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Category:Legal-Affidavit
MONTHYEARULNRC-06829, Affidavit2023-08-0303 August 2023 Affidavit ULNRC-06808, Affidavit2023-04-27027 April 2023 Affidavit ULNRC-06796, Enclosure 6 - Affidavit for Withholding by Kimberly Manzione2023-02-14014 February 2023 Enclosure 6 - Affidavit for Withholding by Kimberly Manzione ULNRC-06783, Enclosure 2: Affidavit for Withholding2022-11-16016 November 2022 Enclosure 2: Affidavit for Withholding ULNRC-06774, Affidavits for Withholding2022-10-26026 October 2022 Affidavits for Withholding ULNRC-06768, Attachment 4 to Enclosure 1: Framatome Affidavits for Withholding from Public Disclosure2022-10-0707 October 2022 Attachment 4 to Enclosure 1: Framatome Affidavits for Withholding from Public Disclosure ULNRC-06723, Attachment 4 to Enclosure 1 - Holtec Affidavit for Withholding2022-06-30030 June 2022 Attachment 4 to Enclosure 1 - Holtec Affidavit for Withholding ULNRC-06729, Attachment 4 - Framatome Affidavits for Withholding2022-06-0202 June 2022 Attachment 4 - Framatome Affidavits for Withholding ULNRC-06716, Presentation Information for Third Pre-Application Meeting Regarding Use of Framatome Fuel - Affidavit2022-02-11011 February 2022 Presentation Information for Third Pre-Application Meeting Regarding Use of Framatome Fuel - Affidavit ULNRC-06695, Affidavit of Morris Byram, Framatome, Inc2021-09-30030 September 2021 Affidavit of Morris Byram, Framatome, Inc ULNRC-06694, Framatome, Inc - Affidavit for Morris Byram2021-09-24024 September 2021 Framatome, Inc - Affidavit for Morris Byram ULNRC-06654, Affidavit for Morris Byram2021-05-0303 May 2021 Affidavit for Morris Byram ULNRC-06603, Corrected Affidavit for Proprietary Information Provided in Support of License Amendment Request Regarding Defferal of Upcoming Steam Generator Inspection (LDCN 20-001)2020-09-0303 September 2020 Corrected Affidavit for Proprietary Information Provided in Support of License Amendment Request Regarding Defferal of Upcoming Steam Generator Inspection (LDCN 20-001) ULNRC-06595, Response to Request for Additional Information Regarding License Amendment Request for Deferral of Upcoming Steam Generator Inspection (LDCN 20-0013))2020-08-25025 August 2020 Response to Request for Additional Information Regarding License Amendment Request for Deferral of Upcoming Steam Generator Inspection (LDCN 20-0013)) ULNRC-06586, Attachment 4 - Affidavit2020-06-24024 June 2020 Attachment 4 - Affidavit ML14093A7752014-03-28028 March 2014 Attachment 3: Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-14-3933, Accompanying Affidavit, Proprietary Information Notice, and Copyright Notice ULNRC-06108, Attachment 3: Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-14-3933, Accompanying Affidavit, Proprietary Information Notice, and Copyright Notice2014-03-28028 March 2014 Attachment 3: Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-14-3933, Accompanying Affidavit, Proprietary Information Notice, and Copyright Notice ML12298A0302012-10-22022 October 2012 Transmittal of Pci Proprietary Document No. PCI-2012.10.22-1 Rev 0; Responses to Staff Comments Dated July 11, 2012 2023-08-03
[Table view] Category:License-Application for Facility Operating License (Amend/Renewal) DKT 50
MONTHYEARULNRC-06827, Supplement to License Amendment Request Regarding Support System Requirements for Residual Heat Removal and Control Room Air Conditioning Systems Under Technical Specifications 3.4.8, 3.7.11, and 3.9.6 (LDCN 22-0029)2023-11-20020 November 2023 Supplement to License Amendment Request Regarding Support System Requirements for Residual Heat Removal and Control Room Air Conditioning Systems Under Technical Specifications 3.4.8, 3.7.11, and 3.9.6 (LDCN 22-0029) ML23215A1972023-08-0303 August 2023 Supplement to License Amendment and Exemption Request Regarding Use of Framatome Gaia Fuel (LDCN 22-0002) ML23088A1202023-03-29029 March 2023 Application to Revise Technical Specifications to Adopt TSTF-501-A, Rev. 1, Evaluation of the Proposed Change ML23088A1242023-03-29029 March 2023 Attachment 4: List of Commitments ULNRC-06751, Application to Revise Technical Specifications to Adopt TSTF-501-A, Rev. 1, Relocate Stored Oil & Lube Oil Volume Values to Licensee Control2023-03-29029 March 2023 Application to Revise Technical Specifications to Adopt TSTF-501-A, Rev. 1, Relocate Stored Oil & Lube Oil Volume Values to Licensee Control ULNRC-06781, License Amendment Request to Clarify Support System Requirements for the Residual Heat Removal System and Control Room Air Conditioning System Under Technical Specifications 3.4.8, 3.7.11, and 3.9.6 (LDCN 22-0029)2022-12-0101 December 2022 License Amendment Request to Clarify Support System Requirements for the Residual Heat Removal System and Control Room Air Conditioning System Under Technical Specifications 3.4.8, 3.7.11, and 3.9.6 (LDCN 22-0029) ULNRC-06780, Additional Supplement to License Amendment Request to Adopt TSTF-439 and TSTF-505, LDCN 20-0072022-11-30030 November 2022 Additional Supplement to License Amendment Request to Adopt TSTF-439 and TSTF-505, LDCN 20-007 ML22307A3142022-11-0303 November 2022 Attachment 2: Proposed Technical Specification 5.5.16 Changes (Markup) ML22307A3122022-11-0303 November 2022 Evaluation of the Proposed Change ML22307A3152022-11-0303 November 2022 Attachment 3: Proposed Technical Specification 5.5.16 Changes (Clean Pages) ML22307A3132022-11-0303 November 2022 Attacchment 1: 54032-CALC-01, Revision 1,Callaway Plant: Evaluation of Risk Significance of Permanent ILRT Extension ML22285A1192022-10-12012 October 2022 Attachment 2 to Enclosure 1: Revised Clean Technical Specifications ML22285A1242022-10-12012 October 2022 Attachment 7 to Enclosure 1: ANP-3943NP, Callaway Small Break LOCA Analysis with Gaia Fuel Design, Revision 1, Dated October 2022 ML22285A1232022-10-12012 October 2022 Attachment 6 to Enclosure 1: ANP-3944NP, Callaway Realistic Large Break LOCA Analysis with Gaia Fuel Design, Revision 1, Dated October 2022 ML22285A1222022-10-12012 October 2022 Attachment 5 to Enclosure 1: ANP-3947NP, Callaway Unit 1 License Amendment Request Inputs for Use of Framatome Fuel, Revision 3, Dated October 2022 ML22285A1182022-10-12012 October 2022 Attachment 1 to Enclosure 1: Marked-Up Existing Technical Specifications ML22285A1172022-10-12012 October 2022 Enclosure 1: Description and Assessment of the Proposed Change ML22285A1202022-10-12012 October 2022 Attachment 3 to Enclosure 1: Marked-Up Technical Specifications Bases (for Information Only) ML22285A1252022-10-12012 October 2022 Attachment 8 to Enclosure 1: ANP-3969NP, Callaway Non-LOCA Summary Report, Revision 2, Dated October 2022 ULNRC-06768, Attachment 4 to Enclosure 1: Framatome Affidavits for Withholding from Public Disclosure2022-10-0707 October 2022 Attachment 4 to Enclosure 1: Framatome Affidavits for Withholding from Public Disclosure ML22242A2932022-08-29029 August 2022 Attachment 5 to Enclosure 1 - Criticality Safety Evaluation Report ML22242A1242022-08-29029 August 2022 Enclosure 1: Description and Assessment of the Proposed Change ML22242A1262022-08-29029 August 2022 Attachment 2 to Enclosure 1 - Revised Clean Technical Specifications ML22242A1272022-08-29029 August 2022 Attachment 3 to Enclosure 1 - Marked-Up Technical Specification Bases ML22242A1252022-08-29029 August 2022 Attachment 1 to Enclosure 1 - Marked-Up Existing Technical Specifications ML22216A2412022-08-0404 August 2022 Application to Revise Technical Specifications to Adopt TSTF 577, Revised Frequencies for Steam Generator Tube Inspections (LDCN 21-0013) - Description and Assessment ML22181B1392022-06-30030 June 2022 Attachment 9 - Responses to NRC Audit Questions ULNRC-06723, Attachment 4 to Enclosure 1 - Holtec Affidavit for Withholding2022-06-30030 June 2022 Attachment 4 to Enclosure 1 - Holtec Affidavit for Withholding ML22181B1382022-06-30030 June 2022 Attachment 8 - Revised Operating License Changes ML22181B1372022-06-30030 June 2022 Attachment 7 - Proposed Operating License Changes (Mark-up) ML22181B1312022-06-30030 June 2022 Attachment 1 - Replacement for Attachment 1, Description and Assessment, of ULNRC-06688 ML22181B1352022-06-30030 June 2022 Attachment 5 - Replacement for Attachment 5, Cross-Reference of TSTF-505 and Callaway Technical Specifications, of ULNRC-06688 ML22153A1762022-06-0202 June 2022 Enclosure 1 - Description and Assessment of the Proposed Change ML22153A1752022-06-0202 June 2022 ULNRC-06729: Application for Technical Specification Change and Exemption Request Regarding Transition to Framatome Fuel, LDCN 22-0002 ML22153A1812022-06-0202 June 2022 Attachment 5 - Non-Proprietary Version of Licensing Summary Report ML22039A3192022-02-0808 February 2022 Enclosure 1: Callaway Plant - Description of the Proposed Changes ML22027A8072022-01-27027 January 2022 Enclosure 2: Callaway, Unit 1, License Amendment Request for Risk-Informed Approach to Resolution of Generic Letter 2004-02 ULNRC-06690, Enclosure 5: Callaway, Unit 1, LAR Supplement to Address Audit Discussion Points Summarized in NRC Letter Dated September 14, 2021 (ML21238A138)2022-01-27027 January 2022 Enclosure 5: Callaway, Unit 1, LAR Supplement to Address Audit Discussion Points Summarized in NRC Letter Dated September 14, 2021 (ML21238A138) ML21335A4532021-12-0101 December 2021 Enclosure 1: Full Scope Implementation of Alternative Source Term - Evaluation of Proposed Changes ML21335A4522021-12-0101 December 2021 Supplement to License Amendment Request for Adoption of Alternative Source Term and Revision of Technical Specifications ML21328A1842021-11-24024 November 2021 Supplement to License Amendment Request to Adopt TSTF-439 and TSTF-505, LDCN 20-0007 ML21294A4042021-10-21021 October 2021 Enclosure 4 - Information Supporting Justification of Excluding Sources of Risk Not Addressed by the PRA Models ML21294A4102021-10-21021 October 2021 Enclosure 10 - Program Implementation ML21294A4112021-10-21021 October 2021 Enclosure 11 - Monitoring Program ML21294A4122021-10-21021 October 2021 Enclosure 12 - Risk Management Action Examples ML21294A4092021-10-21021 October 2021 Enclosure 9 - Key Assumptions and Sources of Uncertainty ML21294A4082021-10-21021 October 2021 Enclosure 8 - Attributes of the Real Time Risk Model ML21294A4072021-10-21021 October 2021 Enclosure 7 - PRA Model Update Process ML21294A4062021-10-21021 October 2021 Enclosure 6 - Justification of Application of At-Power PRA Models to Shutdown Modes ML21294A4032021-10-21021 October 2021 Enclosure 3 - Information Supporting Technical Adequacy of PRA Models Without PRA Standards Endorsed by Regulatory Guide 1.200, Revision 2 2023-08-03
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Attachment 4 to to ULNRC-06723 Page 1 of 6 ATTACHMENT 4 HOLTEC AFFIDAVIT FOR WITHHOLDING The following pages provide an affidavit signed by HOLTEC International that sets forth the basis on which the proprietary information in Attachment 6 may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in 10 CFR 2.390(b)(4). Correspondence with respect to the proprietary aspects of Attachment 6 or the supporting HOLTEC affidavit should be addressed to Kimberly Manzione of HOLTEC International.
5 pages follow this cover sheet
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Document ID ULNRC-06723-aff AFFIDAVIT PURSUANT TO 10 CFR 2.390 I, Kimberly Manzione, being duly sworn, depose and state as follows:
( 1) I have reviewed the information described in paragraph (2) which is sought to be withheld, and am authorized to apply for its withholding.
(2) The information sought to be withheld is information provided in reference documents listed below as noted in Ameren Letter ULNRC-06723 and Ameren Licensing Document Change Notice LDCN 22-0015. These following references contain Holtec Proprietary information:
- HI-2220020, Criticality Safety Analysis of SFP for Callaway Nuclear Generating Station
- HI-2220327, Criticality Safety Analysis of SFP for Callaway Nuclear Generating Station (Calculation Package)
(3) In making this application for withholding of proprietary information of which it is the owner, Holtec International 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 10CFR Part 9.l 7(a)(4), 2.390(a)(4), and 2.390(b)(l) 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 Energy Project v. Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704F2d1280 (DC Cir. 1983).
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U.S . Nuclear Regulatory Commission ATTN: Document Control Desk Document ID ULNRC-06723-aff AFFIDAVIT PURSUANT TO 10 CFR 2.390 (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 Holtec's competitors without license from Holtec International 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 Holtec International, its customers, or its suppliers;
- d. Information which reveals aspects of past, present, or future Holtec International customer-funded development plans and programs of potential commercial value to Holtec International;
- 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 and 4. b above.
(5) The information sought to be withheld is being submitted to the NRC in confidence. The information (including that compiled from many sources) is of a sort customarily held in confidence by Holtec International, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by Holtec International. No public disclosure has been made, and it is not available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions or 2 of5
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Document ID ULNRC-06723-aff AFFIDAVIT PURSUANT TO 10 CFR 2.390 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.
Access to such documents within Holtec International 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 designee ), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation.
Disclosures outside Holtec International 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 and compiled by Holtec International at a significant cost to Holtec International. 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 Holtec International's technical database and the results of evaluations performed by Holtec International. A substantial effort has been expended by Holtec International to develop this information. Release of this information would improve a competitor's position because it would enable Holtec's competitor to copy our technology and offer it for sale in competition with our company, causing us financial injury.
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U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Document ID ULNRC-06723-aff AFFIDAVIT PURSUANT TO 10 CFR 2.390 (9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to Holtec International's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part ofHoltec International's comprehensive spent fuel storage 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, and analytical costs comprise a substantial investment of time and money by Holtec International.
The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly 1s substantial.
Holtec International's competitive advantage will be lost if its competitors are able to use the results of the Holtec International 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 Holtec International 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 Holtec International of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing these very valuable analytical tools.
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U.S. Nuclear Regulatory Commission ATfN: Document Control Desk Document ID ULNRC-06723-aff AFFIDAVIT PURSUANT TO 10 CFR 2.390 STATE OF NEW JERSEY )
) ss:
COUNTY OF CAMDEN)
Kimberly Manzione, being duly sworn, deposes and says:
That she has read the foregoing affidavit and the matters stated therein are true and correct to the best of her knowledge, information, and belief.
Executed at Camden, New Jersey, this 1st day of July 2022.
Kimberly Manzione Holtec International Subscribed and sworn before me this ~ day ofJ v,.Jg , 2022.
Erika Grandrimo NOTARY PUBLIC STATE OF NEW JERSEY MY COMMISSION EXPIRES JANUARY 17, 2027 5 of5