ML15111A289

Palo Verde Nuclear Generating Station (PVNGS) Unit 3 - Transmittal of Proprietary Documents for Relief Request 53

ML15111A289
Person / Time
Site:	Palo Verde
Issue date:	04/17/2015
From:	Cadogan J J Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
102-07037-JJC/JR
Download: ML15111A289 (22)

Text

The Attachments to the Enclosure containPROPRIETARY information to be withheld 10 CFR 50 55aunder 10 CFR 2 390John 3 Cadogan,aps Vice President Nuclear EngineeringPalo VerdeNuclear Generating StationP 0 Box 52034Phoenix AZ 85072Mail Station 7602Tel 623 393 5553102-07037-JJC/JRApril 17, 2015ATTN Document Control DeskU S Nuclear Regulatory CommissionWashington, DC 20555-0001Reference Arizona Public Service Company (APS) letter number 102-07034, PaloVerde Nuclear Generating Station Unit 3, Docket No STN 50-530,American Society of Mechanical Engineers (ASME) Code,Section XI,Request for Approval of an Alternative to Flaw Removal -ReliefRequest 53, dated April 17, 2015

Dear SirsSubject Palo Verde Nuclear Generating Station (PVNGS) Unit 3Docket No 50-530Transmittal of Proprietary Documents for Relief Request 53On April 17,

2015, pursuant to 10 CFR 50 55a(z)(1), Arizona Public Service Company(APS) submitted the referenced letter for Nuclear Regulatory Commission (NRC)approval of Relief Request 53This letter transmits proprietary documents referenced in APS letter number 102-07034 The attachments to the enclosure of this letter contain the proprietarydocuments Affidavits provided by Westinghouse Electric Company (Westinghouse),the owner of the information, to support the proprietary nature of the informationare included in the enclosure The affidavits, signed by Westinghouse, set forth thebasis on which the information may be withheld from public disclosure by theCommission and addresses with specificity the considerations listed in paragraph(b)(4) of Section 2 390 of the Commission's regulations Accordingly, it isrespectfully requested that the information which is proprietary to Westinghouse bewithheld from public disclosure in accordance with 10 CFR Section 2 390 of theCommission's regulationsCorrespondence with respect to the copyright or proprietary aspects of theproprietary documents or the supporting Westinghouse affidavits should beaddressed to James Gresham, Manager, Regulatory Compliance, WestinghouseElectric Company, 1000 Westinghouse Drive, Building 3, Cranberry Township,Pennsylvania, 16066Should you need further information regarding this submittal, please contact ThomasN Weber, Nuclear Regulatory Affairs Department Leader, at (623) 393-5764When the Attachments to the Enclosure are separated,this document is not considered ProprietaryA member of the STARS (Strategic Teaming and Resource Sharing) AllianceCallaway Diablo Canyon Palo Verde Wolf Creek The Attachments to the Enclosure contain102-07037-JJC/JR PROPRIETARY information to be withheldATTN Document Control Desk under 10 CFR 2 390U S Nuclear Regulatory CommissionTransmittal of Proprietary Documents for Relief Request 53Page 2No commitments are being made to the NRC by this letterSincerely,JJC/JREnclosure -Proprietary Documents Related to Relief Request 53cc M L DapasM M WatfordC A PeabodyNRC Region IV Regional AdministratorNRC NRR Project ManagerNRC Senior Resident Inspector for PVNGSWhen the Attachments to the Enclosure are separated,this document is not considered Proprietary The Attachments to the Enclosure containPROPRIETARY information to be withheldunder 10 CFR 2 390EnclosureProprietary Documents Related to Relief Request 53When the Attachments to the Enclosure are separated,this document is not considered Proprietary The Attachments to the Enclosure containPROPRIETARY information to be withheldunder 10 CFR 2 390EnclosureProprietary Documents Related to Relief Request 53The attachments to the enclosure provide the proprietary documents referred to inArizona Public Service Company (APS) letter number 102-07034, Palo Verde NuclearGenerating Station Unit 3, Docket No STN 50-530, American Society of MechanicalEngineers (ASME) Code, Section X1, Request for Approval of an Alternative to FlawRemoval -Relief Request 53, dated April 17, 2015 Affidavits to support the proprietarynature of these documents are included in this enclosureThese documents are supported by affidavits signed by Westinghouse, the owner of theinformation The affidavits set forth the basis on which the information may be withheldfrom public disclosure by the Commission and address with specificity theconsiderations listed in paragraph (b)(4) of Section 2 390 of the Commission'sregulations Accordingly, it is respectfully requested that the information which isproprietary to Westinghouse be withheld from public disclosure in accordance with 10CFR Section 2 390 of the Commission's regulationsCorrespondence with respect to the copyright or proprietary aspects of the proprietarydocuments or the supporting Westinghouse affidavits should be addressed to JamesGresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000Westinghouse Drive, Building 3, Cranberry Township, Pennsylvania, 16066This enclosure consists of two pages of descriptive information and two affidavits tosupport withholding the proprietary information in the attachments in accordance with 10CFR 2 390 The affidavits are not considered proprietary and are as follows* Affidavit for Document DAR-MRCDA-1 5-6-P, Rev 1" Affidavit for Documents Supporting DAR-MRCDA-1 5-6-P, Rev 1The proprietary attachments are as followsAttachment 1 -Westinghouse Document DAR-MRCDA-1 5-6-P, Rev 1, Palo VerdeUnit 3 RCS Cold Leg Alloy 600 Small Bore Nozzle RepairAttachment 2- Westinghouse Calculation CN-MRCDA-1 5-13, Rev 0, Qualificationof Palo Verde Unit 3 Reactor Coolant Pump ReplacementInstrumentation NozzleAttachment 3 -Westinghouse Calculation CN-PAFM-1 5-20, Rev 2, Palo Verde Unit3 RCS Cold Leg Alloy 600 Small Bore Nozzle Repair TransientStress and Fracture Mechanics Evaluation for One Cycle OperationAttachment 4 -Westinghouse Calculation TR-FSE-1 5-2, Rev 1, Palo Verde NuclearGenerating Station Unit 3 Evaluation of Potential Loose Part -Reactor Coolant Pump Instrument Nozzle Weld Fragment1When the Attachments to the Enclosure are separated,this document is not considered Proprietary The Attachments to the Enclosure containPROPRIETARY information to be withheldunder 10 CFR 2 390EnclosureProprietary Documents Related to Relief Request 53Attachment 5 -Westinghouse Letter, LTR-ME-1 5-30, Rev 2, ASME Code SectionXI Reconciliation for Arizona Public Service (APS), Palo VerdeNuclear Generating Station (PVNGS) Unit 3 Replacement InstrumentNozzleAttachment 6- Westinghouse Calculation CN-NPE-06-03, Rev 1, Plant X -Structural Evaluations of the RCP Pressure Tap NozzlesAttachment 7 -Drawings Referenced in Responses to NRC Questions" C-8000-101-2017, Rev 2, Wall Static Pressure Suction* STD-009-0009, Rev 2, Coolant Pumps Weld Joint Identification andFabrication Requirements* DWG 339-0054, Rev 0, Safe End Mach Of Pressure Tap Holes andWeld Prep (Suction)* C-14473-220-002, Rev 0, Replacement Pressure Tap Nozzle* E-14473-220-001, Rev 0, Pump Casing -A Pressure Tap NozzleModification Assembly* SE-14473-220-003, Rev 0, Pressure Tap nozzle Replacement PaloVerde Unit 32When the Attachments to the Enclosure are separated,this document is not considered ProDrietarv The Attachments to the Enclosure containPROPRIETARY information to be withheldunder 10 CFR 2 390EnclosureProprietary Documents Related to Relief Request 53AffidavitforDocumentDAR-MRCDA-15-6-P, Rev 1(NOTE Non-proprietary version of document submitted withAPS Letter Number 102-07034, Dated April 17, 2015)When the Attachments to the Enclosure are separated,this document is not considered Proprietary

( ) WestinghouseU S Nuclear Regulatory CommissionDocument Control Desk11555 Rockville PikeRockville, MD 20852Westinghouse Electric CompanyEngineenng Equipment and Major Projects1000 Westinghouse Drive, Building 3Cranberry Township, Pennsylvania 16066USADirect telDirect faxe mailProj letter(412) 374 4643(724) 940 8560greshaja@westinghouse cornCVER 15 34 Rev 1CAW-15 4163April 17, 2015APPLICATION FOR WITHHOLDING PROPRIETARYINFORMATION FROM PUBLIC DISCLOSURESubject DAR-MRCDA-15-6 P, Revision 1, "Palo Verde Unit 3 RCS Cold Leg Alloy 600 Small BoreNozzle Repair" (Proprietary)The proprietary information for which withholding is being requested in the above-referenced report isfurther identified m Affidavit CAW-15-4163 signed by the owner of the proprietary information,Westinghouse Electric Company LLC The Affidavit, which accompanies this letter, sets forth the basison which the information may be withheld from public disclosure by the Commission and addresses withspecificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2 390 of the Commission sregulationsAccordingly, this letter authorizes the utilization of the accompanying Affidavit by Arizona PublicService (APS)Correspondence with respect to the proprietary aspects of the Application for Withholding or theWestinghouse Affidavit should reference CAW-15 4163, and should be addressed to James A Gresham,Manager, Regulatory Compliance, Westinghouse Electric Company 1000 Westinghouse Drive,Building 3 Suite 310, Cranberry Township, Pennsylvania 16066Very truly yours,James A Gresham, ManagerRegulatory Compliance CAW-15-4163April 17, 2015AFFIDAVITCOMMONWEALTH OF PENNSYLVANIAssCOUNTY OF BUTLERI, James A Gresham, am authorized to execute this Affidavit on behalf of Westinghouse ElectricCompany LLC (Westinghouse), and that the averments of fact set forth m this Affidavit are true andcorrect to the best of my knowledge, information, and beliefAJames A Gresham, ManagerRegulatory Compliance 2CAW-15-4163(1) I am Manager, Regulatory Compliance, Westinghouse Electric Company LLC (Westinghouse),and as such, I have been specifically delegated the function of reviewing the proprietaryinformation sought to be withheld from public disclosure m connection with nuclear power plantlicensing and rule making proceedings, and am authorized to apply for its withholding on behalfof Westinghouse(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2 390 of theCommission's regulations and in conjunction with the Westinghouse Application for WithholdingProprietary Information from Public Disclosure accompanying this Affidavit(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designatinginformation 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 Comnussion's regulations,the following is furnished for consideration by the Commission in determining whether theinformation 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 heldin confidence by Westinghouse(ii) The information is of a type customarily held in confidence by Westinghouse and notcustomarily disclosed to the public Westinghouse has a rational basis for determiningthe types of information customarily held in confidence by it and, in that connectionutilizes a system to determine when and whether to hold certain types of information inconfidence The application of that system and the substance of that system constituteWestinghouse policy and provide the rational basis requiredUnder that system, information is held in confidence if it falls in one or more of severaltypes, the release of which might result in the loss of an existing or potential competitiveadvantage, 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 ofWestinghouse's competitors without license from Westinghouse constitutes acompetitive economic advantage over other companies 3CAW-15-4163(b) It consists of supporting data, including test data relative to a process (orcomponent, structure, tool, method, etc ), the application of which data secures acompetitive economic advantage, e g , by optimization or improvedmarketability(c) Its use by a competitor would reduce his expenditure of resources or improve hiscompetitive position m the design, manufacture, shipment, installation, assuranceof quality, or licensing a simular product(d) It reveals cost or price information, production capacities, budget levels orcommercial strategies of Westinghouse, its customers or suppliers(e) It reveals aspects of past, present, or future Westinghouse or customer fundeddevelopment plans and programs of potential commercial value to Westinghouse(f) It contains patentable ideas, for which patent protection may be desirable(ili) There are sound policy reasons behind the Westinghouse system which include thefollowing(a) The use of such information by Westinghouse gives Westinghouse a competitiveadvantage over its competitors It is, therefore, withheld from disclosure toprotect the Westinghouse competitive position(b) It is information that is marketable in many ways The extent to which suchinformation is available to competitors diminishes the Westinghouse ability tosell products and services involving the use of the information(c) Use by our competitor would put Westinghouse at a competitive disadvantage byreducing his expenditure of resources at our expense(d) Each component of proprietary information pertinent to a particular competitiveadvantage is potentially as valuable as the total competitive advantage Ifcompetitors acquire components of proprietary information, any one component 4CAW-15-4163may be the key to the entire puzzle, thereby depriving Westinghouse of acompetitive advantage(e) Unrestricted disclosure would jeopardize the position of prominence ofWestinghouse m the world market, and thereby give a market advantage to thecompetition of those countries(f) The Westinghouse capacity to invest corporate assets in research anddevelopment depends upon the success in obtaining and maintaining acompetitive advantage(iv) The information is being transmitted to the Commission in confidence and, under theprovisions of 10 CFR Section 2 390, it is to be received in confidence by theCommission(v) The information sought to be protected is not available in public sources or availableinformation has not been previously employed in the same original manner or method tothe best of our knowledge and belief(vi) The proprietary information sought to be withheld in this submittal is that which isappropriately marked in DAR-MRCDA-15-6-P, Revision 1, "Palo Verde Unit 3 RCSCold Leg Alloy 600 Small Bore Nozzle Repair" (Proprietary), for submittal to theCommission, being transmitted by APS letter and Application for WithholdingProprietary Information from Public Disclosure, to the Document Control Desk Theproprietary information as submitted by Westinghouse is that associated with the PaloVerde Unit 3 RCS Cold Leg Alloy 600 small bore nozzle repair, and may be used onlyfor that purpose(a) This information is part of that which will enable Westinghouse to(i) Provide fracture mechanics technical justification and structuralevaluation to support continued operation for Palo Verde Unit 3 withreactor coolant pump instrument nozzle with a half-nozzle repair 5CAW 15 4163(b) Further this information has substantial commercial value as follows(i) Westinghouse plans to sell the use of similar information to its customersfor the purpose of providing fracture mechanics technical justificationand structural evaluation to support operation of reactor coolant pumpswith instrument nozzles with a half nozzle repair(n) Westinghouse can sell support and defense of industry guidelines andacceptance criteria for plant-specific applications(ill) The information requested to be withheld reveals the distinguishingaspects of a methodology which was developed by WestinghousePublic disclosure of this proprietary information is likely to cause substantial harm to thecompetitive position of Westinghouse because it would enhance the ability ofcompetitors to provide similar technical evaluation justifications and licensing defenseservices for commercial power reactors without commensurate expenses Also, publicdisclosure of the information would enable others to use the information to meet NRCrequirements for licensing documentation without purchasing the right to use theinformationThe development of the technology described in part by the information is the result ofapplying the results of many years of experience in an intensive Westinghouse effort andthe expenditure of a considerable sum of moneyIn order for competitors of Westinghouse to duplicate this information, similar technicalprograms would have to be performed and a significant manpower effort, having therequisite talent and expenence, would have to be expendedFurther the deponent sayeth not PROPRIETARY INFORMATION NOTICETransmitted herewith are proprietary and non-propnetary versions of documents furnished to the NRCthat associated with the Palo Verde Unit 3 RCS Cold Leg Alloy 600 small bore nozzle repair, and may beused only for that purposeIn order to conform to the requirements of 10 CFR 2 390 of the Commission's regulations concerning theprotection of proprietary information so submitted to the NRC, the information which is proprietary in theproprietary versions is contained within brackets and where the proprietary information has been deletedin the non-proprietary versions, only the brackets remain (the information that was contained within thebrackets in the proprietary versions having been deleted) The justification for claiming the informationso 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 beingidentified as proprietary or in the margin opposite such information These lower case letters refer to thetypes of information Westinghouse customarily holds in confidence identified in Sections (4)(n)(a)through (4)(ii)(f) of the Affidavit accompanying this transmittal pursuant to 10 CFR 2 390(b)(1)COPYRIGHT NOTICEThe reports transmitted herewith each bear a Westinghouse copyright notice The NRC is permitted tomake the number of copies of the information contained in these reports which are necessary for itsinternal use in connection with generic and plant-specific reviews and approvals as well as the issuancedenial, 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 publicdisclosure to the extent such information has been identified as proprietary by Westinghouse, copyrightprotection notwithstanding With respect to the non-proprietary versions of these reports, the NRC ispermitted to make the number of copies beyond those necessary for its internal use which are necessary inorder to have one copy available for public viewing in the appropriate docket files in the public documentroom in Washington, DC and in local public document rooms as may be required by NRC regulations ifthe number of copies submitted is insufficient for thus purpose Copies made by the NRC must includethe copyright notice in all instances and the proprietary notice if the original was identified as proprietary The Attachments to the Enclosure containPROPRIETARY information to be withheldunder 10 CFR 2 390EnclosureProprietary Documents Related to Relief Request 53AffidavitforDocuments SupportingDAR-MRCDA-15-6-P, Rev 1When the Attachments to the Enclosure are separated,this document is not considered Proprietary Westinghouse Electric CompanyS W estinghouse Engineering Equipment and Major Projects1000 Westinghouse Drive Building 3Cranberry Township Pennsylvania 16066USAU S Nuclear Regulatory Cominussion Direct tel (412) 374 4643Document Control Desk Direct fax (724) 940 856011555 Rockville Pike e mail greshaja@westinghouse cornRockville, MD 20852 Proj letter CVER-15 34 Rev 1CAW-15-4164April 17, 2015APPLICATION FOR WITHHOLDING PROPRIETARYINFORMATION FROM PUBLIC DISCLOSURESubject Supporting Documents to DAR-MRCDA-15-6I LTR-ME-15-30 Revision 2, "ASME Code Section XI Reconciliation for Arizona Public Service(APS), Palo Verde Nuclear Generating Station (PVNGS) Umt 3 Replacement Instrument Nozzle"(Proprietary)2 CN-PAFM-15-20 Revision 2, "Palo Verde Unit 3 RCS Cold Leg Alloy 600 Small Bore NozzleRepair Transient Stress and Fracture Mechanics Evaluation for One Cycle Operation" (Proprietary)3 CN-MRCDA-15-13 Revision 0 "Qualification of Palo Verde Unit 3 Reactor Coolant PumpReplacement Instrumentation Nozzle" (Proprietary)4 TR-FSE-15-2, Revision 1, "Palo Verde Nuclear Generating Station Unit 3 Evaluation of PotentialLoose Part -Reactor Coolant Pump Instrument Nozzle Weld Fragment" (Proprietary)5 CN-NPE-06-XXXX-03, Revision 1, "Plant X -Structural Evaluations of the RCP Pressure TapNozzles" (Proprietary)6 C-14473-220 002, Revision 0, "Replacement Pressure Tap Nozzle" (Proprietary)7 E-14473-220-001, Revision 0, "Pump Casing -A Pressure Tap Nozzle Modification Assembly"(Proprietary)8 C-8000-101-2017, Revision 2, 'Wall Static Pressure Suction" (Proprietary)9 339-0054, Revision 0 "Safe End Mach Of Pressure Tap Holes & Weld Prep (Suction)"(Proprietary)10 STD 009-0009, Revision 2, "Coolant Pumps Weld Joint Identification and FabricationRequirements" (Proprietary)11 SE-14473-220-003, Revision 0, "Pressure Tap Nozzle Replacement Palo Verde Unit 3" (Proprietary)The proprietary information for which withholding is being requested in the above-referenced reports isfurther identified in Affidavit CAW- 15-4164 signed by the owner of the proprietary mformation,Westinghouse Electric Company LLC The Affidavit, which accompanies this letter, sets forth the basison which the information may be withheld from public disclosure by the Commission and addresses withspecificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2 390 of the Commission'sregulationsThe subject documents were prepared and classified as Westinghouse Proprietary Class 2 Westinghouserequests that the documents be considered proprietary m their entirety As such, non-proprietary versionswill not be issued CAW-15-4164April 17, 2015Accordingly this letter authorizes the utilization of the accompanying Affidavit by Arizona PublicService (APS)Correspondence with respect to the proprietary aspects of the Application for Withholding or theWestinghouse Affidavit should reference CAW-15-4164, and should be addressed to James A Gresham,Manager, Regulatory Compliance, Westinghouse Electrc Company, 1000 Westinghouse Drive,Building 3 Suite 310, Cranberry Township Pennsylvania 16066Very truly yours,~n/James A Gresham ManagerRegulatory Compliance CAW-15-4164April 17, 2015AFFIDAVITCOMMONWEALTH OF PENNSYLVANIAssCOUNTY OF BUTLERI, James A Gresham am authorized to execute this Affidavit on behalf of Westinghouse ElectricCompany LLC (Westinghouse) and that the averments of fact set forth in this Affidavit are true andcorrect to the best of my knowledge information, and beliefxsA Greshamn ManagerRegulatory Compliance 2CAW-15-4164(1) 1 am Manager, Regulatory Compliance, Westinghouse Electric Company LLC (Westinghouse),and as such, I have been specifically delegated the function of reviewing the proprietaryinformation sought to be withheld from public disclosure in connection with nuclear power plantlicensing and rule making proceedings, and am authorized to apply for its withholding on behalfof Westinghouse(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2 390 of theCommission's regulations and in conjunction with the Westinghouse Application for WithholdingProprietary Information from Public Disclosure accompanying this Affidavit(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designatinginformation 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 theinformation sought to be withheld from public disclosure should be withheld(1) The information sought to be withheld from public disclosure is owned and has been heldin confidence by Westinghouse(n1) The information is of a type customarily held in confidence by Westinghouse and notcustomarily disclosed to the public Westinghouse has a rational basis for determiningthe 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 inconfidence The application of that system and the substance of that system constituteWestinghouse policy and provide the rational basis requiredUnder that system, information is held in confidence if it falls in one or more of severaltypes, the release of which might result in the loss of an existing or potential competitiveadvantage 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 3CAW-15 4164Westinghouse's competitors without license from Westinghouse constitutes acompetitive economic advantage over other companies(b) It consists of supporting data, including test data relative to a process (orcomponent, structure, tool method, etc ), the application of which data secures acompetitive economic advantage, e g by optmuzation or improvedmarketability(c) Its use by a competitor would reduce his expenditure of resources or improve hiscompetitive position in the design manufacture, shipment installation, assuranceof quality, or licensing a similar product(d) It reveals cost or price information, production capacities, budget levels, orcommercial strategies of Westinghouse, its customers or suppliers(e) It reveals aspects of past, present or future Westinghouse or customer fundeddevelopment plans and programs of potential commercial value to Westinghouse(f) It contains patentable ideas, for which patent protection may be desirable(ni There are sound policy reasons behind the Westinghouse system which include thefollowing(a) The use of such information by Westinghouse gives Westinghouse a competitiveadvantage over its competitors It is, therefore, withheld from disclosure toprotect the Westinghouse competitive position(b) It is information that is marketable in many ways The extent to which suchinformation is available to competitors diminishes the Westinghouse ability tosell products and services involving the use of the information(c) Use by our competitor would put Westinghouse at a competitive disadvantage byreducing his expenditure of resources at our expense 4CAW-15-4164(d) Each component of proprietary information pertinent to a particular competitiveadvantage is potentially as valuable as the total competitive advantage Ifcompetitors acquire components of proprietary information, any one componentmay be the key to the entire puzzle thereby depriving Westinghouse of acompetitive advantage(e) Unrestricted disclosure would jeopardize the position of prominence ofWestinghouse m the world market, and thereby give a market advantage to thecompetition of those countries(f) The Westinghouse capacity to invest corporate assets in research anddevelopment depends upon the success in obtaining and maintaining acompetitive advantage(iv) The information is being transmitted to the Commission in confidence and, under theprovisions of 10 CFR Section 2 390, it is to be received in confidence by theCommission(v) The information sought to be protected is not available in public sources or availableinformation has not been previously employed in the same original manner or method tothe best of our knowledge and belief(vi) The proprietary information sought to be withheld in this submittal is that which supportsDAR MRCDA-15-6, for submittal to the Commission being transmitted by APS letterand Application for Withholding Proprietary Information from Public Disclosure, to theDocument Control Desk The proprietary information as submitted by Westinghouse isthat associated with the Palo Verde Unit 3 RCS Cold Leg Alloy 600 small bore nozzlerepair, and may be used only for that purpose(a) This information is part of that which will enable Westinghouse to(1) Provide fracture mechanics technical justification and structuralevaluation to support continued operation for Palo Verde Unit 3 withreactor coolant pump instrument nozzle with a half-nozzle repair 5CAW-15-4164(b) Further this informauon has substantial commercial value as follows(1) Westinghouse plans to sell the use of similar information to its customersfor the purpose of fracture mechanics technical justification andstructural evaluation to support operation of reactor coolant pumps withinstrument nozzles with a half nozzle repair(ni) Westinghouse can sell support and defense of industry guidelines andacceptance criteria for plant-specific applications(iii) The information requested to be withheld reveals the distinguishingaspects of a methodology which was developed by WestinghousePublic disclosure of this proprietary information is likely to cause substantial harm to thecompetitive position of Westinghouse because it would enhance the ability ofcompetitors to provide similar technical evaluation justifications and licensing defenseservices for commercial power reactors without commensurate expenses Also, publicdisclosure of the information would enable others to use the information to meet NRCrequirements for licensing documentation without purchasing the right to use theinformationThe development of the technology described in part by the information is the result ofapplying the results of many years of experience in an intensive Westinghouse effort andthe expenditure of a considerable sum of moneyIn order for competitors of Westinghouse to duplicate this information, similar technicalprograms would have to be performed and a significant manpower effort, having therequisite talent and experience, would have to be expendedFurther the deponent sayeth not PROPRIETARY INFORMATION NOTICETransmitted herewith are the proprietary versions of documents furnished to the NRC associated with thePalo Verde Unit 3 RCS Cold Leg Alloy 600 small bore nozzle repair, and may be used only for thatpurpose The documents are to be considered proprietary in their entiretyCOPYRIGHT NOTICEThe report transmitted herewith bears a Westinghouse copyright notice The NRC is permitted to makethe number of copies of the information contained in this report which is necessary for its internal use inconnection with generic and plant-specific reviews and approvals as well as the issuance, demal,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 publicdisclosure to the extent such information has been identified as proprietary by Westinghouse, copyrightprotection notwithstanding Copies made by the NRC must include the copyright notice in all instancesand the proprietary notice if the original was identified as proprietary