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Category:Letter type:RS
MONTHYEARRS-23-120, Supplemental Information Letter for Part 73 Exemption Request - Responses to Request for Confirmatory Information2023-11-10010 November 2023 Supplemental Information Letter for Part 73 Exemption Request - Responses to Request for Confirmatory Information RS-23-103, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-10-13013 October 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation RS-23-097, Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans2023-10-12012 October 2023 Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans RS-23-080, Constellation Energy Generation, LLC, Application to Revise Technical Specifications to Adopt TSTF-264-A, Revision 0, 3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs2023-08-30030 August 2023 Constellation Energy Generation, LLC, Application to Revise Technical Specifications to Adopt TSTF-264-A, Revision 0, 3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs RS-23-087, Revision to Approved Alternatives Associated with the Use of the BWRVIP Guidelines in Lieu of Specific ASME Code Requirements on Reactor2023-08-0404 August 2023 Revision to Approved Alternatives Associated with the Use of the BWRVIP Guidelines in Lieu of Specific ASME Code Requirements on Reactor RS-23-084, Response to Request for Additional Information Regarding the Application to Revise Design Basis to Allow Use of Plastic Section Properties in Lower Downcomer Braces Analysis2023-07-24024 July 2023 Response to Request for Additional Information Regarding the Application to Revise Design Basis to Allow Use of Plastic Section Properties in Lower Downcomer Braces Analysis RS-23-077, Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations2023-06-16016 June 2023 Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations RS-23-042, Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling2023-05-25025 May 2023 Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling RS-23-049, Constellation Energy Generation, LLC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations2023-03-23023 March 2023 Constellation Energy Generation, LLC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations RS-23-048, Exigent Amendment Request to Revise Design Basis Related to Seismic Requirements2023-03-0707 March 2023 Exigent Amendment Request to Revise Design Basis Related to Seismic Requirements RS-23-045, Constellation Energy Generation, LLC Submittal of Fitness for Duty Performance Data Reports for 2022 Per 10 CFR 26.717(c) & 10 CFR 26.2032023-02-28028 February 2023 Constellation Energy Generation, LLC Submittal of Fitness for Duty Performance Data Reports for 2022 Per 10 CFR 26.717(c) & 10 CFR 26.203 RS-23-037, Annual 10 CFR 50.46 Report of Emergency Core Cooling System Evaluation Model Changes and Errors for LaSalle County Station2023-02-22022 February 2023 Annual 10 CFR 50.46 Report of Emergency Core Cooling System Evaluation Model Changes and Errors for LaSalle County Station RS-23-003, Constellation Energy Generation, LLC, Summary of Changes to Quality Assurance Topical Report, NO-AA-10, and Decommissioning Quality Assurance Program, NO-DC-102023-01-31031 January 2023 Constellation Energy Generation, LLC, Summary of Changes to Quality Assurance Topical Report, NO-AA-10, and Decommissioning Quality Assurance Program, NO-DC-10 RS-22-085, Application to Revise Design Basis to Allow Use of Plastic Section Properties in Lower Downcomer Braces Analysis2023-01-12012 January 2023 Application to Revise Design Basis to Allow Use of Plastic Section Properties in Lower Downcomer Braces Analysis RS-23-006, Supplemental Information Regarding License Amendment Request Relocation of Pressure and Temperature Limit Curves to the Pressure and Temperature Limits Report2023-01-10010 January 2023 Supplemental Information Regarding License Amendment Request Relocation of Pressure and Temperature Limit Curves to the Pressure and Temperature Limits Report RS-22-126, Constellation Energy Generation, LLC - Request to Use Provisions of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI2022-11-30030 November 2022 Constellation Energy Generation, LLC - Request to Use Provisions of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI RS-22-109, Response to Request for Additional Information License Amendments Related to Fuel Storage2022-10-12012 October 2022 Response to Request for Additional Information License Amendments Related to Fuel Storage RS-22-092, Nine and Quad Cities - Application to Revise Primary Containment Isolation Instrumentation Technical Specifications in Accordance with TSTF-306, Revision 2, Add Action to LCO 3.3.6.1 to Give Option to Isolate the Penetration2022-10-0303 October 2022 Nine and Quad Cities - Application to Revise Primary Containment Isolation Instrumentation Technical Specifications in Accordance with TSTF-306, Revision 2, Add Action to LCO 3.3.6.1 to Give Option to Isolate the Penetration RS-22-093, Advisement of Leadership Changes for Constellation Energy Generation, LLC and Submittal of Updated Standard Practice Procedures Plans2022-08-18018 August 2022 Advisement of Leadership Changes for Constellation Energy Generation, LLC and Submittal of Updated Standard Practice Procedures Plans RS-22-083, Response to Request for Additional Information Related to the License Amendment Request to Change New Fuel Storage Vault and Spent Fuel Storage Pool Criticality Methodologies, with Proposed Changes to Technical2022-06-17017 June 2022 Response to Request for Additional Information Related to the License Amendment Request to Change New Fuel Storage Vault and Spent Fuel Storage Pool Criticality Methodologies, with Proposed Changes to Technical RS-22-051, Constellation Energy Generation, LLC - Update to Correspondence Addressees and Service Lists2022-04-12012 April 2022 Constellation Energy Generation, LLC - Update to Correspondence Addressees and Service Lists RS-22-049, Constellation Energy Generation, LLC, Supplemental Information to Correct Typographical Errors in Constellation'S Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for2022-04-0404 April 2022 Constellation Energy Generation, LLC, Supplemental Information to Correct Typographical Errors in Constellation'S Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for V RS-22-045, Constellation Energy Generation, LLC, Response to NRC Regulatory Issue Summary 2022-01, Preparation and Scheduling of Operator Licensing Examinations2022-03-25025 March 2022 Constellation Energy Generation, LLC, Response to NRC Regulatory Issue Summary 2022-01, Preparation and Scheduling of Operator Licensing Examinations RS-22-035, Supplemental Information Regarding Relief Request I4R-13 Relief from Code Examinations for 1B33-F060A and 1B33-F060B Repairs2022-03-0404 March 2022 Supplemental Information Regarding Relief Request I4R-13 Relief from Code Examinations for 1B33-F060A and 1B33-F060B Repairs RS-22-033, Response to Request for Additional Information Regarding Relief Request I4R-13 Relief from Code Examinations for 1B33-F060A and 1B33-F060B Repairs2022-03-0303 March 2022 Response to Request for Additional Information Regarding Relief Request I4R-13 Relief from Code Examinations for 1B33-F060A and 1B33-F060B Repairs RS-22-032, Relief Request I4R-13 Relief from Code Examinations for 1B33-F060A and 1B33-F060B Repairs2022-03-0202 March 2022 Relief Request I4R-13 Relief from Code Examinations for 1B33-F060A and 1B33-F060B Repairs RS-22-023, Constellation Energy Generation, LLC, Executed Trust Fund Agreement Amendment and Subordinate Trust Agreement2022-02-23023 February 2022 Constellation Energy Generation, LLC, Executed Trust Fund Agreement Amendment and Subordinate Trust Agreement RS-22-027, Constellation, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated2022-02-23023 February 2022 Constellation, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated P RS-22-018, Annual 10 CFR 50.46 Report of Emergency Core Cooling System Evaluation Model Changes and Errors for LaSalle County Station2022-02-22022 February 2022 Annual 10 CFR 50.46 Report of Emergency Core Cooling System Evaluation Model Changes and Errors for LaSalle County Station RS-22-019, Constellation Energy Generation, LLC - Update to Correspondence Addressees and Service Lists2022-02-16016 February 2022 Constellation Energy Generation, LLC - Update to Correspondence Addressees and Service Lists RS-22-015, Notification of Completion of License Transfer and Request to Continue Processing Pending NRC Actions Previously Requested by Exelon Generation Company, LLC2022-02-0101 February 2022 Notification of Completion of License Transfer and Request to Continue Processing Pending NRC Actions Previously Requested by Exelon Generation Company, LLC RS-22-004, Supplement to Application to Adopt TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements2022-01-0404 January 2022 Supplement to Application to Adopt TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements RS-21-121, Proposed Changes to Decommissioning Trust Agreements and Master Terms2021-12-15015 December 2021 Proposed Changes to Decommissioning Trust Agreements and Master Terms RS-21-115, Supplemental Information for License Amendment Request Regarding New Fuel Storage Vault and Spent Fuel Storage Pool Criticality Methodologies, with Proposed Changes to Technical Specifications 4.3.1 and 5.6.52021-11-0404 November 2021 Supplemental Information for License Amendment Request Regarding New Fuel Storage Vault and Spent Fuel Storage Pool Criticality Methodologies, with Proposed Changes to Technical Specifications 4.3.1 and 5.6.5 RS-21-109, Request to Withhold Meeting Materials for the Non-Public Meeting Held on September 2, 20212021-10-14014 October 2021 Request to Withhold Meeting Materials for the Non-Public Meeting Held on September 2, 2021 RS-21-091, Implementation of Insider Threat Program Requirements Associated with the Voluntary Security Clearance Program and Advisement of Leadership Changes2021-09-13013 September 2021 Implementation of Insider Threat Program Requirements Associated with the Voluntary Security Clearance Program and Advisement of Leadership Changes RS-21-078, Response to Request for Additional Information for Application to Revise Technical Specification to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements, and TSTF-583-T, TSTF-582 Diesel2021-08-19019 August 2021 Response to Request for Additional Information for Application to Revise Technical Specification to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements, and TSTF-583-T, TSTF-582 Diesel RS-21-085, Response to Request for Additional Information Regarding License Amendment Request to Incorporate Licensing Topical Report NEDE-33885PA, Revision 1, GNF CRDA Application Methodology (EPID-L-2021-LLA-0016)2021-08-17017 August 2021 Response to Request for Additional Information Regarding License Amendment Request to Incorporate Licensing Topical Report NEDE-33885PA, Revision 1, GNF CRDA Application Methodology (EPID-L-2021-LLA-0016) RS-21-063, Application to Adopt TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements2021-06-30030 June 2021 Application to Adopt TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements RS-21-064, License Amendment Request Re New Fuel Storage Vault and Spent Fuel Storage Pool Criticality Methodologies - Cover Letter2021-06-30030 June 2021 License Amendment Request Re New Fuel Storage Vault and Spent Fuel Storage Pool Criticality Methodologies - Cover Letter RS-21-070, Proposed Alternative to Utilize Code Case N-8932021-06-30030 June 2021 Proposed Alternative to Utilize Code Case N-893 RS-21-055, Response to Third Round Request for Additional Information (Rals) for LaSalle License Amendment Request to Adopt Risk Informed Completion Times TSTF- 505, Revision 2, Provide Risk-Informed Extended.2021-05-10010 May 2021 Response to Third Round Request for Additional Information (Rals) for LaSalle License Amendment Request to Adopt Risk Informed Completion Times TSTF- 505, Revision 2, Provide Risk-Informed Extended. RS-21-054, Response to NRC Regulatory Issue Summary 2021-01, Preparation and Scheduling of Operator Licensing Examinations2021-04-29029 April 2021 Response to NRC Regulatory Issue Summary 2021-01, Preparation and Scheduling of Operator Licensing Examinations RS-21-050, Response to Request for Additional Information (RAI) Regarding Request for License Amendment Regarding Ultimate Heat Sink (EPID-L-2020-LLA-0165)2021-04-16016 April 2021 Response to Request for Additional Information (RAI) Regarding Request for License Amendment Regarding Ultimate Heat Sink (EPID-L-2020-LLA-0165) RS-21-045, Response to Request for Additional Information (RAI) Regarding Request for License Amendment Regarding Ultimate Heat Sink (EPID-L-2020-LLA-0165)2021-04-0707 April 2021 Response to Request for Additional Information (RAI) Regarding Request for License Amendment Regarding Ultimate Heat Sink (EPID-L-2020-LLA-0165) RS-21-040, Response to Second Round Request for Additional Information (Rais) for License Amendment Request to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b2021-03-31031 March 2021 Response to Second Round Request for Additional Information (Rais) for License Amendment Request to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b RS-21-043, Supplemental Information Regarding Relief Request I4R-12 Relief from Code Examinations for 2B33-F060A and 2B33-F060B Repairs, Revision 22021-03-26026 March 2021 Supplemental Information Regarding Relief Request I4R-12 Relief from Code Examinations for 2B33-F060A and 2B33-F060B Repairs, Revision 2 RS-21-042, Relief Request I4R-12 Relief from Code Examinations for 2B33-F060A and 2B33-F060B Repairs, Revision 22021-03-26026 March 2021 Relief Request I4R-12 Relief from Code Examinations for 2B33-F060A and 2B33-F060B Repairs, Revision 2 RS-21-039, Supplemental Information Regarding Application for Order Approving Transfers and Proposed Conforming License Amendments2021-03-25025 March 2021 Supplemental Information Regarding Application for Order Approving Transfers and Proposed Conforming License Amendments RS-21-035, Relief Request I4R-12 Relief from Code Examinations for 2B33-F060A and 2B33-F060B Repairs2021-03-0909 March 2021 Relief Request I4R-12 Relief from Code Examinations for 2B33-F060A and 2B33-F060B Repairs 2023-08-04
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ATTACHMENT 10 Cameron International Corporation Affidavits Supporting Withholding
Measurement Systems Caldon Ultrasonics Technology Center 1000 McClaren Woods Drive Coraopolis, PA 15108 Tel 7'2427'3-9300 CAMERON Fax 7'2427'3-9301 www.c-a-m .com January 27, 2010 Document Control Desk U. S. Nuclear Regulatory Commission Washington,, DC 20555 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
1 . Caldons Ultrasonics Engineering Report ER-629 Rev. 1 "Bounding Uncertainty Analysis for Thermal Power Determination at LaSalle Unit 1 Using the LEFM,/+ System"
- 2. Caldon' Ultrasonics Engineering Report No. ER--644 Rev. 0, "LEFM,I + Meter Factor Calculation and Accuracy Assessment for LaSalle Unit 1 Nuclear Power Station"
- 3. Caldon Ultrasonics Engineering Report ER--746 Rev. 1 a "Bounding Uncertainty Analysis for Thermal Power Determination at LaSalle Unit 2 Using the LEFM,/ + System"
- 4. Caldon' Ultrasonics Engineering Report No. ER-791 Rev. 0, "Meter Factor Calculation and Accuracy Assessment for LaSalle Unit 2" Gentlemen:
This application for withholding is submitted by Cameron International Corporation, a Delaware Corporation (herein called "Cameron") on behalf of its operating unit, Caldon Ultrasonics Technology Center, pursuant to the provisions of paragraph (b)(1) of Section 2.390 ofthe Commission's regulations. It contains trade secrets and/or commercial information proprietary to Cameron and customarily held in confidence.
The proprietary information for which withholding is being requested is identified in the subject submittal. In conformance with 10 CFR Section 2.390, Affidavit CAW 10-01 accompanies this application for withholding setting forth the basis on which the identified proprietary information may be withheld from public disclosure .
January 27, 2010 Page 2 Accordingly, it is respectfully requested that the subject information, which is proprietary to Cameron, be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations .
Correspondence with respect to this application for withholding or the accompanying affidavit should reference CAW 10-01 and should be addressed to the undersigned .
Very truly yours, Ernest M. Hauser Director of Sales Enclosures (Only upon separation of the enclosed confidential material should this letter and affidavit be released.)
January 27, 2010 CAW 10-01 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF ALLEGHENY :
Before me, the undersigned authority, personally appeared Ernest M. Hauser, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Cameron International Corporation, a Delaware Corporation (herein called "Cameron") on behalf of its operating unit, Caldon Ultrasonics Technology Center, and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:
Sworn to and subscribed before me this day of 2010 Not COMMONWEALTH OF PENNSYLVANIA NOWM Seal Thomas, Notary Pub0c County 2011 Member, Pennsylvania Association of Notaries
January 27, 2010 CAW 10-01
- 1. 1 am the Director of Sales of Caldon Ultrasonics Technology Center, and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rulemaking proceedings, and am authorized to apply for its withholding on behalf of Cameron.
- 2. I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Cameron application for withholding accompanying this Affidavit .
3 . I have personal knowledge of the criteria and procedures utilized by Cameron in designating information as a trade secret, privileged or as confidential commercial or financial information.
The material and information provided herewith is so designated by Cameron, in accordance with those criteria and procedures, for the reasons set forth below.
- 4. Pursuant to the provisions of paragraph (b) (4) of Section 2.390 of the Commission's regulations, 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 Cameron.
The information is of a type customarily held in confidence by Cameron and not customarily disclosed to the public. Cameron has a rational basis for determining the types of information customarily held in confidence by it and, in that connection utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Cameron policy and provides the rational basis required. Furthermore, the information is submitted voluntarily and need not rely on the evaluation of any rational basis .
January 27, 2010 CAW 10-01 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 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 Cameron's competitors without license from Cameron 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, and assurance of quality, or licensing a similar product.
(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Cameron, its customer or suppliers .
(e) It reveals aspects of past, present or future Cameron or customer funded development plans and programs of potential customer value to Cameron.
(I} It contains patentable ideas, for which patent protection may be desirable .
There are sound policy reasons behind the Cameron system, which include the following :
(a) The use of such information by Cameron gives Cameron a competitive advantage over its competitors . It is, therefore, withheld from disclosure to protect the Cameron competitive position.
January 27, 2010 CAW 10-01 (b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Cameron ability to sell products or services involving the use of the information.
(c) Use by our competitor would put Cameron at a competitive disadvantage by reducing his expenditure of resources at our expense.
(d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Cameron of a competitive advantage.
(e) Unrestricted disclosure would jeopardize the position of prominence of Cameron in the world market, and thereby give a market advantage to the competition of those countries .
(fl The Cameron capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.
(iii) The information is being transmitted to the Commission in confidence, and, under the provisions of 10 CFR §§ 2. 390, it is to be received in confidence by the Commission.
(iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same manner or method to the best of our knowledge and belief.
January 27, 2010 CAW 10-01 (v) The proprietary information sought to be withheld are the submittals titled :
" Caldone Ultrasonics Engineering Report ER-629 Rev. 1 "Bounding Uncertainty Analysis for Thermal Power Determination at LaSalle Unit 1 Using the LEFMJ +
System"
" Caldone Ultrasonics Engineering Report No. ER-644 Rev. 0, "LEFM./ + Meter Factor Calculation and Accuracy Assessment for LaSalle Unit 1 Nuclear Power Station."
" Caldone Ultrasonics Engineering Report ER746 Rev. 1 a "Bounding Uncertainty Analysis for Thermal Power Determination at LaSalle Unit 2 Using the LEFMJ +
System"
" Caldone Ultrasonics Engineering Report No. ER-791 Rev. 0, "Meter Factor Calculation and Accuracy Assessment for LaSalle Unit 2" It is designated therein in accordance with 10 CFR §§ 2.390(b)(1)(i)(A,B), with the reason(s) for confidential treatment noted in the submittal and further described in this affidavit. This information is voluntarily submitted for use by'the NRC Staff in their review of the accuracy assessment of the proposed methodology for LEFM CheckPlus Systems used by LaSalle Units 1 and 2 for an MUR UPRATE.
Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Cameron because it would enhance the ability of competitors to provide similar flow and temperature measurement systems 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 the right to use the information.
January 27, 2010 CAW 10-01 The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Cameron effort and the expenditure of a considerable sum of money.
In order for competitors of Cameron to duplicate this information, similar products would have to be developed, similar technical programs would have to be performed, and a significant manpower effort, having -the requisite talent and experience, would have to be expended for developing analytical methods and receiving NRC approval for those methods .
Further the deponent sayeth not.