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Category:Letter type:NL
MONTHYEARNL-24-0031, Inservice Inspection Program Owner'S Activity Report (OAR-1) for Outage 2R232024-01-29029 January 2024 Inservice Inspection Program Owner'S Activity Report (OAR-1) for Outage 2R23 NL-24-0020, Plan, Unit 1 Responses to NRC Request for Additional Information for Refueling Outage 1R24 Steam Generator Tube Inspection Report2024-01-22022 January 2024 Plan, Unit 1 Responses to NRC Request for Additional Information for Refueling Outage 1R24 Steam Generator Tube Inspection Report NL-23-0926, Correction of Technical Specification Typographical Error2024-01-12012 January 2024 Correction of Technical Specification Typographical Error NL-23-0878, Request for Exemption from Security Event Notification Implementation2023-11-29029 November 2023 Request for Exemption from Security Event Notification Implementation NL-23-0827, Response to Requests for Additional Information for a License Amendment Request and a Proposed Alternative Related to TS 3.4.142023-11-17017 November 2023 Response to Requests for Additional Information for a License Amendment Request and a Proposed Alternative Related to TS 3.4.14 NL-23-0750, Response to Second Request for Additional Information Regarding License Amendment Request: Technical Specification Revision to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the Colr2023-10-0404 October 2023 Response to Second Request for Additional Information Regarding License Amendment Request: Technical Specification Revision to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the Colr NL-23-0745, Refueling Outage 1R24 Steam Generator Tube Inspection Report2023-09-22022 September 2023 Refueling Outage 1R24 Steam Generator Tube Inspection Report NL-23-0695, Response to Round 2 Request for Additional Information Regarding License Amendment Request for Technical Specification 3.8.3, Inverters Operating, Completion Time Extension (LAR-22-002S2)2023-08-31031 August 2023 Response to Round 2 Request for Additional Information Regarding License Amendment Request for Technical Specification 3.8.3, Inverters Operating, Completion Time Extension (LAR-22-002S2) NL-23-0666, License Amendment Request: Remove Combined License Appendix C (LAR 23-008)2023-08-28028 August 2023 License Amendment Request: Remove Combined License Appendix C (LAR 23-008) NL-23-0670, Response to Request for Additional Information Regarding License Amendment Request: Technical Specification Revision to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the COLR Consistent with WCAP-144832023-08-11011 August 2023 Response to Request for Additional Information Regarding License Amendment Request: Technical Specification Revision to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the COLR Consistent with WCAP-14483 NL-23-0658, Southern Nuclear Operating Company - Response to Request for Additional Information Regarding Quality Assurance Topical Report Submittal2023-08-11011 August 2023 Southern Nuclear Operating Company - Response to Request for Additional Information Regarding Quality Assurance Topical Report Submittal NL-23-0672, Licensee Guarantees of Payment of Deferred Premiums2023-08-10010 August 2023 Licensee Guarantees of Payment of Deferred Premiums NL-23-0542, CFR 50.46 ECCS Evaluation Model Annual Report for 20222023-08-0909 August 2023 CFR 50.46 ECCS Evaluation Model Annual Report for 2022 NL-23-0624, Report of Changes to Emergency Plan and Summary of 50.54(q) Analysis2023-08-0404 August 2023 Report of Changes to Emergency Plan and Summary of 50.54(q) Analysis NL-23-0611, Core Operating Limits Report, Cycle 11 Version 12023-07-19019 July 2023 Core Operating Limits Report, Cycle 11 Version 1 NL-23-0584, Preservice Inspection Program Owner'S Activity Report2023-07-10010 July 2023 Preservice Inspection Program Owner'S Activity Report NL-23-0555, Request for Exemption from Physical Barrier Requirement2023-07-0707 July 2023 Request for Exemption from Physical Barrier Requirement NL-23-0506, to Non-Voluntary License Amendment Request: Technical Specification Revision to Adopt WCAP-17661-P-A, Improved RAOC and CAOC Fq Surveillance Technical Specifications2023-07-0505 July 2023 to Non-Voluntary License Amendment Request: Technical Specification Revision to Adopt WCAP-17661-P-A, Improved RAOC and CAOC Fq Surveillance Technical Specifications NL-23-0541, Inservice Inspection Program Owners Activity Report for Outage 1R242023-06-28028 June 2023 Inservice Inspection Program Owners Activity Report for Outage 1R24 NL-23-0444, Quality Assurance Topical Report Submittal2023-06-15015 June 2023 Quality Assurance Topical Report Submittal NL-23-0339, Response to Request for Additional Information Regarding License Amendment Request for Technical Specification 3.8.3, Inverters - Operating, Completion Time Extension (LAR-22-002S1)2023-06-13013 June 2023 Response to Request for Additional Information Regarding License Amendment Request for Technical Specification 3.8.3, Inverters - Operating, Completion Time Extension (LAR-22-002S1) NL-23-0455, Report of 10 CFR 50.59 Changes, Tests, and Experiments and 10 CFR 52 Appendix D Departure Report2023-06-12012 June 2023 Report of 10 CFR 50.59 Changes, Tests, and Experiments and 10 CFR 52 Appendix D Departure Report NL-23-0467, Response to Request for Additional Information Regarding License Amendment Request: Timing of Unit 4 Technical Specifications Effectiveness Prior to Initial Criticality (LAR-23-005S1)2023-06-0909 June 2023 Response to Request for Additional Information Regarding License Amendment Request: Timing of Unit 4 Technical Specifications Effectiveness Prior to Initial Criticality (LAR-23-005S1) NL-23-0346, License Amendment Request for Exception to Regulatory Guide 1.163 (LAR 23-007)2023-05-25025 May 2023 License Amendment Request for Exception to Regulatory Guide 1.163 (LAR 23-007) NL-23-0383, SNC Response to Regulatory Issue Summary 2023-01:Preparation And.2023-05-19019 May 2023 SNC Response to Regulatory Issue Summary 2023-01:Preparation And. NL-23-0385, License Amendment Request: More Restrictive Action for Technical Specification 3.1.9 (LAR-23-006R1)2023-05-17017 May 2023 License Amendment Request: More Restrictive Action for Technical Specification 3.1.9 (LAR-23-006R1) NL-23-0398, Withdrawal of Request of License Amendment Request Regarding More Restrictive Action for Technical Specification 3.1.9 (LAR-23-006)2023-05-16016 May 2023 Withdrawal of Request of License Amendment Request Regarding More Restrictive Action for Technical Specification 3.1.9 (LAR-23-006) NL-23-0372, Units 1 & 2, Joseph M. Farley Nuclear Plant - Units 1 & 2, Vogtle Electric Generating Plant - Units 1 & 2, Annual Radiological Environmental Operating Reports for 20222023-05-10010 May 2023 Units 1 & 2, Joseph M. Farley Nuclear Plant - Units 1 & 2, Vogtle Electric Generating Plant - Units 1 & 2, Annual Radiological Environmental Operating Reports for 2022 NL-23-0360, Supplement to License Amendment Request and Exemptions to Allow Use of Lead Test Assemblies for Accident-Tolerant Fuel2023-05-0505 May 2023 Supplement to License Amendment Request and Exemptions to Allow Use of Lead Test Assemblies for Accident-Tolerant Fuel NL-23-0326, Response to Apparent Violation in NRC Inspection Report 05000424, 425/2023090; EA-22-1082023-05-0101 May 2023 Response to Apparent Violation in NRC Inspection Report 05000424, 425/2023090; EA-22-108 NL-23-0217, License Amendment Request to Revise Technical Specification Surveillance Requirement 3.4.14.1 and Proposed Inservice Testing Alternative ALT-VR-022023-05-0101 May 2023 License Amendment Request to Revise Technical Specification Surveillance Requirement 3.4.14.1 and Proposed Inservice Testing Alternative ALT-VR-02 NL-23-0330, Core Operating Limits Report, Cycle 25, Version 12023-04-26026 April 2023 Core Operating Limits Report, Cycle 25, Version 1 NL-23-0310, Annual Non-Radiological Environmental Operating Reports and Annual Radioactive Effluent Release Reports for 20222023-04-25025 April 2023 Annual Non-Radiological Environmental Operating Reports and Annual Radioactive Effluent Release Reports for 2022 NL-23-0135, License Amendment Request: Timing of Technical Specifications Effectiveness Prior to Initial Criticality (LAR-23-005)2023-04-17017 April 2023 License Amendment Request: Timing of Technical Specifications Effectiveness Prior to Initial Criticality (LAR-23-005) NL-23-0019, GEN-ISI-ALT-2023-01, Request to Use Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI2023-04-12012 April 2023 GEN-ISI-ALT-2023-01, Request to Use Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI NL-23-0152, License Amendment Request: Technical Specification Revision to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the COLR Consistent with WCAP-144832023-04-11011 April 2023 License Amendment Request: Technical Specification Revision to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the COLR Consistent with WCAP-14483 NL-23-0263, Southern Nuclear Company Submittal of Drug and Alcohol Testing Errors Identified 10 CFR 26.719(c) 30-Day Report2023-04-0505 April 2023 Southern Nuclear Company Submittal of Drug and Alcohol Testing Errors Identified 10 CFR 26.719(c) 30-Day Report NL-23-0136, License Amendment Request: More Restrictive Action for Technical Specification 3.1.9 (LAR-23-006)2023-04-0505 April 2023 License Amendment Request: More Restrictive Action for Technical Specification 3.1.9 (LAR-23-006) NL-23-0132, License Amendment Request: Remove Combined License Appendix C (LAR 23-001)2023-04-0404 April 2023 License Amendment Request: Remove Combined License Appendix C (LAR 23-001) NL-23-0014, Southern Nuclear Operating Co Submittal of Report on Status of Decommissioning Funding2023-03-29029 March 2023 Southern Nuclear Operating Co Submittal of Report on Status of Decommissioning Funding NL-23-0208, Independent Spent Fuel Storage Installation ISFSI, Decommissioning Funding Plan Triennial Update2023-03-29029 March 2023 Independent Spent Fuel Storage Installation ISFSI, Decommissioning Funding Plan Triennial Update NL-23-0193, Request for License Amendment: Relocation of TS 3.7.9, Spent Fuel Pool Makeup Water Sources (LAR-23-003)2023-03-24024 March 2023 Request for License Amendment: Relocation of TS 3.7.9, Spent Fuel Pool Makeup Water Sources (LAR-23-003) NL-23-0196, Response to Request for Additional Information Regarding License Amendment Request for Alternative Source Term, TSTF-51, TSTF-471, and TSTF-4902023-03-24024 March 2023 Response to Request for Additional Information Regarding License Amendment Request for Alternative Source Term, TSTF-51, TSTF-471, and TSTF-490 NL-23-0228, Nuclear Property Insurance Coverage as of April 1, 2023 and Licensee Guarantees of Payment of Deferred Premiums (10 CFR 140.21)2023-03-20020 March 2023 Nuclear Property Insurance Coverage as of April 1, 2023 and Licensee Guarantees of Payment of Deferred Premiums (10 CFR 140.21) NL-22-0977, License Amendment Request to Modify Technical Specification 5.5.11.c Acceptance Criteria for Charcoal Filter Testing2023-02-0909 February 2023 License Amendment Request to Modify Technical Specification 5.5.11.c Acceptance Criteria for Charcoal Filter Testing NL-23-0010, Response to Request for Additional Information Regarding License Amendment Request for Alternative Source Term, TSTF-51, TSTF-471, and TSTF-4902023-02-0606 February 2023 Response to Request for Additional Information Regarding License Amendment Request for Alternative Source Term, TSTF-51, TSTF-471, and TSTF-490 NL-23-0076, Exigent License Amendment Request: Technical Specification Exceptions for In-containment Refueling Water Storage Tank Operability Prior to Initial Criticality (LAR-23-004)2023-01-31031 January 2023 Exigent License Amendment Request: Technical Specification Exceptions for In-containment Refueling Water Storage Tank Operability Prior to Initial Criticality (LAR-23-004) NL-23-0013, Response to Request for Additional Information Related to 10CFR 50.75 Decommissioning Funding Assurance Requirements2023-01-30030 January 2023 Response to Request for Additional Information Related to 10CFR 50.75 Decommissioning Funding Assurance Requirements NL-23-0068, Responses to NRC Request for Additional Information Related to the Refueling Outage 2R22 Steam Generator Tube Inspection Report2023-01-27027 January 2023 Responses to NRC Request for Additional Information Related to the Refueling Outage 2R22 Steam Generator Tube Inspection Report NL-23-0012, Post-Audit Supplement to License Amendment Request and Exemptions to Allow Use of Lead Test Assemblies for Accident-Tolerant Fuel2023-01-20020 January 2023 Post-Audit Supplement to License Amendment Request and Exemptions to Allow Use of Lead Test Assemblies for Accident-Tolerant Fuel 2024-01-29
[Table view] Category:Proprietary Information Review
MONTHYEARML24029A0592024-01-30030 January 2024 Request for Withholding Information from Public Disclosure Responses to NRC Request for Additional Information for Refueling Outage 1R24 Steam Generator Tube Inspection Report Enclosure 2, GAE-NRCD-RF-LR-000002 P-Attachment, Rev. 0 ML23345A1312024-01-0303 January 2024 Withholding Letter - SNC Fleet - Physical Barriers Exemption (L-2023-LLE-0018 and L-2023-LLE-0021) ML23234A2352023-09-0808 September 2023 Request for Withholding Information from Public Disclosure Notification of Full Compliance of Required Action for NRC Order EA-12-049 Mitigation Strategies for Beyond-Design-Basis External Events ML23205A0612023-07-27027 July 2023 Response to Request for Withholding Proprietary Information from Public Disclosure for the Vogtle Electric Generating Plant Enclosure 2 to SNC Letter NL-23-0611 for Unit 4, Core Operating Limits Report, Cycle 1, Version 1 ML23024A1102023-02-0303 February 2023 Request for Withholding Informatio from Public Disclosure License Amendment Req. and Ex to Allow Use of Lead Test Assemblies for Accident Tolerant Fuel Encl 2, Response to NRC Audit Questions Related to Hbhe Lta. ML22297A0242022-10-26026 October 2022 Resp to Req for Withholding Proprietary Info from Public Disclosure for Vogtle 3 and 4, ENC 2 and 4 to SNC Letter ND-22-0817, Req for Alternative (VEGP 3&4-ISI1-ALT-17) ML22266A0492022-09-28028 September 2022 Request for Withholding Info from Public Disclosure LAR and Exemptions to Allow Use of LTAs for ATF - Encl. 1, SNC Response to Requests for Additional Info Attachment 2 Proprietary Response to Questions 2-6 EPID L-2022-LLA-0097 ML22251A3482022-09-16016 September 2022 Request for Withholding Info. from Public Disclosure for Slides in the Closed Session of the Pre-Submittal Meeting Regarding the Proposed Online Monitoring License Amendment Request for Vogtle Electric Generating Plant, Units 1 and 2 EPID L ML22234A0692022-09-15015 September 2022 Request for Withholding Info from Public Disclosure LAR and Exemptions to Allow Use of LTAs for ATF - Enclosure 1, Evaluation of the Proposed Change (Proprietary) EPID L-2022-LLA-0097, LLE-0020, LLE-0021, LLE-0022 ML22255A2032022-09-0202 September 2022 AMS Affidavit for SNC Slides - Pre-Submittal Meeting on September 13, 2022 - Vogtle Online Monitoring LAR ML21270A0212021-10-14014 October 2021 Request for Withholding Information from Public Disclosure WCAP-18647-P, Rev. 0, Technical Basis for Westinghouse Embedded Flaw Repair of the Reactor Vessel Head Penetrations ML21061A2842021-03-0808 March 2021 Request for Withholding Information from Public Disclosure for the Vogtle Electric Generating Plant, Unit 3 Core Operating Limits Report, Cycle 1, Version 3 ML20364A1932020-12-30030 December 2020 Response to Request for Withholding Proprietary Information from Public Disclosure for the Vogtle Electric Generating Plant, Units 3 and 4 Alternative Requirements for ASME Section XI Examination Coverage of Weldolet Branch Connection Welds ML19283C9322019-10-16016 October 2019 Request for Withholding Information from Public Disclosure, Vogtle Electric Generating Plant Units 3 and 4, Related to Request for License Amendment Regarding Protection and Safety Monitoring Revision (LAR-19-001) ML18282A0772018-10-11011 October 2018 Request for Withholding Proprietary Information from Public Disclosure for the Vogtle Electric Generating Plant, Units 3 and 4 (LAR 17-043S1) ML18123A2592018-05-0202 May 2018 Request for Withholding of Proprietary Information from Public Disclosure (ND-18-0853) ML18082A4942018-03-27027 March 2018 Request for Withholding Proprietary Information from Public Disclosure - Vogtle Electric Generating Plant, Units 3 and 4 (LAR 17-028S1) ML18073A1672018-03-19019 March 2018 LAR-17-030 - Proprietary Letter ML18073A1662018-03-19019 March 2018 LAR-17-030S1 - Proprietary Letter Supplement 1 ND-18-0300, Westinghouse Electric Co., Application for Withholding Proprietary Information from Public Disclosure2018-02-27027 February 2018 Westinghouse Electric Co., Application for Withholding Proprietary Information from Public Disclosure ML18033A6712018-02-0909 February 2018 Proprietary Letter (LAR-17-043) ML17310A1012017-11-0808 November 2017 Request for Withholding Information from Public Disclosure ML17191A5702017-07-24024 July 2017 Request for Withholding Information from Public Disclosure ML17191A8332017-07-24024 July 2017 Request for Withholding Information from Public Disclosure for Vogtle Electric Generating Plant, Units 1 and 2 ML17191A6912017-07-24024 July 2017 Request for Withholding Information from Public Disclosure for Vogtle Electric Generating Plant, Units 1 and 2 ML15051A3302015-02-27027 February 2015 Request for Withholding Information from Public Disclosure ML12111A0352012-04-26026 April 2012 Request for Withholding Information from Public Disclosure ML11355A1182012-01-12012 January 2012 Request for Withholding Information from Public Disclosure for Vogtle Electric Generating Plant, Units 1 and 2 ML11103A0682011-05-18018 May 2011 (Vogtle 1 and 2) - Request for Withholding Information from Public Disclosure ML1106902472011-05-16016 May 2011 Request for Withholding Information from Public Disclosure (Tac Nos. ME5067 and ME5068) ML0806504772008-08-0606 August 2008 Request for Withholding Information from Public Disclosure (TAC Nos. MD4727 and MD4728) NL-08-0869, Vogtle, Units 1 and 2 - Enclosure 4, Westinghouse Letter, CAW-08-2449, Application for Withholding and Affidavit, Proprietary Information Notice, and Copyright Notice2008-06-23023 June 2008 Vogtle, Units 1 and 2 - Enclosure 4, Westinghouse Letter, CAW-08-2449, Application for Withholding and Affidavit, Proprietary Information Notice, and Copyright Notice NL-08-0869, Vogtle, Units 1 and 2 - Enclosure 7, Westinghouse Letter, CAW-08-2448, Application for Withholding and Affidavit, Proprietary Information Notice, and Copyright Notice2008-06-23023 June 2008 Vogtle, Units 1 and 2 - Enclosure 7, Westinghouse Letter, CAW-08-2448, Application for Withholding and Affidavit, Proprietary Information Notice, and Copyright Notice ML0818202162008-06-23023 June 2008 Enclosure 7, Westinghouse Letter, CAW-08-2448, Application for Withholding and Affidavit, Proprietary Information Notice, and Copyright Notice ML0818202102008-06-23023 June 2008 Enclosure 4, Westinghouse Letter, CAW-08-2449, Application for Withholding and Affidavit, Proprietary Information Notice, and Copyright Notice ML0809503362008-04-0707 April 2008 Request for Withholding Information from Public Disclosure ML0806605122008-03-10010 March 2008 Request for Withholding Information from Public Disclosure, Response to Request for Additional Information Regarding Technical Specifications 3.3.2 and 3.5.4, MD7772 and MD7773 ML0805200492008-02-28028 February 2008 Request for Withholding Information from Public Disclosure ML0728400822007-10-25025 October 2007 Request for Withholding Information from Public Disclosure (TAC Nos. MD6625 and MD6626) ML0728400172007-10-25025 October 2007 Request for Withholding Information Public Disclosure ML0618003642006-06-28028 June 2006 Westinghouse Electric Company, Request for Withholding Information from Public Disclosure for Vogtle Electric Generating Plant, Units 1 and 2 ML0527906462005-10-20020 October 2005 Withholding Information from Public Disclosure, Tac Nos. MC5863 and MC5864 2024-01-30
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Vogtle Electric Generating Plant Units 1 and License Amendment Request to Revise Technical Specification Sections 5.5.9, "Steam Generator (SG) Program" and TS "Steam Generator Tube Inspection Report" for Interim Alternate Repair Enclosure Westinghouse Letter, CAW-08-2448, Application for Withholding and Proprietary Information Notice, and Copyright Westinghouse Electric Company* westinghouse Nuclear Services P.O. Box355 Pittsburgh, Pennsylvania 15230-0355 USA U.S. Nuclear Regulatory Commission Direct tel: (4]2) 374-4643 Document Control Desk Direct fax: (412) 374-3846 Washington, DC 20555-0001 e-mail: greshaja@westinghouse.com Our ref: CA W-08-2448 June 23, 200S APPLICA nON FOR WITHHOLDING PROPRIETARY INFQRMA nON FROM PUBLIC DISCLOSURE L TR-CDME-OS-43 P-Attachment, "Response to NRC Request for Additional Infonnation Relating to LTR-CDME-GS-ll P-Attachment," dated March IS, 200S (Proprietary)
The proprietary infonnation for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-08-2448 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from pubbc disclosure by the and addresses With specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.
Accordingly, this letter authorizes the utilization of the accompanying affidavit by Southern Nuclear Operating Company. Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CA W-OS-244S, 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.
Very truly yours, .; ..J. A. Gresham, Manager Regulatory Compliance and Plant Licensing Enclosures cc: Jon Thompson (NRC 0-7EIA)
CA W-08-2448 bee: J. A. Gresham (ECE 4-7A) lL R. Bastien, lL (Nivelles, Belgium) C. Brinkman, lL (Westinghouse Electric Co., 12300 Twinbrook Parkway, Suite 330, Rockville, MD 20852) RCPL Administrative Aide (ECE 4-7 A) lL (letter and affidavit only) G. W. Whiteman, Waltz Mill H. O. Lagally, Waltz Mill C. D. Cassino, Waltz Mill J. T. Kandra, Waltz Mill E. C. Arnold, ECE 557A CA W-08-2448 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 offact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief: l 1 !t, k II' /" I-¥J I
' -,'/j1. A. Gresham, Manager Regulatory Compliance and Plant Licensing Sworn to and subscribed before this 23 rd day of June
./ I'Notary Pub IC
CAW-08-2448 I 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 rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse. I 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 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. Pursuantto 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. The information is ofa 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 constitute Westinghouse policy and provide 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: 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.
CA W-08-2448 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. 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. It reveals cost or price infonnation, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers. It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse. It contains patentable ideas, for which patent protection may be desirable.
There are sound policy reasons behind the Westinghouse system which include the following: The use of such infonnation by Westinghouse gives Westinghouse a competitive advantage over its competitors.
It is, therefore, withheld from disclosure to protect the Westinghouse competitive position. It is infonnation that is marketable in many ways. The extent to which such infonnation is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the infonnation. Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense. Each component of proprietary infonnation pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage.
If competitors acquire components of proprietary information, anyone component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.
CA W-08-2448 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. The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage. 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. 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 know ledge and belief. (v) The proprietary information sought to be withheld in this submittal is that which is ----_.._-------------------_._------------_._-------------
...appropriately marked in L TR-CDME-08-43 P-Attachment, "Response to NRC Request for Additional Information (RAI) Relating to L TR-CDME-08-11 P-Attachment," dated March 18, 2008 (Proprietary), for submittal to the Commission, being transmitted by Southern Nuclear Operating Company Application for Withholding Proprietary Information from Public Disclosure to the Document Control Desk. The proprietary information as submitted for use by Westinghouse for Vogtle Unit 2 is expected to be applicable to other licensee submittals in support of implementing an interim alternate repair criterion (IARC) that requires a full-length inspection of the tubes within the tubesheet but does not require plugging tubes with a certain arc length of circumferential cracking below 17 inches from the top of the tubesheet.
This information is part of that which will enable Westinghouse to: (a) Provide documentation of the analyses, methods, and testing for the implementation of an interim alternate repair criterion for the portion if the tubes within the tubesheet of the Vogtle Unit 2 steam generators.
CAW-08-2448 (b) Assist the customer in obtaining NRC approval of the Technical Specification changes associated with the interim alternate repair criterion.
Further this information has substantial commercial value as follows: Westinghouse plans to sell the use of similar information to its customers for the purposes of meeting NRC requirements for licensing documentation. Westinghouse can sen support and defense of the technology to its customers in the licensing process. 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 calculation, evaluation and licensing defense services for commercial power reactors without conunensurate 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 ofa 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.
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).
--COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding.
With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.