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Category:Legal-Affidavit
MONTHYEARNL-22-0289, License Amendment Request to Revise Technical Specification 4.3 Fuel Storage to Correct Tabulated Values from the Associated Spent Fuel Pool (SFP) Criticality Analysis2022-09-21021 September 2022 License Amendment Request to Revise Technical Specification 4.3 Fuel Storage to Correct Tabulated Values from the Associated Spent Fuel Pool (SFP) Criticality Analysis NL-22-0362, Southern Nuclear Operating Company, Inc. - Foreign Ownership, Control, or Influence Five-Year Renewal Filing and NRC Facility Clearance Update2022-06-0101 June 2022 Southern Nuclear Operating Company, Inc. - Foreign Ownership, Control, or Influence Five-Year Renewal Filing and NRC Facility Clearance Update NL-20-0828, Attachment 5 - Caw 20-05, Application for Withholding Proprietary Information from Public Disclosure2020-06-24024 June 2020 Attachment 5 - Caw 20-05, Application for Withholding Proprietary Information from Public Disclosure NL-15-0188, Response to Request for Additional Information Regarding the License Amendment Request to Revise Technical Specification Surveillance Requirement 3.1.3.2 and Specification 5.6.52015-02-13013 February 2015 Response to Request for Additional Information Regarding the License Amendment Request to Revise Technical Specification Surveillance Requirement 3.1.3.2 and Specification 5.6.5 NL-13-1073, Response to Request for Additional Information Concerning the Deferral of Inservice Inspection of Reactor Pressure Vessel Cold Leg Nozzle Dissimilar Metal Weld - Questions 2, 4. and 62013-05-24024 May 2013 Response to Request for Additional Information Concerning the Deferral of Inservice Inspection of Reactor Pressure Vessel Cold Leg Nozzle Dissimilar Metal Weld - Questions 2, 4. and 6 2022-09-21
[Table view] Category:Letter type:NL
MONTHYEARNL-24-0261, 10 CFR 50.46 ECCS Evaluation Model Annual Report for 20232024-07-19019 July 2024 10 CFR 50.46 ECCS Evaluation Model Annual Report for 2023 NL-24-0281, License Amendment Request to Change Technical Specification 3.6.5, Containment Air Temperature Actions2024-07-18018 July 2024 License Amendment Request to Change Technical Specification 3.6.5, Containment Air Temperature Actions NL-24-0227, Proposed Inservice Inspection Alternative GEN-ISI-AL T-2024-03 for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1)2024-07-0303 July 2024 Proposed Inservice Inspection Alternative GEN-ISI-AL T-2024-03 for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1) NL-24-0234, Application to Revise Technical Specifications to Adopt TSTF-589, Eliminate Automatic Diesel Generator Start During Shutdown2024-06-28028 June 2024 Application to Revise Technical Specifications to Adopt TSTF-589, Eliminate Automatic Diesel Generator Start During Shutdown NL-24-0230, Plants Units 1&2, License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-500, Revision 2, DC Electrical Rewrite – Update to TSTF-3602024-06-28028 June 2024 Plants Units 1&2, License Amendment Request for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-500, Revision 2, DC Electrical Rewrite – Update to TSTF-360 NL-24-0143, Proposed Alternative to Use ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/ Replacement Activities in2024-06-27027 June 2024 Proposed Alternative to Use ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/ Replacement Activities in NL-24-0201, Proposed Inservice Inspection Alternative GEN-ISI-ALT-2024-002 for Steam Generator Welds in Accordance with 10 CFR 50.55a(z)(1)2024-06-18018 June 2024 Proposed Inservice Inspection Alternative GEN-ISI-ALT-2024-002 for Steam Generator Welds in Accordance with 10 CFR 50.55a(z)(1) NL-24-0238, RIPE License Amendment Request to Change Containment Air Temperature Actions, Supplemental Information2024-06-14014 June 2024 RIPE License Amendment Request to Change Containment Air Temperature Actions, Supplemental Information NL-24-0229, Notice of Intent to Pursue Subsequent License Renewal2024-06-0707 June 2024 Notice of Intent to Pursue Subsequent License Renewal NL-24-0202, SNC Response to Regulatory Issue Summary 2024-01: Preparation and Scheduling of Operator Licensing Examinations2024-05-24024 May 2024 SNC Response to Regulatory Issue Summary 2024-01: Preparation and Scheduling of Operator Licensing Examinations NL-24-0191, Annual Radiological Environmental Operating Reports for 20232024-05-10010 May 2024 Annual Radiological Environmental Operating Reports for 2023 NL-24-0064, Units 1 & 2 and Hatch Nuclear Plant - Units 1 & 2 License Amendment Request to Revise Technical Specification 1.1 and Add Online Monitoring Program to Technical Specification 5.52024-05-0303 May 2024 Units 1 & 2 and Hatch Nuclear Plant - Units 1 & 2 License Amendment Request to Revise Technical Specification 1.1 and Add Online Monitoring Program to Technical Specification 5.5 NL-24-0188, Cycle 33 Core Operating Limits Report2024-05-0101 May 2024 Cycle 33 Core Operating Limits Report NL-24-0165, Annual Non-Radiological Environmental Operating Reports and Annual Radioactive Effluent Release Reports for 20232024-04-25025 April 2024 Annual Non-Radiological Environmental Operating Reports and Annual Radioactive Effluent Release Reports for 2023 NL-24-0137, RIPE License Amendment Request to Change Containment Air Temperature Actions2024-04-19019 April 2024 RIPE License Amendment Request to Change Containment Air Temperature Actions NL-24-0134, Renewed National Pollutant Discharge Elimination System (NPDES) Permit2024-04-12012 April 2024 Renewed National Pollutant Discharge Elimination System (NPDES) Permit NL-24-0088, Application to Revise Technical Specifications Regarding Change to Containment Spray Nozzle Test Frequency2024-04-0505 April 2024 Application to Revise Technical Specifications Regarding Change to Containment Spray Nozzle Test Frequency NL-24-0115, Response to Request for Additional Information Exemption Requests for Physical.2024-04-0404 April 2024 Response to Request for Additional Information Exemption Requests for Physical. NL-24-0116, Nuclear Property Insurance Coverage as of April 1, 2024 and Licensee Guarantees of Payment of Deferred.2024-03-29029 March 2024 Nuclear Property Insurance Coverage as of April 1, 2024 and Licensee Guarantees of Payment of Deferred. NL-24-0092, Inservice Inspection Program Owners Activity Report (OAR-1) for Outage 2R292024-03-15015 March 2024 Inservice Inspection Program Owners Activity Report (OAR-1) for Outage 2R29 NL-24-0003, Inservice Inspection Program Owners Activity Report (OAR) Supplement for Outages 1 R30 and 1 R312024-02-16016 February 2024 Inservice Inspection Program Owners Activity Report (OAR) Supplement for Outages 1 R30 and 1 R31 NL-24-0042, Response to Request for Additional Information Exemption Requests for Physical Barriers2024-02-13013 February 2024 Response to Request for Additional Information Exemption Requests for Physical Barriers NL-24-0033, Response to Question for Withholding Information from Public Disclosure Exemption Requests for Physical Barriers2024-02-0505 February 2024 Response to Question for Withholding Information from Public Disclosure Exemption Requests for Physical Barriers NL-24-0011, Report of Changes to Emergency Plan and Summary of 50.54(q) Analysis2024-01-11011 January 2024 Report of Changes to Emergency Plan and Summary of 50.54(q) Analysis NL-23-0901, 30-Day 10 CFR 21 Notification - Framatome Supplied Siemens Medium Voltage (Mv) Circuit Breakers2023-12-15015 December 2023 30-Day 10 CFR 21 Notification - Framatome Supplied Siemens Medium Voltage (Mv) Circuit Breakers NL-23-0908, Cycle 30 Core Operating Limits Report2023-12-13013 December 2023 Cycle 30 Core Operating Limits Report NL-23-0877, Request for Exemption from Security Event Notification Implementation2023-11-29029 November 2023 Request for Exemption from Security Event Notification Implementation NL-23-0825, Reply to Notice of Violation EA-23-080 and Readiness for 95001 Inspection2023-11-14014 November 2023 Reply to Notice of Violation EA-23-080 and Readiness for 95001 Inspection NL-23-0739, Response to NRC Inspection Report and Preliminary White Finding2023-09-0808 September 2023 Response to NRC Inspection Report and Preliminary White Finding NL-23-0713, Response to Request for Additional Information Regarding Emergency License Amendment Request: Technical Specification 3.6.5, Containment Air Temperature, One-Time Temporary Change to Limit2023-08-23023 August 2023 Response to Request for Additional Information Regarding Emergency License Amendment Request: Technical Specification 3.6.5, Containment Air Temperature, One-Time Temporary Change to Limit NL-23-0716, Response to Request for Additional Information Regarding Emergency License Amendment Request: Technical Specification 3.6.5, Containment Air Temperature, One-Time Temporary Change to Limit2023-08-23023 August 2023 Response to Request for Additional Information Regarding Emergency License Amendment Request: Technical Specification 3.6.5, Containment Air Temperature, One-Time Temporary Change to Limit NL-23-0704, Emergency License Amendment Request: Technical Specification 3.6.5, Containment Air Temperature, One-Time Temporary Change to Limit2023-08-22022 August 2023 Emergency License Amendment Request: Technical Specification 3.6.5, Containment Air Temperature, One-Time Temporary Change to Limit NL-23-0658, Southern Nuclear Operating Company - Response to Request for Additional Information Regarding Quality Assurance Topical Report Submittal2023-08-11011 August 2023 Southern Nuclear Operating Company - Response to Request for Additional Information Regarding Quality Assurance Topical Report Submittal NL-23-0542, CFR 50.46 ECCS Evaluation Model Annual Report for 20222023-08-0909 August 2023 CFR 50.46 ECCS Evaluation Model Annual Report for 2022 NL-23-0624, Report of Changes to Emergency Plan and Summary of 50.54(q) Analysis2023-08-0404 August 2023 Report of Changes to Emergency Plan and Summary of 50.54(q) Analysis NL-23-0628, Readiness for Supplemental Inspection EA-22-1012023-07-26026 July 2023 Readiness for Supplemental Inspection EA-22-101 NL-23-0566, ISFSI and Edwin I. Hatch Nuclear Plant ISFSI - Registration of Spent Fuel Cask Use2023-07-13013 July 2023 ISFSI and Edwin I. Hatch Nuclear Plant ISFSI - Registration of Spent Fuel Cask Use NL-23-0555, Request for Exemption from Physical Barrier Requirement2023-07-0707 July 2023 Request for Exemption from Physical Barrier Requirement NL-23-0506, to Non-Voluntary License Amendment Request: Technical Specification Revision to Adopt WCAP-17661-P-A, Improved RAOC and CAOC Fq Surveillance Technical Specifications2023-07-0505 July 2023 to Non-Voluntary License Amendment Request: Technical Specification Revision to Adopt WCAP-17661-P-A, Improved RAOC and CAOC Fq Surveillance Technical Specifications NL-23-0444, Quality Assurance Topical Report Submittal2023-06-15015 June 2023 Quality Assurance Topical Report Submittal NL-23-0457, ISFSI, and Edwin I. Hatch Nuclear Plant, ISFSI - Registration of Spent Fuel Cask Use2023-06-12012 June 2023 ISFSI, and Edwin I. Hatch Nuclear Plant, ISFSI - Registration of Spent Fuel Cask Use NL-23-0449, National Pollutant Discharge Elimination System (NPDES) Permit Renewal Application2023-06-0202 June 2023 National Pollutant Discharge Elimination System (NPDES) Permit Renewal Application NL-23-0383, SNC Response to Regulatory Issue Summary 2023-01:Preparation And.2023-05-19019 May 2023 SNC Response to Regulatory Issue Summary 2023-01:Preparation And. NL-23-0372, Units 1 & 2, Joseph M. Farley Nuclear Plant - Units 1 & 2, Vogtle Electric Generating Plant - Units 1 & 2, Annual Radiological Environmental Operating Reports for 20222023-05-10010 May 2023 Units 1 & 2, Joseph M. Farley Nuclear Plant - Units 1 & 2, Vogtle Electric Generating Plant - Units 1 & 2, Annual Radiological Environmental Operating Reports for 2022 NL-23-0337, Response to Request for Additional Information Related to License Amendment Request to Revise the Frequency of Surveillance Requirement 3.6.3.52023-05-0505 May 2023 Response to Request for Additional Information Related to License Amendment Request to Revise the Frequency of Surveillance Requirement 3.6.3.5 NL-23-0295, Reply to a Notice of Violation; EA-22-1012023-05-0101 May 2023 Reply to a Notice of Violation; EA-22-101 NL-23-0310, Annual Non-Radiological Environmental Operating Reports and Annual Radioactive Effluent Release Reports for 20222023-04-25025 April 2023 Annual Non-Radiological Environmental Operating Reports and Annual Radioactive Effluent Release Reports for 2022 NL-23-0019, GEN-ISI-ALT-2023-01, Request to Use Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI2023-04-12012 April 2023 GEN-ISI-ALT-2023-01, Request to Use Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI NL-23-0263, Southern Nuclear Company Submittal of Drug and Alcohol Testing Errors Identified 10 CFR 26.719(c) 30-Day Report2023-04-0505 April 2023 Southern Nuclear Company Submittal of Drug and Alcohol Testing Errors Identified 10 CFR 26.719(c) 30-Day Report NL-23-0208, Independent Spent Fuel Storage Installation ISFSI, Decommissioning Funding Plan Triennial Update2023-03-29029 March 2023 Independent Spent Fuel Storage Installation ISFSI, Decommissioning Funding Plan Triennial Update 2024-07-03
[Table view] Category:Proprietary Information Review
MONTHYEARML24201A2032024-08-0101 August 2024 Request for Withholding Information from Public Disclosure for Joseph M. Farley Nuclear Plant, Units 1 and 2, License Amendment Request to Change Technical Specification 3.6.5, Containment Air Temperature Actions ML23345A1312024-01-0303 January 2024 Withholding Letter - SNC Fleet - Physical Barriers Exemption (L-2023-LLE-0018 and L-2023-LLE-0021) ML22311A5122022-11-29029 November 2022 Request for Withholding Information from Public Disclosure License Amendment Request to Revise TS 4.3, Fuel Storage, to Correct Tabulated Values from the Associated SFP Criticality Analysis ML20280A6852020-10-26026 October 2020 Request for Withholding Information from Public Disclosure for Joseph M. Farley, Units 1 and 2 ML20216A3182020-08-13013 August 2020 Request for Withholding Information from Public Disclosure for Joseph M. Farley Nuclear Plant, Units 1 and 2 - Measurement Uncertainty Recapture Power Uprate NL-20-0828, Attachment 5 - Caw 20-05, Application for Withholding Proprietary Information from Public Disclosure2020-06-24024 June 2020 Attachment 5 - Caw 20-05, Application for Withholding Proprietary Information from Public Disclosure ML20115E6182020-05-0404 May 2020 Request for Withholding Information from Public Disclosure ML18312A2412018-11-15015 November 2018 Request for Withholding Information from Public Disclosure - November 13, 2018, Closed Meeting Presentation Slides ML18116A0062018-05-0404 May 2018 Request for Withholding Information from Public Disclosure ML15051A3302015-02-27027 February 2015 Request for Withholding Information from Public Disclosure ML14175A5562014-07-0202 July 2014 Request for Withholding Information from Public Disclosure for Joseph M. Farley ML13199A1582013-08-0505 August 2013 Request for Withholding Information from Public Disclosure, Relief Request of Proposed Inservice Inspection Alternative FNP-ISI-ALT-13, Version 1.0 ML0835203162009-06-0909 June 2009 Request Westinghouse Electric Company Withholding Information from Public Disclosure ML0413804262004-05-17017 May 2004 Withholding from Public Disclosure, WCAP-12825, Addendum 1 ML0313404722003-05-14014 May 2003 Proprietary Information Reviews, Request for Withholding Information from Public Disclosure-Westinghouse Electric Company, TAC MB8007 & TAC MB8008 2024-08-01
[Table view] |
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Supplement to LAR for MUR-PU (NL-20-0828) Page 36 of43 Attachment 5 CAW 20-05, APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Page 37 of43 Cameron Technologies US LLC June 24, 2020 CAW20-05 Document Control Desk U. s. Nuclear Regulatory Commission Washington, DC 20555 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION .FROM PUBLIC DISCLOSURE
Subject:
Rev. 1 Errata documents supplementing Cameron Engineering ReportER-1180P Rev. 1 and Rev.
1 Errata "Bounding Uncertainty Amalysis for Thermal Power Determination at Farley Unit 1 Using the LEFM., + System" and ER-1181 P Rev. 1 and Rev 1. Errata *isounding Uncertainty Analysis for Thermal Power Determination at Farley Unit 2 Using the LEFM .., + System" Gentlemen:
This application for-withholding is submitted by Cameron Technologies US, LLC, a Delaware limited liability company (herein called "Cameron") pursuantto the provisions of paragraph (b)(1) of Section 2.390 ofthe Commission's regulations. it contains trade secrets and/or *commercial information proprietary to Cameron and customarily held in confidence.
The proprietary information for which withholding is being requested is identified in the subject submittal. In conformance with 10CFR Section 2.390, Affidavit CAW 20-05 accompanies this application for withholding setting forth the basis on which the identified proprietary information may be withheld from public disclosure.
Accordingly, it is respectfully requested thatthe subject information, which is proprietary to Cameron, be withheld from public disclosure. in accordance with 10 CFR Section 2.390 of the Commission's regulations.
Correspondence with respect to this application for withholding or the accompanying affidavit should reference CAW 20-05 and should be addressed to the undersigned.
~;~
cZ:'~na Phillips Nuclear Sates Manager Enclosures (Only upon separation of the enclosed confidential material should this letter and affidavit be released:)
1
Supplement to LAR for MUR-PU (NL-20-0828)
?JiiJ82°4;1020 CAW2O-05 AFFIDA\iiT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF ALLEGHENY:
Before me, the undersigned authority, personally appeared Joanna Phillips, who, being by me duly sworn according t9 law, deposes and says that she is authorized to t:xecute this Affidavit on behalf of Cameron Technologies US, LLC, a Delaware limited liability company (herein called "Cameron"},.and that the averments of fact set forth in this Affidavit are true and correct to the best of her knowledge, information, and belie.f. . .* . *. ~ . .. -. **.**
~***.
J~hillips Nuclear Sales Manager Signed and sworn to before me thi~ j4 Th day of if&'"- .2020 JJ\llN\wA. -~h-\M Notary Public C*mmol)weallh of Pennsylvania - Notary Seal Frances A. Lewis, Notary Public Allegheny County My commission expires November 25, 2022 Commlss_lon number 1287160 Member,.Pennsylvani11.Assoeiation of Notaries 1
Supplement to LAR for MUR-PU (NL-20-0828)
Jff'iiJ 2°4;~ 0 2 0 9
CAW20-05
- 1. I am the Nuclear Sales Manager for Caldon Technologies US, LLC, and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be Withheld from public disclosure in connection with nuclear power plant licensing and rulemaking proceedings, and am autho.rized to apply for its* wi:thholdjng on behalf of Cameron.
- 2. I am making t;his Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Cameron application for withholding accompanying this Affidavit.
- 3. I have personal knowledge of the criteria and procedures utilized by Cameron in designating information as a trade secret, privileged or as confidential commercicd or financial information.
- 4. Cameron requests that the information identified in paragraph S(v) below be withheld from the public on the following bases:
Trade secrets and commercial information obtained from a person and privileged or confidential The material and information provided herewith is so designated by Cameron, in accordance with those criteria and procedures, for the reasons set forth below.
- 5. Pursuant to the provisions of paragraph (b) (4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether -the information sought to be withheld from public disclosure should be withheld.
(i) The information sought to he withheld from public disclosure is owned and has be~n held in confidence by Cameron.
(ii) The information is of a type customarily held in confidence by Cameron and not customarily disclosed to the public. Cameron has a rational basis for determining the types of information customarily held in confidence by it and, in that connection utilizes a 2
Supplement to LAR for MUR-PU (NL-20-0828) Page 40 of43 June 24, 2020 CAW20-05 system to determine when and whether to hold certain types of information in confidence; The application of that system and the substance .of that system constitutes Cameron policy and provides the rational basis required. Furthermore, the information is submitted voluntarily arid need not rely on the evaluation of any rational basis.
Under that system, information is held in confidence if it falls in one or more of several types, the release ofwhich might result in the loss of an existing or potential advantage, as follows:
(a) The information reveals the distinguishing aspects of a proqess (or component, structure, tool, method, etc.) where prevention ofits use by any of Cameron's competitors with.out license from Cameron constitutes a competitive economic advantage over other companies.
{b) It consists of supporting data, including test data, relative to a process (or component, 'structure, tool, me~hod, etc.), the application of which data secures a competitive.economic advantage, e.g,, by optimization or improved marketability.
(c) Its use by a competitor would reduce his expenditure ofresources or improve his competitive position in the destgn, manufacture, shipment, installation, and assurance of quality, or licensing a similar product.
(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Cameron, its customer or suppliers.
(e) It reveals aspects of past, present or future Cameron or cu_stomer funded development plans and programs of potential customer value to Cameron.
(f) It contains patentable ideas, for which patent protection may be desirable.
The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (a), (b) and (c), above.
3
Supplement to LAR for MUR-PU {NL-20-0828) Page41 of43 June 24, 2020 CAW20-0S There are sound policy reasons behind the Cameron system, which include the following:
(a) The use of such information by Camerop_ gives Cameron a competitive advantage over its competitors. It. is, therefore, withheld from disclosure to protect the Carneron competitive position.
(b) It is information th~t is marketable in 11,1any ways. The e:xtent to which suth information is availableto competitors diminishes the Cameron ability to sell products or services involving the use of the information.
(c) Use by our competitor would put Cameron at a competitive disadvantage by reducing his expenditure of resources at our expense.
(d) Each component of proprietary information pertinentto a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire c;omponents Qf proprietary information, any one component may be the key to the entire puzzle, thereby depriving Cameron of a competitive advantage.
(e) Unres.tricted disclosure would jeopardize the position of prominence of Cameron in the world Illarket, and thereby give a market advantage to the competition of those countries.
(f) The Cameron capacity to invest corporate assets in research and development depends upon the success iri obtaining and maintaining a competitive advantage.
(iii) The .information is being transmitted to the Commission in confidence, and, under the provisions of 10 CFR §§ 2. 390, it ts to bereceived in confidence by the Commission.
4
Supplement to LAR for MUR-PU (NL-20-0828) Page 42 of43 June 24, 2020 CAW20-05 (iv) The information soughtto be protected is not available in public sources or available information has not been previously employed in the same manner or method to the best of our knowledge and belief.
(v) The proprietary information sought to be withheld is the Rev. 1 Errata supplemental documents submitted for:
Cameron Engineering Report ER-1180 Rev. 1 and Rev.1 Errata "Bounding Uncertainty Analysis for Thermal Power Determination at Farley Unit 1 Using the LEFM.; + System
Cameron Engineering Report ER-1181 Rev. 1 and Rev. 1 Errata "Bounding Uncertainty Analysis for Thermal Power Determination at Farley Unit 2 Using the LEFM.; + System"
- Rev. 1 and Rev. 1 Errata Page 4 and 5 of each Report contain partial proprietary information It is designated therein in accordance with 1_0 CFR §.§ 2.390(b)(l)(i)(A,B), with the reason(s) for confidential treatment note4 in the submittal and further described in this affidavit. This information is voluntarily submitted for use by the NRC Staff in their review of the accuracy assessment of the proposed methodology for the LEFM CheckPlus System used by Farley Unit 1 for flow measurement at the licensed reactor thermal power level of2821 MWt Pub.lie disclosure of this proprietary information ii, likely to cause substantial harm to the competitive position *of Cameron because it would enhance the ability of competitors to provide similar flow and temperature measu:rementsystems and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without the .right to*usethe information.
The development of the technology described in part by the information is the result of applying the results of many years ofexperience in an intensive Cameron effort and the expenditure of a considerable sum of money.
In order for competitors of Cameron to duplicate this information, similar products would have to be developed, similar technical programs would have to be performed, and a significant 5
Supplement to LAR for MUR-PU (NL-20-0828)
J~lie4~t42020 CAW20-05 manpower effort, having the-requisite talent and experience, would have to be expended for developing analytical methods and receiving NRC approval for those methods.
Further the deponent sayeth not 6