ML20090K519
| ML20090K519 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 03/11/1992 |
| From: | Rhodes F WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20034D346 | List: |
| References | |
| ET-92-0032, ET-92-32, NUDOCS 9203190072 | |
| Download: ML20090K519 (5) | |
Text
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t-i WeitLF CREEK
- NUCLEAR OPERATING CORPORATION 4
Forrest T. Rhodes vec 14ewdent ingmc+r6ng & httuucal Services
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March 11, 1992 ET 92-0032
-U. S. Nuclear Regalatm
- Conmis sion ATThi Document Contrei % 4 Mail Station F1-137 Vashington, D. C.
20555 Subjects. Docket No. 50-4823-Reload Safety E..austion Methodology Topical Report f
Gentlemeni The purpose: of~ this letter is.-to submit Wolf Creek Nuclear. Operating Corporation's (VCNOC) Reload Safety Evaluation Methodology topical report for Nuclear Regulatory Conunission (NRC) review and approval, This submit.tal
.was discussed atla meeting between;the NRC staff and VCNOC on January-28, H
1991.
.The-topical report is being provided as an attachment to this letter.
.It is requested that the NRC complete its review and approve the attached topical by Februar7-1. 1993.-
'In accordance with the provisions: of 10 CFR 2.790, it is-respectfully _
requested that the-attachment to this-letter be regarded as pt oprietary 1
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 fort.h the basis, by which this information should, be withheld from public disclosure by the Cocaission and addrerrees.
The. attachment-to this letter in its entirety should.be regarded as proprietary information until the NRC review-is' complete.
at which. time f
WCNOC will : indicate.-the specific portions within the report which are.
proprietary, f-
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9203190072 920311 P.0 Box 411 e Burlington, KS 66839 / Phone (316) 364-8831 DR APOCK 0500 2
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I If you have any questions concerning this matter, please contact me or Mr. S. G. Wideman of my ataff.
Very truly yours, n
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j Forrest T. Rhodes j
Vice President 1
Engineering & Technical Services
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Attachment j
ect A. T. Howell (NP.C), w/a R. D.- Martin (NRC),.w/a G. A. Pick (MRC), v/a W. D. Reckley (NRC), w/a j
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fFFIDAVE STATE OF KANSAS
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SS COUNTY OF COFFEY
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Before me, the undersigned authority, personally appeared Forrest J. Rhodes,
- who, beir.g by me duly sworn according to law, deposes and says:
(1)
I am Vice President Engineering and Technical Services for the Volf
" reek Nuclear Operating Corporation (WCNSC),
and I have been
..=cifically delegated the function of reviewing the proprietary rmation-sought to be withheld from public disclosure in WCNOC's
'ttal of Reload Safety Evaluation Methodology for the Wolf Creek rating Station topical report.
and am authorized to apply for its tolding on behalf of WCNOC.
am making this Affidavit in conformance with the provisions of.
CFR Saction 2.740 of the Commission's regulations and in conjunction s
with WCNOC ictter ET 92-0032 for Reload Safety Evaluation Methodolohy for-the Wolf Creek Generating Station topical report submittal accompanying this affidavit.
(3)
I have personal '.wwledge of the criteria and procedures utilized by WCNOC in designating 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 Commisolon'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.
(1)
.Tr.e information sought to te withheld from public disclosure has been held in confi ence by WCN00.
The information is of a type customerilyfheld in confidence by other organizations and not customarily disclosed to the public.
Based on a review of 10 CFR 2.770, the information to be held in confidence falls in one or mero of several; types, the release of which might result in the loss of an existing or potentisl competitive advantage-. as follows:
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(a)
The information reveals the distinguishing aspects of a process or a method, where prevention of its uee by any other c ompar.y without license from VCNOC 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 corupetitive advantage.
(c)
Its use by another company would reduce its expenditure of resources or impr1ve its competitive rosition in the design, assurance of quality, ot licensing a similar product.
(d)
It is not the property of WCNOC, but must be treated as proprietary by WCHOC according to agreenents with the owners of the information.
~
r There are sound reasona behind the WCNOC position which include the following (a)
It is information which is marketable in many ways.
(b) Use by other companies would put VCNOC 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 puzzi.e, thereby depriving WCNOC of a g
competitive advantage.
(11)
The inforuation is being transmitted to the Cammission 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 ic not available in public sources to the best of our knowledge and belief.
(iv) The proprietary information sought to be withheld in this submittel is the Reload Safety Evaluation Methodology for Wolf Creek Generating Station topical recort, dated January. 1992.
The aubject 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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l Public disclosure of this information is likely to cause substantial harm to the competitive position of kcNOC because it would simplify design e.nd eveluation tasks without requiring a cotunensurate investment of time and ef fort.
(5) The above statements are true and correct to the best of my knowledge, i.. formation and belief.
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'/j/f7 Forrest T. Rhodes Vice Praesident Engineering & Technical Services SUBSCRIBED and sworn to betore me +.his jj day of Yl.14ch,1992.
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