ML22129A154

Westinghouse Submittal of Triennial Update of the Decommissioning Funding Plan

ML22129A154
Person / Time
Site:	Westinghouse
Issue date:	05/09/2022
From:	Donnelly P Westinghouse
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
Shared Package
ML22129A153	List: ML22129A154
References
AW-22-020, LTR-RAC-22-27
Download: ML22129A154 (1)

Text

WESTINGHOUSE NON-PROPRIETARY CLASS 3 Westinghouse Electric Company LLC Columbia Nuclear Fuel Site 5801 Bluff Road Hopkins, South Carolina 29061-9121 USA Director, Office of Nuclear Material Safety and Direct tel: 803-647-1957 Safeguards U. S. Nuclear Regulatory Commission e-mail: donnelpb@westinghouse.com Document Control Desk 11555 Rockville Pike Your ref:

Rockville, Maryland 20852-2738 Our ref: LTR-RAC-22-27 May 9, 2022

SUBJECT:

Westinghouse Submittal of Triennial Update of the Decommissioning Funding Plan Westinghouse Electric Company LLC (Westinghouse) is pleased to submit the triennial update of the Columbia Fuel Fabrication Facility Decommissioning Funding Plan.

The plan is proprietary in its entirety; therefore, a non-proprietary version will not be submitted. The attached Affidavit sets forth the basis on which the information identified as proprietary may be withheld from public disclosure by the Commission.

If you have any questions, please contact me at (803) 647-1957.

Patrick Donnelly Patrick Donnelly (May 9, 2022 15:16 EDT)

Patrick Donnelly, Manager Regulatory Affairs Westinghouse Columbia Fuel Fabrication Facility Docket 70-1151 License SNM-1107 Attachment

1. Affidavit AW-22-020, (Non-Proprietary)

Enclosure

1. Westinghouse Columbia Fuel Fabrication Facility Decommissioning Funding Plan, (Proprietary) cc: w/o enclosure U. S. Nuclear Regulatory Commission, Region II 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, Georgia 30303-1257 Attn: Mr. Thomas Vukovinsky

© 2022 Westinghouse Electric Company LLC All Rights Reserved

WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 2 of 2 Our ref: LTR-RAC-22-27 May 9, 2022 U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, Maryland 20852-2738 Attn: Ms. Jennifer Tobin

Westinghouse Non-Proprietary Class 3 AFFIDAVIT AW-22-020 Page 1 of 2 Commonwealth of Pennsylvania:

County of Butler:

(1) I, Camille Zozula, Manager, Regulatory Compliance and Corporate Licensing, 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 Westinghouse Columbia Fuel Fabrication Facility Decommissioning Funding Plan 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) The information sought to be withheld is being transmitted to the Commission in confidence and, to Westinghouses knowledge, is not available in public sources.

(iii) Westinghouse notes that a showing of substantial harm is no longer an applicable criterion for analyzing whether a document should be withheld from public disclosure. Nevertheless, 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 AW-22-020 Page 2 of 2 (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 submittal contains proprietary information throughout, for the reasons set forth in Sections (5) (b) and (d) of this Affidavit. Accordingly, a redacted version would be of no value to the public.

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: 5/6/2022 _____________________________

Signed electronically by Camille Zozula