ML20059C178

Forwards Proprietary TR-90-0025 W01, Core Thermal-Hydraulic Analysis Methodology for Wolf Creek Generating Station, for Review & Approval by 920101.Rept Withheld (Ref 10CFR2.790)

ML20059C178
Person / Time
Site:	Wolf Creek
Issue date:	08/21/1990
From:	Rhodes F WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19307A514	List: ML20059C178
References
ET-90-0140, ET-90-140, NUDOCS 9008310093
Download: ML20059C178 (4)

Text

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. . ., , o W44.F CREEK NUCLEAR OPERATING CORPORATION Forrest T. Rhodes ve. Pr.me-a ensmeerms & 1perWeel homees August 21, 1990 ET 90-0140 U. S. Nuclear Regulatory Consalesion ATTNs Document Control Desk Mail Station P1-137 Washington, D. C. 20555

Subject:

Core Thermal-Hydraulic Analysie Methodology for the Wolf Creek Generating Station The purpose of this letter is to sutuait Wolf Creek Nuclear Operating Corporation's (WCNOC) Core Thermal-Hydraulic Analysis Hethodology topical report for Nuclear Regulatory Commissicn (NRC) review and approval. This submittal was discussed at a meeting between the NRC staff and WCNOC which took place on May 18, 1989. The topical report is being provided as an attachment to this letter. It is requested that NRC complete its review and approve this submittal by January 1, 1992.

In accordanne with the provisions of 10 CFR 2.790, it is respectfully requested that the attachment to this letter be regarded as proprietary information and be withheld from public disclosure on the grounds that it contains trade secrets and confidential coamercial information. The affidavit, which accompanies this letter, sets forth the basis by which this information should be withheld from public disclosure by the Consaission and addressees.

As discussed Nith Mr. D. V. Pickett, NRC, the topical report in its entirety is to be regarded as proprietary information until the NRC review is complete, at which time VCNOC will indicate the specific portions within the report which are proprietary.

Very truly yours, 9008310093 900021 / -

PDR P

ADOCK 050004G2 PNU /

Forrest T. Rhodes Vice President 3 ,. Engineering & Technical Services

%dv FTR/aem Attachment cca R. D. Martin (NRC), w/a D. V. Pickett (NRC), w/a M. E. Skow (NRC). w/a J. S. Wiebe (NRC), w/a P.O. Som 411 / Burimpton, KS 9883s 1 Phone: (316) 364-8s31 An Eguel opporturey Employer M+CVET

n AITIMY1T STATE OF EANSAs )

) ss COUNTY OF COFFEY )

Before me. the undersigned authority, persoi illy r, feared Forrest T. Rhodes, who, being by me duly sworn according to las poses and says:

(1) I am Vice President Engineering and Techuical Services for the Wolf Creek. Nuclear Operating Corporation (WCNOC), and I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in WCHOC's submittal of Core Thermal-Hydraulic Analysie Methodology topical repert, and am authorized to apply for its withholding on behalf of WCN00.

(2) I am making this Affidavit in conformance- with the provisions of 10 CFR Section 2.790 of the Commission's regulations and in conjunction with WCN00 letter ET 90-0140 Core Thermal-Hydraulic Analysis Methodology topical report for submittal accompanying this affidavit.

(3) I have personal knowledge of the criteria and procedures utilized by WCN00 in designating information as a trade secret, privileged or as confidential commercial.

(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.

(1) The information sought to be withheld from public disclosure has been held in confidence by WCNOC. The information is of a type customarily held in confidence by other organizations and not customarily disclosed to the public.

Based on a review of 10 CFR 2.790, the information to be held in confidence falls in one or more of several types, the release of which might result in thu loss of an existing or potential competitive advantage, as follows:

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(a) The information reveals the distinguishing aspects of a process or a method, where prevention of its use by any other.

company without license from VCNOC constitutes a competitive economic advantage over other campanits.

(b) It- consists of supporting data relative to a process or a method, the application of which secures a. competitive advantage.

(c) Its use by another company would reduce its expenditure of resources or improve its competitive position in the design,.

assurance of quality, or licensing a similar product.

(d) It is not the property of WCNOC, but must be treated as proprietary by WCNOC according to agreements with the owners of the information.

! There are sound reasons behind the WCNOC position which include the followings (a) It is information which is marketable in many wayw.

.(b) Use by other companies .would put WCN00 at a competitive disadvantage by reducing their expenditure of resources at our expense.

(c) Each component of proprietary information pertinent to a.

particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire L components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving WCNOC'of a competitive advantage.

(ii) The information is being transmitted to the Commission in L confidence and, under the provisions of 10 CFR Section 2.790, it is to be received in confidence by the Commission.

(iii) The.information sought to be protected is not available in public sources to the best of our knowledge and belief.-

p (iv) The proprietary information sought to be withheld 1- this >

submittal la the Core Thermal-Hydraulic Analysis Methodology l topical report, dated July, 1990. -

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the subject information could only be duplicated by competitors if they were to invest time and effort equivalent to that invested by ,

WCNOC provided they have the requisite talent and experience.

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Public disclosure of this information is likely to cause substantial harm to the competitive position of WCNOC because it

. would simplify -design and evaluation tasks without requiring a consnensurate investment of time and effort.

($) The above statements are true and correct to the best of my knowledet, information and belief.

M Forrest T. Rhodes Vice President Engineering & Technical Services SUBSCRIBED and sworn to before me this N () day of 1990.

...... %4a Notary Public LLA~

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