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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217K4391999-10-18018 October 1999 Provides Response to RAI to Support USI A-46 Program Submittal for North Anna Power Station,Units 1 & 2.Rev 10 to BNL Rept 52361,encl ML20217H3301999-10-14014 October 1999 Forwards Rev 0 to COLR for North Anna 2 Cycle 14 Pattern Su. No New Commitments Intended by Ltr ML18152B3541999-10-12012 October 1999 Requests Use of Code Case N-532 & N-619,per Provisions of 10CFR50.55a(a)(3).Detailed Info Supporting Request,Encl. Attachment 2 Includes Technical White Paper That Provides Further Technical Info ML20216K1681999-10-0101 October 1999 Forwards Vols I-VIII of Rev 35 to UFSAR for Naps.Rev Also Includes Update to Chapter 17 of Ufsar,Which Contains Operational QA Program.Changes to Program Description Do Not Reduce Commitments Contained Therein ML20212J9101999-10-0101 October 1999 Forwards SE Accepting Licensee 990916 & 27 Relief Requests IWE-3 for Plant.Se Addresses Only IWE-3 Due to Util Urgent Need for Relief.Requests IWE-7 & IWE-8 Will Be Addressed at Later Date ML18152B3391999-09-27027 September 1999 Forwards Revised Relief Request IWE-3,which Now Includes Addl Visual Exam Requirement After post-repair or Mod Pressure Testing Is Completed,Per Telcon with NRC ML20212G5091999-09-22022 September 1999 Forwards in Triplicate,Applications for Renewal of Licenses for Listed Individuals.Encls Withheld,Per 10CFR2.790(a)(6) ML18152B6671999-09-17017 September 1999 Forwards Two NRC Forms 536,containing Info on Proposed Site Specific Operator Licensing Exam Schedules & Estimated Number of Applicants Planning to Take Exams And/Or Gfes,In Response to NRC Administrative Ltr 99-03 ML18152B3331999-09-17017 September 1999 Forwards Revised 180-day Response to NRC GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves. ML18152B3341999-09-16016 September 1999 Requests Relief from Specific Requirements of Subsection IWE of 1992 Edition with 1992 Addenda of ASME Section XI Re Containment Liner Examination Requirements,For North Anna & Surry Power Stations ML20211N2531999-09-0808 September 1999 Responds to Request to Exceed 60,000 Mwd/Mtu Lead Rod Burnup in Small Number of Fuel Rods in North Anna Unit 2.Informs That NRC Offers No Objection to Requested Use of Rods in Reconstituted Fuel Assembly.Se Supporting Request Encl ML18152B4471999-09-0101 September 1999 Requests That NRC Remove Listed Labels from Distribution ML20211L9151999-09-0101 September 1999 Forwards Response to NRC Request for Comments Re Closure of Review of Response to GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity ML20211J2211999-08-31031 August 1999 Approves Request to Remove Augmented ISI (Aii) Program for RCS Bypass Lines from North Anna Licensing Basis.Se Re Request to Apply LBB to Eliminate Augmented Insp Program on RCS Bypass Lines Encl ML20211H4131999-08-27027 August 1999 Informs That Util Revised Encl Bases for TS 2.2.1, Reactor Trip Sys Instrumentation Setpoints, Discussing Steam Flow/ Feed Flow Mismatch Portion of Steam Flow/Feed Flow Mismatch & Low SG Water Level Reactor Trip Setpoint ML20138B3241999-08-23023 August 1999 Forwards Draft Response to Question 1 Re NAPS USI A-46 ML20211D9041999-08-20020 August 1999 Forwards Revised Pages to Third Ten Year ISI Program & Relief Requests, Replacing Pages in 990408 Submittal ML20211B3871999-08-17017 August 1999 Requests Permission to Routinely Discharge from SW Reservior to Waste Heat Treatment Facility Under Existing Vpdes Permit Through Outfalls 108 & 103.Discharges Are Scheduled to Commence on 990907,due to High Priority Placed on Project ML20210T0671999-08-13013 August 1999 Informs of Completion of Review of Proposed Revs of Schedule for Withdrawal of Rv Surveillance Capsules Submitted by VEPCO on 981217.Approves Proposed Revs.Forwards Safety Evaluation ML20210Q9841999-08-12012 August 1999 Forwards Rev 1 to Vepc COLR for North Anna Unit 2,Cycle 13 Pattern Ud, Per TS 6.9.1.7.d.COLR Was Revised to Include Temp Coastdown Operation at End of Cycle 13 ML18152B4081999-08-0606 August 1999 Forwards Response to NRC 990520 & 0525 RAIs Re North Anna & Surry Responses to GL 95-07, Pressure Locking & Thermal Binding of SR Power-Operated Gate Valves. ML20210Q7661999-08-0606 August 1999 Requests Exception to 10CFR50.4 Requirement to Provide Total of Twelve Paper Copies When Submitting Surry & North Anna UFSAR Updates.Seek Approval to Submit Only Signed Original & One CD-ROM Version,Per Conversation with J Skoczlas ML18152B4091999-08-0505 August 1999 Forwards Vepc semi-annual fitness-for-duty Program Performance Data Rept for 990101-990630,IAW 10CFR26.71(d) ML20210N2921999-08-0505 August 1999 Discusses Which Submitted Proposed TSs Bases Change for Containment Leakage. Licensee Changes to Bases May Be Subj to Future Insps or Audits ML20210J8861999-08-0202 August 1999 Provides Clarification to Commitment Made in Identifying Extent by Which Existing Plant Design Complied with RG 1.97,specifically Re Variable, Radiation Exposure Rate ML20210F6121999-07-28028 July 1999 Forwards Supplemental Info on Proposed Irradiation of Fuel Rods Beyond Current Lead Rod Burnup Limit,Documenting Info Provided During 990624 Meeting & Suppl Original Submittal ML18152B3971999-07-26026 July 1999 Provides Estimates of Licensing Actions Expected to Be Submitted in Fys 2000 & 2001,in Response to NRC AL 99-02 ML20209E7621999-07-0909 July 1999 Provides Addl Info to Justify Use of Less than One Gpm Detectable Leakage Rate to Establish Required Margin for Crack Stability in LBB Analysis,Per 980623 Application on Reactor Coolant Loop Bypass Lines 05000338/LER-1999-005, Forwards LER 99-005-00,IAW 10CFR50.73.Commitment Made by Util Encl1999-07-0808 July 1999 Forwards LER 99-005-00,IAW 10CFR50.73.Commitment Made by Util Encl ML20209E3711999-07-0202 July 1999 Forwards Insp Repts 50-338/99-03 & 50-339/99-03 on 990425-0605.Violations Being Treated as Noncited Violations ML18152B4401999-07-0101 July 1999 Informs NRC That on 990511,Dominion Resources,Inc,Executed Amended & Restated Agreement & Plan of Merger with Consolidated Natural Gas Co ML18152B4371999-06-24024 June 1999 Forwards Response to NRC Request for Clarification of Relief Requests Submitted on 990212,requesting Relief from Performing Hydrostatic Testing for Certain Small Diameter Class 1,RCS Pressure Boundary Connections ML20196G2581999-06-23023 June 1999 Discusses Closure of GL 92-01,rev 1,suppl 1,reactor Vessel Structural Integrity ML20212J2951999-06-22022 June 1999 Forwards Corrected Markup & Typed Version of Affected Pages. Requests That Attached Pages for Those Previously Provided in 990506 Submittal Be Replaced & Incorporated Into NRC Review of Proposed TS ML18152B4361999-06-22022 June 1999 Forwards Response to RAI Re Surry & North Anna Power Stations,Units 1 & 2,per GL 96-06 ML20196F1151999-06-22022 June 1999 Forwards Relief Requests NDE-047 & NDE-048 for North Anna Power Station,Unit 1 Re ASME Section XI ISI Program ML20196G2211999-06-21021 June 1999 Forwards Licensee Sampling & Testing Obligations Re Vpdes Permit VA0052451 Reissuance Application.Details of Requests for Sampling & Testing Waivers,Included ML20195J7011999-06-15015 June 1999 Forwards Revised EPIP 2.01 Which Corrects Typo That Was Found in Step 10 of Procedure.Rev Does Not Implement Actions That Decrease Effectiveness of EP ML20195J1391999-06-11011 June 1999 Submits Addl Info as Addendum to Original Application Which Proposed Use of Three Chemicals in Bearing Cooling Tower at North Anna Power Station,Per Reissuance of Vpdes Permit ML18152B4301999-06-0303 June 1999 Informs of Util Intention to Revise Schedule for Submittal of License Renewal Applications for Surry & North Anna Power Stations to March 2002 ML20195C6601999-06-0101 June 1999 Forwards Response to NRC 990216 RAI Re Summary Rept of USI A-46 Program ML20207C9851999-05-28028 May 1999 Requests Regrading of Rt Robinson 990408 Written Exam,Based on Listed Reasons.Answer C for Question 18 Is Requested to Be Reconsidered as Correct or Question Be Deleted ML18152B4261999-05-28028 May 1999 Provides Formal Notification of Effect of Recent Organizational Restructuring on OLs of North Anna & Surry Power Stations,Per NRC 990513 Telcon Request ML18152B4221999-05-27027 May 1999 Forwards Info Concerning Changes to ECCS Evaluation Models & Application in Existing Licensing Analyses for Surry & North Anna Power Stations,Units 1 & 2 ML18152B4231999-05-26026 May 1999 Informs That Vepc Will Revise 180 Day Response to NRC GL 96-05,within 120 Days of Date of Ltr to Incorporate Commitment to Participate in Joint Owners Group Program as Applicable ML20206U7441999-05-20020 May 1999 Informs That NRC Unable to Conclude That NAPS Has Met Intent of Supplement 4 to GL 88-20.RAI Re Fire Area of IPEEE Encl. Response Requested within 90 Days of Submittal Date ML20207A8541999-05-20020 May 1999 Forwards RAI Re Licensee Listed Responses to GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves. Response Requested within 90 Days of Submittal Date ML20195B5381999-05-14014 May 1999 Forwards Rev 8,Change 2 to North Anna Units 1 & 2 IST Programs for Pumps & Valves. Summaries of Program Changes Provided for Each Unit IST Program.Relief Requests Have Been Removed from IST Programs ML18152A3701999-05-13013 May 1999 Submits Proposal to Use Provisions of ASME Section XI Code Case N-597 for Analytical Evaluation of Class 1,2 & 3 Carbon & Low Alloy Steel Piping Components Subjected to Wall Thinning as Result of Flow Accelerated or Other Corrosion ML20206L4661999-05-10010 May 1999 Forwards SE Accepting Request to Delay Submitting Plant, Unit 1 Class Piping ISI Program for Third Insp Interval Until 010430,to Permit Development of Risk Informed ISI Program for Class 1 Piping 1999-09-08
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217K4391999-10-18018 October 1999 Provides Response to RAI to Support USI A-46 Program Submittal for North Anna Power Station,Units 1 & 2.Rev 10 to BNL Rept 52361,encl ML20217H3301999-10-14014 October 1999 Forwards Rev 0 to COLR for North Anna 2 Cycle 14 Pattern Su. No New Commitments Intended by Ltr ML18152B3541999-10-12012 October 1999 Requests Use of Code Case N-532 & N-619,per Provisions of 10CFR50.55a(a)(3).Detailed Info Supporting Request,Encl. Attachment 2 Includes Technical White Paper That Provides Further Technical Info ML20216K1681999-10-0101 October 1999 Forwards Vols I-VIII of Rev 35 to UFSAR for Naps.Rev Also Includes Update to Chapter 17 of Ufsar,Which Contains Operational QA Program.Changes to Program Description Do Not Reduce Commitments Contained Therein ML18152B3391999-09-27027 September 1999 Forwards Revised Relief Request IWE-3,which Now Includes Addl Visual Exam Requirement After post-repair or Mod Pressure Testing Is Completed,Per Telcon with NRC ML20212G5091999-09-22022 September 1999 Forwards in Triplicate,Applications for Renewal of Licenses for Listed Individuals.Encls Withheld,Per 10CFR2.790(a)(6) ML18152B3331999-09-17017 September 1999 Forwards Revised 180-day Response to NRC GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves. ML18152B6671999-09-17017 September 1999 Forwards Two NRC Forms 536,containing Info on Proposed Site Specific Operator Licensing Exam Schedules & Estimated Number of Applicants Planning to Take Exams And/Or Gfes,In Response to NRC Administrative Ltr 99-03 ML18152B3341999-09-16016 September 1999 Requests Relief from Specific Requirements of Subsection IWE of 1992 Edition with 1992 Addenda of ASME Section XI Re Containment Liner Examination Requirements,For North Anna & Surry Power Stations ML18152B4471999-09-0101 September 1999 Requests That NRC Remove Listed Labels from Distribution ML20211L9151999-09-0101 September 1999 Forwards Response to NRC Request for Comments Re Closure of Review of Response to GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity ML20211H4131999-08-27027 August 1999 Informs That Util Revised Encl Bases for TS 2.2.1, Reactor Trip Sys Instrumentation Setpoints, Discussing Steam Flow/ Feed Flow Mismatch Portion of Steam Flow/Feed Flow Mismatch & Low SG Water Level Reactor Trip Setpoint ML20138B3241999-08-23023 August 1999 Forwards Draft Response to Question 1 Re NAPS USI A-46 ML20211D9041999-08-20020 August 1999 Forwards Revised Pages to Third Ten Year ISI Program & Relief Requests, Replacing Pages in 990408 Submittal ML20210Q9841999-08-12012 August 1999 Forwards Rev 1 to Vepc COLR for North Anna Unit 2,Cycle 13 Pattern Ud, Per TS 6.9.1.7.d.COLR Was Revised to Include Temp Coastdown Operation at End of Cycle 13 ML20210Q7661999-08-0606 August 1999 Requests Exception to 10CFR50.4 Requirement to Provide Total of Twelve Paper Copies When Submitting Surry & North Anna UFSAR Updates.Seek Approval to Submit Only Signed Original & One CD-ROM Version,Per Conversation with J Skoczlas ML18152B4081999-08-0606 August 1999 Forwards Response to NRC 990520 & 0525 RAIs Re North Anna & Surry Responses to GL 95-07, Pressure Locking & Thermal Binding of SR Power-Operated Gate Valves. ML18152B4091999-08-0505 August 1999 Forwards Vepc semi-annual fitness-for-duty Program Performance Data Rept for 990101-990630,IAW 10CFR26.71(d) ML20210J8861999-08-0202 August 1999 Provides Clarification to Commitment Made in Identifying Extent by Which Existing Plant Design Complied with RG 1.97,specifically Re Variable, Radiation Exposure Rate ML20210F6121999-07-28028 July 1999 Forwards Supplemental Info on Proposed Irradiation of Fuel Rods Beyond Current Lead Rod Burnup Limit,Documenting Info Provided During 990624 Meeting & Suppl Original Submittal ML18152B3971999-07-26026 July 1999 Provides Estimates of Licensing Actions Expected to Be Submitted in Fys 2000 & 2001,in Response to NRC AL 99-02 ML20209E7621999-07-0909 July 1999 Provides Addl Info to Justify Use of Less than One Gpm Detectable Leakage Rate to Establish Required Margin for Crack Stability in LBB Analysis,Per 980623 Application on Reactor Coolant Loop Bypass Lines 05000338/LER-1999-005, Forwards LER 99-005-00,IAW 10CFR50.73.Commitment Made by Util Encl1999-07-0808 July 1999 Forwards LER 99-005-00,IAW 10CFR50.73.Commitment Made by Util Encl ML18152B4401999-07-0101 July 1999 Informs NRC That on 990511,Dominion Resources,Inc,Executed Amended & Restated Agreement & Plan of Merger with Consolidated Natural Gas Co ML18152B4371999-06-24024 June 1999 Forwards Response to NRC Request for Clarification of Relief Requests Submitted on 990212,requesting Relief from Performing Hydrostatic Testing for Certain Small Diameter Class 1,RCS Pressure Boundary Connections ML18152B4361999-06-22022 June 1999 Forwards Response to RAI Re Surry & North Anna Power Stations,Units 1 & 2,per GL 96-06 ML20196F1151999-06-22022 June 1999 Forwards Relief Requests NDE-047 & NDE-048 for North Anna Power Station,Unit 1 Re ASME Section XI ISI Program ML20212J2951999-06-22022 June 1999 Forwards Corrected Markup & Typed Version of Affected Pages. Requests That Attached Pages for Those Previously Provided in 990506 Submittal Be Replaced & Incorporated Into NRC Review of Proposed TS ML20195J7011999-06-15015 June 1999 Forwards Revised EPIP 2.01 Which Corrects Typo That Was Found in Step 10 of Procedure.Rev Does Not Implement Actions That Decrease Effectiveness of EP ML18152B4301999-06-0303 June 1999 Informs of Util Intention to Revise Schedule for Submittal of License Renewal Applications for Surry & North Anna Power Stations to March 2002 ML20195C6601999-06-0101 June 1999 Forwards Response to NRC 990216 RAI Re Summary Rept of USI A-46 Program ML18152B4261999-05-28028 May 1999 Provides Formal Notification of Effect of Recent Organizational Restructuring on OLs of North Anna & Surry Power Stations,Per NRC 990513 Telcon Request ML20207C9851999-05-28028 May 1999 Requests Regrading of Rt Robinson 990408 Written Exam,Based on Listed Reasons.Answer C for Question 18 Is Requested to Be Reconsidered as Correct or Question Be Deleted ML18152B4221999-05-27027 May 1999 Forwards Info Concerning Changes to ECCS Evaluation Models & Application in Existing Licensing Analyses for Surry & North Anna Power Stations,Units 1 & 2 ML18152B4231999-05-26026 May 1999 Informs That Vepc Will Revise 180 Day Response to NRC GL 96-05,within 120 Days of Date of Ltr to Incorporate Commitment to Participate in Joint Owners Group Program as Applicable ML20195B5381999-05-14014 May 1999 Forwards Rev 8,Change 2 to North Anna Units 1 & 2 IST Programs for Pumps & Valves. Summaries of Program Changes Provided for Each Unit IST Program.Relief Requests Have Been Removed from IST Programs ML18152A3701999-05-13013 May 1999 Submits Proposal to Use Provisions of ASME Section XI Code Case N-597 for Analytical Evaluation of Class 1,2 & 3 Carbon & Low Alloy Steel Piping Components Subjected to Wall Thinning as Result of Flow Accelerated or Other Corrosion ML20206H0221999-05-0303 May 1999 Informs That Licensee Changes Bases for TS 3/4.6.1.2, Containment Leakage. Changes Allow Use of Other NRC Staff Approved/Endorsed Integrated Leak Test Methodologies to Perform Containment Leakage Rate Testing.Ts Bases Page,Encl ML20206G9481999-05-0303 May 1999 Informs NRC That Insp of 58 Accessible safety-related Pipe Supports Completed in Response to NOV from Insp Rept 50-338/98-05 & 50-339/98-05.Commitments Made Include Plans to Perform Assessment of Welding & Welding Insp ML20205T1181999-04-16016 April 1999 Requests NRC Approval Prior to Proposed Irradiation of Fuel Rods Beyond Current Lead Rod Burnup Limit.Nrc Concurrence with Irradiation Program Requested by End of June 1999 ML20205P1891999-04-0808 April 1999 Forwards ISI Program for Third ten-yr ISI Interval for North Anna Unit 1 for Class 1,2 & 3 Components & Component Support.Third ten-yr Insp Interval for North Anna Unit 1 Begins on 990501.Page 2-26 of Encl Not Included ML20205K3631999-04-0505 April 1999 Requests That Relief Request IWE-3 Be Removed from 980804 Relief Requests Submitted to Nrc.Subject Relief Request Was Inadvertently Retained in Attachment 1 for Unit 1 ML20205K2191999-04-0101 April 1999 Forwards Response to NRC 990106 RAI Re Util Summary Rept on USI A-46 Program,Submitted 970527.Calculations & Corrected Table 11.1-1,encl ML18151A5851999-03-31031 March 1999 Forwards Rept on Status of Decommissioning Funding for Each of Four Nuclear Power Reactors,Per 10CFR50.75(f)(1) ML18152A2801999-03-30030 March 1999 Forwards Summary of Structural Integrity Evaluation of Thermally Induced Over Pressurization of Containment Penetration Piping During DBA for SPS & Naps,Units 1 & 2,per GL 96-06.Draft Proposed UFSAR Revised Pages,Encl ML20204H0331999-03-17017 March 1999 Forwards Rev 5 to PSP for Surry & North Anna Power Stations & Associated Isfsis.Description & Justification for Changes Included with Plan Rev.Rev 5 to PSP Withheld Per 10CFR73.21 ML20205E2701999-02-25025 February 1999 Forwards Rept on Status of Decommissioning Funding for North Anna Power Station,Units 1 & 2.Trust Agreement Between Old Dominion & Bankers Trust Co,Effective 990301,attached ML20207A8741999-02-25025 February 1999 Draft Response to NRC Telcon Re Licensee Request for Approval of LBB Evaluation in Support of Elimination of Augmented Insp Program on RCS Loop Bypass Lines.Response Justifies Use of Less than One Gpm Detectable Leakage Rate ML18152B5401999-02-11011 February 1999 Requests Relief from Specific Requirements of Subsection Iwl of 1992 Edition with 1992 Addenda of ASME Section Xi,Per 10CFR50.55a(a)(3) ML20203C8181999-02-0505 February 1999 Forwards Response to NRC 981217 Telcon RAI Re risk-basis of Nitrogen Accumulator Action Statement to Complete NRC Review of 951025 Proposed TS Changes 1999-09-27
[Table view] |
Text
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i Westinghouse Energy Systems $$,,,, 3,3,m Electric Corporation -
August 27, 1991 !
CAW-91-201 -
Document Control Desk [
US Nuclear Regulatory Commission Washington, DC 20555
[
Attention: Dr. Thomas Murley, Director !
APPLICATION FOR WITHHOLDING PROPRIETARY ;
INFORMATION FROM PUBLIC DISCLOSURE ,
Subject:
" North Anna Unit 1 Steam Generator Operating Cycle Evr uation",
WCAP-13034 i
Dear Dr. Murley:
The proprietary information for which withholding is being requested in the I above-referenced letter is further identified in Affidavit CAW-91-193 signed by ,
the lwner of the proprietary information, Westinghouse Electric Corporation. '
The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and _ ;
addresses with specificity the considerations listed in paragraph (b)(4) of to i CFR Section 2.790 of the Commission's regulations. j Accordingly, this letter authorizes the utilization of the accompanying "
Affidavit by Virginia Electric and Power Company. j Correspondence with respect to the proprietary aspects of the application for !
withholding or the Westinghouse affidavit should reference this letter, CAW-91-201, and should be addressed to the undersigned. !
Very truly yours, [
l- Y 5 l, R. P. Di iazza, Mana er s Enclosures Nuclear Safety Licensing cc: M. P. Siemien, Esq.
Office of the General Counsel, NRC lDR10910o139 910830 p ADOCK 05000339 PDR 0255JtDLC/082391
b CAW-91-193 6FFIDAV11 .
t COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF ALLEGHENY:
Before me, the undersigned authority, personally appeared Ronald P. DiPiazza, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Corporation (" Westinghouse") and that ,
the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:
/
/ i} ~
donald P. D1 Piazza, Manh ,
Nuclear Safety Licensing Sworn to and subscribed -
O before me this za day .
of k d , 1991.
i h%U.ut,Nf.k,klm Notary Public I~ NOTAAiAL LE/4 LOARA:NE M P;PLCA. NOTARY P'.3UC uCNROEV:LLE DQ40. ALLE3HENf cO'riTf Mf COW:S$CN EXP:REs OE0 14. mt Me%er, Psvsfira oswa%*,2 t;,5
l '
! CAW-91-193 (1) I am Manager, Nuclear Safety Licensing, in the Nuclear and Advanced Technology Division, of the Westinghouse Electric Corporation and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rulemaking proceedings, and am authorized to apply for its withholding on behalf of the
>- Westinghouse Energy Systems Business Unit.
(2) I am making this Affidavit in conformance with the provisions of 10CFR Section 2.790 of the Commission's regulations and in conjunction with the Westinghouse application for withholding accompanying this Affidavit.
(3) I have personal knowledge of the criteria and procedures utilized by the Westingboase Energy Systems Business Unit in designating information as a trade secret, privileged or as confidential commercial or financial information.
(4) Pursuant to the provisions of paragraph (b)(4) of Sectlon 2.790 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withhela 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.
CAW-91-193 i
(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to :'e public. I
'destinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.
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.
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CAW-91-193 (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 qua'ity, or licensing a similar product.
(d) It reveals cost or price information, production capacities, }
budget levels, or commercial stv ategies 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. l (f) It contains patentable ideas, for which p tent protection may be ;
desirable, i
(g) It is not the property of Westinghouse, but must be treated as proprietary by Westinghouse according to agreements with the ;
owner.
l l There arc sound policy reasons behind the Westingh'ase system which I
include the following:
(a) The use of such information by Westinghouse gives Westinghouse a competitive advar.tage over its competitors. It is, therefore, withheld froia disclosure to protect the Westinghouse competitive positinn.
L-
.. 1 CAW-91-193 (b) It is information which is marketable in many ways. The extent to which such information .s available to competitors diminishes the Westinghouse ability to sell products and services involving ,
the use of the information. l t
i (c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our j expense. !
(d) Each component of proprietary information pertinent to a l 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 Westinghouse of a competitive advantage.
i L (e) Unrestricted disclosure would jeopardize the position of ,
prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.
(f) Tne Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and +
maintaining a competitive advantage.
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j CAW-91-193 (iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10CFR Section 2.790, it is to be received in confidence by the Commi.31an.
(iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.
(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in " North Anna Unit 1 Steam Generator Operating Cycle Evaluation", WCAP-13034, April, 1993 (Proprietary), for North Anna Unit 1, being transmitted by the Virginia Liectric and Power Company JVEPCO) letter and Application for Withholding Proprietary Information from Public Disclosure, E. W. Harrell, VEPC0, to NRC Document Control Desk, attention of Dr. Thomas Murley. The proprietary information as submitted for use by Virginia Electric and Power Company for North Anna Unit 1 is expected to be applicable in other licensee submittals in response to certain NRC requirements for the justification of plant operation with steam generator tubes which are experiencing both axial and/or circumferentially oriented cracking at the top of tubesheet and tube support plant locations.
CAW-91-193 This information is part or that which will enable Westinghouse to:
(a) Prov'.de documentation of the methods used to address the l safety significance of plant operation with the presence of the type of steam generator cracking reported at North Anna l Unit I and to assess the maintenance of steam generator tube l integrity utilizing the most limiting criteria of RG 1.121,
" Bases for Plugging Degraded Steam Generator Tubes".
(b) Establish an applicable administrative steam generator tube primary to secondary leak rate limit.
(c) Provide a set of stabilization criteria for steam generator tubes removed from service with circumferential cracks.
(d) Assist the customer in obtaining NRC approval.
Further this information has substantial commercial value as follows:
(a) Westinghouse plans to sell the use of similar information to its customers for purposes of meeting NRC requirements for licensing documentation.
(b) Westinghouse can sell support ar.d defense of the technology to its customers in the licensing process.
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0 8- CAW-91-193 l
l 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 l i
to provide similar steam generator information 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.
The development of the technology described in part by the information is the result of cpplying the results of many years of experience in an intensi') Westinghouse effort and the expenditure of a considerable sum of money.
In order for ccmpetitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended for developing testing and analytical methods and performing tests.
Further the deponent sayeth not.
4
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Proprietary Information Notice Transmitted herewith are proprietary and/or non-proprietary versions of
' documents furnished to the NRC in connection with requests for generic and/or plant-specific review ano approval.
-In order to conform to the requirements of 10 CFR 2.790 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC,-the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the
-information that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information so l designated as proprietary is indicated in both versions by meens of lower ase letters (a) through (g) contained within parentheses 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 refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(g) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.790(b)(1).
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Copyright Notice
.The reports transmitted herewith each' bear a Westinghouse copyright notice.
The_NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, ]
denial, amendment, transfer,- renewal, modification, suspension, revocation, or violation of a. license, permit, order, or regulation subject to the requirements of 10 CFR 2.790 regarding restrictions on public disclosure _to the extent such information has been identified as proprietary by Westinghouse, copyright protection.not withstanding. With respect to the non-proprietary.
versions of these reports. the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to- !
have one copy ~ available for public viewing in the appropriate docket _ files in !
the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is
-insufficient for this purpose.- The NRC is not authorized to make copies for the personal use of members of the public who make use of.the NRC public document rooms. Copies made.by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.
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