ML12286A061: Difference between revisions
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| number = ML12286A061 | | number = ML12286A061 | ||
| issue date = 09/30/2012 | | issue date = 09/30/2012 | ||
| title = | | title = License Amendment Request - Extended Power Uprate, WCAP-17639-NP, Revision 2, Instrumentation Description for the Peach Bottom Unit 2 Replacement Steam Dryer | ||
| author name = Acosta C F | | author name = Acosta C F | ||
| author affiliation = Westinghouse Electric Co, LLC | | author affiliation = Westinghouse Electric Co, LLC | ||
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| document type = Report, Technical | | document type = Report, Technical | ||
| page count = 78 | | page count = 78 | ||
| project = | |||
| stage = Other | |||
}} | }} | ||
Revision as of 10:46, 8 February 2019
| ML12286A061 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/30/2012 |
| From: | Acosta C F Westinghouse |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| WCAP-17639-NP, Rev 2 | |
| Download: ML12286A061 (78) | |
Text
Westinghouse Non-Proprietary Class 3 WCAP-17639-NP September 2012 Revision 2 Enclosure B.7 Instrumentation Description for the Peach Bottom Unit 2 Replacement Steam Dryer Westinghouse WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-17639-NP Revision 2 Instrumentation Description for the Peach Bottom Unit 2 Replacement Steam Dryer Author Christian F. Acosta*Reviewed by David A. Suddaby*September 2012 Approved:
David R. Forsyth*, Manager Acoustics and Structural Analysis*Electronically approved records are authenticated in the electronic document management system.Westinghouse Electric Company LLC 1000 Westinghouse Drive Cranberry Township, PA 16066, USA© 2012 Westinghouse Electric Company LLC All Rights Reserved ii RECORD OF REVISIONS Revision Description Completed 2 Revised in accordance with customer audit. Due to the extent of revisions, change bars See EDMS are not used.WCAP-17639-NP Revision 2 September 2012 TABLE OF CONTENTS RECORD OF REVISIONS
.........................................................................................................................
ii L IST O F T A B L E S ......................................................................................................................................
iv L IST O F F IG U R E S .......................................................................................................................................
v LIST OF ACRONYM S ...............................................................................................................................
vi I INTRODUCTION
........................................................................................................................
1-1 2 INSTRUM ENTATION OVERVIEW ...........................................................................................
2-1 3 DATA ACQUISITION AND REDUCTION SYSTEM ...............................................................
3-1 3.1 INSTRUMENT SPECIFICATIONS
...............................................................................
3-1 3.2 INSTRUMENT POSITIONS
..........................................................................................
3-2 3.3 ENSURING ACQUISITION OF QUALITY DATA ......................................................
3-3 3.4 ONLINE DATA EVALUATION SYSTEM ....................................................................
3-4 3.5 DETERMINING FREQUENCY, MODAL CONTENT, AND MAXIMUM VALUES. 3-4 3.6 BIAS ERRORS AND RANDOM UNCERTAINTIES
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3-4 4 REFERE NCES .............................................................................................................................
4-1 WCAP- 17639-NP Revision 2 September 2012 iv LIST OF TABLES]a,c .....................................................................................
3 -1 Table 3-1 WCAP- 17639-NP Revision 2 September 2012 V LIST OF FIGURES Figure 1-1 []a,c .......................................
1-1 WCAP- 17639-NP Revision 2 September 2012 vi LIST OF ACRONYMS Acronym Definition ACM acoustic circuit model DAS data acquisition system NRC U.S. Nuclear Regulatory Commission OEM original equipment manufacturer Trademark Note: INCONEL is a registered trademark of the Special Metals Corporation group of companies.
WCAP- 17639-NP Revision 2 September 2012 1-1 1 INTRODUCTION Exelon is replacing the original equipment manufacturer (OEM) steam dryers at its Peach Bottom site.The Peach Bottom site has two reactors numbered Unit 2 and Unit 3 that will have their steam dryers replaced with Westinghouse-designed steam dryers.This document describes the instrumentation to be installed on the Peach Bottom Unit 2 replacement steam dryer (shown in Figure 1-1). This dryer will be the first of the two installed.
The Peach Bottom Unit 2 steam dryer will be considered a "Prototype" design consistent with the U.S. Nuclear Regulatory Commision (NRC) document Regulatory Guide 1.20, "Comprehensive Vibration Assessment Program for Reactor Internals During Preoperational and Initial Startup Testing" (Reference 1).]a,c a,c Figure 1-1 [I a,c WCAP- 17639-NP Revision 2 September 2012 2-1 2 INSTRUMENTATION OVERVIEW a,c WCAP-17639-NP Revision 2 September 2012 3-1 3 DATA ACQUISITION AND REDUCTION SYSTEM Sections 3.1 through 3.6 address subitems (a) through (f) of Section 2.2, item 1, in Regulatory Guide 1.20 (Reference 1). The material is limited to description of direct steam dryer instrumentation.
3.1 INSTRUMENT
SPECIFICATIONS Consistent with the guidance contained in RG 1.20 (Reference 1), this section describes the accelerometer, pressure transducer, and strain gauge being used to instrument the steam dryer. Table 3-1 summarizes the instruments.
Table 3-1 [ ]axc]bIc I]abc II a,b,c WCAP- 17639-NP Revision 2 September 2012 3-2 ja,b,c 3.2 INSTRUMENT POSITIONS Regulatory Guide 1.20 requests details on the "transducer positions, which should be sufficient to monitor significant lateral, vertical, and torsional structural motions of major reactor internals components in shell, beam, and rigid body modes of vibration, as well as significant hydraulic responses and those parameters that can be used to confirm the input forcing function" (Reference 1). This section describes the criteria used to identify locations for the accelerometers, pressure transducers, and strain gauges installed on the steam dryer.II pc, WCAP- 17639-NP Revision 2 September 2012 3-3 a~c 3.3 ENSURING ACQUISITION OF QUALITY DATA Regulatory Guide 1.20 requests details on the "precautions being taken to ensure acquisition of quality data (e.g., optimization of signal-to-noise ratio, relationship of recording times to data reduction requirements, choice of instrumentation system)" (Reference 1).I WCAP- 17639-NP Revision 2 September 2012 3-4 Ii] a,c 3.4 ONLINE DATA EVALUATION SYSTEM Regulatory Guide 1.20 requests details on the "online data evaluation system to provide immediate verification of general data quality" (Reference 1).]abc II]arbkc 3.5 DETERMINING FREQUENCY, MODAL CONTENT, AND MAXIMUM VALUES Regulatory Guide 1.20 requests details on the "procedures for determining frequency, modal content, and maximum values of response" (Reference 1).]a,c 3.6 BIAS ERRORS AND RANDOM UNCERTAINTIES Regulatory Guide 1.20 requests details on "all bias errors (such as model underprediction) and random uncertainties (such as instrumentation error) associated with the instrumentation and data acquisition systems" (Reference 1).[]a,c WCAP- 17639-NP Revision 2 September 2012 4-1 4 REFERENCES
- 1. U.S. Nuclear Regulatory Commission, Regulatory Guide 1.20, Revision 3, "Comprehensive Vibration Assessment Program for Reactor Internals During Preoperational and Initial Startup Testing," March 2007.2. Westinghouse Report, WCAP-17590-P, Rev. 0, "Peach Bottom Units 2 & 3 Replacement Steam Dryer Acoustic Load Definition," August 2012.WCAP- 17639-NP Revision 2 September 2012 Attachment 16 Peach Bottom Atomic Power Station Units 2 and 3 NRC Docket Nos. 50-277 and 50-278 WEC Affidavits for Withholding Information from Public Disclosure
-Replacement Steam Dryer Evaluation of Attachment 17 Enclosure Number 17A WEC Affidavit Number CAW-1 2-3525 CAW-1 2-3526 CAW-12-3527 CAW-1 2-3528 Enclosure Title B.1 B.3 B.4U/2 CAW-1 2-3529 B.4U/3 CAW-12-3533"Peach Bottom Atomic Power Station Unit 2 and Unit 3 Replacement Steam Dryer Comprehensive Vibration Assessment Program (CVAP)""Peach Bottom Units 2 and 3 Replacement Steam Dryer Acoustic Load Definition""Peach Bottom Units 2 and 3 Replacement Steam Dryer Structural Evaluation for High-Cycle Acoustic Loads""Peach Bottom Units 2 and 3 ASME Code Stress Report""Peach Bottom Unit 2 Replacement Steam Dryer Power Ascension Program Description for Extended Power Uprate""Peach Bottom Unit 3 Replacement Steam Dryer Power Ascension Program Description for Extended Power Uprate""Peach Bottom Unit 2 and Unit 3 Replacement Steam Dryer Four-Line Subscale Acoustic Test Data Evaluation and Derivation of CLTP-to-EPU Scaling Spectra""Peach Bottom Unit 2 and Unit 3 Processing of MSL Strain Gauge Data and Computation of Predicted EPU Signature""Instrumentation Description for the Peach Bottom Unit 2 Replacement Steam Dryer" B.5 CAW-1 2-3530 CAW-1 2-3531 CAW-12-3532 B.6 B.7 O Westinghouse U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Westinghouse Electric Company Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA Direct tel: (412) 374-4419 Direct fax: (724) 720-0857 e-mail: maurerbf@westinghouse.com WEC-PCH-RSD-12-139 CAW- 12-3525 September 25, 2012 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
-Enclosure 17A, Revision 1, "Peach Bottom Atomic Generating Station Unit 2 and Unit 3 Comprehensive Vibration Assessment Program (CVAP)" (Proprietary)
The proprietary information for which withholding is being requested in the above-referenced document is further identified in Affidavit CAW-12-3525 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. 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 of the Commission's regulations.
Accordingly, this letter authorizes the utilization of the accompanying affidavit by Exelon Generation.
Correspondence with respect to the proprietary aspects of this application for withholding or the accompanying affidavit should reference CAW-12-3525 and should be addressed to J.A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.Very truly yours, B.F. Maurer, Manager ABWR Licensing Enclosures CAW-12-3525 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF BUTLER: Before me, the undersigned authority, personally appeared B. F. Maurer, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief: B. F. Maurer, Manager ABWR Licensing Sworn to and subscribed before me this 25th day of September 2012 Notary Public /COMMONWEALTH OF PENNSYLVANIA NotarialSeal Anne M. Stegman, Notary Public Unity Twp., Westmoreland County My Commission Expires Aug. 7, 2016 MEMBER. PENNSYLVANIA AS,..DCATION OF NOTARIES 2 CAW-12-3525 (1) I am Manager, ABWR Licensing, in Nuclear Services, 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 Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.
(3) 1 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 Commission's 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 constitutes Westinghouse policy and provides 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 Westinghouse's 3 CAW-12-3525 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.
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.
4 CAW-12-3525 (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.(iii) 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.(iv) 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.(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP-17635-P
-Enclosure 17A, Revision 1, "Peach Bottom Atomic Generating Station Unit 2 and Unit 3 Comprehensive Vibration Assessment Program (CVAP)" (Proprietary) for submittal to the Commission, being transmitted by Exelon Generation letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with the review of the Replacement Steam Dryer design and analysis which is a part of the Extended Power Uprate License Amendment Request for Peach Bottom Units 2 and 3, and may be used only for that purpose.
5 CAW-12-3525 This information is part of that which will enable Westinghouse to: (a) Assist the customer in obtaining NRC review of the Westinghouse Replacement Steam Dryer design and analysis methodology as applied to BWR extended power uprate applications.
Further this information has substantial commercial value as follows: (a) Westinghouse plans to sell the use of this information to its customers for purposes of replacement steam dryer design and analysis for licensing basis applications.(b) Its use by a competitor would improve their competitive position in the design and licensing of a similar product for BWR steam dryers in support of extended power uprate applications.(c) The information requested to be withheld reveals the distinguishing aspects of a design and 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 evaluations 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.
Proprietary Information Notice Transmitted herewith are proprietary and/or non-proprietary versions of documents 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 Commission's 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.
O Westinghouse U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Westinghouse Electric Company Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA Direct tel: (412) 374-4419 Direct fax: (724) 720-0857 e-mail: maurerbf@westinghouse.com Proj letter. WEC-PCH-RSD-12-134 CAW-12-3526 September 25, 2012 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
WCAP-17590-P, Revision 0, "Peach Bottom Units 2 & 3 Replacement Steam Dryer Acoustic Load Definition" (Proprietary)
The proprietary information for which withholding is being requested in the above-referenced document is further identified in Affidavit CAW-12-3526 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. 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 of the Commission's regulations.
Accordingly, this letter authorizes the utilization of the accompanying affidavit by Exelon Generation.
Correspondence with respect to the proprietary aspects of this application for withholding or the accompanying affidavit should reference CAW-12-3 526 and should be addressed to J.A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.Very truly yours, B.F. Maurer, Manager ABWR Licensing Enclosures CAW-12-3526 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF BUTLER: Before me, the undersigned authority, personally appeared B.F. Maurer, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief: B.F. Maurer, Manager ABWR Licensing Sworn to and subscribed before me this 25th day of September 2012 Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Anne M. Stegman, Notary Public Unity Twp., Westmoreland County My Commission Expires Aug. 7, 2016 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES 2 CAW-12-3526 (1) I am Manager, ABWR Licensing, in Nuclear Services, 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) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's 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 Commission's 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 constitutes Westinghouse policy and provides 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 Westinghouse's 3 CAW-12-3526 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.
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.
4 CAW- 12-3526 (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.(iii) 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.(iv) 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.(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP-I 7590-P, Revision 0, "Peach Bottom Units 2 & 3 Replacement Steam Dryer Acoustic Load Definition" (Proprietary) for submittal to the Commission, being transmitted by Exelon Generation letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with the review of the Replacement Steam Dryer design and analysis which is a part of the Extended Power Uprate License Amendment Request for Peach Bottom Units 2 and 3, and may be used only for that purpose.
5 CAW- 12-3526 This information is part of that which will enable Westinghouse to: (a) Assist the customer in obtaining NRC review of the Westinghouse Replacement Steam Dryer design and analysis methodology as applied to BWR extended power uprate applications.
Further this information has substantial commercial value as follows: (a) Westinghouse plans to sell the use of this information to its customers for purposes of replacement steam dryer design and analysis for licensing basis applications.(b) Its use by a competitor would improve their competitive position in the design and licensing of a similar product for BWR steam dryers in support of extended power uprate applications.(c) The information requested to be withheld reveals the distinguishing aspects of a design and 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 evaluations 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.
Proprietary Information Notice Transmitted herewith are proprietary and/or non-proprietary versions of documents 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 Commission's 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.
O Westinghouse Westinghouse Electric Company Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Direct tel: (412) 374-4419 Direct fax: (724) 720-0857 e-mail: maurerbf@westinghouse.com WEC-PCH-RSD-12-140 CAW-12-3527 September 25, 2012 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
WCAP-17609-P, Revision 1, "Peach Bottom Units 2 and 3 Replacement Steam Dryer Structural Evaluation for High-Cycle Acoustic Loads" (Proprietary)
The proprietary information for which withholding is being requested in the above-referenced document is further identified in Affidavit CAW-12-3527 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. 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 of the Commission's regulations.
Accordingly, this letter authorizes the utilization of the accompanying affidavit by Exelon Generation.
Correspondence with respect t6 the proprietary aspects of this application for withholding or the accompanying affidavit should reference CAW-12-3527 and should be addressed to J.A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.Very truly yours, B.F. Maurer, Manager ABWR Licensing Enclosures CAW- 12-3527 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF BUTLER: Before me, the undersigned authority, personally appeared B.F. Maurer, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief: B.F. Maurer, Manager ABWR Licensing Sworn to and subscribed before me this 25th day of September 2012 Notary Public COMMONWEALTH OF PENNSYLVANIA I Notarial Seal Anne K. Stegman, Notary Public Unity Twp., Westmoreland County My Commission Expires Aug. 7, 2016 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES 2 CAW-12-3527 (I) I am Manager, ABWR Licensing, in Nuclear Services, 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) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.
(3) 1 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 Commission's 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 constitutes Westinghouse policy and provides 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 Westinghouse's 3 CAW-12-3527 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.
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.
4 CAW-12-3527 (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.(iii) 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.(iv) 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.(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP-17609-P, Revision 1, "Peach Bottom Units 2 and 3 Replacement Steam Dryer Structural Evaluation for High-Cycle Acoustic Loads" (Proprietary) for submittal to the Commission, being transmitted by Exelon Generation letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with the review of the Replacement Steam Dryer design and analysis which is a part of the Extended Power Uprate License Amendment Request for Peach Bottom Units 2 and 3, and may be used only for that purpose.
5 CAW-12-3527 This information is part of that which will enable Westinghouse to: (a) Assist the customer in obtaining NRC review of the Westinghouse Replacement Steam Dryer design and analysis methodology as applied to BWR extended power uprate applications.
Further this information has substantial commercial value as follows: (a) Westinghouse plans to sell the use of this information to its customers for purposes of replacement steam dryer design and analysis for licensing basis applications.(b) Its use by a competitor would improve their competitive position in the design and licensing of a similar product for BWR steam dryers in support of extended power uprate applications.(c) The information requested to be withheld reveals the distinguishing aspects of a design and methodology which was developed by Westinghouse.
Public disclosure of this proprietary information is likely to cause substantialharm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluations 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.
Proprietary Information Notice Transmitted herewith are proprietary and/or non-proprietary versions of documents 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 Commission's 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.
O Westinghouse U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Westinghouse Electric Company Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA Direct tel: (412) 374-4419 Direct fax: (724) 720-0857 e-mail: maurerbf@westinghouse.com WEC-PCH-RSD-12-142 CAW-12-3528 September 25, 2012 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
WCAP-17649-P, Revision 0, "Peach Bottom Units 2 and 3 ASME Code Stress Report" (Proprietary)
The proprietary information for which withholding is being requested in the above-referenced document is further identified in Affidavit CAW-12-3528 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. 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 of the Commission's regulations.
Accordingly, this letter authorizes the utilization of the accompanying affidavit by Exelon Generation.
Correspondence with respect to the proprietary aspects of this application for withholding or the accompanying affidavit should reference CAW-12-3528 and should be addressed to J. A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.Very truly yours, B.F. Maurer, Manager ABWR Licensing Enclosures CAW-12-3528 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF BUTLER: Before me, the undersigned authority, personally appeared B.F. Maurer, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief: B.F. Maurer, Manager ABWR Licensing Sworn to and subscribed before me this 25th day of September 2012 Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Anne M. Stegman, Notary Public Unity Twp., Westmoreland County My Commission Expires Aug. 7, 2016 MEMBER, PENNSYLVANIA ASSOCIATIONd OF NOTARIES 2 CAW-12-3528 (1) I am Manager, ABWR Licensing, in Nuclear Services, 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 Commission's 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 Commission's 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 constitutes Westinghouse policy and provides 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 Westinghouse's 3 CAW- 12-3528 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.
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.
4 CAW-12-3528 (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.(iii) 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.(iv) 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.(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP-17649-P, Revision 0, "Peach Bottom Units 2 and 3 ASME Code Stress Report" (Proprietary) for submittal to the Commission, being transmitted by Exelon Generation letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with the review of the Replacement Steam Dryer design and analysis which is a part of the Extended Power Uprate License Amendment Request for Peach Bottom Units 2 and 3, and may be used only for that purpose.
5 CAW-12-3528 This information is part of that which will enable Westinghouse to: (a) Assist the customer in obtaining NRC review of the Westinghouse Replacement Steam Dryer design and analysis methodology as applied to BWR extended power uprate applications.
Further this information has substantial commercial value as follows: (a) Westinghouse plans to sell the use of this information to its customers for purposes of replacement steam dryer design and analysis for licensing basis applications.(b) Its use by a competitor would improve their competitive position in the designand licensing of a similar product for BWR steam dryers in support of extended power uprate applications.(c) The information requested to be withheld reveals the distinguishing aspects of a design and 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 evaluations 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.
Proprietary Information Notice Transmitted herewith are proprietary and/or non-proprietary versions of documents 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 Commission's 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.
O Westinghouse Westinghouse Electric Company Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Directtel:
(412) 374-4419 Direct fax: (724) 720-0857 e-mail: maurerbf@westinghouse.com WEC-PCH-RSD-12-136 CAW-12-3529 September 25, 2012 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
WCAP-17654-P, Revision 2, "Peach Bottom Unit 2 Replacement Steam Dryer Power Ascension Program for Extended Power Uprate Description" (Proprietary)
The proprietary information for which withholding is being requested in the above-referenced document is further identified in Affidavit CAW-12-3529 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. 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 of the Commission's regulations.
Accordingly, this letter authorizes the utilization of the accompanying affidavit by Exelon Generation.
Correspondence with respect to the proprietary aspects of this application for withholding or the accompanying affidavit should reference CAW-12-3529 and should be addressed to J.A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.Very truly yours, B.F. Maurer, Manager ABWR Licensing Enclosures CAW-12-3529 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF BUTLER: Before me, the undersigned authority, personally appeared B.F. Maurer, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief: B.F. Maurer, Manager ABWR Licensing Sworn to and subscribed before me this 25th day of September 2012 Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Anne M. Stegman, Notary Public Unity Twp., Westmoreland County My Commission Expires Aug. 7, 2016 MEMBER, PENNSYLVANIA ASSocIAeTON OF NOTARIES 2 CAW-12-3529 (1) I am Manager, ABWR Licensing, in Nuclear Services, 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 Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.
(3) 1 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 Commission's 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 constitutes Westinghouse policy and provides 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 Westinghouse's 3 CAW-12-3529 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.
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.
4 CAW-12-3529 (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.(iii) 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.(iv) 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.(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP- 1 7654-P, Revision 2, "Peach Bottom Unit 2 Replacement Steam Dryer Power Ascension Program for Extended Power Uprate Description" (Proprietary) for submittal to the Commission, being transmitted by Exelon Generation letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with the review of the Replacement Steam Dryer design and analysis which is a part of the Extended Power Uprate License Amendment Request for Peach Bottom Units 2 and 3, and may be used only for that purpose.
5 CAW-12-3529 This information is part of that which will enable Westinghouse to: (a) Assist the customer in obtaining NRC review of the Westinghouse Replacement Steam Dryer design and analysis methodology as applied to BWR extended power uprate applications.
Further this information has substantial commercial value as follows: (a) Westinghouse plans to sell the use of this information to its customers for purposes of replacement steam dryer design and analysis for licensing basis applications.(b) Its use by a competitor would improve their competitive position in the design and licensing of a similar product for BWR steam dryers in support of extended power uprate applications.(c) The information requested to be withheld reveals the distinguishing aspects of a design and 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 evaluations 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.
Proprietary Information Notice Transmitted herewith are proprietary and/or non-proprietary versions of documents 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 Commission's 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.
OWestinghouse U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Westinghouse Electric Company Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA Directtel:
(412) 374-4419 Direct fax: (724) 720-0857 e-mail: maurerbf@westinghouse.com WEC-PCH-RSD-12-137 CAW-12-3533 September 25, 2012 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
WCAP- 17655-P, Revision 2, "Peach Bottom Unit 3 Replacement Steam Dryer Power Ascension Program for Extended Power Uprate Description" (Proprietary)
The proprietary information for which withholding is being requested in the above-referenced document is further identified in Affidavit CAW-12-3533 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. 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 of the Commission's regulations.
Accordingly, this letter authorizes the utilization of the accompanying affidavit by Exelon Generation.
Correspondence with respect to the proprietary aspects of this application for withholding or the accompanying affidavit should reference CAW-12-3533 and should be addressed to J.A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.Very truly yours, B.F. Maurer, Manager ABWR Licensing Enclosures CAW-12-3533 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF BUTLER: Before me, the undersigned authority, personally appeared B.F. Maurer, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief: B.F. Maurer, Manager ABWR Licensing Sworn to and subscribed before me this 25th day of September 2012 Notary Public_OMMONWEr.ALTH OF PENNSYLVANIA Notarial Seal Anne M. Stegman, Notary Public Unity Twp., Westmoreland County My Commission Expires Aug. 7, 2016 MEMBER, PENNSYLVMIIA ASSOCIATIOF OF NOTARIES 2 CAW-12-3533 (1) 1 am Manager, ABWR Licensing, in Nuclear Services, 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) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's 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 Commission's 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 constitutes Westinghouse policy and provides 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 Westinghouse's 3 CAW-12-3533 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.
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.
4 CAW- 12-3533 (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.(iii) 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.(iv) 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.(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP-17655-P, Revision 2, "Peach Bottom Unit 3 Replacement Steam Dryer Power Ascension Program for Extended Power Uprate Description" (Proprietary) for submittal to the Commission, being transmitted by Exelon Generation letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with the review of the Replacement Steam Dryer design and analysis which is a part of the Extended Power Uprate License Amendment Request for Peach Bottom Units 2 and 3, and may be used only for that purpose.
5 CAW-12-3533 This information is part of that which will enable Westinghouse to: (a) Assist the customer in obtaining NRC review of the Westinghouse Replacement Steam Dryer design and analysis methodology as applied to BWR extended power uprate applications.
Further this information has substantial commercial value as follows: (a) Westinghouse plans to sell the use of this information to its customers for purposes of replacement steam dryer design and analysis for licensing basis applications.(b) Its use by a competitor would improve their competitive position in the design and licensing of a similar product for BWR steam dryers in support of extended power uprate applications.(c) The information requested to be withheld reveals the distinguishing aspects of a design and 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 evaluations 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.
Proprietary Information Notice Transmitted herewith are proprietary and/or non-proprietary versions of documents 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 Commission's 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.
S Westinghouse Westinghouse Electric Company Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4419 Document Control Desk Direct fax: (724) 720-0857 11555 Rockville Pike e-mail: maurerbf@westinghouse.com Rockville, MD 20852 Proi letter: WEC-PCH-RSD-12-135 CAW-12-3530 September 24, 2012 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
WCAP-1761 I-P, Revision 1, "Peach Bottom Unit 2 and Unit 3 Replacement Steam Dryer Four-Line Subscale Acoustic Test Data Evaluation and Derivation of CLTP-to-EPU Scaling Spectra" (Proprietary)
The proprietary information for which withholding is being requested in the above-referenced document is further identified in Affidavit CAW-12-3530 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. 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 of the Commission's regulations.
Accordingly, this letter authorizes the utilization of the accompanying affidavit by Exelon Generation.
Correspondence with respect to the proprietary aspects of this application for withholding or the accompanying affidavit should reference CAW-12-3530 and should be addressed to J.A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.Very truly yours, B.F. Maurer, Manager ABWR Licensing Enclosures CAW-12-3530 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF BUTLER: Before me, the undersigned authority, personally appeared B.F. Maurer, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief: B.F. Maurer, Manager ABWR Licensing Sworn to and subscribed before me this 24th day of September 2012 Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seat I Anne M. Stegman, NotarY Public Unity Twp., westmoreiand County My Commission Expires Aug. 7, 2016 MEMER. PENNSYLVANIA ASSOCIATION Of NOTARIES 2 CAW-12-3530 (1) 1 am Manager, ABWR Licensing, in Nuclear Services, 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 Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.
(3) 1 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 Commission's 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 constitutes Westinghouse policy and provides 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 Westinghouse's 3 CAW-12-3530 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.
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.
4 CAW-12-3530 (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.(iii) 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.(iv) 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.(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP-1761 1-P, Revision 1, "Peach Bottom Unit 2 and Unit 3 Replacement Steam Dryer Four-Line Subscale Acoustic Test Data Evaluation and Derivation of CLTP-to-EPU Scaling Spectra" (Proprietary) for submittal to the Commission, being transmitted by Exelon Generation letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with the review of the Replacement Steam Dryer design and analysis which is a part of the Extended Power Uprate License Amendment Request for Peach Bottom Units 2 and 3, and may be used only for that purpose.
5 CAW-12-3530 This information is part of that which will enable Westinghouse to: (a) Assist the customer in obtaining NRC review of the Westinghouse Replacement Steam Dryer design and analysis methodology as applied to BWR extended power uprate applications.
Further this information has substantial commercial value as follows: (a) Westinghouse plans to sell the use of this information to its customers for purposes of replacement steam dryer design and analysis for licensing basis applications.(b) Its use by a competitor would improve their competitive position in the design and licensing of a similar product for BWR steam dryers in support of extended power uprate applications.(c) The information requested to be withheld reveals the distinguishing aspects of a design and 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 evaluations 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.i Proprietary Information Notice Transmitted herewith are proprietary and/or non-proprietary versions of documents 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 Commission's 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 2.3 90(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.
- Westinghouse U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Westinghouse Electric Company Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA Direct tel: (412) 374-4419 Direct fax: (724) 720-0857 e-mail: maurerbf@westinghouse.com Proj letter: WEC-PCH-RSD-12-133 CAW- 12-3531 September 24, 2012 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
WCAP-17626-P, Revision 0, "Processing of Peach Bottom Unit 2 and Unit 3 MSL Strain Gauge Data and Computation of Predicted EPU Signature" (Proprietary)
The proprietary information for which withholding is being requested in the above-referenced document is further identified in Affidavit CAW- 12-3531 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. 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 of the Commission's regulations.
Accordingly, this letter authorizes the utilization of the accompanying affidavit by Exelon Generation.
Correspondence with respect to the proprietary aspects of this application for withholding or the accompanying affidavit should reference CAW-12-3531 and should be addressed to J.A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.Very truly yours, B.F. Maurer, Manager ABWR Licensing Enclosures CAW-12-3531 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF BUTLER: Before me, the undersigned authority, personally appeared B.F. Maurer, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this N Affidavit are true and correct to the best of his knowledge, information, and belief: B.F. Maurer, Manager ABWR Licensing Sworn to and subscribed before me this 24th day of September 2012 Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Anne M. Stegman, Notary Public Unity Twp., Westmoreland County My Commission Expires Aug. 7, 2016 MEMBER, PENNSYLVANIA ASSOCIATION OF: NOTARIES 2 CAW-12-3531 (1) I am Manager, ABWR Licensing, in Nuclear Services, 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 Commission's 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 Commission's 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 constitutes Westinghouse policy and provides 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 Westinghouse's 3 CAW-12-3531 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.
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.
4 CAW-12-3531 (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.(iii) 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.(iv) 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.(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP-17626-P, Revision 0, "Processing of Peach Bottom Unit 2 and Unit 3 MSL Strain Gauge Data and Computation of Predicted EPU Signature" (Proprietary) for submittal to the Commission, being transmitted by Exelon Generation letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with the review of the Replacement Steam Dryer design and analysis which is a part of the Extended Power Uprate License Amendment Request for Peach Bottom Units 2 and 3, and may be used only for that purpose.
5 CAW-12-3531 This information is part of that which will enable Westinghouse to: (a) Assist the customer in obtaining NRC review of the Westinghouse Replacement Steam Dryer design and analysis methodology as applied to BWR extended power uprate applications.
Further this information has substantial commercial value as follows: (a) Westinghouse plans to sell the use of this information to its customers for purposes of replacement steam dryer design and analysis for licensing basis applications.(b) Its use by a competitor would improve their competitive position in the design and licensing of a similar product for BWR steam dryers in support of extended power uprate applications.(c) The information requested to be withheld reveals the distinguishing aspects of a design and 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 evaluations 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.
Proprietary Information Notice Transmitted herewith are proprietary and/or non-proprietary versions of documents 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 Commission's 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.
O Westinghouse U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Westinghouse Electric Company Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 1 6066 USA Direct tel: (412) 374-4419 Direct fax: (724) 720-0857 e-mail: maurerbf@westinghouse.com WEC-PCH-RSD-12-138 CAW-12-3532 September 25, 2012 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
WCAP-17639-P, Revision 2, "Instrumentation Description for the Peach Bottom Unit 2 Replacement Steam Dryer" (Proprietary)
The proprietary information for which withholding is being requested in the above-referenced document is further identified in Affidavit CAW-12-3532 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. 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 of the Commission's regulations.
Accordingly, this letter authorizes the utilization of the accompanying affidavit by Exelon Generation.
Correspondence with respect to the proprietary aspects of this application for withholding or the accompanying affidavit should reference CAW-12-3532 and should be addressed to J.A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.Very truly yours, B.F. Maurer, Manager ABWR Licensing Enclosures CAW-12-3532 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF BUTLER: Before me, the undersigned authority, personally appeared B.F. Maurer, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief: B.F. Maurer, Manager ABWR Licensing Sworn to and subscribed before me this 25th day of September 2012 L~4 COMMONWEALTH OF PENNSYLVANIA Notarial Seal Anne M. Stegman, Notary Public Unity Twp., Westmoreland County My Commission Expires Aug. 7, 2016 MEMBER. PENNSYLVANIA ASSOCIATON OF NOTARIES 2 CAW-12-3532 (1) I am Manager, ABWR Licensing, in Nuclear Services, 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 2.3 90 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.
(3) 1 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 Commission's 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 constitutes Westinghouse policy and provides 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 Westinghouse's 3 CAW-12-3532 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, too], 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.
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.
4 CAW-12-3532 (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.(iii) 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.(iv) 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.(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP-17639-P, Revision 2, "Instrumentation Description for the Peach Bottom Unit 2 Replacement Steam Dryer" (Proprietary) for submittal to the Commission, being transmitted by Exelon Generation letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with the review of the Replacement Steam Dryer design and analysis which is a part of the Extended Power Uprate License Amendment Request for Peach Bottom Units 2 and 3, and may be used only for that purpose.
5 CAW-12-3532 This information is part of that which will enable Westinghouse to: (a) Assist the customer in obtaining NRC review of the Westinghouse Replacement Steam Dryer design and analysis methodology as applied to BWR extended power uprate applications.
Further this information has substantial commercial value as follows: (a) Westinghouse plans to sell the use of this information to its customers for purposes of replacement steam dryer design and analysis for licensing basis applications.(b) Its use by a competitor would improve their competitive position in the design and licensing of a similar product for BWR steam dryers in support of extended power uprate applications.(c) The information requested to be withheld reveals the distinguishing aspects of a design and 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 evaluations 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.
Proprietary Information Notice Transmitted herewith are proprietary and/or non-proprietary versions of documents 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 Commission's 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.