ML20049A139

LIC-204, Revision 4, Handling Requests to Withhold Proprietary Information from Public Disclosure

ML20049A139
Person / Time
Issue date:	07/06/2020
From:	Craig Erlanger Division of Operating Reactor Licensing
To:
Pulvirenti A
References
LIC-204, Y020190367
Download: ML20049A139 (16)

Text

OFFICE OF NUCLEAR REACTOR REGULATION LIC-204, Revision 4 Handling Requests to Withhold Proprietary Information from Public Disclosure Volume 200 Licensing Support Approved By:

Craig G. Erlanger Date Approved:

July 6, 2020 Effective Date:

July 13, 2020 Certification Date:

July 13, 2025 Responsible Organization:

NRR/DORL Primary

Contact:

Thomas J. Wengert 301-415-4037 Thomas.Wengert@nrc.gov Summary of Changes: General update due to the fall 2019 reunification of the Office of Nuclear Reactor Regulation (NRR) and the Office of New Reactors (NRO).

Training:

None ADAMS Accession Number:

ML20049A139 TABLE OF CONTENTS

1.

POLICY............................................................................................................................. 2

2.

OBJECTIVES.................................................................................................................... 2

3.

BACKGROUND................................................................................................................ 2

4.

BASIC REQUIREMENTS................................................................................................. 3

5.

RESPONSIBILITIES AND AUTHORITIES...................................................................... 10

6.

PERFORMANCE MEASURES....................................................................................... 11

7.

PRIMARY CONTACT..................................................................................................... 11

8.

RESPONSIBLE ORGANIZATION................................................................................... 11

9.

EFFECTIVE DATE.......................................................................................................... 11

10.

CERTIFICATION DATE.................................................................................................. 11

11.

REFERENCES................................................................................................................ 11

ML20049A139

• indicates concurrence via e-mail OFFICE NRR/DORL/LA NRR/DORL/SME NRR/DORL/LPL4/BC*

NRR/DANU/D*

NAME JBurkhardt APulvirenti JDixon-Herrity JMonninger DATE 3/2/2020 3/2/2020 5/7/2020 3/12/2020 OFFICE NRR/DNRL/D*

NRR/VPO/D*

NRR/DORL/D*

OCIO/GEMSB/IMSB*

NAME ABradford MKing CErlanger (GSuber for)

MJanney DATE 4/29/2020 4/27/2020 6/16/2020 4/30/2020 OFFICE OGC/RPS/LCLSP*

NRR/DRMA NRR/DORL/D NAME MClark TGorham CErlanger DATE 6/1/2020 6/25/2020 7/6/2020

NRR Office Instruction LIC-204, Revision 4 Page 2 of 12

1.

POLICY The U.S. Nuclear Regulatory Commission (NRC) is required by Section 2.390(a) of Title 10 of the Code of Federal Regulations (10 CFR) to make public final NRC records and documents including but not limited to correspondence to and from the NRC.

Where a submitter identifies information as a trade secret or confidential or privileged commercial or financial information (i.e., proprietary information) and requests that the information be withheld from public disclosure under 10 CFR 2.390(b), the NRC must make a determination on the request.

2.

OBJECTIVES This office instruction (OI) contains guidance for the review and disposition of requests to withhold proprietary information from public disclosure pursuant to 10 CFR 2.390. It is not the intent of this OI to address every circumstance. When guidance in this OI does not address the specific circumstance, the Primary Contact listed in Section 7.0 of the OI or the Office of the General Counsels Assistant General Counsel for Legal Counsel, Legislation, and Special Projects (OGC/RPS/LCLSP) should be consulted. Additionally, that OGC division should also be contacted whenever legal advice or assistance is needed. OGC concurrence on routine determinations is not required.

3.

BACKGROUND All submittals that are requested to be withheld from public disclosure because they contain proprietary information shall be reviewed by the staff to ensure that the submittals comply with the affidavit and marking requirements in 10 CFR 2.390(b), and that the justification for withholding is supportable. Additionally, the staff should ensure that the public has access to as much information as possible regarding the basis for regulatory decisions by making the non-proprietary portions of the submittal available to the public. In general, this objective is accomplished by releasing a redacted version of the submittal to the public, as described in Sections 4.1 and 4.7 of this OI. Information such as safeguards information must be withheld from the public in accordance with 10 CFR 2.390(a) and underlying laws, while other information, such as personal-privacy information, may also qualify for withholding under 10 CFR 2.390(a).

In proprietary determinations, reviews for withholding proprietary information will be made or coordinated by the cognizant Project Manager (PM). The PM should arrange for assistance as necessary and coordinate the review to ensure continuity and a timely determination. In certain determinations, as described in Section 4.5 of this OI, the PM should consult with the OGC. The determination should normally be made within 60 days of the date of receipt of the material, except for material used to support meetings as described in Section 4.6 of this OI.

Additionally, Management Directive (MD) 3.1, Freedom of Information Act, includes guidance regarding the release of information when a proprietary determination has yet to be made by the staff.

A list of templates for correspondence documenting proprietary determinations is provided in Enclosure 2 to this OI and can be found in the Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML062080003.

NRR Office Instruction LIC-204, Revision 4 Page 3 of 12 Concurrence and signature of correspondence should be consistent with OI ADM-200, Delegation of Signature Authority.

3.1 Definitions

1.

Submitter - individual or organization who submits the proprietary information to the NRC. The submitter is often an applicant or licensee.

In some instances, the submitter is also the owner of the information (e.g., a fuel vendor who submits a proprietary topical report for review and approval).

2.

Owner - individual or organization who owns the proprietary information.

The owner of the proprietary information prepares and signs the affidavit (e.g., a fuel vendor). The owner can be, but is not necessarily, the submitter.

4.

BASIC REQUIREMENTS 4.1 Affidavit or Unsworn Declaration The request for withholding must be submitted at the same time the proprietary information sought to be withheld is submitted to the NRC. The request must be accompanied by either (1) an affidavit that is notarized or signed under oath and affirmation, or (2) an unsworn declaration made under penalty of perjury that meets the requirements of 28 U.S. Code §1746. The factors set out in 10 CFR 2.390(b)(4) must be addressed in the affidavit or declaration, including specific reasons why the document is considered to contain proprietary information, the release of which would cause harm to the competitive position of the owner of the information.

The PM should review the affidavit or declaration to ensure that it is complete and meets all the requirements of 10 CFR 2.390(b)(1)(ii) and (iii). Normally, the submitter of the information to be withheld, submits the affidavit or declaration.

However, the affidavit or declaration itself must be prepared and signed by the owner of the information. The requirements of 10 CFR 2.390(b)(1)(ii) and (iii) are summarized below.

Note: all references to an affidavit below and in future sections are intended to cover either an affidavit or an unsworn declaration submitted in accordance with 27 U.S. Code § 1746.

1.

The affidavit must identify the document or part of the documents sought to be withheld.

2.

The affidavit must identify the official position of the person making the affidavit. Where the affidavit has been submitted by a company, this person shall be an officer or upper-level management official who has been specifically delegated the function of reviewing the information sought to be withheld and authorized to apply for its withholding on behalf of the company. Further, the affidavit shall be executed by the owner of

NRR Office Instruction LIC-204, Revision 4 Page 4 of 12 the information, even if the information is submitted to the Commission by another person.

3.

The affidavit must declare the basis for proposing the information be withheld, including the considerations set forth in 10 CFR 2.390(a).

4.

The affidavit must contain a specific statement of the harm that would result if the information sought to be withheld is disclosed to the public.

5.

The affidavit must indicate the location(s) in the document of all information sought to be withheld.

A withholding request based on 10 CFR 2.390(a)(4) must contain a full statement of the reason for claiming the information should be withheld from public disclosure. The statement should address, with specificity, the considerations listed in 10 CFR 2.390(b)(4).

Note that under 10 CFR 2.390(b), an affidavit is only required for documents submitted as trade secrets and commercial or financial information (i.e.,

proprietary information), that is, information covered by 10 CFR 2.390(a)(4). An affidavit is not required for documents or information falling within the other exemptions listed in 10 CFR 2.390(a). For example, a submittal containing personal privacy information covered by 10 CFR 2.390(a)(6) is not required to be accompanied by an affidavit. However, the request for withholding should indicate that personal privacy information is included, the document should be properly marked to indicate the personal information, and a version suitable for public disclosure should be submitted.

4.2 Marking of Information Sought to be Withheld The portions of the document that are claimed to be proprietary must be identified. The top of the first page of the document and the top of each page containing proprietary information must be marked with language clearly indicating that it contains proprietary information to be withheld from public disclosure under 10 CFR 2.390. The language should be similar to confidential information submitted under 10 CFR 2.390, withhold from public disclosure under 10 CFR 2.390, or proprietary. Watermarks are not sufficient.

Additionally, each document or page to be withheld from public disclosure must contain, adjacent to the information, or at the top if the entire page is affected, markings to indicate the basis (i.e., proprietary) for proposing that the information be withheld under 10 CFR 2.390(a).

As discussed above, the specific basis for withholding needs to be set forth either in the document or in the affidavit. If the document or page in question contains more than one type of information to be withheld or if the affidavit does not clearly indicate the basis for withholding, adjacent markings (i.e., subscript annotations next to each bracketed portion) of material to be withheld is required.

If all the information to be withheld on a given page is proprietary and the affidavit clearly indicates the basis for the withholding request, then a marking such as

NRR Office Instruction LIC-204, Revision 4 Page 5 of 12 proprietary at the top of the page is enough and adjacent markings of proprietary material are not necessary.

In addition to the document containing proprietary information, the submitter should provide a non-proprietary (i.e., redacted) version of the report or document. If no non-proprietary version of the document is submitted, the affidavit prepared by the owner of the information must clearly explain why the non-proprietary version is not submitted. For example, if the document contains extensive proprietary information to an extent that a redacted version would be of no value to the public, a non-proprietary version is not required to be submitted to the NRC. Absent such a finding, the submitter should provide a version that could be made available to the public. The task of providing a public version rests on the submitter, not on the NRC staff.

4.3 Proprietary Determination by NRC Staff If the staff determines that the information contains trade secrets or confidential commercial or financial information within the scope of 10 CFR 2.390(b)(4), then, pursuant to 10 CFR 2.390(b)(5), the staff must determine: (1) whether the right of the public to be fully apprised of any proposed action outweighs the demonstrated concern for protection of a competitive position; and (2) whether the information should be withheld.

The PM should consider each of the following questions to determine if the information is proprietary information and, if so, whether it should be withheld.

These questions are drawn from the requirements of 10 CFR 2.390(b)(4):

1.

Was the information held in confidence by the owner?

2.

Is the information of a type normally held in confidence?

3.

Was the information sent to and received by the NRC in confidence?

4.

Is the information not already publicly available?

5.

Is public disclosure likely to cause harm to the owner of the information?

6.

Does the publics interest in disclosure of the information outweigh any harm to the owner of the information?

The responsibility of making the determination rests with the cognizant PM; however, the PM may coordinate with NRC staff in making the determination.

For example, staff familiar with the technical content of the document (i.e.,

technical staff) can provide insight into the answer to question 4. If any of the answers to the first five questions are No, or if the answer to the sixth question is Yes, the withholding may be denied. If all the first five answers are Yes and the sixth answer is No, the PM may approve the request for withholding from the public based on guidance in Section 4.4 of this OI.

Correspondence and reports that identify procedures for the physical protection of a licensed facility, or information submitted in confidence by a foreign government or company owned by a foreign government, are automatically deemed to meet the requirements for withholding from public disclosure in accordance with10 CFR 2.390(d).

NRR Office Instruction LIC-204, Revision 4 Page 6 of 12 Voluntary Submittals Occasionally, a submitter or owner will submit a document to the Commission for information only and the document is not legally required to be submitted nor retained for inspection and is not related to a request for NRC review and approval of an application or a document or for any other NRC decision. A different criterion is used to evaluate whether the voluntary submittal contains proprietary information. The NRC staff determines whether the documents are proprietary by determining that such documents are held in confidence by the owner and customarily held in confidence. The determinations that are normally made for other proprietary requests (i.e., weighing public interest in disclosure against the harm to the submitter) are not required for voluntary submittals.

Irrelevant or Unnecessary Information A submitter may submit a document which is ultimately deemed to be irrelevant or unnecessary for the NRC to perform its functions (e.g., if the information is not necessary to make a safety determination or regulatory decision during a review). Such information should be returned to the submitter in accordance with 10 CFR 2.390(b)(5).

Deficient Affidavit A deficient affidavit contains insufficient information to support a decision under the considerations of 10 CFR 2.390(b)(4). If the PM finds the affidavit deficient, the PM may request that the submitter provide supplemental information in a new affidavit. For example, a deficient affidavit might not contain a full statement of harm or address the considerations with enough specificity. To request a new affidavit with supplemental information, the PM should issue a letter to the licensee submitter using the template contained in the ADAMS Package Accession No. ML062080003. When a new affidavit is received, the PM should proceed to make a final determination on whether to withhold the information from the public.

4.4 Issuance, Correspondence, and Documentation of the Proprietary Determination Approval of the Request to Withhold from the Public After making the determination, the PM should prepare a letter to the submitter of the request using the appropriate approval letter template contained in ADAMS Package Accession No. ML062080003. A courtesy copy of the letter should be sent to the owner of the information, if appropriate, and should be issued within 60 days of receipt of the information. The PM should obtain concurrence from cognizant technical Branch Chiefs to ensure that technical staff have fully considered question 4 in the determination process.

Denial of the Request to Withhold from the Public If the PM determines that all or part the information should not be withheld from the public (i.e., if the PM answers No to any of the first five questions listed above or Yes to the sixth question), the request for withholding may be

NRR Office Instruction LIC-204, Revision 4 Page 7 of 12 rejected. The PM is encouraged to discuss the potential rejection with the submitter to determine if a satisfactory resolution can be reached to allow approval of the request.

If the PM decides to reject the request for withholding, the PM will then agree on a reasonable time frame after which the NRC will make the document available in ADAMS. The PM will then prepare a rejection letter according to the template found in ADAMS Package Accession No. ML062080003, including the date that the document will be made public. An example of a recent rejection letter, with justification for rejection, can be found at ADAMS Accession No. ML19242B700.

If the submitter does not desire the document to be made public on the date stated in the rejection letter, the submitter may request that the document(s) be withdrawn and returned to them. The PM should coordinate with OGC/RPS/LCLSP to determine whether the document and all copies can be returned to the submitter. If the withdrawal request is granted, the document will be removed from ADAMS in accordance with ADAMS Navigator User Guide (ADAMS Accession No. ML16173A430), and returned to the submitter. In addition, any copy of the document in possession of the NRC, such as electronic files on computer servers, digital storage media, or paper copies, should be deleted or disposed of appropriately.

If withdrawal is not requested following a rejection letter, and mutual agreement or some other resolution is not reached, the PM will consult with OGC/RPS/LCLSP and take action under 10 CFR 2.390(c) to issue a memorandum to the Chief, Information Management Services Branch, Governance & Enterprise Management Services Division, Office of the Chief Information Officer (OCIO/GEMS/IMSB), to make the information publicly available.

Paragraph 2.390(c)(3) of 10 CFR lists the circumstances under which the document submitted for withholding may not be withdrawn and returned to the submitter. The document may not be withdrawn if the information:

(i)

Forms part of the basis of an official agency decision, including but not limited to, rulemaking proceeding or licensing activity; (ii)

Is contained in a document that was made available to or prepared for an NRC advisory committee (iii)

Was revealed, or relied upon, in an open Commission meeting held in accordance with 10 CFR part 9 subpart C; (iv)

Has been requested in a Freedom of Information Act request; or (v)

Has been obtained during the course of an investigation conducted by the NRC Office of Investigations.

NRR Office Instruction LIC-204, Revision 4 Page 8 of 12 If the licensing action is still under review and the final decision has not yet been made, the submitter may still opt to withdraw the information. If the information is withdrawn, the review of the licensing request would then continue without that information, possibly affecting the final decision.

Availability of Correspondence Documenting Proprietary Determinations Normally the request for withholding, affidavit, and correspondence about the request for withholding do not contain proprietary information and are made available to the public, except in the case where the submittal contains a potential allegation. In NRC's correspondence with the submitter of proprietary information, any proprietary questions or other statements containing proprietary information should be placed in an enclosure to the cover letter so that the cover letter may be placed in the public domain while the enclosure is withheld.

Submittals that Contain Potential Allegations If the document(s) contains an allegation or any information which the staff determines to be necessary to resolve an allegation, the document cannot be withdrawn. However, the document should be removed from ADAMS and will be kept only in the NRC's allegation files and treated in accordance with NRC allegation program requirements. The PM should consult with the Office Allegation Coordinator for guidance. Legal questions should be referred to OGC/GCLR/LCLSP.

If potentially sensitive or allegation information is found when the PM reviews documents when received, the PM should immediately contact the Document Control Desk staff at ADAMSSupport.email@nrc.gov to delay or cancel the release of the documents that may have been profiled for release to the public.

4.5 The Role of OGC in Proprietary Determinations OGC advice may be sought when the staff desires legal advice on a withholding determination. While it is not expected that OGC views will be sought in routine cases, OGC review is required on all:

1.

Determinations to release information over a submitters objection,

2.

Cases involving a dispute that the staff cannot resolve with the submitter,

3.

Voluntary submittals,

4.

Controversial or high-visibility cases that are likely to receive Commission or senior management attention, and

5.

Requests by the submitter to withdraw a document from NRC consideration.

NRR Office Instruction LIC-204, Revision 4 Page 9 of 12 4.6 Proprietary Material Used in NRC Meetings There are two categories of meetings where it is necessary to hand out and discuss material considered to be proprietary. Refer to MD 3.5, Attendance at NRC Staff Sponsored Meetings, for more detailed guidance regarding meetings.

1) Meetings Where the Staff Has Already Determined the Information to be Proprietary If the information to be discussed at a closed meeting has already been submitted to the NRC, the material does not require its own affidavit. The meeting material may constitute the information in a new format (e.g., slides, handouts) if the content of this material is the same as was previously deemed proprietary by the staff. For example, if a licensee submits proprietary information in a license amendment request and later requests a meeting to discuss proprietary information in the request, then meeting slides containing the same information do not need its own affidavit. However, the PM should be cognizant some determinations may be time limited (see Section 4.9 of this OI).

2) Meetings Where the Staff Has Not Previously Made a Determination Whether the Information is Proprietary In many cases, a licensee or submitter requests a closed meeting to discuss information which has not yet been reviewed by NRC staff. Typical examples of such meetings include pre-submittal meetings before an application is submitted and meetings during a review to discuss technical aspects of draft requests for addition information (RAIs) or responses to RAIs. The submitter should provide the information and affidavit and NRC should complete the determination prior to the meeting. Thirty days would be an appropriate time frame to allow for the proprietary determination and issuance of the approval letter. The PM does have the option to accept the information and affidavit from the submitter at a date closer to the meeting at their discretion so long as they can make a determination in enough time to support holding the meeting.

For additional detail, the PM should refer to MD 3.5.

Version of Material on Which the Determination is Made For the purposes of making a proprietary determination, the information may, but does not necessarily need to, be the final version of the information or even the same format so long as the information requested to be withheld does not change when it is provided or discussed at the meeting. For example, a draft copy of presentation slides or even a bullet list or technical report may be accepted instead of final slides so long as the draft material contains enough specificity to enable the staff to reach a decision and the final version contains the same content as the draft version.

NRR Office Instruction LIC-204, Revision 4 Page 10 of 12 Oral Discussion Meetings Closed meetings which involve only oral discussions (i.e., no presentation slides or written material) are discouraged, as meetings tend to be more productive when NRC staff are provided written material to reference. However, if a submitter requests to restrict public access to a meeting at which no written material will be presented but rather only verbal information of a proprietary nature is discussed, the submitter is still required to provide an affidavit for the meeting to allow the meeting or a portion of the meeting to be closed.

4.7 Handling and Transmittal of Proprietary Correspondence For handling and transmittal of proprietary correspondence, the staff should refer to the guidance in MDs 3.4, 12.6, and 3.53. The staff can also refer to the SUNSI website at https://drupal.nrc.gov/sunsi for additional guidance.

Proprietary information should be transmitted outside the NRC only if a need-to-know exists and the proprietary information is encrypted using secure encryption software.

4.8 Time Limits on Proprietary Documents It is not possible to grant a blanket approval of proprietary information used or referenced repeatedly over a period, in part because the criteria for withholding are time-dependent. In each case, the complete review, as described in this procedure, will be made the first time the information is submitted. Any extracted information from a proprietary document with a proprietary determination more than 1-year old should be accompanied by a new affidavit listing the current reasons for withholding. The PM or technical reviewer will review in accordance with normal procedures and issue a letter to the submitter of the information.

Revised or updated documents are considered newly submitted and must also be accompanied by an affidavit. A document that is merely listed as a bibliographical reference does not require a new affidavit.

4.9 Recovering from an Inadvertent Proprietary Release If a proprietary document is inadvertently released to the public in ADAMS, the cognizant PM manager is referred to MD 3.4 for appropriate procedures to remove the document from public access and to properly report the release as a spill.

5.

RESPONSIBILITIES AND AUTHORITIES All NRR Staff Members Coordinate with the cognizant PM to provide input into making the determination.

Signature Authority Signature authority shall be consistent with OI ADM-200.

NRR Office Instruction LIC-204, Revision 4 Page 11 of 12 Project Manager The PM is responsible for the evaluation and generation of withholding determinations (approval or disapproval) to the submitter of the document. The PM coordinates reviews with technical staff and OGC to complete the review.

Technical Reviewer Provides input as requested by the PM for withholding determinations.

Branch Chief The Branch Chiefs for the PM and technical reviewer(s) concur on the proprietary determination.

6.

PERFORMANCE MEASURES None defined at this time.

7.

PRIMARY CONTACT Thomas J. Wengert 301-415-4037 Thomas.Wengert@nrc.gov

8.

RESPONSIBLE ORGANIZATION DORL

9.

EFFECTIVE DATE July 13, 2020

10.

CERTIFICATION DATE July 13, 2025

11.

REFERENCES 10 CFR 2.390, Public inspections, exemptions, requests for withholding 28 U.S. Code §1746, Unsworn declarations under penalty of perjury Management Directive 3.1, Freedom of Information Act, 5 USC 552; 10 CFR Part 9 ADM-200, Delegation of Signature Authority Management Directive 3.4, Release of Information to the Public

NRR Office Instruction LIC-204, Revision 4 Page 12 of 12 Management Directive 3.5, Attendance at NRC Staff Sponsored Meetings Management Directive 3.53, NRC Records and Document Management Program Management Directive 12.6, NRC Sensitive Unclassified Information Security Program Guidance for Determining the Public Applicability - NRC Records (ADAMS Accession No. ML072770468)

ADAMS Navigator User Guide (ADAMS Accession No. ML16173A430)

NRC Regulatory Issue Summary 2004-11, Supporting Information Associated with Requests for Withholding Proprietary Information, June 29, 2004

Enclosures:

1.

Appendix A: Change History

2.

List of Templates

Appendix A - Change History Office Instruction LIC-204, Revision 4 Handling Requests to Withhold Proprietary Information from Public Disclosure LIC-204, Revision 4, Change History Date Description of Changes Method Used to Announce &

Distribute Training 06/30/2001 Initial Issuance E-mail to NRR staff Training on LIC-204 to PMs and LAs in DLPM and RLSB within 90 days of issuance 11/08/2002 Changes in Revision 1 include (1) revised the title and content of section 4.7, Discussion of Proprietary Material Provided at NRC Meetings with Licensees and Vendors to provide clarification on the handling of proprietary material during meetings, (2) removal of Appendix B sample letters, inclusion of a reference to approved examples on R:\\DLPM Boilerplates, and editorial changes in the procedure to reflect these changes, and (3) various updates and editorial changes.

E-mail to NRR staff Training on LIC-204 to PMs and LAs in DLPM and RLSB within 90 days of issuance 04/02/2004 No change bars due to extensive changes. Changes include (1) updated roles and responsibilities, (2) updated changes to 2.790, (3) handling proprietary e-mails, and (4) removal of unnecessary restrictions E-mail to NRR staff Training on LIC-204 to PMs and LAs in DLPM and RLSB within 90 days of issuance

LIC-204, Revision 4, Change History Date Description of Changes Method Used to Announce &

Distribute Training 01/26/2007 No change bars due to extensive changes. Changes include (1) updated organizational names due to fall 2005 NRR re-organization, (2) define submitter and owner of proprietary information and clarify that responses to requests to withhold proprietary information are addressed to the submitter, not the owner, (3) refer to OI for meetings, and (4) update per SUNSI Handling Requirements.

E-mail to NRR staff Training on LIC-204 to PMs and LAs in DORL, DPR, DLR, and DNRL 07/062020 General update due to fall 2019 reunification of the Office of Nuclear Reactor Regulation (NRR) and the Office of New Reactors (NRO).

E-mail to staff None

Office Instruction LIC-204, Revision 4 Handling Requests to Withhold Proprietary Information from Public Disclosure List of Templates ADAMS Package Accession No. ML062080003 Template ADAMS Accession No.

Letter approving request to withhold proprietary information when a non-proprietary version was provided ML062080078 Letter approving request to withhold proprietary information when a non-proprietary version was NOT provided ML062080083 Letter requesting supplemental information to support the request for withholding ML062080106 Letter rejecting request to withhold proprietary information ML062080090 Letter transmitting proprietary information to a contractor/consultant (non-disclosure agreement) - OGC review is required ML062080054