ML19345F265
| ML19345F265 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 12/10/2019 |
| From: | Pope A Westinghouse, Westinghouse |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML19346F754 | List: |
| References | |
| LTR-RAC-19-98 | |
| Download: ML19345F265 (6) | |
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 580 l Bluff Road Hopkins, South Carolina 29061-9121 USA Directtel: 803-647-1994 e-mail: popeah@westinghouse.com Your ref:
Our ref: LTR-RAC-19-98 December 10, 2019
SUBJECT:
Westinghouse Response to Request for Additional Information (Cost Activity Code:
L333 l 7)
Westinghouse Electric Company LLC (Westinghouse) is pleased to submit responses to the questions contained in your letter "Request for Additional Information Regarding Westinghouse Electric Company LLC 2019 Decommissioning Funding Plan Update," dated November 15, 2019.
The RAJ responses are proprietary in their entirety, and a non-proprietary version is not submitted. In conformance 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 Information 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 Gerard Couture ofmy staff at (803) 647-2119.
Director, Organizational Effectiveness 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 Responses to CFFF DFP RAis 1-4 (Proprietary) cc: w/o enclosure Mr. Thomas Vukovinsky Ms. Marilyn Diaz
© 2019 Westinghouse Electric Co111pany LLC All Rights Reserved
WESTINGHOUSE NON-PROPRIETARY CLASS 3 ATTACHMENT 1 Page2of6 Our ref: LTR-RAC-19-98 December l 0, 2019 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
Reference:
"Westinghouse Responses to CFFF DFP RAis" (Proprietary)
Letter from Annette Pope to Director, Office of Nuclear Material Safety and Safeguards, LTR-RAC-19-98, dated December 10, 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 )(1) 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 RAI responses are proprietary in their 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 3 of6 Ourref: LTR-RAC-19-98 December I 0, 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 Westinghouse responses to Requests for Additional Information (RAis) on 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 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 and is not customarily disclosed to the public.
(ii)
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 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 information. 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 4 of6 Our ref: LTR-RAC-19-98 December I 0, 2019 (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, strncture, 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 ofresources 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.
(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 of my knowledge, information, and belief.
I declare under penalty of pe1jury that the foregoing is true and correct.
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Executed on: I:;._/ II Id() I °I I
I Page 5 of6 Our ref: L TR-RAC-l 9-98 December 10, 20l9
~*6~
~e, Director, Organizational Effectiveness Westinghouse Columbia Fuel Fabrication Facility
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 6 of6 Our ref: LTR-RAC-19-98 December l 0, 2019 PROPRIETARY INFORMATION NOTICE Transmitted herewith is a proprietary version of a document furnished to the NRC in connection with plant-specific decommissioning 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 Responses to CFFF DFP RA!s 1-4" 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.