ML25322A125

Request for Withholding Information from Public Disclosure

ML25322A125
Person / Time
Site:	Limerick
Issue date:	11/21/2025
From:	Marshall M NRC/NRR/DORL/LPL1
To:	Mudrick C Constellation Energy Generation, Constellation Nuclear
Klett, AL
References
EPID L-2022-LLA-0140
Download: ML25322A125 (0)

Text

November 21, 2025 Mr. Christopher H. Mudrick, Sr.

Senior Vice President Constellation Energy Generation, LLC President and Chief Nuclear Officer Constellation Nuclear 200 Exelon Way Kennett Square, PA 19348

SUBJECT:

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

Dear Mr. Mudrick:

By letter dated February 5, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25037A286), you submitted an affidavit dated January 29, 2025, executed by Jerrod Ewing, Manager, Operating Plants Licensing, Westinghouse Electric Company LLC. Also, by letters dated:

February 21, 2025 (ML25055A156), you submitted affidavits dated January 29, 2025, executed by Jerrod Ewing, Manager, Operating Plants Licensing, Westinghouse Electric Company LLC and dated February 21, 2025, executed by Sailaja Mokkapati, Director-Licensing, Constellation Energy Company, LLC.

July 10, 2025 (ML25191A223), you submitted affidavits dated July 10, 2025, executed by Jerrod Ewing, Manager, Operating Plants Licensing, Westinghouse Electric Company LLC and dated July 8, 2025, executed by Wendi Para, Director-Licensing, Constellation Energy Company, LLC.

July 30, 2025 (ML25211A294), you submitted an affidavit dated July 21, 2025, executed by Jerrod Ewing, Manager, Operating Plants Licensing, Westinghouse Electric Company LLC.

September 26, 2025 (ML25269A191), you submitted an affidavit dated September 26, 2025, executed by Rosemary Null, Manager, New Plants Licensing, Westinghouse Electric Company LLC.

October 1, 2025 (ML25274A140), you submitted an affidavit dated October 1, 2025, executed by Jerrod Ewing, Manager, Operating Plants 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):

WEC LIM-25-004-P, Revision 0, Limerick Units 1 and 2 Digital Modernization Project, Component Interface Module (CIM) Request for Confirmatory Information (RCI)

Equipment Qualification Testing and Analysis - LGS PPS Components, Proprietary Response to RAI-37 and -39 through -41 Response to RAI-38 and -42 through -46 Response to RAI-24, -26, -29, and -33 through -36 Response to RAI-25, -27, -28, -30, and -32 Update to WCAP-18598, Revision 2, Licensing Technical Report for the Limerick Generating Station Units 1&2 Digital Modernization Project Nonproprietary copies of these documents have been placed in the U.S. Nuclear Regulatory Commissions (NRCs) Public Document Room and added to the NRC Library in 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.

or (5)

Constellation (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 (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.

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 versions 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 can be reached at 301-415-2871.

Sincerely,

/RA/

Michael L. Marshall, Jr., Senior Project Manager Licensing Processes Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos.: 50-352 and 50-353 cc: Listserv

ML25322A125 NRR-084 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NRR/DORL/LPL1/BC NRR/DORL/LPL1/PM NAME MMarshall KEntz UShoop MMarshall DATE 11/18 /2025 11/18/2025 11/20/2025 11/21/2025