ML16039A338

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Request for Withholding Information from Public Disclosure for Byron Station, Unit Nos. 1 and 2, and Braidwood Station, Units 1 and 2
ML16039A338
Person / Time
Site: Byron, Braidwood  Constellation icon.png
Issue date: 02/18/2016
From: Joel Wiebe
Plant Licensing Branch III
To: Bryan Hanson
Exelon Generation Co
Joel S. Wiebe, NRR/DORL
References
TAC MF6715, TAC MF6716, TAC MF6717, TAC MF6718
Download: ML16039A338 (4)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 18, 2016 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO)

Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

REQUEST FOR WITHHOLDING INFORMATION FROM PUBLIC DISCLOSURE FOR BYRON STATION, UNIT NOS. 1AND2, AND BRAIDWOOD STATION, UNITS 1 AND 2 (TAC NOS. MF6715, MF6716, MF6717, AND MF6718)

Dear Mr. Hanson:

By letter dated September 11, 2015, you submitted an affidavit dated July 29, 2015, executed by Gayle Elliott of AREVA Inc., requesting that the information contained in the following documents be withheld from public disclosure pursuant to Title 1O of the Code of Federal Regulations (10 CFR), Part 2, Section 2.390:

  • Calculation Summary Sheet 32-9236713-001, "Byron and Braidwood RVCH Nozzle As-Left J-Groove Analysis"
  • Calculation Summary Sheet 32-9237284-001, "Byron/Braidwood RVCH Nozzle IDTB Repair Weld Anomaly" The affidavit stated that the submitted information should be considered exempt from mandatory public disclosure for the following reasons:
1. Information contained in these Documents has been classified by AREVA as proprietary in accordance with the policies established by AREVA Inc. for the control and protection of proprietary and confidential information.
2. These Documents contain information of a proprietary and confidential nature and is of the type customarily held in confidence by AREVA and not made available to the public.

Other companies regard information of the kind contained in these Documents as proprietary and confidential.

3. These Documents have been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in these Documents be withheld from public disclosure. The request for withholding of proprietary information is made in accordance with 10 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."

4. The following criteria are customarily applied by AREVA to determine whether information should be classified as proprietary:

B. Hanson (a) The information reveals details of AREVA's research and development plans and programs 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 AREVA.

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

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

The information in these Documents is considered proprietary for the reasons set forth in paragraphs 4(c), 4(d) and 4(e) above.

5. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in these Documents has been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
6. AREVA policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.

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

Therefore, the Calculation Summary Sheet 32-9236713-001, "Byron and Braidwood RVCH Nozzle As-Left J-Groove Analysis" and the Calculation Summary Sheet 32-9237284-001, "Byron/Braidwood RVCH Nozzle IDTB Repair Weld Anomaly" marked as proprietary, 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 Nuclear Regulatory Commission (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

B. Hanson NRC makes a determination adverse to the above, you will be notified in advance of any public disclosure.

If you have any questions regarding this matter, I may be reached at 301-415-6606.

Sincerely, Joel S. Wiebe, Senior Project Manager Plant Licensing Branch 111-2 Division of Operating Reactor Licenses Office of Nuclear Reactor Regulation Docket Nos. STN 50-456, STN 50-457, STN 50-454 and STN 50-455:

cc: Distribution via Listserv Gayle Elliott, Manager, Product Licensing 3315 Old Forest Road Lynchburg, VA 24501

ML16039A338 OFFICE LPL3-2/PM LPL3-2/LA LPL3-2/BC/A LPL3-2/PM NAME JWiebe SRohrer JPoole JWiebe DATE 2/11/16 2/9/16 2/17/16 2/18/16