ML20329A219
| ML20329A219 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 11/16/2020 |
| From: | Point Beach |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20329A292 | List: |
| References | |
| NRC 2020-0032 | |
| Download: ML20329A219 (51) | |
Text
Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NRC 2020-0032 Enclosure 2 Affidavits Supporting Withholding Proprietary Information from Public Disclosure Pursuant to 10 CFR 2.390 (12 Attachments)
(51 Total Pages, including cover sheets)
Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NRC 2020-0032 Enclosure 2 Document List
- CAW-20-5109, Affidavit for Westinghouse proprietary portions of Point Beach Nuclear Plant Units 1 and 2 Subsequent License Renewal Application (SLRA) Table 4.3.4-1 Sentinel Locations, dated October 30, 2020 (Enclosure 5 Attachment 1) - CAW-20-5091, Affidavit for Westinghouse proprietary portions of WCAP-18554-P Revision 1, dated September 16, 2020 (Enclosure 5 ) - Framatome Affidavit dated November 4, 2020 for proprietary information contained in the following reports:
- Framatome Topical Report BAW-2192, Revision 0, Supplement 3P, Revision 0, Low Upper-Shelf Toughness Fracture Mechanics Analysis of Reactor Vessels of B&W Owners Reactor Vessel Working Group for Levels A & B Service Loads, October 2020 (Enclosure 5, Attachment 3),
- Framatome Topical Report BAW-2178, Revision 0, Supplement 2P, Revision 0, Low Upper-Shelf Toughness Fracture Mechanics Analysis of Reactor Vessels of B&W Owners Reactor Vessel Working Group for Levels C & D Service Loads, October 2020 (Enclosure 5, Attachment 4), and
- Framatome Technical Report ANP-3886P, Revision 0, PWROG-20043-P, PWROG - PBN Unit 1 IS Plate A9811-1 Equivalent Margins Analysis for SLR, October 2020 (Enclosure 5, Attachment 5) - CAW-20-5065, Affidavit for Westinghouse proprietary portions of LTR-SDA-II-20-05-P, Rev. 2, dated July 7, 2020 (Enclosure 5 Attachment 6) - CAW-20-5071, Affidavit for Westinghouse proprietary portions of LTR-SDA-II-20-08-P, Rev. 1, dated July 20, 2020 (Enclosure 5 Attachment 7) - CAW-20-5101, Affidavit for Westinghouse proprietary portions of LTR-SDA-II-20-13-P, Rev. 2, dated September 29, 2020 (Enclosure 5 ) - CAW-20-5110, Affidavit for Westinghouse proprietary portions of File No.: 2000088.310P - PROPRIETARY, Revision 1, EAF Refined Analyses (Charging Nozzle, Hot Leg Surge Nozzle, SI Nozzle, SI/RHR Tee), dated November 3, 2020 (Enclosure 5 Attachment 9) - CAW-20-5102, Affidavit for Westinghouse proprietary portions of LTR-SDA-20-064-P, Rev. 1, dated October 7, 2020 (Enclosure 5 Attachment
- 10) - CAW-20-5057, Affidavit for Westinghouse proprietary portions of WCAP-14439-P, Revision 4, dated June 12, 2020 (Enclosure 5 Attachment 11)
Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NRC 2020-0032 Enclosure 2 0 - CAW-20-5073, Affidavit for Westinghouse proprietary portions of LTR-PAFM-05-58-P, Rev. 3, dated July 23, 2020 (Enclosure 5 Attachment 12) 1 - CAW-20-5067, Affidavit for Westinghouse proprietary portions of LTR-SDA-20-020-P, Rev. 1, dated July 9, 2020 (Enclosure 5 Attachment 13) 2 - CAW-20-5066, Affidavit for Westinghouse proprietary portions of LTR-REA-20-29-P, Rev. 0, dated July 8, 2020 (Enclosure 5 Attachment 14)
Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NRC 2020-0032 Enclosure 2, Attachment 1 Affidavits Supporting Withholding Proprietary Information from Public Disclosure Pursuant to 10 CFR 2.390 CAW-20-5109, Affidavit for Westinghouse proprietary portions of Point Beach Nuclear Plant Units 1 and 2 Subsequent License Renewal Application (SLRA)
Table 4.3.4-1 Sentinel Locations, dated October 30, 2020 (Enclosure 5 Attachment 1)
(4 Total Pages, including cover sheets)
Westinghouse Non-Proprietary Class 3 CAW-20-5109 Page 1 of 3 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF BUTLER:
(1)
I, Zachary S. Harper, 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 of LTR-SDA-II-20-18, Rev. 2 and Point Beach Nuclear Plant Units 1 and 2 Subsequent License Renewal Application (SLRA) Table 4.3.4-1 Sentinel Locations 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 CAW-20-5109 Page 2 of 3 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.
(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 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
Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NRC 2020-0032 Enclosure 2, Attachment 2 Affidavits Supporting Withholding Proprietary Information from Public Disclosure Pursuant to 10 CFR 2.390 CAW-50-5091, Affidavit for Westinghouse proprietary portions of WCAP-18554-P Revision 1, dated September 16, 2020 (Enclosure 5 Attachment 2)
(4 Total Pages, including cover sheets)
Westinghouse Non-Proprietary Class 3 CAW-20-5091 Page 1 of 3 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF BUTLER:
(1)
I, Zachary S. Harper, 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 of WCAP-18554-P Revision 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 CAW-20-5091 Page 2 of 3 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.
(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 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
Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NRC 2020-0032 Enclosure 2, Attachment 3 Affidavits Supporting Withholding Proprietary Information from Public Disclosure Pursuant to 10 CFR 2.390 Framatome Affidavit dated November 4, 2020 for proprietary information contained in the following reports:
- Framatome Topical Report BAW-2192, Revision 0, Supplement 3P, Revision 0, Low Upper-Shelf Toughness Fracture Mechanics Analysis of Reactor Vessels of B&W Owners Reactor Vessel Working Group for Levels A & B Service Loads, October 2020 (Enclosure 5, Attachment 3),
- Framatome Topical Report BAW-2178, Revision 0, Supplement 2P, Revision 0, Low Upper-Shelf Toughness Fracture Mechanics Analysis of Reactor Vessels of B&W Owners Reactor Vessel Working Group for Levels C & D Service Loads, October 2020 (Enclosure 5, Attachment 4), and
- Framatome Technical Report ANP-3886P, Revision 0, PWROG-20043-P, PWROG - PBN Unit 1 IS Plate A9811-1 Equivalent Margins Analysis for SLR, October 2020 (Enclosure 5, )
(4 Total Pages, including cover sheets)
A F F I D A V I T
- 1.
My name is Philip A. Opsal. I am Manager, Product Licensing for Framatome Inc. (formally known as AREVA Inc.), and as such I am authorized to execute this Affidavit.
- 2.
I am familiar with the criteria applied by Framatome to determine whether certain Framatome information is proprietary. I am familiar with the policies established by Framatome to ensure the proper application of these criteria.
- 3.
I am familiar with the Framatome information contained in the following Reports referred to herein as Documents.:
Framatome Topical Report BAW-2192, Revision 0, Supplement 3P, Revision 0, Low Upper-Shelf Toughness Fracture Mechanics Analysis of Reactor Vessels of B&W Owners Reactor Vessel Working Group for Levels A & B Service Loads, October 2020, Framatome Topical Report BAW-2178, Revision 0, Supplement 2P, Revision 0, Low Upper-Shelf Toughness Fracture Mechanics Analysis of Reactor Vessels of B&W Owners Reactor Vessel Working Group for Levels C & D Service Loads, October 2020, Framatome Technical Report ANP-3886P, Revision 0, PWROG-20043-P, PWROG - PBN Unit 1 IS Plate A9811-1 Equivalent Margins Analysis for SLR, October 2020.
Information contained in these Documents has been classified by Framatome as proprietary in accordance with the policies established by Framatome for the control and protection of proprietary and confidential information.
- 4.
These Documents contain information of a proprietary and confidential nature and is of the type customarily held in confidence by Framatome and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in these Documents as proprietary and confidential.
- 5.
These Documents have been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in these Documents be withheld from public disclosure. The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is requested qualifies under 10 CFR 2.390(a)(4) Trade secrets and commercial or financial information.
- 6.
The following criteria are customarily applied by Framatome to determine whether information should be classified as proprietary:
(a)
The information reveals details of Framatomes research and development plans and programs or their results.
(b)
Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.
(c)
The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for Framatome.
(d)
The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for Framatome in product optimization or marketability.
(e)
The information is vital to a competitive advantage held by Framatome, would be helpful to competitors to Framatome, and would likely cause substantial harm to the competitive position of Framatome.
The information in these Documents is considered proprietary for the reasons set forth in paragraphs 6(b), 6 (c), 6(d) and 6(e) above.
- 7.
In accordance with Framatomes policies governing the protection and control of information, proprietary information contained in these Documents has been made available, on a limited basis, to others outside Framatome only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8.
Framatome policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.
- 9.
The foregoing statements 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 November 4, 2020.
Philip A. Opsal
Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NRC 2020-0032 Enclosure 2, Attachment 4 Affidavits Supporting Withholding Proprietary Information from Public Disclosure Pursuant to 10 CFR 2.390 CAW-50-5065, Affidavit for Westinghouse proprietary portions of LTR-SDA-II-20-05-P, Rev. 2, dated July 7, 2020 (Enclosure 5 Attachment 6)
(4 Total Pages, including cover sheets)
Westinghouse Non-Proprietary Class 3 CAW-20-5065 Page 1 of 3 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF BUTLER:
(1)
I, Zachary S. Harper, 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 of LTR-SDA-II-20-05-P, Rev. 2 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 CAW-20-5065 Page 2 of 3 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.
(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 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
Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NRC 2020-0032 Enclosure 2, Attachment 5 Affidavits Supporting Withholding Proprietary Information from Public Disclosure Pursuant to 10 CFR 2.390 CAW-50-5071, Affidavit for Westinghouse proprietary portions of LTR-SDA-II-20-08-P, Rev. 1, dated July 20, 2020 (Enclosure 5 Attachment 7)
(4 Total Pages, including cover sheets)
Westinghouse Non-Proprietary Class 3 CAW-20-5071 Page 1 of 3 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF BUTLER:
(1)
I, Zachary S. Harper, 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 of LTR-SDA-II-20-08-P, Rev. 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 CAW-20-5071 Page 2 of 3 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.
(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 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
Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NRC 2020-0032 Enclosure 2, Attachment 6 Affidavits Supporting Withholding Proprietary Information from Public Disclosure Pursuant to 10 CFR 2.390 CAW-50-5101, Affidavit for Westinghouse proprietary portions of LTR-SDA-II-20-13-P, Rev. 2, dated September 29, 2020 (Enclosure 5 Attachment 8)
(4 Total Pages, including cover sheets)
Westinghouse Non-Proprietary Class 3 CAW-20-5101 Page 1 of 3 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF BUTLER:
(1)
I, Zachary S. Harper, 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 of LTR-SDA-II-20-13-P, Rev. 2 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 CAW-20-5101 Page 2 of 3 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.
(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 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
Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NRC 2020-0032 Enclosure 2, Attachment 7 Affidavits Supporting Withholding Proprietary Information from Public Disclosure Pursuant to 10 CFR 2.390 CAW-50-5110, Affidavit for Westinghouse proprietary portions of File No.: 2000088.310P - PROPRIETARY, EAF Refined Analyses (Charging Nozzle, Hot Leg Surge Nozzle, SI Nozzle, SI/RHR Tee), dated November 3, 2020 (Enclosure 5 Attachment 9)
(4 Total Pages, including cover sheets)
Westinghouse Non-Proprietary Class 3 CAW-20-5110 Page 1 of 3 AFFIDAVIT COMMONWEALTH 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 of File No.: 2000088.310P - PROPRIETARY, Revision 1, EAF Refined Analyses (Charging Nozzle, Hot Leg Surge Nozzle, SI Nozzle, SI/RHR Tee) 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 CAW-20-5110 Page 2 of 3 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.
(f)
It contains patentable ideas, for which patent protection may be desirable.
(6)
The attached document is bracketed to indicate the information requested for withholding.
The justification for withholding information in each bracket is set forth in Sections (5)(a) through (c) of this Affidavit.
Westinghouse Non-Proprietary Class 3 CAW-20-5110 Page 3 of 3 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: _______________
Korey L. Hosack, Manager Licensing, Analysis, & Testing 2020 11 03
Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NRC 2020-0032 Enclosure 2, Attachment 8 Affidavits Supporting Withholding Proprietary Information from Public Disclosure Pursuant to 10 CFR 2.390 CAW-50-5102, Affidavit for Westinghouse proprietary portions of LTR-SDA-20-064-P, Rev. 1, dated October 7, 2020 (Enclosure 5 Attachment 10)
(4 Total Pages, including cover sheets)
Westinghouse Non-Proprietary Class 3 CAW-20-5102 Page 1 of 3 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF BUTLER:
(1)
I, Zachary S. Harper, 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 of LTR-SDA-20-064-P, Rev. 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 CAW-20-5102 Page 2 of 3 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.
(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 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
Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NRC 2020-0032 Enclosure 2, Attachment 9 Affidavits Supporting Withholding Proprietary Information from Public Disclosure Pursuant to 10 CFR 2.390 CAW-50-5057, Affidavit for Westinghouse proprietary portions of WCAP-14439-P, Revision 4, dated June 12, 2020 (Enclosure 5 Attachment 11)
(4 Total Pages, including cover sheets)
Westinghouse Non-Proprietary Class 3 CAW-20-5057 Page 1 of 3 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF BUTLER:
(1)
I, Zachary S. Harper, 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 of WCAP-14439-P, Revision 4 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 CAW-20-5057 Page 2 of 3 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.
(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 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
Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NRC 2020-0032 Enclosure 2, Attachment 10 Affidavits Supporting Withholding Proprietary Information from Public Disclosure Pursuant to 10 CFR 2.390 0
CAW-50-5073, Affidavit for Westinghouse proprietary portions of LTR-PAFM-05-58-P, Rev. 3, dated July 23, 2020 (Enclosure 5 Attachment 12)
(4 Total Pages, including cover sheets)
Westinghouse Non-Proprietary Class 3 CAW-20-5073 Page 1 of 3 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF BUTLER:
(1)
I, Zachary S. Harper, 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 of LTR-PAFM-05-58-P, Rev. 3 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 CAW-20-5073 Page 2 of 3 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.
(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 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
Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NRC 2020-0032 Enclosure 2, Attachment 11 Affidavits Supporting Withholding Proprietary Information from Public Disclosure Pursuant to 10 CFR 2.390 1
CAW-50-5067, Affidavit for Westinghouse proprietary portions of LTR-SDA-20-020-P, Rev. 1, dated July 9, 2020 (Enclosure 5 Attachment 13)
(4 Total Pages, including cover sheets)
Westinghouse Non-Proprietary Class 3 CAW-20-5067 Page 1 of 3 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF BUTLER:
(1)
I, Zachary S. Harper, 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 of LTR-SDA-20-020-P, Rev. 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 CAW-20-5067 Page 2 of 3 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.
(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 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
Point Beach Nuclear Plant Units 1 and 2 Dockets 50-266 and 50-301 NRC 2020-0032 Enclosure 5, Attachment 14 Affidavits Supporting Withholding Proprietary Information from Public Disclosure Pursuant to 10 CFR 2.390 2
CAW-50-5066, Affidavit for Westinghouse proprietary portions of LTR-REA-20-29-P, Rev. 0, dated July 8, 2020 (Enclosure 5 Attachment 14)
(4 Total Pages, including cover sheets)
Westinghouse Non-Proprietary Class 3 CAW-20-5066 Page 1 of 3 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF BUTLER:
(1)
I, Zachary S. Harper, 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 of LTR-REA-20-29-P, Rev. 0 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 CAW-20-5066 Page 2 of 3 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.
(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 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