ML20151Z097

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Requests That Proprietary Rev 5 to WCAP-14807, Notrump Final Validation Rept, Be Withheld from Public Disclosure, Per 10CFR2.790
ML20151Z097
Person / Time
Site: 05200003
Issue date: 08/13/1998
From: Mcintyre B
WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To: Quay T
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20138L015 List:
References
AW-98-1274, NUDOCS 9809210154
Download: ML20151Z097 (9)
v • d • e


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Westinghouse Energy Systems Ba 355 ,

Pinsburgh Pennsylvanu 15230 0355 Electric Corporation  !

AW-98-1274 August 13,1998 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 ATFENTION: M R. T. R. QUAY l l

APPLICATION FOR WITHHOLDING PROPRIETARY l INFORMATION FROM PUBLIC DISCLOSURE

SUBJECT:

WCAP-14807, NOTRUPM FINAL VALIDATION REPORT FOR AP600, REVISION 5 AND NON-PROPRIETARY VERSION, WCAP-14808.

Dear Mr. Quay:

The application for withholding is submitted by Westinghouse Electric Corporation

(" Westinghouse") pursuant to the provisions of paragraph (b)(1) of Sectior. 2.790 of the j Commission's regulations. It contains commercial strategic information proprietary to l Westinghouse and customarily held in confid. ace.

l l

The proprietary material for which withholding is being requested is identified in the proprietary version of the subject report. In conformance with 10CFR Section 2.790, Affidavit AW-98-1274 accompanies this application for withholding setting forth the basis on which the identified proprietary infonnation may be withheld from public disclosure.

Accordingly, it is respectfully requested that the subject information which is proprietary to I Westinghouse be withheld from public disclosure in accordance with 10CFR Section 2.790 of the )I Commission's regulations.

Correspondence with respect to this application for withholding or the accompanying affidavit should reference AW-98-1274 and should be addressed to the undersigned.

Very truly yours, f g L VXF Brian A. McIntyre, Manager Advanced Plant Safety and Licensing jml cc: T. Carter NRC OWFN - MS SE7 9809210154 980813 PDR ADOCK 05200003 A PDR 3789a duc

1 COPYRIGIIT 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, I l

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 identined as proprietary by Westinghouse, copyright protection notwithstanding. 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, D.C. and in local public document rooms as may be required by NRC regulations if I the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identi6ed as proprietary.

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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 and 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). Thejustification for claiming the information so designated as proprietc.ry is indicated in both versions by means oflower case letters (a) through (f) 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 ofinformation Westinghouse customarily holds in confidence identified in Section (4)(ii)(a) thorough (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR2.790(b)(1).

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i- AW-98-1274

. AFFIDAVIT  ;

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COMMONWEALTil OF PENNSYLVANIA:

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, i COUNTY OF ALLEGilENY:

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Before me, the undersigned authority, personally appeared Brian A. McIntyre, 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:

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Brian A. McIntyre, Manager Advanced Plant Safety and Licensing Swom to and subscribed before me this / Y day of 811AtAC/~~

,1998  ;

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Notary Public )

Notanal Seat

' Lorraine M. Polica. Notary Public '

Monroeville Boro, Allegheny County My Commission Expires Dec.14,1999 ,

Member, Pennsylvania Association of Notarles {

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AW-98-1274 (1) I am Manager, Advanced Plant Safety And Licensing, in the New Plant Projects

! Division, of the Westinghouse Electric Company, a division of CBS Corporation t l l

(" Westinghouse"), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in i connection with nuclear power plant licensing and rulemaking proceedings, and am I

authorized to apply for its withholding on behalf of the Westinghouse Energy Systems Business Unit.

1 (2) I am making this Affidavit in conformance with the provisions of 10CFR Section 2.790 l l

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 Westinghouse 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 Section 2.790 of the Commission's I 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 public disclosure is owned and has been held in confidence by Westinghouse.

1 (ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types ofinformation customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types ofinformation in confidence. The application of that systen and the substance of that system constitutes Westinghouse policy and provides the rational basis required.

i Under that system, infonnation is held in confidence if it falls in one or more of l

several types, the release of which might result in the loss of an existing or 6
potential competitive advantage, as follows

1 3785a duc

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. AW-98-1274 l l

(a) The information reveals the distinguishing aspects of a process (or component, structure, teol, method, etc.) where prevention ofits use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

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(b) It consists of supporting data, including ie. data, relative to a process (or l component, structure, tool, method, etc.), th- cpplication of which data secures a competitive economic advantage, e.g., by optimizatior er improved marketability.

1 (c) Its use by a competitor would reduce his expenditure of resources or i 1

improve his competitive position in the design, manufacture, shipment, l l

l installation, assurance of quality, or licensing a similar product. j l

l l (d) It reveals cost or price information, production capacities, budget levels, I or commercial strategies of Westinghouse, its customers or suppliers.

i (e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

There are sound policy reasons behind the Westinghouse system which include the following:

(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westmghouse competitive position.

(b) It is information which is marketable in many ways. The extent to which such information is available to competitors diminishes the 1

Westinghouse ability to sell products and services involving the use of the information.

3785a doc

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, AW-98-1274 (c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

I (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components er proprietary information, any one component may be the key to the entire puzde, thereby depriving Westinghouse of a competitive advantage.

(e) Unrestricted disclosure wouldjeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.

(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

(iii) The information is being transmitted to the Commission in confidence and, imder the provisions of 10CFR Section 2.790, it is to be received in confidence 1 y the Commission.

(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) Enclosed is Letter DCP/NRCl410 (NSD-NRC-98-5754), August 13,1998, being transmitted by Westinghouse Electric Company, a division of CBS Corporation

(" Westinghouse"), letter and Application for Withholding Proprietary Information from Public Disclosure, Brian A. McIntyre (yW), to Mr. T. R. Quay, Office of NRR. The proprietary information as submitted for use by Westinghouse Electric Company is in response to questions concerning the l AP600 plant and the associated design certification application and is expected to i be applicable in other licensee submittals in response to certain NRC requirements forjustification oflicensing advanced nuclear power plant designs.

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This information is part of that which will enable Westinghouse to:

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-(a) Demonstrate the design and safety of the AP600 Passive Safety Systems.

l (b) Establish applicable verification testing methods.  ;

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-(c) Design Advanced Nuclear Power Plants that meet NRC requirements.

(d) Establish technical and licensing approaches for the AP600 that will 1 ultimately result in a certified design.

(e) Assist customers in obtaining NRC approval for future plants.

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! 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 advanced plant licenses.

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(b) Westinghouse can sell support and defense of the technology to its customers in the licensing process.

t 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 advanced nuclear power designs and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use l- the information to meet NRC requirements for licensing documentation without l purchasing the right to use the information. ,

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AW-98 1274 l

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The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.

In order for competitors of Westinghouse to duplicate this information, similar  ;

technical programs would have to be performed and a significant manpower i

effort, having the requisite talent and experience, would have to be expended for developing analytical methods and receiving NRC approval for those methods.

Further the deponent sayeth not.  ;

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l l  : Westinghouse. Energy Systems Box 355 l Pittsburgh Pennsylvania 15230-0355 L Electric Corporation ]

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DCP/NRCl410 NSD-NRC-98-5754

( Docket No.: 52-003 August 13,1998 Document Control Desk

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U.S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: MR. T. R. QUAY l

SUBJECT:

WCAP-14807, NOTRUMP FINAL VALIDATION REPORT FOR AP600, REVISION 5 AND NON-PROPRIETARY VERSION, WCAP-14808

References:

1. ' DCP/NRCl138, WCAP-14807, NOTRUMP Final Validation Report for AP600, Revision 3,11/17/97,(NSD-NRC-97-5439).

f 2.. DCP/NRCl161, Additional Change Pages to WCAP-14807,NOTRUMP Final Validation Repor; for AP600, . Revision 3, November,1997, i (NSD-NRC-97-5465).  ;

3. DCP/NRCl273, WCAP-1480[7], NOTRUMP Final Validation Report .;
for AP600, Revision 4,2/27/98,(NSD-NRC-98-5589).
4. DCP/NRCl296, Errata Pages for WCAP-1480[7], NOTRUMP Final

, Validation report for AP600, Revision'4,3/13/98,(NSD-NRC-98-5614).

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5. NRC Letter From William C. Huffman to Brian A.McIntyre," Request for Withholding Information From Public Disclosure for Westinghouse f AP600 Design Letters,7/14/98. l

Dear Mr. Quay:

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h Enclosure I contains proprietary change pages to WCAP-14807,"NOTRUMP Final Validation Report for AP600." When inserted into Revision 4, WCAP-14807 will be updated to Revision 5.

The changes include:

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,se. Corrections m Section 1.7 to address ACRS comment.

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. . Revised section.l.17, as committed in July ACRS meeting.

- 'e Removal of proprietary markings from figures 8.3.1-18 and 8.3.1-29, similar information _

. presented at July ACRS meeting. p j f td Ys+N' ,,,.s

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4 DCP/NRC1410 NSD-NRC-98-5754 August 13,1998 As requested by Reference 5, Enclosures 2 and 3 contain the non-proprietary versions of the Revision 3 and 4 change pages respectively. The proprietary versions of these change pages were provided in References I through 4. Enclosure 4 contains the non-proprietary version of the Revision 5 change pages. Enclosures 2,3, and 4 should be insened into the non-proprietary WCAP-14808.

The Westinghouse Electric Corporation copyright notice, proprietary information notice, application for withholding and affidavit are also attached, l 1

This submittal contains Westinghouse proprietary information consisting of trade secrets, l

commercial information or financial information which we consider privileged or confidential  !

pursuant to 10CFR2.790. Therefore, it is requested that the Westinghouse proprietary I information attached hereto be handled on a confidential basis and be withheld from public disclosures.

This material is for your internal use only and may be used for the purpose for which it is submitted. It should not be otherwise used, disclosed, duplicated, or disseminated, in whole or in part, to any other person or organization outside the Commission, the Office of Nuclear Reactor Regulation, the Office of Nuclear Regulatory Research and the necessary subcontractors that have signed a proprietary non-disclosure agreement with Westinghouse without the express written approval of Westinghouse.

Correspondence with respect to the application for withholding should reference AW-98-1274, l and should be addressed to Brian A. McIntyre, Manager of Advanced Plant Safety and Licensing, Westinghouse Ele- ic Corporation, P.O. Box 355, Pittsburgh, Pennsylvania, 15230-0355.

Please contact Susan Fanto on (412) 374-4028 if you have any questions concerning this transmittal.

1

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Brian A. McIntyre, Manager Advanced Plant Safety and Licensing l

jml Enclosure cc: W. C. Iluffman, NRC (SEl,1E2,1E3,1E4)

P. A. Boehnert, ACRS (3El)

11. A. Sepp, Westinghouse (w/o Enclosure)
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L- l Westin use Energy Systems Ba 355 -

Electri Corporation Pittsburgh Pennsylvania 15230-0355

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AW-98-1274 August 13,1998 l Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 I i

ATFENTION: MR. T. R. QUAY l I

APPLICATION FOR WITHHOLDING PROPRIETARY j INFORMATION FROM PUBLIC DISCLOSURE

SUBJECT:

WCAP-14807, NOTRUPM FINAL VALIDATION REPORT FOR AP600, REVISION 5 AND NON-PROPRIETARY VERSION, WCAP-14808.

J I

Dear Mr. Quay.

1

.The application for withholding is submitted by Westinghouse Electric Corporation  ;

(" Westinghouse") pursuant to the provisions of paragraph (bXI) of Section 2.790 of the l Co.nmission's regulations. It contains commercial strategic information proprietary to Westinghouse and customarily held in confidence.

The proprietary material for which withholding is being requested is identified in the proprietary version of the subject report. In conformance with 10Ct R Section 2.790, Affidavit AW-98-1274 accompanies this application for withholding setting forth the basis on which the identified l i

proprietary information may be withheld from public disclosure.

l Accordingly, it is respectfully requested that the subject information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10CFR Section 2.790 of the Commission's regulations.

Correspondence with respect to this application for withholding or the accompanying affidavit should reference AW-98-1274 and should be addressed to the undersigned.

Very truly yours, A

VA.

t Brian A. McIntyre, Manager Advanced Plant Safety and Licensing jml cc: T. Carter NRC OWFN - MS SE7

.Maia doc Hr-o44u i 5 'l i ff -

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l COPYRIGIIT NOTICE l

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 notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitter to make the number of copies i

l 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, D.C. and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. 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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PROPRIETARY INFORMATION NOTICE i

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 and approval.

In order to conform to the requirements of 10 CFR 2.790 of the Commission's regulations 1 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). Thejustification for claiming the information so designated as proprietary is indicated in both versions by means oflower case letters (a) through (f) 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 ofinformation Westinghouse customarily holds in confidence identified in Section (4)(ii)(a) thorough (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR2.790(b)(1).

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AW-98-1274 AFFIDAVIT COMMONWEALTil OF PENNSYLVANIA:

ss COUNTY OF ALLEGilENY:

Before me, the undersigned authority, personally appeared Brian A. McIntyre, 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:.

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Brian A. McIntyre, Manager Advanced Plant Safety and Licensing Sworn to and subscribed before me this /3 day of j 1 M ,1998 0 '

. a v. M Notary Public Notarial Sea!

. Lorraine M. Piplica. Notary Public Monroevme Boro, Megheny County My Comm6ssion Exp'"+ Cec. 14,1999 Member, Pennsylvanialic,sation of Notarles

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l AW-98-1274 I (1) I am Manager, Advanced Plant Safety And Licensing, in the New Plant Projects Division, of the Westinghouse Electric Company, a division of CBS Corporation I

(" Westinghouse"), 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 j of the Commission's regulations and in conjunction with the Westinghouse application i

for withholding accompanying this Affidavit. l (3) I have personal knowledge of the criteria and procedures utilized by the Westinghouse Energy Systems Business Unit in designating information as a trade secret, privileged or as confidential commercial or financial information.

I l i

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.790 of the Commission's l

regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should l be withheld. )

l (i) The information sought to be withheld from public disclosure is owned and has

! been held in confidence by Westinghouse.

l (ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types ofinformation customarily held in confidence by it

and, in that connection, utilizes a system to determine when and whether to hold

! certain types ofinformation 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 ifit falls in one or more of several types, the release of which might result in the loss of an existing or i potential competitive advantage, as follows:

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AW-98-1274 (a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention ofits 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.

1 (d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

l (e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

There are sound policy reasons behind the Westinghouse system which include the following:

(a) The use of such infonnation by Westinghouse gives Westinghouse a competitive advantage over its competitors. it is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

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, (b) It is information which is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.

3?th dec

l AW-98-1274 (c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

(d) 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 Westinghouse of a competitive advantage.

(e) Unrestricted disclosure wouldjeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.

(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

(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 Commission.

(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) Enclosed is Letter DCP/NRCl410 (NSD-NRC-98-5754), August 13,1998, being transmitted by Westinghouse Electric Company, a division of CBS Corporation

(" Westinghouse"), letter and Application for Withholding Proprietary Information from Public Disclosure, Brian A. McIntyre (W), to Mr. T. R. Quay, Office of NRR. The proprietary information as submitted for use by Westinghouse Electric Company is in response to questions concerning the AP600 plant and the associated design certification application and is expected to be applicable in other licensee submittals in response to certain NRC requirements forjustification of licensing advanced nuclear power plant designs.

3785a es

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AW-98-1274 i

This information is part of that which will enable Westinghouse to:

! (a) Demonstrate the design and safety of the AP600 Passive Safety Systems.

1 (b) Establish applicable verification testing methods. l (c) Design Advanced Nuclear Power Plants that meet NRC requirements.

(d) Establish technical and licensing approaches for the AP600 that will ultimately result in a certified design l (e) Assist customers in obtaining NRC approval for future plants.

Further this information has substantial commercial value as follows:

l (a) Westinghouse plans to sell the use of similar information to its customers for purposes of meeting NRC requirements for advanced plant licenses.

(b) Westinghouse can sell support and defense of the technology to its customers in the licensing process.

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 advanced nuclear power designs and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use i~

the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

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AW-98-1274 The development of the technology described in part by the information is the

result of applying the results of many years of experience in an intensive ,

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l Westinghouse effort and the expenditure of a considerable sum of money.

l l' in order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower l effort, having the requisite talent and experience, would have to be expended for l developing analytical methods and receiving NRC approval for those methods.

Further the deponent sayeth not.

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3785a doc 4

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