ML25091A293
| ML25091A293 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 04/01/2025 |
| From: | Duke Energy Progress |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML25091A290 | List: |
| References | |
| RA-25-0067 | |
| Download: ML25091A293 (1) | |
Text
Enclosure 2 H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT NUMBER 2 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATON FROM PUBLIC DISCLOSURE PURSUANT TO 10 CFR 2.390
ENCLOSURE 2 ATTACHMENT 1 H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT NUMBER 2 AFFIDAVIT CAW-24-032 FOR WESTINGHOUSE WCAP-15628-P, REVISION 1
- This record was final approved on 06/11/2024 14:16:26. (This statement was added by the PRIME system upon its validation)
Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-24-032 Page 1 of 3 Commonwealth of Pennsylvania:
County of Butler:
(1)
I, Camille Zozula,Manager, Global Nuclear Regulatory Affairs, 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-15628 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)
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.
- This record was final approved on 06/11/2024 14:16:26. (This statement was added by the PRIME system upon its validation)
Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-24-032 Page 2 of 3 (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 lower-case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (5)(a) through (f) of this Affidavit.
- This record was final approved on 06/11/2024 14:16:26. (This statement was added by the PRIME system upon its validation)
Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-24-032 Page 3 of 3 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: 6/11/2024 Signed electronically by Camille Zozula
ENCLOSURE 2 ATTACHMENT 2 H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT NUMBER 2 AFFIDAVIT CAW-24-056 FOR WESTINGHOUSE WCAP-18900-P, REVISION 0
- This record was final approved on 11/25/2024 12:00:27. (This statement was added by the PRIME system upon its validation)
Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-24-056 Page 1 of 3 Commonwealth of Pennsylvania:
County of Butler:
(1)
I, Jerrod Ewing, Manager, Operating Plants 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 WCAP-18900-P in Duke Energy letter WEC-DUKE-RNP-SLR-24-041 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.
- This record was final approved on 11/25/2024 12:00:27. (This statement was added by the PRIME system upon its validation)
Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-24-056 Page 2 of 3 (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 lower-case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (5)(a) through (f) of this Affidavit.
- This record was final approved on 11/25/2024 12:00:27. (This statement was added by the PRIME system upon its validation)
Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-24-056 Page 3 of 3 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: 11/25/2024 Signed electronically by Jerrod Ewing
- This record was final approved on 11/25/2024 12:00:27. (This statement was added by the PRIME system upon its validation)
CAW-24-056 Revision 0 Non-Proprietary Class 3
- This page was added to the quality record by the PRIME system upon its validation and shall not be considered in the page numbering of this document.**
Approval Information Author Approval Ewing Jerrod Nov-25-2024 12:00:27 Files approved on Nov-25-2024
ENCLOSURE 2 ATTACHMENT 3 H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT NUMBER 2 AFFIDAVIT CAW-24-058 FOR WESTINGHOUSE WCAP-18944-P, REVISION 1
- This record was final approved on 12/09/2024 07:54:29. (This statement was added by the PRIME system upon its validation)
Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-24-058 Page 1 of 3 Commonwealth of Pennsylvania:
County of Butler:
(1)
I, Zachary Harper, Consulting Engineer, 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 WCAP-18944-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)
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.
- This record was final approved on 12/09/2024 07:54:29. (This statement was added by the PRIME system upon its validation)
Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-24-058 Page 2 of 3 (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 lower-case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (5)(a) through (f) of this Affidavit.
- This record was final approved on 12/09/2024 07:54:29. (This statement was added by the PRIME system upon its validation)
Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-24-058 Page 3 of 3 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: 12/9/2024 Signed electronically by Zachary Harper
- This record was final approved on 12/09/2024 07:54:29. (This statement was added by the PRIME system upon its validation)
CAW-24-058 Revision 0 Non-Proprietary Class 3
- This page was added to the quality record by the PRIME system upon its validation and shall not be considered in the page numbering of this document.**
Approval Information Manager Approval Harper Zachary S Dec-09-2024 07:54:29 Files approved on Dec-09-2024
ENCLOSURE 2 ATTACHMENT 4 H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT NUMBER 2 AFFIDAVIT CAW-25-009 FOR WESTINGHOUSE WCAP-18939-P, REVISION 1
- This record was final approved on 02/28/2025 15:49:18. (This statement was added by the PRIME system upon its validation)
Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-25-009 Page 1 of 3 Commonwealth of Pennsylvania:
County of Butler:
(1)
I, Zachary Harper, Consulting Engineer, 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 WCAP-18939-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)
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.
- This record was final approved on 02/28/2025 15:49:18. (This statement was added by the PRIME system upon its validation)
Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-25-009 Page 2 of 3 (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 lower-case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (5)(a) through (f) of this Affidavit.
- This record was final approved on 02/28/2025 15:49:18. (This statement was added by the PRIME system upon its validation)
Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-25-009 Page 3 of 3 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: 2/28/2025 Signed electronically by Zachary Harper
- This record was final approved on 02/28/2025 15:49:18. (This statement was added by the PRIME system upon its validation)
CAW-25-009 Revision 0 Non-Proprietary Class 3
- This page was added to the quality record by the PRIME system upon its validation and shall not be considered in the page numbering of this document.**
Approval Information Author Approval Harper Zachary S Feb-28-2025 15:49:18 Files approved on Feb-28-2025