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Category:Legal-Affidavit
MONTHYEARML23333A0192023-11-27027 November 2023 Att. K- Bill Powers 2023 Expert Declaration ML23265A5492023-09-22022 September 2023 Transmittal of WCAP-18830-P/NP Turkey Point Fuel Storage Criticality Analysis for 24 Month Cycles to Support a License Amendment Request from FPL - License Amendment Request 277 Updated Spent Fuel Pool Criticality Analysis L-2023-110, Response to Requests for Additional Information Regarding License Amendment Request No. 276, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project2023-08-25025 August 2023 Response to Requests for Additional Information Regarding License Amendment Request No. 276, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project L-2023-069, Response to Requests for Additional Information Regarding License Amendment Request No. 276, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project2023-05-31031 May 2023 Response to Requests for Additional Information Regarding License Amendment Request No. 276, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project L-2023-010, Supplemental Information Regarding License Amendment Request 274, Reactor Protection System, Engineered Safety Features Actuation System, and Nuclear Instrumentation System Replacement Project - Submittal of RPS / ESFAS / Nis2023-02-10010 February 2023 Supplemental Information Regarding License Amendment Request 274, Reactor Protection System, Engineered Safety Features Actuation System, and Nuclear Instrumentation System Replacement Project - Submittal of RPS / ESFAS / Nis L-2023-004, Supplemental Information Regarding License Amendment Request 274, Reactor Protection System, Engineered Safety Features Actuation System, and Nuclear Instrumentation System Replacement Project - Submittal of Huma Factors Results2023-01-17017 January 2023 Supplemental Information Regarding License Amendment Request 274, Reactor Protection System, Engineered Safety Features Actuation System, and Nuclear Instrumentation System Replacement Project - Submittal of Huma Factors Results L-2022-166, Response to Request for Supplemental Information Regarding License Amendment Request 274, Reactor Protection System, Engineered Safety Features Actuation System, and Nuclear Instrumentation System Replacement2022-10-0505 October 2022 Response to Request for Supplemental Information Regarding License Amendment Request 274, Reactor Protection System, Engineered Safety Features Actuation System, and Nuclear Instrumentation System Replacement ML22243A1622022-08-26026 August 2022 Submittal of License Amendment Request 276, Revise Fire Protection Program in Support of Reactor Coolant Pump Seal Replacement Project ML22172A2072022-06-16016 June 2022 Affidavit Dated June 16, 2022 ML22144A3922022-05-18018 May 2022 Affidavit Dated May 18 2022, Executed by Phillip A. Opsal - Framatome (Public Available) L-2022-073, Diversity and Defense-In-Depth Evaluation (D3), Framatome Document No. 51-9324096-0042022-05-0303 May 2022 Diversity and Defense-In-Depth Evaluation (D3), Framatome Document No. 51-9324096-004 ML22101A2042022-04-0606 April 2022 Nextera/Fpl Affidavit for Proprietary Presentation for April 13, 2022 Public Meeting Re Planned Turkey Point Digital Instrumentation and Controls License Amendment Request ML22115A1772022-03-12012 March 2022 Affidavit Dated March 12 2022, Executed by Phillip A. Opsal - Framatome ML22063A4482022-03-0202 March 2022 Nextera/Fpl Affidavit for Proprietary Presentation for March 7, 2022, Public Meeting ML22047A1342022-02-14014 February 2022 Affidavit Dated February 14, 2022, Executed by Paul S. Manzon L-2021-213, Response to Request for Additional Information Regarding License Amendment Request 273, Update Listing of Approved LOCA Methodologies to Adopt Full Spectrum LOCA Methodology2021-11-19019 November 2021 Response to Request for Additional Information Regarding License Amendment Request 273, Update Listing of Approved LOCA Methodologies to Adopt Full Spectrum LOCA Methodology ML21200A1572021-07-18018 July 2021 July 18, 2021 - Framatome Affidavit for Nextera/Fpl Meeting Slides for July 22, 2021 Partially Closed Meeting Concerning Control Room Digital Modernization ML21159A1652021-06-0404 June 2021 Affidavit for Nextera Tricon Presentation for Turkey Point 5th Presubmittal Meeting ML21047A2152021-02-16016 February 2021 Affidavit for NRC Presubmittal Meeting Telecon February 18, 2021 Open Meeting - FPL Safety System Replacement Project LAR - Nonproprietary ML21011A2352021-01-11011 January 2021 Affidavit for Slides for January 13, 2021 Presubmittal Meeting with NextEra Concerning Digital I&C L-2020-104, Fifth Ten-Year Inservice Inspection Interval Relief Request No. 7 for Train a and B Component Cooling Water (CCW) Supply and Return Piping2020-09-18018 September 2020 Fifth Ten-Year Inservice Inspection Interval Relief Request No. 7 for Train a and B Component Cooling Water (CCW) Supply and Return Piping L-2018-193, Set 6 Responses to Request for Additional Information (RAI) on Subsequent License Renewal Application Safety Review2018-11-0202 November 2018 Set 6 Responses to Request for Additional Information (RAI) on Subsequent License Renewal Application Safety Review ML18299A1142018-10-24024 October 2018 Subsequent License Renewal Application Safety Review Requests for Additional Information (RAI) Set 4 Responses ML18296A0242018-10-16016 October 2018 Set 3 Response to Request for Additional Information to Subsequent License Renewal Application Safety Review L-2018-082, Turkey Point, Units 3 and 4 - Enclosure 2 to L-2018-082, Applications for Withholding Proprietary Information from Public Disclosure Per 10 CFR 2.390 (Public Version)2018-04-10010 April 2018 Turkey Point, Units 3 and 4 - Enclosure 2 to L-2018-082, Applications for Withholding Proprietary Information from Public Disclosure Per 10 CFR 2.390 (Public Version) ML18113A1422018-04-10010 April 2018 Enclosure 2 to L-2018-082, Applications for Withholding Proprietary Information from Public Disclosure Per 10 CFR 2.390 (Public Version) ML18053A1372018-02-16016 February 2018 Subsequent License Renewal Application - Supplement 2 L-2018-039, License Renewal Application - Supplement 12018-02-0909 February 2018 License Renewal Application - Supplement 1 L-2017-062, Request for Withholding Information from Public Disclosure Subsequent License Renewal Notification2017-03-30030 March 2017 Request for Withholding Information from Public Disclosure Subsequent License Renewal Notification L-2016-202, Notice of Intent to Pursue License Renewal, Request for Withholding from Public Disclosure2017-03-0303 March 2017 Notice of Intent to Pursue License Renewal, Request for Withholding from Public Disclosure L-2015-189, License Amendment Request 240, Conditional Exemption from End-of-Life Moderator Temperature Coefficient Measurement2015-10-0606 October 2015 License Amendment Request 240, Conditional Exemption from End-of-Life Moderator Temperature Coefficient Measurement ML12027A0422012-01-12012 January 2012 Westinghouse Input to NRC Frapcon Models Related to the Turkey Point Unit 3 & 4 Extended Power Uprate (EPU) License Amendment Request (LAR) (Cover Letter) L-2011-100, Response to NRC Request for Additional Information Regarding Extended Power Uprate License Amendment Request No. 205 and Nuclear Performance and Code Review Issues2011-05-18018 May 2011 Response to NRC Request for Additional Information Regarding Extended Power Uprate License Amendment Request No. 205 and Nuclear Performance and Code Review Issues ML1035601812010-12-20020 December 2010 License Amendment Request for Extended Power Uprate, Attachment 05; Westinghouse & Areva Affidavits for Attachment 4 L-2010-113, Turkey Point, Units 3 and 4 - License Amendment Request for Extended Power Uprate, Attachment 05; Westinghouse & Areva Affidavits for Attachment 42010-12-20020 December 2010 Turkey Point, Units 3 and 4 - License Amendment Request for Extended Power Uprate, Attachment 05; Westinghouse & Areva Affidavits for Attachment 4 L-2010-113, License Amendment Request for Extended Power Uprate, Attachment 13; Westinghouse Affidavit for Attachment 122010-08-11011 August 2010 License Amendment Request for Extended Power Uprate, Attachment 13; Westinghouse Affidavit for Attachment 12 L-2010-113, Turkey Point, Units 3 and 4 - License Amendment Request for Extended Power Uprate, Attachment 11; Westinghouse Affidavit for Attachment 102010-07-26026 July 2010 Turkey Point, Units 3 and 4 - License Amendment Request for Extended Power Uprate, Attachment 11; Westinghouse Affidavit for Attachment 10 ML1035601872010-07-26026 July 2010 License Amendment Request for Extended Power Uprate, Attachment 11; Westinghouse Affidavit for Attachment 10 L-2010-113, Turkey Point, Units 3 and 4 - License Amendment Request for Extended Power Uprate, Attachment 09; Cameron Affidavit for Attachment 82010-07-16016 July 2010 Turkey Point, Units 3 and 4 - License Amendment Request for Extended Power Uprate, Attachment 09; Cameron Affidavit for Attachment 8 ML1035601852010-07-16016 July 2010 License Amendment Request for Extended Power Uprate, Attachment 09; Cameron Affidavit for Attachment 8 ML18228A1321979-03-0909 March 1979 Licensee'S Response to Untimely Request for Hearing of Mark P. Oncavage L-78-323, Submit Supplemental Information for Proposed Amendment to Facility Operating Licenses to Operate Until Next Refueling Prior to Conducting Steam Generator Inspection1978-10-0202 October 1978 Submit Supplemental Information for Proposed Amendment to Facility Operating Licenses to Operate Until Next Refueling Prior to Conducting Steam Generator Inspection ML18227B3061978-08-25025 August 1978 Application for Extension of Time L-78-264, 08/09/1978 Letter Order for Amendment to Facility Operating Licenses DPR-31 & DPR-411978-08-0909 August 1978 08/09/1978 Letter Order for Amendment to Facility Operating Licenses DPR-31 & DPR-41 L-78-233, 07/11/1978 Letter Request to Amend Appendix a of Facility Operating Licenses1978-07-11011 July 1978 07/11/1978 Letter Request to Amend Appendix a of Facility Operating Licenses L-78-217, 06/22/1978 Letter Proposed Modifications to Technical Specification Figure 2.1-1, Reactor Core Thermal and Hydraulic Safety Limits, Three Loop Operation1978-06-22022 June 1978 06/22/1978 Letter Proposed Modifications to Technical Specification Figure 2.1-1, Reactor Core Thermal and Hydraulic Safety Limits, Three Loop Operation L-78-123, 04/10/1978 Response to Request for Additional Information Proposed Inservice Inspection and Pump & Valve Test Programs1978-04-10010 April 1978 04/10/1978 Response to Request for Additional Information Proposed Inservice Inspection and Pump & Valve Test Programs ML18227D4111978-03-0707 March 1978 Transmitting Steam Generator Repair Report, Revision 2 ML18227D8091978-01-27027 January 1978 01/27/1978 Letter Request to Amend Appendix a of Facility Operating Licenses ML18227B2801978-01-27027 January 1978 Submit Proposed Facility Operating Licenses with ECCS Reanalysis 2023-09-22
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Westinghouse Non-Proprietary Class 3 Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-5093 Document Control Desk e-mail: harperzs@westinghouse.com 11555 Rockville Pike Rockville, MD 20852 LTR-NRC-23-23 September 22, 2023
Subject:
Transmittal of WCAP-18830-P/NP Turkey Point Fuel Storage Criticality Analysis for 24 Month Cycles to Support a License Amendment Request from FPL - License Amendment Request 277 Updated Spent Fuel Pool Criticality Analysis Enclosed are proprietary and non-proprietary versions of WCAP-18830, Turkey Point Fuel Storage Criticality Analysis for 24 Month Cycles, September 2023. The WCAP provides the technical bases for the subject LAR.
The WCAP would normally be submitted by the Licensee (FPL) as an attachment to the LAR. However, due to the temporary restricted use of the data needed to validate the criticality safety analysis results, Westinghouse is providing WCAP-18830-P/NP and the associated Affidavit. This process has been discussed with the Turkey Point NRC project manager, Michael Mahoney.
This submittal contains proprietary information of Westinghouse Electric Company LLC (Westinghouse). In conformance with the requirements of 10 CFR Section 2.390, as amended, of the Nuclear Regulatory Commissions (Commissions) regulations, we are enclosing with this submittal an Affidavit. The Affidavit sets forth the basis on which the information identified as proprietary may be withheld from public disclosure by the Commission.
Correspondence with respect to the proprietary aspects of this submittal or the Westinghouse Affidavit should reference AW-23-040 and should be addressed to Camille T. Zozula, Interim Director, Management Systems and Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 1, Cranberry Township, PA 16066.
Zachary S. Harper, Manager Licensing Engineering cc: Ekaterina Lenning Michael Mahoney
Enclosures:
(1) Affidavit, AW-23-040 (2) WCAP-18830-P, Turkey Point Fuel Storage Criticality Analysis for 24 Month Cycles (Proprietary)
(3) WCAP-18830-NP, Turkey Point Fuel Storage Criticality Analysis for 24 Month Cycles (Non-proprietary)
© 2023 Westinghouse Electric Company LLC. All Rights Reserved.
Westinghouse Non-Proprietary Class 3 AFFIDAVIT AW-23-040 Page 1 of 3 Commonwealth of Pennsylvania:
County of Butler:
(1) I, Zachary Harper, Senior Manager, Licensing Engineering, have been specifically delegated and authorized to apply for withholding and execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse).
(2) I am requesting the proprietary portions of LTR-NRC-23-23 be withheld from public disclosure under 10 CFR 2.390.
(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged, or as confidential commercial or financial information.
(4) Pursuant to 10 CFR 2.390, 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 be withheld from public disclosure is owned and has been held in confidence by Westinghouse and is not customarily disclosed to the public.
(ii) The information sought to be withheld is being transmitted to the Commission in confidence and, to Westinghouses knowledge, is not available in public sources.
(iii) Westinghouse notes that a showing of substantial harm is no longer an applicable criterion for analyzing whether a document should be withheld from public disclosure. Nevertheless, 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.
Westinghouse Non-Proprietary Class 3 AFFIDAVIT AW-23-040 Page 2 of 3 (5) Westinghouse has policies in place to identify proprietary information. Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:
(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse 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, assurance of quality, or licensing a similar product.
(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.
(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.
(f) It contains patentable ideas, for which patent protection may be desirable.
(6) The attached documents are bracketed and marked to indicate the bases for withholding. The justification for withholding is indicated in both versions by means of lower-case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower-case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (5)(a) through (f) of this Affidavit.
Westinghouse Non-Proprietary Class 3 AFFIDAVIT AW-23-040 Page 3 of 3 I declare that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief. I declare under penalty of perjury that the foregoing is true and correct.
Executed on: 9/22/2023 _____________________________
Signed electronically by Zachary Harper