ML13074A088

Request for Withholding Information from Public Disclosure

ML13074A088
Person / Time
Site:	Three Mile Island
Issue date:	03/28/2013
From:	Peter Bamford Plant Licensing Branch 1
To:	Pacilio M Exelon Nuclear
Bamford P
References
TAC ME9818
Download: ML13074A088 (4)

Text

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• • • • -it Mr. Michael Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

THREE MILE ISLAND NUCLEAR STATION, UNIT 1 - REQUEST FOR WITHHOLDING INFORMATION FROM PUBLIC DISCLOSURE (TAC NO. ME9818)

Dear Mr. Pacilio:

By letter dated January 17, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13018A248), Exelon Generation Company, LLC (Exelon) submitted supplemental information in support of a relief request proposing to perform a weld overlay of the lower cold leg letdown nozzle dissimilar metal welds and Alloy 600 safe-end at Three Mile Island Nuclear Station, Unit 1 (TMI-1). By letter dated March 11, 2013 (ADAMS Accession No. ML13071A093), based upon comments from the Nuclear Regulatory Commission (NRC) staff, Exelon submitted a revised portion of the supplement. This revised supplement corrected certain areas of Attachments 3 and 4 to the letter dated January 17, 2013, identified for public withholding, that should not have delineated for withholding. Specifically, in the letter dated March 11, 2013, Exelon submitted revised proprietary and non-proprietary versions of three calculations and analyses performed by AREVA NP, Inc. (AREVA NP), that support the requested relief.

Attachment 3 to the letter dated March 11, 2013, contains an affidavit, dated March 1, 2013, executed by Gayle F. Elliott, Manager, Product Licensing for AREVA NP, requesting that information contained in the following documents be withheld from public disclosure pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Part 2, Section 2.390:

• Calculation Summary Sheets (CSS) 32-9183944-003, entitled, "TMI-1 Letdown Nozzle Weld Overlay Sizing Calculation," dated February 2013,

• CSS 32-9185635-002, entitled, "TMI-1 Letdown Nozzle Weld Overlay Section III Analysis," dated February 2013, and

• CSS 32-9186192-002, entitled, "TMI Unit 1 Weld Residual Stress Analysis for CL

[cold leg] Letdown Nozzle Weld Overlay," dated February 2013.

A non-proprietary version of these documents, based on the letter dated March 11, 2013, has been placed in the NRC's Public Document Room and added to the ADAMS Public Electronic Reading Room. It may be found at ADAMS Accession No. ML13071A093.

Attachment 5 to the letter dated January 17, 2013, contains an affidavit, dated January 10, 2013, executed by Gayle F. Elliott, Manager, Product Licensing for AREVA NP, requesting that, in part, information contained in the following document be withheld from public disclosure pursuant to 10 CFR 2.390:

M. Pacilio -2

• CSS 32-9186194-001, entitled, 'TMI Unit 1 CL Letdown Nozzle DMW [dissimilar metal weldJ and Safe End Crack Growth Analysis," dated January 2013.

A non-proprietary version of this document, based on the letter dated January 17, 2013, has been placed in the NRC's Public Document Room and added to the ADAMS Public Electronic Reading Room. It may be found at ADAMS Accession No. ML13018A248.

The affidavits stated that the submitted information should be considered exempt from mandatory public disclosure for the following reasons:

6(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 AREVA NP.

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

We have reviewed your submittals and the material in accordance with requirements of 10 CFR 2.390 and, on the basis of your statements, have determined that the submitted information sought to be withheld, corrected as described above, contains proprietary commercial information and should be withheld from public disclosure.

Therefore, the version of the submitted information marked proprietary, submitted on January 17. 2013. and corrected by letter dated March 11, 2013, as described above. will be withheld from public disclosure pursuant to 10 CFR 2.390(b)(5) and Section 103(b) of the Atomic Energy Act of 1954. as amended.

Withholding from public inspection shall not affect the right, if any, of persons properly and directly concerned to inspect the documents. If the need arises. we may send copies of this information to our consultants working in this area. We will, of course. ensure that the conSUltants have signed the appropriate agreements for handling proprietary information.

If the basis for withholding this information from public inspection should change in the future such that the information could then be made available for public inspection, you should promptly notify the NRC. You also should understand that the NRC may have cause to review this determination in the future. for example, if the scope of a Freedom of Information Act request includes your information. In all review situations, if the NRC makes a determination adverse to the above, you will be notified in advance of any public disclosure.

M. Pacilio - 3 Please contact me at 301-415-2833, if you have any questions.

Sincerely, Peter Bamford, Project Manager Plant licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-289 cc:

Gayle F. Elliott Manager, Product Licensing AREVA NP Inc.

3315 Old Forest Road Lynchburg, VA 24501 Additional distribution via Listserv

M. Pacilio -3 Please contact me at 301-415-2833, if you have any questions.

Sincerely, IRN Peter Bamford, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-289 cc:

Gayle F. Elliott Manager, Product Licensing AREVA NP Inc.

3315 Old Forest Road Lynchburg, VA 24501 Additional distribution via Listserv DISTRIBUTION:

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