ND-20-1414, (VEGP) Units 3 and 4 - Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390 (CAW-20-5130) (VEGP 3&4 PSI/ISI-ALT-15)

(VEGP) Units 3 and 4 - Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390 (CAW-20-5130) (VEGP 3&4 PSI/ISI-ALT-15)

ML20358A184
Person / Time
Site:	Vogtle
Issue date:	12/23/2020
From:	Roberts K Southern Nuclear Operating Co
To:	Office of Nuclear Reactor Regulation
Shared Package
ML20358A178	List: ML20358A179 ML20358A180 ML20358A182 ML20358A183 ND-20-1414, (VEGP) Units 3 and 4 - Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390 (CAW-20-5130) (VEGP 3&4 PSI/ISI-ALT-15)
References
ND-20-1414
Download: ML20358A184 (3)

Text

Southern Nuclear Operating Company ND-20-1414 Enclosure 5 Vogtle Electric Generating Plant(VEGP) Units 3 and 4 Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390 (VEGP 3&4-PSI/ISI-ALT-15)

(This Enclosure consists of 3 pages, including this cover page)

ND-20-1414 Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390(VEGP 3&4-PSI/ISI-ALT-15)

Affidavit of Kelli A. Roberts

1. My name is Kelli A. Roberts. I am the acting Vogtle Units 3 & 4 Regulatory Affairs Director for Southern Nuclear Operating Company(SNO). I have been delegated the function of reviewing proprietary information sought to be withheld from public disclosure and am authorized to apply for its withholding on behalf of SNO.

2. I am making this affidavit on personal knowledge, in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations, and in conjunction with SNC's filing on dockets52-025 and 52-026, Vogtle Electric Generating Plant Units 3 and 4, Proposed Alternative VEGP 3&4-PSI/ISI-ALT-15 (Proprietary) in Accordance with 10 CFR 50.55a(z)(1)

Regarding Preservice and Inservice Inspection Requirements for ASME Section XI Examination Coverage of Weldolet Branch Connection Welds. I have personal knowledge of the criteria and procedures used by SNC to designate information as a trade secret, privileged or as confidential commercial or financial information.

3. Based on the reason(s) at 10 CFR 2.390(a)(4), this affidavit seeks to withhold from public disclosure Enclosure 2 of SNC letter ND-20-1414 for Vogtle Electric Generating Plant Units 3 and 4, Proposed Alternative VEGP 3&4-PSI/ISI-ALT-15 (Proprietary) in Accordance with 10 CFR 50.55a(z)(1) Regarding Preservice and Inservice Requirements for ASME Section XI Examination Coverage of Weldolet Branch Connection Welds.

4. The following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

a. The information sought to be withheld from public disclosure has been held in confidence by SNC and Westinghouse Electric Company.

Page 2 of 3

ND-20-1414 Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390(VEGP 3&4-PSI/ISI-ALT-15)

b. The information is of a type customarily held in confidence by SNC and Westinghouse Electric Company and not customarily disclosed to the public.

c. The release of the information might result in the loss of an existing or potential competitive advantage to SNC and/or Westinghouse Electric Company.

d. Other reasons identified in Enclosure 4 of SNC letter ND-20-1414 for Vogtle Electric Generating Plant Units 3 and 4, Westinghouse Affidavit CAW-20-5130(VEGP 3&4-PSI/ISI-ALT-15).

5. Additionally, release of the information may harm SNC because SNC has a contractual relationship with Westinghouse Electric Company regarding proprietary information. SNC is contractually obligated to seek confidential and proprietary treatment of the information.

6. The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.

7. To the best of my knowledge and belief, the information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on \7Jl JI Kelli A. Roberts Date Page 3 of 3