ML25055A156

Proposed License Condition - Qualification of Components - Limerick Generating Station Digital Plant Protection System

ML25055A156
Person / Time
Site:	Limerick
Issue date:	02/21/2025
From:	Para W Constellation Energy Generation
To:	Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML25055A155	List: ML25055A156
References
Download: ML25055A156 (1)

Text

200 Energy Way Kennett Square, PA 19348 www.ConstellationEnergy.com ATTACHMENT 2 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 When separated, the cover letter, Attachment 1, Attachment 3, Attachment 4, and Attachment 5 are decontrolled.

ATTACHMENT 2 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 10 CFR 50.90 February 21, 2025 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Document Control Desk Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353

Subject:

Proposed License Condition - Qualification of Components - Limerick Generating Station Digital Plant Protection System

References:

1. Constellation Energy Generation, LLC (CEG) letter to the U.S. Nuclear Regulatory Commission (NRC), "License Amendment Request to Revise the Licensing and Design Basis to Incorporate the Replacement of Existing Safety-Related Analog Control Systems with a Single Digital Plant Protection System (PPS)," dated September 26, 2022 (NRC Agencywide Documents Access and Management System (ADAMS) Accession No. ML22269A569).

2.

CEG letter to the NRC, "Resubmittal of License Amendment Request to Revise the Licensing and Design Basis to Incorporate the Replacement of Existing Safety-Related Analog Control Systems with a Single Digital Plant Protection System (PPS) - To Address Proprietary Issues with INL HFE Reports," dated September 12, 2023 (ADAMS Accession No. ML23255A095).

3. CEG letter to the NRC, Supplement to License Amendment Request to Revise the Licensing and Design Basis to Incorporate the Replacement of Existing Safety-Related Analog Control Systems with a Single Digital Plant Protection System (PPS) - Qualification Summary Report Rev 1, dated November 21, 2023 (ADAMS Accession No. ML23325A206).

Proposed License Condition Limerick Digital Modernization Project Docket Nos. 50-352 and 50-353 February 21, 2025 Page 2 ATTACHMENT 2 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 When separated, the cover letter, Attachment 1, Attachment 3, Attachment 4, and Attachment 5 are decontrolled.

4. CEG letter to the NRC, Supplement to License Amendment Request to Revise the Licensing and Design Basis to Incorporate the Replacement of Existing Safety-Related Analog Control Systems with a Single Digital Plant Protection System (PPS)-SyRS, SyDS, FMEA, LTR, AOA, EQRS Revision Update, dated January 26, 2024 (ADAMS Accession No. ML24026A296).

5. CEG letter to the NRC, Request to Return and Replace WEC Documents (EQ-EV-386-GLIM, EQ-QR-433-GLIM, and APP-GW-GLR-611), to meet 10CFR2.390 Request to Withdraw from Public Disclosure Requirements, dated June 28, 2024 (ADAMS Accession No. ML24180A157).

6.

Email from Michael Marshall, U.S. Nuclear Regulatory Commission to Francis Mascitelli, Constellation Energy Generation, LLC, Limerick Generating Station, Units 1 and 2 - Request for Additional Information Regarding Limerick Digital Instrumentation and Controls License Amendment Request (EPID L-2022-LLA-0140), dated March 19, 2024 (ADAMS Accession No. ML24079A292) 7.

CEG letter to the NRC, Response to Requests for Additional Information (RAIs 9 through 14) for License Amendment Request to Revise the Licensing and Design Basis to Incorporate the Replacement of Existing Safety-Related Analog Control Systems with a Single Digital Plant Protection System (PPS), dated May 3, 2024 (ADAMS Accession No. ML24124A043).

In Reference 1 Constellation Energy Generation, LLC (CEG) requested a License Amendment Request (LAR) to facilitate replacement of the Limerick Generating Station, Units 1 and 2 (LGS) existing safety-related analog control systems with a single digital Plant Protection System (PPS). In Reference 2, CEG submitted a LAR supplement that replaced in its entirety the original LAR. CEG replaced the original submittal to address issues associated with proprietary/non-proprietary information.

In both the Reference 1 LAR submittal and Enclosure 1 to the Reference 2 LAR resubmittal, CEG indicated that the LAR was developed and submitted in accordance with the Alternate Review Process (ARP) guidance in NRC Digital Instrumentation and Control (DI&C) Interim Staff Guidance (ISG)-06, Licensing Process.

In Reference 3, CEG transmitted EQ-QR-433-GLIM, Qualification Summary Report for the Plant Protection System Upgrade for Limerick Units 1 & 2, Revision 1 (EQSR) in accordance with the ARP requirements specified in DI&C-ISG-06, Section D.3, Hardware Equipment Qualification and Enclosure B, Information Provided in Support of a License Amendment Request for a Digital Instrumentation and Control Modification, Item 1.6,

Proposed License Condition Limerick Digital Modernization Project Docket Nos. 50-352 and 50-353 February 21, 2025 Page 3 ATTACHMENT 2 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 When separated, the cover letter, Attachment 1, Attachment 3, Attachment 4, and Attachment 5 are decontrolled.

(Summary of) Hardware Equipment Qualification (see D.3). Due to delays in manufacturing and equipment qualification (EQ) testing, CEG indicated that EQ summary report revisions would be submitted as EQ testing is completed.

In Reference 4, CEG transmitted EQ-QR-433-GLIM, Revision 3. In Reference 5, CEG transmitted EQ-QR-433-GLIM-P, Revision 4 to reinsert a figure the was inadvertently removed from Revision 3.

In Reference 6, the NRC provided six requests for additional information (RAIs) to support the NRCs review of the Reference 2 LAR. The six RAIs concerned EQ testing and analysis of LGS PPS components. CEG provided responses to the six EQ-related RAIs in Reference 7.

The response to RAI 9 described the planned fault testing of isolation barriers and the acceptance criteria for the fault tests. The response to RAI 11.a identified 51 LGS PPS components that required additional EQ evaluation and testing. The response to RAI 14 addressed plant-specific EQ requirements for fiber optic cabling.

Based on recent discussions with the NRC concerning the schedule for completing fault tests of isolation barriers, EQ tests and analyses of the 51 LGS PPS components, and environmental qualification requirements for fiber optic cables, CEG proposes to incorporate a License Condition (LC) for LGS Unit 1 and Unit 2 that would require, prior to startup following the first refueling outage during which the LGS PPS is installed, completion of all EQ tests and analyses. The proposed License Conditions are provided in Attachment 1 to this letter. to this letter describes the planned fault tests of isolation barriers, planned EQ tests and analyses of the original 51 LGS PPS components listed in Reference 7, new components that have been added to the design subsequent to the Reference 7 response, and the planned environmental qualification tests of fiber optic assemblies and cables.

Table 1 in Attachment 2 provides a list of isolation barriers subject to fault testing. Table 2 in provides the list of the original 51 LGS PPS components, new components added to the design, and the Westinghouse Electric Company (WEC) fiber optic cable assemblies that will be subject to EQ testing and analysis, the associated EQ test status (i.e., OPEN or CLOSED), and the acceptance criteria. Table 3 in Attachment 2 identifies the fiber optic cable procured by CEG and the environmental qualification testing requirements for the cabling. Attachment 2 includes information proprietary to WEC and CEG. provides a non-proprietary version of Attachment 2. provides an affidavit signed by WEC, the owner of proprietary information.

The affidavit sets forth the basis upon which the information may be withheld from public disclosure by the NRC, and it addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390 of the NRCs regulations. WEC requests that the WEC

Proposed License Condition Limerick Digital Modernization Project Docket Nos. 50-352 and 50-353 February 21, 2025 Page 4 proprietary information contained in Attachment 2 be withheld from public disclosure in accordance with 10 CFR 2.390. Future correspondence with respect to the proprietary aspects of the application for withholding related to WEC proprietary information or the WEC affidavit provided in the applicable attachment should reference this request letter. provides an affidavit signed by CEG, the owner of proprietary information.

The affidavit sets forth the basis upon which the information may be withheld from public disclosure by the NRC, and it addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390 of the NRCs regulations. CEG requests that the WEC proprietary information contained in Attachment 2 be withheld from public disclosure in accordance with 10 CFR 2.390. Future correspondence with respect to the proprietary aspects of the application for withholding related to CEG proprietary information or the CEG affidavit provided in the applicable attachment should reference this request letter.

CEG has reviewed the information supporting a finding of no significant hazards consideration, and the environmental consideration, which was previously provided to the NRC in the Reference 2 letter. CEG has concluded that the information provided in this letter does not affect the bases for concluding that the proposed license amendments do not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92.

In addition, CEG has concluded that the information in this letter does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendments.

This letter contains no regulatory commitments.

ATTACHMENT 2 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 When separated, the cover letter, Attachment 1, Attachment 3, Attachment 4, and Attachment 5 are decontrolled.

Proposed License Condition Limerick Digital Modernization Project Docket Nos. 50-352 and 50-353 February 21, 2025 Page 5 ATTACHMENT 2 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 When separated, the cover letter, Attachment 1, Attachment 3, Attachment 4, and Attachment 5 are decontrolled.

In accordance with 10 CFR 50.91, Notice for public comment; State consultation, paragraph (b), CEG is notifying the Commonwealth of Pennsylvania of this license amendment request supplement by transmitting a copy of this letter to the designated State Official.

If you have any questions regarding this submittal, then please contact Ms. Ashley Rickey at Ashley.Rickey@constellation.com.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this 21st day of February, 2025.

Respectfully, Wendi E. Para Senior Manager, Licensing and Regulatory Affairs Constellation Energy Generation, LLC Proposed License Conditions Equipment Qualification Testing and Analysis - LGS PPS Components, Proprietary Equipment Qualification Testing and Analysis - LGS PPS Components, Non-Proprietary WEC Affidavit CAW-25-002 for WEC Proprietary Information in Attachment 2

CEG Affidavit for CEG Proprietary Information in Attachment 2 cc:

USNRC Region I, Regional Administrator w/ attachments USNRC Project Manager, LGS

USNRC Senior Resident Inspector, LGS

Director, Bureau of Radiation Protection - Pennsylvania Department

of Environmental Protection

Proposed License Condition LGS Digital Modernization Project Page 1 of 1 Docket Nos. 50-352 and 50-353 ATTACHMENT 2 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 When separated, the cover letter, Attachment 1, Attachment 3,, and Attachment 5 are decontrolled ATTACHMENT 1 Proposed License Conditions Limerick Generating Station, Unit 1 NRC Docket No. 50-352 (26)

Equipment Qualification Testing and Analysis - Plant Protection System Components Prior to startup following the first refueling outage during which the digital instrumentation and control (DI&C) Plant Protection System (PPS) at the Limerick Generating Station, Unit 1 (LGS) is installed, Constellation Energy Generation, LLC (CEG) shall complete seismic, environmental, and electromagnetic capability (EMC) testing and analysis of critical hardware components, as described in CEG letter to the U.S. Nuclear Regulatory Commission (NRC), Proposed License Condition - Qualification of Components - Limerick Generating Station Digital Plant Protection System, dated February 21, 2025, Attachment 2, Equipment Qualification and Analysis - LGS PPS Components. To satisfy this License Condition, CEG will formally document the successful completion of the required EQ testing and analyses described in Attachment 2.

Limerick Generating Station, Unit 2 NRC Docket No. 50-353 (15)

Equipment Qualification Testing and Analysis - Plant Protection System Components Prior to startup following the first refueling outage during which the digital instrumentation and control (DI&C) Plant Protection System (PPS) at the Limerick Generating Station, Unit 2 (LGS) is installed, Constellation Energy Generation, LLC (CEG) shall complete seismic, environmental, and electromagnetic capability (EMC) testing and analysis of critical hardware components, as described in CEG letter to the U.S. Nuclear Regulatory Commission (NRC), Proposed License Condition - Qualification of Components - Limerick Generating Station Digital Plant Protection System, dated February 21, 2025, Attachment 2, Equipment Qualification and Analysis - LGS PPS Components. To satisfy this License Condition, CEG will formally document the successful completion of the required EQ testing and analyses described in Attachment 2.

Proposed License Condition LGS Digital Modernization Project Page 1 of 5 Docket Nos. 50-352 and 50-353 ATTACHMENT 2 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 When separated, the cover letter, Attachment 1, Attachment 3,, and Attachment 5 are decontrolled ATTACHMENT 3 Equipment Qualification Testing and Analysis - LGS PPS Components Non-Proprietary Limerick Generating Station, Units 1 and 2 NRC Docket Nos. 50-352 and 50-353 Constellation Energy Generation, LLC (CEG) will conduct fault testing of Isolation Barriers that will be installed as part of Limerick Generating Station, Unit 1 and Unit 2 (LGS) Plant Protection System (PPS) modification, as listed in Table 1 below.

The fault testing and analysis of Isolation Barriers, including acceptance criteria, is described in CEG letter to the NRC, Response to Requests for Additional Information (RAIs 9 through 14) for License Amendment Request to Revise the Licensing and Design Basis to Incorporate the Replacement of Existing Safety-Related Analog Control Systems with a Single Digital Plant Protection System (PPS), dated May 3, 2024 (ADAMS Accession No. ML24124A043) (i.e., the CEG response to RAI 9).

CEG will conduct seismic, environmental, and electromagnetic capability (EMC) equipment qualification (EQ) testing and analysis of the LGS PPS hardware components that will be installed as part of LGS PPS modification, as listed in Table 2 and Table 3 below.

The hardware components in Table 2 include: the 51 LGS PPS components originally listed in the the May 3, 2024 CEG letter (i.e., the response to RAI 11.a); new components that have been added to the design subsequent to the May 3, 2024 CEG letter, and the planned qualification tests of fiber optic cables provided by the vendor. The hardware component listed in Table 3 represents the fiber optic cable procured directly by CEG.

EQ testing and analysis of the LGS PPS components listed in Table 2 and Table 3 will be conducted in accordance with NRC Regulatory Guide (RG) 1.75, Physical Independence of Electric Systems, Revision 2, RG 1.89, Environmental Qualification of Certain Electric Equipment Important to Safety for Nuclear Power Plants, Revision 1, RG 1.100, Seismic Qualification of Electric Equipment for Nuclear Power Plants, Revision 1, RG 1.180, Guidelines for Evaluation Electromagnetic and Radio-Frequency Interference in Safety-Related Instrumentation and Control Systems, Revision 2, and RG 1.209, Guidelines for Environmental Qualification of Safety-Related Computer-Based Instrumentation and Control Systems in Nuclear Power Plants, Revision 0.

CEG will review and determine EQ testing and analysis requirements for all additional or different LGS PPS hardware components and part numbers that are not listed in Tables 1, 2, and 3 in accordance with RG 1.75, Revision 2, RG 1.89, Revision 1, RG 1.100, Revision 1, RG 1.180, Revision 2, and RG 1.209, Revision 0.

Proposed License Condition LGS Digital Modernization Project Page 2 of 5 Docket Nos. 50-352 and 50-353 ATTACHMENT 2 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 When separated, the cover letter, Attachment 1, Attachment 3,, and Attachment 5 are decontrolled The EQ testing and analysis process for LGS PPS hardware components is described in EQ-QR-433-GLIM-P, Qualification Summary Report for the Plant Protection System Upgrade for Limerick Units 1 & 2, Revision 4, which was submitted by CEG letter dated June 28, 2024 (ADAMS Accession No. ML24180A157). Seismic, environmental, and EMC testing is described in Sections 3.1.1, Component Seismic Testing, 3.2.1, Component Environmental Testing, and 3.3.1, Component EMC Testing, respectively.

The seismic qualification testing of the LGS PPS components listed in Table 2 will verify that the components will be capable of operation without loss of safety function or physical integrity, as defined by the seismic acceptance criteria for each component listed in Table 2.

Environmental qualification testing will verify that the LGS PPS components listed in Tables 2 and 3 will be capable of operation without loss of safety functions, as as defined by the environmental acceptance criteria for each component listed in Tables 2 and 3.

EMC qualification testing will verify that the LGS PPS components listed in Table 2 will be capable of operation without loss of safety functions, as defined by the EMC acceptance criteria for each component listed in Table 2.

Proposed License Condition LGS Digital Modernization Project Page 3 of 5 Docket Nos. 50-352 and 50-353 Table 1 Isolation Barrier Fault Testing

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ATTACHMENT 2 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 When separated, the cover letter, Attachment 1, Attachment 3,, and Attachment 5 are decontrolled

nse Condition odernization Project Page 4 of 5 0-352 and 50-353 ATTACHMENT 2 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 When separated, the cover letter, Attachment 1, Attachment 3,, and Attachment 5 are decontrolled Table 2 LGS PPS Component Equipment Qualification Testing

Proposed License Condition LGS Digital Modernization Project Page 5 of 5 Docket Nos. 50-352 and 50-353

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ATTACHMENT 2 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 When separated, the cover letter, Attachment 1, Attachment 3,, and Attachment 5 are decontrolled Table 3 CEG-procured Fiber Optic Cable Equipment Qualification Testing

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Proposed License Condition LGS Digital Modernization Project Docket Nos. 50-352 and 50-353 ATTACHMENT 2 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 When separated, the cover letter, Attachment 1, Attachment 3,, and Attachment 5 are decontrolled ATTACHMENT 4 Non-Proprietary Limerick Generating Station, Units 1 and 2 NRC Docket Nos. 50-352 and 50-353 WEC Affidavit CAW-25-002 for Proprietary Information, Tables 1 and 2 (3 pages)

• • • This record was final approved on 01/29/2025 14:07:21. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-25-002 Page 1 of 3 Commonwealth of Pennsylvania:

County of Butler:

(1)

I, Jerrod Ewing, Manager, Operating Plants Licensing, 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 LIM-25-014-P 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.

• • • This record was final approved on 01/29/2025 14:07:21. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-25-002 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.

• • • This record was final approved on 01/29/2025 14:07:21. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-25-002 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: 1/29/2025 Signed electronically by Jerrod Ewing gned electronically

Proposed License Condition LGS Digital Modernization Project Docket Nos. 50-352 and 50-353 ATTACHMENT 2 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 When separated, the cover letter, Attachment 1, Attachment 3,, and Attachment 5 are decontrolled ATTACHMENT 5 Non-Proprietary Limerick Generating Station, Units 1 and 2 NRC Docket Nos. 50-352 and 50-353 CEG Affidavit for Proprietary Information, Table 3 (2 pages)

AFFIDAVIT for Table 3, CEG Procured Cable Fiber Optic Cable Equipment Qualification Testing Page 1 of 2 Constellation Energy Generation, LLC AFFIDAVIT Commonwealth of Pennsylvania:

County of Chester:

(1) I, Sailaja Mokkapati, Director-Licensing, have been specifically delegated and authorized to apply for withholding and execute this Affidavit on behalf of Constellation Energy Company, LLC (CEG).

(2) I am requesting Table 3 -- CEG Procured Cable Fiber Optic Cable Equipment Qualification Testing, be withheld from public disclosure under 10 CFR 2.390. This table contains acceptance criteria that is contained in CEG NE-381 Nuclear Safety Related Specification for Fiber-Optic Instrumentation & Control System Cable, which has previously been withheld from public disclosure under 10 CFR 2.390 (ML24124A043).

(3) I have personal knowledge of the criteria and procedures utilized by CEG 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 CEG 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 CEG knowledge, is not available in public sources.

(iii) CEG 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 CEG 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. Furthermore, 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.

(5) CEG 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 CEGs competitors without license from CEG constitutes a competitive economic advantage over other companies.

AFFIDAVIT for Table 3, CEG Procured Cable Fiber Optic Cable Equipment Qualification Testing Page 2 of 2 (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 their expenditure of resources or improve their 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 CEG, its customers or suppliers.

(e) It reveals aspects of past, present, or future CEG or customer funded development plans and programs of potential commercial value to CEG.

(f) It contains patentable ideas, for which patent protection may be desirable.

(6) The attached submittal contains proprietary information throughout, for the reasons set forth in Sections (5) (a), (b), and (c) of this Affidavit. Accordingly, a redacted version would be of no value to the public.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this 21st day of February 2025.

Signed electronically by: ________________________

Mokkapati, Sailaja Digitally signed by Mokkapati, Sailaja Date: 2025.02.21 11:54:36 -05'00'