information withheld from public inspection.

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

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AFFIDAVIT OF JAMR9 H. TAYLOR (Cont'd.)- +

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I (ii) The following criteria are customarily applied by FTI in a rational decision process  !

to determine whether the information should be classified as proprietary.~ Information j t

L 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. >

b. The information reveals data or material concerning FTI research or i

, development plans or programs of present or potential competitive advantage

! i to FTI. l l

c. The use of the information by a competitor would decrease his expenditures, i in time or resources, in designing, producing or marketing a similar product. l l

d. The information consists of test data or other similar data concerning a  !

l process, method or component, the application of which results in a l competitive advantage to FTI.

l l e. . The information reveals special aspects of a process,- method, component or - )

i the like, the exclusive use of which results in a competitive advantage to FTI.  :

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

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AFFIDAVIT OF JAMES 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 FTI procedures with respect l 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, ss.:ifically identifies the criteria applicable to the document (s) listed in Exhibit "A".

(iii) The document (s) listed in Exhibit "A", v/hich has been made available to the United l

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

l (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, Westinghouse or other current or potential domestic or foreign competitors of FTI.

1 (v) Specific information with regard to whether public disclosure of the information is 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 FTI .

developing the information; and the ease or difficulty with which the information could be properly duplicated by others is given in Exhibit "B".  :

t E. I have personally reviewed the document (s) listed on Exhibit "A" and have found that it is l

considered proprietary by FTI because it contains information which falls within one or more -

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 1

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

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l utilized by FTI in its business which afford FTI 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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/JAMES H. TAY l l

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, State of Virginia) l ) SS. Lynchburg City of Lynchburg) l l

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\ I James H. Taylor, being duly sworn, on his oath deposes and says that he is the person who l l subscribed his name to the foregoing statement, and that the matters and facts set forth in the statement are true.

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< JAMES H. TAY  !

l l Subscribed and sworn before me this lldlay of (7alv 1996.

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I asL S. Oew Notary Public in and for the City 2

of Lynchburg, State of Virginia.

I My Commission Expires 04 3/.I499  !

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