ML20121A214

Westinghouse, Transmittal of Amendment Request for CoC 72-1026

ML20121A214
Person / Time
Site:	Westinghouse, 07201026
Issue date:	04/30/2020
From:	Quinn R Westinghouse, Westinghouse
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
Shared Package
ML20121A196	List: ML20121A214
References
LTR-NRC-20-35
Download: ML20121A214 (4)

Text

Westinghouse Non-Proprietary Class 3 Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: 1-724-584-4696 Document Control Desk 11555 Rockville Pike e-mail: quinnrd@westinghouse.com Rockville, MD 20852 LTR-NRC-20-35 April 30, 2020

Subject:

Transmittal of Amendment Request for CoC 72-1026 Enclosed are the proprietary and non-proprietary versions of the SENTRY' Dry Storage System Safety Analysis Report. Westinghouse is requesting the NRC review and approve the proposed amendment to Certificate of Conformance (CoC) 72-1026 adding the SENTRY Dry Storage System.

This submittal contains proprietary information of Westinghouse Electric Company LLC (Westinghouse). In conformance with the requirements of 10 CFR Section 2.390, as amended, of the Nuclear Regulatory Commissions (Commissions) regulations, we are enclosing with this submittal an Affidavit. The Affidavit sets forth the basis on which the information identified as proprietary may be withheld from public disclosure by the Commission.

Correspondence with respect to the proprietary aspects of this submittal or the Westinghouse Affidavit should reference AW-20-5042 and should be addressed to Camille T. Zozula, Manager, Infrastructure & Facilities Licensing, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 1, Suite 165, Cranberry Township, PA 16066.

Robert D. Quinn, Director Nuclear Material Management cc: John McKirgan (NRC)

Niskha Devaser (NRC)

Enclosures:

1. Affidavit AW-20-5042

2. WSNF-230 (WDD-LI-00086-GEN) Revision 0, SENTRY' Dry Storage System Safety Analysis Report (SAR) - Proprietary Version

3. WSNF-230 (WDD-LI-00088-GEN) Revision 0, SENTRY' Dry Storage System Safety Analysis Report (SAR) - Non-Proprietary Version.

© 2020 Westinghouse Electric Company LLC. All Rights Reserved.

Westinghouse Non-Proprietary Class 3 AW-20-5042 Page 1 of 3 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

COUNTY OF BUTLER:

(1) I, Zachary S. Harper, have been specifically delegated and authorized to apply for withholding and execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse).

(2) I am requesting the proprietary portions of WDD-LI-00086-GEN Revision 0 be withheld from public disclosure under 10 CFR 2.390.

(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 10 CFR 2.390, 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 and is not customarily disclosed to the public.

(ii) Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications 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.

Westinghouse Non-Proprietary Class 3 AW-20-5042 Page 2 of 3 AFFIDAVIT (5) Westinghouse has policies in place to identify proprietary information. 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).

(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.

(6) The attached documents are bracketed and marked to indicate the bases for withholding. The justification for withholding 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

Westinghouse Non-Proprietary Class 3 AW-20-5042 Page 3 of 3 AFFIDAVIT refer to the types of infom1ation Westinghouse customarily holds in confidence identified in Sections (5)(a) through (t) of this Affidavit.

I declare that the avem1ents of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief.

I declare under penalty of perjury that the foregoing is true and correct.

Zachary S. Harper, Manager Licensing Engineering