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Category:Letter type:NL
MONTHYEARNL-24-0337, Interim 10 CFR 21.21(a)(2) Report Regarding Operation Technology, Inc., ETAP Software Error in Transient Stability Program2024-09-0909 September 2024 Interim 10 CFR 21.21(a)(2) Report Regarding Operation Technology, Inc., ETAP Software Error in Transient Stability Program NL-24-0299, Exemption Request: Final Safety Analysis Report Update Schedule, Response to Request for Additional Information2024-08-14014 August 2024 Exemption Request: Final Safety Analysis Report Update Schedule, Response to Request for Additional Information NL-24-0282, License Amendment Request and Exemption Request: Remove Tier 1 and Tier 2* Requirements2024-07-25025 July 2024 License Amendment Request and Exemption Request: Remove Tier 1 and Tier 2* Requirements NL-24-0126, – Units 3 and 4, License Amendment Request: Changes to Technical Specification 3.7.6, Main Control Room Emergency Habitability System (Ves) Action a and SR 3.7.6.62024-07-25025 July 2024 – Units 3 and 4, License Amendment Request: Changes to Technical Specification 3.7.6, Main Control Room Emergency Habitability System (Ves) Action a and SR 3.7.6.6 NL-24-0286, Emergency Request to Revise Technical Specification 3.7.9 for a One-Time Change to Support a Unit 1 Nuclear Service Cooling Water Transfer Pump Repair2024-07-20020 July 2024 Emergency Request to Revise Technical Specification 3.7.9 for a One-Time Change to Support a Unit 1 Nuclear Service Cooling Water Transfer Pump Repair NL-24-0261, 10 CFR 50.46 ECCS Evaluation Model Annual Report for 20232024-07-19019 July 2024 10 CFR 50.46 ECCS Evaluation Model Annual Report for 2023 NL-24-0227, Proposed Inservice Inspection Alternative GEN-ISI-AL T-2024-03 for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1)2024-07-0303 July 2024 Proposed Inservice Inspection Alternative GEN-ISI-AL T-2024-03 for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1) NL-24-0234, Application to Revise Technical Specifications to Adopt TSTF-589, Eliminate Automatic Diesel Generator Start During Shutdown2024-06-28028 June 2024 Application to Revise Technical Specifications to Adopt TSTF-589, Eliminate Automatic Diesel Generator Start During Shutdown NL-24-0143, Proposed Alternative to Use ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/ Replacement Activities in2024-06-27027 June 2024 Proposed Alternative to Use ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/ Replacement Activities in NL-24-0087, License Amendment Request: Changes to Technical Specification 3.7.6, Main Control Room Emergency Habitability System (Ves) Air Storage Tanks2024-06-21021 June 2024 License Amendment Request: Changes to Technical Specification 3.7.6, Main Control Room Emergency Habitability System (Ves) Air Storage Tanks NL-24-0243, Registration of Spent Fuel Cask Use2024-06-18018 June 2024 Registration of Spent Fuel Cask Use NL-24-0201, Proposed Inservice Inspection Alternative GEN-ISI-ALT-2024-002 for Steam Generator Welds in Accordance with 10 CFR 50.55a(z)(1)2024-06-18018 June 2024 Proposed Inservice Inspection Alternative GEN-ISI-ALT-2024-002 for Steam Generator Welds in Accordance with 10 CFR 50.55a(z)(1) NL-24-0202, SNC Response to Regulatory Issue Summary 2024-01: Preparation and Scheduling of Operator Licensing Examinations2024-05-24024 May 2024 SNC Response to Regulatory Issue Summary 2024-01: Preparation and Scheduling of Operator Licensing Examinations NL-24-0191, Annual Radiological Environmental Operating Reports for 20232024-05-10010 May 2024 Annual Radiological Environmental Operating Reports for 2023 NL-24-0194, Revised Request for Relief and Alternative Requirements for Squib Valves First Test Interval (V34-IST-ALT-03-R1)2024-05-0707 May 2024 Revised Request for Relief and Alternative Requirements for Squib Valves First Test Interval (V34-IST-ALT-03-R1) NL-24-0170, Responses to Second Round NRC Request for Additional Information for Refueling Outage 1 R24 Steam Generator Tube Inspection Report2024-04-25025 April 2024 Responses to Second Round NRC Request for Additional Information for Refueling Outage 1 R24 Steam Generator Tube Inspection Report NL-24-0165, Annual Non-Radiological Environmental Operating Reports and Annual Radioactive Effluent Release Reports for 20232024-04-25025 April 2024 Annual Non-Radiological Environmental Operating Reports and Annual Radioactive Effluent Release Reports for 2023 NL-24-0154, Preservice Inspection Progam Owners Activity Report2024-04-16016 April 2024 Preservice Inspection Progam Owners Activity Report NL-24-0128, License Amendment Request: Technical Specification 5.5.13, Ventilation Filter Testing Program (VFTP) Testing Frequency2024-04-0404 April 2024 License Amendment Request: Technical Specification 5.5.13, Ventilation Filter Testing Program (VFTP) Testing Frequency NL-24-0115, Response to Request for Additional Information Exemption Requests for Physical.2024-04-0404 April 2024 Response to Request for Additional Information Exemption Requests for Physical. NL-24-0116, Nuclear Property Insurance Coverage as of April 1, 2024 and Licensee Guarantees of Payment of Deferred.2024-03-29029 March 2024 Nuclear Property Insurance Coverage as of April 1, 2024 and Licensee Guarantees of Payment of Deferred. NL-24-0098, Report on Status of Decommissioning Funding2024-03-28028 March 2024 Report on Status of Decommissioning Funding NL-24-0112, Request for Revision to NRC Staff Assessment of Vogtle Site Updated Seismic Hazards2024-03-28028 March 2024 Request for Revision to NRC Staff Assessment of Vogtle Site Updated Seismic Hazards NL-24-0097, Exemption Request: Final Safety Analysis Report Update Schedule2024-03-22022 March 2024 Exemption Request: Final Safety Analysis Report Update Schedule NL-22-0267, License Amendment Request to Revise Diesel Generator Frequency and Voltage Ranges for Technical Specification 3.8.1, AC Sources – Operating, Surveillance Requirements2024-03-20020 March 2024 License Amendment Request to Revise Diesel Generator Frequency and Voltage Ranges for Technical Specification 3.8.1, AC Sources – Operating, Surveillance Requirements NL-24-0060, Request for Relief and Alternative Requirements for Squib Valves First Test Interval (V34-IST-ALT-03)2024-02-15015 February 2024 Request for Relief and Alternative Requirements for Squib Valves First Test Interval (V34-IST-ALT-03) NL-24-0042, Response to Request for Additional Information Exemption Requests for Physical Barriers2024-02-13013 February 2024 Response to Request for Additional Information Exemption Requests for Physical Barriers NL-24-0045, Supplement to Response to Requests for Additional Information for Proposed Alternative ALT-VR-022024-02-0808 February 2024 Supplement to Response to Requests for Additional Information for Proposed Alternative ALT-VR-02 NL-24-0033, Response to Question for Withholding Information from Public Disclosure Exemption Requests for Physical Barriers2024-02-0505 February 2024 Response to Question for Withholding Information from Public Disclosure Exemption Requests for Physical Barriers NL-24-0038, National Pollutant Discharge Elimination System (NPDES) Permit Renewal Application2024-02-0202 February 2024 National Pollutant Discharge Elimination System (NPDES) Permit Renewal Application NL-24-0031, Inservice Inspection Program Owners Activity Report (OAR-1) for Outage 2R232024-01-29029 January 2024 Inservice Inspection Program Owners Activity Report (OAR-1) for Outage 2R23 NL-24-0020, Plan, Unit 1 Responses to NRC Request for Additional Information for Refueling Outage 1R24 Steam Generator Tube Inspection Report2024-01-22022 January 2024 Plan, Unit 1 Responses to NRC Request for Additional Information for Refueling Outage 1R24 Steam Generator Tube Inspection Report NL-23-0926, Correction of Technical Specification Typographical Error2024-01-12012 January 2024 Correction of Technical Specification Typographical Error NL-23-0878, Request for Exemption from Security Event Notification Implementation2023-11-29029 November 2023 Request for Exemption from Security Event Notification Implementation NL-23-0827, Response to Requests for Additional Information for a License Amendment Request and a Proposed Alternative Related to TS 3.4.142023-11-17017 November 2023 Response to Requests for Additional Information for a License Amendment Request and a Proposed Alternative Related to TS 3.4.14 NL-23-0750, Response to Second Request for Additional Information Regarding License Amendment Request: Technical Specification Revision to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the Colr2023-10-0404 October 2023 Response to Second Request for Additional Information Regarding License Amendment Request: Technical Specification Revision to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the Colr NL-23-0745, Refueling Outage 1R24 Steam Generator Tube Inspection Report2023-09-22022 September 2023 Refueling Outage 1R24 Steam Generator Tube Inspection Report NL-23-0742, to Non-Voluntary License Amendment Request: Technical Specification Revision to Adopt WCAP-17661-P-A, Improved RAOC and CAOC Fo Surveillance Technical Specifications2023-09-20020 September 2023 to Non-Voluntary License Amendment Request: Technical Specification Revision to Adopt WCAP-17661-P-A, Improved RAOC and CAOC Fo Surveillance Technical Specifications NL-23-0695, Response to Round 2 Request for Additional Information Regarding License Amendment Request for Technical Specification 3.8.3, Inverters Operating, Completion Time Extension (LAR-22-002S2)2023-08-31031 August 2023 Response to Round 2 Request for Additional Information Regarding License Amendment Request for Technical Specification 3.8.3, Inverters Operating, Completion Time Extension (LAR-22-002S2) NL-23-0666, License Amendment Request: Remove Combined License Appendix C (LAR 23-008)2023-08-28028 August 2023 License Amendment Request: Remove Combined License Appendix C (LAR 23-008) NL-23-0670, Response to Request for Additional Information Regarding License Amendment Request: Technical Specification Revision to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the COLR Consistent with WCAP-144832023-08-11011 August 2023 Response to Request for Additional Information Regarding License Amendment Request: Technical Specification Revision to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the COLR Consistent with WCAP-14483 NL-23-0658, Southern Nuclear Operating Company - Response to Request for Additional Information Regarding Quality Assurance Topical Report Submittal2023-08-11011 August 2023 Southern Nuclear Operating Company - Response to Request for Additional Information Regarding Quality Assurance Topical Report Submittal NL-23-0672, Licensee Guarantees of Payment of Deferred Premiums2023-08-10010 August 2023 Licensee Guarantees of Payment of Deferred Premiums NL-23-0542, CFR 50.46 ECCS Evaluation Model Annual Report for 20222023-08-0909 August 2023 CFR 50.46 ECCS Evaluation Model Annual Report for 2022 NL-23-0624, Report of Changes to Emergency Plan and Summary of 50.54(q) Analysis2023-08-0404 August 2023 Report of Changes to Emergency Plan and Summary of 50.54(q) Analysis NL-23-0611, Core Operating Limits Report, Cycle 11 Version 12023-07-19019 July 2023 Core Operating Limits Report, Cycle 11 Version 1 NL-23-0584, Preservice Inspection Program Owner'S Activity Report2023-07-10010 July 2023 Preservice Inspection Program Owner'S Activity Report NL-23-0555, Request for Exemption from Physical Barrier Requirement2023-07-0707 July 2023 Request for Exemption from Physical Barrier Requirement NL-23-0506, to Non-Voluntary License Amendment Request: Technical Specification Revision to Adopt WCAP-17661-P-A, Improved RAOC and CAOC Fq Surveillance Technical Specifications2023-07-0505 July 2023 to Non-Voluntary License Amendment Request: Technical Specification Revision to Adopt WCAP-17661-P-A, Improved RAOC and CAOC Fq Surveillance Technical Specifications NL-23-0541, Inservice Inspection Program Owners Activity Report for Outage 1R242023-06-28028 June 2023 Inservice Inspection Program Owners Activity Report for Outage 1R24 2024-09-09
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WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 (DECONTROLLED UPON REMOVAL OF ENCLOSURE 1 AND ENCLOSURE 3) 4 Southern Nuclear Regulatory Affairs 40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 NOV 0 3 2017 205 992 5000 tel 205 992 7601 fax Docket Nos.: 50-424 NL-17-1830 50-425 U.S. Nuclear RegulatorY Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant - Units 1 and 2 Slides for SNC Non-Public Meeting on November 14, 2017 Ladies and Gentlemen:
Southern Nuclear Operating Company (SNC) hereby submits voluntarily the material to be presented at the November 14, 2017, non-public meeting with the Nuclear Regulatory Commission (NRG). In accordance with 10 CFR 2.390, Public Exemptions, Request for Withholding, SNC requests that the NRG withhold the enclosed information from public disclosure, as such information is considered both Business-Confidential and Proprietary.
SNC has included in Enclosure 2, a signed affidavit from FPoliSolutions, LLC, attesting to the proprietary nature of the information contained in Enclosure 3. Due to SNC's classification of this information as business-confidential, a non-proprietary version of this presentation has not been included as an enclosure to this letter.
This letter contains no NRG commitments. If you have any questions, please contact Ken McElroy at 205.992.7369.
- Respectfully submitted, J. J. Hutto Regulatory Affairs Director JJH/KMO/cbg
Enclosure:
- 1. BUSINESS CONFIDENTIAL- Notice Regarding Meeting Classification
- 2. FPoliSolutions, LLC Affidavit
- 3. PROPRIETARY INFORMATION - Slides for November 141h Non-Public Meeting cc: Regional Administrator NRR Project Manager - Vogtle 1 & 2 Senior Resident Inspector- Vogtle 1 & 2 RType: CVC7000
Vogtle Electric Generating Plant - Units 1 and 2 Slides for SNC Non-Public Meeting on November 14, 2017 Enclosure 2 FPoliSolutions, LLC Affidavit
AFFIDAVIT PURSUANT TO 10 CFR 2.390 I, Cesare Frepoli, state as follows:
(1) I am the President of FPoliSolutions. LLC, and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be 1.whheld, and have been authorized to apply for its withholding.
(2) The information sought to be withheld is contained in Enclosure 3 to Southern Nuclear Operating Company (SNC) letter NL-17-1830. This Enclosure contains FPoliSolutions, LLC proprietary information.
(3) In making this application for withholding of proprietary information of which it is the owner, FPoliSolutions, LLC relies upon the exemption from disclosure set forth in the Freedom of Information Act CFOIA"). 5 USC Sec. 552{b)(4), and the Trade Secrets Act, 18 USC Sec.
1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) trade secrets and commercial or financial information obtained from a person and privileged or confidential"
{Exemption 4). The material for which exemption from disclosure is here sought is all "confidential commercial information", and some portions also qualify under the narrower definition of trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992), and Public Citizen Heafth Research Group v. FDA, 704F2d1280 (DC Cir. 1983).
(4) Some examples of categories of information which fit into the definition of proprietary information are:
- a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by FPoliSolutions, LLC competitors without license from FPoliSolutions, LLC constitutes a competitive economic advantage over other companies;
- b. Information which, if used 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 of a similar product;
- c. Information which reveals cost or price information, production, capacities, budget levels, or commercial strategies of FPoliSolutions, LLC, its customers, or its suppliers;
- d. Information which reveals aspects of past. present, or future FPoliSolutions, LLC customer funded development plans and programs, resulting in potential products to FPoliSolutions, LLC;
- e. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.
The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a., (4)b., (4~c., and (4)d. above.
(5) To address 10 CFR 2.390 (b) (4), the information sought to be withheld is being submitted to the NRC in confidence. The information is of a sort customarily held in confidence by FPoliSo!utions, LLC, and is in fact so held. The information sought to be withheld has, to Affidavit Page l of 4
AFFIDAVIT PURSUANT TO 10 CFR 2.390 the best of my knowledge and belief, consistently been held in confidence by FPoliSo!utions, LLC, no public disclosure has been made. and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, er must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.
(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or subject to the terms under which it was licensed to FPoliSolutions, LLC_
(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disc!osure.s outside FPoliSolutions, LLC are limited to regulatory bodies, customers, and potential customers. and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with
- appropriate regulatory provisions or proprietary agreements.
(8) The information classified as proprietary was developed ;:md compiled by FPoliSolutions.
LLC at a significant cost to FPoliSolutions. LLC. This information is classified as proprietary because it contains detailed descriptions of analytical approaches and methodologies not available elsewhere. This information would provide other parties, including competitors.
with information from FPoliSolutions' technical database and the res.ults of evaluations performed by FPoliSolutions, LLC. A substantial effort has been expended by FPoliSolutions, LLC to develop this information. Release of this information would improve a competitor's position because it would enable FPoliSolutions' competitor to copy our technology and offer it for sale in competition with our company, causing us financial injury.
{9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to FPoliSolutions' competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of FPoliSolutions' comprehensive safety analysis technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process.
The research, development, engineering, analytical. and NRC review costs comprise a substantial investment of time and money by FPoliSolutions, LLC.
The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.
FPoliSolutions' competitive advantage will be lost if its competitors are able to use the results of the FPoliSolutions, LLC experience to normalize or verify their own process or if
- they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.
Affidavit Page 2 of 4
AFFIDAVIT PURSUANT TO 10 CFR 2.390 The value of this information to FPoliSolutions, LLC would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive FPoliSolutions, LLC of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable analytical tools.
I declare under penalty of perjury that the foregoing is true and correct Executed on this 31st day of October 2017.
Cesare Frepoli President FPoliSolutions, LLC 450 William Pitt ~Vay Pittsburgh, PA 15238 frepolc@fpolisolutions.com Affidavit Page 3 of 4
AFFIDAVIT PURSUANT TO 10 CFR 2.390 STATE OF PENNSILVANIA }
) TOWIT:
COUNTY OF ALLEGHENY)
I, Cesare Frepofi, state that I am the President for FPo!iSofutions, LLC, and that I am duly authorized to execute and file this affidavit on behalf of FPoliSolutions. LLC. To the best of my knowledge and belief, the statements contained in this document with respect to FPoliSolutions, LLC are true and correct.
President FPoliSolutions, LLC Swam to and subscribed before me this -3.L day of O cTOP.Ei (2- , 2017.
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Notary Public My commission expires: :..fa/fl I 0,* ;l.O ~ I Affidavit Page 4 of 4