ML20265A287

From kanterella
Jump to navigation Jump to search

Request for Withholding Information from Public Disclosure Submittals for a Digital Upgrade
ML20265A287
Person / Time
Site: Waterford Entergy icon.png
Issue date: 10/01/2020
From: Audrey Klett
Plant Licensing Branch IV
To:
Entergy Operations
Klett A
References
EPID L-2020-LLA-0164
Download: ML20265A287 (5)


Text

October 1, 2020 Site Vice President Entergy Operations, Inc.

Waterford Steam Electric Station, Unit 3 17265 River Road Killona, LA 70057-3093

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3 - REQUEST FOR WITHHOLDING INFORMATION FROM PUBLIC DISCLOSURE RE:

SUBMITTALS FOR A DIGITAL UPGRADE (EPID L-2020-LLA-0164)

Dear Sir or Madam:

By letter W3F1-2020-0040 dated June 16, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20168A904), Entergy Operations, Inc. (the licensee) submitted two affidavits dated April 6 and June 8, 2020, which were executed by Mr. Zachary S. Harper for Westinghouse Electric Company LLC, requesting that the U.S.

Nuclear Regulatory Commission (NRC) withhold the following attachments to the enclosure of letter W3F1-2020-0040 from public disclosure pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Part 2, Section 2.390:

, WCAP-18484-P, Revision 0, Licensing Technical Report for the Waterford Steam Electric Station Unit 3 Common Q Core Protection Calculator System, Proprietary

, Westinghouse Specification 00000-ICE-30158, Revision 14, System Requirements Specification for the Common Q Core Protection Calculator System, Proprietary

, Westinghouse Specification WNA-DS-04517-CWTR3, Revision 2,

[Waterford 3] System Requirements Specification for the Core Protection Calculator System, Proprietary

, Westinghouse Specification 00000-ICE-3338, Revision 0, Failure Modes and Effects Analysis for the Common Q Core Protection Calculator System, Proprietary 0, Westinghouse Specification WNA-AR-00909-CWTR3, Revision 1,

[Waterford 3] Failure Modes and Effects Analysis for the Core Protection Calculator System, Proprietary 1, Westinghouse Specification EQ-QR-400-CWTR3, Revision 0, Core Protection Calculator System Primary Digital Components Qualification Summary Report for Waterford Unit 3, Proprietary

A nonproprietary version of Attachment 4 (Attachment 6 of letter W3F1-2020-0040 dated June 16, 2020), has been placed in the NRCs Public Document Room and added to the NRC Library in ADAMS at the above-referenced Accession No. ML20168A904.

The affidavits dated April 6 and June 8, 2020, stated that the submitted information in Attachments 4, 7, 8, 9, 10, and 11 to the enclosure of letter W3F1-2020-0040 should be considered exempt from mandatory public disclosure for the following reasons:

4(i)

The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse and is not customarily disclosed to the public.

4(ii)

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications 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 purchasing the right to use the information.

By letter W3F1-2020-0038 dated July 23, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20205L588), Entergy Operations, Inc.

submitted two affidavits dated April 6 and July 7, 2020, which were executed by Mr. Zachary S.

Harper for Westinghouse Electric Company LLC, requesting that the NRC withhold the following attachments to the enclosure of letter W3F1-2020-0038 from public disclosure pursuant to 10 CFR 2.390:

, WCAP-18484-P, Revision 0, Licensing Technical Report for the Waterford Steam Electric Station Unit 3 Common Q Core Protection Calculator System, Proprietary

, Westinghouse Specification 00000-ICE-30158, Revision 14, System Requirements Specification for the Common Q Core Protection Calculator System, Proprietary

, Westinghouse Specification WNA-DS-04517-CWTR3, Revision 2,

[Waterford 3] System Requirements Specification for the Core Protection Calculator System, Proprietary

, Westinghouse Calculation WNA-CN-00572-CWTR3, Revision 0, Core Protection Calculator System Response Time Calculation, Proprietary 0, Westinghouse Specification WNA-AR-00909-CWTR3, Revision 1, Failure Modes and Effects Analysis for the Core Protection Calculator System, Proprietary 1, Westinghouse EQ-QR-400-CWTR3, Revision 0, Core Protection Calculator System Primary Digital Components Qualification Summary Report for Waterford Unit 3, Proprietary

A nonproprietary version of Attachment 4 (Attachment 6 of letter W3F1-2020-0038 dated July 23, 2020), has been placed in the NRCs Public Document Room and added to the NRC Library in ADAMS at the above-referenced Accession No. ML20205L588.

The affidavits dated April 6 and July 7, 2020, stated that the submitted information in Attachments 4, 7, 8, 9, 10, and 11 to the enclosure of letter W3F1-2020-0038 should be considered exempt from mandatory public disclosure for the following reasons:

4(i)

The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse and is not customarily disclosed to the public.

4(ii)

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications 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 purchasing the right to use the information.

The NRC staff has reviewed the submittals in accordance with the requirements of 10 CFR 2.390 and, based on the statements in the affidavits, has determined that the submitted information sought to be withheld (i.e., Attachments 4, 7, 8, 9, 10, and 11 of the enclosures to letters W3F1-2020-0040 and W3F1-2020-0038) contains proprietary commercial information and should be withheld from public disclosure.

Therefore, the aforementioned documents 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, the NRC may send copies of this information to its consultants. The NRC will ensure that its 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, the licensee should promptly notify the NRC. The NRC may revisit this determination in the future if, for example, the scope of a Freedom of Information Act request includes this information. The NRC will notify the licensee in advance of any public disclosure if the NRC makes such a determination.

Any questions regarding this matter can be directed to me at 301-415-0489 or Audrey.Klett@nrc.gov.

Sincerely,

/RA/

Audrey L. Klett, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-382 cc: Camille T. Zozula Manager, Infrastructure & Facilities Licensing Ref. CAW-20-5031, CAW-20-5040, CAW-20-5064 Westinghouse Electric Company 1000 Westinghouse Drive, Suite 165 Cranberry Township, PA 16066 Listserv

ML20265A287

  • by e-mail OFFICE NRR/DORL/LPL4/PM*

NRR/DORL/LPL4/LA*

NRR/DSS/SNSB/BC*

NAME AKlett PBlechman SKrepel DATE 09/28/2020 09/22/2020 09/29/2020 OFFICE NRR/DRO/IOLB/BC*

NRR/DRO/IQVB/BC*

NRR/DEX/EICA/BC*

NAME CCowdrey KKavanagh JJohnston DATE 09/28/2020 09/28/2020 09/30/2020 OFFICE NRR/DEX/EICB/BC*

NRR/DORL/LPL4/BC*

NRR/DORL/LPL4/PM*

NAME MWaters JDixon-Herrity AKlett DATE 09/28/2020 10/01/2020 10/01/2020