ML20020A008
| ML20020A008 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 01/20/2020 |
| From: | Harper Z Westinghouse, Westinghouse |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20020A007 | List: |
| References | |
| LTR-NRC-20-4, WCAP-18461-NP, WCAP-18461-P | |
| Download: ML20020A008 (4) | |
Text
Westinghouse Non-Proprietary Class 3
@Westinghouse U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA Direct tel: (412) 374-5093 e-mail: harperzs@westinghouse.com LTR-NRC-20-4 January 20, 2020
Subject:
Submittal ofWCAP-18461-P and WCAP-18461-NP, "Common Q Platform and Component Interface Module System Elimination of Technical Specification Surveillance Requirements" (Proprietary/Non-Proprietary)
Enclosed are the proprietary and non-proprietary versions of WCAP-18461, "Common Q Platform and Component Interface Module System Elimination of Technical Specification Surveillance Requirements," submitted for NRC review and approval.
Westinghouse requests to be considered for a modified review in which the Safety Evaluation will be issued 12 months after submittal. The primary reason for this request is the licensing precedence for this approach was established in a Vogtle 3&4 LAR (MLI 9084A309 and MLI 9280E4 l 4) and associated Safety Evaluation (ML l 9297C988/ML19297D159).
This submittal contains proprietary information of Westinghouse Electric Company LLC ("Westinghouse"). In conformance with the requirements of IO CFR Section 2.390, as amended, of the Nuclear Regulatory Commission's
("Commission's") regulations, we are enclosing with this submittal an Affidavit. The Affidavit sets forth the basis on which the information identified as proprietary may be withheld from public disclosure by the Commission.
Correspondence with respect to the proprietary aspects of this submittal or the Westinghouse Affidavit should reference A W-20-4995 and should be addressed to Zachary S. Harper, Manager, Licensing Engineering, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 1, Cranberry Township, PA 16066.
cc: Ekaterina Lenning (NRC)
Dennis Morey (NRC)
Joseph Holonich (NRC)
Enclosures:
I. Affidavit AW-20-4995 ary S. Harper, Manager Licensing Engineering
- 2.
WCAP-18461-P, "Common Q Platform and Component Interface Module System Elimination of Technical Specification Surveillance Requirements" (Proprietary)
- 3.
WCAP-18461-NP, "Common Q Platform and Component Interface Module System Elimination of Technical Specification Surveillance Requirements" (Non-Proprietary)
© 2020 Westinghouse Electric Company LLC. All Rights Reserved.
Westinghouse Non-Proprietary Class 3 AW-20-4995 Page 1 of 3 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF BUTLER:
(1)
I, Zachary S. Harper, 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 proprietary portions of WCAP-18461-P 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 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.
Westinghouse Non-Proprietary Class 3 AW-20-4995 Page 2 of 3 AFFIDAVIT (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:
(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.
(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 documents are bracketed and marked to indicate the bases for withholding. The justification for withholding 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
Westinghouse Non-Proprietary Class 3 AFFIDAVIT AW-20-4995 Page 3 of3 refer to the types of information Westinghouse customarily holds in confidence identified in Sections (5)(a) through (f) of this Affidavit.
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 perjury that the foregoing is true and correct.
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