View source for ND-18-0759, Transmittal of Proprietary Presentation Slides for NRC Public Meeting Held on May 17, 2018 Proposed VEGP 3&4 License Amendment Request: Containment Pressure Analysis

{{Adams
| number = ML18156A559
| issue date = 06/05/2018
| title = Transmittal of Proprietary Presentation Slides for NRC Public Meeting Held on May 17, 2018 Proposed VEGP 3&4 License Amendment Request: Containment Pressure Analysis
| author name = Whitley B
| author affiliation = Southern Nuclear Operating Co, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRO
| docket = 05200025, 05200026
| license number = 
| contact person = 
| case reference number = ND-18-0759
| document report number = APP-GW-GLY-160, Rev 0
| package number = ML18156A558
| document type = Letter type:ND, Meeting Briefing Package/Handouts, Slides and Viewgraphs
| page count = 47
| project = 
| stage = Meeting
}}

=Text=
{{#Wiki_filter:B. H. Whitley                 Southern Nuclear Director              Operating Company, Inc.
Regulatory Affairs 42 Inverness Center Parkway Birmingham, AL 35242 Tel 205.992.7079 Fax 205.992.5296 June 5, 2018 Docket Nos.: 52-025                                                                        ND-18-0759 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 Held on May 17, 2018 Proposed VEGP 3&4 License Amendment Request: Containment Pressure Analysis Ladies and Gentlemen:
On May 17, 2018, an NRC public meeting was held with Southern Nuclear Operating Company (SNC) and Westinghouse Electric Company (WEC) to exchange technical information regarding changes to the containment pressure analysis for Vogtle Electric Generating Plant (VEGP) Units 3 and 4. The purpose of this letter is to transmit the proprietary presentation material that was used to facilitate the May 17, 2018 meeting along with the non-proprietary version of the presentation. provides the slide presentation titled, Containment Analysis Audit Kickoff - Non-Proprietary. provides the slide presentation titled, Containment Analysis Audit Kickoff -
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. is Westinghouses Proprietary Information Notice, Copyright Notice and CAW-18-4749, Application for Withholding Proprietary Information from Public Disclosure and Affidavit. The affidavit sets forth the basis upon which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations. Accordingly, it is respectfully requested that the information that is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.
Correspondence with respect to the proprietary aspects of the items listed above or the supporting Westinghouse affidavit should reference CAW-17-4749 and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company,

U. S. Nuclear Regulatory Commission ND-18-0759 Page 2 of 4 James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 2 Suite 259, Cranberry Township, Pennsylvania 16066.
Correspondence with respect to proprietary aspects of this letter and its enclosures should also be addressed to Brian H. Whitley at the contact information within this letter This letter contains no regulatory commitments. This letter has been reviewed and determined not to contain security related information.
Should you have any questions, please contact Mr. Wesley A. Sparkman at (205} 992-5061 .
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 51h of June 2018.
Respectfully submitted, Brian H. Whit!
Director, Regulatory Affairs Southern Nuclear Operating Company

==Enclosures:==
: 1. Presentation Material: APP-GW-GLY-160, Revision 0, Containment Analysis Audit Kickoff- Non-Proprietary
: 2. Presentation Material: APP-GW-GLY-159, Revision 0, Containment Analysis Audit Kickoff- Proprietary (Withheld Information)
: 3. Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390
: 4. Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-18-4749, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice

U. S. Nuclear Regulatory Commission ND-18-0759 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 Mr. C. R. Pierce Ms. A. G. Aughtman Mr. D. L. Fulton Mr. M. J. Yox Mr. J. Tupik Mr. B. H. Whitley Mr. W. A. Sparkman Ms. A. C. Chamberlain Ms. A. L. Pugh Mr. F. J. Redwanz 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. T. E. Chandler Ms. P. Braxton Mr. T. Brimfield Mr. C. J. Even Mr. A. Lerch State of Georgia Mr. R. Dunn (w/o enclosure 2)
Oglethorpe Power Corporation Mr. M. W. Price (w/o enclosure 2)
Mr. K. T. Haynes (w/o enclosure 2)
Ms. A. Whaley (w/o enclosure 2)

U. S. Nuclear Regulatory Commission ND-18-0759 Page 4 of 4 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. G. Koucheravy (w/o enclosures)
Mr. M. Corletti Mr. M. L. Clyde Ms. L. Iller 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 Mr. R. Grumbir, APOG (w/o enclosure 2)
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-18-0759 Enclosure 1 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Presentation Material:
APP-GW-GLY-160, Revision 0, Containment Analysis Audit Kickoff - Non-Proprietary (Enclosure 1 consist of 27 pages, plus this cover page)
May 29, 2018 SVP_SV0_005227                                                                                                                                                  Page 2 of 28 APP-GW-GLY-160, Revision 0                                                                                                                     Page 2 Westinghouse Non-Proprietary Class 3                                                       &#xa9; 2018 Westinghouse Electric Company LLC. All Rights Reserved.
Containment Analyses Audit Kickoff VEGP LAR-17-043 (WEC LAR-079)
Michael J. Patterson/Debra Ohkawa May 17, 2018 2
                              7KLVUHFRUGZDVILQDODSSURYHGRQ30 7KLVVWDWHPHQWZDVDGGHGE\WKH35,0(V\VWHPXSRQLWVYDOLGDWLRQ May 29, 2018 SVP_SV0_005227                                                                                                                                                  Page 3 of 28 APP-GW-GLY-160, Revision 0                                                                                                                     Page 3 Westinghouse Non-Proprietary Class 3                                                       &#xa9; 2018 Westinghouse Electric Company LLC. All Rights Reserved.
Purpose
* VEGP LAR-17-043 proposes updates to the Chapter 6 containment response analyses for the loss of coolant accident (LOCA) and steamline break (SLB) events to reflect the finalized detailed design
* Presentation material to augment the reviewers guide
               - What has changed since the DCD Rev. 19 WGOTHIC evaluation model (EM)/analyses and where is the corresponding calc note documentation?
               - Information to support NRC provided talking points
* NRC questions welcomed along the way and at the end 3
                              7KLVUHFRUGZDVILQDODSSURYHGRQ30 7KLVVWDWHPHQWZDVDGGHGE\WKH35,0(V\VWHPXSRQLWVYDOLGDWLRQ May 29, 2018 SVP_SV0_005227                                                                                                                                                  Page 4 of 28 APP-GW-GLY-160, Revision 0                                                                                                                     Page 4 Westinghouse Non-Proprietary Class 3                                                       &#xa9; 2018 Westinghouse Electric Company LLC. All Rights Reserved.
Overview of Changes
* Documentation Improvements
               - WCAP-15846 defines the methodology
               - Calc notes systematically structured
* WGOTHIC Model
* WGOTHIC Code
* Mass and Energy Releases
               - LOCA
               - SLB
* PCS Flow ITAAC 4
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Containment Analysis Flow Chart a,c 5
                              7KLVUHFRUGZDVILQDODSSURYHGRQ30 7KLVVWDWHPHQWZDVDGGHGE\WKH35,0(V\VWHPXSRQLWVYDOLGDWLRQ May 29, 2018 SVP_SV0_005227                                                                                                                                                  Page 6 of 28 APP-GW-GLY-160, Revision 0                                                                                                                     Page 6 Westinghouse Non-Proprietary Class 3                                                       &#xa9; 2018 Westinghouse Electric Company LLC. All Rights Reserved.
APP-SSAR-GSC-768: WGOTHIC Evaluation Model Updates a,c 6
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WGOTHIC Evaluation Model Changes Effect on Peak Containment Pressure a,c 7
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APP-SSAR-GSC-768: WGOTHIC Evaluation Model Heat Sinks a,c 8
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APP-SSAR-GSC-768: WGOTHIC Evaluation Model Control Volumes and Flow Paths a,c 9
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APP-SSAR-GSC-768: WGOTHIC Evaluation Model Containment Vessel a,c 10
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APP-SSAR-GSC-768: WGOTHIC Evaluation Model Baffle and PCS Flowrates a,c 11
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PCS Flowrates Delivered vs. Evaporation-limited vs. DCD Rev. 19*
a,c 12
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PCS Flowrates Rainout Fraction of PCS Flow a,c 13
                              7KLVUHFRUGZDVILQDODSSURYHGRQ30 7KLVVWDWHPHQWZDVDGGHGE\WKH35,0(V\VWHPXSRQLWVYDOLGDWLRQ May 29, 2018 SVP_SV0_005227                                                                                                                                                 Page 14 of 28 APP-GW-GLY-160, Revision 0                                                                                                                    Page 14 Westinghouse Non-Proprietary Class 3                                                       &#xa9; 2018 Westinghouse Electric Company LLC. All Rights Reserved.
APP-SSAR-GSC-768: WGOTHIC Evaluation Model Materials a,c 14
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WGOTHIC Code Versions a,c 15
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WGOTHIC Code Change Effect on Peak Containment Pressure a,c 16
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WGOTHIC Code Changes Error Corrections a,c 17
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WGOTHIC Code Changes Error Corrections a,c 18
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WGOTHIC Code Changes Array Sizes a,c 19
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WGOTHIC Code Changes Evaporation-Limited PCS Flow a,c 20
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WGOTHIC Code Changes 2-D Conduction a,c 21
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WGOTHIC Code Changes 2-D Conduction Impact (CN-CRA-14-18) a,c 22
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Mass and Energy Release Analyses Overview of Impact a,c 23
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APP-SSAR-GSC-191: LOCA Mass/Energy Release a,c 24
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APP-SSAR-GSC-191: LOCA Mass/Energy Release (cont.)
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APP-SSAR-GSC-172: SLB Mass/Energy Release a,c 26
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PCS Flow ITAAC Evaluation a,c
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Summary/Conclusions a,c 28
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Southern Nuclear Operating Company ND-18-0759 Enclosure 2 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Presentation Material:
APP-GW-GLY-159, Revision 0, Containment Analysis Audit Kickoff - Proprietary (Withheld Information)
(Enclosure 2 consist of 28 pages, plus this cover page)

Southern Nuclear Operating Company ND-18-0759 Enclosure 3 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390 (Enclosure 3 consist of two pages, plus this cover page.)

ND-18-0759 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 Nuclear Development Regulatory Affairs Director for Southern Nuclear Operating Company (SNC). I have been delegated the function 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 dockets 52-025 and 52-026, Vogtle Electric Generating Plant Units 3 and 4, APP-GW-GLY-159, Revision 0, NRC Pre-Submittal Meeting Presentation of WEC LAR-079: Containment Analysis Audit Kickoff - Proprietary. 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-18-0759 for Vogtle Electric Generating Plant Units 3 and 4, Transmittal of Proprietary Presentation Slides for NRC Public Meeting Held on May 17, 2018 Regarding License Amendment Request and Exemption for: Containment Pressure Analysis.
: 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.

ND-18-0759 Enclosure 3 Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390
: b. The information is of a type customarily held in confidence by SNC and Westinghouse Electric Company and not customarily disclosed to the public.
: 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 2 of SNC letter ND-18-0759 for Vogtle Electric Generating Plant Units 3 and 4, APP-GW-GLY-159, Revision 0, "NRC Pre-Submittal Meeting Presentation of WEC LAR-079: Containment Analysis Audit Kickoff- Proprietary" and those reasons are incorporated here by reference.
: 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.
Executed   on_v+/_{+p_t>___
I Brian H. Whitley                                                            Date

Southern Nuclear Operating Company ND-18-0759 Enclosure 4 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-18-4749, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice (Enclosure 4 consist of 10 pages, plus this cover page.)
May 29, 2018 SVP_SV0_005227                                                                                             Page 2 of 11 Westinghouse Non-Proprietary Class 3
 @ Westinghouse                                                                  Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA Direct tel : (412) 374-4372 U.S. Nuclear Regulatory Commission                                Direct fax: (724) 940-8505 Document Control Desk                                                e-mail: monohajs@westinghouse.com 11555 Rockville Pike Rockville, MD 20852                                                            CA W-18-4749 May 23 , 2018 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

==Subject:==
WEC LAR-079 NRC Audit Kickoff Meeting Presentation The Application for Withholding Proprietary Information from Public Disclosure is submitted by Westinghouse Electric Company LLC (" Westinghouse"), pursuant to the provisions of paragraph (b)(l) of Section 2.390 of the Nuclear Regulatory Commission' s ("Commission' s") regulations. It contains commercial strategic information proprietary to Westinghouse and customarily held in confidence.
The proprietary information for which withholding is being requested in the above-referenced presentation is further identified in Affidavit CA W-18-4749 signed by the owner of the proprietary information, Westinghouse. The Affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 ofthe Commission' s regulations.
Accordingly, this letter authorizes the utilization ofthe accompanying Affidavit by Southern Nuclear Operating Company.
Correspondence with respect to the proprietary aspects of the Application for Withholding or the Westinghouse Affidavit should reference CA W- 18-4749, and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 2, Suite 259, Cranberry Township, Pennsylvania 16066.
g,L!.&#xa3;~0!~
Licensing Inspections and Special Programs
                         &#xa9; 2018 Westinghouse Electric Company LLC. All Rights Reserved.
May 29, 2018 SVP_SV0_005227                                                                                  Page 3 of 11 Westinghouse Non-Proprietary Class 3 Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA Enclosures to CAW-18-4749
: 1. AFFIDAVIT
: 2. PROPRIETARY INFORMATION NOTICE and COPYRIGHT NOTICE
                      &#xa9; 2018 Westinghouse Electric Company LLC. All Rights Reserved.
May 29, 2018 SVP_SV0_005227                            Page 4 of 11 Enclosure 1 to CAW-18-4749 AFFIDAVIT May 29, 2018 SVP_SV0_005227                                                                                        Page 5 of 11 CAW-18-4749 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF BUTLER:
I, Jill S. Monahan, am authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC ("Westinghouse") and declare that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief.
Executed on:      5 -dd*-;;)018'                         ~, .QQ S /]oo~-1/l-Jill S. Monahan, Manager Licensing Inspections and Special Programs May 29, 2018 SVP_SV0_005227                                                                                       Page 6 of 11 3                                     CAW-18-4749 (1)      I am Manager, Licensing Inspections and Special Programs, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.
(2)      I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Nuclear Regulatory Commissions (Commissions) regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.
(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 the provisions of paragraph (b)(4) of Section 2.390 of the Commissions regulations, 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.
(ii)     The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitute Westinghouse policy and provide the rational basis required.
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 May 29, 2018 SVP_SV0_005227                                                                                     Page 7 of 11 4                                       CAW-18-4749 Westinghouses 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.
(iii) There are sound policy reasons behind the Westinghouse system which include the following:
(a)     The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.
(b)     It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.
(c)     Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.
May 29, 2018 SVP_SV0_005227                                                                                   Page 8 of 11 5                                     CAW-18-4749 (d)      Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.
(e)      Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.
(f)      The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.
(iv)  The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, is to be received in confidence by the Commission.
(v)   The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.
(vi)  The proprietary information sought to be withheld in this submittal is that which is appropriately marked in ND-18-0759, Transmittal of Proprietary Presentation Slides for NRC Public Meeting Held on May 17, 2018, Proposed VEGP 3&4 License Amendment Request: Containment Pressure Analysis, for a meeting held on May 17, 2018, for submittal to the Commission, being transmitted by Southern Nuclear Operating Company letter. The proprietary information as submitted by Westinghouse is that associated with NRC audit kickoff meeting for containment analyses as part of WEC LAR-079 (SNC LAR-17-043), and may be used only for that purpose.
May 29, 2018 SVP_SV0_005227                                                                                    Page 9 of 11 6                                    CAW-18-4749 (a)      This information is part of that which will enable Westinghouse to:
(i)      Manufacture and deliver products to utilities based on proprietary designs.
(b)      Further, this information has substantial commercial value as follows:
(i)      Westinghouse plans to sell the use of similar information to its customers for the purpose of licensing new nuclear power stations.
(ii)     Westinghouse can sell support and defense of industry guidelines and acceptance criteria for plant-specific applications.
(iii)    The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.
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.
The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.
In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.
Further the deponent sayeth not.
May 29, 2018 SVP_SV0_005227                                                     Page 10 of 11 Enclosure 2 to CAW-18-4749 PROPRIETARY INFORMATION NOTICE and COPYRIGHT NOTICE May 29, 2018 SVP_SV0_005227                                                                                      Page 11 of 11 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.}}