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EPID:L-2019-LRO-0067, Submittal to NRC Vessels & Internals Integrity Branch of Plant-Specific Evaluation of the Core Support Barrel Spring 2018 Inspection Results (Open) |
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Category:Legal-Affidavit
MONTHYEARL-2024-053, License Amendment Request L-2024-053, Updated Spent Fuel Pool Criticality Analysis2024-04-30030 April 2024 License Amendment Request L-2024-053, Updated Spent Fuel Pool Criticality Analysis L-2022-046, Subsequent License Renewal Application Revision - Documents WCAP-18623-P/NP Revision 1 Submittal2022-04-13013 April 2022 Subsequent License Renewal Application Revision - Documents WCAP-18623-P/NP Revision 1 Submittal ML21285A1092021-09-16016 September 2021 Enclosure 2: St. Lucie Nuclear Plant, Units 1 and 2, Subsequent Licensee Renewal Application, Revision 1 - Affidavits ML21215A3172021-08-0303 August 2021 Enclosure 2: Affidavits Supporting Withholding Proprietary Information from Public Disclosure L-2020-066, Submittal of WCAP-18452-P, Revision 1, Core Support Barrel and Core Shroud Flaw Analysis2020-04-30030 April 2020 Submittal of WCAP-18452-P, Revision 1, Core Support Barrel and Core Shroud Flaw Analysis L-2019-130, Revised Plant-Specific Evaluation of the Core Support Barrel Spring 2018 Inspection Results2019-08-19019 August 2019 Revised Plant-Specific Evaluation of the Core Support Barrel Spring 2018 Inspection Results L-2019-013, Submittal to NRC Vessels & Internals Integrity Branch of Plant-Specific Evaluation of the Core Support Barrel Spring 2018 Inspection Results2019-02-11011 February 2019 Submittal to NRC Vessels & Internals Integrity Branch of Plant-Specific Evaluation of the Core Support Barrel Spring 2018 Inspection Results L-2016-143, Response to Request for Additional Information for the Proposed Technical Specification Change to Remove the 10 Year Sediment Cleaning of the Fuel Oil Storage Tank and Relocate to Licensee-Controlled Documents2016-07-15015 July 2016 Response to Request for Additional Information for the Proposed Technical Specification Change to Remove the 10 Year Sediment Cleaning of the Fuel Oil Storage Tank and Relocate to Licensee-Controlled Documents ML15356A1842015-12-0808 December 2015 St. Lucie, Unit 2 - RAI Response for Snpb RAI-9 for the Technical Specification LAR and Exemption Request Regarding the Transitioning to Areva Fuel L-2015-279, RAI Response Clarification for SRXB-RAI-1 and Snpb RAI-2 Thru RAI-20 for the Technical Specification LAR and Exemption Request Regarding the Transitioning to Areva Fuel2015-11-0303 November 2015 RAI Response Clarification for SRXB-RAI-1 and Snpb RAI-2 Thru RAI-20 for the Technical Specification LAR and Exemption Request Regarding the Transitioning to Areva Fuel ML14079A4452014-03-20020 March 2014 Affidavit of Omar R. Lopez-Santiago Concerning Sace'S Claims Regarding Staff'S Steam Generator Inservice Inspection L-2012-207, Response to NRC Reactor Systems Branch Request for Additional Information Regarding Extended Power Uprate License Amendment Request2012-05-0303 May 2012 Response to NRC Reactor Systems Branch Request for Additional Information Regarding Extended Power Uprate License Amendment Request L-2012-171, Response to NRC Nuclear Performance Branch Request for Additional Information Regarding Extended Power Uprate License Amendment Request2012-04-19019 April 2012 Response to NRC Nuclear Performance Branch Request for Additional Information Regarding Extended Power Uprate License Amendment Request L-2012-075, Response to NRC Mechanical and Civil Engineering Branch (Emcb) Request for Additional Information Regarding Extended Power Uprate License Amendment Request2012-03-0606 March 2012 Response to NRC Mechanical and Civil Engineering Branch (Emcb) Request for Additional Information Regarding Extended Power Uprate License Amendment Request L-2011-464, Response to NRC Instrumentation & Controls Branch Request for Additional Information Regarding Extended Power Uprate License Amendment Request2011-11-0101 November 2011 Response to NRC Instrumentation & Controls Branch Request for Additional Information Regarding Extended Power Uprate License Amendment Request L-2011-413, Submittal of Attachment 2, Response to NRC Reactor Systems Branch Request for Additional Information Re Extended Power Uprate License Amendment Request2011-09-29029 September 2011 Submittal of Attachment 2, Response to NRC Reactor Systems Branch Request for Additional Information Re Extended Power Uprate License Amendment Request ML1107301162011-02-25025 February 2011 St. Lucie, Unit 2 - License Amendment Request for Extended Power Uprate L-2011-021, St. Lucie, Unit 2 - License Amendment Request for Extended Power Uprate2011-02-25025 February 2011 St. Lucie, Unit 2 - License Amendment Request for Extended Power Uprate ML1035604192010-11-22022 November 2010 St. Lucie, Unit 1 - Transmittal of Affidavits from Westinghouse, Areva and Caldon Ultrasonica Technology Center Re License Amendment Request for Extended Power Uprate L-2010-259, St. Lucie, Unit 1 - Transmittal of Affidavits from Westinghouse, Areva and Caldon Ultrasonica Technology Center Re License Amendment Request for Extended Power Uprate2010-11-22022 November 2010 St. Lucie, Unit 1 - Transmittal of Affidavits from Westinghouse, Areva and Caldon Ultrasonica Technology Center Re License Amendment Request for Extended Power Uprate L-10-384, Extended Power Uprate Licensing Report, Attachment 6; Applications for Withholding Proprietary Information from Public Disclosure2010-11-0909 November 2010 Extended Power Uprate Licensing Report, Attachment 6; Applications for Withholding Proprietary Information from Public Disclosure ML18227B3061978-08-25025 August 1978 Application for Extension of Time L-78-135, Forwarding Amendments 1 and 2 to Report CEN-79-P, Reactor Operation with Guide Tube Wear.1978-04-17017 April 1978 Forwarding Amendments 1 and 2 to Report CEN-79-P, Reactor Operation with Guide Tube Wear. ML18088A8561978-03-31031 March 1978 Response to 3/10/1978 Letter. Submits Affidavit of Messrs. Kent, Bivans and Flugger, and 12/14/1977 Fpl'S Response to Nrc'S Questions Concerning 5/16/1977 Outage Enclosed ML18114A2331978-02-27027 February 1978 Letter to Confirm Report CEN-79-P Reactor Operation with Guide Tube Wear Was Delivered to Nrc. Requests That Report Be Withheld from Public Disclosure ML18127A5771977-11-0404 November 1977 Affidavit of Clifford s Kent ML18088A8701976-08-0404 August 1976 Supplemental Affidavit of Robert E. Bathen Florida Power & Light Company Nuclear Units NRC Docket Nos. 50-335A, 50-389A, 50-250A, and 50-251A ML18088A8991976-08-0404 August 1976 Supplemental Affidavit of Robert E. Bathen Before the Nuclear Regulatory Commission of the United States ML18088B1771976-07-29029 July 1976 Supplemental Affidavit of Robert A. Jablon ML18088A8681976-04-14014 April 1976 Affidavit of Robert E. Bathen Florida Power & Light Company Nuclear Units NRC Docket No. P-636-A and NRC Docket No. 50-389-A Before the Nuclear Regulatory Commission of the United States ML18088A8691976-04-14014 April 1976 Affidavit of Harry C. Luff, Jr. Florida Power & Light Company Nuclear Units NRC Docket No. P-636-A and NRC Docket 50-389-A Before the Nuclear Regulatory Commission ML18144A7591975-02-14014 February 1975 Letter Submitting Environmental Technical Specifications for St. Lucie Plant Unit No. 1 2024-04-30
[Table view] Category:Letter type:L
MONTHYEARL-2024-158, Supplemental Information to License Amendment Request to Adopt Common Emergency Plan with Site-Specific Annexes2024-09-25025 September 2024 Supplemental Information to License Amendment Request to Adopt Common Emergency Plan with Site-Specific Annexes L-2024-136, Supplement to License Amendment Request to Adopt Common Emergency Plan with Site-Specific Annexes2024-09-16016 September 2024 Supplement to License Amendment Request to Adopt Common Emergency Plan with Site-Specific Annexes L-2024-138, License Amendment Request L-2024-138, Fuel Methodology Changes in Support of St. Lucie, Unit 2 Transition to 24-Month Fuel Cycles2024-09-11011 September 2024 License Amendment Request L-2024-138, Fuel Methodology Changes in Support of St. Lucie, Unit 2 Transition to 24-Month Fuel Cycles L-2024-148, Submittal of Offsite Dose Calculation Manual (Odcm), Revision 552024-09-0909 September 2024 Submittal of Offsite Dose Calculation Manual (Odcm), Revision 55 L-2024-140, Cycle 28 Core Operating Limits Report2024-08-14014 August 2024 Cycle 28 Core Operating Limits Report L-2024-133, Snubber Program Plan Submittal2024-08-14014 August 2024 Snubber Program Plan Submittal L-2024-132, 2024 Population Update Analysis2024-08-13013 August 2024 2024 Population Update Analysis L-2024-129, Relief Request (RR) 14. Limited Coverage Exams Due to Impractical Inservice Inspection Requirements - Fourth Ten-Year Inservice Inspection Program Interval2024-08-0707 August 2024 Relief Request (RR) 14. Limited Coverage Exams Due to Impractical Inservice Inspection Requirements - Fourth Ten-Year Inservice Inspection Program Interval L-2024-121, Subsequent License Renewal Commitment 30 Revision2024-07-30030 July 2024 Subsequent License Renewal Commitment 30 Revision L-2024-123, Submittal of In-Service Inspection Program Owners Activity Report (OAR-1)2024-07-29029 July 2024 Submittal of In-Service Inspection Program Owners Activity Report (OAR-1) L-2024-125, Notice of Intent to Provide Supplemental Information to License Amendment Request to Adopt Common Emergency Plan with Site-Specific Annexes2024-07-24024 July 2024 Notice of Intent to Provide Supplemental Information to License Amendment Request to Adopt Common Emergency Plan with Site-Specific Annexes L-2024-114, Quality Assurance Topical Report (FPL-1 Revision 31 Annual Submittal2024-07-10010 July 2024 Quality Assurance Topical Report (FPL-1 Revision 31 Annual Submittal L-2024-110, Environmental Protection Plan Report, Unusual or Important Environmental Event - Manatee in Intake2024-07-10010 July 2024 Environmental Protection Plan Report, Unusual or Important Environmental Event - Manatee in Intake L-2024-109, Schedule for Subsequent License Renewal Environmental Review2024-07-0303 July 2024 Schedule for Subsequent License Renewal Environmental Review L-2024-104, Response to Request for Additional Information, St. Luce Relief Request (RR) 7, Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1 Extension of Inspection Interval for Reactor Pressure Vessel Welds from 102024-06-26026 June 2024 Response to Request for Additional Information, St. Luce Relief Request (RR) 7, Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1 Extension of Inspection Interval for Reactor Pressure Vessel Welds from 10 L-2024-097, Technical Specification Special Report2024-06-20020 June 2024 Technical Specification Special Report L-2024-102, Official Service List Update2024-06-19019 June 2024 Official Service List Update L-2024-090, Revised Steam Generator Tube Inspection Reports2024-06-0404 June 2024 Revised Steam Generator Tube Inspection Reports L-2024-075, Notification of Improved Standard Technical Specifications (ITS) Implementation2024-05-13013 May 2024 Notification of Improved Standard Technical Specifications (ITS) Implementation L-2024-053, License Amendment Request L-2024-053, Updated Spent Fuel Pool Criticality Analysis2024-04-30030 April 2024 License Amendment Request L-2024-053, Updated Spent Fuel Pool Criticality Analysis L-2024-071, Cycle 27 Core Operating Limits Report2024-04-29029 April 2024 Cycle 27 Core Operating Limits Report L-2024-070, Cycle 32 Core Operating Limits Report2024-04-29029 April 2024 Cycle 32 Core Operating Limits Report L-2024-064, Florida Power & Light Company - 10 CFR 50.46 - Emergency Core Cooling System SBLOCA 30-Day Report2024-04-17017 April 2024 Florida Power & Light Company - 10 CFR 50.46 - Emergency Core Cooling System SBLOCA 30-Day Report L-2024-056, Annual Radiological Environmental Operating Report for Calendar Year 20232024-04-17017 April 2024 Annual Radiological Environmental Operating Report for Calendar Year 2023 L-2024-054, 2023 Annual Environmental Operating Report2024-04-0909 April 2024 2023 Annual Environmental Operating Report L-2024-047, Proposed Use of a Subsequent ASME Code Edition and Addenda2024-03-28028 March 2024 Proposed Use of a Subsequent ASME Code Edition and Addenda L-2024-045, Report of 10 CFR 72.48 Plant Changes2024-03-27027 March 2024 Report of 10 CFR 72.48 Plant Changes L-2024-011, and Point Beach, Units 1 and 2 - 10 CFR 50.46 Annual Reporting of Changes to, or Errors in Emergency Core Cooling System Models or Applications2024-03-13013 March 2024 and Point Beach, Units 1 and 2 - 10 CFR 50.46 Annual Reporting of Changes to, or Errors in Emergency Core Cooling System Models or Applications L-2024-023, Unusual or Important Environmental Event - Turtle Mortality2024-03-0606 March 2024 Unusual or Important Environmental Event - Turtle Mortality L-2024-015, 2023 Annual Radioactive Effluent Release Report2024-02-29029 February 2024 2023 Annual Radioactive Effluent Release Report L-2024-029, 2023 Annual Operating Report2024-02-28028 February 2024 2023 Annual Operating Report L-2024-026, Revised Reactor Vessel Materials Surveillance Capsule Withdrawal Schedules2024-02-27027 February 2024 Revised Reactor Vessel Materials Surveillance Capsule Withdrawal Schedules L-2024-010, Point Units 3 and 4, Seabrook, Duane Arnold, and Point Beach Units 1 and 2, Nuclear Property Insurance - 10 CFR 50.54(w)(3)2024-01-25025 January 2024 Point Units 3 and 4, Seabrook, Duane Arnold, and Point Beach Units 1 and 2, Nuclear Property Insurance - 10 CFR 50.54(w)(3) L-2024-004, Relief Request (RR) 7, Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) Extension of Inspection Interval for Reactor Pressure Vessel Welds from 10 to 20 Years2024-01-18018 January 2024 Relief Request (RR) 7, Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) Extension of Inspection Interval for Reactor Pressure Vessel Welds from 10 to 20 Years L-2024-002, Withdrawal of Proposed Alternative to American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code for the Auxiliary Feedwater (AFW) 2C Pump2024-01-0808 January 2024 Withdrawal of Proposed Alternative to American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code for the Auxiliary Feedwater (AFW) 2C Pump L-2023-173, Quality Assurance Topical Report (FPL-1) Revision 30 Update2023-12-15015 December 2023 Quality Assurance Topical Report (FPL-1) Revision 30 Update L-2023-179, Unusual or Important Environmental Event - Turtle Mortality2023-12-14014 December 2023 Unusual or Important Environmental Event - Turtle Mortality L-2023-168, License Amendment Request Supplement to Revision 2 for the Technical Specifications Conversion to NUREG-1432 Revision 52023-12-12012 December 2023 License Amendment Request Supplement to Revision 2 for the Technical Specifications Conversion to NUREG-1432 Revision 5 L-2023-155, Supplement to Response to Request for Additional Information, Revised NextEra Common Emergency Plan, and Revised Site-Specific Emergency Plan Annexes Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-06542023-11-28028 November 2023 Supplement to Response to Request for Additional Information, Revised NextEra Common Emergency Plan, and Revised Site-Specific Emergency Plan Annexes Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, L-2023-162, Response to 50.69 2nd Round of Rals2023-11-21021 November 2023 Response to 50.69 2nd Round of Rals L-2023-131, Subsequent License Renewal Application - Second Annual Update2023-09-28028 September 2023 Subsequent License Renewal Application - Second Annual Update L-2023-136, Supplement to License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors2023-09-26026 September 2023 Supplement to License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors L-2023-122, Corrections to the 2022 Annual Radiological Environmental Operating Report2023-09-20020 September 2023 Corrections to the 2022 Annual Radiological Environmental Operating Report L-2023-127, Correction to the 2022 Annual Radioactive Effluent Release Report2023-09-18018 September 2023 Correction to the 2022 Annual Radioactive Effluent Release Report L-2023-113, Correction to the 2020 Annual Radiological Environmental Operating Report2023-09-14014 September 2023 Correction to the 2020 Annual Radiological Environmental Operating Report L-2023-118, Response to Request for Additional Information Regarding License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors2023-09-11011 September 2023 Response to Request for Additional Information Regarding License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors L-2023-108, Report of 10 CFR 50.59 Plant Changes2023-09-11011 September 2023 Report of 10 CFR 50.59 Plant Changes L-2023-107, Technical Specification Bases Control Program Periodic Report of Bases Changes TS 6.8.4.j.42023-09-0606 September 2023 Technical Specification Bases Control Program Periodic Report of Bases Changes TS 6.8.4.j.4 L-2023-112, Corrections to the 2021 Annual Radioactive Effluent Release Report2023-09-0606 September 2023 Corrections to the 2021 Annual Radioactive Effluent Release Report L-2023-114, Proposed Turkey Point Units 6 and 7; Seabrook Station; Point Beach Units 1 and 2 - Official Service List Update2023-08-17017 August 2023 Proposed Turkey Point Units 6 and 7; Seabrook Station; Point Beach Units 1 and 2 - Official Service List Update 2024-09-09
[Table view] |
Text
Exe1npt From Public Disclosure- 10 CFR 2.390 Infonnation FEB 1 1 2019 L-2019-013 10 CFR 50.4 U.S. Nuclear Regulatory Co1n1nission ATIN: Docu1nent Control Desk Washington, DC 20555 Re: St. Lucie Plant Unit 1 Docket No. 50-335 Renewed Facility Operating License No. DPR-67 Sub1nittal to NRC Vessels & Internals Integrity Branch of Plant-Specific Evaluation of the Core Support Barrel Spring 2018 Inspection Results
References:
(1) FPL Letter L-2011-255, dated July 8, 2011, "Response to NRC Vessels & Internals Integrity Branch Request for Additional Infonnation Regarding Extended Power Uprate License Amendment Request," Accession No. ML11194A016 (2) Final Safety Evaluation by the Office of Nuclear Reactor Regulation for Topical Report WCAP-17096-NP, Revision 2 "Reactor Internals Acceptance Criteria IYiethodology and Data Requirements," Accession No. IviL16061A243 In Reference 1 above, FPL co1nmitted to adopt IYIRP-227 -A with respect to the aging 1nanagement of the reactor vessel and internals (RVI) co1nponents during the period of extended operation. In Reference 2 above, the NRC staff imposed a condition requiring licensees to submit the detailed analysis, replacement schedule, or justification for so1ne other alternative process, within one year of the RVI inspection where degradation is discovered.
Attach1nent 1 to this letter provides an affidavit requesting that Attach1nent 2 be withheld fron1 the public as it contains proprietary infonnation.
Attach1nent 2 provides the disposition for the indications observed on the core shroud and the outside diameter of the St. Lucie Unit 1 core support barrel during the MRP-227 -A inspections conducted during the U1 Spring 2018 refueling outage. The indications are being evaluated against an acceptable flaw length pennitting a one cycle (18-lnonth) return to service (with 1nargin).
Attachment 2 contains proprietary information. Upon removal, this page is uncontrolled.
Florida Power & Light Company 6501 S. Ocean Drive, Jensen Beach, FL 34957
Exempt From Public Disclosure -10 CFR 2.390 Information St. Lucie Unit 1 L-2019-013 Docket No. 50-335 Page 2 of 2 Contact Mr. Michael J. Snyder, St. Lucie Licensing Manger, at (772) 467-7036, if there are any questions about this submittal.
Very truly yours, Daniel DeBoer Site Director St. Lucie Plant Attachments cc: St. Lucie NRC Project Manager St. Lucie NRC Resident Inspector contains proprietary information. Upon removal, this page is uncontrolled.
St. Lucie Unit 1 L-2019-013 Docket No. 50-355 Attachment 1 CA\V-18-4834 Application for \Vithholding proprietary information from Public Disclosure.
Next 7 Pages
Westinghouse Non-Proprietary Class 3
@ Westinghouse Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-3382 Document Control Desk Direct fax: (724) 940-8542 11555 Rockville Pike e-mail: russpa@westinghouse.com Rockville, MD 20852 CAW-18-4834 November 29,2018 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
LTR-AMLR-18-57 Rev 0- "Disposition of Indications Observed in the Core Support Barrel at St. Lucie Unit 1" The Application for Withholding Proprietary Information from Public Disclosure is submitted by Westinghouse Electric Company LLC ("Westinghouse"), pursuant to the provisions of paragraph (b)( 1) of Section 2.390 of the Nuclear Regulatory Commission's ("Commission's") regulations. It contains commercial strategic information proprietary to Westinghouse and customarily held in confidence.
The proprietary information for which withholding is being requested in the subject report is further identified in Affidavit CAW-18-4834 signed by the owner of the proprietary information, West,inghouse.
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 CPR Section 2.390 of the Commission's regulations.
The subject document was prepared and classified as Westinghouse Proprietary Class 2. It contains proprietary
- information throughout, for the reasons set forth in Sections 4(ii) {a, b, c} of this Affidavit. Accordingly, a redacted .
version would be of no value to the public and a non-proprietary version will not be issued.
Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Florida Power &
Light Company.
Correspondence with respect to the proprietary aspects of the Application for Withholding or the Westinghouse Affidavit should reference CAW-18-4834, and should be addressed to Camille T. Zozula, Manager, Infrastructure & Facilities Licensing, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 2, Suite 259, Cranberry Towns~ennsylvania 1~066.
\::Jtyv._}_ a,02~~-
Paul A. Russ, Director Licensing and Regulatory Affairs
Enclosures:
- 1. Mfidavit CAW-18-4834
- 2. Proprietary Information Notice and Copyright Notice
- 3. LTR-AMLR-18-57 Rev. 0- "Disposition of Indications Observed in the Core Support Barrel and Core Shroud at St. Lucie Unit 1"
© 2018 Westinghouse Electric Company LLC. All Rights Reserved.
CAW-18-4834 AFFIDAVIT COMMONW EALTH OF PENNSYLVANIA:
ss COUNTY OF BUTLER:
I, Paul A. Russ, am authorized to execute this Affidavit on behalf of Westinghou se Electric Company LLC ("Westinghouse") and declare that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief.
Executed on: IL ) Z '1.
I t(S1 Paul A. Russ, Director Licensing and Regulatory Affairs
3 CAW-18-4834 (1) I am Director, Licensing and Regulatory Affairs, 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 CPR Section 2.390 of the Nuclear Regulatory Commission's ("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 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
4 CAW-18-4834 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.
(iii) 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.
5 CAW-18-4834 (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, is to be received in confidence by the Commission.
(v) The information sought to be protected is not available in public sources or av~ilable 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 in LTR-AMLR-18-57 Rev. 0, "Disposition of Indications Observed in the Core Support Barrel and Core Shroud at St. Lucie Unit 1" (Proprietary), for submittal to the Commission, being transmitted by Florida Power & Light Company letter. The proprietary information as submitted by Westinghouse is that associated with St. Lucie Unit 1 Core Barrel Flaw Evaluation, and may be used only for that purpose.
(a) This information is part of that which will enable Westinghouse to evaluate Reactor Vessel Internals Core Support Barrel flaws.
(b) Further, this information has substantial commercial value as follows:
6 CAW-18-4834 (i) Westinghouse plans to sell the use of similar information to its customers for the purpose of evaluating Reactor Vessel Internals Core Support Barrel flaws.
(ii) Westinghouse can sell support and defense of industry guidelines and acceptance criteria for plant-specific applications.
(iii) The information requested to be withheld reveals the distinguishing aspects of a methodology 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 technical evaluation justifications 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.
PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and non-proprietary versions of a document, furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.
In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the Affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).
COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is
- permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.