ML21239A115
| ML21239A115 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/13/2021 |
| From: | Polickoski J Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML21239A124 | List: |
| References | |
| CNL-21-072, EPID L-2020-LLA-0004 | |
| Download: ML21239A115 (9) | |
Text
Proprietary Information - Withhold from Public Disclosure Under 1 O CFR 2.390 This letter is decontrolled when separated from Enclosure 2 1\\14 TENNESSEE VALLEY AUTHORITY 1101 Market Street, Chattanooga, Tennessee 37402 CNL-21-072 August13, 2021 ATTN : Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Sequoyah Nuclear Plant, Units 1 and 2 Renewed Facility License Nos. DPR-77 and DPR-79 NRC Docket Nos. 50-327 and 50-328 10 CFR 50.90
Subject:
Partial Response to Additional Request for Additional Information, (QUESTION 2) Regarding Application to Revise Sequoyah Nuclear Plant, Units 1 and 2 Updated Final Safety Analysis Report Regarding Changes to Hydrologic Analysis - Correction of Submitted File Types Contained on Digital Versatile Disc (TS-19-02) (EPID L-2020-LLA-0004)
References:
- 1. TVA Letter to NRC, CNL-21-024, "Partial Response to Additional Request for Additional Information, (QUESTION 2) Regarding Application to Revise Sequoyah Nuclear Plant Units 1 and 2 Updated Final Safety Analysis Report Regarding Changes to Hydrologic Analysis (TS-19-02)
(EPID L-2020-LLA-0004)," dated June 15, 2021 (ML21203A335 and ML21208A030)
In Reference 1, Tennessee Valley Authority (TVA) submitted a response to a Nuclear Regulatory Commission (NRC) Request for Additional Information (RAI). In Reference 1, contained two electronic file documents on a Digital Versatile Disc (DVD) to support A z::: 2 TVA's RAI response. Upon submittal, the DVD documents were reviewed for acceptability per D~.:...>
NRC documentation requirements. Both submitted documents contained embedded attachments and file types that did not meet NRC acceptance requirements for electronic file ~ 3 D
submittals.
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Proprietary Information - Withhold from Public Disclosure Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosure 2
- J~R
Proprietary Information - Withhold from Public Disclosure Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosure 2 U.S. Nuclear Regulatory Commission CNL-21-072 Page 2 August 13, 2021 Therefore, this letter resubmits the DVD containing the document files previously submitted in Reference 1, but in a revised format that meets NRC documentation standards for acceptance.
To meet NRC preflight approval standards, TVA restructured the previously attached PDF files to the base PDF documents. Non-PDF files have been removed from the PDF document files and placed in separate folders on the DVD for retention in the NRC library.
The Reference 1 RAI response remains valid. None of the calculation technical content nor the responses previously submitted in Reference 1 have been changed. This letter and the enclosed DVD only serves as a replacement of the original DVD to meet NRC documentation requirements. of this letter provides a replacement DVD of digital versions of Barge Design Solutions, Inc., Software Dedication Report (SOR) 16-01, Revision 3 and non-proprietary TVA calculation CDQ0000002020000153, Revision 0, "Manual Computation of Grid Point PMP Depths" for NRC review. Only the SOR is considered proprietary. Enclosure 2 contains information that Barge Design Solutions (Barge) considers to be proprietary pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 2.390, "Public inspections, exemptions, requests for withholding," paragraph (a)(4). Enclosure 1 provides the Barge Design Solutions affidavit supporting this proprietary withholding request. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the NRC and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390. Accordingly, TVA requests that the information which is proprietary to Barge Design Solutions, Inc., be withheld from public disclosure in accordance with 1 O CFR Section 2.390. Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Barge Design Solutions, Inc. affidavit should be addressed to Carrie Stokes, Senior Vice President, Barge Design Solutions, Inc., 615 3rd Avenue S., Suite 700, Nashville, TN 37210.
TVA has determined that this letter does not change the no significant hazards considerations or the environmental considerations contained in previous hydrology submittals. Additionally, in accordance with 10 CFR 50.91 (b)(1 ), "Notice for Public Comment, State Consultation," TVA is sending a copy of this letter and the enclosures to the Tennessee Department of Environment and Conservation.
There are no new regulatory commitments associated with this submittal. Please address any questions regarding this submittal to Kimberly Hulvey, Senior Manager, Fleet Licensing at 423-751 -3275.
Proprietary Information -Withhold from Public Disclosure Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosure 2
Proprietary Information -Withhold from Public Disclosure Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosure 2 U.S. Nuclear Regulatory Commission CNL-21-072 Page 3 August 13, 2021 I declare under penalty of perjury that the foregoing is true and correct. Executed on this 13th day of August 2021.
Respectfully,
~
Zd?- ~
James T. Polickoski Director, Nuclear Regulatory Affairs
Enclosures:
- 1.
Barge Design Solutions, Inc., Affidavit
- 2.
DVD and List of Contents (Only the SDR 16-01, Revision 3 contains Proprietary Information) cc (Enclosures):
NRC Regional Administrator - Region II NRC Senior Resident Inspector - Sequoyah Nuclear Plant, Units 1 and 2 NRC Project Manager - Sequoyah Nuclear Plant Director, Division of Radiological Health - Tennessee State Department of Environment and Conservation Proprietary Information - Withhold from Public Disclosure Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosure 2 Barge Design Solutions, Inc., Affidavit CNL-21-072
)ss.
COUNTY OF DAVIDSON)
- 1.
My name is Carrie Stokes. I am Senior Vice President, for Barge Design Solutions, Inc. and as such I am authorized to execute this Affidavit.
- 2.
I am familiar with the criteria applied by Barge Design Solutions, Inc. to determine whether certain Barge Design Solutions, Inc. information is a trade secret, proprietary, and commercially sensitive. I am familiar with the policies established by Barge Design Solutions, Inc.
to ensure the proper application of these criteria.
report:
- 3.
I am familiar with the Barge Design Solutions, Inc. information contained in the "Software Dedication Report, PMP Evaluation Tool Package, SOR 16-01" dated April 2021 and referred to herein as "Dedication Report." Information regarding the dedication methodology and test problem suite has been classified by Barge Design Solutions, Inc.
as proprietary and a trade secret in accordance with the policies established by Barge Design Solutions, Inc. for the control and protection of proprietary information in furtherance of the business of Barge Design Solutions, Inc..
- 4.
This Dedication Report contains trade secrets and information of a proprietary nature of the type customarily held in confidence by Barge Design Solutions, Inc. and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in this Dedication Report as commercially sensitive, trade secrets, proprietary, and confidential.
- 5.
This Dedication Report 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 Barge Design Solutions, Inc. to determine whether information should be classified as proprietary:
(a)
The information reveals details of Barge Design Solutions, lnc.'s research and development processes 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.
(d)
The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for Barge Design Solutions, Inc. in product optimization or marketability.
(e)
The information is vital to a competitive advantage held by Barge Design Solutions, Inc., would be helpful to competitors, and would likely cause substantial harm to the competitive position of Barge Design Solutions, Inc.
The information in the Dedication Report is considered proprietary for the reasons set forth in paragraphs 6(a) - 6{e) above.
- 7.
In accordance with Barge Design Solutions, lnc.'s policies governing the protection and control of information, trade secrets and confidential or proprietary information contained in this Dedication Report have been made available, on a limited basis, to others outside Barge Design Solutions, Inc. only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8.
Barge Design Solutions, Inc. policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.
- 9.
The foregoing statements are true and correct to the best of my knowledge, information, and belief.
FURTHER AFFIANT SA VETH NOT.
SUBSCRIBED before me this 9th day of {lpf; )
Proprietary Information - Withhold from Public Disclosure Under 1 O CFR 2.390 This letter is decontrolled when separated from Enclosure 2
DVD List of Contents PDF Files for ADAMS
- 1.
CDQ0000002020000153 RO Combined File.pdf 2
SDR 16-01 R3 AWA EVAL Tool Combine Files.pdf Non-PDF Files for Retention in NRC Reading Room
- 1.
CDQ0000002020000153 Attachments
- a.
CDQ0000002020000153 Appendix A
- i.
Appendix A Attachments Proprietary Information Appendix_ A-1_ArcGIS_DAD_DBF _Extraction_Check_Files.zip Appendix_A-2_QGIS_DAD_DBF _Extraction_Check_Files.zip Appendix_A-3_ArcGIS_SAF _DBF _Extraction_Check_Files.zip Appendix_A-4_QGIS_SAF _DBF _Extraction_Check_Files.zip Appendix_A-5 _DAD _DBF _ExportCheck.xlsx Appendix_A-6_DBF _ExportCheck.xlsx CDQ0000002020000153_Appendix A-DAD and SAF Grid Point Data GIS Export Evaluation.docx DAD_ SAF _ ExportCheckCalculation Tables.xlsx
- b. CDQ0000002020000153 - Appendix B Appendix B Attachments.zip
- c.
CDQ0000002020000153 - Appendix C Appendix C Attachments.zip
- 2.
SDR 16-01 R3 Attachments Proprietary Information
- a. Attachment 2 - AWA Script Modification
- i. -AWA Script Modification.xlsx
- b. Attachment 3 - Test Suite Files
- i.
Attachments to Attachment 3 AWA_Dedication_GIS_Files.zip ExcelComparisonFiles.zip
- c. Att to Attachment 9
- i.
Modified_PMP _Evaluation_ Tool.zip CNL-21-072