ML19241A174

Request for Withholding Info from Public Disclosure for North Anna Power Station, Units 1 and 2, Proposed License Amendment Request Revision of Analytical Methodology Reference in Code Operating Limits Report for Small Break LOCA

ML19241A174
Person / Time
Site:	North Anna
Issue date:	09/03/2019
From:	Geoffrey Miller Plant Licensing Branch II
To:	Stoddard D Southern Nuclear Operating Co
Miller G, NRR/DORL/LPL2-1, 415-2481
References
EPID L-2018-LLA-0195
Download: ML19241A174 (4)

Text

September 3, 2019 Mr. Daniel G. Stoddard Senior Vice President and Chief Nuclear Officer Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT:

REQUEST FOR WITHHOLDING INFORMATION FROM PUBLIC DISCLOSURE FOR NORTH ANNA POWER STATION, UNITS 1 AND 2, PROPOSED LICENSE AMENDMENT REQUEST REVISION OF ANALYTICAL METHODOLOGY REFERENCE IN CORE OPERATING LIMITS REPORT FOR SMALL BREAK LOSS OF COOLANT ACCIDENT (EPID: L-2018-LLA-0195)

Dear Mr. Stoddard:

By letter dated July 12, 2018 (Agencywide Documents Access Management System (ADAMS)

Accession No. ML18198A118), Mr. Mark D. Sattain of your staff submitted an affidavit dated June 28, 2018, executed by Philip A. Opsal, Manager, Product Licensing, Framatome Inc.,

(formerly known as AREVA Inc.), requesting that the information contained in the following document be withheld from public disclosure pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Part 2, Section 2.390:

Framatome Document 103-3467-000, North Anna Fuel-vendor Independent Small Break LOCA Analysis, ANP-3676P Rev. 0 A nonproprietary version of this document can be found at ADAMS Accession No. ML18198A119.

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

This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document 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."

6. The following criteria are customarily applied by Framatome Inc.

to determine whether information should be classified as proprietary:

D. Stoddard (a) The information reveals details of Framatome lnc.'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 Framatome Inc.

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

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

The information in this Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above.

7. In accordance with Framatome lnc.'s policies governing the protection and control of information, proprietary information contained in this Document has been made available, on a limited basis, to others outside Framatome Inc. only as required and under suitable agreement providing for nondisclosure and limited use of the information.

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 version(s) 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.

D. Stoddard 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.

If you have any questions, please contact me at (301) 415-2481, or via email at ed.miller@nrc.gov.

Sincerely,

/RA/

G. Edward Miller, Project Manager Special Projects and Process Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-338 and 50-339 cc: Listserv

ML19241A174 OFFICE DORL/LSPB/PM DORL/LPL2-1/LA DORL/LPL2-1/BC DORL/LSPB/PM NAME GEMiller KGoldstein MMarkley GEMiller DATE 9/3/19 08/30/19 9/3/19 9/3/19