ML102380256
| ML102380256 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 08/20/2010 |
| From: | Bajestani M Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML102380256 (34) | |
Text
Withhold from Public Disclosure Under 10 CFR 2.390 Tennessee Valley Authority, Post Office Box 2000, Spring City, Tennessee 37381-2000 August 20, 2010 10 CFR 50.4 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop: OWFN P1-35 Washington, D.C. 20555-0001 Watts Bar Nuclear Plant, Unit 2 NRC Docket No. 50-391
Subject:
WATTS BAR NUCLEAR PLANT (WBN) UNIT 2 - INSTRUMENTATION AND CONTROLS STAFF INFORMATION REQUESTS
Reference:
Licensee Open Items to be Resolved for SER Approval List The purpose of this letter is to provide documents in response to three of NRC's information requests contained in the "Licensee Open Items to be Resolved for SER Approval List." to this letter provides the information requested by NRC., Attachments 1, 3 and 5, contain information proprietary to Westinghouse; and the affidavits for withholding for these documents are contained in Attachments 2, 4 and 6. TVA requests that the Westinghouse proprietary information be withheld from public disclosure in accordance with 10 CFR § 2.390. TVA will submit the nonproprietary versions of these documents to NRC within two weeks of receipt from the vendor. provides the Regulatory Commitment contained in this letter. If you have any questions, please contact William Crouch at (423) 365-2004.
I declare under the penalty of perjury that the foregoing is true and correct. Executed on the 2 0 th day of August, 2010.
Sincerely, Masoud s ani Watts r nit 2 Vice President C
Withhold from Public Disclosure Under 10 CFR 2.390 Tennessee Valley Authority, Post Office Box 2000, Spring City, Tennessee 37381-2000 August 20,2010 u.s. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop: OWFN P1-35 Washington, D.C. 20555-0001 Watts Bar Nuclear Plant, Unit 2 NRC Docket No. 50-391 10 CFR 50.4
Subject:
WATTS BAR NUCLEAR PLANT (WBN) UNIT 2 -INSTRUMENTATION AND CONTROLS STAFF INFORMATION REQUESTS
Reference:
Licensee Open Items to be Resolved for SER Approval List The purpose of this letter is to provide documents in response to three of NRC's information requests contained in the "Licensee Open Items to be Resolved for SER Approval List." to this letter provides the information requested by NRC., Attachments 1, 3 and 5, contain information proprietary to Westinghouse; and the affidavits for withholding for these documents are contained in Attachments 2, 4 and 6. TVA requests that the Westinghouse proprietary information be withheld from public disclosure in accordance with 10 CFR § 2.390. TVA will submit the nonproprietary versions of these documents to NRC within two weeks of receipt from the vendor. provides the Regulatory Commitment contained in this letter. If you have any questions, please contact William Crouch at (423) 365-2004.
I declare under the penalty of perjury that the foregoing is true and correct. Executed on the 20th day of August, 2010.
Sincerely,
U.S. Nuclear Regulatory Commission Page 2 August 20, 2010
Enclosures:
- 1. Responses to Licensee Open Items to be Resolved For SER Approval
- 2. Regulatory Commitment cc (Enclosures):
U. S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200
'Atlanta, Georgia 30303-1257 NRC Resident Inspector Unit 2 Watts Bar Nuclear Plant 1260 Nuclear Plant Road Spring City, Tennessee 37381 U.S. Nuclear Regulatory Commission Page 2 August 20, 2010
Enclosures:
- 1. Responses to Licensee Open Items to be Resolved For SER Approval
- 2. Regulatory Commitment cc (Enclosures):
U. S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200
'Atlanta, Georgia 30303-1257 NRC Resident Inspector Unit 2 Watts Bar Nuclear Plant 1260 Nuclear Plant Road Spring City, Tennessee 37381
Enclosure I TVA Letter Dated 8/20/2010 Watts Bar Nuclear Plant (WBN) Unit 2 Instrumentation And Controls Staff Information Requests This enclosure provides TVA's responses to NRC information requests maintained in the "Licensee Open Items to be Resolved for the SER Approval List." Each NRC information request is identified by the unique numbering system utilized in the aforementioned NRC list of open actions.
- 1. NRC Request (Item Number 66)
By letter dated March 12, 2010, TVA stated that the target submittal date for the "Watts Bar 2 PAMS Software Design Description (two documents, one for flat panel display and one for AC 160)" was March 31, 2010.
TVA Response:
TVA initially responded to this request stating that Westinghouse has made the requested documents available in its Rockville office. However, NRC stated that its review must be based on docketed material. Accordingly, Westinghouse is currently developing nonproprietary versions of the NRC-requested vendor proprietary documents, as well as the corresponding withholding affidavits.
At this time one of the requested documents is available. Attachment 1 contains the following Westinghouse document: "WNA-SD-00250-WBT, Revision 0, 'Software Design Description for the Post Accident Monitoring System AC160 Software' (Proprietary), dated May 2010." Attachment 2 contains the Application for Withholding Proprietary Information for Public Disclosure, CAW-10-2918, dated August 16, 2010, for Attachment 1.
- 2. NRC Request (Item Number 70)
By letter dated March 12, 2010, TVA stated that the target submittal date for the "Concept and Definition Phase V&V Report" was March 31, 2010.
TVA Response:
TVA initially responded to this request stating that Westinghouse has made the requested documents available in its Rockville office. However, NRC stated that its review must be based on docketed material. Accordingly, Westinghouse is currently developing nonproprietary versions of the NRC-requested vendor proprietary documents, as well as the corresponding withholding affidavits. contains the requested Westinghouse Document: "WNA-VR-00283-WBT, Revision 0, 'Watts Bar 2 NSSS Completion Program I&C Projects IV&V Phase Summary Report' (Proprietary), dated March 2010." Attachment 4 contains the Application for Withholding Proprietary Information for Public Disclosure, CAW-10-2912, dated August 11, 2010, for Attachment 3.
TVA Letter Dated 8/20/2010 Watts Bar Nuclear Plant (WBN) Unit 2 Instrumentation And Controls Staff Information Requests This enclosure provides TVA's responses to NRC information requests maintained in the "Licensee Open Items to be Resolved for the SER Approval List." Each NRC information request is identified by the unique numbering system utilized in the aforementioned NRC list of open actions.
- 1. NRC Request (Item Number 66)
By letter dated March 12, 2010, TVA stated that the target submittal date for the "Watts Bar 2 PAMS Software Design Description (two documents, one for flat panel display and one for AC 160)" was March 31, 2010.
TVA Response:
TVA initially responded to this request stating that Westinghouse has made the requested documents available in its Rockville office. However, NRC stated that its review must be based on docketed material. Accordingly, Westinghouse is currently developing nonproprietary versions of the NRC-requested vendor proprietary documents, as well as the corresponding withholding affidavits.
At this time one of the requested documents is available. Attachment 1 contains the following Westinghouse document: "WNA-SD-00250-WBT, Revision 0, 'Software Design Description for the Post Accident Monitoring System AC160 Software' (Proprietary), dated May 2010." Attachment 2 contains the Application for Withholding Proprietary Information for Public Disclosure, CAW-1 0-2918, dated August 16, 2010, for Attachment 1.
- 2. NRC Request (Item Number 70)
By letter dated March 12, 2010, TVA stated that the target submittal date for the "Concept and Definition Phase V&V Report" was March 31,2010.
TVA Response:
TVA initially responded to this request stating that Westinghouse has made the requested documents available in its Rockville office. However, NRC stated that its review must be based on docketed material. Accordingly, Westinghouse is currently developing nonproprietary versions of the NRC-requested vendor proprietary documents, as well as the corresponding withholding affidavits. contains the requested Westinghouse Document: "WNA-VR-00283-WBT, Revision 0, 'Watts Bar 2 NSSS Completion Program I&C Projects IV&V Phase Summary Report' (Proprietary), dated March 2010." Attachment 4 contains the Application for Withholding Proprietary Information for Public Disclosure, CAW-1 0-2912, dated August 11, 2010, for Attachment 3.
TVA Letter Dated 8/20/2010 Watts Bar Nuclear Plant (WBN) Unit 2 Instrumentation And Controls Staff Information Requests
- 3.
NRC Request (Item Number 261)
Please provide the Requirements Traceability Matrix for generic PAMS and/or any other RTMs applicable to WBN2 PAMS. Some requirements in the Software Requirements Specification are simply not present in the Watts Bar 2 PAMS specifiec RTM (WNA-VR-O02 79-WB T).
If some requirements in the SRS are not present in any traceability matrix, please indicate how traceability and verifiability are achieved.
TVA Response: contains the requested Westinghouse document: "WNA-VR-00279-WBT, Revision 0, 'RRAS Watts BAR 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Post Accident Monitoring System' (Proprietary), dated March 2010." Attachment 6 contains the Application for Withholding Proprietary Information for Public Disclosure, CAW-10-2914, dated August 11, 2010, for Attachment 5.
TVA Letter Dated 8/20/2010 Watts Bar Nuclear Plant (WBN) Unit 2 Instrumentation And Controls Staff Information Requests
- 3. NRC Request (Item Number 261)
Please provide the Requirements Traceability Matrix for generic PAMS and/or any other RTMs applicable to WBN2 PAMS. Some requirements in the Software Requirements Specification are simply not present in the Watts Bar 2 PAMS specifiec RTM (WNA-VR-
. 00279-WBT).
If some requirements in the SRS are not present in any traceability matrix, please indicate how traceability and verifiability are achieved.
TVA Response: contains the requested Westinghouse document: "WNA-VR-00279-WBT, Revision 0, 'RRAS Watts BAR 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Post Accident Monitoring System' (Proprietary), dated March 2010." Attachment 6 contains the Application for Withholding Proprietary Information for Public Disclosure, CAW-1 0-2914, dated August 11, 2010, for Attachment 5.
TVA Letter Dated 8120/2010 Watts Bar Nuclear Plant (WBN) Unit 2 Instrumentation And Controls Staff Information Requests Attachments
- 1. Westinghouse Document WNA-SD-00250-WBT, Revision 0, 'Software Design Description for the Post Accident Monitoring System AC160 Software' (Proprietary), dated May 2010.
- 2. Application for Withholding Proprietary Information for Public Disclosure, CAW-10-2918, dated August 16, 2010, for Westinghouse document titled: WNA-SD-00250-WBT, Revision 0, 'Software Design Description for the Post Accident Monitoring System AC160 Software,' dated May 2010.
- 3. Westinghouse Document WNA-VR-00283-WBT, Revision 0, 'Watts Bar 2 NSSS Completion Program I&C Projects IV&V Phase Summary Report' (Proprietary), dated March 2010.
- 4. Application for Withholding Proprietary Information for Public Disclosure, CAW-1 0-2912, dated August 11, 2010, for Westinghouse document titled: WNA-VR-00283-WBT, Revision 0, 'Watts Bar 2 NSSS Completion Program I&C Projects IV&V Phase Summary Report,' dated March 2010.
- 5. Westinghouse Document WNA-VR-00279-WBT, Revision 0, 'RRAS Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Post Accident Monitoring System' (Proprietary), dated March 2010.
- 6. Application for Withholding Proprietary Information for Public Disclosure, CAW-10-2914, dated August 11, 2010, for Westinghouse document titled: WNA-VR-00279-WBT, Revision 0, 'RRAS Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Post Accident Monitoring System,' (Proprietary), dated March 2010.
TVA Letter Dated 8/20/2010 Watts Bar Nuclear Plant (WBN) Unit 2 Instrumentation And Controls Staff Information Requests Attachments
- 1. Westinghouse Document WNA-SD-00250-WBT, Revision 0, 'Software Design Description for the Post Accident Monitoring System AC160 Software' (Proprietary), dated May 2010.
- 2. Application for Withholding Proprietary Information for Public Disclosure, CAW-10-2918, dated August 16, 2010, for Westinghouse document titled: WNA-SD-00250-WBT, Revision 0, 'Software Design Description for the Post Accident Monitoring System AC160 Software,' dated May 2010.
- 3. Westinghouse Document WNA-VR-00283-WBT, Revision 0, 'Watts Bar 2 NSSS Completion Program I&C Projects IV&V Phase Summary Report' (Proprietary), dated March 2010.
- 4. Application for Withholding Proprietary Information for Public Disclosure, CAW-10-2912, dated August 11, 2010, for Westinghouse document titled: WNA-VR-00283-WBT, Revision 0, 'Watts Bar 2 NSSS Completion Program I&C Projects IV&V Phase Summary Report,' dated March 2010.
- 5. Westinghouse Document WNA-VR-00279-WBT, Revision 0, 'RRAS Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Post Accident Monitoring System' (Proprietary), dated March 2010.
- 6. Application for Withholding Proprietary Information for Public Disclosure, CAW-10-2914, dated August 11, 2010, for Westinghouse document titled: WNA-VR-00279-WBT, Revision 0, 'RRAS Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Post Accident Monitoring System,' (Proprietary), dated March 2010.
TVA Letter Dated 8/20/2010 Watts Bar Nuclear Plant (WBN) Unit 2 Instrumentation And Controls Staff Information Requests ATTACHMENT 2 Application for Withholding Proprietary Information for Public Disclosure, CAW-10-2918, dated August 16, 2010, for Westinghouse document titled:
"WNA-SD-00250-WBT, Revision 0, 'Software Design Description for the Post Accident Monitoring System AC160 Software,"' dated May 2010.
TVA Letter Dated 8/20/2010 Watts Bar Nuclear Plant (WBN) Unit 2 Instrumentation And Controls Staff Information Requests ATTACHMENT 2 Application for Withholding Proprietary Information for Public Disclosure, CAW-1 0-2918, dated August 16, 2010, for Westinghouse documenttitled:
"WNA-SD-00250-WBT, Revision 0, 'Software Design Description for the Post Accident Monitoring System AC160 Software,'" dated May 2010.
I
0Westinghouse Westinghouse Electric Company Nudlear 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) 374-3846 Washington, DC 20555-0001 e-mail: greshaja@westinghouse.com Proj letter: WBT-D-2247 CAW-10-2918 August 16, 2010 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
WNA-SD-00250-WBT, Rev. 0, "Software Design Description for the Post Accident Monitoring System AC160 Software", dated May 2010 The proprietary information for which withholding is being requested in the above-referenced reports are further identified in Affidavit CAW-] 0-2918 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 public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.
The subject document was prepared and classified as Westinghouse Proprietary Class 2. Westinghouse requests that this document be considered proprietary in its entirety.
Accordingly, this letter authorizes the utilization of the accompanying affidavit by the Tennessee Valley Authority.
Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-10-2918, 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
-Ut (e Westinghouse U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Westinghouse Electric Company Nudear Services P.O. Box 355 Pittsburgh, Pennsylvania 15230-0355 USA Direct tel: (412) 374-4643 Direct fax: (412) 374-3846 e-mail: gresbaja@westingbouse.com Proj letter: WBT-D-2247 CAW-tO-2918 August 16,2010 APPLICATION FOR WITHHOLDlNG PROPRIETARY lNFORMATION FROM PUBLIC DISCLOSURE
Subject:
WNA-SD-00250-WBT, Rev. 0, "Software Design Description for the Post Accident Monitoring System AC160 Software", dated May 2010 The proprietary information for which withholding is being requested in the above-referenced reports are further identified in Affidavit CA W-l 0-2918 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this Jetter, 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 Section 2.390 of the Commission's regulations.
The subject document was prepared and classified as Westinghouse Proprietary Class 2. Westinghouse requests that this document be considered proprietary in its entirety.
Accordingly, this letter authorizes the utilization of the accompanying affidavit by the Tennessee Valley Authority.
Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-10-2918, 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,
~.~
Regulatory Compliance and Plant Licensing Enclosures
CAW-10-2918 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:
A A. Gresham, Manager Regulatory Compliance and Plant Licensing Sworn to and subscribed before me this 16th day of August 2010 Notary Public6 C00MMONWEALTH OF PENNSYLVANIA Notauial Seal Cynthia Oksky, Notary Public Manor Boro, Westmoreland County My CsmmNsion Exp1res July 16,2014 Member. Pennsylvanla Association of Notaries CAW-10-2918 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:
Sworn to and subscribed before me this 16th day of August 2010 CDMMONWEAlTH OF PENNSYlVANIA Notarfal Seal Cynthia Olesky, Notary Public Manor Boro, Westmoreland County My Cornm!ssIon ExpIres July 16, 2014 Member. Pennsvtvanla AssocIation of Notartes Regulatory Compliance and Plant Licensing
2 2
~CA W-10-29 18 (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 rule making 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 Proprietary Information from Public Disclosure accompanying this Affidavit.
(3) 1 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)X4) 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 2
CAW-IO-2918 (1)
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.
(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 Westinghouse Application for Withholding Proprietary Information from Public Disclosure 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 (bX4) 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
3 CAW-10-2918 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.
(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 that 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.
3 CAW-1O-291S 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.
(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 that 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.
4 4 CAW-10-2918 (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.
(i) 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.
(v)
The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WNA-SD-00250-WBT, Rev. 0, "Software Design Description for the Post Accident Monitoring System AC1 60 Software", dated May 2010, for submittal to the Commission, being transmitted by Tennessee Valley Authority letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with Watts Bar Nuclear Power Plant Unit 2, Post Accident Monitoring System, and may be used only for that purpose.
4 CAW-l 0-2918 (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, anyone 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.
(t)
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.
(v)
The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WNA-SD-002S0-WBT, Rev. 0, "Software Design Description for the Post Accident Monitoring System AC 160 Software", dated May 2010, for submittal to the Commission, being transmitted by Tennessee Valley Authority letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with Watts Bar Nuclear Power Plant Unit 2, Post Accident Monitoring System, and may be used only for that purpose.
5 5
~CAW-1 0-2918 This information is part of that which will enable Westinghouse to:
(a)
Provide information in support of plant Post Accident Monitoring system licensing submittals.
(b) provide customer specific design information relative to Westinghouse standard platform design.
Further this information has substantial commercial value as follows:
(a)
Westinghouse plans to sell the use of similar systems for similar applications to its customers.
(b)
The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.
(c)
The information requested to be withheld reveals the distinguishing aspects of a design which was developed by Westinghouse.
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 simrilar designs, calculations, methodologies 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 stum 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.
5 CAW-I0-2918 This infonnation is part of that which will enable Westinghouse to:
(a)
Provide infonnation in support of plant Post Accident Monitoring system licensing submittals.
(b) provide customer specific design infonnation relative to Westinghouse standard platfonn design.
Further this infonnation has substantial commercial value as follows:
(a)
Westinghouse plans to sell the use of similar systems for similar applications to its customers.
(b)
The infonnation requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.
(c)
The infonnation requested to be withheld reveals the distinguishing aspects of a design which was developed by Westinghouse.
Public disclosure of this proprietary information is likely to cause substantial hann to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar designs, calculations, methodologies and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the infonnation would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the infonnation.
The development of the technology described in part by the infonnation 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 mon~.
In order for competitors of Westinghouse to duplicate this infonnation, similar technical programs would have to be perfonned 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 is the proprietary version of a document furnished to the NRC in connection with requests for generic and/or plant-specific review and approval. The document is to be considered proprietary in its entirety.
COPYRIGHT NOTICE The report transmitted herewith bears a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in this report which is 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. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.
PROPRIETARY INFORMATION NOTICE Transmitted herewith is the proprietary version of a document furnished to the NRC in connection with requests for generic and/or plant-specific review and approval. The document is to be considered proprietary in its entirety.
COPYRIGHT NOTICE The report transmitted herewith bears a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in this report which is 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 proprietaIy by Westinghouse, copyright protection notwithstanding. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.
Tennessee Valley Authority Letter for Transmittal to the NRC The following paragraphs should be included in your letter to the NRC:
Enclosed are:
copies WNA-SD-00250-WBT, Rev. 0, "Software Design Description for the Post Accident Monitoring System AC160 Software", dated May 2010.
Also enclosed is the Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-10-2918, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice.
As Item 1 contains information proprietary to Westinghouse Electric Company LLC, it is supported by an affidavit signed by Westinghouse, the owner of the information. 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 (bX4) of Section 2.390 of the Commission's regulations.
Accordingly, it is respectfully requested that the 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 the copyright or proprietary aspects of the items listed above or the supporting Westinghouse affidavit should reference CAW-10-2918 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.
Tennessee Valley Authority Letter for Transmittal to the NRC The following paragraphs should be included in your letter to the NRC:
Enclosed are:
copies WNA-SD-002S0-WBT, Rev.* 0, "Software Design Description for the Post Accident Monitoring System ACI60 Software", dated May 2010.
Also enclosed is the Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-I 0-2918, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice.
As Item 1 contains information proprietary to Westinghouse Electric Company LLC, it is supported by an affidavit signed by Westinghouse, the owner of the information. 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 Section 2.390 of the Commission's regulations.
Accordingly, it is respectfully requested that the 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 the copyright or proprietary aspects of the items listed above or the supporting Westinghouse affidavit should reference CA W 2918 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.
Enclosure I TVA Letter Dated 8/20/2010 Watts Bar Nuclear Plant (WBN) Unit 2 Instrumentation And Controls Staff Information Requests ATTACHMENT 4 Application for Withholding Proprietary Information for Public Disclosure, CAW-10-2912, dated August 11, 2010, for Westinghouse document titled:
"WNA-VR-00283-WBT, Revision 0, 'Watts Bar 2 NSSS Completion Program I&C Projects IV&V Phase Summary Report," dated March 2010 TVA Letter Dated 8/20/2010 Watts Bar Nuclear Plant (WBN) Unit 2 Instrumentation And Controls Staff Information Requests ATTACHMENT 4 Application for Withholding Proprietary Information for Public Disclosure, CAW-1 0-2912, dated August 11, 2010, for Westinghouse document titled:
"WNA-VR-00283-WBT, Revision 0, 'Watts Bar 2 NSSS Completion Program I&C Projects IV&V Phase Summary Report," dated March 2010
0Westinghouse Westinghouse 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) 374-3846 Washington, DC 20555-0001 e-mail: greshaja@westinghouse.com Proj letter: WBT-D-2247 CAW-10-2912 August 11, 2010 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
WNA-VR-00283-WBT, Rev. 0, "Watts Bar 2 NSSS Completion Program I&C Projects IV&V Phase Summary Report," (Proprietary)
The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-10-2912 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 public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.
The subject document was prepared and classified as Westinghouse Proprietary Class 2. Westinghouse requests that this document be considered proprietary in its entirety.
Accordingly, this letter authorizes the utilization of the accompanying affidavit by the Tennessee Valley Authority.
Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-10-2912, 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 yot s,
/J. A. Gresham, Manager Regulatory Compliance and Plant Licensing Enclosures Westinghouse U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Westinghouse Electric Company Nuclear Services P.O. Box 355 Pittsburgh. Pennsylvania 15230-0355 USA Direct tel: (412) 374-4643 Direct fax: (412) 374-3846 e-mail: greshaja@westinghouse.com Proj letter: WBT-D-2247 CAW-I0-2912 August 11,2010 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
WNA-VR-00283-WBT, Rev. 0, "Watts Bar 2 NSSS Completion Program I&C Projects N&V Phase Summary Report," (Proprietary)
The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW 2912 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 public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.
The subject document was prepared and classified as Westinghouse Proprietary Class 2. Westinghouse requests that this document be considered proprietary in its entirety.
Accordingly, this letter authorizes the utilization of the accompanying affidavit by the Tennessee Valley Authority.
Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-10-2912, 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.
. ~ ery t~ly YOl/fS, dCtJ~
h A. Gresham, Manager Regulatory Compliance and Plant Licensing Enclosures
CAW-10-2912 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:
J. A. Gresham, Manager Regulatory Compliance and Plant Licensing Sworn to and subscribed before me this 11 th day of August 2010 Notary Public SCOMMONWA.TH OF PENNSYi.VMA Notarlal Seal Cynthia Olesfy, Notary Public Manor 8oro, Westmoreand County MY Commission Expires July 16,2014 Memhber Pennsvfvanua Asodatlon of'NOtaries CAW-1O-2912 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:
Sworn to and subscribed before me this 11 th day of August 2010 COMMONWEALnt OF PENNSYlVANIA NOlarfal Seal Cynthia Olesky, Notary Public Manor BolO, Westmoreland County My Commission EXpIres July 16, 2014 Memtle'*. PennSYlvania Assodltlon of Notarfes Ii. A. Gresham, Manager Regulatory Compliance and Plant Licensing
2 CAW-10-2912 (1)
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.
(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 Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.
(3) 1 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 2
CAW-IO-2912 (1)
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.
(2)
I ani 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 Proprietary Information from Public Disclosure 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 infomlation 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
3 CAW-10-2912 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.
(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.
(1)
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 that 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.
3 CAW-I0-2912 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.
(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 that 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.
4 CAW-10-2912 (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.
(v)
The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WNA-VR-00283-WBT, Rev. 0, "Watts Bar 2 NSSS Completion Program I&C Projects IV&V Phase Summary Report," (Proprietary) dated March 2010, for submittal to the Commission, being transmitted by Tennessee Valley Authority letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with Watts Bar Nuclear Power Plant Unit 2, Post Accident Monitoring System and may be used only for that purpose.
4 CAW-JO-29J2 (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, anyone 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.
(v)
The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WNA-VR-00283-WBT, Rev. 0, "Watts Bar 2 NSSS Completion Program I&C Projects IV&V Phase Summary Report," (Proprietary) dated March 2010, for submittal to the Commission, being transmitted by Tennessee Valley Authority letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with Watts Bar Nuclear Power Plant Unit 2, Post Accident Monitoring System and may be used only for that purpose.
5 CAW-10-2912 This information is part of that which will enable Westinghouse to:
(a)
Provide information in support of plant Post Accident Monitoring system licensing submittals.
(b)
Provide customer specific design information relative to Westinghouse standard platform design.
Further this information has substantial commercial value as follows:
(a)
Westinghouse plans to sell the use of similar systems for similar applications to its customers.
(b)
The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.
(c)
The information requested to be withheld reveals the distinguishing aspects of a design which was developed by Westinghouse.
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 designs, calculations, methodologies 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.
Further the deponent sayeth not.
5 CA W-IO-2912 This infonnation is part of that which will enable Westinghouse to:
(a)
Provide infonnation in support of plant Post Accident Monitoring system licensing submittals.
(b)
Provide customer specific design infonnation relative to Westinghouse standard platfonn design.
Further this infonnation has substantial commercial value as follows:
(a)
Westinghouse plans to sell the use of similar systems for similar applications to its customers.
(b)
The infonnation requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.
(c)
The infonnation requested to be withheld reveals the distinguishing aspects of a design which was developed by Westinghouse.
Public disclosure of this proprietary infonnation is likely to cause substantial hann to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar designs, calculations, methodologies and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the infonnation would enable others to use the infonnation to meet NRC requirements for licensing documentation without purchasing the right to use the infonnation.
The development of the technology described in part by the infonnation 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 infonnation, similar technical programs would have to be perfomled 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 is the proprietary version of a document furnished to the NRC in connection with requests for generic and/or plant-specific review and approval. The document is to be considered proprietary in its entirety.
COPYRIGHT NOTICE The report transmitted herewith bears a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in this report which is 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. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.
PROPRIETARY INFORMATION NOTICE Transmitted herewith is the proprietary version of a document furnished to the NRC in connection with requests for generic and/or plant-specific review and approval. The document is to be considered proprietary in its entirety.
COPYRIGHT NOTICE The report transmitted herewith bears a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in this report which is 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. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.
Tennessee Valley Authority Letter for Transmittal to the NRC The following paragraphs should be included in your letter to the NRC:
Enclosed are:
- 1. _ copies of WNA-VR-00283-WBT, Rev. 0, "Watts Bar 2 NSSS Completion Program I&C Projects IV&V Phase Summary Report," (Proprietary) dated March 2010.
Also enclosed is the Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-10-2912, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice.
As Item I contains information proprietary to Westinghouse Electric Company LLC, it is supported by an affidavit signed by Westinghouse, the owner of the information. 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 Section 2.390 of the Commission's regulations.
Accordingly, it is respectfully requested that the 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 the copyright or proprietary aspects of the items listed above or the supporting Westinghouse affidavit should reference CAW-10-2912 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.
Tennessee Valley Authority Letter for Transmittal to the NRC The following paragraphs should be included in your letter to the NRC:
Enclosed are:
L _ copies ofWNA-VR-00283-WBT, Rev. 0, "Watts Bar 2 NSSS Completion Program I&C Projects IV&V Phase Summary Report," (Proprietary) dated March 2010.
Also enclosed is the Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW 2912, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice.
As Item 1 contains information proprietary to Westinghouse Electric Company LLC, it is supported by an affidavit signed by Westinghouse, the owner of the information. 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 Section 2.390 of the Commission's regulations.
Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 ofthe Commission's regulations.
Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse affidavit should reference CAW-IO-2912 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.
TVA Letter Dated 8/20/2010 Watts Bar Nuclear Plant (WBN) Unit 2 Instrumentation And Controls Staff Information Requests ATTACHMENT 6 Application for Withholding Proprietary Information for Public Disclosure, CAW-10-2914, dated August 11, 2010, for Westinghouse document titled:
"WNA-VR-00279-WBT, Revision 0, RRAS Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Post Accident Monitoring System," (Proprietary) dated March 2010.
TVA Letter Dated 8/20/2010 Watts Bar Nuclear Plant (WBN) Unit 2 Instrumentation And Controls Staff Information Requests ATTACHMENT 6 Application for Withholding Proprietary Information for Public Disclosure, CAW-10-2914, dated August 11,2010, for Westinghouse document titled:
"WNA-VR-00279-WBT, Revision 0, RRAS Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Post Accident Monitoring System," (Proprietary) dated March 2010.
efestinghouse Westinghouse Electric Company NuclearServices P.O. Box 3 5 5 Pittsburgh, Pennsylvania 15230-0355 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (412) 374-3846 Washington, DC 20555-0001 e-mail: greshaja@westinghouse.com Proj letter: WBT-D-2247 CAW-10-2914 August 11, 2010 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
WNA-VR-00279-WBT, Rev. 0, "RRAS Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Post Accident Monitoring System,"
(Proprietary)
The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-1 0-2914 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 public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.
The subject document was prepared and classified as Westinghouse Proprietary Class 2. Westinghouse requests that this document be considered proprietary in its entirety.
Accordingly, this letter authorizes the utilization of the accompanying affidavit by the Tennessee Valley Authority.
Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-10-2914, 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 e) Westinghouse Westinghouse Electric Company Nuclear Services P.O. Box355 Pittsburgh. Pennsylvania 15230-0355 USA U.S. Nuclear Regulatory Commission Document Control Desk Direct tel: (412) 3744643 Direct fax: (412) 374-3846 Washington, DC 20555-0001 e-mail: greshaja@westinghouse.com Proj letter: WBT-D-2247
Subject:
CAW-I0-2914 August 11,2010 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMA nON FROM PUBLIC DISCLOSURE WNA-VR-00279-WBT, Rev. 0, "RRAS Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Post Accident Monitoring System."
(Proprietary)
The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW 2914 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 public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.
The subject document was prepared and classified as Westinghouse Proprietary Class 2. Westinghouse requests that this document be considered proprietary in its entirety.
Accordingly, this letter authorizes the utilization of the accompanying affidavit by the Tennessee Valley Authority.
Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CA W-1 0-2914, 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, l~~r Regulatory Compliance and Plant Licensing Enclosures
CAW-10-2914 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:
JAA. Gresham, Manager Regulatory Compliance and Plant Licensing Sworn to and subscribed before me this 11 th day of August 2010 Notary Public COMMONWmEALT OF PENNSYLVANIA Notarial Seal Cynthia Olesky, Notary Public f~nO or oo, Westmorelarp Qiunty nI a, '. wm n
, J:
My Co."mmtsson B*eS J.ul 16; 2014 Member. Pennslvhania AssowaUon o*'lie CAW-IO-2914 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 avennents of fact set forth in this Affidavit are true and correct to the best of his knowledge, infonnation, and belief:
Sworn to and subscribed before me this 11 th day of August 20 I 0 Q.~~~
Notary Public COMMONWEALTH OF PENNSYlVANIA Notarfal Seal Cynthia Olesky, Notary Public Manor Bore, Westmoreland County My Commission ExpIres July 16, 2014 Regulatory Compliance and Plant Licensing
2 CAW-10-2914 (1)
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.
(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 Proprietary Information from Public Disclosure 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 2
CAW-IO-2914 (1)
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.
(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 Westinghouse Application for Withholding Proprietary Information from Public Disclosure 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
3 CAW-10-2914 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.
(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 that 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.
3 CAW-IO-2914 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.
(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 that 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.
4 CAW-10-2914 (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.
(v)
The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WNA-VR-00279-WBT, Rev. 0, "RRAS Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Post Accident Monitoring System," (Proprietary) dated March 2010, for submittal to the Commission, being transmitted by Tennessee Valley Authority letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with Watts Bar Nuclear Power Plant Unit 2, Post Accident Monitoring System and may be used only for that purpose.
4 CAW-IO-2914 (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, anyone 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.
(v)
The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WNA-VR-00279-WBT, Rev. 0, "RRAS Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Post Accident Monitoring System," (Proprietary) dated March 2010, for submittal to the Commission, being transmitted by Tennessee Valley Authority letter and Application for Withholding Proprietary Information from Public Disclosure. to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with Watts Bar Nuclear Power Plant Unit 2, Post Accident Monitoring System and may be used only for that purpose.
5 CAW-10-2914 This information is part of that which will enable Westinghouse to:
(a)
Provide information in support of plant Post Accident Monitoring system licensing submittals.
(b)
Provide customer specific design information relative to Westinghouse standard platform design.
Further this information has substantial commercial value as follows:
(a)
Westinghouse plans to sell the use of similar systems for similar applications to its customers.
(b)
The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.
(c)
The information requested to be withheld reveals the distinguishing aspects of a design which was developed by Westinghouse.
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 designs, calculations, methodologies 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.
Further the deponent sayeth not.
5 CAW-l 0-2914 This information is part of that which will enable Westinghouse to:
(a)
Provide information in support of plant Post Accident Monitoring system licensing submittals.
(b)
Provide customer specific design infonnation relative to Westinghouse standard platform design.
Further this information has substantial commercial value as follows:
(a)
Westinghouse plans to sell the use of similar systems for similar applications to its customers.
(b)
The infonnation requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.
(c)
The infonnation requested to be withheld reveals the distinguishing aspects of a design which was developed by Westinghouse.
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 designs, calculations, methodologies 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 infonnation.
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 infonnation, 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 is the proprietary version of a document furnished to the NRC in connection with requests for generic and/or plant-specific review and approval. The document is to be considered proprietary in its entirety.
COPYRIGHT NOTICE The report transmitted herewith bears a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in this report which is 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. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.
PROPRIETARY INFORMATION NOTICE Transmitted herewith is the proprietary version of a document furnished to the NRC in connection with requests for generic and/or plant-specific review and approval. The document is to be considered proprietary in its entirety.
COPYRIGHT NOTICE The report transmitted herewith bears a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in this report which is 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. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.
Tennessee Valley Authority Letter for Transmittal to the NRC The following paragraphs should be included in your letter to the NRC:
Enclosed are:
- 1. _ copies of WNA-VR-00279-WBT, Rev. 0, "RRAS Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Post Accident Monitoring System," (Proprietary) dated March 2010.
Also enclosed is the Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-10-2914, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice.
As Item I contains information proprietary to Westinghouse Electric Company LLC, it is supported by an affidavit signed by Westinghouse, the owner of the information. 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 Section 2.390 of the Commission's regulations.
Accordingly, it is respectfully requested that the 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 the copyright or proprietary aspects of the items listed above or the supporting Westinghouse affidavit should reference CAW-10-2914 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.
Telmessee Valley Authority Letter for Transmittal to the NRC The following paragraphs should be included in your letter to the NRC:
Enclosed are:
- 1. _copies ofWNA-VR-00279-WBT, Rev. 0, "RRAS Watts Bar 2 NSSS Completion Program I&C Projects Requirements Traceability Matrix for the Post Accident Monitoring System," (Proprietary) dated March 2010.
Also enclosed is the Westinghouse Application for Withholding Proprietary InfOlmation from Public Disclosure CAW 2914, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice.
As Item I contains information proprietary to Westinghouse Electric Company LLC, it is supported by an affidavit signed by Westinghouse, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with speci ficity the considerations Ii sted in paragraph (b)( 4) of Section 2.3 90 of the Commission's regulations.
Accordingly, it is respectfully requested that the 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 the copyright or proprietary aspects of the items listed above or the supporting Westinghouse affidavit should reference CA W 2914 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.
TVA Letter Dated 08/20/2010 Watts Bar Nuclear Plant (WBN) Unit 2 Instrumentation And Controls Staff Information Requests Commitment TVA will submit the nonproprietary versions of WNA-SD-00250-WBT Revision 0, WNA-VR-00283-WBT, Revision 0 and WNA-VR-00279-WBT, Revision 0, to NRC within two weeks of receiving them from the vendor.
TVA Letter Dated 08/20/2010 Watts Bar Nuclear Plant (WBN) Unit 2 Instrumentation And Controls Staff Information Requests Commitment TVA will submit the nonproprietary versions of WNA-SO-00250-WBT Revision 0, WNA-VR-00283-WBT, Revision 0 and WNA-VR-00279-WBT, Revision 0, to NRC within two weeks of receiving them from the vendor.