ML19206A043
| ML19206A043 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 07/25/2019 |
| From: | Couture G Westinghouse |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML19206A195 | List: |
| References | |
| CAC L33317, LTR-RAC-19-55 | |
| Download: ML19206A043 (7) | |
Text
WESTINGHOUSE NON-PROPRIETARY CLASS 3
@Westinghouse Director, Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, Maryland 20852-2738 Westinghouse Electric Company LLC Columbia Fuel Site 5801 BluffRoad Hopkins, South Carolina 29061-9 I 2 I USA Direct tel: 803-647-2119 e-mail: couturgf@westinghouse.com Your ref:
Our ref: LTR-RAC-I 9-55 July 25, 2019
SUBJECT:
Westinghouse Submittal of Triennial Update of Decommissioning Funding Plan (Cost Activity Code: L333 l 7)
Westinghouse Electric Company LLC (Westinghouse) is pleased to submit the triennial update of the Columbia Fuel Fabrication Facility Decommissioning Funding Plan.
The plan is proprietary in its entirety, and a non-proprietary version is not submitted. In confonnance with the requirements of 10 CFR 2.390, as amended, of the Commission's regulations, an Application for Withholding Proprietary Information from Public Disclosure, with Proprietary Infonnation and Copyright Notice, and an Affidavit are submitted. The Affidavit sets forth the basis on which the information identified as proprietary may be withheld from public disclosure by the Commission.
If you have any questions, please contact me at (803) 647-2119.
~.Jt~
Gerard F. Couture, Licensing Manager, Acting Westinghouse Columbia Fuel Fabrication Facility Docket 70-1151 License SNM-1107 Attachment
- 1.
Application for Withholding Proprietary Information from Public Disclosure with Proprietary Information Notice and Copyright Notice and One (1) copy of Affidavit (Non-Proprietary)
Enclosure
- 1.
Westinghouse Columbia Fuel Fabrication Facility Decommissioning Funding Plan (Proprietary)
© 2019 Westinghouse Electric Cornpany LLC All Rights Reserved
WESTINGHOUSE NON-PROPRIETARY CLASS 3 cc: w/o enclosure U. S. Nuclear Regulatory Commission, Region II 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, Georgia 30303-1257 Attn: Mr. Thomas Vukovinsky U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, Maryland 20852-2738 Attn: Ms. Marilyn Diaz Mail Stop: TWFN-4A60 Page 2 of7 Our ref: LTR-RAC-19-55 July 25, 2019
' '"' ~...
WESTINGHOUSE NON-PROPRIETARY CLASS 3 ATTACHMENT 1 Page 3 of7 Our ref: LTR-RAC-19-55 July 25, 2019 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
Reference:
"Westinghouse Columbia Fuel Fabrication Facility Decommissioning Funding Plan" (Proprietary)
Letter from Gerard F. Couture to Director, Office of Nuclear Material Safety and Safeguards, LTR-RAC-19-55, dated July 25, 2019 The Application for Withholding Proprietary Information from Public Disclosure is submitted by Westinghouse Electric Company LLC (Westinghouse), pursuant to the provisions of paragraph (b)(l) of Section 2.390 of the Commission's regulations. It contains technical and commercial cost information proprietary to Westinghouse and customarily held in confidence.
The plan is proprietary in its entirety, and a non-proprietary version is not submitted. In conformance with 10 CFR Section 2.390, an Affidavit accompanies this Application for Withholding Proprietary Information from Public Disclosure, setting forth the basis on which the identified proprietary information may be withheld from public disclosure.
Accordingly, it is respectfully requested that the subject information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.
If you have any questions, please contact me at (803) 647-1994.
~~?~
Director, Organizational Effectiveness Westinghouse Columbia Fuel Fabrication Facility Docket 70-1151 License SNM-1107
WESTINGHOUSE NON-PROPRIETARY CLASS 3 AFFIDAVIT STATE OF SOUTH CAROLINA:
COUNTY OF RICHLAND:
Page 4 of7 Our ref: LTR-RAC-19-55 July 25, 2019 (1)
I, Annette Pope have been specifically delegated and authorized to apply for withholding and execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse).
(2)
I am requesting the Columbia Fuel Fabrication Facility (CFFF) Decommissioning Funding Plan (DFP) be withheld from public disclosure under 10 CFR 2.390.
(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 10 CFR 2.390, the following is furnished for consideration by the Commission in detennining 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 and is not customarily disclosed to the public.
(ii)
Public disclosure of this proprietary infonnation is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluations and cost estimates 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.
(5)
Westinghouse has policies in place to identify proprietary infonnation. 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:
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 5 of7 Our ref: LTR-RAC-19-55 July 25, 2019 (a)
The information reveals the distinguishing aspects of a process ( or component, stmcture, 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, stmcture, 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 infonnation, 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.
(6)
The attached submittal contains proprietary information throughout, for the reasons set forth in Sections 5 { (b) and ( d)} of this Affidavit. Accordingly, a redacted version would be of no value to the public.
I declare that the averments of fact set forth in this Affidavit are true and correct to the best ofmy knowledge, information, and belief.
I declare under penalty of perjury that the foregoing is tme and correct.
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Ann tte Pope, Page 6 of7 Our ref: LTR-RAC-19-55 July 25, 2019 Director, Organizational Effectiveness Westinghouse Columbia Fuel Fabrication Facility
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 7 of7 Our ref: LTR-RAC-19-55 July 25, 2019 PROPRIETARY INFORMATION NOTICE Transmitted herewith is a proprietary version of a document furnished to the NRC in connection with plant-specific deco1mnissioning information, and may be used only for that purpose.
COPYRIGHT NOTICE If any documents transmitted herewith bear a Westinghouse copyright notice, the NRC is permitted to make the number of copies of the information contained in this report which are necessary for its internal use in connection with review of the submittal, "Westinghouse Columbia Fuel Fabrication Facility Decommissioning Funding Plan" 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.