ML20245E181

Request for Withholding Information from Public Disclosure

ML20245E181
Person / Time
Site:	Watts Bar
Issue date:	10/23/2020
From:	Kimberly Green Plant Licensing Branch II
To:	Jim Barstow Tennessee Valley Authority
Green K, NRR/DORL/LPLII, 415-1627
References
EPID L-2019-LLS-0000
Download: ML20245E181 (4)

Text

October 23, 2020 Mr. James Barstow Vice President, Nuclear Regulatory Affairs and Support Services Tennessee Valley Authority 1101 Market Street, LP 4A-C Chattanooga, TN 37402-2801

SUBJECT:

WATTS BAR NUCLEAR PLANT, UNIT 2 - REQUEST FOR WITHHOLDING INFORMATION FROM PUBLIC DISCLOSURE (EPID L-2019-LLS-0000)

Dear Mr. Barstow:

By letter to the U.S. Nuclear Regulatory Commission (NRC) dated October 10, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19283G119), Tennessee Valley Authority (TVA) submitted affidavits dated August 14 and 28, 2019, executed by Joanna Phillips, Nuclear Sales Manager, Cameron Technologies US, Inc., requesting that the information contained Cameron Engineering Report ER-734 Revision 2, Bounding Uncertainty Analysis for Thermal Power Determination at Watts Bar Unit 2 Using the LEFM+ System, and Cameron Engineering Report ER-732 Revision 0, Meter Factor Calculation and Accuracy Assessment for Tennessee Valley Authority, Watts Bar Nuclear Plant Unit 2, be withheld from public disclosure pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 2.390.

The NRC subsequently determined that the information requested to be withheld is proprietary and issued a determination by letter dated January 7, 2020 (ADAMS Accession No. ML19339E088).

During its review of the license amendment request (LAR), the NRC staff identified some information that was marked as proprietary in ER-734 Revision 2 but was not marked accordingly in the LAR. Therefore, by , (WBN-TS-19-28)|letter dated July 27, 2020]] (ADAMS Accession No. ML20210M034), TVA submitted an affidavit dated July 8, 2020, executed by Joanna Phillips, Nuclear Sales Manager, Cameron Technologies US, LLC (Cameron), requesting that the information contained in Cameron Engineering Report ER-734 Revision 3, Bounding Uncertainty Analysis for Thermal Power Determination at Watts Bar Unit 2 Using the LEFM+

System, be withheld from public disclosure pursuant to 10 CFR 2.390. Revision 3 was submitted to correct the proprietary marking discrepancies. The NRC staff notes that since the submittal of ER-734 Revision 2, Sensia LLC acquired Cameron. Cameron Technologies US, LLC, is a wholly owned subsidiary of Sensia LLC.

Prior to the NRCs determination regarding whether ER-734 Revision 3 should be withheld from public disclosure, TVA submitted a letter dated August 28, 2020 (ADAMS Accession No. ML20244A300), which contained an affidavit dated August 17, 2020, executed by

J. Barstow Joanna Phillips, requesting that the information in the following document be withheld from public disclosure pursuant to 10 CFR 2.390:

Cameron Engineering Report ER-734 Rev 4, Bounding Uncertainty Analysis for Thermal Power Determination at Watts Bar Unit 2 Using the LEFM+ System A nonproprietary copy of this document has been placed in the NRCs Public Document Room and added to the NRC Library in ADAMS.

In the August 28 letter, TVA explained that Cameron identified an error regarding certain input parameters used in the calculation of the system mass flow and thermal power measurement uncertainty values in Engineering Reports ER-734P and ER-734NP, Revision 3. As a result, TVA submitted ER-734P and ER-734NP, Revision 4, which supersede Revision 3, and requested withdrawal of Revision 3 of the reports.

The NRC acknowledges TVAs request to withdraw ER-734P and ER-734NP, Revision 3.

The August 17, 2020, affidavit stated that the submitted information should be withheld from public disclosure for one or more of the following reasons:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Camerons competitors without a 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, method, 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 of resources or improve his competitive position in the design, manufacture, shipment, installation, and assurance of quality, or licensing a similar product.

We have reviewed your application and the material in accordance with the requirements of 10 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 version 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

J. Barstow 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 regarding this matter, I may be reached at 301-415-1627.

Sincerely,

/RA/

Kimberly J. Green, Senior Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-391 cc: Ms. Joanna Phillips Nuclear Sales Manager Cameron Technologies US, LLC 1000 McClaren Woods Drive Coraopolis, Pennsylvania 15216 cc: Listserv

ML20245E181 *by e-mail OFFICE NRR/DORL/LPL2-2/PM NRR/DORL/LPL2-2/LA NRR/DEX/EICB/BC*

NAME KGreen BAbeywickrama MWaters DATE 10/02/2020 09/29/2020 10/15/2020 OFFICE NRR/DORL/LPL2-2/BC* NRR/DORL/LPL2-2/PM NAME UShoop KGreen DATE 10/23/2020 10/23/2020