ML102390421
| ML102390421 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Kewaunee, Surry, North Anna  |
| Issue date: | 08/20/2010 |
| From: | Funderburk C Dominion, Dominion Energy Kewaunee, Dominion Nuclear Connecticut, Dominion Resources Services, Virginia Electric & Power Co (VEPCO) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 10-486, CAW-09-2701, FOIA/PA-2011-0115 | |
| Download: ML102390421 (12) | |
Text
Dominion Resources Services, Inc. PROPRIETARY DomIion 5000 Dominion Boulevard, Glen Allen, VA 23060 Web Address: www.dom.com August 20, 2010 United States Nuclear Regulatory Commission Serial No.10-486 Attention: Document Control Desk NL&OS/ETS: RO Washington, D.C. 20555 Docket Nos. 50-280/281 50-338/339 50-336/423 50-305 License Nos. DPR-32/37 NPF-4/7 DPR-65/NPF-49 DPR-43 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)
DOMINION NUCLEAR CONNECTICUT. INC. (DNC)
DOMINION ENERGY KEWAUNEE, INC. (DEK)
NORTH ANNA AND SURRY POWER STATIONS UNITS 1 AND 2 MILLSTONE POWER STATION UNITS 2 AND 3 KEWAUNEE POWER STATION DOM-NAF-2-P/NP, REVISION 0.2-A. REACTOR CORE THERMAL-HYDRAULICS USING THE VIPRE-D COMPUTER CODE In accordance with the NRC guidelines, Dominion, DNC and DEK are hereby submitting the approved version of DOM-NAF-2, Revision 0.2, Reactor Core Thermal-Hydraulics Using the VIPRE-D Computer Code. The information requested in the NRC guidelines has been incorporated into the published Topical Report DOM-NAF-2-P, Revision 0.2-A.
Attachments 1 and 2 provide the Proprietary (DOM-NAF-2-P, Revision 0.2-A) and Non-Proprietary of (DOM-NAF-2-NP, Revision 0.2-A) versions of the topical report. Under separate letter, copies of DOM-NAF-2-P, Revision 0.2-A and DOM-NAF-2-NP, Revision 0.2-A have been provided to Dr. V. Sreenvias, NRC Licensing Project Manager. contains information proprietary to Westinghouse Electric Company, LLC.
Therefore, this information classification is supported by an affidavit signed by Westinghouse, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390 of the Commission's regulations. Accordingly, it is respectfully requested that the information, which is proprietary to Westinghouse, be withheld from public disclosure in accordance with 10 CFR 2.390 of the Commission's regulations.
The affidavit is included in Westinghouse authorization letter LTR-CAW-09-2701, "Application for Withholding Proprietary Information from Public Disclosure," which also includes a Proprietary Information Notice and a Copyright Notice. The Westinghouse Attachment 1contains information that is being withheld from public disclosure under 10 CFR 2.390. Upon separation this letter is decontrolled.
Serial No.10-486 Docket Nos. 50-305/336/423/338/339/280/281 Page 2 of 4 PROPRIETARY authorization letter is provided in Attachment 3. Correspondence with respect to the copyright or proprietary aspects of the Westinghouse information noted above or the supporting Westinghouse affidavit should reference the authorization letter and should be addressed to J. A. Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.
If you have any questions or require additional information, please contact Mr. Thomas Shaub at (804) 273-2763.
Sincerely, C. L. Funderburk Director Nuclear Licensing and Operations Support Dominion Resources Services, Inc. for Dominion Energy Kewaunee, Inc.
Dominion Nuclear Connecticut, Inc.
Virginia Electric and Power Company Commitments made in this letter: None Attachments:
- 1. Reactor Core Thermal-Hydraulics Using the VIPRE-D Computer Code, DOM-NAF-2-P, Revision 0.2-A, (PROPRIETARY).
- 2. Reactor Core Thermal-Hydraulics Using the VIPRE-D Computer Code DOM-NAF-2-NP, Revision 0.2-A, (NON-PROPRIETARY).
- 3. Westinghouse Electric Company LLC Authorization Letter LTR-CAW-09-2701, "Application for Withholding Proprietary Information from Public Disclosure," dated November 10, 2009 Attachment 1 contains information that is being withheld from public disclosure under 10 CFR 2.390. Upon separation this letter is decontrolled.
Serial No.10-486 Docket Nos. 50-305/336/423/338/339/280/281 Page 3 of 4 PROPRIETARY cc: (without attachments)
U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, Pennsylvania 19406-1415 U.S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Avenue, NE Suite 1200' Atlanta, Georgia 30303-1257 U.S. Nuclear Regulatory Commission Region III 2443 Warrenville Road Suite 210 Lisle, Illinois 60532-4352 Mr. K. D. Feintuch NRC Senior Project Manager - Kewaunee Power Station U. S. Nuclear Regulatory Commission One White Flint North 1,1555 Rockville Pike Mail Stop 08 H-4A Rockville, Maryland 20852-2738 Ms. C. J. Sanders NRC Project Manager - Millstone Power Station Units 2 and 3 U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 8 B1A Rockville, Maryland 20852-2738 Ms. K. R. Cotton NRC Project Manager - Surry Power Station U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 Attachment 1 contains information that is being withheld from public disclosure under 10 CFR 2.390. Upon separation this letter is decontrolled.
Serial No.10-486 Docket Nos. 50-305/336/423/338/339/280/281 Page 4 of 4 PROPRIETARY Dr. V. Sreenvias NRC Project Manager - North Anna Power Station U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Kewaunee Power Station NRC Senior Resident Inspector Millstone Power Station NRC Senior Resident Inspector North Anna Power Station NRC Senior Resident Inspector Surry Power Station contains information that is being withheld from public disclosure under 10 CFR 2.390. Upon separation this letter is decontrolled.
Serial No.10-486 Docket Nos. 50-305/336/423/338/339/280/281 ATTACHMENT 3 WESTINGHOUSE ELECTRIC COMPANY LLC AUTHORIZATION LETTER LTR-CAW-09-2701, "APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE," DATED NOVEMBER 10, 2009 DOMINION ENERGY KEWAUNEE, INC.
DOMINION NUCLEAR CONNECTICUT, INC.
VIRGINIA ELECTRIC AND POWER COMPANY KEWAUNEE POWER STATION MILLSTONE POWER STATION UNITS 2 AND 3 NORTH ANNA POWER STATION UNITS 1 AND 2 SURRY POWER STATION UNITS 1 AND 2
( Westinghouse Westinghouse Electric Company Nuclear Services P.O. Box 355 Pittsburgh. Pennsylvania 15230-03.55 USA U.S. Nuclear Rcgulatory Commission Directteh (412) 374-4643 Document Control Desk Direct fax- (4t2) 374-3846 Washington, DC 20555-0001 ! e-mail: greshaja@westingbouse.com Our ref: CAW-09-2701 November 10, .2009 APPLICATION -FORWITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
Supplemental Information in Support of the Removal of the Grid Spacing Restriction in Appendix B to Fleet Report DOM-NAF-2 (Proprietary)
The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-09-2701 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 Dominion Generation.
Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-09-2701, and should be addressed to J. A. Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.
Very truly y urs, JA.Gresham, Manager Regulatory Compliance and Plant Licensing Enclosures
CAW-09-2701 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF ALLEGHENY:
Before me, the undersigned authority, personally appeared J. A. Gresham, 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 fhate set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:
J. A. Gresham, Manager Regulatory Compliance and Plant Licensing Sworn to and subscribed before me this 1 0 'I day of November, 2009 Notary Public COMMONWEALTH Of PENNSYLVANIA NOTARIAL. SEAL Renee Giampolo, Notary Public Penn Township, Westmoreland County My Commission Expires September 25, 2013
2 CAW-09-2701 (1) I am Manager, Regulatory Compliance and Plant 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" 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 constitute Westinghouse policy and provide the rational basis required.
Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:
(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.
3 CAW-09-2701 (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. Its, 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.
(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.
4 CAW-09-2701 (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 2.3 90, 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, "Supplemental Information in Support of the.Removal of the Grid Spacing Restriction in Appendix B to Fleet Report DOM-NAF-2 (Dominion Letter 09-528A)," dated November, 10, 2009 (Proprietary), for submittal to the Commission, being transmitted by Dominion Generation and Application for Withholding Proprietary Information from Public Disclosure to the Document Control Desk. The proprietary information as submitted by Westinghouse for Dominion Generation is expected to be used in support of the removal of the grid spacing restriction.
This information is part of that which will enable Westinghouse to:
(a) Assist customer to obtain a license change.
Further this information has substantial commercial value as follows:
(a) Westinghouse can use this information to further enhance their licensing position with their competitors.
5 CAW-09-2701 (b) The information requested to be withheld reveals the distinguishing aspects of Westinghouse fuel designs and CHF correlations.
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 calculation, evaluation 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 2.3 90 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.