CNL-18-103, Topical Report TVA-NPG-AWA16, TVA Overall Basin Probable Maximum Precipitation and Local Intense Precipitation Analysis, Calculation CDQ0000002016000041,.

Topical Report TVA-NPG-AWA16, TVA Overall Basin Probable Maximum Precipitation and Local Intense Precipitation Analysis, Calculation CDQ0000002016000041,.

ML18262A091
Person / Time
Site:	Browns Ferry, Watts Bar, Sequoyah
Issue date:	09/06/2018
From:	Henderson E Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CNL-18-103 TVA-NPG-AWA16, Rev 1
Download: ML18262A091 (7)

Text

Proprietary Information Withhold from Public Disclosure Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosure 1, Data Set #1 - Dewpoint Climatology IIID Tennessee Valley Authority , 11 01 Market Street, Chattanooga , Tennessee 37402 CNL-18-103 September 6, 2018 10 CFR 50.4 ATTN : Document Control Desk U.S. Nuclear Regulatory Commission Washington , D.C. 20555-0001 Browns Ferry Nuclear Plant, Units 1, 2, and 3 Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259, 50-260, and 50-296 Sequoyah Nuclear Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-77 and DPR-79 NRC Docket Nos. 50-327 and 50-328 Watts Bar Nuclear Plant, Units 1 and 2 Facility Operating License Nos. NPF-90 and NPF-96 NRC Docket Nos. 50-390 and 50-391

Subject:

Topical Report TVA-NPG-AWA16, "TVA Overall Basin Probable Maximum Precipitation and Local Intense Precipitation Analysis, Calculation CDQ0000002016000041," Revision 1, Supplemental Information

Reference:

1. TVA Letter to NRC, "Request for Review and Approval of Topical Report TVA-NPG-AWA16, 'TVA Overall Basin Probable Maximum Precipitation and Local Intense Precipitation Analysis , Calculation CDQ0000002016000041 ', Revision 1," dated June 22, 2018 (ML18192A510)

In the Reference letter dated June 22, 2018, Tennessee Valley Authority (TVA) submitted Topical Report TVA-NPG-AWA16, "TVA Overall Basin Probable Maximum Precipitation and Local Intense Precipitation Analysis, Calculation CDQ0000002016000041, " Revision 1, for review and approval. Approval of this Topical Report was requested to support Probable Maximum Flood calculations associated with planned License Amendment Requests for Sequoyah Nuclear Plant (SQN) , Units 1 and 2, and Watts Bar Nuclear Plant (WBN) ,

Units 1 and 2, and a potential License Amendment Request for Browns Ferry Nuclear Plant, Units 1, 2, and 3.

The purpose of th is letter is to provide supplemental information in support of the review of Topical Report TVA-NPG-AWA 16, Revision 1. Specifically, several data sets that were used in the development of Topica l Report TVA-NPG-AWA 16, Revision 1, are provided in Enclosure 1.

U.S. Nuclear Regulatory Commission CNL-18-103 Page 2 September 6, 2018 Applied Weather Associates (AWA) considers portions of the data sets in Enclosure 1 (Enclosure 1, Data Set #1 - Dewpoint Climatology) to be proprietary and therefore exempt from public disclosure pursuant to 10 CFR 2.390. An affidavit for withholding information, executed by AWA, is provided in Enclosure 2. Therefore, on behalf of AWA, TVA requests that , Data Set #1 - Dewpoint Climatology, be withheld from public disclosure in accordance with the AWA affidavit and the provisions of 10 CFR 2.390.

There are no regulatory commitments associated with this submittal. Please address any questions regarding this request to Russell Thompson at 423-751-2567.

Respectfully, E. K. Henderson Director, Nuclear Regulatory Affairs

Enclosures:

1. TVA-NPG-AWA16, "TVA Overall Basin Probable Maximum Precipitation and Local Intense Precipitation Analysis, Calculation CDQ0000002016000041," Revision 1, Data Sets

2. Affidavit - Applied Weather Associates cc (w/o Enclosures):

NRC Regional Administrator - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant NRR Project Manager - Browns Ferry Nuclear Plant NRC Senior Resident Inspector - Sequoyah Nuclear Plant NRR Project Manager - Sequoyah Nuclear Plant NRC Senior Resident Inspector - Watts Bar Nuclear Plant NRR Project Manager - Watts Bar Nuclear Plant

Enclosure 2 Affidavit - Applied Weather Associates

AFFIDAVIT STATE OF COLORADO )

) ss.

COUNTY OF EL PASO )

1. My nam~ .is William D. Kappel. I am President and Chief Meteorologist, for Appljed Weather Associates and as such I am authorized to ex-acute this Affidavit.

2. I am familiar with the criteria applied by Applied Weather Associates to determine whether certain Applied Weather Associates information is proprietary. I am familiar with the policies established by Applied Weather Associates to ensure the proper application of these criteria.

3. I am familiar with the Applied Weather Associates information contained in the report "TVA Overall Basin Probable Maximum Precipitation and Local Intense Precipitation_ Analysis" dated June 2018 and referred to herein-as "Document." Information regarding the SPAS Hourly Rainfall ASCII Grids and dew point climatology ASCII grids provide~ as electronic files to supplement this Document has been classified by Applied Weather Associates as proprietary in accordance with the policies established by Applied Weather Associates for the control and protection of proprietary and confidential information.

4. This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by Applied Weather Associates and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.

5. This Document has been made available to the U.S.- Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure. The request for withholding of proprietary information is made in accordance with 1o CFR 2.390. The information for which withholding from disclosure is

requested qualifies under 10 CFR 2.390(a){4) "Trade secrets and commercial or financial information."

6. The following criteria are customarily applied by Applied Weather Associates to determine whether information should be classified as proprietary:

(a) The information reveals details of Applied Weather Associates' research and development processes or their results.

(b) Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.

(c) The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for Framatome.

(d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for Applied Weather Associates in product optimization or marketability.

(e) The information is vital to a competitive advantage held by Framatome, would be helpful to competitors to Framatome, and would likely cause substantial harm to the competitive position of Applied Weather Associates.

The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above.

7. In accordance with Applied Weather Associates' policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside Applied Weather Associates only as required and under suitable agreement providing for nondisclosure and limited use of the information.

8. Applied Weather Associates policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.

7

9. The foregoing statements are true and correct to the best of my knowledge, information, and belief.

SUBSCRIBED before me this_ la_

day of ~\) ~ , 2018.

JORDYN GILLILAND NOTARY PUBLIC STATE OF COLORAl;lO NOTARY ID 20184015409 MY COMMISSION EXPIRES APRIL 06. 2022

Enclosure 1 TVA-NPG-AWA16, "TVA Overall Basin Probable Maximum Precipitation and Local Intense Precipitation Analysis, Calculation CDQ0000002016000041," Revision 1 Data Sets