ML24341A106
| ML24341A106 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 02/28/2025 |
| From: | Michael Mahoney NRC/NRR/DORL/LPL4 |
| To: | Entergy Operations |
| Wengert, Thomas | |
| References | |
| EPID L-2024-LLA-0158 GNRO2024-00033 | |
| Download: ML24341A106 (1) | |
Text
February 28, 2025 Vice President, Operations Entergy Operations, Inc.
Grand Gulf Nuclear Station P.O. Box 756 Port Gibson, MS 39150
SUBJECT:
GRAND GULF NUCLEAR STATION, UNIT 1 - REQUEST FOR WITHHOLDING INFORMATION FROM PUBLIC DISCLOSURE (EPID L-2024-LLA-0158)
Dear Vice President,
Operations:
By letter to the U.S. Nuclear Regulatory Commission (NRC) dated November 25, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24330A234), Entergy Operations, Inc. (Entergy) submitted an affidavit dated July 9, 2024, executed by Lisa K. Schichlein, Senior Licensing Engineer, Regulatory Affairs, Global Nuclear Fuel - Americas, LLC. (GNF), and an affidavit dated July 17, 2024, executed by Karl Scot Leuenroth, Division Manager, Curtiss-Wrights Scientech Division, requesting that the following document be withheld from public disclosure pursuant to Section 2.390, Public inspections, exemptions, requests for withholding, of Title 10 of the Code of Federal Regulations (10 CFR):
NEDC-34125P, Grand Gulf Nuclear Station: Fuel Storage Criticality Safety Analysis with Rack Inserts, Revision 0, July 2024 A nonproprietary copy of this document has been placed in the NRCs Public Document Room and added to the NRC Library in ADAMS at the above-referenced Accession No. ML24330A234.
The GNF affidavit stated that the submitted information should be considered exempt from mandatory public disclosure for the following reasons:
- a.
Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention or its use by GNFs competitors without license from GNF constitutes a competitive economic advantage over other companies;
- b.
Information which, if used by a competitor, would reduce [its] expenditure of resources or improve [its] competitive position in the design, manufacture, shipment, installation, assurance of quality or licensing of a similar product;
The Curtiss-Wright affidavit stated that the submitted information should be considered exempt from mandatory public disclosure for the following reasons:
5).
Public disclosure of the information is likely to cause substantial harm to the competitive position of Curtiss-Wright because:
a)
A similar product is manufactured and sold by competitors of Curtiss-Wright.
b)
Development of the information by Curtiss-Wright required expenditure of considerable resources. To the best of my knowledge and belief, a competitor would have to undergo similar expense in generating equivalent information.
c)
In order to acquire such information, a competitor would also require considerable time and inconvenience related to the development of a design and analysis of a similar neutron attenuation technology for use in a spent fuel pool.
d)
The availability of such information to competitors would enable them to modify their product to better compete with Curtiss-Wright, take marketing or other actions to improve their products position of impair the position of Curtiss-Wrights product, and avoid developing similar data and analyses in support of their processes, methods or apparatus.
We have reviewed the requests and the material in accordance with the requirements of 10 CFR 2.390 and, based on the statements in the affidavits, have determined that the submitted information sought to be withheld contains proprietary commercial information and should be withheld from public disclosure.
The NRC staff has identified a statement on page 13 of NEDC-34125P, which was requested to be withheld from public disclosure; however, this statement was found in the public domain (ML081820352). Enclosed to this letter is page 13 of NEDC-34125P.
The enclosure to this letter will be made publicly available after March 17, 2025. If, prior to the release of the enclosure to the public, you request the withdrawal of NEDC-34125P, in accordance with 10 CFR 2.390(c)(3), your request will be considered in light of applicable statutes and regulations, and a determination will be made regarding whether the documents will be returned to you.
The remaining information marked as proprietary, as requested, 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 301-415-3867 or via email at Michael.Mahoney@nrc.gov.
Sincerely,
/RA/
Michael Mahoney, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-416 Enclosure Page 13 of NEDC-34125P cc: Listserv
ENCLOSURE Page 13 of NEDC-34
13 NEDO-34125 Revision 0 Non-Proprietary Information 4.2 GNF2 Fuel Description Criticality safety analyses to determine storage system reactivity are performed using the GNF2 fuel design. The GNF2 fuel lattice configuration is a 10x10 fuel rod array minus eight fuel rods that have been replaced with two large water rods, as shown in Figure 2 with corresponding dimensions in Table 6. Figure 2 also demonstrates the part-length rod locations, which cannot be changed for this fuel design. The references in Figure 3 correspond to Table 7. GNF2 pellet stack density is provided in Table 8. ((
))
Figure 2 - GNF2 Fuel Lattice Configuration
- concurrence via email OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA*
NRR/DORL/LP4/BC*
NAME MMahoney PBlechman TNakanishi DATE 02/18/2025 2/27/2025 02/27/2025 OFFICE NRR/DORL/LPL4/PM*
NAME MMahoney DATE 02/28/2025