ML111120271
| ML111120271 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 04/18/2011 |
| From: | David Helker Exelon Generation Co, Exelon Corp, Exelon Nuclear |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML111120270 | List: |
| References | |
| Download: ML111120271 (5) | |
Text
Exelon Nuclear 200 Exelon Way Kennett Square, PA 19348 www.exeloncorp.com Exelon Nuclear PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 April 18, 2011 u.s. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278
Subject:
Spent Fuel Pool Criticality Documents
Reference:
1)
Letter from D. P. Helker (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commissi.Qn, IISpent Fuel Pool Criticality Documents,II dated February 9, 2011 2)
Letter from D. P. Helker (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, IISpent Fuel Pool Criticality Documents,1I dated February 23, 2011 In the Reference 1 letter, as requested by the U.S. Nuclear Regulatory Commission Senior Resident Inspector at Peach Bottom Atomic Power Station, Exelon Generation Company, LLC (Exelon) submitted several documents for NRC review. We note that there is no outstanding license amendment request associated with this issue.
Reference 2 provided additional information as requested.
In this submittal, attached are copies of NET-174-01, Revision 1 C1BADGER Test Campaign at Peach Bottom Unit 3
- 11) and NET-192-01, Revision 1 C1BADGER Test Campaign at Peach Bottom Unit 2 11). Additionally, NET-264-01, Revision 4 CIBADGER Test Campaign at Peach Bottom Unit 2 11
) and NET-350-01, Revision 1 CI2010 Badger Test Campaign at Peach Bottom Unit 2 11
) have been updated and are being resubmitted.
Attachments 1, 2, 3, 4 transmitted herewith contain Proprietary Information.
When separated from attachments, this document is decontrolled.
u.s. Nuclear Regulatory Commission Spent Fuel Pool Criticality Documents April 18, 2011 Page 2 Attachments 1 through 4 contain information proprietary to Curtiss-Wright Flow Control Service Company (NETCO). NETCO requests that the information contained in these attachments be withheld from public disclosure in accordance with 10 CFR 2.390(a)(4). An Affidavit supporting this request is contained in Attachment 5.
If any additional information is needed, then please contact Tom Loomis at (610) 765-5510.
Respectfully, David P. Helker Manager, Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments:
1)
IIBADGER Test Campaign at Peach Bottom Unit 3:1NET-174-01, Revision 1 (Proprietary) 2)
IIBADGER Test Campaign at Peach Bottom Unit 2,11 NET-192-01, Revision 1 (Proprietary) 3)
IIBADGER Test Campaign at Peach Bottom Unit 2,11 NET-264-01, Revision 4 (Proprietary) 4)
112010 Badger Test Campaign at Peach Bottom Unit 2:1NET-350-01, Revision 1 (Proprietary) 5)
Affidavit cc:
USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, PBAPS USNRC Project Manager, PBAPS R. R. Janati, Bureau of Radiation Protection (w/o Attachments)
S. T. Gray, State of Maryland (w/o Attachments)
i!AeP!J4V S TUOWLI3CflV Affidavit
NETCO 731 Grant Avenue Lake Ktine NY 1)1 9 I
Phone d45 382 691?
IJR755 rx 8453826917 AIRJGHT ow CntroI Coinpadv AFFIDAVIT I, Matthew L. Eyre, Director of NETCO, a business unit of Curtiss-Wright Flow Control Service Company, do hereby affirm and state:
I.
I am the Director of NETCO, a business unit of Curtiss-Wright Flow Control Service Company (NETCO), authorized to execute this affidavit on its behalf.
I am further authorized to review information submitted to the Nuclear Regulatory Commission (NRC) and apply to the NRC for the withholding of information from disclosure.
- 2. The information sought to be withheld is contained in the NETCO technical reports:
BADGER Test Campaign at Peach Bottom Unit 3, designated as NET-I 74-01, Rev 1; BADGER Test Campaign at Peach Bottom Unit 2, designated as NET-192-01, Rev 1; BADGER Test Campaign at Peach Bottom Unit 2, designated as NET-264-01, Rev 4 and 2010 BADGER Test Campaign at Peach Bottom Unit 2, designated as NET-350-01, Rev 1.
3.
In making this application for withholding of proprietary information of which it is the owner, NETCO relies on provisions of NRC regulation 10 CFR 2.390(a) 4. The information for which exemption from disclosure is sought is confidential commercial information.
- 4. Some categories of information which fit into the definition of proprietary information are:
a) Information that discloses a process or a method including data and supporting analysis and use of such information by a competitor would constitute a competitive advantage over other companies; b) Information if used by a competitor would reduce the competitors expenditure of resources or improve his competitive position in the implementation of a similar product.
5.
Initial approval of proprietary treatment of a document is made by the Director of NETCO, the person most likely to be familiar with the value and sensitivity of the information and its relation to industry knowledge. Access to such information within NETCO is on a need to know basis.
NETCO 731 Grant Avenue Lake Katine, NY 12449 Phone: 845.382.6912 Fax: 845.382.6917 AFFIDAVIT I, Matthew L. Eyre, Director of NETCO, a business unit of Curtiss-Wright Flow Control Service Company, do hereby affirm and state:
- 1. I am the Director of NETCO, a business unit of Curtiss-Wright Flow Control Service Company (NETCO), authorized to execute this affidavit on its behalf. I am further authorized to review information submitted to the Nuclear Regulatory Commission (NRC) and apply to the NRC for the withholding of information from disclosure.
- 2. The information sought to be withheld is contained in the NETCO technical reports:
"BADGER Test Campaign at Peach Bottom Unit 3," designated as NET-174-01, Rev 1; "BADGER Test Campaign at Peach Bottom Unit 2," designated as NET-192-01, Rev 1; "BADGER Test Campaign at Peach Bottom Unit 2," designated as NET-264-01, Rev 4 and "2010 BADGER Test Campaign at Peach Bottom Unit 2," designated as NET-350-01, Rev 1.
3.
In making this application for withholding of proprietary information of which it is the owner, NETCO relies on provisions of NRC regulation 10 CFR 2.390(a) 4. The information for which exemption from disclosure is sought is confidential commercial information.
- 4. Some categories of information which fit into the definition of proprietary information are:
a) Information that discloses a process or a method including data and supporting analysis and use of such information by a competitor would constitute a competitive advantage over other companies; b) Information if used by a competitor would reduce the competitor's expenditure of resources or improve his competitive position in the implementation of a similar product.
5.
Initial approval of proprietary treatment of a document is made by the Director of NETCO, the person most likely to be familiar with the value and sensitivity of the information and its relation to industry knowledge. Access to such information within NETCO is on a "need to know" basis.
Page 2 of 2
- 6. The information referred to in paragraph (2) above is classified as proprietary because it contains details of NETCOs spent fuel pool criticality analysis methodology. The development of methods used in these analyses was achieved at significant cost.
7.
Public disclosure of the information sought to be withheld may cause harm to NETCOs competitive position and may reduce profit-making opportunities.
I declare under penalty of perjury that the foregoing affidavit and statements therein are true and correct to the best of my knowledge, information and belief.
Matthew L. Eyre Director NETCO, a business unit of Curtiss-Wright Flow Control Service Company April 12, 2011 5is L,f\\J L1
\\
o flki EL 1 E JOAN SMITH Notar(PuhliC, State of New York RestaLcn# 01 SM60431 70 QuaIflei in Ulster County Common Expires 06/12/20 NETCO 731 Grant Avenue
- Lake Katrine, NY 12449
- Phone 845.3826912
- Fax: 845.382.6917 Page 2 of 2
- 6. The information referred to in paragraph (2) above is classified as proprietary because it contains details of NETCO's spent fuel pool criticality analysis methodology. The development of methods used in these analyses was achieved at significant cost.
7.
Public disclosure of the information sought to be withheld may cause harm to NETCO's competitive position and may reduce profit-making opportunities.
I declare under penalty of perjury that the foregoing affidavit and statements therein are true and correct to the best of my knowledge, information and belief.
Matthew L. Eyre Director NETCO, a business unit of Curtiss-Wright Flow Control Service Company April 12, 2011 o
(Y"l A"ff*'6
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NETCO 731 Grant Avenue' Lake Katrine, NY 12449' Phone 845.382.6912' Fax: 845.382.6917