ML20178A565
| ML20178A565 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 06/19/2020 |
| From: | Dullinger J Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML20178A565 (8) | |
Text
ATTACHMENT 1 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION
- WITHHOLD UNDER 10 CFR 2.390 -
WHEN SEPARATED FROM ATTACHMENT 1, THIS LETTER IS DECONTROLLED Exelon Generation June 19, 2020 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Joseph A. Dullinger Plant Manager Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD 20657 410-495-5205 Office 610-765-5881 Mobile www.exeloncorp.com joseph.dullinger@exeloncorp.com Calvert Cliffs Nuclear Power Plant; Unit Nos. 1 & 2;
.Renewed Facility Operating License Nos. DPR-53 and DPR-69 Docket Nos. 50-317 & 50-318
Subject:
References:
Startup Test Activity Reduction (STAR} Summary Report
- 1.
WCAP-16011-P-A, Revision 0, "Startup Test Activity Reduction Program," February 2005 Pursuant to WCAP-16001-P-A, Revision 0, Calvert Cliffs Nuclear Power Plant (CCNPP) is submitting the Unit 1 Cycle 25 Startup Report. This report is required due to the implementation of Startup Test Activity Reduction (STAR).
STAR was implemented successfully during this outage. The measured test results for all the required STAR tests in Table 3-3 of Reference 1 are shown in Attachment 1 and were within the test criteria. contains proprietary information. Attachment 2 contains the non-proprietary version. contains the Westinghouse Electric Company Affidavit for withholding proprietary information in accordance with 10 CFR 2.390. The Westinghouse affidavit references their proprietary document, "NF-CB-20-082", 'Implementation of the STAR Program at Calvert Cliffs Nuclear Power Plant',
which identifies the proprietary information contained in the specific RAI questions and responses in.
There are no regulatory commitments contained in this correspondence.
Should you have questions regarding this matter, please contact Mr. Casey McLynden at (779) 231-1689.
ATTACHMENT 1 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION
- WITHHOLD UNDER 10 CFR 2.390 -
WHEN SEPARATED FROM ATTACHMENT 1, THIS LETTER IS DECONTROLLED.
ATTACHMENT 1 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION
-WITHHOLD UNDER 10 CFR 2.390-WHEN SEPARATED FROM ATTACHMENT 1, THIS LETTER IS DECONTROLLED.
Document Control Desk June 19, 2020 Page 2 Respectfully,
~
Joseph A. Dul linger*
Plant Manager JAD/LDS/lmd Attachment (1) CCNPP Startup Test Activity Reduction (STAR) Summary Report for 1R25 (Proprietary)
Attachment (2) CCNPP Startup Test Activity Reduction (STAR) Summary Report for 1R25 (Non-Proprietary)
Attachment (3) Affidavit Pursuant to 10 CFR 2.390 cc:
NRC Project Manager, Calvert Cliffs NRC Regional Administrator, Region I NRC Resident Inspector, Calvert Cliffs S. Seaman, MD-DNR ATTACHMENT 1 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION
-WITHHOLD UNDER 10 CFR 2.390-WHEN SEPARATED FROM ATTACHMENT 1, THIS LETTER IS DECONTROLLED.
ATTACHMENT (3).
Affidavit Pursuant to 10 CFR 2.390
Westinghouse Non-Proprietary Class 3 NF-CB-20-082 Westinghouse Affidavit CAW-20-5045, Utility Customer Instructions May2020 (5 pages including this cover page)
Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, PA 16066
© 2020 Westinghouse Electric Company LLC All Rights Reserved
Westinghouse Non-Proprietary Class 3 AFFIDAVIT CA W-20-5045 Page 1 of 3 COMMONWEAL TH OF PENNSYLVANIA:
COUNTY OF BUTLER:
(1)
I, Korey L. Hosack, have been specifically delegated and authorized to apply for withholding and execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse).
(2)
I am requesting the proprietary portions ofNF-CB-20-082, Attachment 1 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.
Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-20-5045 Page 2 of3 (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.
(f)
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 oflower 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
Westinghouse Non-Proprietary Class 3 AFFIDAVIT lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (S)(a) through (f) of this Affidavit.
CA W-20-5045 Page 3 of3 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: 2020 05 06
~-
Korey L. Hosack, Manager Licensing, Analysis, & Testing
Westinghouse Non-Proprietary Class 3 Utility Customer Instructions NF-CB-20-082 Please include the following information in the TRANSMITTAL LETTER to the NRC. This is not a part of the affidavit.
Enclosed is:
CA W-20-5045.
The enclosure contains information proprietary to Westinghouse Electric Company LLC
("Westinghouse"), it is supported by an Affidavit signed by Westinghouse, the owner of the information. The Affidavit sets forth the basis on which the information may be withheld from public disclosure by the Nuclear Regulatory Commission ("Commission") and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations.
Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.
Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse Affidavit should reference CA W-20-5045 and should be addressed to Korey L. Hosack, Manager, Licensing, Analysis, & Testing, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 1, Cranberry Township, Pennsylvania 16066.