ML20249A523
| ML20249A523 | |
| Person / Time | |
|---|---|
| Site: | 07109276 |
| Issue date: | 05/29/1998 |
| From: | Quinn R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | Haughney C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20036E436 | List: |
| References | |
| WES-98-012, WES-98-12, NUDOCS 9806170008 | |
| Download: ML20249A523 (4) | |
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Westingho'use Spent Nuclebt Fuels Program suae 203 Electric Corporation
@j8j[$b In reply refer to:
WES-98-012 May 29,1998 Mr. Charles J. Haughney Acting Director Spent Fuel Project Office Division of Nuclear Materials Safety and Safeguards United States Nuclear Regulatory Commission 11555 Rockville Pike Rockville,MD 20852
Subject:
Transportation License Application for the Wesflex System
References:
- 1. Docket No. 71-9276
- 2. Docket No. 72-1026
DearMr Haughney:
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Westinghouse is pleased to request your review and approval of the transportation components of the Westinghouse Wesflex Spent Fuel Management System. The application for transportation certification includes the Westlex canisters which were previously submitted on Docket 72-1026 for storage certification under the provisions of 10CFR72 Subpart K.
Application is hereby made for approval of the Westlexm Transportation System under the provisions of 10CFR71. Enclosed are 15 copies each of a Proprietary and a Non-Proprietary l
I Revision 0 of the Wesflexm Transportation System Safety Analysis Reports (SARs): document WSNF-100,"Wesfiex" W125 Transportation Cask Safety Analysis Report," and document WSNF-103,"Wesflexm W74 Canister Transportation Safety Analysis Report." In addition,3 proprietary copies of the corresponding calculation packages are also being submitted.
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The Proprietary copies of the report and calculation packages contain information that is p
consiA: red proprietary to Westinghouse. The enclosed Application for Withholding and affidavit l
are submitted in accordance with the portions of 10CFR2.790 requesting that proprietary versions not be disclosed to the public. A non-proprietary version of the report is included with I hg{-
this submittal.
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Document WSNF-101, "Wesflex W21 Canister Transportation Safety Analysis Report,"
document WSNF-102,"Wesflex W44 Canister Transportation Safety Analysis Report," and l
' sub' sequent canister SARs will be submitted under separate cover.
l' All design work and future fabrication, assembly, testing, maintenance, repair, modification and of the package are performed under the Westinghouse Energy Systems Quality Management Syst which has been approved by NRC under Docket No. 71-0708.
Should you any member of your staff have any questions, please contact me at (408)369-674.
Sincerely, Robert D. Quinn Manager, Regulatory Compliance cc:
Mr. James L. Gallagher
Enclosures:
- 1. Westlexm' W125 Transportation Cask SAR, Document No. WSNF-100, Proprietary Revision 0,15 copies
- 2. Wesflex W125 Transportation Cask SAR, Document No. WSNF-100, Non-Proprietary Revision 0,15 copies j
- 3. Wesflexm W125 Transportation Cask SAR Supporting Calculations, Proprietary,3 copies j
1
- 4. Wesflex W74 Canister Transportation SAR,' Document No. WSNF-103, Proprietary Revision 0,15 copies
- 5. Wesflex W74 Canister Transportation SAR, Document No. WSNF-103, Non-Proprietary Revision 0,15 copies
- 6. Wesflex W74 Canister Transportation SAR Supporting Calculations, Proprietary,3 copies
- 7. Copyright Notice
- 8. Proprietary Notice
- 9. Application for Withholding Proprietary Information from Public Disclosure j
- 10. Affidavit Pursuant to 10CFR2.790 d
1
Copyright 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, 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 that 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 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, DC 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 Transmitted herewith are proprietary and/or non-proprietary versions of documents fumished 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 has been deleted). The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower 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 of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.790(b)(1).
4 AFFIDAVIT PURSUANT TO 10 CFR 2.790 State of California
)
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SS.
County of Santa Clara
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I, Robert D. Quinn, depose and say as follows:
(1)
I am Manager of Regulatory Compliance, Spent Nuclear Fuel Programs, Westinghouse Electric Company, a subsidiary of CBS Corporation, and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be 4
withheld, and have been duly authorized to apply for its withholding.
-(2)
The information sought to be withheld is contained in the documents entitled "Westlex*
W125 Transportation Cask Safety Analysis Report," Westinghouse Document WSNF-100, and "Wesflex W74 Canister Transportation Safety Analysis Report," Document WSNF-103. These documents have been appropriately designated as proprietary.
(3)
I have personal knowledge of the criteria and procedures used by Westinghouse in designating information as trade secret, privileged, or as confidential commercial or financial information.
~(4)
Pursuant to the provisions of paragraph (b)(4) of 10 CFR 2.790, the following is furnished for consideration by the Conunission in determining whether the information sought to be withheld from public disclosure, including the information as designated in paragraph (2) above, should be withheld.
I L
(i)
The information sought to be withheld from public disclosure is included in the licensing drawings and calculations of a canister-based spent fuel storage and transportation system, which is owned and has been held in confidence by g
(ii)
The information 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 Affidavit WES-98-013 Page 1 of 4 05/29/98
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 syr.em, 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 potential competitive advantage, as follows:
The information reveals the distinguishing aspects of a process or a.
component, structure, tool, method, etc., and the prevention ofits use by Westinghouse's competitors, without license from Westinghouse, gives Westinghouse a competitive economic advantage.
b.
The information consists of supporting data (including test data) relative to a process or component, structure, tool, method, etc. and gives Westinghouse a competitive economic advantage, e.g., by optimization or improved marketability, The information, if used by a competitor, would reduce the competitor's c.
expenditure of resources or improve the competitor's advantage in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product.
d.
The information reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.
The information reveals aspects ofpast, present, or future Westinghouse or e.
customer funded development plans and programs of potential commercial value to Westinghouse.
f.
The information contains patentable ideas, for which patent protection may be desirable.
Affidavit WES-98-013 Page 2 of 4 05/29/98
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(iii)' The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR 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) - The proprietary information sought to be withheld in this submittal is that which is appropriately marked, dated February 1998, and being transmitted by Westinghouse Electric Company with Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information has been presented to the Nuclear Regulatory Commission and is being voluntarily provided by Westinghouse.
_ (vi)
Public disclosure of the information is likely to cauw substantial harm to the competitive position of Westinghouse because:
(i)
A similar product is manufactured and sold by competitors of
-l Westinghouse.
(ii)
The development of this information by Westinghouse is the result of a significant expenditure of staff effort and a considerable sum of money.
To the best of my knowledge and belief, a competitor would have to undergo similar effort and expense in generating equivalent information.
(iii)
In order to acquire such information, a competitor would also require considerable time and inconvenience related to the development of a design of a canister-based spent fuel storage and transportation system.
(iv)
The information consists of detailed' description of the design, analysis and fabrication of a transportable spent fuel storage system, the application of which provides a competitive economic advantage. The availability of I
l-
'such information to competitors would enable them to modify their product to better compete with Westinghouse, take marketing or other actions to improve their product's position or impair the position of k
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Affidavit WES-98-013 Page 3 of 4 05/29/98
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Westinghouse's product, and avoid developing fabrication data in support of their processes, methods, and/or apparatus.
(v)
In pricing Westinghouse's products and services, significant research, development, engineering, analytical, licensing, fabrication, quality assurance and other costs must be included. The ability of Westinghouse's competitors to utilize such information without similar expenditure of resources may enable them to sell their product at prices reflecting significantly lower costs.
Further the deponent sayeth not.
w Robert D. Quirm Manager of Regulatory Compliance Spent Nuclear Fuel Programs Westinghouse Electric Company l
Subscribed and swom before me this cQ8ay of AltuA -
,1998.
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Commission # 1174006 l
j Notoy Pubile - Coffamic santa Clara County Notary Public U j
w Comm.eg*es Feb20.ZM (
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l Affidavit WES-98-013 Page 4 of 4 05/29/98 t