|
---|
Category:CORRESPONDENCE-LETTERS
MONTHYEARML17355A4601999-10-26026 October 1999 Forwards Revised Epips,Including Revs to 0-EPIP-1102, 0-EPIP-1212,0-EPIP-20110,0-EPIP-20111,0-EPIP-20132, 0-EPIP-20133 & 0-EPIP-20201,per 10CFR50.54(q) & 10CFR50, App E.Epip 0-EPIP-20107,has Been Deleted ML17355A4301999-10-0808 October 1999 Forwards Rev 16 of Updated Fsar.Info Accurately Reflects Plant Changes Made Since Previous Submittal.Rev Incorporates Changes Completed Between 971015 & 990408.Summary of Accuracy Review Changes & Instructions,Included ML17355A4461999-10-0404 October 1999 Notifies NRC of Change in Commitment to Perform Periodic Testing of Critical Welds & Parts on Special Lifting Devices IAW NUREG-0612.Use of Ae Technology Will Provide Same Level of Testing Quality as Did NDE Methods Noted in ANSI Std L-99-208, Forwards Changes,Tests & Experiments Made as Allowed by 10CFR50.59 for Period Covering 971014-990408. Summary of PORV Actuations & Results of Plants SG Tube Insp,Which Occurred During That Time Included1999-10-0404 October 1999 Forwards Changes,Tests & Experiments Made as Allowed by 10CFR50.59 for Period Covering 971014-990408. Summary of PORV Actuations & Results of Plants SG Tube Insp,Which Occurred During That Time Included ML17355A4291999-10-0404 October 1999 Forwards Response to NRC Telcon Questions Re License Amend Request Dtd 990727,proposing Amend on one-time Basis to Modify TS 3.8.1.1 & TS 3.4.3 & 3.5.2 to Extend Allowed Outage Time for EDG from 72 H to 7 Days ML20212M1601999-09-28028 September 1999 Refers to 990908 Engineering Meeting Conducted at NRC Region II to Discuss Engineering Issues at Lucie & Turkey Point Facilities.List of Attendees & Copy of Presentation Handout Encl ML17355A4251999-09-22022 September 1999 Forwards NRC Form 536 in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams, Issued 990820 ML17355A4111999-09-0909 September 1999 Informs That Thermo-Lag Upgrades for Fire Zones 47,54,113, 114,115,116,118,119,120 & 143 Completed on 990726,per GL 92-08 ML17355A4131999-09-0707 September 1999 Forwards Revised Relief Request 20 Re Requirement to Perform Exams as Required by IWL-2524 & IWL-2525,Table IWL-2500-1 for Exempt Tendon Insp,Per Recent Discussions with NRC ML17355A4141999-09-0202 September 1999 Documents That Util Has No Concerns or Challenges Related to site-specific Written Exam Administered at Plant on 990830 ML17355A4041999-08-23023 August 1999 Forwards Info to Support Assessment of Potential Risks Associated with Proposed Civil Aircraft Operations at Former Homestead Air Force Base to FP&L Turkey Point Nuclear Facility Units 3 & 4 ML17355A4071999-08-23023 August 1999 Informs That FPL Has Completed Review of Info Listed in Reactor Vessel Integrity Database,Version 2 & Found Listed Discrepancies,Re Closure of GL 92-01,rev 1,suppl 1, Reactor Vessel Structural Integrity. ML17355A4061999-08-23023 August 1999 Forwards Semiannual FFD Performance Rept for Period of Jan- June 1999,for Turkey Point Units 3 & 4.List of Events Reported & Summary of Mgt Actions Taken,Included ML17355A4001999-08-20020 August 1999 Informs That on 990722,util Determined Blind Specimen Submitted to Smithkline Beecham Clinical Labs on 990721,was Reported Back with Unsatisfactory Results.Attachment 1 Is Summary of Investigation of Unsatisfactory Performance ML17355A3941999-07-27027 July 1999 Submits Response to NRC AL 99-02, Operating Reactor Licensing Action Estimates, for FY00 & FY01 ML17355A3871999-07-16016 July 1999 Provides Supplement to FP&L Response to NRC Request for Info Re Y2K Readiness at Nuclear Power Plants ML17355A3851999-07-14014 July 1999 Informs That Pages Missing from 1998 Annual Radiological Environ Operating Rept, Contain Info Unrelated to ODCM- Specified Sampling & Were Not Included as Part of Rept ML17355A3711999-07-0606 July 1999 Forwards Revised EPIPs 0-EPIP-20201, Maintaining Emergency Preparedness - Radiological Emergency Plan Training & 0-EPIP-20126, Off-Site Dose Calculations. with Summary of Changes ML17355A3591999-06-30030 June 1999 Forwards Turkey Point,Unit 4 ISI Rept. Listed Repts Are Encl.No Eddy Current Exams Scheduled for Unit 4 Steam Generators ML17355A3661999-06-30030 June 1999 Forwards Florida Power & Light Topical QA Rept, Dtd June 1999.Encl I Includes Summary of Changes Made to Topical QA Rept Since 1998 ML17355A3571999-06-28028 June 1999 Informs That Util Voluntarily Reporting Facility Readiness as Outlined in Suppl 1 to GL 98-01.Encl Is Y2K Readiness Disclosure for Units 3 & 4,reporting Status of Facility Y2K Readiness ML17355A3521999-06-18018 June 1999 Forwards Response to NRC 990415 RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves. ML17355A3491999-06-0404 June 1999 Forwards Summary of Corrective Actions Implemented by FPL Re GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design Basis Accident Conditions. ML17355A3441999-05-27027 May 1999 Modifies FPLs Consent to Confirmatory Order to Reflect Resolution of Four Issues Identified as Pending in L-99-031 ML17355A3451999-05-24024 May 1999 Requests Waiver of 520 Hours (13 Wks) Required Parallel Watchstanding in Control Room Prior to License Application Submittal for W Conley ML17355A2921999-04-22022 April 1999 Forwards Rev 35 to Turkey Point EP & Revised EPIP 0-EPIP-20101, Duties of EC, Per Requirements of 10CFR50, App E & 10CFR50.54(q).Summary of Changes,Encl.Implementation Date for Both Documents Was 990330 ML20205M0431999-04-13013 April 1999 Eighth Partial Response to FOIA Request for Records.App Q & R Records Encl & Being Made Available in PDR ML17355A2891999-04-0909 April 1999 Forwards Relief Request 20, Exempt Tendon Insp, Requesting Relief from ASME Section XI Code,1992 Edition,Paragraph IWL-2521.1(c) Which Requires That Each Exempted Tendon Be Examined IAW IWL-2524 & IWL-2525.Approval Needed by 991001 ML17355A2861999-04-0505 April 1999 Forwards COLR for Turkey Point Unit 4,Cycle 18,IAW TS 6.9.1.7 ML17336A0681999-04-0101 April 1999 Expresses Support for FP&L Request for Waiver of Applicable Review Fees Upon FP&L Submittal of an Application for License Renewal for Turkey Point Units 3 & 4 ML17355A2751999-03-25025 March 1999 Informs NRC & Staff of Fp&Ls Plans to Submit License Renewal Application for Turkey Point Units 3 & 4 by End of Dec 2000 ML17355A2641999-03-19019 March 1999 Requests Changes to FPL Official Service List for Turkey Point,Units 3 & 4.Add s Franzone & Remove G Hollinger from All Correspondence ML17355A2651999-03-19019 March 1999 Forwards Annual Radioactive Effluent Release Rept for Jan-Dec 1998 & Rev 7 to ODCM for Gaseous & Liquid Effluents from Turkey Point,Units 3 & 4. ML17355A2621999-03-16016 March 1999 Forwards Special Rept as Result of Turkey Point Unit 3 End-of-Cycle 16 ISI of SG Tubes.Rept Summarizes Results of SG Tube ISI ML17355A2631999-03-12012 March 1999 Forwards FPL Decommissioning Fund Status Repts for St Lucie, Units 1 & 2 & Turkey Point,Units 3 & 4.Rept for St Lucie, Unit 2 Provides Status of Decommissioning Funds for All Three Owners of That Unit ML20204C6991999-03-10010 March 1999 Requests Amend to Turkey Point PSP to Modify Requirement to Post Security Officers to Provide Continuous Observation of Entire PA Perimeter in Event of Security Computer Failure. Change to Security Force Staffing Level Also Requested ML17355A2451999-03-0909 March 1999 Submits Info on FPL Current Levels of Nuclear Property Insurance,Per 10CFR50.54(w)(3) ML17355A2501999-03-0808 March 1999 Informs That Licensee Reviewed NRC 990228 Ltr Issuing Exemption Requested Re Fire Rating of Raceway Fire Barriers in Open Turbine Bldg.Tabulated Summary of Util Comments & Marked Copy of NRC Ltr & SER Encl ML17355A2441999-03-0101 March 1999 Provides Update to Util Written Notices,Dtd 961120 & 970627 of Claim Involving Alleged Bodily Injury Arising Out of or in Connection with Use of Radioactive Matl at Units 3 & 4 ML17355A2431999-02-25025 February 1999 Informs That FPL Does Not Have Any Candidates from Turkey Point Scheduled to Participate in 990407,Generic Fundamentals Examination (GFE) ML17355A2301999-02-18018 February 1999 Forwards Semiannual Fitness for Duty Performance Data for Period of 980701-981231 for Turkey Point Units 3 & 4 ML17355A2361999-02-18018 February 1999 Forwards Tabulation of 1998 Occupational Exposure Data for Turkey Point,Units 3 & 4,per TS 6.9.1.2.a.Reactor Coolant Specific Activity Limits of 100/E-bar Mci Per Gram of Gross Radioactivity Were Not Exceeded During 1998 L-99-042, Forwards Rev 13 to Turkey Point Physical Security Plan,Per 10CFR50.54(p).Util Determined That Rev Does Not Decrease Safeguards Effectiveness of Plan.Encl Withheld,Per 10CFR2.790(a)(3)1999-02-18018 February 1999 Forwards Rev 13 to Turkey Point Physical Security Plan,Per 10CFR50.54(p).Util Determined That Rev Does Not Decrease Safeguards Effectiveness of Plan.Encl Withheld,Per 10CFR2.790(a)(3) ML17355A2341999-02-18018 February 1999 Provides Response to RAI Re GL 97-01, Degradation of Crdm/ CEDM Nozzle & Other Vessel Closure Head Penetrations. ML17355A2231999-02-0808 February 1999 Informs That Util Will Comply with Commitment with Respect to Units 3 & 4,in Response to Ja Zwolinski 990129 Ltr.Util Also Agrees to Incorporate Commitment Into Confirmatory Order Modifying License Effective Immediately Upon Issuance ML17355A2031999-01-29029 January 1999 Forwards Rev 3 to Turkey Point Nuclear Plant Recovery Plan. Rev Does Not Decrease Effectiveness of Plan ML17355A2171999-01-20020 January 1999 Forwards Listed ISI Repts for Turkey Point Unit 3,in Accordance with Provisions of ASME Code,Section XI ML17354B2241999-01-0606 January 1999 Forwards Annual 10CFR50.46 Rept Re Changes To,Or Errors Discovered in ECCS Evaluation Models,Or in Application of Such Models That Effect Peak Clad Temp Calculation ML17354B2081998-12-15015 December 1998 Informs That Fpl,In Cooperation with State of Fl & County Emergency Response Agencies,Will Conduct Exercise of Turkey Point Radiological Emergency Plan on 990210.Scenario Package Forwarded to Emergency Preparedness Section Chief,Region II ML17354B2091998-12-15015 December 1998 Forwards Price Anderson Guarantees Annual Financial Rept,Per 10CFR140.21.Exhibit 1 Submitted to Satisfy Annual Financial Reporting Requirement of 10CFR50.71(b) 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML17355A4601999-10-26026 October 1999 Forwards Revised Epips,Including Revs to 0-EPIP-1102, 0-EPIP-1212,0-EPIP-20110,0-EPIP-20111,0-EPIP-20132, 0-EPIP-20133 & 0-EPIP-20201,per 10CFR50.54(q) & 10CFR50, App E.Epip 0-EPIP-20107,has Been Deleted ML17355A4301999-10-0808 October 1999 Forwards Rev 16 of Updated Fsar.Info Accurately Reflects Plant Changes Made Since Previous Submittal.Rev Incorporates Changes Completed Between 971015 & 990408.Summary of Accuracy Review Changes & Instructions,Included ML17355A4461999-10-0404 October 1999 Notifies NRC of Change in Commitment to Perform Periodic Testing of Critical Welds & Parts on Special Lifting Devices IAW NUREG-0612.Use of Ae Technology Will Provide Same Level of Testing Quality as Did NDE Methods Noted in ANSI Std L-99-208, Forwards Changes,Tests & Experiments Made as Allowed by 10CFR50.59 for Period Covering 971014-990408. Summary of PORV Actuations & Results of Plants SG Tube Insp,Which Occurred During That Time Included1999-10-0404 October 1999 Forwards Changes,Tests & Experiments Made as Allowed by 10CFR50.59 for Period Covering 971014-990408. Summary of PORV Actuations & Results of Plants SG Tube Insp,Which Occurred During That Time Included ML17355A4291999-10-0404 October 1999 Forwards Response to NRC Telcon Questions Re License Amend Request Dtd 990727,proposing Amend on one-time Basis to Modify TS 3.8.1.1 & TS 3.4.3 & 3.5.2 to Extend Allowed Outage Time for EDG from 72 H to 7 Days ML17355A4251999-09-22022 September 1999 Forwards NRC Form 536 in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams, Issued 990820 ML17355A4111999-09-0909 September 1999 Informs That Thermo-Lag Upgrades for Fire Zones 47,54,113, 114,115,116,118,119,120 & 143 Completed on 990726,per GL 92-08 ML17355A4131999-09-0707 September 1999 Forwards Revised Relief Request 20 Re Requirement to Perform Exams as Required by IWL-2524 & IWL-2525,Table IWL-2500-1 for Exempt Tendon Insp,Per Recent Discussions with NRC ML17355A4141999-09-0202 September 1999 Documents That Util Has No Concerns or Challenges Related to site-specific Written Exam Administered at Plant on 990830 ML17355A4041999-08-23023 August 1999 Forwards Info to Support Assessment of Potential Risks Associated with Proposed Civil Aircraft Operations at Former Homestead Air Force Base to FP&L Turkey Point Nuclear Facility Units 3 & 4 ML17355A4071999-08-23023 August 1999 Informs That FPL Has Completed Review of Info Listed in Reactor Vessel Integrity Database,Version 2 & Found Listed Discrepancies,Re Closure of GL 92-01,rev 1,suppl 1, Reactor Vessel Structural Integrity. ML17355A4061999-08-23023 August 1999 Forwards Semiannual FFD Performance Rept for Period of Jan- June 1999,for Turkey Point Units 3 & 4.List of Events Reported & Summary of Mgt Actions Taken,Included ML17355A4001999-08-20020 August 1999 Informs That on 990722,util Determined Blind Specimen Submitted to Smithkline Beecham Clinical Labs on 990721,was Reported Back with Unsatisfactory Results.Attachment 1 Is Summary of Investigation of Unsatisfactory Performance ML17355A3941999-07-27027 July 1999 Submits Response to NRC AL 99-02, Operating Reactor Licensing Action Estimates, for FY00 & FY01 ML17355A3871999-07-16016 July 1999 Provides Supplement to FP&L Response to NRC Request for Info Re Y2K Readiness at Nuclear Power Plants ML17355A3851999-07-14014 July 1999 Informs That Pages Missing from 1998 Annual Radiological Environ Operating Rept, Contain Info Unrelated to ODCM- Specified Sampling & Were Not Included as Part of Rept ML17355A3711999-07-0606 July 1999 Forwards Revised EPIPs 0-EPIP-20201, Maintaining Emergency Preparedness - Radiological Emergency Plan Training & 0-EPIP-20126, Off-Site Dose Calculations. with Summary of Changes ML17355A3591999-06-30030 June 1999 Forwards Turkey Point,Unit 4 ISI Rept. Listed Repts Are Encl.No Eddy Current Exams Scheduled for Unit 4 Steam Generators ML17355A3661999-06-30030 June 1999 Forwards Florida Power & Light Topical QA Rept, Dtd June 1999.Encl I Includes Summary of Changes Made to Topical QA Rept Since 1998 ML17355A3571999-06-28028 June 1999 Informs That Util Voluntarily Reporting Facility Readiness as Outlined in Suppl 1 to GL 98-01.Encl Is Y2K Readiness Disclosure for Units 3 & 4,reporting Status of Facility Y2K Readiness ML17355A3521999-06-18018 June 1999 Forwards Response to NRC 990415 RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves. ML17355A3491999-06-0404 June 1999 Forwards Summary of Corrective Actions Implemented by FPL Re GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design Basis Accident Conditions. ML17355A3441999-05-27027 May 1999 Modifies FPLs Consent to Confirmatory Order to Reflect Resolution of Four Issues Identified as Pending in L-99-031 ML17355A3451999-05-24024 May 1999 Requests Waiver of 520 Hours (13 Wks) Required Parallel Watchstanding in Control Room Prior to License Application Submittal for W Conley ML17355A2921999-04-22022 April 1999 Forwards Rev 35 to Turkey Point EP & Revised EPIP 0-EPIP-20101, Duties of EC, Per Requirements of 10CFR50, App E & 10CFR50.54(q).Summary of Changes,Encl.Implementation Date for Both Documents Was 990330 ML17355A2891999-04-0909 April 1999 Forwards Relief Request 20, Exempt Tendon Insp, Requesting Relief from ASME Section XI Code,1992 Edition,Paragraph IWL-2521.1(c) Which Requires That Each Exempted Tendon Be Examined IAW IWL-2524 & IWL-2525.Approval Needed by 991001 ML17355A2861999-04-0505 April 1999 Forwards COLR for Turkey Point Unit 4,Cycle 18,IAW TS 6.9.1.7 ML17336A0681999-04-0101 April 1999 Expresses Support for FP&L Request for Waiver of Applicable Review Fees Upon FP&L Submittal of an Application for License Renewal for Turkey Point Units 3 & 4 ML17355A2751999-03-25025 March 1999 Informs NRC & Staff of Fp&Ls Plans to Submit License Renewal Application for Turkey Point Units 3 & 4 by End of Dec 2000 ML17355A2641999-03-19019 March 1999 Requests Changes to FPL Official Service List for Turkey Point,Units 3 & 4.Add s Franzone & Remove G Hollinger from All Correspondence ML17355A2651999-03-19019 March 1999 Forwards Annual Radioactive Effluent Release Rept for Jan-Dec 1998 & Rev 7 to ODCM for Gaseous & Liquid Effluents from Turkey Point,Units 3 & 4. ML17355A2621999-03-16016 March 1999 Forwards Special Rept as Result of Turkey Point Unit 3 End-of-Cycle 16 ISI of SG Tubes.Rept Summarizes Results of SG Tube ISI ML17355A2631999-03-12012 March 1999 Forwards FPL Decommissioning Fund Status Repts for St Lucie, Units 1 & 2 & Turkey Point,Units 3 & 4.Rept for St Lucie, Unit 2 Provides Status of Decommissioning Funds for All Three Owners of That Unit ML20204C6991999-03-10010 March 1999 Requests Amend to Turkey Point PSP to Modify Requirement to Post Security Officers to Provide Continuous Observation of Entire PA Perimeter in Event of Security Computer Failure. Change to Security Force Staffing Level Also Requested ML17355A2451999-03-0909 March 1999 Submits Info on FPL Current Levels of Nuclear Property Insurance,Per 10CFR50.54(w)(3) ML17355A2501999-03-0808 March 1999 Informs That Licensee Reviewed NRC 990228 Ltr Issuing Exemption Requested Re Fire Rating of Raceway Fire Barriers in Open Turbine Bldg.Tabulated Summary of Util Comments & Marked Copy of NRC Ltr & SER Encl ML17355A2441999-03-0101 March 1999 Provides Update to Util Written Notices,Dtd 961120 & 970627 of Claim Involving Alleged Bodily Injury Arising Out of or in Connection with Use of Radioactive Matl at Units 3 & 4 ML17355A2431999-02-25025 February 1999 Informs That FPL Does Not Have Any Candidates from Turkey Point Scheduled to Participate in 990407,Generic Fundamentals Examination (GFE) ML17355A2341999-02-18018 February 1999 Provides Response to RAI Re GL 97-01, Degradation of Crdm/ CEDM Nozzle & Other Vessel Closure Head Penetrations. L-99-042, Forwards Rev 13 to Turkey Point Physical Security Plan,Per 10CFR50.54(p).Util Determined That Rev Does Not Decrease Safeguards Effectiveness of Plan.Encl Withheld,Per 10CFR2.790(a)(3)1999-02-18018 February 1999 Forwards Rev 13 to Turkey Point Physical Security Plan,Per 10CFR50.54(p).Util Determined That Rev Does Not Decrease Safeguards Effectiveness of Plan.Encl Withheld,Per 10CFR2.790(a)(3) ML17355A2361999-02-18018 February 1999 Forwards Tabulation of 1998 Occupational Exposure Data for Turkey Point,Units 3 & 4,per TS 6.9.1.2.a.Reactor Coolant Specific Activity Limits of 100/E-bar Mci Per Gram of Gross Radioactivity Were Not Exceeded During 1998 ML17355A2301999-02-18018 February 1999 Forwards Semiannual Fitness for Duty Performance Data for Period of 980701-981231 for Turkey Point Units 3 & 4 ML17355A2231999-02-0808 February 1999 Informs That Util Will Comply with Commitment with Respect to Units 3 & 4,in Response to Ja Zwolinski 990129 Ltr.Util Also Agrees to Incorporate Commitment Into Confirmatory Order Modifying License Effective Immediately Upon Issuance ML17355A2031999-01-29029 January 1999 Forwards Rev 3 to Turkey Point Nuclear Plant Recovery Plan. Rev Does Not Decrease Effectiveness of Plan ML17355A2171999-01-20020 January 1999 Forwards Listed ISI Repts for Turkey Point Unit 3,in Accordance with Provisions of ASME Code,Section XI ML17354B2241999-01-0606 January 1999 Forwards Annual 10CFR50.46 Rept Re Changes To,Or Errors Discovered in ECCS Evaluation Models,Or in Application of Such Models That Effect Peak Clad Temp Calculation ML17354B2081998-12-15015 December 1998 Informs That Fpl,In Cooperation with State of Fl & County Emergency Response Agencies,Will Conduct Exercise of Turkey Point Radiological Emergency Plan on 990210.Scenario Package Forwarded to Emergency Preparedness Section Chief,Region II ML17354B2091998-12-15015 December 1998 Forwards Price Anderson Guarantees Annual Financial Rept,Per 10CFR140.21.Exhibit 1 Submitted to Satisfy Annual Financial Reporting Requirement of 10CFR50.71(b) ML17354B2061998-12-0909 December 1998 Informs That Request for Exemption Specified in Section II.B.3 Will Not Be Needed Re Fire Rating of Raceway Fire Barriers in Open Turbine Bldg ML17354B1981998-11-25025 November 1998 Forwards Scope & Objective for 1999 Plant Annual Emergency Preparedness Exercise.Objectives Developed in Conjunction with State & Local Govts.Exercise Scheduled for 990210 1999-09-09
[Table view] |
Text
Westinghouse Energy Systems Box 355 Pittsburgh Pennsylvania 15230 0355 Electric Corporation April 2, 1991 CAW-90-105 Document Control Desk US Nuclear Regulatory Commission Washington, DC 20555 Attention: Dr. Thomas Hurley, Director APPLICATION- FOR. WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
WCAP-12374 "Eagle 21 Micro Processor Based Process Protection System for Turkey Point Units 3 and 4 (Proprietary)
Dear Dr. Hurley:
~
The-proprietary information for which withholding is being requested in the
~
enclosed letter by Florida Power and Light- Company is further identi.fied in Affidavit CAW-90-105 .signed by the owner of the proprietary information, Westinghouse Electric -Corporation. 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 2.790 of the Commission's regulations.
Accordingly, this letter authorizes the utilization of the accompanying
,Affidavit by Florida Power and Light Company.
Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-90-105, and should be addressed to the undersigned.
Very truly yours, R. P. DiPiazza, Manager Enclosures Operating Plant Licensing Support cc: H. P. Siemien, Esq.
Office of"the General Counsel, NRC 9104160423 910405 PDR ADOCK 05000250 P PDR
4 t Pf 0
l' 1 pp
(
fl 7 ~P
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 2.790 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 (g) contained within parentheses located as a superscript immediately following-the brackets'nclosing 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)(g) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.790(b)(1).
i
~ j'a,r pl<;,',p~,'
tlat il
Copyright Notice
- -The,reports='transmitted.,herewith each..bear-a..Westinghouse;copyright notice.
-"'"'he" 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 2.790 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection not withstanding. 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,
~ ~
'nsufficient for this purpose. 'The NRC is not authorized to make copies for
~
~
~ ~
the personal use of members of the public who make use of the NRC public
"- document rooms.- . Copies:made by:the=NRC -must-:include the -copyright-.notice:.in'-
~
all instances and the proprietary notice if the original was identified as proprietary.
P 0
CAW-90-105 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF ALLEGHENY:
Before me, the undersigned authority, personally appeared
-Ronald,P..DiPiazza, who, being by meduly sworn according to law,
~
deposes -and says that: he is authorized"to"execute this Affidavit on
~
behalf of Westinghouse Electric Corporation (nWestinghouse") and that
~ ~
the averments of. fact set forth in this Affidavit are true and correct
~
-to the'best of his knowledge, information, and belief:
Ronald P. DiPiazza, Manager Operating Plant Licensing Support Sworn to and subscribed before me this 2>~ day of , 1991.
Notary Public NOTARIALSEAL LORRAINE M. PIPLICA, NOTARY PUBLIC MON ROEVILLE GORO, ALLEGHENYCOUNTY MYCOMMISSION EXPIRES DEC. f4, 1991 Member, Pennsyfvarr'a Association of Notaries
d II I" ~~
e
CAW-90-105 (1) I am Hanager, Operating Plant Licensing Support, in the Nuclear and Advanced Technology Division, of the Westinghouse Electric Corporation 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 rulemaking proceedings, and am authorized to apply for its withhol.ding on behalf of the
=-'~'. :.~':-":,~.<>Westinghouse Energy -Systems Business Unit.
~
(2) I am making this Affidavit in conformance with the provisions of 10CFR
=. -, Section .2.790,.of. the Commission's .regulations and in conjunction .with the
'Westinghouse"application -for=withholding accompanying this.Affidavi.t;- =.-=--
(3) I have personal knowledge .of the- criteria and procedures:utilized -by the .
=Westinghouse"Energy Systems Business Unit 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 2.790 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.
~4 K
'I
~ ~ ~ ~ ~ ><~AFk
% ~ I, tW p<
0
)4, L ! r gfa
e CAW-90-105 (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
. - -. >> .-'-: *- "--- ~<<~'"pol.icy"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 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.
I L 0
t e>
<p q a k
k t ~ '
a "Q,' jet M< av I qS"
%i .'r E k
\
- a. p S+ =C r'.r K4 4>>
4 t, 7 a~
CAW-90-105 (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.
(g) It is not the property of Westinghouse, but must be treated as
, proprietary-. by Westinghouse according to agreements with the owner.
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.,
1 e
h ~ ~
1
CAW-90-105 (b) It is inFormation which 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.
(e) Unrestricted disclosure would jeopardize the position of
. " "...prominence of'estinghouse in the world ma'rket, 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.
'1
+s s A ~ <
P'
CAW-90-105 (iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10CFR Section 2.790, 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 "Eagle-21 "Micro-Processor-Based: Process'rotection System", 'WCAP-12734 ':
(Proprietary), for Turkey Point Units 3 and 4, being transmitted by the Florida Power-and*-Light-Company-(FPL) -letter -and Application for Withholding Proprietary Information from-Public Disclosure, J. Goldberg, FPL, to Document Control Desk, to the Attention of Dr. Thomas Murley, Director, Office of NRC. The
,;proprietary information as submitted for use by Florida Power and Light Company for the Turkey Point Units 3 and 4 is expected to be applicable in other licensee submittals in response to certain NRC requirements for justification of the Eagle 21 Process Protection System.
1 4 ~
o, v'
)*c S, a
'I a
I fE ~ I l l'
e CAW-90-105 This information is part or that which will enable Westinghouse to:
(a) Provide documentation which summarizes the EAGLE 21 Process Protection System design features, hardware architecture, siftware development and software implementation.
" " "'('b):;, Provide documentation which describes the EAGLE 21 Process Protection System Equipment gualification Program.
-'--(c) -Provide -documentation which describes the EAGLE 21 Process Protection -System Design, Verification and Validation Program'.
-. "-(d)':.Provide documentation which describes how the EAGLE 21 Process Protection System complies with applicable regulatory criteria.
(e) Assist a customer to obtain NRC approval for operation of the EAGLE 21 Process Protection System.
Further this information"has substantial commercial .value as follows:
(a) Westinghouse plans to sell the use of similar information to its customers for purposes of justifying relaxation of similar technical specification surveillance requirements.
(b) Westinghouse can sell support and defense of this methodology to its customers in the licensing process.
t 0 "~ p -+ g~QQf$ '
'l t'
CAW-90-105 Public disclosure of this'roprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar analytical documentation 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 for developing testing and analytical methods and performing tests.
Further the deponent sayeth not.
+ps Q~
N V r 0