ML24215A404

Request for Withholding Information from Public Disclosure

ML24215A404
Person / Time
Site:	Limerick   (NPF-039, NFP-085)
Issue date:	09/18/2024
From:	Robert Kuntz NRC/NRR/DORL/LPL3
To:	Rhoades D Constellation Energy Generation, Constellation Nuclear
Kuntz R, NRR/DORL/LPL3
References
EPID L-2022-LLA-0140
Download: ML24215A404 (1)

Text

September 18, 2024 David P. Rhoades Senior Vice President Constellation Energy Generation, LLC President and Chief Nuclear Officer Constellation Nuclear 4300 Winfield Rd.

Warrenville, IL 60555

SUBJECT:

LIMERICK GENERATING STATION, UNITS 1 AND 2 - REQUEST FOR WITHHOLDING INFORMATION FROM PUBLIC DISCLOSURE (EPID L-2022-LLA-0140)

Dear David Rhoades:

By letters dated August 12 (Agencywide Documents Access and Management System Accession No. ML22224A149) and November 29, 2022 (ML22333A817), July 31, 2023 (ML23212B236), and January 26 (ML24026A296), May 3 (ML24124A043), June 14 (ML24166A114), and June 28, 2024 (ML24180A156), you submitted affidavits dated July 11, August 5, and November 14, 2022, July 7 and July 20, 2023, and March 4, June 12, and June 19, 2024, executed by Zachary Harper, Manager, Licensing Engineering, Westinghouse Electric Company LLC. Also, by letter dated January 26, 2024, you submitted an affidavit dated January 25, 2024, executed by Anthony Schoedel, Manager, Advanced reactors Licensing, Westinghouse Electric Company LLC. In the letters you requested that the information contained in the following documents be withheld from public disclosure pursuant to Section 2.390 of Title 10 of the Code of Federal Regulations (10 CFR):

WNA-AR-01074-GLIM-P, Limerick Generating Station Defense in Depth and Diversity Common Cause Failure Coping Analysis, Revision 2 WCAP-18598-P, Licensing Technical Report for the Limerick Generating Station Units 1&2 Digital Modernization Project, Revision 0 WCAP-17179-P, AP1000 Component Interface Module Technical Report, APP-GW-GLR-143, Revision 6 WNA-AR-01074-GLIM-N, Limerick Generating Stations Units 1 & 2 Defense in Depth and Diversity Common Cause Failure Coping Analysis, Revision 3 WCAP-18598-P, Licensing Technical Report for the Limerick Generating Station Units 1&2 Digital Modernization Project, Revision 2 LIM-24-066-P, Limerick NRC Equipment Qualification Request for Additional Information, Revision 1

WEC LIM-24-085-P, Limerick Units 1 and 2 Digital Modernization Project, Component Interface Module (CIM) Request for Additional Information (RAI) - Round 2, Revision 2 EQ-EV-386-GLIM-P, Comparison of Equipment Qualification Hardware Testing for Common Q Applications to Limerick Requirements, Revision 2 EQ-QR-433-GLIM-P, Qualification Summary Report for the Plant Protection System Upgrade for Limerick Units 1 & 2, Revision 4 APP-GW-GLR-611-P, ITAAC 2.5.02.14: Component Interface Module Design Process Technical Report, Revision 3 Nonproprietary copies of these document have been placed in the U.S. Nuclear Regulatory Commissions (NRCs) Public Document Room and added to the NRC Library in the Agencywide Documents Access and Management System (ADAMS).

The affidavits stated that the submitted information should be considered exempt from mandatory public disclosure for the following reasons:

(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 Westinghouses 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.

We have reviewed your application and the material in accordance with the requirements of 10 CFR 2.390 and, on the basis of 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(s) 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 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 301-415-3733.

Sincerely,

/RA/

Robert F. Kuntz, Senior Project Manager Licensing Processes Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos.: 50-352 and 50-353 cc: Listserv

ML24215A404 NRR-084 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL1/LA NRR/DEX/EICB/BC NRR/DORL/LPL1/BC NRR/DORL/LPL3/PM NAME RKuntz KZeleznock FSacko (SDarbali for) HGonzález RKuntz DATE 08/01/2024 08/06/2024 9/17/24 9/18/2024 9/18/2024