ML20087E404
| ML20087E404 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 01/15/1992 |
| From: | Rhodes F WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19351B107 | List: |
| References | |
| ET-92-0011, ET-92-11, NUDOCS 9201210211 | |
| Download: ML20087E404 (5) | |
Text
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l LF CREEK W@ NUCLEAR OPERATING m
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I Forrest T. Rhodes t-V,co Pressdent.
Engineering & Techrucat Servkes January 15, 1992 '
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q ET 92-0011 L.
v U. S.--Nuclear Regulatory Commission y"
ATTN: Document Control Desk Mkil Station Pl.137 Vastington..D.
C.-
20555 Subject Docket No. 50-482:
Steady State Core Physics Methodology J
. Topical Report
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.The.'turpost' of 'this letter 'is to submit Wolf Creek Nuclear Operating Corporation's-(VCNOC) Steady State Core Physics Methodology topical report
. for Nt.<:J ear P9gulatory Connission :(NRC) raview and approval.
This submittal c.3 b
vu dies.ts?*d at a meeting'between the NRC reafF and WCNOC which took place l:
provided as an attachment to on luyc'Ss 1989... The' topical report is 1 e8 N this letter.
It is requested that the NRC complete its -r sv.ew and approve it.his cuhmittal-by February-1.-1993.
~In:iaccordance:. with the provisions ;of 16 C7R 2.790 it is respectfully sego+tted ths.t the attachment to this letter be regarded as proprietary finformation and -be' withheld from public disclosure on the grocnds that it
~
I contains trade secrets - and confider.tial-commercial information.
The
' affidavit _which' accompanies this_lettar, sets forth the basis by which this information should be withheld from public disclosure by the Commi"sion and Inddressees.-
g The attachment-- to this letter in its. entirety should be regarded as
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proprietary information until the NRC rey!ev is complete, at which tima WCNOC will indicate the specific-portions within the. report which ar.
- proprietary.
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L 9201210211 920115 C'
POR ADOCK 05000482 P
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PO. Box 4111 Durhngton, KS 66839 / Phone- (316) 364 0831 An Equal Opporturuty Employer M FACVET
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c t-ET 92-0011 Fage 2 of 2:
If you have any questions concerning this matter, please contact me or Mr. S. G. Wideman of my staff.
Very truly yours,
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Forrest T. Rhodes Vice President Engineering & Technical Services FTR/aem t
Attachment cca A. T. Howell.(NRC), w/a R. D. Martin (NRC), w/a L
G. A. Pick (NRC), w/a W. D. Reckley (NRC), w/a
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SS COUNTY OF COFFEY
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Before me, the undersigned authority, personally appeared Forrest T. Rhodes,
- who, being by me duly sworn according to law, deposes and saysi (1)
I am Vice President Engineering and Technical Services for the Wolf Creek Nuclear Operating Corporation (WCNOC),
and I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in WCNOC's submittal of Steady State Core Physics Methodology topical report, and am authorized to apply for its withholding on behalf of WCN00.
(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 92-0011 for Steady State Core Physics Methodology topical report submittal accompanying this affidavit (3)
I have personal. knowledge of the criteria and procedures utilized'by WCNOC in designating information as a trade secret, privileged or ac confidential' commercial.
(4)
Pitr auant to the provisions of paragraph (b)(4) of Section 2.790 cf the Cunmission'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 publia disclosuro has been -held in confidence by WCN00.
The information is of a typa.
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 tyna*
the release of which might result in the loss of an exi -
or potential competitive advantage, as follows:
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. - - - - - ~. ~. _.
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-l (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 competit.ve-
. economic advantage over other companies.
. (b)- It-_ consists of supporting data relative to a process or a method,- the application aof 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.
I (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 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 bxpenditure 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.
i)
_The =information is being transmitted to the__ Commission in
, confidence and, under the provisions of 10 CFR Section 2.790, it t
is to be received in confidence by the Commission.
(iii) The information sought to be protected is not available inn _public sources t; the best of_our knowledge and-belief.
(iv) The -proprietary information -sought to be withheld in.this submittal is theLSteady State Core Physics for Methodology topical report, dated December, 1991.
The subject-information could only be duplicated.by competitors if-they were to invest time and effort equivalent to that invested by VCNOC provided-they have the requisite talent and experience.
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Public disclosure ~ of-this information is likely to cause substantial harm to the competitive position of WCHOC because it would simplify design and evaluation tasks without requiring a comensurate investment of time and ef fort,
'(5)
The above statements are true and correct to the best of my knowledge, information and belief.
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Forrest T. Rhodes Vice President Engineering & Technical Services SUBSCRIBED and sworn to before me this /5 day of H
. 1992, 9n ak [$sden kp [ <,
Notary Publie g......... y. v N i ys).8X . 7-My Comission Expires cI-4-f4 2/
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