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Category:Legal-Affidavit
MONTHYEARDCL-23-022, 2023 Annual Statement of Insurance for Pacific Gas and Electric Companys Diablo Canyon Power Plant2023-03-29029 March 2023 2023 Annual Statement of Insurance for Pacific Gas and Electric Companys Diablo Canyon Power Plant DCL-19-082, Submittal of Site-Specific Decommissioning Cost Estimate2019-12-0404 December 2019 Submittal of Site-Specific Decommissioning Cost Estimate DCL-18-100, License Amendment Request 18-02 - License Amendment Request to Revise Technical Specification 5.6.5b1 Core Operating Limits Report (COLR) for Full Spectrum Loss-of-Coolant Accident Methodology2018-12-26026 December 2018 License Amendment Request 18-02 - License Amendment Request to Revise Technical Specification 5.6.5b1 Core Operating Limits Report (COLR) for Full Spectrum Loss-of-Coolant Accident Methodology ML16061A4522016-02-11011 February 2016 Submittal of Tricon Phase 2 Documents for the License Amendment Request for Process Protection System Replacement DCL-16-020, Diablo Canyon, Units 1 and 2 - Submittal of Tricon Phase 2 Documents for the License Amendment Request for Process Protection System Replacement2016-02-11011 February 2016 Diablo Canyon, Units 1 and 2 - Submittal of Tricon Phase 2 Documents for the License Amendment Request for Process Protection System Replacement ML16026A3882016-01-0505 January 2016 Westinghouse Electric Company, LLC, Submittal of Proprietary Version of LTR-DCPPS-15-008 Response to NRC RAI 73 (Open Item 129). ML15090A2752015-03-26026 March 2015 Independent Spent Fuel Storage Installation - Consent and Hearing Waiver Form ML14171A2372014-06-11011 June 2014 Submittal of Supplemental Analysis for Inservice Inspection Program Relief Request SWOL-REP-1 U2 ML14205A0352014-03-12012 March 2014 Affidavit No. 993754-AFF-104T, Dated 03/12/2014, Signed by Mark Herschthal DCL-14-034, Affidavit No. 993754-AFF-104T, Dated 03/12/2014, Signed by Mark Herschthal2014-03-12012 March 2014 Affidavit No. 993754-AFF-104T, Dated 03/12/2014, Signed by Mark Herschthal DCL-13-061, CS Innovations - Application for Witholding Proprietary Information from Public Disclosure, Enclosure, Attachment 22013-04-25025 April 2013 CS Innovations - Application for Witholding Proprietary Information from Public Disclosure, Enclosure, Attachment 2 ML13078A2922013-03-0505 March 2013 Areva Affidavit for Areva Calculations #32-9199805-000, Diablo Canyon Power Plant Unit 2 Pzr Safety and Spray Nozzles Planar Flaw Analysis (Proprietary) and #32-9199937-000, DCPP Unit 2 - Evaluation of Laminar Indications in Pressurizer Noz DCL-12-069, Diablo Canyon, Units 1 and 2 - Submittal of Attachment 1, Quality Assurance Plan and Revised Phase 1 Documents for the License Amendment Request for Digital Process Protection System Replacement and Attachment 8 Affidavit 993754-AFF-38T2012-08-0202 August 2012 Diablo Canyon, Units 1 and 2 - Submittal of Attachment 1, Quality Assurance Plan and Revised Phase 1 Documents for the License Amendment Request for Digital Process Protection System Replacement and Attachment 8 Affidavit 993754-AFF-38T ML12222A0942012-08-0202 August 2012 Submittal of Attachment 1, Quality Assurance Plan and Revised Phase 1 Documents for the License Amendment Request for Digital Process Protection System Replacement and Attachment 8 Affidavit 993754-AFF-38T ML12137A0242012-05-15015 May 2012 Diablo Canyon - May Hearing File Update ML11297A0562011-10-18018 October 2011 Diablo Canyon - October Hearing File Update ML0715501312007-05-23023 May 2007 SER Compliance with WCAP-16260-P-A the Spatially Corrected Inverse Count Rate (Scicr) Method for Subcritical Reactivity Measurement DCL-05-121, Correction of Information Contained in License Amendment Request 05-04. Revision to Technical Specification 5.3.1. 'Unit Staff Qualifications.'2005-12-23023 December 2005 Correction of Information Contained in License Amendment Request 05-04. Revision to Technical Specification 5.3.1. 'Unit Staff Qualifications.' DCL-05-018, License Amendment Request 05-01 Revision to Technical Specification 5.5.9, Steam Generator Tube Surveillance Program, and 5.6.10, Steam Generator Tube Inspection Report. to Allow Use of the W* Alternate Repair Criteria.2005-03-11011 March 2005 License Amendment Request 05-01 Revision to Technical Specification 5.5.9, Steam Generator Tube Surveillance Program, and 5.6.10, Steam Generator Tube Inspection Report. to Allow Use of the W* Alternate Repair Criteria. DCL-04-149, License Amendment Request 04-07, Revision to Technical Specifications 3.7.17 and 4.3 for Cycles 14-16 for a Cask Pit Spent Fuel Storage Rack2004-11-0303 November 2004 License Amendment Request 04-07, Revision to Technical Specifications 3.7.17 and 4.3 for Cycles 14-16 for a Cask Pit Spent Fuel Storage Rack DCL-04-123, License Amendment Request 04-06 Removal of Technical Specifications 5.6.1, Occupational Radiation Exposure Report, and 5.6.4, Monthly Operating Reports2004-11-0101 November 2004 License Amendment Request 04-06 Removal of Technical Specifications 5.6.1, Occupational Radiation Exposure Report, and 5.6.4, Monthly Operating Reports DCL-04-104, Response to NRC Request for Additional Information Regarding License Amendment Request 04-01, 'Revised Steam Generator Voltage-based Repair Criteria Probability of Detection Method for Plant.2004-08-18018 August 2004 Response to NRC Request for Additional Information Regarding License Amendment Request 04-01, 'Revised Steam Generator Voltage-based Repair Criteria Probability of Detection Method for Plant. DCL-04-089, Response to June 14 and July 6, 2004, NRC Request for Additional Information Re License Amendment Request 03-18, Revision to Technical Specifications 5.5.9, 'Steam Generator (SG) Tube Surveillance Program,' & 5.6.10.2004-07-30030 July 2004 Response to June 14 and July 6, 2004, NRC Request for Additional Information Re License Amendment Request 03-18, Revision to Technical Specifications 5.5.9, 'Steam Generator (SG) Tube Surveillance Program,' & 5.6.10. DCL-04-095, 60-Day Response to NRC Bulletin 2004-01, Inspection of Alloy 82/182/600 Materials Used in the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized Water Reactors2004-07-27027 July 2004 60-Day Response to NRC Bulletin 2004-01, Inspection of Alloy 82/182/600 Materials Used in the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized Water Reactors DCL-04-066, Response to NRC Request for Additional Information Regarding License Amendment Request 03-12, Revision to Technical Specifications 3.3.1, 'Rts Instrumentation,' and 3.3.2, 'Esfas Instrumentation.'2004-06-0404 June 2004 Response to NRC Request for Additional Information Regarding License Amendment Request 03-12, Revision to Technical Specifications 3.3.1, 'Rts Instrumentation,' and 3.3.2, 'Esfas Instrumentation.' ML0412804352004-04-30030 April 2004 Notice of Change of Address ML0409704212004-03-31031 March 2004 Saybrook Capital, LLC Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for February 1 Through February 29, 2004 ML0409805912004-03-18018 March 2004 Public Policy Advocates Llc'S Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expense for February 1, 2004 Through February 29, 2004 ML0406204532004-02-23023 February 2004 Declaration of Sandip Sen in Support of Debtor'S Motion for Authority to Establish Cash-collateralized Letter of Credit Program and Facility to Secure Gas Purchases, and to Incur Secured Debt Related Thereto (the Motion)' ML0403706042004-01-29029 January 2004 Declaration of Michael J. Donnelly in Support for Authority to Establish Cash-Collaterized Letter of Program and Facility to Secure Gas Purchases, and to Incur Secured Debt Related Thereto ML0403706012004-01-29029 January 2004 Declaration of Raymond X. Welch in Support of Motion for Authority to Establish Cash-Collateralized Letter of Credit Program and Facility to Secure Gas Purchases, and to Incur Secured Debt Related Thereto ML0400700982003-12-30030 December 2003 Howard, Rice Nemerovski, Canady, Falk & Rabkin Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for November, 2003 ML0400200602003-12-22022 December 2003 Declaration of Grant Guerra in Support of Motion for Order Authorizing the Debtor to Settle Claim No. 13377 Filed by the Presidio Trust ML0333810452003-11-26026 November 2003 Cooley Godward Llp'S Twenty-Ninth Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for the Period October 1, 2003 - October 31, 2003 ML0331800932003-11-0606 November 2003 Proof of Service ML0331701792003-10-31031 October 2003 Declaration of Michael J. Donnelly in Support of Pg&E'S Application for Authority to Incur Plan Implementation Expenses in Connection with Certain Financings DCL-03-133, Full Compliance with Order for Compensatory Measures Related to Fitness-For-Duty Enhancements Applicable to Nuclear Facility Security Force Personnel, Dated 04/29/03 (EA-03-038)2003-10-28028 October 2003 Full Compliance with Order for Compensatory Measures Related to Fitness-For-Duty Enhancements Applicable to Nuclear Facility Security Force Personnel, Dated 04/29/03 (EA-03-038) ML0331800862003-10-23023 October 2003 Relief from Stay Cover Sheet ML0331800902003-10-23023 October 2003 Declaration of Jennifer A. Becker in Support of City of Oakland and Port of Oakland'S Motion for Relief from Automatic Stay ML0328703662003-09-29029 September 2003 Skadden, Arps, Slate, Meagher & Flom Llp'S Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for the Period August 1, 2003 Through August 31, 2003 ML0327312982003-09-24024 September 2003 (Reorganized) California Power Exchange Corporation'S Limited Objection to Motion for Order Authorizing Pacific Gas and Electric Company to Compromise Claims Against El Paso Natural Gas Company Et Alia and to Enter Into Agreements Resolving ML0327314402003-09-23023 September 2003 Fact Witness Disclosure of Satellite Senior Income Fund, Satellite Senior Income Fund II and Deutsche Bank Trust Company Americas to Objection to Confirmation of Plan of Reorganization Under Chapter 11 of the Bankruptcy Code for Pacific Gas ML0327313322003-09-22022 September 2003 Notice of Hearing on Interim Compensation Applications of Professionals and Final Expense Application of Creditors' Committee Members ML0326810702003-09-16016 September 2003 Declaration of Michael J. Donnelly in Support of Debtor'S Notice of Motion and Motion for Order Approving Debtor'S Execution and Performance Under the Amendment to First Amended and Restated Summary of Terms with Respect to Forbearance and ML0325412082003-09-11011 September 2003 Order Re Ex Parte Application of Pacific Gas and Electric Company Authorizing Settlement and Withdrawal of Claim of Laguna Irrigation District ML0325911092003-09-0505 September 2003 Declaration of Joshua Bar-Lev in Support of Debtor'S Motion for Order Authorizing Pacific Gas and Electric Company to Compromise Claims Against El Paso Natural Gas Company Et Alla and to Enter Into Agreements Resolving the Claims ML0325411442003-09-0404 September 2003 Relief from Stay Cover Sheet - Motion & Notice of Motion of Smud for Relief from Automatic Stay in Litigation ML0325213432003-08-29029 August 2003 Declaration of Joseph Sauvage in Support of Motion for Authority to Enter Into Certain Hedging Transactions in Connection with Financing Under Proposed Plan of Reorganization, and to Incur Secured Debt Related Thereto ML0325213452003-08-29029 August 2003 Declaration of Walter Hulse in Support of Motion for Authority to Enter Into Certain Hedging Transactions in Connection with Financing Under Proposed Plan of Reorganization, and to Incur Secured Debt Related Thereto ML0325213412003-08-29029 August 2003 Howard, Rice, Nemerovski, Canady, Falk & Rabkin Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for July, 2003 2023-03-29
[Table view] Category:Letter
MONTHYEARIR 05000275/20230042024-02-0909 February 2024 Integrated Inspection Report 05000275/2023004 and 05000323/2023004 ML24002B1802024-01-29029 January 2024 LRA Audit Plan DCL-24-010, Nuclear Material Transaction Report for New Fuel2024-01-29029 January 2024 Nuclear Material Transaction Report for New Fuel ML24018A0152024-01-29029 January 2024 License Renewal Application Review Schedule Letter ML24017A2492024-01-24024 January 2024 Letter to Neil Peyron, Chairman, Tule River Tribe, Re. Diablo Canyon ML24024A1752024-01-24024 January 2024 Letter to Tribal Council San Luis Obispo County Chumash Indians on Section 106 Consultation and Scoping Process for the Environmental Review of Diablo Canyon Nuclear Plant, Unit 1 and 2 License Renewal Application ML24003A8902024-01-24024 January 2024 Letter to P. Gerfen - Diablo Canyon Notice of Intent to Conduct Scoping and Prepare an Environmental Impact Statement ML24012A1582024-01-24024 January 2024 Letter to Hon. Violet Sage Walker, Chairwoman Northern Chumash Tribal Council on Section 106 Consultation and Scoping Process for the Environmental Review of Diablo Canyon Nuclear Plant, Unit 1 and 2 License Renewal Application ML24012A0062024-01-24024 January 2024 Achp Scoping Letter for Diablo Canyon License Renewal ML24012A0552024-01-24024 January 2024 Letter to J. Polanco, Shpo, on Request to Initiate Section 106 Consultation and Scooping Process for the Environmental Review of Diablo Canyon Nuclear Plant, Unit 1 and 2 License Renewal Application ML24024A1562024-01-24024 January 2024 Letter to Hon. Gabe Frausto, Coastal Band of Chumash Indians on Section 106 Consultation and Scoping Process for the Environmental Review of Diablo Canyon Nuclear Plant, Unit 1 and 2 License Renewal Application ML24024A1652024-01-24024 January 2024 Letter to Hon. Mona Olivas Tucker, Yak Tityu Tityu Yak Tilhini Northern Chumas Indians on Section 106 Consultation and Scoping Process for the Environmental Review of Diablo Canyon Nuclear Plant, Unit 1 and 2 License Renewal Application ML24024A1612024-01-24024 January 2024 Letter Hon. Gary Pierce, Salian Tribe of Monterey and San Luis Obispo Counties on Section 106 Consultation and Scoping Process for the Environmental Review of Diablo Canyon Nuclear Plant, Unit 1 and 2 License Renewal Application ML24012A0362024-01-24024 January 2024 Request to Initiate Section 106 Consultation and Scoping Process for the Environmental Review License Renewal Application DCL-24-009, Nuclear Material Transaction Report for New Fuel2024-01-17017 January 2024 Nuclear Material Transaction Report for New Fuel DCL-24-008, Schedule Considerations for Review of the DCPP License Renewal Application2024-01-17017 January 2024 Schedule Considerations for Review of the DCPP License Renewal Application DCL-24-004, Supplement to License Amendment Request 23-01 Revision to Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b2024-01-15015 January 2024 Supplement to License Amendment Request 23-01 Revision to Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b IR 05000275/20230112024-01-12012 January 2024 NRC License Renewal Phase 1 Inspection Report 05000275/2023011 DCL-23-129, Nuclear Material Transaction Report for New Fuel2023-12-27027 December 2023 Nuclear Material Transaction Report for New Fuel ML23326A0122023-12-21021 December 2023 12-21-23 Letter to the Honorable Byron Donalds from Chair Hanson Responds to Letter Regarding 2.206 Petition to Close Diablo Canyon Nuclear Power Plant, Unit 1 ML23341A0042023-12-19019 December 2023 LRA Acceptance Letter ML23352A2342023-12-18018 December 2023 Notification of Age-Related Degradation Inspection (05000275/2024014 and 05000323/2024014) and Request for Information DCL-23-122, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-12-14014 December 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation DCL-23-128, Emergency Plan Update2023-12-13013 December 2023 Emergency Plan Update ML23355A0952023-12-0808 December 2023 License Renewal Application Online Reference Portal DCL-23-125, Core Operating Limits Report for Unit 1 Cycle 252023-12-0606 December 2023 Core Operating Limits Report for Unit 1 Cycle 25 ML23291A2702023-11-28028 November 2023 Letter to Nakia Zavalla, Shpo, the Santa Ynez Band of Chumash Indians; Re., Diablo Canyon ISFSI Initiating Section 106 Consultation ML23320A2442023-11-28028 November 2023 Letter to Kerri Vera, Director of Department of Environmental Protection, Tule River Tribe; Re., Diablo Canyon ISFSI Initiating Section 106 Consultation ML23325A1382023-11-27027 November 2023 ISFSI Tribal Letter to San Luis Obispo County Chumash Indians ML23325A1322023-11-27027 November 2023 ISFSI Tribal Letter to Salian Tribe of Montgomery, San Luis Obispo ML23325A1332023-11-27027 November 2023 ISFSI Tribal Letter to Yak Tityu Tityu Northern Chumash Indians ML23307A0062023-11-27027 November 2023 ISFSI Tribal Letter to Northern Chumash Tribal Council ML24003A7242023-11-27027 November 2023 Independent Safety Committee; Diab Lo Canyon Nuclear Power Plant Operations, Thirty-Third Annual Report on the Safety ML23325A1292023-11-27027 November 2023 ISFSI Tribal Letter to Coastal Band of Chumash ML23320A1502023-11-17017 November 2023 Individual Notice of Consideration of Issuance of Amendment to Facility Operating License, Proposed No Significant Hazards Consideration Determination, & Opportunity for Hearing (Exigent Circumstances) (EPID L-2023-LLA-0155) - LTR DCL-23-121, Supplement to License Amendment Request 23-03, Revision to Technical Specification3.7.8, Auxiliary Saltwater System2023-11-16016 November 2023 Supplement to License Amendment Request 23-03, Revision to Technical Specification3.7.8, Auxiliary Saltwater System ML23296A0982023-11-15015 November 2023 Notification and Request for Consultation Regarding Pacific Gas and Electric Diablo Canyon Independent Spent Fuel Storage Installation Material License Renewal Request (Docket Number: 72-26) DCL-23-120, License Amendment Request 23-03 Revision to Technical Specification 3.7.8, Auxiliary Saltwater (Asw) System2023-11-14014 November 2023 License Amendment Request 23-03 Revision to Technical Specification 3.7.8, Auxiliary Saltwater (Asw) System ML23293A1052023-11-14014 November 2023 Receipt and Availability of License Renewal Application IR 05000275/20230032023-11-13013 November 2023 Integrated Inspection Report 05000275/2023003 and 05000323/2023003 ML23311A2082023-11-0909 November 2023 Reassignment of U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch IV DCL-23-118, License Renewal Application2023-11-0707 November 2023 License Renewal Application ML23318A2102023-10-31031 October 2023 Independent Safety Committee; Thirty-Third Annual Report on the Safety of Diablo Canyon Nuclear Power Plant Operations DCL-2023-520, Discharge Self-Monitoring at Diablo Canyon Power Plant (DCPP)2023-10-19019 October 2023 Discharge Self-Monitoring at Diablo Canyon Power Plant (DCPP) DCL-23-103, Independent Spent Fuel Storage Installation - Withdrawal of License Amendment Request 22-01, Request for Approval of Alternative Security Measures for Early Warning System2023-10-13013 October 2023 Independent Spent Fuel Storage Installation - Withdrawal of License Amendment Request 22-01, Request for Approval of Alternative Security Measures for Early Warning System IR 05000275/20240152023-10-10010 October 2023 Information Request for the Cybersecurity Baseline Inspection, Notification to Perform Inspection (050002752024015 and 050003232024015) 2024-02-09
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OWestinghouse WWestinghouse Electric Company Nuclear Services P.O. Box 355 Pittsburgh, Pennsylvania 15230-0355 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (412) 374-4011 Washington, DC 20555-0001 e-mail: greshaja@westinghouse.com Our ref: LTR-NRC-07-28 May 23, 2007
Subject:
SER Compliance with WCAP-16260-P-A "The Spatially Corrected Inverse Count Rate (SCICR)
Method for Subcritical Reactivity Measurement" (Proprietary/Non-Proprietary)
Enclosed are copies of the Proprietary/Non-Proprietary SER Compliance with WCAP- 16260-P-A "The Spatially Corrected Inverse Count Rate (SCICR) Method for Subcritical Reactivity Measurement."
Per SER Limitations and Conditions documented in the NRC's SER for WCAP-16260, Limitation and Condition # 2 specifies the following:
"2. Reactivity-sensitivity analyses must be conducted and submitted to the NRC staff for review/audit on a plant-specific basis to predetermine the masking effect (biases) so that they can be accounted for in SCICR applications to the plant."
The first application of this methodology for Diablo Canyon Unit 1 is planned for Cycle 15. Enclosed are the reactivity-sensitivity analyses to determine the plant-specific masking effect for Diablo Canyon Unit 1 discussed in the enclosure.
Also enclosed is:
- 1. One (1) copy of the Application for Withholding, AW-07-2286 (Non-Proprietary) with Proprietary Information Notice.
- 2. One (1) copy of Affidavit (Non-Proprietary).
This submittal contains proprietary information of Westinghouse Electric Company LLC. In conformance with the requirements of 10 CFR Section 2.390, as amended, of the Commission's regulations, we are enclosing with this submittal an Application for Withholding from Public Disclosure and an affidavit. The affidavit sets forth the basis on which the information identified as proprietary may be withheld from public disclosure by the Commission.
Correspondence with respect to this affidavit or Application for Withholding should reference AW-07-2286 and should be addressed to J. A. Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.
rs, f ey rly 1 J.A. Gresham, Manager Regulatory Compliance and Plant Licensing Enclosures cc: A. Mendiola, NRR A. Attard, NRR J. Thompson, NRR H. Cruz, NRR L. M. Feizollahi, NRR Pacific Gas & Electric c/o Diablo Canyon Unit 1 i
W estinghouse Westinghouse Electric Company Nuclear Services P.O. Box 35 5 Pittsburgh, Pennsylvania 15230-0355 USA U.S. Nuclear Regulatory Commission Direct tel: 412/374-4643 ATTN: Document Control Desk Direct fax: 412/374-4011 Washington, DC 20555 e-mail: greshaja@westinghouse.com Our ref: AW-07-2286 May 23, 2007 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
LTR-NRC-07-28 P-Attachment, SER Compliance with WCAP-l 6260-P-A "The Spatially Corrected Inverse Count Rate (SCICR) Method for Subcritical Reactivity Measurement" (Proprietary)
The application for withholding is submitted by Westinghouse Electric Company LLC (Westinghouse) pursuant to the provisions of paragraph (b)(1) of Section 2.390 of the Commission's regulations. It contains commercial strategic information proprietary to Westinghouse and customarily held in confidence.
The proprietary material for which withholding is being requested is identified in the proprietary version of the subject report. In conformance with 10 CFR Section 2.390, Affidavit AW-07-2286 accompanies this application for withholding, setting forth the basis on which the identified proprietary information may be withheld from public disclosure.
Accordingly, it is respectfully requested that the subject information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.
Correspondence with respect to this application for withholding or the accompanying affidavit should reference AW-07-2286 and should be addressed to J. A. Gresham, Manager of Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P. 0. Box 355, Pittsburgh, Pennsylvania 15230-0355.
'Manager Regulatory Compliance and Plant Licensing cc: A. Mendiola, NRR A. Attard, NRR J. Thompson, NRR H. Cruz, NRR L. M. Feizollahi, NRR Pacific Gas & Electric c/o Diablo Canyon Unit 1
AW-07-2286 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF ALLEGHENY:
Before me, the undersigned authority, personally appeared J. A. Gresham, 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 Company LLC (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:
JJ. A. Gresham, Manager Regulatory Compliance and Plant Licensing Sworn to and subscribed before me this 4 day of ,2007 Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sharon L.Marlde, Notary Public Monroeville Boro, Allegheny County My Commission Expires Jan. 29,2011 Member, Pennsylvania Association of Notaries
2 AW-07-2286 (1) 1 am Manager, Regulatory Compliance and Plant Licensing, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse) and as such, 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 and rulemaking proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.
(2) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse "Application for Withholding" accompanying this Affidavit.
(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.
(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 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.
(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 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, utilizes 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.
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.
(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, 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.
3 AW-07-2286 (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 commercial value to Westinghouse.
(f) It contains patentable ideas, for which patent protection may be desirable.
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 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 market, and thereby give a market advantage to the competition of 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 10 CFR Section 2.390, it is to be received in confidence by the Commission.
(iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.
4 AW-07-2286 (v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in LTR-NRC-07-28 P-Attachment, SER Compliance with WCAP-16260-P-A "The Spatially Corrected Inverse Count Rate (SCICR) Method for Subcritical Reactivity Measurement,"
(Proprietary), for submittal to the Commission, being transmitted by Westinghouse letter (LTR- NRC-07-28) and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse Electric Company is for NRC review/audit.
This information is part of that which will enable Westinghouse to:
(a) Demonstrate the applicability of the SC]CR Methodology for a specific plant.
(b) Assist customers in implementing an improved measurement technique.
Further this information has substantial commercial value as follows:
(a) Westinghouse can use this methodology to further enhance their licensing position over their competitors.
(b) Assist customers to obtain license changes.
Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar methodology and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.
The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.
In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended for developing the enclosed improved core thermal performance methodology.
Further the deponent sayeth not.
PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.
In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information.
These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).
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Westinghtus.e Non-Proprietary Class 3 LTR-NRC-07-:28NP-Attachment SER Compliance with WCAP-16260-P-A "The Spatially Corrected Inverse Count-Rate (SCICR)
Method for Subcritical Reactivity Measurement" (Non-Proprietary)
Westinghouse Electric Company P.O: Box 355 Pittsburgh, Pennsylvania 15230-0355
© 2007 Westinghouse Electric Company-LLC AlI.Rights Reserved Page 1 of 3
WestinghoUse Non-Proprietary Class 3 Reactivity-Sensitivity Analyses ofSCICR Applicati6n attDiablo Canyon Unit 1 The first application of the spatially corrected inverse-counrtrate (SCICR) method for subcritical reactivity, measurement is planned for Diablo Canyon Unit 1. This method of reactivity measurement is described in the approved Westinghouse Topical Report (TR) WCAP-,16260-P-A. The final safety evaluation performed by the NRC staff (TAC No. MC3,065) included the condition that reactidvity-sensitivity analyses must be conducted and submitted to the NRC' staff for review/auditon a plant-specific, basis to predetermine any masking effect(biases) in the SC!CR applications at each plant. Note that Unit ahas a
different control rod pattern than Unit 2, which has had complete reactivity-sensitivity analyses previously provided to the NRC slif.,
The sensitivity calculations. were performed :in the, sa -memanner as described in Section 5.3 of WCAP- l6260-P-A. The results of the core reactivity, bias and control rod constant bias cases are presented below. These are equivalent t: Tables 5-2 and 5-4 of WcAP-i6260-PA.
Diablo Canyon Unit 1 Quality of the SCICR Line Fit in the Simulated Cases With Core Reactivity and Control Rod Constants Biases
.(RMS =Root Mean Squared, pem 10 -.5) a, c Two types of reactivity-sensitivity conditions Were performnedfor Diablo Canyon Unit 1 (Section .5.3 of the original Westinghouse WCAP- 16260-P submittal). As required :in, the SER, .this is -consistent with all initial plant SCICR applications subsequent. to the review and approval of WCAP-16260[P.
"IC ,
LTR-NRC-07-28 NP-Attachm ent Page.2 of 3
Westinghouse Non-Proprietary Class 3 I
In understanding the
] ~ is the same as other recent SCICR applications [
H, C, again confirming that. these plants also exhibited Mean,/RMS values [ ] ' their reactivity-sensitivity analyses for first in SCICR application. [
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Cwill be used for SCICR applications at Diablo Canyon Unit, 1 as the threshold C
for review of a potential reactivity bias. Like the database of plants provided %in:WCAP-16260-P, a, c.
LTR-NRC-07-28 NP-Attachment Page 3 of 3