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Category:Legal-Affidavit
MONTHYEARML23317A1192023-11-10010 November 2023 Constellation Energy Generation, LLC - 2023 Annual Report - Guarantees of Payment of Deferred Premiums ML22320A5592022-11-16016 November 2022 2022 Annual Report - Guarantees of Payment of Deferred Premiums ML21307A0542021-11-0202 November 2021 Annual Report - Guarantees of Payment of Deferred Premiums ML21272A2772021-09-29029 September 2021 Update to Application for Order Approving License Transfers and Proposed Conforming License Amendments ML21057A2732021-02-25025 February 2021 Application for Order Approving License Transfers and Proposed Conforming License Amendments NMP1L3371, Summary of Changes, Quality Assurance Topical Report, NO-AA-10 & Decommissioning Quality Assurance Program, NO-DC-102021-02-10010 February 2021 Summary of Changes, Quality Assurance Topical Report, NO-AA-10 & Decommissioning Quality Assurance Program, NO-DC-10 ML20310A1152020-11-0404 November 2020 Annual Report - Guarantees of Payment of Deferred Premiums ML19318G1702019-11-14014 November 2019 2019 Annual Report - Guarantees of Payment of Deferred Premiums ML18316A0032018-11-0707 November 2018 Submittal of 2018 Annual Report - Guarantees of Payment of Deferred Premiums RS-16-018, Response to Request for Additional Information Regarding Request for License Amendment Regarding Transition to Areva Fuel2016-01-28028 January 2016 Response to Request for Additional Information Regarding Request for License Amendment Regarding Transition to Areva Fuel RS-14-310, License Amendment Request Regarding Spent Fuel Storage Pool Criticality Methodology and Proposed Change to Technical Specification 4.3.1, Criticality2014-12-30030 December 2014 License Amendment Request Regarding Spent Fuel Storage Pool Criticality Methodology and Proposed Change to Technical Specification 4.3.1, Criticality ML14321A7052014-11-14014 November 2014 2014 Annual Report - Guarantees of Payment of Deferred Premiums RS-14-238, Transmittal of Proprietary Meeting Slides2014-08-25025 August 2014 Transmittal of Proprietary Meeting Slides ML14204A7092014-07-23023 July 2014 Enclosure 3, Affidavit of Peter M. Yandow RS-14-160, Co. - Submission of Standard Practice Procedure Plans and Foreign Ownership Control or Influence Package2014-07-0202 July 2014 Co. - Submission of Standard Practice Procedure Plans and Foreign Ownership Control or Influence Package RS-12-227, Exelongeneration, Submission of Standard Practice Procedure Plans and Updated Foreign Ownership Control or Influence Package2012-12-19019 December 2012 Exelongeneration, Submission of Standard Practice Procedure Plans and Updated Foreign Ownership Control or Influence Package ML1127000682011-09-26026 September 2011 Enclosure 3, Mfn 10-245 R4, Affidavit ML1031904262010-11-0808 November 2010 Corp. - 2010 Annual Report - Guarantees of Payment of Deferred Premiums ML0606605542006-03-0101 March 2006 Attachment 2 to March 3, 2006, Letter (Affidavit and Non-proprietary Version of Attachment 1) ML0606203832006-02-22022 February 2006 Affidavit and Non-Proprietary Version of Attachment 1 to February 22, 2006, Exelon Letter ML0604603842006-02-0707 February 2006 Affidavit, Quad Cities Replacement Steam Dryer Meeting on November 8 - 9, 2005 ML0606203682006-01-26026 January 2006 Attachment 3 (Technical Specifications) and 4 (Affidavit and Non-Proprietary Version of Attachment 2 to Exelon Letter Dated January 26, 2006) RS-05-145, Technical Documentation Related to Analysis and Design of New Quad-Cities Steam Dryers, and Responses to Requests for Additional Information Related to EPU Operation at Dresden and Quad-Cities Nuclear Power Stations2005-10-17017 October 2005 Technical Documentation Related to Analysis and Design of New Quad-Cities Steam Dryers, and Responses to Requests for Additional Information Related to EPU Operation at Dresden and Quad-Cities Nuclear Power Stations ML0520003282005-07-14014 July 2005 Surveillance Program for Channel-Control Blade Interference RS-05-061, Response to Request for Additional Information for Review of Quad Cities Replacement Steam Dryer2005-05-12012 May 2005 Response to Request for Additional Information for Review of Quad Cities Replacement Steam Dryer RS-05-055, Technical Documentation Related to Analysis and Design of New Quad Cities Steam Dryers, and Responses to Requests for Additional Information Related to EPU Operation at Dresden and Quad Cities Nuclear Power Stations2005-05-0606 May 2005 Technical Documentation Related to Analysis and Design of New Quad Cities Steam Dryers, and Responses to Requests for Additional Information Related to EPU Operation at Dresden and Quad Cities Nuclear Power Stations RS-05-059, General Electric Technical Documents Related to Analysis and Design of New Quad Cities Steam Dryers, and Responses to Requests for Additional Information Related to EPU Operation at Dresden and Quad Cities Nuclear Power Stations2005-05-0606 May 2005 General Electric Technical Documents Related to Analysis and Design of New Quad Cities Steam Dryers, and Responses to Requests for Additional Information Related to EPU Operation at Dresden and Quad Cities Nuclear Power Stations RS-05-053, Technical Documentation Related to Analysis and Design of New Quad Cities Steam Dryers, and Responses to Requests for Additional Information Related to EPU Operation at Dresden and Quad Cities Nuclear Power Stations2005-04-28028 April 2005 Technical Documentation Related to Analysis and Design of New Quad Cities Steam Dryers, and Responses to Requests for Additional Information Related to EPU Operation at Dresden and Quad Cities Nuclear Power Stations RS-05-040, Technical Documentation Related to Analysis and Design of New Quad Cities Steam Dryers, and Responses to Requests for Additional Information Related to EPU Operation at Dresden and Quad Cities Nuclear Power Stations2005-04-0101 April 2005 Technical Documentation Related to Analysis and Design of New Quad Cities Steam Dryers, and Responses to Requests for Additional Information Related to EPU Operation at Dresden and Quad Cities Nuclear Power Stations ML0504505642005-01-26026 January 2005 Affidavit of David J. Robare Dated January 26, 2005 SVPLTR 04-0020, Core Operating Limits Report for Unit 3 Cycle 18A, Revision 1, and General Electric Affidavit2004-04-30030 April 2004 Core Operating Limits Report for Unit 3 Cycle 18A, Revision 1, and General Electric Affidavit 2023-11-10
[Table view] Category:Letter type:SVPLTR
MONTHYEARSVPLTR 23-0037, Core Operating Limits Report for Cycle 292023-11-29029 November 2023 Core Operating Limits Report for Cycle 29 SVPLTR 23-0021, Registration of Use of Casks to Store Spent Fuel2023-06-20020 June 2023 Registration of Use of Casks to Store Spent Fuel SVPLTR 23-0018, Submittal of 2022 Annual Radiological Environmental Operating Report2023-05-15015 May 2023 Submittal of 2022 Annual Radiological Environmental Operating Report SVPLTR 23-0019, ILT 22-1 (2023-301) Svpltr 23-0019 Post-Exam Submittal Letter (1)2023-05-0101 May 2023 ILT 22-1 (2023-301) Svpltr 23-0019 Post-Exam Submittal Letter (1) SVPLTR 23-0014, Annual Dose Report for 20222023-04-15015 April 2023 Annual Dose Report for 2022 SVPLTR 23-0004, Owner'S Activity Report Submittal Dresden Nuclear Power Station 6500 North Dresden Road Morris, Il 60450 Fifth 10-Year Interval 2022 Refueling Outage Activities2023-02-10010 February 2023 Owner'S Activity Report Submittal Dresden Nuclear Power Station 6500 North Dresden Road Morris, Il 60450 Fifth 10-Year Interval 2022 Refueling Outage Activities SVPLTR 22-0037, Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report2022-09-0707 September 2022 Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report SVPLTR 22-0024, Registration of Use of Casks to Store Spent Fuel2022-06-16016 June 2022 Registration of Use of Casks to Store Spent Fuel SVPLTR 22-0016, Unit 3, Deviation from BWR Vessel and Internals Project (BWRVIP) Guideline - Inspection of Unit 2 and Unit 3 Shroud Vertical Welds2022-06-0808 June 2022 Unit 3, Deviation from BWR Vessel and Internals Project (BWRVIP) Guideline - Inspection of Unit 2 and Unit 3 Shroud Vertical Welds SVPLTR 22-0017, Registration of Use of Casks to Store Spent Fuel2022-05-25025 May 2022 Registration of Use of Casks to Store Spent Fuel SVPLTR 21-0061, Core Operating Limits Report for Dresden Unit 2 Cycle 282021-11-19019 November 2021 Core Operating Limits Report for Dresden Unit 2 Cycle 28 SVPLTR 21-0057, Submittal of 10 CFR 72.48 Evaluation Summary Report2021-10-15015 October 2021 Submittal of 10 CFR 72.48 Evaluation Summary Report SVPLTR 21-0030, Registration of Use of Casks to Store Spent Fuel2021-06-0202 June 2021 Registration of Use of Casks to Store Spent Fuel SVPLTR 21-0028, 2020 Annual Radiological Environmental Operating Report2021-05-0606 May 2021 2020 Annual Radiological Environmental Operating Report SVPLTR 21-0027, Radioactive Effluent Release Report and Offsite Dose Calculation Manual2021-04-22022 April 2021 Radioactive Effluent Release Report and Offsite Dose Calculation Manual SVPLTR 21-0005, Submittal of Analytical Evaluation of Isolation Condenser Nozzle to Shell Weld Flaw Indications (ISI Weld 3/2/1302A-12/12-8)2021-01-29029 January 2021 Submittal of Analytical Evaluation of Isolation Condenser Nozzle to Shell Weld Flaw Indications (ISI Weld 3/2/1302A-12/12-8) SVPLTR 20-0053, Deviation from BWR Vessel and Internals Project (BWRVIP) Guideline - Inspection of Unit 3 Top Guide Rim Weld2020-10-15015 October 2020 Deviation from BWR Vessel and Internals Project (BWRVIP) Guideline - Inspection of Unit 3 Top Guide Rim Weld SVPLTR 20-0045, Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report2020-09-0101 September 2020 Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report SVPLTR 20-0037, Response to Apparent Violation in NRC Inspection Report 05000237/2020012 and 05000249/2020012; EA-20-0532020-07-0202 July 2020 Response to Apparent Violation in NRC Inspection Report 05000237/2020012 and 05000249/2020012; EA-20-053 SVPLTR 20-0027, Registration of Use of Casks to Store Spent Fuel2020-05-14014 May 2020 Registration of Use of Casks to Store Spent Fuel SVPLTR 20-0014, Submittal of 2019 Radioactive Effluent Release Report and Offsite Dose Calculation Manual2020-04-21021 April 2020 Submittal of 2019 Radioactive Effluent Release Report and Offsite Dose Calculation Manual SVPLTR 20-0010, Fifth 10-Year Interval 2019 Refueling Outage Activities2020-02-13013 February 2020 Fifth 10-Year Interval 2019 Refueling Outage Activities SVPLTR 19-0049, Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report2019-09-10010 September 2019 Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report SVPLTR 19-0031, Registration of Use of Casks to Store Spent Fuel2019-06-14014 June 2019 Registration of Use of Casks to Store Spent Fuel SVPLTR 19-0020, Submittal of 2018 Radioactive Effluent Release Report and Offsite Dose Calculation Manual2019-04-19019 April 2019 Submittal of 2018 Radioactive Effluent Release Report and Offsite Dose Calculation Manual SVPLTR 19-0005, Owner'S Activity Report Submittal Fifth 10-Year Interval 2018 Refueling Outage Activities2019-02-0808 February 2019 Owner'S Activity Report Submittal Fifth 10-Year Interval 2018 Refueling Outage Activities SVPLTR 18-0025, Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report2018-08-15015 August 2018 Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report SVPLTR 18-0020, Corrected 2017 Radioactive Effluent Release Report2018-06-28028 June 2018 Corrected 2017 Radioactive Effluent Release Report SVPLTR 18-0018, Registration of Use of Casks to Store Spent Fuel2018-06-14014 June 2018 Registration of Use of Casks to Store Spent Fuel SVPLTR 18-0012, Submittal of 2017 Radioactive Effluent Release Report and Offsite Dose Calculation Manual2018-04-24024 April 2018 Submittal of 2017 Radioactive Effluent Release Report and Offsite Dose Calculation Manual SVPLTR 18-0007, Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revisions 17 and 182018-03-0101 March 2018 Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revisions 17 and 18 SVPLTR 17-0033, Submittal of Corrected 2016 Radioactive Effluent Release Report for January Through December2017-08-29029 August 2017 Submittal of Corrected 2016 Radioactive Effluent Release Report for January Through December SVPLTR 17-0026, Registration of Use of Casks to Store Spent Fuel2017-06-0606 June 2017 Registration of Use of Casks to Store Spent Fuel SVPLTR 17-0017, Submittal of 2016 Radioactive Effluent Release Report2017-04-26026 April 2017 Submittal of 2016 Radioactive Effluent Release Report SVPLTR 16-0027, 2016 Dresden Nuclear Station Initial License Examination Proposed Exam Files - Licensee Letter Transmitting the Proposed Examination/Test to the NRC2016-12-0101 December 2016 2016 Dresden Nuclear Station Initial License Examination Proposed Exam Files - Licensee Letter Transmitting the Proposed Examination/Test to the NRC SVPLTR 16-0061, Core Operating Limits Report for Unit 3 Cycle 252016-11-21021 November 2016 Core Operating Limits Report for Unit 3 Cycle 25 SVPLTR 16-0018, Transmittal of 2015 Radioactive Effluent Release Report and Offsite Dose Calculation Manual2016-04-25025 April 2016 Transmittal of 2015 Radioactive Effluent Release Report and Offsite Dose Calculation Manual SVPLTR 16-0017, Submittal of Post Accident Monitoring Report Instrumentation2016-04-0808 April 2016 Submittal of Post Accident Monitoring Report Instrumentation SVPLTR 16-0001, Cyber-Security Ms 1 Thru 7 Inspection 2014 405; Notification of Completion of Corrective Actions2016-01-21021 January 2016 Cyber-Security Ms 1 Thru 7 Inspection 2014 405; Notification of Completion of Corrective Actions SVPLTR 15-0070, Core Operating Limits Report for Cycle 24A2015-12-15015 December 2015 Core Operating Limits Report for Cycle 24A SVPLTR 15-0065, Core Operating Limits Report for Cycle 252015-11-16016 November 2015 Core Operating Limits Report for Cycle 25 SVPLTR 15-0059, Core Operating Limits Report, Cycle 242015-10-25025 October 2015 Core Operating Limits Report, Cycle 24 SVPLTR 15-0056, 1, 2 and 3 - Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report2015-09-0404 September 2015 1, 2 and 3 - Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report SVPLTR 15-0055, Notification of Readiness for NRC 95001 Inspection2015-08-25025 August 2015 Notification of Readiness for NRC 95001 Inspection SVPLTR 15-0052, Response to Preliminary White Finding2015-08-14014 August 2015 Response to Preliminary White Finding SVPLTR 15-0046, ISFSI - Registration of Use of Casks to Store Spent Fuel2015-07-17017 July 2015 ISFSI - Registration of Use of Casks to Store Spent Fuel SVPLTR 15-0043, Registration of Use of Casks to Store Spent Fuel2015-06-12012 June 2015 Registration of Use of Casks to Store Spent Fuel SVPLTR 15-0034, 2014 Annual Radiological Environmental Operating Report2015-05-14014 May 2015 2014 Annual Radiological Environmental Operating Report SVPLTR 15-0020, Written Position on Preliminary White Finding Discussed in NRC Inspection Report 05000237/2014005; 05000249/20140052015-03-0202 March 2015 Written Position on Preliminary White Finding Discussed in NRC Inspection Report 05000237/2014005; 05000249/2014005 SVPLTR 15-0014, Owner'S Activity Report Submittal Fifth 10-Year Interval 2014 Refueling Outage Activities2015-02-11011 February 2015 Owner'S Activity Report Submittal Fifth 10-Year Interval 2014 Refueling Outage Activities 2023-06-20
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ExekonSM Exelon Generation Company, LLC www.exeloncorp.com Nuclear Dresden Nuclear Power Station 6500 North Dresden Road Morris, IL 60450-9765 April 30, 2004 SVPLTR: #04-0020 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington D.C. 20555-0001 Dresden Nuclear Power Station, Unit 3 Facility Operating License No. DPR-25 NRC Docket No. 50-249
Subject:
Core Operating Limits Report for Unit 3 Cycle 18A, Revision 1 The purpose of this letter is to transmit Revision 1 of the Core Operating Limits Report (COLR) for Dresden Nuclear Power Station (DNPS) Unit 3 operating cycle 18A D3C18A in accordance with Technical Specifications Section 5.6.5, "CORE OPERATING LIMITS REPORT (COLR)."
The Unit 3 COLR contains proprietary information of the type that General Electric (GE) maintains in confidence and withholds from public disclosure. The information has been handled and classified as proprietary to GE as indicated in the affidavit included in Attachment A. Exelon Generation Company, LLC (EGC) hereby requests that Attachment B be withheld from public disclosure in accordance with 10 CFR 2.390, "Public inspections, exemptions, requests for withholding," and 10 CFR 9.17, "Agency records exempt from public disclosure."
This revision to the Unit 3 COLR was issued to remove the Control Blade History impact on LHGR associated with the transition to Powerplex IlIl Core Monitoring Code. The Unit 3 COLR is contained in Attachment B to this letter.
The non-proprietary COLR version is contained in Attachment C to this letter.
Should you have any questions concerning this letter, please contact Mr. Jeff Hansen at (815) 416-2800.
Respectfully, Danny . Bost Site e President Dr den Nuclear Power Station Attachments: A - General Electric Affidavit B - Core Operating Limits Report for Dresden Unit 3 Cycle 18A, Revision 1 (Proprietary version)
C - Core Operating Limits Report for Dresden Unit 3 Cycle 18A, Revision 1 (Non-Proprietary version) cc: Regional Administrator- NRC Region IlIl NRC Senior Resident Inspector - Dresden Nuclear Power Station 4fDol
Attachment A General Electric Affidavit
Affidavit Affidavit 1,Jens G. M. Andersen, state as follows:
(1) I am Fellow and project manager, TRACG Development, Global Nuclear Fuel -
Americas, L.L.C. ("GNF-A") and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.
(2) The information' sought to be withheld is contained in the attachment, "Core Operating Limits Report for Dresden Unit 3 Cycle 18A, Revision 1". GNF proprietary information is indicated by enclosing it in double brackets. In each case, the superscript notation (3)refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.
(3) In making this application for withholding of proprietary information of which it is the owner or licensee, GNF-A relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 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 2.790(a)(4) for "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 Energv Project v. Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992), and Public Citizen Health 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 GNF-A's competitors without license from GNF-A 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 GNF-A, its customers, or its suppliers;
- d. Information which reveals aspects of past, present, or future GNF-A customer-funded development plans and programs, of potential commercial value to GNF-A;
- e. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.
-Affidavit The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b., above.
(5) To address the 10 CFR 2.790 (b) (4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GNF-A, and is in fact so held. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in (6) and (7) following. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GNF-A, 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, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence.
(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 GNF-A. Access to such documents within GNF-A is limited on a "need to know" basis.
(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 Operationjfor technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GNF-A 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 identified in paragraph (2) is classified as proprietary because it contains details of GNF-A's fuel design and licensing methodology.
The development of the methods used in these analyses, along with the testing, development and approval of the supporting methodology was achieved at a significant cost, on the order of several million dollars, to GNF-A or its licensor.
(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GNF-A's competitive position and foreclose or reduce the availability of profit-making opportunities. The fuel design and licensing methodology is part of GNF-A's comprehensive BWR safety and 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. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.
The research, development, engineering, analytical, and NRC review costs comprise a substantial investment of time and money by GNF-A or its licensor.
Affidavit 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.
GNF-A's competitive advantage will be lost if its competitors are able to use the results of the GNF-A 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.
The value of this information to GNF-A 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 GNF-A 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 affidavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.
Executed at Wilmington, North Carolina, this 8th day of April, 2004.
Jens G. M. Andersen Global Nuclear Fuel - Americas, LLC