Letter Sequence Response to RAI |
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TAC:ME2531, Clarify Application of Setpoint Methodology for LSSS Functions (Approved, Closed) |
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MONTHYEARML0931404632009-11-0303 November 2009 License Amendment Request Regarding Power Range Neutron Monitoring System Upgrade Project stage: Request ML0934100662009-12-10010 December 2009 Acceptance Review of License Amendment Request for Power Range Neutron Monitoring System - Includes Revised Schedule for Completion Based on Late Submittal Project stage: Acceptance Review ML1004308252010-02-0808 February 2010 Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI ML1010902452010-04-22022 April 2010 Request for Additional Information Power Range Neutron Monitoring System Project stage: RAI ML1014100942010-05-18018 May 2010 Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI ML1014704032010-05-25025 May 2010 Affidavit for 5/25/10 NRC Meeting to Discuss Response to Requests for Additional Information on License Amendment Request for Digital Power Range Neutron Monitoring System Project stage: Response to RAI GNRO-2010/00040, Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System2010-06-0303 June 2010 Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI ML1018001492010-06-18018 June 2010 Schedule for Responding to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Request ML1017904372010-06-30030 June 2010 0000-0102-0888-RI, Plant-Specific Responses Required by Numac Prnm Retrofit Plus Option III Stability Trip Function Topical Report, (NEDC-3241OP-A) Project stage: Other ML1021500292010-07-29029 July 2010 Responses to NRC Request for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI GNRO-2010/00064, Response to NRC Request for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System2010-09-29029 September 2010 Response to NRC Request for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI GNRO-2010/00075, Response to NRC Request for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System2010-12-13013 December 2010 Response to NRC Request for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI GNRO-2010/00070, Response to NRC Request for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System2010-12-14014 December 2010 Response to NRC Request for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI ML1111704322011-04-27027 April 2011 Request for Additional Information, Round 4, License Amendment Request for Power Range Neutron Monitoring System Project stage: RAI ML1111704242011-04-27027 April 2011 E-mail, Request for Additional Information, Round 4, License Amendment Request for Power Range Neutron Monitoring System Project stage: RAI GNRO-2011/00032, Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System2011-05-0303 May 2011 Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI ML1113204932011-05-12012 May 2011 E-mail, Request for Additional Information, Round 5, License Amendment Request for Power Range Neutron Monitoring System Project stage: RAI GNRO-2011/00038, Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System2011-05-16016 May 2011 Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI GNRO-2011/00039, Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System2011-05-26026 May 2011 Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI GNRO-2011/00042, Responses to NRC Requests for Additional Information Re License Amendment Request for Power Range Neutron Monitoring System2011-05-31031 May 2011 Responses to NRC Requests for Additional Information Re License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI ML1113906562011-06-0202 June 2011 Request for Withholding Information from Public Disclosure, 5/11/2011 Affidavit Executed by J. Harrison, GE-Hitachi Nuclear Energy Americas LLC, Attachment 1 to GNRO-2011/00038 Project stage: Withholding Request Acceptance ML1113905962011-06-0202 June 2011 Request for Withholding Information from Public Disclosure, 4/28/2011 Affidavit Executed by E. Schrull, GE-Hitachi Nuclear Energy Americas LLC, Attachment 1 to GNRO-2011/00032 Project stage: Withholding Request Acceptance GNRO-2011/00044, Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System2011-06-13013 June 2011 Responses to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI ML1117402132011-06-23023 June 2011 Email, Request for Additional Information, Round 6, License Amendment Request for Power Range Neutron Monitoring System Project stage: RAI GNRO-2011/00045, Supplemental Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System2011-06-28028 June 2011 Supplemental Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Supplement GNRO-2011/00057, Response to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System2011-07-22022 July 2011 Response to NRC Requests for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI GNRO-2011/00066, Response to NRC Request for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System2011-09-28028 September 2011 Response to NRC Request for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI GNRO-2011/00089, Response to NRC Request for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System2011-10-18018 October 2011 Response to NRC Request for Additional Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI GNRO-2011/00090, Supplemental Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System (TAC No. ME2531) - Software Evaluation Report2011-10-26026 October 2011 Supplemental Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System (TAC No. ME2531) - Software Evaluation Report Project stage: Supplement GNRO-2011/00091, Supplemental Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System (TAC No. ME2531) V&V Summary Test Report2011-11-0808 November 2011 Supplemental Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System (TAC No. ME2531) V&V Summary Test Report Project stage: Supplement GNRO-2011/00110, Supplemental Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System (TAC No. ME2531) V&V Summary Test Report2011-12-0101 December 2011 Supplemental Information Pertaining to License Amendment Request for Power Range Neutron Monitoring System (TAC No. ME2531) V&V Summary Test Report Project stage: Supplement ML1204406602012-02-27027 February 2012 Request for Withholding Information from Public Disclosure, 11/29/2011 Affidavit Executed by J. Harrison, GE-Hitachi Nuclear Energy Americas LLC, Attachment 1 to GNRO-2011/00110 Project stage: Withholding Request Acceptance ML1204406382012-02-27027 February 2012 Request for Withholding Information from Public Disclosure, 9/22/2011 Affidavit Executed by J. Harrison, GE-Hitachi Nuclear Energy Americas LLC, Attachment 1 to GNRO-2011/00066 Project stage: Withholding Request Acceptance ML1204406532012-02-27027 February 2012 Request for Withholding Information from Public Disclosure, 11/3/2011 Affidavit Executed by E. Schrull, GE-Hitachi Nuclear Energy Americas LLC, Attachment 1 to GNRO-2011/00091 Project stage: Withholding Request Acceptance ML1204406022012-02-27027 February 2012 Request for Withholding Information from Public Disclosure, 5/19/2011 Affidavit Executed by J. Harrison, GE-Hitachi Nuclear Energy Americas LLC, Attachment 1 to GNRO-2011/00039 Project stage: Withholding Request Acceptance ML1204406162012-02-27027 February 2012 Request for Withholding Information from Public Disclosure, 5/25/2011 Affidavit Executed by E. Schrull, GE-Hitachi Nuclear Energy Americas LLC, Attachment 1 to GNRO-2011/00042 Project stage: Withholding Request Acceptance ML1204406232012-02-27027 February 2012 Request for Withholding Information from Public Disclosure, 6/23/2011 Affidavit Executed by E. Schrull, GE-Hitachi Nuclear Energy Americas LLC, Attachment 1 to GNRO-2011/00045 Project stage: Withholding Request Acceptance ML1204406272012-02-27027 February 2012 Request for Withholding Information from Public Disclosure, 7/21/2011 Affidavit Executed by E. Schrull, GE-Hitachi Nuclear Energy Americas LLC, Attachment 1 to GNRO-2011/00057 Project stage: Withholding Request Acceptance ML1204406462012-02-27027 February 2012 Request for Withholding Information from Public Disclosure, 10/20/2011 Affidavit Executed by E. Schrull, GE-Hitachi Nuclear Energy Americas LLC, Attachment 1 to GNRO-2011/00090 Project stage: Withholding Request Acceptance ML1210701392012-04-0202 April 2012 Email Correction to Technical Specification Table 3.3.1-1 Project stage: Other ML1209403902012-04-16016 April 2012 Correction to Technical Specification (TS) Page 3.3-6 for Amendment No. 188, Revise TSs to Reflect Installation of Digital GE-Hitachi Nuclear Measurement Analysis and Control Power Range Neutron Monitoring System Project stage: Other GNRO-2012/00031, Supplemental Information - License Conditions, Extended Power Uprate2012-04-26026 April 2012 Supplemental Information - License Conditions, Extended Power Uprate Project stage: Supplement GNRO-2013/00031, Corrected Response to NRC Request for Additional Information Regarding License Amendment Request for Power Range Neutron Monitoring System2013-05-22022 May 2013 Corrected Response to NRC Request for Additional Information Regarding License Amendment Request for Power Range Neutron Monitoring System Project stage: Response to RAI ML13149A2252013-06-24024 June 2013 Correction to Safety Evaluation Page 60 (Redacted) for Amendment No. 188, Revise TSs to Reflect Installation of Digital GE-Hitachi Nuclear Measurement Analysis and Control Power Range Neutron Monitoring System Project stage: Approval 2011-04-27
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Category:Legal-Affidavit
MONTHYEARML23159A2302023-06-0808 June 2023 Response to Request for Additional Information Concerning Request to Update ASME Code Relief Request Safety Evaluations with NRC-Approved Revision of BWRVIP Guidelines (GG-ISI-020, and RBS-ISI-019) ML22301A1742022-10-28028 October 2022 Global Nuclear Fuel Americas, LLC (GNF) - Part 21 60-Day Interim Report Notification: GNF3 Raised Water Rod (SC-22-04 Rt) GNRO-2016/00024, Operating License Manual Update Submittal2016-05-17017 May 2016 Operating License Manual Update Submittal ML16084A9772016-03-14014 March 2016 MP Machinery and Testing, LLC Affidavit for Proprietary Version of Report MPM-814779, Revision 1 and 2 GNRO-2014/00080, Affidavits for the Proprietary MP Machinery and Testing, LLC (Mpm) Reports Attached in Letters GNRO-2014/00080 and GNRO-2015/000112015-08-18018 August 2015 Affidavits for the Proprietary MP Machinery and Testing, LLC (Mpm) Reports Attached in Letters GNRO-2014/00080 and GNRO-2015/00011 GNRO-2015/00031, Response to Request for Additional Information Regarding Fluence License Amendment Request2015-05-0808 May 2015 Response to Request for Additional Information Regarding Fluence License Amendment Request GNRO-2014/00064, Superseding Response to Request for Additional Information Regarding Maximum Extended Load Line Limit Plus Amendment Request, Dated 3/18/20142014-09-0404 September 2014 Superseding Response to Request for Additional Information Regarding Maximum Extended Load Line Limit Plus Amendment Request, Dated 3/18/2014 ML14204A7092014-07-23023 July 2014 Enclosure 3, Affidavit of Peter M. Yandow GNRO-2014/00015, Responses to NRC Requests for Additional Information Pertaining to the Final Report for the GGNS Replacement Steam Dryer2014-03-20020 March 2014 Responses to NRC Requests for Additional Information Pertaining to the Final Report for the GGNS Replacement Steam Dryer GNRO-2014/00024, Response to Request for Additional Information Regarding Maximum Extended Load Line Limit Plus Amendment Request, Dated 2/6/20142014-03-10010 March 2014 Response to Request for Additional Information Regarding Maximum Extended Load Line Limit Plus Amendment Request, Dated 2/6/2014 GNRO-2013/00050, Criticality Safety Analysis License Amendment Request - Responses to NRC Requests for Additional Information2013-07-0202 July 2013 Criticality Safety Analysis License Amendment Request - Responses to NRC Requests for Additional Information GNRO-2012/00018, Response to Request for Additional Information Regarding Extended Power Uprate2012-03-21021 March 2012 Response to Request for Additional Information Regarding Extended Power Uprate ML1203401652012-01-30030 January 2012 Affidavit for 1/30/12 Meeting Slides GNRO-2011/00088, Response to Request for Additional Information Regarding Extended Power Uprate2011-10-10010 October 2011 Response to Request for Additional Information Regarding Extended Power Uprate ML1127000682011-09-26026 September 2011 Enclosure 3, Mfn 10-245 R4, Affidavit GNRO-2011/00075, Supplemental Information Extended Power Uprate2011-09-0202 September 2011 Supplemental Information Extended Power Uprate ML1026604002010-08-20020 August 2010 GE-Hitachi Nuclear Energy Americas LLC - Affidavit of Edward Schrull Withholding from Public Disclosure Proprietary Report NEDC-33477P ML1014704032010-05-25025 May 2010 Affidavit for 5/25/10 NRC Meeting to Discuss Response to Requests for Additional Information on License Amendment Request for Digital Power Range Neutron Monitoring System ML1003603912010-02-0404 February 2010 Steam Dryer 2/18/10 NRC Presentation, Affidavit ML0930806782009-11-0404 November 2009 Entergy, Grand Gulf Nuclear Station, Supporting Affidavit from Edward D. Scroll for the Steam Dryer Presentation for 11/12/2009 Meeting - (ME2423) GNRO-2006/00064, Supplement to Amendment Request Changes to the Local Power Range Monitor (LPRM) Calibration Frequency2006-11-22022 November 2006 Supplement to Amendment Request Changes to the Local Power Range Monitor (LPRM) Calibration Frequency ML0627703182006-09-28028 September 2006 Transmittal of Draft Slide Presentation for Nrc/Entergy/Westinghouse Pre-Submittal Meeting (Proprietary/Non-Proprietary) ML0520003282005-07-14014 July 2005 Surveillance Program for Channel-Control Blade Interference 2023-06-08
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GE-Hitachi Nuclear Energy Americas LLC AFFIDAVIT I, Edward Schrull, state as follows:
(1) I am the Vice President, Regulatory Affairs, Services Licensing, GE-Hitachi Nuclear Energy Americas LLC (GEH), and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.
(2) The information sought to be withheld is contained in Enclosure 1 of GEH letter, GG-PRNM-168777-EC067, Edward Cooper (GEH) to Jon Langberg (Entergy), Grand Gulf PRNM Upgrade Project - Presentation for May 25, 2010, NRC Meeting, dated May 25, 2010. The GEH proprietary information in Enclosure 1, which is entitled NRC RAIs Regarding GGNS PRNM System LAR, is enclosed by double square brackets. ((This sentence is an example.{3})). Figures containing GEH proprietary information are identified with double square brackets before and after the object. In each case, the superscript notation {3} refers to Paragraph (3) of this affidavit that provides the basis for the proprietary determination.
(3) In making this application for withholding of proprietary information of which it is the owner or licensee, GEH relies upon the exemption from disclosure set forth in the Freedom of Information Act (FOIA), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) for trade secrets (Exemption 4). The material for which exemption from disclosure is here sought also qualifies under the narrower definition of trade secret, within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975 F2d 871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F2d 1280 (DC Cir. 1983).
(4) The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. Some examples of categories of information that fit into the definition of proprietary information are:
- a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GEH's competitors without license from GEH constitutes a competitive economic advantage over GEH and/or other companies.
- b. Information that, if used by a competitor, would reduce their expenditure of resources or improve their competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product.
- c. Information that reveals aspects of past, present, or future GEH customer-funded development plans and programs, that may include potential products of GEH.
Presentation for May 25, 2010, NRC Meeting Affidavit Page 1 of 3
- d. Information that discloses trade secret and/or potentially patentable subject matter for which it may be desirable to obtain patent protection.
(5) To address 10 CFR 2.390(b)(4), the information sought to be withheld is being submitted to the NRC in confidence. The information is of a sort customarily held in confidence by GEH, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GEH, not been disclosed publicly, and not been made available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary and/or confidentiality agreements that provide for maintaining the information in confidence. The initial designation of this information as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure are as set forth in the following paragraphs (6) and (7).
(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, who is the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or who is the person most likely to be subject to the terms under which it was licensed to GEH. Access to such documents within GEH is limited to a need to know basis.
(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist, or other equivalent authority for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GEH are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary and/or confidentiality agreements.
(8) The information identified in paragraph (2) above is classified as proprietary because it contains details developed by GEH from NEDC-32410P-A, Nuclear Measurement Analysis and Control Power Range Neutron (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function, dated October 1995. Development of the NUMAC PRNM, and information related to the design, modification, analyses methodologies and processes related to the NUMAC PRNM was achieved at a significant cost to GEH. The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GEH asset.
(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEH's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GEH's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost.
The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.
Presentation for May 25, 2010, NRC Meeting Affidavit Page 2 of 3
The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GEH. The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial. GEH's competitive advantage will be lost if its competitors are able to use the results of the GEH experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.
The value of this information to GEH would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GEH of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable analytical tools.
I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.
Executed on this 25th day of May 2010.
Edward D. Schrull Vice President, Regulatory Affairs Services Licensing GE-Hitachi Nuclear Energy Americas LLC 3901 Castle Hayne Rd.
Wilmington, NC 28401 edward.schrull@ge.com Presentation for May 25, 2010, NRC Meeting Affidavit Page 3 of 3