ML19133A119

Request for Withholding Information from Public Disclosure

ML19133A119
Person / Time
Site:	Browns Ferry
Issue date:	08/26/2019
From:	Farideh Saba Plant Licensing Branch II
To:	James Shea Tennessee Valley Authority
Saba F
References
EPID L-2018-LLA-0048
Download: ML19133A119 (4)

Text

Mr. Joseph W. Shea Vice President, Nuclear Regulatory Affairs and Support Services Tennessee Valley Authority Browns Ferry Nuclear Plant 1101 Market Street, LP 4A Chattanooga, TN 37402-2801 UNITED STATES WASHINGTON, D.C. 20555-0001 August26,2019

SUBJECT:

BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3 - REQUEST FOR WITHHOLDING INFORMATION FROM PUBLIC DISCLOSURE (EPID L-2018-LLA-0048)

Dear Mr. Shea:

By letter to the U.S. Nuclear Regulatory Commission (NRC), dated February 23, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML180798140), Tennessee Valley Authority (TVA) submitted affidavits dated February 19, 2018, and February 15, 2018, executed by Ms. Lisa K. Schichlein, Senior Project Manager, NPP/Services Licensing, Regulatory Affairs, GE-Hitachi Nuclear Energy Americas LLC (GEH),

requesting that the information contained in the following documents (Attachments 5 and 34, respectively, of the letter dated February 23, 2018) be withheid from public disclosure pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Part 2, Section 2.390:

GEH proprietary report NEDC-33877P, "Safety Analysis Report for Browns Ferry Nuclear Plant Units 1, 2, and 3 Maximum Extended Load Line Limit Analysis Plus," Revision 0, dated February 2018. 4 GEH proprietary report 004N6594-P Revision 2, "Steady-State Core Simulator Comparisons Using GEH/GNF and Framatome (formerly AREVA) Methods,"

dated February 2018.

Nonproprietary copies of these documents are provided in Attachments 6 and 35 of the TVA letter dated February 23, 2018.

The GEH affidavits dated February 19, 2018, and February 15, 2018, stated that the submitted documents contain proprietary information that should be considered exempt from mandatory public disclosure of 10 CFR 2.390(b )( 4) requirements for the following reasons:

a Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GEH's

J.Shea competitors without license from GEH constitutes a competitive economic advantage over 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, resulting in potential products to GEH;

d.

Information that discloses trade secret or potentially patentable subject matter for which it may be desirable to obtain patent protection.

We have reviewed your application and the material in accordance with the requirements of 1 O CFR 2.390 and, based on 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 versions of the submitted information 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 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.

J.Shea Docket Nos. 50-259, 50-260, and 50-296 cc: Ms. Lisa K. Schichlein Senior Project Manager NPP/Services Licensing Regulatory Affairs Sincerely, Farideh E. Saba, Senior Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation GE-Hitachi Nuclear Energy Americas LLC 3901 Castle Hayne Road Wilmington, NC 28401 Listserv

ML19133A119 OFFICE NRR/DORL/LPL2-2/PM NRR/DORL/LAiT NAME FSaba KEntz DATE 06/24/19 06/24/19 OFFICE NRR/DSS/SRXB/BC(A)

NRR/DORL/LPL2-2/BC NAME JBorromeo UShoop DATE 08/12/19 08/23/19 NRR/DORL/LPL2-2/LA BClayton (JBurkhardt for) 06/24/19 NRR/DORL/LPL2-2/PM FSaba 08/26/19