ML20066H270
| ML20066H270 | |
| 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) |
| Shared Package | |
| ML19310D172 | List: |
| References | |
| ET-91-0026, NUDOCS 9102200247 | |
| Download: ML20066H270 (7) | |
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WOLF CREEK NUCLEAR OPERATING CORPORATION Fonest T. Rhodes h%'**",'
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February 1, 1991 ET 91-0026 U. S. Nucisar Regulatory Commission ATTH:
Document Control Desk i
Mail Station P1-137 Washington, D. C.
20555
Subject:
Docket No. 50-482: WCNOC Transient Analysis Methodology Topical The purpose of this letter is to sub:ait Wolf Creek Nuclear Oporating Corporation's (VCNOC) Transient Analysis Methodology Topical Report for Nucler.r Regulatory Connission (NRC) review and approval. This submittal was discussed at a meeting between NRC staff and WCNnC which took ylace on May 18, 1989.
The Topical report is being provided as Attachment I.
It is 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 st.imittals for the Reload' Analyses Topical. Reports.
l In accordance, with.the provisions of 10 CFR 2.790, it is respectfully requeoted that Attachment I to this leMer be regarded as proprietary information and be withheld from public disclosure en the grounds that it contains trade-secrets and confidential ec.mercial information.
The affidavit which accompanies this letter, sets forth the basis tich this information should be. withheld from puslic disclosure by the CA r ion and addressees.-
Attrchment. 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, f
i Forrest T. Rhodes Vice Precident Engineering ; Technical Services PTR/aem t.
cci A. T. Howell (NRC), w/a l
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R. D. Martin (NRC), w/a D. V. Pickett (NRC), w/a M. E. Skov (NRC), w/a
'l-RO. Son 411/ Burtngeort xs cease i Phone: (31s) 364-es31
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. Before'me.,the undersigned authority, personally appeare'J Forrrest T. Rhodes.
who, beinglby me duly sworn according to law, deposes and says:
t (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 proprietary information sought
~
mto be withheld from public disclosure la WCNOC's submittal of Transient
' Analysis Methodology topical report, and am authorized to apply for ite.
withholding on behalf of WCNOC.
(2) 1I am= making this Affidavitz in conformance with;-the prowisions of 110 CFR Section-2.790.of the Commission's regulations and in conjunction with WCNOCJ1etter ET1 91-0026 Transient Analysis Methodology' topical-
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- report.for :sut~'.tta11 accompanying this affidavit.
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{3)-_I have: personal. knowledge ~of the criteria 'andi procedures utilized by WCNOC -in-l designating information as a tradelsecret, privileged or as
-confidentialLeommercial.
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uh (4) ; Pursuant to the-provisions of paragraph (b)(4; of Section 2.790 of. the f
4 Commission's regulations.-tne following-is urnished for consideration
'byothe= Commission;inLdetermining wheth r thi M ccmaticn sought to -be:
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.vithheld from'public. disclosure should be wi'.hheld.
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.(1): The">information: sought to be withheld from public disclosure has
.been hold 11n confidence by1WCNOC.
The.information is of a type customarily: held Lin1. confidence..by other organizations and not j
4L customarily disclosed to the public,
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, Based on a:rev3*w.of 10.CFR'2.790, the.information to be held in j
confidence. falls.in:one or more of several types, the-release of o
which1might result :in; the-l loss of an existing or potential-1 b
gg competitire advantage,Las follows:
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WCNOC RELOAD DESIGN SCHEDULE AUG 90 Rod Exchange & Core T/H Topicals to NRC SEP 90 OCT 90 NOV 90 DEC 90 JAN 91 Transient Topical to NRC FEB 91 hlAR 91 APR 91 hfAY 91 JUN 91 JUL 91 NRC Approval for Rod Exchange Topical AUG 91 SEP 91 OCT 91 NOV 91 DEC 91 Core Design & RSE Topicals to NRC JAN 92 NRC Approval for Core T/H Topical FEB 92 htAR 92 APR 92 htAY 92 JUN 92 NRC Approval for Transient Topical JUL 92 AUG 92 SEP 92 OCT 92 NCV 92 DEC 92 JAN 93 FEB 93 NRC Approval for Core Design & RSE Topicals AIAR 93 AM
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Attachmant 11 to ET 91-0026 j
c ATTACHMENT II PROJECTED SUBKITTALS OF RELOAD ANALYSES TOPICAL REPORTS
.h' (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 VCNOC constitutes a competitive i
economic advantage over other companies.
(b) It consists of supporting data relative to a process er 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, ascurance of quality, or licensing a simalar product.
(d) It is not the property of WCNOC, but must be treated as proprietary by WCNOC according to agreements with the owners of the information.
There are sour.d 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 :ompetitive disadvant' age by reducing their expenditure of resources at our expense.
(c) Each component of proprietary information perti_ent 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.
-(11) The information 10 being transmitted to the Coer.is sion in confidence and, under the provisions of 10 CFR Section 2.790, it is to be received in confidence by the Connission.
(iii) - The information sought to be' protected is not available in public sources to the best of our knowledge and belief.
(iv) The proprietary information sought to be withheld in this submittal is the Transient Analysis Methodology topical report, dated January, 1991.
The subject information could-only be duplicated by competitors if they were to invest time and effort equivalent to that invested by WCNOC provided they have the requisite talent and experience.
2
Public disclosure of this information is likely to cause substantial harm to the competitive-position of WCNOC because it-would simplify design and evaluation tasks without requirjag a commensurate investment of time and effort.
I (5) The above statements are true and correct to the best of my knowledge, information and belief.
Forrest T. Rhodes Vice President Engineering & Technical Services SUBSCRIBED and sworn to before me this
/
day of G
, 1991.
bla4Lk,UL mn Notary Public
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My Comission Expires: 4W N Y/ffY 5
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Attachment I to ET 91-0026 t
ATTACIMENT I TRANSIENT ANALYSIS METHODOI,0GY TOPICAL REPORT
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