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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20211D7501999-08-23023 August 1999 Responds to NRC Re Violations Noted in OI Rept 3-98-043 & EA 99-183.Corrective Actions:Oversight of Training Program & Contractor Policies That Implement Parts of Security Program Have Been Increased by Addl Position ML20205M9421999-04-13013 April 1999 Forwards Emergency Response Data System Implementation Documents.Data Point Library Updates for Kewaunee (271), San Onofre (272) & Clinton (273) Encl.Also Encl Plant Attribute Library Update for Grand Gulf (274).Without Encls ML17230A3661999-03-18018 March 1999 Forwards Listed Nelia Insurance Policy Endorsements for Kewaunee Nuclear Power Plant,Per Requirements of 10CFR140.15 ML20203F2541999-02-10010 February 1999 Informs That Beginning 990216,DE Hills Will Be Chief of Operations Branch Which Includes Operator Licensing Function ML20155F7951998-11-0303 November 1998 Second Partial Response to FOIA Request for Documents. Records Subj to Request Encl & Identified in App C ML20154F1481998-10-0202 October 1998 Forwards Insp Rept 50-305/98-15 on 980831-0904.No Violations Noted.Insp Exam of Activities Conducted Under License Re Physical Security & to Compliance with Commission Rules & Regulations & with Conditions of License ML20237E0881998-08-24024 August 1998 Clarifies Info Provided Re Containment Ventilation Sys & Use of Mixing Factor of 0.5,in Response to NRC Request Made During Telcon ML20237A2301998-08-0707 August 1998 Forwards Original & Three Copies of Rev 11 to Knpp Security Manual.Screening Criteria Form for Each Change W/Description & Criteria of Review Has Been Included as Attachment A. Reissued Security Manual Included in Attachment B.W/O Encls ML20236R9051998-07-21021 July 1998 Informs That Document Entitled, WCAP-14677,Rev 1 F* & Elevated F* Tube Alternate Repair Criteria for Tubes W/Degradation within Tubesheet Region of Kewaunee Sgs, Will Be Withheld from Public Disclosure,Per 10CFR2.790 ML20249B7471998-06-23023 June 1998 Forwards RAI Re 980601 Proposed Amend to Revise F* & Ef* Criteria for SG Tubes in Kewaunee Tss.Proposed Amend Would Revise Existing F* & Ef* Distances in TS 4.2.b to Reflect Changes to Primary to Secondary Differential Pressure ML20249A8751998-06-16016 June 1998 Forwards Request for Addl Info Re Proposed Amend to Redefine Parent Tube Pressure Boundary for Westinghouse Mechanical Hybrid Expansion Joint SG Tube Sleeves,Submitted by Util ML20248M2521998-06-0909 June 1998 Forwards Assessment of Kewannee Cycle 22 Alternate Repair Criteria 90 Day Rept,For Info ML20217F3401998-04-23023 April 1998 Forwards Annual Environ Monitoring Rept Jan-Dec 1997, Per TS 6.9.b.1.Results of 1997 Land Use Census,Iaw Plant ODCM, Section 3/4.7.1,included in Rept ML20216B3281998-04-0707 April 1998 Discusses Amend 132 to License DPR-43.Requested Revised Analysis Reflecting Higher Source Term Encl.Results of Analysis Conclude That Potential Thyroid Doses to Public Continue to Be Less than Guideline Values of 10CFR100 ML20217J2131998-04-0202 April 1998 Forwards Copy of Each Revised Forms 398,personal Qualifications Statement & 396,certification of Medical Exam by Facility Licensee.Due to Error on Instructions for Form 398,addendum for Completing Form Are Provided ML20217H4031998-03-27027 March 1998 Informs That NRC Staff Has Initiated Variety of Activities Re Mgt of Licensing Basis Info as Result of Problems Encountered at Millstone & Maine Yankee Facilities ML20217G1461998-03-25025 March 1998 Responds to NRC Re Violations Noted in Insp Rept 50-305/98-03 on 980128-0203.Corrective Actions:Controlling & Properly Securing SGI ML20203C8481997-12-10010 December 1997 Forwards Emergency Response Data Sys Implementation Documents for Plants.W/O Encl ML20212H0121997-11-0404 November 1997 Forwards Insp Rept 50-305/97-14 on 970915-19.No Violations Noted.Rept Identifies Areas Examined within Security Program ML20217P3511997-08-26026 August 1997 Ack Receipt of & Check for $50,000 in Payment for Civil Penalty Proposed by NRC in . Corrective Actions Will Be Examined During Future Insp ML20217J9641997-08-11011 August 1997 Responds to NRC Re Violations Noted in Insp Rept 50-305/97-02 on 970106-31.Corrective Actions:Will Revise IST Procedures to Use More Accurate Instrumentation Satisfying Requirements & to Include Acceptance Criteria ML20140E8861997-06-0707 June 1997 Forwards Amend 133 to License DPR-43 & Safety Evaluation. Amend Establishes New Design Basic Flow Rate for AFW Pumps Consistent W/Assumptions Used in Reanalysis of Limiting Design Basis Event for AFW Sys ML20140F2171997-04-30030 April 1997 Final Response to FOIA Requests for Documents.Records in App B Encl & Will Be Available in PDR IA-97-130, Final Response to FOIA Requests for Documents.Records in App B Encl & Will Be Available in PDR1997-04-30030 April 1997 Final Response to FOIA Requests for Documents.Records in App B Encl & Will Be Available in PDR ML20140F2211997-04-0404 April 1997 FOIA Request for Documents Re Recently Issued TIA for Plant Concerning Safety Question on Auxiliary Feedwater Sys ML20137A2111997-03-14014 March 1997 Transmits Info Pertaining to NRC Staff Review of Weld Defects in CE Designed SG Tube Sleeves ML20134Q0981997-02-21021 February 1997 Ninth Partial Response to FOIA Request for Documents. Forwards Documents Listed in App P.App Q Documents Partially Withheld (Ref FOIA Exemption 6).Documents Also Available in PDR ML20134Q1251997-02-20020 February 1997 Forwards Original & Three Copies of Rev 10 to Knpp Security Manual.Manual Is Being Changed to Incorporate Use of Vehicle Barrier Sys,Per 10CFR73.55 & 73.1(a).Encl Withheld ML20133E7031997-01-0606 January 1997 Forwards Insp Rept 50-305/96-12 on 961118-27 & Notice of Violation ML20133G2291997-01-0606 January 1997 Ltr Contract:Task Order 115, Kewaunee Safety Sys Operational Performance Insp, Under Contract NRC-03-93-026 ML20129K1131996-11-0505 November 1996 Forwards Copy of Master Bwr/Pwr Gfes Exam W/Answer Key for Info.W/O Encl ML20129J2641996-10-29029 October 1996 Ack Receipt of 960613 & 1024 10CFR50.54(a) Submittals Re Changes to Quality Assurance Program Description.Based on Review,Nrc Concludes That Revision Continues to Meet Requirements of 10CFR50,App B & Acceptable ML18065B0081996-10-14014 October 1996 Informs That Overheads Will Be Presented by Licensee at 961016 Meeting at NRC Headquarters in White Flint.Encl Withheld ML20117P6861996-09-20020 September 1996 Forwards Rev 9 to Security Manual.Encl Withheld ML20117L7171996-09-0505 September 1996 Forwards Proposed Tech Specs Re Amend for Use of Westinghouse Laser Welded Steam Generator Tube Sleeves,Per Discussion W/Nrc ML20100M7451996-02-29029 February 1996 Provides Revised Description of Proposed Vehicle Control Measures.Encl Withheld ML20217H4281996-01-24024 January 1996 Discusses Review of Nuclear Energy Inst Guidance Document, Guideline for Managing NRC Commitments, Rev 2,dtd 951219 ML20094H8491995-11-0606 November 1995 Forwards Rev 8 to Security Manual.Rev Withheld ML20091P4951995-08-28028 August 1995 Forwards Clarification of Rev 7 to Security Manual.Encl Withheld ML20094D9291995-08-10010 August 1995 Forwards Scenario Package for 951011 Emergency Exercise at Plant,Per from Cj Paperiello ML20087K2451995-08-0202 August 1995 Forwards Revised Description of Proposed Vehicle Control Measures.Primary Change in Design Is Use of Jersey Barriers in Lieu of Combination Cable & Rock Design.Encl Withheld ML20084L1091995-05-30030 May 1995 Forwards Rev 7 of Kewaunee NPP Security Manual.Encl Withheld ML20080N0061995-02-28028 February 1995 Forwards Summary Description of Plant Proposed Vehicle Control Measures & Results of Vehicle Bomb Comparison.Encl Withheld ML20078R3291994-12-19019 December 1994 Discusses Results & Conclusions of Osre Conducted During 940815-18.Weakness Noted as Being Unique & Only Possible During Specific Time Periods ML20072J3401994-08-22022 August 1994 Responds to NRC Re Violations Noted in Insp Rept 50-305/94-09 on 940516-0704.Corrective Actions:Memo,Stating That Turbine Driven AFW Pump Should Be Declared Inoperable Whenever AFW-10A or 10B Closed or Inoperable,Issued ML20070P5811994-03-29029 March 1994 Requests Meeting W/Nrc & Appropriate Members of NRC Dept Re Disposal of high-level Radwaste from NPP ML20059E9511994-01-0707 January 1994 Requests Addl Info Re Graded Approach for GL 89-10, Safety-Related Motor-Operated Valve Testing & Surveillance ML20058E6581993-12-0101 December 1993 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 940209.Informs That Facility Must Submit Ltr Identifying Individuals Who Will Take Exam ML20058A1291993-11-16016 November 1993 Forwards Safeguards Info Referenced in Preliminary Draft Guide Re Proposed Rule for Protection Against Manevolent Use of Vehicles at Nuclear Power Plants.Encl Withheld ML20059D2761993-10-26026 October 1993 Forwards Copy of Master Bwr/Pwr Gfes Exam W/Answer Key.W/O Encl 1999-08-23
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20211D7501999-08-23023 August 1999 Responds to NRC Re Violations Noted in OI Rept 3-98-043 & EA 99-183.Corrective Actions:Oversight of Training Program & Contractor Policies That Implement Parts of Security Program Have Been Increased by Addl Position ML17230A3661999-03-18018 March 1999 Forwards Listed Nelia Insurance Policy Endorsements for Kewaunee Nuclear Power Plant,Per Requirements of 10CFR140.15 ML20237E0881998-08-24024 August 1998 Clarifies Info Provided Re Containment Ventilation Sys & Use of Mixing Factor of 0.5,in Response to NRC Request Made During Telcon ML20237A2301998-08-0707 August 1998 Forwards Original & Three Copies of Rev 11 to Knpp Security Manual.Screening Criteria Form for Each Change W/Description & Criteria of Review Has Been Included as Attachment A. Reissued Security Manual Included in Attachment B.W/O Encls ML20217F3401998-04-23023 April 1998 Forwards Annual Environ Monitoring Rept Jan-Dec 1997, Per TS 6.9.b.1.Results of 1997 Land Use Census,Iaw Plant ODCM, Section 3/4.7.1,included in Rept ML20216B3281998-04-0707 April 1998 Discusses Amend 132 to License DPR-43.Requested Revised Analysis Reflecting Higher Source Term Encl.Results of Analysis Conclude That Potential Thyroid Doses to Public Continue to Be Less than Guideline Values of 10CFR100 ML20217G1461998-03-25025 March 1998 Responds to NRC Re Violations Noted in Insp Rept 50-305/98-03 on 980128-0203.Corrective Actions:Controlling & Properly Securing SGI ML20217J9641997-08-11011 August 1997 Responds to NRC Re Violations Noted in Insp Rept 50-305/97-02 on 970106-31.Corrective Actions:Will Revise IST Procedures to Use More Accurate Instrumentation Satisfying Requirements & to Include Acceptance Criteria ML20140F2211997-04-0404 April 1997 FOIA Request for Documents Re Recently Issued TIA for Plant Concerning Safety Question on Auxiliary Feedwater Sys ML20134Q1251997-02-20020 February 1997 Forwards Original & Three Copies of Rev 10 to Knpp Security Manual.Manual Is Being Changed to Incorporate Use of Vehicle Barrier Sys,Per 10CFR73.55 & 73.1(a).Encl Withheld ML18065B0081996-10-14014 October 1996 Informs That Overheads Will Be Presented by Licensee at 961016 Meeting at NRC Headquarters in White Flint.Encl Withheld ML20117P6861996-09-20020 September 1996 Forwards Rev 9 to Security Manual.Encl Withheld ML20117L7171996-09-0505 September 1996 Forwards Proposed Tech Specs Re Amend for Use of Westinghouse Laser Welded Steam Generator Tube Sleeves,Per Discussion W/Nrc ML20100M7451996-02-29029 February 1996 Provides Revised Description of Proposed Vehicle Control Measures.Encl Withheld ML20094H8491995-11-0606 November 1995 Forwards Rev 8 to Security Manual.Rev Withheld ML20091P4951995-08-28028 August 1995 Forwards Clarification of Rev 7 to Security Manual.Encl Withheld ML20094D9291995-08-10010 August 1995 Forwards Scenario Package for 951011 Emergency Exercise at Plant,Per from Cj Paperiello ML20087K2451995-08-0202 August 1995 Forwards Revised Description of Proposed Vehicle Control Measures.Primary Change in Design Is Use of Jersey Barriers in Lieu of Combination Cable & Rock Design.Encl Withheld ML20084L1091995-05-30030 May 1995 Forwards Rev 7 of Kewaunee NPP Security Manual.Encl Withheld ML20080N0061995-02-28028 February 1995 Forwards Summary Description of Plant Proposed Vehicle Control Measures & Results of Vehicle Bomb Comparison.Encl Withheld ML20078R3291994-12-19019 December 1994 Discusses Results & Conclusions of Osre Conducted During 940815-18.Weakness Noted as Being Unique & Only Possible During Specific Time Periods ML20072J3401994-08-22022 August 1994 Responds to NRC Re Violations Noted in Insp Rept 50-305/94-09 on 940516-0704.Corrective Actions:Memo,Stating That Turbine Driven AFW Pump Should Be Declared Inoperable Whenever AFW-10A or 10B Closed or Inoperable,Issued ML20070P5811994-03-29029 March 1994 Requests Meeting W/Nrc & Appropriate Members of NRC Dept Re Disposal of high-level Radwaste from NPP ML20056C5071993-02-19019 February 1993 FOIA Request for Documents Re Meeting Minutes,Summaries, Transcripts or Other Documents Resulting from NRC Meeting Held 930209 at Region III Ofc in Glen Ellyn,Il to Discuss Kewaunee Engineering Activities & Other Items of Interest ML20128H9271993-02-13013 February 1993 Advises That All Actions Necessary to Ensure Compliance W/ 10CFR50,App E,Section VI Re ERDS Completed.Installation of ERDS Hardware in Technical Support Ctr Complete & Temporary Telephone Line Replaced W/Permanent Line ML20128D2721993-02-0202 February 1993 Provides Listed Submittal Describing Actions Currently Being Performed & Schedule for Completion of Actions Associated W/ Resolution of long-term Recommendation GL-4,per ML20126E7221992-12-28028 December 1992 Forwards Response to NRC Re Weaknesses & Followup Items Noted in Insp Rept 50-305/92-21 of Annual Emergency Plan Exercise.Corrective Actions:More Mgt Involvement Will Be Provided & Emergency Plan Will Be Revised ML20095G9561992-04-27027 April 1992 Forwards Rev 5 to Security Manual,Revised to Reflect Requirements of New Access Authorization Rule.Rev Withheld ML20091M5531992-01-27027 January 1992 Forwards Rev 4 to Security Manual,Reflecting Recent Organizational & Title Changes & Adding Vehicle Insp Portal on North Gate.Rev Withheld ML20086E3411991-11-21021 November 1991 Forwards Response to Security Concern RIII-91-A-0056,per NRC .Investigation Determined That No Violation of Burns fitness-for-duty Program Occurred & That Burns Program Meets NRC Guidance for Overtime ML20079L0391991-10-29029 October 1991 Forwards Rev 3 to Security Manual to Address Issues Identified in NRC .Manual Withheld ML20079K8081991-10-28028 October 1991 Forwards Emergency Response Data Sys Implementation Program Plan.Implementation Program Plan Indicates That Sys May Be Operational as Early as Feb 1992 Provided No Obstacles Encountered During Hardware/Software Implementation ML1116610971991-08-30030 August 1991 Forwards Rev 3 to WCAP-11476, Handbook on Flaw Evaluation Kewaunee,Unit 1 Steam Generators Upper Shell to Cone Weld. Proprietary Suppl 1 to Kewaunee Unit 1 Steam Generator Upper Shell to Cone Welds Steam Generator... Withheld ML20091B6991991-07-25025 July 1991 Forwards Exercise Scenario Manual Minus Inject Messages Addressing Ingestion Pathway Objectives on Day 2 & 3 of 910924 Annual Emergency Exercise at Plant,Per NRC Requesting Advance Submittal of Exercise Objective.W/O Encl ML20073C2761991-04-0505 April 1991 Forwards Rev 2 to Security Manual,Reflecting Expanded Protection Area Boundary.Rev Withheld (Ref 10CFR73.21) ML1116610051990-10-0909 October 1990 Forwards Nonproprietary WCAP-12712 & Proprietary WCAP-12711, Reevaluation of U-Bend Tube Fatigue for Kewaunee Plant Steam Generators, Per NRC Bulletin 88-002 ML1116610071990-09-17017 September 1990 Requests Withholding of Proprietary WCAP-12711, Reevaluation of U-Bend Tube Fatique for Kewaunee Plant Steam Generators. ML1116506681990-08-17017 August 1990 Forwards Pages Inadvertently Deleted from 1990 Rev to Updated FSAR Submitted on 900720 ML20055C9811990-06-29029 June 1990 Forwards Response to Violations Noted in Insp Rept 50-305/90-04.Response Withheld (Ref 10CFR73.21) ML1116609691990-04-11011 April 1990 Requests That WCAP-12558 Kewaunee Steam Generator Tubesheet Crevice Indications Return to Power Rept, Be Withheld (Ref 10CFR2.790) ML1116609671990-04-0606 April 1990 Forwards Nonproprietary WCAP-12559 & Proprietary WCAP-12558, Kewaunees Steam Generator Tubesheet Crevice Indications Return to Power Rept, as Followup to 900328 Meeting. Proprietary Version Withheld (Ref 10CFR2.790) ML20012A4031990-03-0101 March 1990 Informs That Revised Listed Drawings Sent to Region III for Filing ML20006E8641990-02-19019 February 1990 Suppl Response to NRC 890725 Ltr Re Safeguards Info Violation Noted in Insp Rept 50-305/89-09.Corrective Action: Section V of General Employee Training Manual Security Removed ML1116609341990-01-15015 January 1990 Forwards Nonproprietary WCAP-12441 & Proprietary WCAP-12440, Presentation to NRC Re Kewaunee (Wps) SECY-83-472 LOCA Analysis Effort. Wiesemann 891204 Request for Withholding Also Encl.Proprietary Rept Withheld (Ref 10CFR2.790) ML20005D9601989-12-27027 December 1989 Forwards Response to Allegation RIII-A-89-A-0137.Encl Withheld (Ref 10CFR73.21) ML20005D8131989-12-22022 December 1989 Forwards Status & Proposed Schedule for Security Mod Completion.Implementation Schedule for Proposed Mods Extended Until Oct 1990 Due to Several Major Project Increases.Encl Withheld (Ref 10CFR73.21) ML20011D9111989-12-20020 December 1989 Forwards Executed Amend 8 to Indemnity Agreement B-53 ML19332E6091989-12-0404 December 1989 Forwards Rev 1 to Security Manual.Rev Withheld (Ref 10CFR73.21) ML1116609361989-12-0404 December 1989 Submits Application for Withholding of Proprietary WCAP-12440, Presentation to NRC Re Kewaunee (Wps) SECY-83-472 LOCA Analysis Effort, Per 10CFR2.790.Affidavit Supporting Request Encl ML20247J7721989-07-19019 July 1989 Forwards Rept for Unannounced off-hours Drills on 881020 for State of WI,site-specific to Zion,Point Beach,Kewaunee & Prairie Island Nuclear Power Stations.No Deficiencies or Areas Requiring Corrective Actions Noted 1999-08-23
[Table view] Category:VENDOR/MANUFACTURER TO NRC
MONTHYEARML1116610071990-09-17017 September 1990 Requests Withholding of Proprietary WCAP-12711, Reevaluation of U-Bend Tube Fatique for Kewaunee Plant Steam Generators. ML1116609691990-04-11011 April 1990 Requests That WCAP-12558 Kewaunee Steam Generator Tubesheet Crevice Indications Return to Power Rept, Be Withheld (Ref 10CFR2.790) ML1116609361989-12-0404 December 1989 Submits Application for Withholding of Proprietary WCAP-12440, Presentation to NRC Re Kewaunee (Wps) SECY-83-472 LOCA Analysis Effort, Per 10CFR2.790.Affidavit Supporting Request Encl ML20196A8671988-11-14014 November 1988 Requests Withholding of Proprietary Rev 1 to WCAP-11643, Kewaunee Steam Generator Sleeving Rept (Mechanical Sleeves), Per 10CFR2.790 ML20154H0361988-04-27027 April 1988 Requests That Proprietary WCAP-11817, Slide Presentation Matl,Nrc Meeting 880331,Kewaunee Nuclear Power Plant Steam Generator Tube Sleeve Installation, Be Withheld Per 10CFR2.790(b)(1) NRC-88-3329, Forwards Nonproprietary WCAP-11818 & Proprietary WCAP-11817, Slide Presentation Matl,Nrc Meeting 880331,Kewaunee Nuclear Power Plant Steam Generator Tube Sleeve Installation. Proprietary Rept Withheld (Ref 10CFR2.790)1988-04-27027 April 1988 Forwards Nonproprietary WCAP-11818 & Proprietary WCAP-11817, Slide Presentation Matl,Nrc Meeting 880331,Kewaunee Nuclear Power Plant Steam Generator Tube Sleeve Installation. Proprietary Rept Withheld (Ref 10CFR2.790) ML1116511951980-04-11011 April 1980 Forwards Proprietary & Nonproprietary Versions of Structural Analysis of RCS for Postulated LOCA, Preliminary Issue.Applications for Withholding Encl. Proprietary Version Withheld (Ref 10CFR2.790) ML20147D7201978-09-29029 September 1978 Expresses Concern Re Adequate & Reliable Electric Power Supply.Requests to Make Limited Appearance Statement in Renewal Proceedings 1990-09-17
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April 27, 1988-Westinghouse PowerSystems "'3"'"5 Electric Corporation Box 355 PmsDtigh Pennsytvania 15230-0355 AW-88-039 Dr. Thomas'Mur'ey, nirector Office of Nucleas hactor Regulation U.S. Nuclear Regulatory Comission Washington, D.C. 20555 APPLICATION FOR WITHHOLDING PROPRIETARY ,
INFORMATION FROM PUBLIC DISCLOSURE
Subject:
Slide Presentation Material for NRC Meeting - Keuaunee Steam Generator Tube Sleeves (WCAPs 11817 and 11818)
Reference:
Westinghouse Letter to NRC, NS-NRC-88-3329, dated April 27, 1988 .
Dear Dr. Murley:
The application for withholding is submitted by Westinghouse Electric Corporation
("Westinghouse") pursuant to the provisions of paragraph (b) (1) of Section 2.790
- of the Commission's regulations. It contains commercial strategic information l
proprietary to Westinghouse and customarily held in confidence, i The proprietary material for which withholding is being required is of the same i technical type as that proprietary material previously submitted as Affidavit CAW-81-079.
Accordingly, it is respectfully requested that the subject information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10CFR Section 2.790 of the Commission's regulations.
Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, AW-88-039, -
and should be addressed to the undersigned.
Very ruly yours, M
Robert A. Wiesemann, Manager Regulatory & Legislative Affairs Enclosures cc: E. C. Shomaker, Esq. _.
Office of the General Counsel, NRC 7
8805250203 880427 PDR ADOCK 05000305
i PROPRIETARY INFORMATION NOTICE
\ .
TRANS)CTTED HDDiITH ARE PROPRIETARY AND/OR NON-PROPRIETARY YERSIO DOCUMENTS F13RNISHED TO THE NRC IN CONNECTION WITH REQUESTS F PLANT SPECIFIC REVIEW AND APPROVAL.
IN OFDER 70 CONPORM 70 THE REQUIREMENTS & 10CFR2.790 7 THE COMMISS REDULATIONS CONCERNING THE PROTECTION OF PROPRIETARY INFORMATION 70 WE NRC, THE INFORMATION WHICH IS PROPRIETARY IN THE PROPRIETARY VERSIONS IS CONTAINED WITHIN ARACKETS AND WHEE THE PROPRIETARY INFORMATION HA ~
. DEI.ETED IN THE NON-PROPRIETARY VERSIONS ELY THE BRACKETS RDEIN, THE -
HTOPyATION THAT WAS CONTAIhi.3 WITHIN THE BRACKETS IN THE PROPRIETARY VERSIONS HAVING BEDI DEI.ETED. THE JUSTIFICATION FOR CI.AI}ENG THE INFORMATION SO DESIDNATED AS PROPRIETARY IS INDICATE IN BOTH VERSIONS BY MEANS, W L0m CASE LETTERS (a) THROUGH (g) CONTAINED WITHIN PARENTHESES LOCATED AS A SUPERSCRIPT IMMEDIATELY FOLLOWING THE BRACKETS DiCI.CSING EACH ITDi 0F INFORMATIO IDENTIFIED AS PROPRIETARY OR IN THE MARGIN OPPOSITE sum Ih70RMATION.
LCWER CASE LETTERS REFER 70 THE TYPES & INFORMATION WESTINGHOUSEa HOLDS IN CONFIDENCE DENTIFIED IN SECTIONS (4)(11)(a) through (4)(ii)(g) 0F THE AFFIDAVIT ACCOMPANYING THIS HANS.$UTTAL PUR. TANT 1D 10CFR2.790(b)(1) t k
f
(
_ _ _ _ _ _ _ _ _ _ _ _ , . . - - - - - - - - - > - - - - = ~ ~
F CAW-81-79 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF ALLEGHENY:
Before me, the undersigned authority, personally appeared Robert A. Wiesemann, 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 Corporation ("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:
dh o A Robert A. Wiesemann, Manager Regulatory and Legislative Affairs Sworn to and subscribed before me this o day of D w ./w 1981.
o ._ /
s' f$ff(fb i. %Y/ WFY
.- Notary;Public.jf t**,, s
CAW-81-79 (1) I am Manager, Regulatory and Legislative Affairs, in the Nuclear Technology Division, of Westinghouse Electric Corporation and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public dis-closure in connection with nuclear power plant licensing or rule-making proceedings, and am authorized to apply for its withholding on behalf of the Westinghouse Water Reactor Divisions.
(2) I am making this Affidavit in conformance with the provisions of 10CFR Section 2.790 of the Commission's regulations and in con-junction with the Westinghouse application for withholding ac-companying this Affidavit.
(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse Nuclear Energy Systems 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 in-formation 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.
7_.
CAW-81-79 (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 t; asis 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 com-petitive 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 consti-tutes 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.
CAW-81 -79 (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 cap-acities, budget levels, or comercial strategies of Westinghouse, its customers or suppliers.
(e) It reveals aspects of past, present, or future West-inghouse or customer funded development plans and pro-grams of potential comercial value to Westinghouse.
(f) It contains patentable ideas, for which patent pro-tection 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.
I There are sound policy reasons behind the Westinghouse system which include the following:
l (a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its com-petitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.
( - _
CAW-81-79 (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 infonnation.
(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 infor-mation, any one component may be the key to the entire ouzzle, thereby depriving Westinghouse of a competitive advantage.
t (e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition I in those countries.
I i
l (f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.
l l
l I .
I L
CAW-81-79 (iii) The information is being transmitted to the Conmission 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 pre-viously employed in the same ori,ginal 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 "Steam Generator Tube Plugging Margin Analysis" for the Virgil C.
Summer Nuclear Power Plant Unit No.1. WCAP-9912, Revi-sion 2 (Proprietary) being transmitted by South Carolina Electric and Gas Company letter Application for Withholding Proprietary Information from Public Disclosure, Nichols to Denton, November 1981. The proprietary information as sub-mitted for South Carolina . Electric and Gas Company, Virgil C.
Sunner Nuclear Station use is expected to be applicable in other licensee and applicant submittals in response to cer-tain NRC requirements for justification of the steam l
generator tube plugging margin.
l This information is part of that which will enable Westing-l housc to:
(a) Provide documentation of the analyses, method and test- ?
Ing for determining plugging margin.
l
7 CAW-81-79 (b) Establish the minimum wall thickness in compliance with Regulatory Guide 1.121.
(c) Establish the stress limits versus thinning of the remaining tube wa.
(d) Establish the maximum allowable leakage in support of the leak-before-break criteria.
(e) Assist the customer to obtain NRC approval.
Further this information has substantial commercial value J
as follows:
(a) Westinghouse plans to sell similar information to its customers for purposes of meeting NRC requirements for licensing documentation.
(b) Westinghouse can sell support and defense of the tech-nology to its customers in the licensing process.
Public disclosure of this information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to pro-vide similar analytical documentation and licensing defanse services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC require-ments for licensing documentation without purchasing the right to use the information.
a
~
f~ .
CAW-81-79 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 system design software development.
Further the deponent sayeth not.
9 o