Letter Sequence Request |
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TAC:MF3143, Predicting END-OF-CYCLE Mtc and Deleting Need for END-OF-CYCLE Mtc Verifiation (NPSD-911-A), Revise Mtc Surveillance for Startup Test Activity Reduction (STAR) Program (WCAP-16011) (Approved, Closed) |
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MONTHYEARML13329A0382013-08-31031 August 2013 WCAP-17787-NP, Rev 0, Palo Verde Nuclear Generating Station STAR Program Implementation Report. Project stage: Request ML13365A2072013-09-25025 September 2013 Westinghouse Application for Withholding Proprietary Information from Public Disclosure for WCAP-17787-P Project stage: Request ML13329A7002013-11-20020 November 2013 Transmittal of Proprietary Documents for Startup Test Activity Reduction (STAR) Program License Amendment Request Project stage: Request ML13357A2492013-12-20020 December 2013 NRR E-mail Capture - Acceptance Review of Palo Verde Amendment Request Regarding Startup Test Activity Reduction (STAR) Program Project stage: Acceptance Review ML14027A7012014-01-16016 January 2014 Transmittal of Updated Affidavit from Westinghouse for Proprietary Document for Startup Test Activity Reduction (STAR) Program License Amendment Request (LAR) Project stage: Request ML14006A2242014-01-24024 January 2014 Request for Proprietary Withholding of Information - 9/25/13 Affidavit Executed by J. Gresham, Westinghouse WCAP-17787 Project stage: Other ML14042A1822014-02-27027 February 2014 Request for Withholding Information from Public Disclosure - 1/10/14 Affidavit Executed by J. Gresham, Westinghouse WCAP-16011-P-A, Revision 0 Project stage: Withholding Request Acceptance ML15005A0282014-12-19019 December 2014 Response to Request for Additional Information Regarding Application for Technical Specification Change Regarding Moderator Temperature Coefficient Surveillance for Startup Test Activity Reduction Program Project stage: Response to RAI ML15070A1242015-03-30030 March 2015 Issuance of Amendment Nos. 195, 195, and 195, Adopt TSTF-486, Revision 2, Revise Mtc Surveillance for Startup Test Activity Reduction (STAR) Program (WCAP-16011) and TSTF-406, Revision 2 Project stage: Approval 2014-01-16
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Category:Letter
MONTHYEARML24019A2012024-01-19019 January 2024 Fourth 10-Year Interval, Second Period Owners Activity Report Number 1R24 ML24019A1362024-01-18018 January 2024 Inservice Inspection Request for Information ML24012A2452024-01-12012 January 2024 Response to Request for Additional Information to Proposed Method to Manage Environmentally Assisted Fatigue for the Pressurizer Surge Line ML24010A1532024-01-10010 January 2024 Information Request for the Cybersecurity Baseline Inspection, Notification to Perform Inspection ML23341A0062023-12-21021 December 2023 Project Manager Assignment IR 05000528/20230112023-12-18018 December 2023 License Renewal Inspection Report 05000528/2023011 ML23335A0782023-11-30030 November 2023 Independent Spent Fuel Storage Installation - Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML23325A1602023-11-17017 November 2023 Supplemental Submittal - Relief Request 70 Proposed Alternatives for Pressurizer Lower Shell Temperature Nozzle IR 05000528/20234032023-11-13013 November 2023 NRC Security Inspection Report 05000528 2023403, 05000529 2023403, 05000530 2023403 (Full Report) ML23311A2082023-11-0909 November 2023 Reassignment of U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch IV ML23299A3052023-10-26026 October 2023 Response to Request for Additional Information Relief Request 70 Proposed Alternatives for Pressurizer Lower Shell Temperature Nozzle IR 05000528/20230032023-10-17017 October 2023 Integrated Inspection Report 05000528 2023003 and 05000529 2023003 and 05000530 2023003 ML23270B9232023-09-28028 September 2023 Notification of Age-Related Degradation Inspection (05000528/2024012, 05000529/2024012, and 05000530/2024012) and Request for Information ML23251A2332023-09-13013 September 2023 Notification of Post Approval Site Inspection for License Renewal and Request for Information Inspection (05000528/2023011) ML23241B0182023-09-13013 September 2023 Use of Honeywell Mururoa V4F1 and MTH2 Supplied Air Suits within Respiratory Protection Program IR 05000528/20243012023-09-0606 September 2023 Notification of NRC Initial Operator Licensing Examination 05000528/2024301; 05000529/2024301; 05000530/2024301 IR 05000528/20230102023-08-22022 August 2023 Biennial Problem Identification and Resolution Inspection Report 05000528/2023010, 05000529/2023010 and 05000530/2023010 IR 05000528/20230052023-08-21021 August 2023 Updated Inspection Plan for Palo Verde Nuclear Generating Station, Units 1, 2, and 3 (Report 05000528/2023005 and 05000529/2023005 and 05000530/2023005) ML23222A2762023-08-10010 August 2023 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Transportable Storage Canister Identification Numbers AMZDFX175 and AMZDFX176 and Vertical Concrete Cask Identification Numbers AMZDNE175, and AMZDNE176 ML23199A2942023-08-0909 August 2023 Issuance of Amendment Nos. 221, 221, and 221, to Revise Technical Specifications to Adopt TSTF-107, Separate Control Rods That Are Untrippable Versus Inoperable IR 05000528/20230022023-08-0808 August 2023 Integrated Inspection Report 05000528/2023002 and 05000529/2023002 and 05000530/2023002 ML23207A2482023-07-26026 July 2023 License Renewal Pressurizer Surge Line Inspection ML23188A1872023-07-0707 July 2023 Fourth 10-Year Interval, Second Period Owners Activity Report Number 2R24 ML23166B0832023-07-0505 July 2023 Independence Spent Fuel Storage Installation - Issuance of Exemption ML23181A1602023-06-30030 June 2023 2 to Updated Final Safety Analysis Report, and Revision 3 to Operations Quality Assurance Program Description ML23180A2222023-06-29029 June 2023 Application to Revise Technical Specifications (TS) 3.5.1, Safety Injection Tanks (Sits) - Operating, TS 3.5.2, Safety Injection Tanks (Sits) - Shutdown, and TS 3.6.5, Containment Air Temperature ML23181A0772023-06-29029 June 2023 Program Review - Simulator Testing Methodology ML23157A1292023-06-0101 June 2023 Annual Report of Guarantee of Payment of Deferred Premium ML23144A3722023-05-24024 May 2023 Response to Regulatory Issue Summary (RIS) 2023-01, Preparation and Scheduling of Operator Licensing Examinations ML23143A3912023-05-23023 May 2023 Independent Spent Fuel Storage Installation - Request for Exemption from NAC-MAGNASTOR Certificate of Compliance 72-1031 - Cask Lid Batch 3 Design Requirements ML23145A2772023-05-17017 May 2023 10-PV-2023-05 Post-Exam Comments ML23132A3392023-05-12012 May 2023 Application to Revise Technical Specifications 3.3.11 to Adopt TSTF-266-A, Revision 3, Eliminate the Remote Shutdown System Table of Instrumentation and Controls IR 05000528/20230012023-05-0808 May 2023 and Independent Spent Fuel Storage Installation - Integrated Inspection Report 05000528/2023001 and 05000529/2023001 and 05000530/2023001 and 07200044/2023001 ML23128A0692023-05-0808 May 2023 Notification of Biennial Problem Dentification and Resolution Inspection and Request for Information ML23122A1822023-04-29029 April 2023 Transmittal of Technical Specification Bases Revision 76 ML23122A1912023-04-29029 April 2023 Unit 1 Core Operating Limits Report Revision 32, Unit 2 Core Operating Limits Report Revision 25, Unit 3 Core Operating Limits Report Revision 31 ML23116A2772023-04-26026 April 2023 Independent Spent Fuel Storage Installation, Annual Radioactive Effluent Release Report 2022 ML23115A4012023-04-26026 April 2023 Review of the 2022 Steam Generator Tube Inspections During Refueling Outage 23 ML23115A4982023-04-25025 April 2023 2022 Annual Environmental Operating Report IR 05000528/20230122023-04-19019 April 2023 Notification of Commercial Grade Dedication Inspection (05000528/2023012, 05000529/2023012, and 05000530/2023012) and RFI ML23108A0342023-04-18018 April 2023 NRC Initial Operator Licensing Examination Approval 05000528/2023301; 05000529/2023301; 05000530/2023301 ML23103A4642023-04-13013 April 2023 Annual Radiological Environmental Operating Report 2022 ML23103A4312023-04-13013 April 2023 Emergency Core Cooling System Performance Evaluation Models, 10 CFR 50.46(a)(3)(ii) Annual Report for 2022 IR 05000528/20224012023-04-13013 April 2023 Cyber Security Inspection Report 05000528/2022401 and 05000529/2022401 and 05000530/2022401 ML23102A3292023-04-12012 April 2023 Application for Authorized Use of Mururoa Single-Use, Supplied Air Suits, Models V4F1 and MTH2 ML23102A3242023-04-12012 April 2023 Supplement to Application to Revise Technical Specifications to Adopt TSTF-107-A, Separate Control Rods That Are Untrippable Versus Inoperable ML23089A4002023-03-30030 March 2023 Consolidated Decommissioning Funding Status Report - 2022 ML23088A4012023-03-30030 March 2023 Project Manager Assignment IR 05000528/20234022023-03-29029 March 2023 and 3 - NRC Security Inspection Report 05000528-2023402, 05000529-2023402, and 05000530-2023402, (Cover Letter Only) ML23080A3002023-03-21021 March 2023 Present Levels of Financial Protection 2024-01-19
[Table view] Category:License-Application for Facility Operating License (Amend/Renewal) DKT 50
MONTHYEARML23180A2222023-06-29029 June 2023 Application to Revise Technical Specifications (TS) 3.5.1, Safety Injection Tanks (Sits) - Operating, TS 3.5.2, Safety Injection Tanks (Sits) - Shutdown, and TS 3.6.5, Containment Air Temperature ML23132A3392023-05-12012 May 2023 Application to Revise Technical Specifications 3.3.11 to Adopt TSTF-266-A, Revision 3, Eliminate the Remote Shutdown System Table of Instrumentation and Controls ML23122A1822023-04-29029 April 2023 Transmittal of Technical Specification Bases Revision 76 ML23102A3242023-04-12012 April 2023 Supplement to Application to Revise Technical Specifications to Adopt TSTF-107-A, Separate Control Rods That Are Untrippable Versus Inoperable ML23102A3292023-04-12012 April 2023 Application for Authorized Use of Mururoa Single-Use, Supplied Air Suits, Models V4F1 and MTH2 ML22341A6132022-12-0707 December 2022 Application to Revise Technical Specifications to Adopt TSTF-107- a, Separate Control Rods That Are Untrippable Versus Inoperable ML22116A2202022-04-26026 April 2022 Application for Technical Specification Improvement to Adopt TSTF-487-A, Revision 1, Relocate DNB Parameters to the COLR ML22053A2332022-02-22022 February 2022 Application to Revise Technical Specifications to Adopt TSTF-567, Add Containment Sump TS to Address GSI-191 Issues ML21323A1702021-11-19019 November 2021 Technical Specifications Bases Revision 73 ML21210A3102021-07-29029 July 2021 Application to Revise Technical Specifications - Administrative Changes ML21139A3302021-05-19019 May 2021 Application for Order Approving Transfers of Control of Licenses for Minority Interests Subject to Expiring Leases ML21106A3002021-04-16016 April 2021 Technical Specification Bases Revisions 71 and 72 ML21022A4082021-01-22022 January 2021 License Amendment Request for Permanent Extension of Type a and Type C Leak Rate Test Frequencies ML20282A9532020-10-0808 October 2020 License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-501, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control ML20183A4602020-07-0101 July 2020 Application to Revise Technical Specifications to Adopt TSTF-563, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program ML19360A1552019-12-26026 December 2019 License Amendment Request (LAR) - Change in Implementation Date for Amendment Number 209 ML19291F7352019-10-18018 October 2019 Independent Spent Fuel Storage Installation (ISFSI) - License Amendment Request for Changes to Emergency Plan Staffing Requirements ML19225D1972019-08-13013 August 2019 Independent Spent Fuel Storage Facility - Application for Approval of Indirect Transfer of Control of Licenses ML18361A8452018-12-27027 December 2018 Application to Revise Technical Specifications to Adopt TSTF- 529, Revision 4, Clarify Use and Application Rules, Using the Consolidated Line Item Improvement Process ML18187A4172018-07-0606 July 2018 License Amendment Request and Exemption Request to Support the Implementation of Framatome High Thermal Performance Fuel ML18145A3032018-05-25025 May 2018 License Amendment Request to Revise Technical Specifications Regarding Response Time Testing of Pressure Transmitters ML17307A1882017-11-0303 November 2017 License Amendment Request Supplement for Risk-Informed Completion Times ML17200D1622017-07-19019 July 2017 License Amendment Request to Adopt 10 CFR 50.69, Risk-informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power Reactors ML17173A8772017-06-22022 June 2017 Application to Revise Technical Specifications to Adopt TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing ML17165A5552017-06-14014 June 2017 License Amendment Request for Revision to the Cyber Security Plan Implementation Schedule Completion Date ML17066A1832017-01-0404 January 2017 License Conditions Regarding Emergency License Amendment Request to Extend Diesel Generator 38 Completion Time ML16356A6892016-12-21021 December 2016 Emergency License Amendment Request for a One-Time Extension of Diesel Generator Completion Time ML16188A3322016-07-0101 July 2016 License Amendment Request and Exemption Request to Support the Implementation of Next Generation Fuel ML16188A3332016-07-0101 July 2016 Description and Assessment of Proposed License Amendment - Technical Analysis ML16182A1712016-06-29029 June 2016 Application to Revise Technical Specifications to Adopt TSTF-523, Generic Letter 2008-01, Managing Gas Accumulation, Using the Consolidated Line Item Improvement Process ML16043A3612016-01-29029 January 2016 Supplemental Information Regarding License Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis ML15336A0842015-11-30030 November 2015 NET-300047-07 Revision 1, Material Qualification Report of Maxus for Spent Fuel Storage. ML15336A0872015-11-25025 November 2015 License Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis ML15336A0832015-09-30030 September 2015 WCAP-18030-NP, Revision 0, Criticality Safety Analysis for Palo Verde Nuclear Generating Station, Units 1, 2, and 3. ML15247A5182015-09-0404 September 2015 Exigent License Amendment Request to Amend Technical Specification Surveillance Requirement 3.1.5.3 for Control Element Assembly 88 for the Remainder of Cycle 19 ML15218A3002015-07-31031 July 2015 License Amendment Request to Revise Technical Specifications to Adopt TSTF-505-A, Revision 1, Risk-Informed Completion Times ML15065A0312015-02-27027 February 2015 License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-439-A, Revision 2, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO ML13329A7002013-11-20020 November 2013 Transmittal of Proprietary Documents for Startup Test Activity Reduction (STAR) Program License Amendment Request ML13280A2642013-09-27027 September 2013 Request to Amend Technical Specification 3.3.3, Control Element Assembly Calculators and TS 3.3.6, Engineered Safety Features Actuation System (ESFAS) Logic and Manual Trip ML13242A0872013-08-26026 August 2013 Response to Request for Additional Information Regarding License Amendment Request for Adoption of Technical Specifications Task Force Traveler TSTF-500, Revision 2, DC Electrical Rewrite - Update to TSTF-360 ML13002A1972012-12-26026 December 2012 License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-500, Revision 2, DC Electrical Rewrite - Update to TSTF-360 ML12353A1582012-12-12012 December 2012 Application for Technical Specification Improvement to Adopt TSTF-490, Revision 0, Deletion of E-Bar Definition and Revision to RCS Specific Activity Technical Specifications ML11334A0462011-11-22022 November 2011 Request for Amendment to Various Technical Specifications to Implement Administrative Changes ML11182A9082011-06-22022 June 2011 Request for Amendment to Technical Specification 3.7.4, Atmospheric Dump Valves (Advs). ML11103A0532011-03-31031 March 2011 License Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee-Controlled Program ML1035600882011-01-19019 January 2011 Issuance of Amendment Nos. 184, 184, and 184, Revise Technical Specification 5.5.8, Inservice Testing Program, to Implement TS Task Force (TSTF)-479-A as Modifed by TSTF-497-A ML1025101612010-08-27027 August 2010 Request for Operating License Amendment - Revision of Feedwater Line Break with Loss of Offsite Power and Single Failure Analysis ML1024500512010-08-25025 August 2010 Request for Amendment to Technical Specification 3.7.4, Atmospheric Dump Valves (Advs). ML1023603352010-08-12012 August 2010 Response to July 21, 2010, Request for Additional Information Regarding Metal Fatigue for the Review of the License Renewal Application, and License Renewal Application Amendment No. 22 ML1021502302010-07-22022 July 2010 Resubmittal of Request for Approval of the PVNGS Cyber Security Plan 2023-06-29
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Text
10 CFR 50.90 DWIGHT C. MIMS Senior Vice President, Nuclear Regulatory & Oversight Palo Verde Nuclear Generating Station P.O. Box 52034 Phoenix, AZ 85072 Mail Station 7605 102-06785-DCM/RKR Tel 623 393 5403 November 20, 2013 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, Maryland 20852
Reference:
APS to NRC letter number 102-06784, Palo Verde Nuclear Generating Station, Units 1, 2, and 3, Docket Nos. STN 50-528/529/530, Application for Technical Specification Change Regarding ModeratorTemperature Coefficient (MTC) Surveillance for Startup Test Activity Reduction (STAR) Program Using the ConsolidatedLine Item Improvement Process (CLIIP), dated November 20, 2013
Dear Sirs:
Subject:
Palo Verde Nuclear Generating Station Units 1, 2, and 3 Docket Nos. STN 50-528/529/530 Transmittal of Proprietary'Documents for Startup Test Activity Reduction (STAR) Program License Amendment Request (LAR)
In accordance with the provisions of 10 CFR 50.90 Arizona Public Service Company (APS) submitted a request for an amendment to the technical specifications (TS) for Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2, and 3. The proposed amendment would modify moderator temperature coefficient (MTC) TS surveillance requirements (SR) associated with implementation of WCAP-16011-P-A, Startup Test Activity Reduction (STAR) Program.
The reference letter provided the formal license amendment request and necessary non-proprietary supporting documents. This letter provides the proprietary versions of two supporting documents. Specifically, WCAP-16011, Startup Test Reduction Activity Program, and WCAP-17787, Palo Verde Nuclear Generating Station STAR Program Implementation Report, which are included as Attachment 1 and Attachment 2, respectively. The affidavits to support the proprietary nature of these documents and the basis for being withheld from public disclosure, pursuant to 10 CFR 2.390, are included with each document. Specifically, WCAP-16011-P-A, Startup Test Reduction Activity Program, Revision 0, and WCAP-17787-P, Palo A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway 0 Comanche Peak 0 Diablo Canyon 0 Palo Verde 0 San Onofre
ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Transmittal of Proprietary Documents for Startup Test Activity Reduction (STAR)
Program License Amendment Request (LAR)
Page 2 b
Verde Nuclear GeneratingStation STAR Program Implementation Report, Revision 0, contain information proprietary to Westinghouse Electric Company LLC.
These documents are supported by affidavits signed by Westinghouse, the owner of the information. The affidavits set 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 proprietary documents or the supporting Westinghouse affidavits should reference Westinghouse letters CAW-05-1950 or CAW-13-3820 for WCAP-16011 or WCAP-17787, respectively, and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 310, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.
Should you need further information regarding this amendment request, please contact Robert K. Roehler, Licensing Section Leader, at (623) 393-5241.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on Ah0*<Z*F') 2013 (Date)
Sincerel DCM/RKR/CJS/hsc Attachments:
- 1. WCAP-16011, Startup Test Reduction Activity Program (Proprietary Version)
- 2. WCAP-17787, Palo Verde Nuclear GeneratingStation STAR Program Implementation Report (Proprietary Version) cc: M. L. Dapas NRC Region IV Regional Administrator J. K. Rankin NRC NRR Project Manager M. A. Brown NRC Senior Resident Inspector for PVNGS A. V. Godwin Arizona Radiation Regulatory Agency (ARRA)
T. Morales Arizona Radiation Regulatory Agency (ARRA)
0 Westinghouse Nuclear Services Westinghouse P.O. Box 355 Electric Company Pittsburgh, Pennsylvania 15230-0355 USA U.S. Nuclear Regulatory Commission Direct tel: 412-374-4643 Document Control Desk Direct fax: 412-374-4011 Washington, DC 20555-0001 e-mail: greshaja@westinghouse.com Our ref: CAW-05-1950 March 2, 2005 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
Letter, F. P. Schiffley (WOG) to NRC Document Control Desk, "Transmittal of NRC-Approved Topical Report WCAP-16011-P-A Startup Test Activity Reduction Program (Proprietary)," WOG-05-92 dated March 2, 2005 (Proprietary)
Reference:
Letter, H. Berkow (NRC) to G. Bischoff (WOG), "Final Safety Evaluation for Topical Report WCAP-1601 1-P, Startup Test Activity Reduction Program (TAC No. MB8724),"
dated January 14, 2005.
This Application for Withholding is submitted by Westinghouse Electric Company LLC (Westinghouse) pursuant to the provisions of 10 CFR 2.390(b)(1), as amended, of the Commission's regulations. It pertains to the proprietary information contained in WCAP-16011-P-A, Revision 0, which is transmitted to the NRC as requested by the Reference letter.
In conformance with 10 CFR Section 2.390, Affidavit CAW-05-1950 accompanies this Application for Withholding and sets forth the basis on which the identified proprietary information may be withheld from public disclosure. The justification for claiming this information as proprietary is identified in Sections (4)(ii)(a) through (4)(ii)(f) of the affidavit. Accordingly, Westinghouse respectfully requests that the proprietary information contained in this transmittal be withheld from public disclosure Correspondence with respect to the proprietary aspects of the Application for Withholding or the Westinghouse affidavit should reference this letter, CAW-05-1950, and should be addressed to the undersigned.
Very truly yours, V J.L am-, Managger Regulatory Compliance and Plant Licensing
Enclosure:
cc: G. S. Shukla / NRC A BNFL Group Company
CAW-05-1950 bcc: J. Gresham (ECE 4-7A)
C. Brinkman (Rockville, MD)
R. Bastien, (Nivelles, Belgium)
H. Jones (Windsor)
RCPL Administrative Aide (ECE 4-7A)
CAW-05-1950 AFFIDAVIT STATE OF CONNECTICUT )
) ss: WINDSOR, CT COUNTY OF HARTFORD )
Before me, the undersigned authority, personally appeared Ian C. Rickard, 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:
Ian C. Rickard, Licensing Project Manager Westinghouse Nuclear Services Sworn to and subscribed before me this 1st day of March 2005.
My commission expires May 31, 2008.
CAW-05-1950 Page 2 (1) I, Ian C. Rickard, depose and say that I am the Licensing Project Manager 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 the Westinghouse Electric Company LLC.
(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 accompanying this Affidavit.
(3) 1have personal knowledge of the criteria and procedures utilized by the Westinghouse Electric Company LLC 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 constitute Westinghouse policy and provide the rational basis required.
Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:
(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.
(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.
(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.
(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.
CAW 1950 Page 3 (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.
(iii) There are sound policy reasons behind the Westinghouse system for classification of proprietary information, 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.
(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.
(iv) 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.
(v) 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.
(vi) The proprietary information sought to be withheld in this submittal is that which is appropriately marked and contained in topical report WCAP-1601 1-P-A, Revision 0, entitled "Startup Test Activity Reduction Program."
This information is part of that which will enable Westinghouse to describe the application of the Startup Test Activity Reduction (STAR) program to nuclear power plants, and in particular to supporting utilities in the application of such, including:
CAW-05-1950 Page 4 (a) The identification of important phenomena relevant to the application of the STAR Program topical report, including critical assumptions and acceptance criteria, (b) A generic assessment of the applicability of the STAR Program to PWR utilities, (c) An evaluation of industry startup test problems and the ability of such problems to be resolved by the STAR Program.
(vii) Further this information has substantial commercial value as follows:
(a) Westinghouse plans to sell the use of similar information to its customers for purposes of meeting NRC requirements for licensing documentation.
(b) Westinghouse can sell support and defense of the STAR Program.
(c) The information requested to be withheld reveals the distinguishing aspects of a methodology that 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 advanced nuclear power plant designs and to provide 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.
CAW-05-1950 Page 5 PROPRIETARY INFORMATION-NOTICE Transmitted herewith are proprietary and non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.
That information which is proprietary in the proprietary version is contained within brackets in order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the identification and protection of proprietary information voluntarily transmitted to the NRC. Such proprietary information has been deleted in the non-proprietary version, leaving only the brackets. The justification for claiming the information designated as proprietary is indicated in both versions by means of superscript letters (a) through (f) following the brackets enclosing each item identified as proprietary. These letters refer to the types of information Westinghouse customarily holds in confidence as identified in Sections (4)(ii)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).
COPYRIGHT NOTICE WCAP-1601 1-P-A has been prepared by Westinghouse Electric Company LLC and bears a Westinghouse Electric Company copyright notice. Information in this report is the property of and contains copyright material owned by Westinghouse Electric Company LLC and /or its subcontractors and suppliers.
The NRC is permitted to make the number of copies of the information that are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.