ML20066H269

Forwards Wolf Creek Nuclear Operating Corp Transient Analysis Methodology Topical Rept. Rept Withheld (Ref 10CFR2.790)

ML20066H269
Person / Time
Site:	Wolf Creek
Issue date:	02/01/1991
From:	Rhodes F WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
ET-91-0026, ET-91-26, NUDOCS 9102200247
Download: ML20066H269 (5)

Text

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l WQLF CREEK NUCLEAR OPERATING CORPORATION Forrest T. Rhodes vice pr.w.nt February 1, 1991 Engensonng & Techn+cel Servkes U. S. Nuclear Regulatory Commission ATTH: Document Control Desk ,

Mail Station P1-137 Washington, D. C. 20$$$

P Subjects Doclret No. 50-482: WCNOC Transient Analysis Methodology Topical The purpose of this- letter is to submit Wolf Creek Nuclear Operating Corporation's (WCN00) Transient Analysis Methodology Topical Report for Nuclear Regulatory Commission (NRC) review and approval. This submittal was discussed at a meeting between NRC staff and WCNOC which took place on May. ,

The Topical report is being provided as Attachment I.. It la

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18, 1989.

requested that NRC complete its review- and approve this' submittal by June 1, 1992 to support the Cycle 7 operation of Wolf Creek Generating Station. Attachment II of this submittal provides'the projected schedule of submittals for thu Reload Analyses Topical Reports.

In accordance with the provisions of 10 CFR 2.790, it is respectfully requested that Attachment I to this letter be regarded as proprietary information and be withheld from public disclosure on the grounds that it contains trade secrets and confidential commercial information. The affidavit, which accompanies this letter, sets forth the basis by which this information should be withheld from public disclosure by the consnission and addressees.

Attachment I in its entirety should be regarded as proprietary information until NRC review is complete, at which time WCNOC will indicate the specific ,

portions within-the report which are proprietary. .

Very truly yours.

. , ' ]

Forrest T.. Rhodes

-Vice President Engineering & Technical Services FTR/aem t

cci A. T. Howell (NRC), w/a R. D. Martin (NRC), w/a j

D. V. Pickett (NRC), w/a M. E. Skow (NRC), w/a >

P.O. Box 411/ Durhngton, KS 66839 / Phone: (316) 364-8831

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AFFIDAVIT STATE OF KANSAS )

) SS COUNTY OF COFFEY )

Before me, the undersigned authority, personally appeared Forrest T. Rhodes who, being by me duly sworn according to law, deposes and says (1) I am Vice President Engineering & Technical Services for the Wolf Creek Nuclear Operating Corporation (WCNOC). and I have been specifically delegated the function of reviewing the 9toprietary information rought to be withheld from public disclosure in WCHOC's submittal of Transient Analysis Methodology topical report, and am authorized to apply for its withholding on behalf of WCNOC.

(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.790 of the Commission's regulations and in conjunction with WCNOC letter ET 91-0026 Transient Analysis Methodology topical report for submittal accompanying this affidavit.

(3) I have personal knowledge of the criteria and procedures utilized by WCHOC in ?esignating information as a trade secret, privileged or as confidential commercial.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.790 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 has been held in confidence by WCNOC. The information is of' a type customarily held in confidence by other organizations and not customarily disclosed to the public.

Based on a review of 10 CFR 2.790, the information to be held in confidence 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:

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5 (a) The information reveals the distinguishing aspects of a ,

process or.a method, where prevention of its use by any other company without license from WCNOC constitutes a competitive economic advantage over other companies.

(b) It- consists of supporting data relative to a process or a method, the application of which secures a competitive ,

advantage.

(c) Its use by another company would reduce its expenditure of

-resources or improve its competitive position in the design, assurance of quality, or licensing a similar product.

(d) It 1:5 not. the property of WCNOC, but murt be treated as proprietary by WCN00 according to agreements with the owners

• of the information.

Thore are sound reasons behind the WCNOC position which include the followings (a) It is information which is marketable in many ways.

(b) Use by other companies would put WCNOC at a competitive disadvantage by reducing their expenditure of resources at our expense.

(c) 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 WCNOC of a competitive advantage.

(ii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.790, it is to be received in confidence by the Commission.

(iii) The information sought to be protected is not available in public sources to the best of our knowledge and belief.

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l (iv) The proprietary information sought- to be withheld in this submittal is the Tranbient Analysis Methodology topical report, dated January. 1991.

l- The subject information could only be duplicated by competitors if I they were to invest time and effort equivalent to that invested by

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WCNOC provided they have the requisite talent and experience.

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Public disclosure of this information is likely to cause i substantial harm to the competitive position of WCNOC because it would simplify design and evaluation tasks without requiring a commensurate investment of time and effort.

(5) The above statements are true and correct to the best of my knowledge, information and belief.

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'? ' ( , i.* //d Forrr-st T. Rhodes .

Vice President Engineering & T<.shnical Services SUBSCRIBED and sworn to before me this / day of Ab y , 1991.

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Att achment I to ET 91-0026

, ATTACIMENT I TRANSIENT ANALYSIS MET 110DOLOGY TOPICAL REPORT f

_ _ - - _ _ _ _ - _ _ _ _ - - _ - _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ - - _ - _ - _ _ _ - _ _ - - _ - _ _ _ - .