ND-19-0340, Transmittal of Proprietary Presentation Slides for NRC Public Meeting on April 11, 2019 Tornado Missile: Turbine Building First Bay Barriers and MSSV Stacks (WEC LAR 221)
ML19113A084 | |
Person / Time | |
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Site: | Vogtle ![]() |
Issue date: | 04/23/2019 |
From: | Whitley B Southern Nuclear Operating Co |
To: | Document Control Desk, Office of New Reactors |
Shared Package | |
ML19113A083 | List: |
References | |
ND-19-0340 | |
Download: ML19113A084 (32) | |
Text
B. H. Whitley Southern Nuclear Director Operating Company, Inc.
Regulatory Affairs 3535 Colonnade Parkway Birmingham, AL 35243 Tel 205.992.7079 April 23, 2019 Docket Nos.: 52-025 ND-19-0340 52-026 10 CFR 2.390 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant Units 3 and 4 Transmittal of Proprietary Presentation Slides for NRC Public Meeting on April 11, 2019 Tornado Missile: Turbine Building First Bay Barriers and MSSV Stacks (WEC LAR 221)
Ladies and Gentlemen:
On April 11, 2019, an NRC public meeting was held with Southern Nuclear Operating Company (SNC) and Westinghouse Electric Company (WEC) to exchange technical information regarding Tornado Missile Protection for Vogtle Electric Generating Plant (VEGP) Units 3 and 4. This meeting built upon previous technical discussions held with the staff on this topic on April 26, 2018 (see ADAMS Accession Number ML18117A351). The purpose of this letter is to transmit the proprietary presentation material (and associated SNC and WEC proprietary documentation) that was used to facilitate the closed portion of the technical exchange meeting along with the non-proprietary version of the presentation. The non-proprietary presentation material for the closed portion of the meeting was previously provided to the NRC via email dated April 1, 2019 (see ADAMS Accession Number ML19091A257). provides the slide presentation titled, Tornado Missile: Turbine Building First Bay Barriers and MSSV Stacks (WEC LAR 221) (Non-Proprietary). provides the slide presentation titled, Tornado Missile: Turbine Building First Bay Barriers and MSSV Stacks (WEC LAR 221) (Proprietary). This presentation contains material identified as Westinghouse Proprietary Class 2, and accordingly is requested to be withheld from public disclosure under 10 CFR 2.390. provides an affidavit from SNC supporting withholding the Proprietary information under 10 CFR 2.390. provides the Westinghouse affidavit for withholding proprietary information contained in Enclosure 2.
This letter contains no regulatory commitments. Should you have any questions, please contact Mr. Ryan Henderson at (205) 992-6426.
U.S. Nuclear Regulatory Commission ND-19-0340 Page 2 of4 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 23rd day of April2019.
Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY : Vogtle Electric Generating Plant (VEGP) Units 3 and 4- Tornado Missile:
Turbine Building First Bay Barriers and MSSV Stacks (WEC LAR 221)
(Non-Proprietary) : Vogtle Electric Generating Plant (VEGP) Units 3 and 4- Tornado Missile:
Turbine Building First Bay Barriers and MSSV Stacks (WEC LAR 221)
(Proprietary) (Withheld Information) : Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390 : Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-19-4884, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice
U.S. Nuclear Regulatory Commission ND-19-0340 Page 3 of 4 cc:
Southern Nuclear Operating Company / Georgia Power Company Mr. S. E. Kuczynski (w/o enclosures)
Mr. D. G. Bost (w/o enclosures)
Mr. M. D. Meier (w/o enclosures)
Mr. D. H. Jones (w/o enclosures)
Mr. J. B. Klecha Mr. G. Chick Mr. D. L. McKinney (w/o enclosures)
Mr. T. W. Yelverton (w/o enclosures)
Mr. B. H. Whitley Ms. C. A. Gayheart (w/o enclosure 2)
Mr. C. R. Pierce Ms. A. G. Aughtman Mr. D. L. Fulton Mr. M. J. Yox Mr. C. T. Defnall Mr. J. Tupik Ms. A. C. Chamberlain Mr. S. Leighty Mr. E. Riffle Ms. K. Roberts Document Services RTYPE: VND.LI.L00 File AR.01.02.06 Nuclear Regulatory Commission Mr. W. Jones (w/o enclosures)
Ms. J. Dixon-Herrity Mr. C. Patel Ms. J. M. Heisserer Mr. B. Kemker Mr. G. Khouri Ms. S. Temple Mr. F. Brown Mr. C. J. Even Mr. A. Lerch Mr. S. Walker State of Georgia Mr. R. Dunn (w/o enclosure 2)
U.S. Nuclear Regulatory Commission ND-19-0340 Page 4 of 4 Oglethorpe Power Corporation Mr. M. W. Price (w/o enclosure 2)
Ms. A. Whaley (w/o enclosure 2)
Municipal Electric Authority of Georgia Mr. J. E. Fuller (w/o enclosure 2)
Mr. S. M. Jackson (w/o enclosure 2)
Dalton Utilities Mr. T. Bundros (w/o enclosure 2)
Westinghouse Electric Company, LLC Mr. L. Oriani (w/o enclosures)
Mr. C. Churchman (w/o enclosures)
Mr. M. Corletti Mr. M. L. Clyde Mr. D. Hawkins Mr. J. Coward Other Mr. S. W. Kline, Bechtel Power Corporation Ms. L. A. Matis, Tetra Tech NUS, Inc. (w/o enclosure 2)
Dr. W. R. Jacobs, Jr., Ph.D., GDS Associates, Inc. (w/o enclosure 2)
Mr. S. Roetger, Georgia Public Service Commission (w/o enclosure 2)
Ms. S. W. Kernizan, Georgia Public Service Commission (w/o enclosure 2)
Mr. K. C. Greene, Troutman Sanders (w/o enclosure 2)
Mr. S. Blanton, Balch Bingham NDDocumentinBox@duke-energy.com, Duke Energy (w/o enclosure 2)
Mr. S. Franzone, Florida Power & Light (w/o enclosure 2)
Southern Nuclear Operating Company ND-19-0340 Enclosure 1 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Tornado Missile: Turbine Building First Bay Barriers and MSSV Stacks (WEC LAR 221)
(Non-Proprietary)
(This enclosure consists of 19 pages, including this cover page.)
APP-GW-GLY-171, Revision 0 Page 2 of 19 SVP_SV0_005447 Attachment 5 Westinghouse Non-Proprietary Class 3 © 2019 Westinghouse Electric Company LLC. All Rights Reserved.
Tornado Missile: Turbine Building First Bay Barriers and MSSV Stacks (WEC LAR 221)
Technical Exchange Meeting: 4/11/19 1
- This record was final approved on 4/2/2019 8:04:01 AM. (This statement was added by the PRIME system upon its validation)
APP-GW-GLY-171, Revision 0 Page 3 of 19 SVP_SV0_005447 Attachment 5 Westinghouse Non-Proprietary Class 3 © 2019 Westinghouse Electric Company LLC. All Rights Reserved.
Background Information UFSAR Subsection 3.5.2: a,c
- Protection from external missiles is provided by the walls and roof of the Seismic Category I (SCI) nuclear island structure.
- Openings through these walls are evaluated on a case by case basis to provide confidence that a missile passing through the opening would not prevent safe shutdown and would not result in an offsite release exceeding the limits defined in 10 CFR 50.34.
UFSAR Subsection 3.5.1.4
- Defines three AP1000 tornado missiles:
- 1 steel sphere (105 mph)
- 8, 275 lb. rigid artillery shell (105 mph horizontal, 74 mph vertical)
- 4000 lb. deformable automobile (105 mph horizontal, 74 mph vertical) 2
- This record was final approved on 4/2/2019 8:04:01 AM. (This statement was added by the PRIME system upon its validation)
APP-GW-GLY-171, Revision 0 Page 4 of 19 SVP_SV0_005447 Attachment 5 Westinghouse Non-Proprietary Class 3 © 2019 Westinghouse Electric Company LLC. All Rights Reserved.
Background Information a,c 3
- This record was final approved on 4/2/2019 8:04:01 AM. (This statement was added by the PRIME system upon its validation)
APP-GW-GLY-171, Revision 0 Page 5 of 19 SVP_SV0_005447 Attachment 5 Westinghouse Non-Proprietary Class 3 © 2019 Westinghouse Electric Company LLC. All Rights Reserved.
Background Information
- LAR-15-021 (WEC LAR-30) was approved to credit the SCII Turbine Building First Bay (TBFB) for protecting the penetrations in the Auxiliary Building north wall (Wall 11) from postulated tornado missiles a,c 4
- This record was final approved on 4/2/2019 8:04:01 AM. (This statement was added by the PRIME system upon its validation)
APP-GW-GLY-171, Revision 0 Page 6 of 19 SVP_SV0_005447 Attachment 5 Westinghouse Non-Proprietary Class 3 © 2019 Westinghouse Electric Company LLC. All Rights Reserved.
Background Information a,c
- Total of 24 openings in roof - 12 per Main Steam Line
- Stack diameter is 24 inches
- Stacks extend ~9 feet above roof
- Diameter of MSSV discharge elbow is 10 inches
- No hard connection between MSSVs and stacks
- Conventional PWR design 5
- This record was final approved on 4/2/2019 8:04:01 AM. (This statement was added by the PRIME system upon its validation)
APP-GW-GLY-171, Revision 0 Page 7 of 19 SVP_SV0_005447 Attachment 5 Westinghouse Non-Proprietary Class 3 © 2019 Westinghouse Electric Company LLC. All Rights Reserved.
Background Information a,c 6
- This record was final approved on 4/2/2019 8:04:01 AM. (This statement was added by the PRIME system upon its validation)
APP-GW-GLY-171, Revision 0 Page 8 of 19 SVP_SV0_005447 Attachment 5 Westinghouse Non-Proprietary Class 3 © 2019 Westinghouse Electric Company LLC. All Rights Reserved.
Missiles Impacting the MS Stacks (Horizontally) a,c Evaluation Summary:
- Assume all rooftop vent paths (stacks, PORV & roof vent) are disabled by tornado missiles
- Steam relieves into the MSIV compartment, though Wall 11 doors and vents, and into the TBFB
- Compartment pressure remains below limit
- Unlikely that all rooftop vent paths could be disabled by tornado missiles Note: If a horizontal missile were to crimp only one stack, an imbalance force on the drip pan would occur causing a moment on the steam line. No break of the main steam line would be expected. However, any potential break would be bounded by the analysis performed in UFSAR 15.1.5. No passive safety features impacted and the plant achieves safe shutdown.
7
- This record was final approved on 4/2/2019 8:04:01 AM. (This statement was added by the PRIME system upon its validation)
APP-GW-GLY-171, Revision 0 Page 9 of 19 SVP_SV0_005447 Attachment 5 Westinghouse Non-Proprietary Class 3 © 2019 Westinghouse Electric Company LLC. All Rights Reserved.
Missiles Impacting the MS Stacks (Horizontally)
- Per UFSAR Table 3.5-1, Wall 11 doors are credited for stopping a postulated 8 artillery shell and 1 sphere
- Since Wall 11 doors are now being credited to open in the event all roof vents are disabled, one new small barrier must be added at EL. 100in the TBFB (in front of the Valve/Piping Room Wall 11 door, 12306) a,c
- No additional barriers needed 8
- This record was final approved on 4/2/2019 8:04:01 AM. (This statement was added by the PRIME system upon its validation)
APP-GW-GLY-171, Revision 0 Page 10 of 19 SVP_SV0_005447 Attachment 5 Westinghouse Non-Proprietary Class 3 © 2019 Westinghouse Electric Company LLC. All Rights Reserved.
Missiles Entering Down the MS Stacks (Vertically) a,c Evaluation Summary:
- Demonstrate that tornado debris falling into the stack, contacting the MSSV cactus arm, is within ASME pipe stress limits
- Demonstrate that the 8 (74 mph) artillery shell contacting the MSSV cactus arm will not break the MS boundary
- Demonstrate that even if a missile breaks a main steam, main feed, or startup feed line, the AP1000 passive safety features are not impacted and the plant still achieves safe shutdown.
- Unlikely that any missile could enter MS stack vertically 9
- This record was final approved on 4/2/2019 8:04:01 AM. (This statement was added by the PRIME system upon its validation)
APP-GW-GLY-171, Revision 0 Page 11 of 19 SVP_SV0_005447 Attachment 5 Westinghouse Non-Proprietary Class 3 © 2019 Westinghouse Electric Company LLC. All Rights Reserved.
Missiles Entering Down the MS Stacks (Vertically)
- Demonstrate that tornado debris falling into the stack, contacting the MSSV cactus arm, is within ASME pipe stress limits
- Missile load is analyzed in a linear elastic model, using equivalent static load method and a conservative dynamic load factor of 2
- Pipe stress is at Level C allowable limits for a missile load of 18,000 lbf
- 18,000 lbf missile load correlates debris size of 7 (50 lbs) steel sphere dropped 32 feet (31 mph) a,c 10
- This record was final approved on 4/2/2019 8:04:01 AM. (This statement was added by the PRIME system upon its validation)
APP-GW-GLY-171, Revision 0 Page 12 of 19 SVP_SV0_005447 Attachment 5 Westinghouse Non-Proprietary Class 3 © 2019 Westinghouse Electric Company LLC. All Rights Reserved.
Missiles Entering Down the MS Stacks (Vertically)
- Demonstrate (LS-Dyna) that the 8 (74 mph) artillery shell contacting the MSSV cactus arm will not break the MS boundary
- Analysis Results
- If the shell catches the top edge of the vent arm, the arm plastically deforms but stops the missile
- If the shell falls directly down the center of the arm, it will puncture the arm and exit with low velocity
- The steam boundary is not breached as a result of an artillery shell missile traveling down an MSSV stack
- The stress generated in the MSSV branch connection and the MSL is less than the strength of these components a,c 11
- This record was final approved on 4/2/2019 8:04:01 AM. (This statement was added by the PRIME system upon its validation)
APP-GW-GLY-171, Revision 0 Page 13 of 19 SVP_SV0_005447 Attachment 5 Westinghouse Non-Proprietary Class 3 © 2019 Westinghouse Electric Company LLC. All Rights Reserved.
Missiles Entering Down the MS Stacks (Vertically) a,c 12
- This record was final approved on 4/2/2019 8:04:01 AM. (This statement was added by the PRIME system upon its validation)
APP-GW-GLY-171, Revision 0 Page 14 of 19 SVP_SV0_005447 Attachment 5 Westinghouse Non-Proprietary Class 3 © 2019 Westinghouse Electric Company LLC. All Rights Reserved.
Missiles Entering Down the MS Stacks (Vertically)
- Demonstrate that even if a missile breaks a main steam, main feed, or startup feed line, the AP1000 passive safety features are not impacted and the plant still achieves safe shutdown.
- Hypothetical vertical artillery shell through MSSV stack does not impact AP1000 passive safety systems and the potential breaks are analyzed
- Main steam line break - UFSAR 15.1.5
- Main feedwater line break - UFSAR 15.2.8 (Bounds a startup feedwater line break) a,c 13
- This record was final approved on 4/2/2019 8:04:01 AM. (This statement was added by the PRIME system upon its validation)
APP-GW-GLY-171, Revision 0 Page 15 of 19 SVP_SV0_005447 Attachment 5 Westinghouse Non-Proprietary Class 3 © 2019 Westinghouse Electric Company LLC. All Rights Reserved.
TBFB Automobile Barriers Evaluation Summary
- Continue to credit barriers that prevent the 1 sphere and 8 artillery shell from passing through Wall 11 openings (method approved in LAR-15-021)
- SCII TBFB structure
- Wall 11 doors
- Existing barrier within the TBFB at EL 117-6
- New barrier within the TBFB at EL 100
- Remove the large TBFB automobile barriers from the plant design
- Torturous path a deformable automobile must take to arrive at a Wall 11 opening is not credible due to intervening structures and equipment 14
- This record was final approved on 4/2/2019 8:04:01 AM. (This statement was added by the PRIME system upon its validation)
APP-GW-GLY-171, Revision 0 Page 16 of 19 SVP_SV0_005447 Attachment 5 Westinghouse Non-Proprietary Class 3 © 2019 Westinghouse Electric Company LLC. All Rights Reserved.
TBFB Automobile Barriers a,c 15
- This record was final approved on 4/2/2019 8:04:01 AM. (This statement was added by the PRIME system upon its validation)
APP-GW-GLY-171, Revision 0 Page 17 of 19 SVP_SV0_005447 Attachment 5 Westinghouse Non-Proprietary Class 3 © 2019 Westinghouse Electric Company LLC. All Rights Reserved.
Proposed licensing changes A case-by-case evaluation has been performed for openings through the SCI MSIV compartment walls to provide confidence that a missile would not prevent safe shutdown. The following licensing basis changes are proposed:
Horizontal Missile Impacting the Stack
- Add a small missile barrier in front of the Wall 11 door at EL. 100 (UFSAR Table 3.5-1)
- Clarify tornado missiles are not a design basis load on the stacks (UFSAR Subsection 3.5.2)
Vertical Missile down the Stack
- Clarify the 8 artillery shell missile is not an ASME design basis load on the MS line (UFSAR Subsection 3.5.2)
- Clarify the automobile missile is not a design basis load on the main steam stacks(UFSAR Subsection 3.5.2)
Deformable Automobile through the TBFB
- Remove the large TBFB automobile barriers since they are not needed (UFSAR Subsection 3.5.2 and Table 3.5-1)
- Clarify that the automobile is not a credible missile for Wall 11 openings (UFSAR Subsection 3.5.2 )
16
- This record was final approved on 4/2/2019 8:04:01 AM. (This statement was added by the PRIME system upon its validation)
APP-GW-GLY-171, Revision 0 Page 18 of 19 SVP_SV0_005447 Attachment 5 Westinghouse Non-Proprietary Class 3 © 2019 Westinghouse Electric Company LLC. All Rights Reserved.
Applicable Regulatory Requirements
- GDC 2 - Design bases for protection against natural phenomena
- GDC 4 - Environmental and dynamic effects design bases
- 10 CFR 100.10(c) - Physical characteristics of the site, including seismology, meteorology, geology, and hydrology
- RG 1.76, Rev. 0 - Design-Basis Tornado and Tornado Missiles for Nuclear Power Plants
- RG 1.117, Rev. 1 - Protection Against Extreme Wind Events and Missiles for Nuclear Power Plants
- SRP 3.5.1.4, Rev. 2 - Missiles Generated by Tornadoes and Extreme Winds 17
- This record was final approved on 4/2/2019 8:04:01 AM. (This statement was added by the PRIME system upon its validation)
APP-GW-GLY-171, Revision 0 Page 19 of 19 SVP_SV0_005447 Attachment 5 Westinghouse Non-Proprietary Class 3 © 2019 Westinghouse Electric Company LLC. All Rights Reserved.
Questions / Discussion 18
- This record was final approved on 4/2/2019 8:04:01 AM. (This statement was added by the PRIME system upon its validation)
Southern Nuclear Operating Company ND-19-0340 Enclosure 3 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390 (This enclosure consists of 3 pages, including this cover page.)
ND-19-0340 Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390 Affidavit of Brian H. Whitley
- 1. My name is Brian H. Whitley. I am the Regulatory Affairs Director of Southern Nuclear Operating Company (SNC). I have been delegated the function of reviewing proprietary information sought to be withheld from public disclosure and am authorized to apply for its withholding on behalf of SNC.
- 2. I am making this affidavit on personal knowledge, in conformance with the provisions of 10 CFR Section 2.390 of the Commissions regulations, and in conjunction with SNCs filing on dockets52-025 and 52-026, Vogtle Electric Generating Plant Units 3 and 4, Transmittal of Proprietary Presentation Slides for NRC Public Meeting on April 11, 2019 Tornado Missile: Turbine Building First Bay Barriers and MSSV Stacks (WEC LAR 221). I have personal knowledge of the criteria and procedures used by SNC to designate information as a trade secret, privileged or as confidential commercial or financial information.
- 3. Based on the reason(s) at 10 CFR 2.390(a)(4), this affidavit seeks to withhold from public disclosure Enclosure 2 of SNC letter ND-19-0340 for Vogtle Electric Generating Plant Units 3 and 4, Tornado Missile: Turbine Building First Bay Barriers and MSSV Stacks (WEC LAR 221) (Proprietary).
- 4. The following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.
- a. The information sought to be withheld from public disclosure has been held in confidence by SNC and Westinghouse Electric Company.
- b. The information is of a type customarily held in confidence by SNC and Westinghouse Electric Company and not customarily disclosed to the public.
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ND-19-0340 Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390
- c. The release of the information might result in the loss of an existing or potential competitive advantage to SNC and/or Westinghouse Electric Company.
- d. Other reasons identified in Enclosure 4 of SNC letter ND-19-0340 for Vogtle Electric Generating Plant Units 3 and 4, Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-19-4884, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice.
- 5. Additionally, release of the information may harm SNC because SNC has a contractual relationship with the Westinghouse Electric Company regarding proprietary information.
SNC is contractually obligated to seek confidential and proprietary treatment of the information.
- 6. The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.
- 7. To the best of my knowledge and belief, 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.
I declare under penalty of perjury that the foregoing is true and correct.
f Brian H. Whitley Executed on 'il ~~ /(1 Date 3 of 3
Southern Nuclear Operating Company ND-19-0340 Enclosure 4 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-19-4884, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice (This enclosure consists of 6 pages, including this cover page.)
ND-19-0340 Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-19-4884, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice Enclosed is:
CAW-19-4884, which includes: the Affidavit, Proprietary Information Notice, Copyright Notice 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 Commissions 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 Commissions regulations.
Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse Affidavit should reference CAW-19-4884 and should be addressed to Camille T. Zozula, Manager, Infrastructure & Facilities Licensing, Westinghouse Electric Company, 1000 Westinghouse Drive, Suite 165, Cranberry Township, Pennsylvania 16066.
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SVP_SV0_005447 Westinghouse Non-Proprietary Class 3 CAW-19-4884 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 APP-GW-GLY-170, Revision 0 as submitted by Southern Nuclear Operating Company Letter ND-19-0340 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.
SVP_SV0_005447 Westinghouse Non-Proprietary Class 3 CAW-19-4884 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) and (c) 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
SVP_SV0_005447 Attachment 1 Westinghouse Non-Proprietary Class 3 CAW-19-4884 Page 3 of3 AFFIDAVIT lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (5)(a) through (f) of this 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: ()I/Jo~t019
~I
~
Zachary S. Harper, Manager APlOOO Licensing
SVP_SV0_005447 PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and non-proprietary versions of a document, furnished 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 2.390 of the Commissions 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 having 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) 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 (4)(ii)(f) of the Affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(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 2.390 regarding restrictions on public disclosure to the extent 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.