ML20098G701
| ML20098G701 | |
| Person / Time | |
|---|---|
| Site: | 07109297 |
| Issue date: | 04/06/2020 |
| From: | Stilwell W Westinghouse |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML20098G694 | List: |
| References | |
| LTR-LCPT-20-06, LTR-LCPT-20-07 | |
| Download: ML20098G701 (4) | |
Text
Westinghouse Non-Proprietary Class 3
@ Westinghouse Westinghouse Electric Company Nuclear Fuel Colwnbia Fuel Fabrication Facility 5801 Bluff Road Hopkins, South Carolina 29061 USA ATIN: Document Control Desk Direct tel: l -803-647-3438 Director, Division of Fuel Management Direct fax:
Office of Nuclear Material Safety and Safeguards e-mail: stilwewc<a'weslinghouse.com U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Your ref: USA/9362/AF-96 Our ref: LTR-LCPT-20-07 April 6, 2020
Subject:
Submittal of LTR-LCPT-20-06, "Amendment Request Application USA/9297/AF-96 for Model No. Traveller STD, XL, and WER Packages" Enclosed are the proprietary and non-proprietary attachments for LTR-LCPT-20-06, "Amendment Request Application USA/9297/AF-96 for Model No. Traveller STD, XL, and VVER Packages."
This submittal contains proprietary information of Westinghouse Electric Company LLC
("Westinghouse"). In conformance with the requirements of 10 CFR Section 2.390, as amended, of the Nuclear Regulatmy Commission's ("Commission's") regulations, we are enclosing with this submittal an Affidavit. The Affidavit sets forth the basis on which the information identified as proprietary may be withheld from public disclosure by the Commission.
Correspondence with respect to the proprietary aspects of the submittal or the Westinghouse Affidavit should reference AW-20-5027 and should be addressed to Wes Stilwell, Director, Nuclear Fuel Transpo1t, Westinghouse Electric Company, Columbia Fuel Fabrication Facility, 5801 Bluff Road, Hopkins, SC 29061.
William (Wes) E. Stilwell, Director, Nuclear Fuel Transport Westinghouse Electric Company, LLC
© 2020 Westinghouse Electric Company LLC All Rights Reserved
- This record was final approved on 4/7/2020 2:53:30 PM. (This statement was added by the PRIME system upon its validation)
Westinghouse Non-Proprietary Class 3 AW-20-5027 Page 1 of3 AFFIDAVIT SOUTH CAROLINA:
COUNTY OF RICHLAND:
(1) I, William E. Stilwell, have been specifically delegated and authorized to apply for w ithholding and execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse).
(2) I am requesting the proprietary portions of L TR-LCPT-20-06 be withheld from public disclosure under 10 CFR 2.390.
(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged, or as confidential commercial or financial information.
(4) Pursuant to 10 CFR 2.390, 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 is owned and has been held in confidence by Westinghouse and is not customarily disclosed to the public.
(ii) 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 to provide similar technical evaluation justifications 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.
- This record was final approved on 4/7/2020 2:53:30 PM. (This statement was added by the PRIME system upon its validation)
Westinghouse Non-Proprietary Class 3 AW-20-5027 Page 2 of3 AFFIDAVIT (5) Westinghouse has policies in place to identify proprietary information. 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).
( 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 quality, or licensing a similar product.
(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies 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.
(t) It contains patentable ideas, for which patent protection may be desirable.
( 6) The attached documents are bracketed and marked to indicate the bases for withholding. The justification for withholding is indicated in both versions by means of lower case letters (a) through (f) 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 (5Xa) through (f) of this Affidavit.
- This record was final approved on 4/7/2020 2:53:30 PM. (This statement was added by the PRIME system upon its validation)
Westinghouse Non-Proprietary Class 3 AW-20-5027 Page 3 of3 AFFIDAVIT I declare that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on: 1/p,; I 3, ao J D William (Wes) E. Stilwell, Director Nuclear Fuel Transport
- This record was final approved on 4/7/2020 2:53:30 PM. (This statement was added by the PRIME system upon its validation)