ML100321411
| ML100321411 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 01/27/2010 |
| From: | Hartz L Virginia Electric & Power Co (VEPCO) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 09-223A | |
| Download: ML100321411 (12) | |
Text
PROPRIETARY INFORMATION-WITHHOLD UNDER 10 CFR 2.390 VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 January 27, 2010 U.S. Nuclear Regulatory Commission Serial No.
09-223A Attention: Document Control Desk NLOS/GDM R1 Washington, D.C. 20555 Docket Nos.
50-280 50-281 License Nos.
DPR-32 DPR-37 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)
SURRY POWER STATION UNITS 1 AND 2 LICENSE AMENDMENT REQUEST MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE PROPRIETARY SUPPORTING DOCUMENTS Pursuant to 10 CFR 50.90, under separate cover (Letter Serial No.09-223 dated January 27, 2010) Dominion is requesting amendments to Operating Licenses DPR-32 and DPR-37 for Surry Power Station Units 1 and 2, respectively.
This measurement uncertainty recapture (MUR) power uprate License Amendment Request (LAR) would increase each unit's authorized core power level from 2546 megawatts thermal (MWt) to 2587 MWt and make changes to the Surry Technical Specifications as necessary to support operation at the uprated power level. The proposed change is an increase in maximum power level (Rated Thermal Power) of approximately 1.6% from the current reactor output.
Information provided in the attachments to this letter is summarized below:
" Attachment 1 provides the Cameron Application for Withholding Proprietary Information from Public Disclosure, and the associated affidavit, concerning the 10 CFR 2.390 information to be withheld from public disclosure.
- Attachment 2 provides the Cameron Bounding Uncertainty Analysis Report for Surry Unit 1 (Proprietary).
" Attachment 3 provides the Cameron Bounding Uncertainty Analysis Report for Surry Unit 2 (Proprietary).
" Attachment 4 provides the Cameron Meter Factor Report for Surry Unit 1 (Proprietary)
- Attachment 5 provides the Cameron Meter Factor Report for Surry Unit 2 (Proprietary)
Attachments 2 through 5 contain information proprietary to Cameron. The proprietary information is supported by Cameron letter CAW-09-06, "Application for Withholding ATTACHMENTS 2 THROUGH 5 CONTAIN PROPRIETARY INFORMATION THAT IS BEING WITHHELD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390. UPON SEPARATION OF ATTACHMENTS 2 THROUGH 5, THIS PAGE IS DECONTROLLED.
49*91
Serial No. 09-223A Docket Nos. 50-280, 281 Page 2 of 3 Proprietary Information from Public Disclosure," dated September 16, 2009, with accompanying affidavit signed by Cameron, the owner of the information.
The Cameron letter is included in Attachment 1 as noted above. The affidavit sets forth the 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 10 CFR 2.390 of the Commission's regulations.
Accordingly, it is respectfully requested that the information be withheld from public disclosure in accordance with 10 CFR 2.390.
If you have any questions or require additional information, please contact Mr. Gary Miller at (804) 273-2771.
Sincerely, L. N. Hartz Vice President - Nuclear Support Services Commitments made in this letter: None Attachments:
- 1. Cameron Application for Withholding Proprietary Information from Public Disclosure and Associated Affidavit
- 2. Cameron Bounding Uncertainty Analysis Report (ER-650, Rev. 2) for Unit 1 (Proprietary)
- 3. Cameron Bounding Uncertainty Analysis Report (ER-651, Rev. 1) for Unit 2 (Proprietary)
- 4. Cameron Meter Factor Report (ER-684, Rev. 2) for Unit 1 (Proprietary)
- 5. Cameron Meter Factor Report (ER-690, Rev. 2) for Unit 2 (Proprietary)
COMMONWEALTH OF VIRGINIA COUNTY OF HENRICO
))
)
The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Leslie N. Hartz, who is Vice President - Nuclear Support Services, of Virginia Electric and Power Company. She has affirmed before me that she is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of her knowledge and belief.
Acknowledged before me this 7 fday of 2010.
My Commission Expires:
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I VICKI L. HULL Notary Public Commonwealth of Virginia 140542 My Commission Expires May 31, 2010 Notary Public E
I
Serial No. 09-223A Docket Nos. 50-280, 281 Page 3 of 3 cc:
U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW Suite 23T85 Atlanta, Georgia 30303 NRC Senior Resident Inspector Surry Power Station State Health Commissioner Virginia Department of Health James Madison Building - 7th Floor 109 Governor Street Suite 730 Richmond, Virginia 23219 Ms. K. R. Cotton NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G9A 11555 Rockville Pike Rockville, Maryland 20852-2738 Dr. V. Sreenivas NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G9A 11555 Rockville Pike Rockville, Maryland 20852-2738
Serial No. 09-223A Docket Nos. 50-280, 281 CAMERON APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE AND ASSOCIATED AFFIDAVIT Virginia Electric Power Company (Dominion)
Surry Power Station Units 1 and 2
Measurement Systems Caldon5 Ultrasonics Technology Center 1000 McClaren Woods Drive Coraopolis, PA 15108 Tel 724-273-9300 Fax 724-273-9301 it AM E
ONwww.
c-a-rn.com September 16, 2009 CAW 09-06 Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
- 1. Caldon Ultrasonics Engineering Report ER-650 Rev. 2 "Bounding Uncertainty Analysis for Thermal Power Determination at Surry Unit 1 Using the LEFM/ + System"
- 2. Caldon Ultrasonics Engineering Report No. ER-648 Rev. 2, "LEFM./ + Meter Factor Calculation and Accuracy Assessment for Surry Unit 1"
- 3.
Caldon Ultrasonics Engineering Report ER-651 Rev. 1 "Bounding Uncertainty Analysis
- for Thermal Power Determination at Surry Unit 2 Using the LEFM/ + System"*
- 4. Caldon Ultrasonics Engineering Report No. ER-690 Rev. 2, "LEFMI" + Meter Factor Calculation and Accuracy Assessment for Surry Unit 2" Gentlemen:
This application for withholding is submitted by Cameron International Corporation, a Delaware Corporation (herein called "Cameron") on behalf of its operating unit, Caldon Ultrasonics Technology Center, pursuant to the provisions of paragraph (b)(1) of Section 2.390 of the Commission's regulations. It contains trade secrets and/or commercial information proprietary to Cameron and customarily held in confidence.
The proprietary information for which withholding is being requested is identified in the subject submittal. In conformance with 10 CFR Section 2.390, Affidavit CAW 09-06 accompanies this application, for withholding setting forth the basis on which the identified proprietary information may be withheld from public disclosure.
September 16, 2009 Page 2 Accordingly, it is respectfully requested that the subject information, which is proprietary to Cameron, 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 CAW 09-06 and should be addressed to the undersigned.
Very truly yours, Calvin R. Hastings General Manager Enclosures (Only upon separation of the enclosed confidential material should this letter and affidavit be released.)
September 16, 2009 CAW 09-06 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF ALLEGHENY:
Before me, the undersigned authority, personally appeared Calvin R. Hastings, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Cameron International Corporation, a Delaware Corporation (herein called "Cameron") on behalf of its operating unit, Caldon Ultrasonics Technology Center, and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:
Calvin R. Hastiis General Manager Sworn to and subscribed before me this _
_____day of
__-____.__, 2009 Nt Pubhicc COMMONWEALTH OF PENNSYLVANIA Notartal Seal Joann B. Thomas, Notary Public Rnday Twp., Allegheny County My Commirsnion Expires July 28,2011 Member, Pennsylvania Association of Notaries
September 16, 2009 CAW 09-06
- 1. I am the General Manager of Caldon Ultrasonics Technology Center, 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 Cameron.
- 2. 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 Cameron application for withholding accompanying this Affidavit.
- 3. I have personal knowledge of the criteria and procedures utilized by Cameron in designating information as a trade secret, privileged or as confidential commercial or financial information.
The material and information provided herewith is so designated by Cameron, in accordance with those criteria and procedures, for the reasons set forth below.
- 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 Cameron.
(ii)
The information is of a type customarily held in confidence by Cameron and not customarily disclosed to the public. Cameron 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 Cameron policy and provides the rational basis required. Furthermore, the information is submitted voluntarily and need not rely on the evaluation of any rational basis.
September 16, 2009 CAW 09-06 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 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 Cameron's competitors without license from Cameron 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, and assurance of quality, or licensing a similar product.
(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Cameron, its customer or suppliers.
(e) It reveals aspects of past, present or future Cameron or customer funded development plans and programs of potential customer value to Cameron.
(f) It contains patentable ideas, for which patent protection may be desirable.
There are sound policy reasons behind the Cameron system, which include the following:
(a) The use of such information by Cameron gives Cameron a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Cameron competitive position.
September 16, 2009 CAW 09-06 (b) It is information that is marketable in many ways. The extent to which such informationi is available to competitors diminishes the Cameron ability to sell products or services involving the use of the information.
(c) Use by our competitor would put Cameron 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 Cameron of a competitive advantage.
(e) Unrestricted disclosure would jeopardize the position of prominence of Cameron in the world market, and thereby give a market advantage to the competition of those countries.
(f) The Cameron capacity to invest corporate assets in research and development depends upon the success in ob~taining and maintaining a competitive advantage.
(iii)
The information is being transmitted to the Commission in confidence, and, under the provisions of 10 CFR §§ 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 manner or method to the best of our knowledge and belief
September 16, 2009 CAW 09-06 (v) The proprietary information sought to be withheld are the submittals titled:
" Caldon Ultrasonics Engineering Report ER-650 Rev. 2 "Bounding Uncertainty Analysis for Thermal Power Determination at Surry Unit 1 Using the LEFM/ +
System"
" Caldon Ultrasonics Engineering Report No. ER-684 Rev. 2, "LEFM,/ + Meter Factor Calculation and Accuracy Assessment for Surry Unit 1"
" Caldon Ultra~onics Engineering Report ER651 Rev. 1 "Bounding Uncertainty Analysis for Thermal Power Determination at Surry Unit 2 Using the LEFM/ +
System"'
" Caldon Ultrasonics Engineering Report No. ER-690 Rev. 2, "LEFM,/ + Meter Factor Calculation and Accuracy Assessment for Surry Unit 2" It is designated therein in accordance with 10 CFR § § 2.390(b)(1)(i)(A,B), with the reason(s) for confidential treatment noted in the submittal and further described in this affidavit. This information is voluntarily submitted for use by the NRC Staff in their review of the accuracy assessment of the proposed methodology for LEFM CheckPlus Systems used by Surry Units 1 and 2 for an MUR UPRATE.
Public disclosure of this proprietary information is likely to cause substantial harm to the
.competitive position of Cameron because it would enhance the ability of competitors to provide similar flow and temperature measurement systems 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 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 Cameron effort and the expenditure of a considerable sum of money.
September 16, 2009 CAW 09-06 In order for competitors of Cameron to duplicate this information, similar products would have to be developed, 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 analytical methods and receiving NRC approval for those methods.
Further the deponent sayeth not.