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| | issue date = 10/24/2018 | | | issue date = 10/24/2018 |
| | title = Extended Power Uprate - Replacement Steam Dryer Final Load Definition and Stress Reports | | | title = Extended Power Uprate - Replacement Steam Dryer Final Load Definition and Stress Reports |
| | author name = Henderson E K | | | author name = Henderson E |
| | author affiliation = Tennessee Valley Authority | | | author affiliation = Tennessee Valley Authority |
| | addressee name = | | | addressee name = |
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| {{#Wiki_filter:Proprietary Information Withhold from Public Disclosure Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosures 1 and 2 Tennessee Valley Authority | | {{#Wiki_filter:Proprietary Information Withhold from Public Disclosure Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosures 1 and 2 Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-18-124 October 24, 2018 10 CFR 50.4 10 CFR 2.390 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Browns Ferry Nuclear Plant, Unit 3 Renewed Facility Operating License No. DPR-68 NRC Docket No. 50-296 |
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| Extended Power Uprate - Unit 3 Replacement Steam Dryer Final Load Definition and Stress Reports | | ==Subject:== |
| | Extended Power Uprate - Unit 3 Replacement Steam Dryer Final Load Definition and Stress Reports |
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| GE-Hitachi Nuclear Energy Americas, LLC NEDC-33894P Revision 0 Affidavit Page 1 of 3 AFFIDAVIT I, Lisa K. Schichlein, state as follows:
| | ==Reference:== |
| (1) I am a Senior Project Manager, NPP/Serv ices Licensing, Regulatory Affairs, GE-Hitachi Nuclear Energy Americas LLC (GEH), and have been delegated the function of reviewing the information described in paragraph (2) whic h is sought to be withheld, and have been authorized to apply for its withholding.
| | NRC Letter to TVA, Browns Ferry Nuclear Plant, Units 1, 2, and 3 - |
| | Issuance of Amendments Regarding Extended Power Uprate (CAC Nos. MF6741, MF6742, and MF6743), dated August 14, 2017 (ML17032A120) |
| | In accordance with 10 CFR 50.92, the NRC issued Reference 1, License Amendment Nos. |
| | 299, 323 and 283 to the Browns Ferry Nuclear Plant (BFN) Units 1, 2 and 3 Renewed Facility Operating Licenses (RFOLs) to increase the authorized maximum power level from 3458 megawatts thermal (MWt) to 3952 MWt. This change to power level is considered an extended power uprate (EPU). |
| | The amended RFOLs contain specific license conditions that control the monitoring, evaluating, and taking prompt action in response to potential adverse flow effects as a result of the EPU on plant structures, systems, and components (including verifying the continued structural integrity of the replacement steam dryer (RSD)) during initial EPU power ascension. This letter satisfies BFN Unit 3 License Condition 2.C(14)(b)4.a by providing, within 90 days following completion of EPU power ascension testing for the BFN Unit 3, final load definition and stress reports, including the results of a complete re-analysis using BFN-specific end-to-end biases and uncertainties and transfer function. |
| | The BFN-specific bias and uncertainties summary includes both Plant Based Load Evaluation Method 1 and Method 2. BFN Unit 3 completed EPU power ascension testing on July 26, 2018. As a result, the due date for this submittal is October 24, 2018. |
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| (2) The information sought to be withheld is contained in GEH report NEDC-33894P Revision 0 , "Browns Ferry Nuclear Plant Unit 3 Replacement Steam Dryer EPU Full Re-Analysis and Benchmarking Report (PBLE01)," October 2018. This document is deemed proprietary in its entirety. The header of each page in this document carries the notation "GEH Proprietary Information - Non-Public{3}." The superscript notation {3} refers to Paragraph (3) of this affidavit, which provide s the basis for the proprietary determination. | | U.S. Nuclear Regulatory Commission CNL-18-124 Page 2 October 24, 2018 General Electric - Hitachi Nuclear Energy Americas LLC (GEH) considers portions of the information provided in Enclosures 1 and 2 of this letter to be proprietary and, therefore, exempt from public disclosure pursuant to 10 CFR 2.390. Affidavits for withholding information, executed by GEH, are provided in Enclosure 3. Therefore, on behalf of GEH, TVA requests that Enclosures 1 and 2 be withheld from public disclosure in accordance with the GEH affidavit and the provisions of 10 CFR 2.390. |
| | There are no new regulatory commitments associated with this submittal. If there are any questions or if additional information is needed, please contact Michael A. Brown at (423) 751-3275. |
| | Respectfully, E. K. Henderson Director, Nuclear Regulatory Affairs |
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| (3) In making this application for withholding of proprietary informati on of which it is the owner or licensee, GEH relies upon the exempti on 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
| | ==Enclosures:== |
| )(4), and 2.390(a)(4) fo r "trade secrets" (Exemption 4). The material for which exemption from disclosure is here sought also qualify under the narrower definition of "trade secret", within the meanings assigned to those terms for purposes of FOIA Exempti on 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975 F2.d 871 (DC Cir. 1992), and Public Citizen Health Research Group | | : 1. NEDC-33894P, Browns Ferry Nuclear Plant Unit 3 Replacement Steam Dryer EPU Full Re-analysis and Benchmarking Report (PBLE01) (proprietary) |
| : v. FDA, 704 F2.d 1280 (DC Cir. 1983).
| | : 2. NEDC-33895P, Browns Ferry Nuclear Plant Unit 3 Replacement Steam Dryer EPU Full Re-analysis and Benchmarking Report (PBLE02) (proprietary) |
| | : 3. Affidavits cc (Enclosures): |
| | NRC Regional Administrator - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant State Health Officer, Alabama State Department of Public Health |
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| (4) Some examples of categories of information which fit into the de finition of proprietary information are:
| | Enclosure 1 NEDC-33894P, Browns Ferry Nuclear Plant Unit 3 Replacement Steam Dryer EPU Full Re-analysis and Benchmarking Report (PBLE01) |
| a.Information that discloses a process, me thod, or apparatus, in cluding supporting data and analyses, where prevention of its use by GEH's competitors without license from GEH 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 aspects of past, present, or future GEH customer-funded development plans and programs, resulting in potential pr oducts to GEH; d.Information which discloses patentable subject matter for which it may be desirable to obtain patent protection. The information sought to be withheld is cons idered to be proprieta ry for the reasons set forth in paragraphs (4)a. and (4)b. above. (5) To address the 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
| | (proprietary) |
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| confidence by GEH, and is in fact so held. The information sought to be withheld has, to GE-Hitachi Nuclear Energy Americas, LLC NEDC-33894P Revision 0 Affidavit Page 2 of 3 the best of my knowledge and belief, consistently been held in confidence by GEH, 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 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
| | Enclosure 2 NEDC-33895P, Browns Ferry Nuclear Plant Unit 3 Replacement Steam Dryer EPU Full Re-analysis and Benchmarking Report (PBLE02) |
| | (proprietary) |
| | Affidavits |
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| forth in paragraphs (6) and (7) following. | | GE-Hitachi Nuclear Energy Americas, LLC AFFIDAVIT I, Lisa K. Schichlein, state as follows: |
| | (1) I am a Senior Project Manager, NPP/Services Licensing, Regulatory Affairs, GE-Hitachi Nuclear Energy Americas LLC (GEH), 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 GEH report NEDC-33894P Revision 0, Browns Ferry Nuclear Plant Unit 3 Replacement Steam Dryer EPU Full Re-Analysis and Benchmarking Report (PBLE01), October 2018. This document is deemed proprietary in its entirety. The header of each page in this document carries the notation GEH Proprietary Information - Non-Public{3}. 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, GEH 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 2.390(a)(4) for trade secrets (Exemption 4). The material for which exemption from disclosure is here sought 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, 975 F2.d 871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F2.d 1280 (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 GEHs competitors without license from GEH 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 aspects of past, present, or future GEH customer-funded development plans and programs, resulting in potential products to GEH; |
| | : d. 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) To address the 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 GEH, and is in fact so held. The information sought to be withheld has, to NEDC-33894P Revision 0 Affidavit Page 1 of 3 |
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| (6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most lik ely 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 GEH. | | GE-Hitachi Nuclear Energy Americas, LLC the best of my knowledge and belief, consistently been held in confidence by GEH, 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 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 GEH. |
| | (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. Disclosures outside GEH 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) above, is classified as proprietary because it contains detailed GEH design information of the methodology used in the design, analysis, and testing of the steam dryers for the GEH Boiling Water Reactor (BWR). Development of these methods, techniques, and information and their application for the design, modification, testing, and analyses methodologies and processes was achieved at a significant cost to GEH. |
| | The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GEH asset. |
| | (9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEHs competitive position and foreclose or reduce the availability of profit-making opportunities. The fuel design and licensing methodology is part of GEHs 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 GEH. |
| | NEDC-33894P Revision 0 Affidavit Page 2 of 3 |
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| (7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principa l scientist or other eq uivalent authority, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determinati on of the accuracy of the proprietary designation. Disclosures outside GEH 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.
| | GE-Hitachi Nuclear Energy Americas, 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. |
| | GEHs competitive advantage will be lost if its competitors are able to use the results of the GEH 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 GEH 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 GEH 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 15th day of October 2018. |
| | Lisa K. Schichlein Senior Project Manager NPP/Services Licensing Regulatory Affairs GE-Hitachi Nuclear Energy Americas, LLC 3901 Castle Hayne Road Wilmington, NC 28401 lisa.schichlein@ge.com NEDC-33894P Revision 0 Affidavit Page 3 of 3 |
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| (8) The information identified in paragraph (2) above, is classified as proprietary because it contains detailed GEH design information of the methodology used in the design, analysis, and testing of the steam dryers for the GEH Boiling Water Reactor (BWR). Development of these methods, techniques, and informat ion and their application for the design, modification, testing, and analyses met hodologies and processes was achieved at a significant cost to GEH. | | GE-Hitachi Nuclear Energy Americas, LLC AFFIDAVIT I, Lisa K. Schichlein, state as follows: |
| The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GEH asset. | | (1) I am a Senior Project Manager, NPP/Services Licensing, Regulatory Affairs, GE-Hitachi Nuclear Energy Americas LLC (GEH), 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 GEH report NEDC-33895P Revision 0, Browns Ferry Nuclear Plant Unit 3 Replacement Steam Dryer EPU Full Re-Analysis and Benchmarking Report (PBLE02), October 2018. This document is deemed proprietary in its entirety. The header of each page in this document carries the notation GEH Proprietary Information - Non-Public{3}. 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, GEH 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 2.390(a)(4) for trade secrets (Exemption 4). The material for which exemption from disclosure is here sought 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, 975 F2.d 871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F2.d 1280 (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 GEHs competitors without license from GEH 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 aspects of past, present, or future GEH customer-funded development plans and programs, resulting in potential products to GEH; |
| | : d. 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) To address the 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 GEH, and is in fact so held. The information sought to be withheld has, to NEDC-33895P Revision 0 Affidavit Page 1 of 3 |
|
| |
|
| (9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEH's competitive position and foreclose or reduce the availability of profit-making opportunities. The fuel design a nd licensing methodology is part of GEH'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 approp riate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods. | | GE-Hitachi Nuclear Energy Americas, LLC the best of my knowledge and belief, consistently been held in confidence by GEH, 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 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 GEH. |
| | (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. Disclosures outside GEH 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) above, is classified as proprietary because it contains detailed GEH design information of the methodology used in the design, analysis, and testing of the steam dryers for the GEH Boiling Water Reactor (BWR). Development of these methods, techniques, and information and their application for the design, modification, testing, and analyses methodologies and processes was achieved at a significant cost to GEH. |
| | The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GEH asset. |
| | (9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEHs competitive position and foreclose or reduce the availability of profit-making opportunities. The fuel design and licensing methodology is part of GEHs 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 GEH. |
| | NEDC-33895P Revision 0 Affidavit Page 2 of 3 |
|
| |
|
| The research, development, engineering, analytical, and NRC review costs comprise a substantial investment of time and money by GEH.
| | GE-Hitachi Nuclear Energy Americas, 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. |
| | | GEHs competitive advantage will be lost if its competitors are able to use the results of the GEH 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. |
| GE-Hitachi Nuclear Energy Americas, LLC NEDC-33894P Revision 0 Affidavit Page 3 of 3 The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quan tify, but it clearly is substantial. | | The value of this information to GEH 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 GEH 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. |
| GEH's competitive advantage will be lost if its competitors are able to use the results of the GEH experience to normalize or verify their own process or if they are able to claim an equivalent understanding by dem onstrating that they can arrive at the same or similar conclusions.
| | I declare under penalty of perjury that the foregoing is true and correct. |
| | | Executed on this 15th day of October 2018. |
| The value of this information to GEH 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 GEH of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing a nd obtaining these very valuable analytical tools. | | Lisa K. Schichlein Senior Project Manager NPP/Services Licensing Regulatory Affairs GE-Hitachi Nuclear Energy Americas, LLC 3901 Castle Hayne Road Wilmington, NC 28401 lisa.schichlein@ge.com NEDC-33895P Revision 0 Affidavit Page 3 of 3}} |
| I declare under penalty of perjury that the foregoing is true and correct. Executed on this 15 th day of October 2018. | |
| Lisa K. Schichlein | |
| | |
| Senior Project Manager | |
| | |
| NPP/Services Licensing | |
| | |
| Regulatory Affairs GE-Hitachi Nuclear Energy Americas, LLC | |
| | |
| 3901 Castle Hayne Road Wilmington, NC 28401 lisa.schichlein@ge.com GE-Hitachi Nuclear Energy Americas, LLC NEDC-33895P Revision 0 Affidavit Page 1 of 3 AFFIDAVIT I, Lisa K. Schichlein, state as follows: | |
| (1) I am a Senior Project Manager, NPP/Serv ices Licensing, Regulatory Affairs, GE-Hitachi Nuclear Energy Americas LLC (GEH), and have been delegated the function of reviewing the information described in paragraph (2) whic h is sought to be withheld, and have been authorized to apply for its withholding.
| |
| | |
| (2) The information sought to be withheld is contained in GEH report NEDC-33895P Revision 0 , "Browns Ferry Nuclear Plant Unit 3 Replacement Steam Dryer EPU Full Re-Analysis and Benchmarking Report (PBLE02)," October 2018. This document is deemed proprietary in its entirety. The header of each page in this document carries the notation "GEH Proprietary Information - Non-Public{3}." The superscript notation {3} refers to Paragraph (3) of this affidavit, which provide s the basis for the proprietary determination.
| |
| | |
| (3) In making this application for withholding of proprietary informati on of which it is the owner or licensee, GEH relies upon the exempti on 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 2.390(a)(4) fo r "trade secrets" (Exemption 4). The material for which exemption from disclosure is here sought also qualify under the narrower definition of "trade secret", within the meanings assigned to those terms for purposes of FOIA Exempti on 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975 F2.d 871 (DC Cir. 1992), and Public Citizen Health Research Group
| |
| : v. FDA, 704 F2.d 1280 (DC Cir. 1983).
| |
| | |
| (4) Some examples of categories of information which fit into the de finition of proprietary information are:
| |
| a.Information that discloses a process, me thod, or apparatus, in cluding supporting data and analyses, where prevention of its use by GEH's competitors without license from GEH 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 aspects of past, present, or future GEH customer-funded development plans and programs, resulting in potential pr oducts to GEH; d.Information which discloses patentable subject matter for which it may be desirable to obtain patent protection. The information sought to be withheld is cons idered to be proprieta ry for the reasons set forth in paragraphs (4)a. and (4)b. above. (5) To address the 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 GEH, and is in fact so held. The information sought to be withheld has, to GE-Hitachi Nuclear Energy Americas, LLC NEDC-33895P Revision 0 Affidavit Page 2 of 3 the best of my knowledge and belief, consistently been held in confidence by GEH, 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 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 lik ely 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 GEH.
| |
| | |
| (7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principa l scientist or other eq uivalent authority, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determinati on of the accuracy of the proprietary designation. Disclosures outside GEH 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) above, is classified as proprietary because it contains detailed GEH design information of the methodology used in the design, analysis, and testing of the steam dryers for the GEH Boiling Water Reactor (BWR). Development of these methods, techniques, and informat ion and their application for the design, modification, testing, and analyses met hodologies and processes was achieved at a significant cost to GEH.
| |
| The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GEH asset.
| |
| | |
| (9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEH's competitive position and foreclose or reduce the availability of profit-making opportunities. The fuel design a nd licensing methodology is part of GEH'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 approp riate 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 GEH.
| |
| | |
| GE-Hitachi Nuclear Energy Americas, LLC NEDC-33895P Revision 0 Affidavit Page 3 of 3 The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quan tify, but it clearly is substantial.
| |
| GEH's competitive advantage will be lost if its competitors are able to use the results of the GEH experience to normalize or verify their own process or if they are able to claim an equivalent understanding by dem onstrating that they can arrive at the same or similar conclusions.
| |
| | |
| The value of this information to GEH 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 GEH of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing a nd obtaining these very valuable analytical tools.
| |
| I declare under penalty of perjury that the foregoing is true and correct. Executed on this 15 th day of October 2018.
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| Lisa K. Schichlein
| |
| | |
| Senior Project Manager
| |
| | |
| NPP/Services Licensing
| |
| | |
| Regulatory Affairs GE-Hitachi Nuclear Energy Americas, LLC
| |
| | |
| 3901 Castle Hayne Road Wilmington, NC 28401 lisa.schichlein@ge.com}}
| |
Letter Sequence Other |
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Initiation
- Request, Request, Request, Request, Request, Request, Request
- Acceptance, Acceptance, Acceptance
- Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement
Administration
- Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance
- Meeting, Meeting, Meeting
Results
Other: CNL-16-008, Update on Progress of Facility Modifications for MSIV Leak Rate, CNL-18-112, Extended Power Uprate - Flow Induced Vibration Summary Report, CNL-18-124, Extended Power Uprate - Replacement Steam Dryer Final Load Definition and Stress Reports, CNL-18-134, Extended Power Uprate - Replacement Steam Dryer Revised Analysis and Limit Curves Report, ML16085A301, ML16105A441, ML16168A026, ML16176A316
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MONTHYEARML15282A2352015-09-21021 September 2015 RHR Heat Exchange K-values Utilities in EPU Containment Analyses Project stage: Request ML15282A1812015-09-21021 September 2015 Non-Proprietary - Safety Analysis Report for Browns Ferry, Units 1, 2 and 3, Extended Power Uprate, Attachment 7 Project stage: Request ML15282A1522015-09-21021 September 2015 Submits Proposed Technical Specifications Change TS-505 - Request for License Amendments - Extended Power Uprate Project stage: Request CNL-15-249, Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 1, Spent Fuel Pool Criticality Safety Analysis Information2015-12-15015 December 2015 Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 1, Spent Fuel Pool Criticality Safety Analysis Information Project stage: Supplement CNL-15-250, Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 2, MICROBURN-B2 Information, Including Enclosures 2, 4, 6, and 72015-12-15015 December 2015 Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 2, MICROBURN-B2 Information, Including Enclosures 2, 4, 6, and 7 Project stage: Supplement CNL-15-261, Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 3, Interconnection System Impact Study Information2015-12-18018 December 2015 Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 3, Interconnection System Impact Study Information Project stage: Supplement ML16032A0442016-02-0101 February 2016 FWS to NRC, Updated List of Threatened and Endangered Species that May Occur in Your Proposed Project Location for Browns Ferry EPU Project stage: Request ML16041A3072016-02-18018 February 2016 Request for Additional Information Related to License Amendment Request Regarding Extended Power Uprate Project stage: RAI ML16041A0222016-02-25025 February 2016 Request for Additional Information Related to License Amendment Request Regarding Extended Power Uprate Project stage: RAI ML16040A2322016-02-25025 February 2016 Request for Additional Information Related to License Amendment Request Regarding Extended Power Uprate Project stage: RAI ML16049A4632016-02-29029 February 2016 Request for Additional Information Related to License Amendment Request Regarding Extended Power Uprate Project stage: RAI CNL-16-045, Proposed Technical Specifications (Ts)Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 6, Response to Request for Additional Information2016-03-0909 March 2016 Proposed Technical Specifications (Ts)Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 6, Response to Request for Additional Information Project stage: Supplement ML16062A0722016-03-15015 March 2016 Request for Additional Information Related to License Amendment Request Regarding Extended Power Uprate Project stage: RAI CNL-16-048, Supplement 7, Responses to Requests for Additional Information, Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU)2016-03-24024 March 2016 Supplement 7, Responses to Requests for Additional Information, Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) Project stage: Supplement ML16084A3202016-03-25025 March 2016 Request for Additional Information Related to License Amendment Request Regarding Extended Power Uprate Project stage: RAI CNL-16-055, Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 8, Response to Request for Additional Information2016-03-28028 March 2016 Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 8, Response to Request for Additional Information Project stage: Supplement ML16089A1372016-03-29029 March 2016 NRR E-mail Capture - Correction to Request for Additional Information Related to License Amendment Request Regarding Extended Power Uprate Project stage: RAI ML16064A2862016-04-0404 April 2016 Request for Additional Information Related to License Amendment Request Regarding Extended Power Uprate Project stage: RAI ML16091A0712016-04-0707 April 2016 Request for Additional Information Related to License Amendment Request Regarding Extended Power Uprate Project stage: RAI ML16085A3012016-04-11011 April 2016 Regulatory Audit Plans for April 19 - 21, 2016, Audit at Excel Facility in Rockville, Maryland, in Support of Extended Power Uprate License Amendment Request Project stage: Other ML16085A0792016-04-14014 April 2016 Request for Additional Information Related to License Amendment Request Regarding Extended Power Uprate Project stage: RAI ML16102A3392016-04-14014 April 2016 Request for Additional Information Related to License Amendment Request Regarding Extended Power Uprate Project stage: RAI CNL-16-069, Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 11, Responses to Requests for Additional Information2016-04-14014 April 2016 Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 11, Responses to Requests for Additional Information Project stage: Supplement ML16104A2452016-04-20020 April 2016 Request for Additional Information Related to License Amendment Request Regarding Extended Power Uprate Project stage: RAI CNL-16-077, for Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Update (EPU) - Supplement 14, Response to Request for Additional Information2016-04-27027 April 2016 for Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Update (EPU) - Supplement 14, Response to Request for Additional Information Project stage: Supplement ML16105A4412016-04-27027 April 2016 Regulatory Audit Plan for May 10-11, 2016, Audit at Excel Facility in Rockville, Maryland, in Support of Extended Power Uprate License Amendment Request Project stage: Other CNL-16-079, Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 15, Responses to Requests for Additional Information2016-05-11011 May 2016 Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 15, Responses to Requests for Additional Information Project stage: Supplement ML16124A9322016-05-12012 May 2016 Request for Withholding Information from Public Disclosure Project stage: Withholding Request Acceptance ML16125A4232016-05-19019 May 2016 Request for Withholding Information from Public Disclosure Project stage: Withholding Request Acceptance CNL-16-008, Update on Progress of Facility Modifications for MSIV Leak Rate2016-05-26026 May 2016 Update on Progress of Facility Modifications for MSIV Leak Rate Project stage: Other CNL-16-091, Brown Ferry, Units 1, 2 & 3, Responses to Requests for Additional Information and Updates Associated with Interconnection System Impact Study Modifications on Proposed Technical Specifications Change TS-505 - Request for License Amendment2016-05-27027 May 2016 Brown Ferry, Units 1, 2 & 3, Responses to Requests for Additional Information and Updates Associated with Interconnection System Impact Study Modifications on Proposed Technical Specifications Change TS-505 - Request for License Amendments Project stage: Response to RAI CNL-16-094, Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 20, Responses to Requests for Additional Information2016-06-0909 June 2016 Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 20, Responses to Requests for Additional Information Project stage: Supplement ML16146A6352016-06-13013 June 2016 Request for Additional Information Related to License Amendment Request Regarding Extended Power Uprate Project stage: RAI ML16161A0642016-06-15015 June 2016 Notice of Forthcoming Closed Meeting with Tennessee Valley Authority and Its Consultant, GEH, Regarding Steam Dryers Structural Adequacy for Browns Ferry Units 1, 2 & 3 Extended Power Uprate (EPU) License Amendment Request (LAR) Project stage: Meeting CNL-16-093, Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate - Supplement 19, Responses to Requests for Additional Information2016-06-17017 June 2016 Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate - Supplement 19, Responses to Requests for Additional Information Project stage: Supplement ML16154A5442016-06-21021 June 2016 Request for Additional Information Related to License Amendment Request Regarding Extended Power Uprate Project stage: RAI ML16168A0262016-06-23023 June 2016 Summary Report for the April 19 to 21, 2016 Audit in Support of Replacement Steam Dryer Review Associated to Extended Power Uprate License Amendment Request (CAC Nos. MF6741, MF6742, and MF6743) Project stage: Other CNL-16-105, Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 22, Responses to Requests for Additional Information2016-06-24024 June 2016 Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 22, Responses to Requests for Additional Information Project stage: Supplement ML16125A4062016-07-0606 July 2016 Request for Withholding Information from Public Disclosure Project stage: Withholding Request Acceptance ML16127A6092016-07-0606 July 2016 NRC Letter Request for Withholding Information from Public Disclosure Project stage: Withholding Request Acceptance ML16125A0842016-07-0707 July 2016 Approval for Request for Withholding Information from Public Disclosure Project stage: Withholding Request Acceptance ML16130A6002016-07-0707 July 2016 Request for Withholding Information from Public Disclosure Project stage: Withholding Request Acceptance ML16173A0262016-07-0707 July 2016 Approval for Request for Withholding Information from Public Disclosure Project stage: Withholding Request Acceptance ML16176A3162016-07-11011 July 2016 Summary Report for the May 3 to May 5, 2016 Audit in Support Containment Accident Pressure Associated to Extended Power Uprate License Amendment Request Project stage: Other CNL-16-109, Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 23, Miscellaneous Updates2016-07-13013 July 2016 Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 23, Miscellaneous Updates Project stage: Supplement CNL-16-119, Brown Ferry Nuclear Plant, Unit 1, 2 and 3 - Proposed Technical Specifications Change TS-505 - Request for License Amendments - Extended Power Uprate - Supplemental Information Related to Replacement Steam Dryers2016-07-13013 July 2016 Brown Ferry Nuclear Plant, Unit 1, 2 and 3 - Proposed Technical Specifications Change TS-505 - Request for License Amendments - Extended Power Uprate - Supplemental Information Related to Replacement Steam Dryers Project stage: Supplement ML16193A4602016-07-21021 July 2016 June 23, 2016, Summary of Closed Meeting with Tennessee Valley Authority Regarding the Structural Adequacy of Steam Dryers for Extended Power Uprate License Amendment Request for Browns Ferry Nuclear Plant, Units 1, 2, and 3 (MF6741, MF6742 Project stage: Meeting ML16194A2292016-07-21021 July 2016 Request for Additional Information Related to License Amendment Request Regarding Extended Power Uprate Project stage: RAI CNL-16-116, Response to Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 252016-07-27027 July 2016 Response to Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 25 Project stage: Supplement CNL-16-118, Response to Request for Additional Information on Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 272016-07-29029 July 2016 Response to Request for Additional Information on Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 27 Project stage: Supplement 2016-04-07
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Category:Legal-Affidavit
MONTHYEARML24019A1122023-12-14014 December 2023 Affidavit by Alan B. Meginnis for Presentation Slide Deck Entitled, Modification of Browns Ferry TS to Eliminate LCO 3.3.2.1 Actions C.2.1.1 and C.2.1.2 for Rod Worth Minimizer Inoperable During Reactor Startup, Dated December 2023 ML24019A1722023-12-14014 December 2023 Affidavit by Alan B. Meginnis for ANP-3874P, Revision 2, Browns Ferry Atrium 11 Control Rod Drop Accident Analysis with the AURORA-B CRDA Methodology, Dated March 2021 CNL-22-100, to Request for License Amendment Regarding Application of Advanced Framatome Methodologies, and Adoption of TSTF-564 Revision 2 for Browns Ferry Nuclear Plant Units 1, 2, and 3,in Support of Atrium 11 Fuel Use at Browns Ferry (TS-535)2022-12-0909 December 2022 to Request for License Amendment Regarding Application of Advanced Framatome Methodologies, and Adoption of TSTF-564 Revision 2 for Browns Ferry Nuclear Plant Units 1, 2, and 3,in Support of Atrium 11 Fuel Use at Browns Ferry (TS-535) CNL-22-096, to Request for License Amendment Regarding Application of Advanced Framatome Methodologies, and Adoption of TSTF-564 Revision 2 for Browns Ferry Nuclear Plant Units 1, 2, and 3, in Support of Atrium 11 Fuel Use at Browns Ferry (TS-535)2022-09-29029 September 2022 to Request for License Amendment Regarding Application of Advanced Framatome Methodologies, and Adoption of TSTF-564 Revision 2 for Browns Ferry Nuclear Plant Units 1, 2, and 3, in Support of Atrium 11 Fuel Use at Browns Ferry (TS-535) CNL-22-056, Supplement to License Amendment Request Regarding Criticality Safety Analysis of Spent Fuel Pool Storage of Atrium 11 Fuel (TS-534)2022-04-28028 April 2022 Supplement to License Amendment Request Regarding Criticality Safety Analysis of Spent Fuel Pool Storage of Atrium 11 Fuel (TS-534) CNL-21-061, Information Transmittal for NRC Confirmatory Calculations Regarding Transition to Atrium 11 Fuel2021-08-0606 August 2021 Information Transmittal for NRC Confirmatory Calculations Regarding Transition to Atrium 11 Fuel CNL-21-053, Request for License Amendment Regarding Application of Advanced Framatome Methodologies, and Adoption of TSTF-564 Revision 2, in Support of Atrium 11 Fuel Use (TS-535)2021-07-23023 July 2021 Request for License Amendment Regarding Application of Advanced Framatome Methodologies, and Adoption of TSTF-564 Revision 2, in Support of Atrium 11 Fuel Use (TS-535) CNL-19-125, Proposed Technical Specifications (TS) Change 510 - Request for License Amendments - Maximum Extended Load Line Limit Analysis Plus - Supplement 12, Additional License Condition2019-12-19019 December 2019 Proposed Technical Specifications (TS) Change 510 - Request for License Amendments - Maximum Extended Load Line Limit Analysis Plus - Supplement 12, Additional License Condition CNL-19-117, Extended Power Uprate - Units 1 and 2 Replacement Steam Dryer Final Load Definition and Stress Reports - Supplemental Information2019-12-12012 December 2019 Extended Power Uprate - Units 1 and 2 Replacement Steam Dryer Final Load Definition and Stress Reports - Supplemental Information CNL-19-076, Extended Power Uprate: Unit 1 Replacement Steam Dryer Final Load Definition and Stress Report, Revision 12019-10-10010 October 2019 Extended Power Uprate: Unit 1 Replacement Steam Dryer Final Load Definition and Stress Report, Revision 1 CNL-19-075, Extended Power Uprate - Unit 2 Replacement Steam Dryer Final Load Definition and Stress Report2019-09-19019 September 2019 Extended Power Uprate - Unit 2 Replacement Steam Dryer Final Load Definition and Stress Report CNL-19-042, Extended Power Uprate - Replacement Steam Dryer Final Load Definition and Stress Report2019-04-29029 April 2019 Extended Power Uprate - Replacement Steam Dryer Final Load Definition and Stress Report CNL-19-045, Proposed Technical Specifications (TS) Change TS-510 - Request for License Amendments - Maximum Extended Load Line Limit Analysis Plus - Supplement 9, Additional Information Regarding Anticipate Transient Without Scram with ...2019-04-24024 April 2019 Proposed Technical Specifications (TS) Change TS-510 - Request for License Amendments - Maximum Extended Load Line Limit Analysis Plus - Supplement 9, Additional Information Regarding Anticipate Transient Without Scram with ... CNL-19-028, Replacement Steam Dryer Revised Analysis and Limit Curves Report, Supplement 12019-02-14014 February 2019 Replacement Steam Dryer Revised Analysis and Limit Curves Report, Supplement 1 CNL-19-017, Proposed Technical Specifications (TS) Change TS-510 - Request for License Amendments - Maximum Extended Load Line Limit Analysis Plus - Supplement 7, Response to Requests for Additional Information2019-01-25025 January 2019 Proposed Technical Specifications (TS) Change TS-510 - Request for License Amendments - Maximum Extended Load Line Limit Analysis Plus - Supplement 7, Response to Requests for Additional Information CNL-19-006, Extended Power Uprate - Replacement Steam Dryer Final Load Definition and Stress Reports - Supplemental Information2019-01-0202 January 2019 Extended Power Uprate - Replacement Steam Dryer Final Load Definition and Stress Reports - Supplemental Information CNL-18-141, Extended Power Uprate - Replacement Steam Dryer Revised Analysis and Limit Curves Report - Supplemental Information2018-12-14014 December 2018 Extended Power Uprate - Replacement Steam Dryer Revised Analysis and Limit Curves Report - Supplemental Information CNL-18-140, Response to Request for Additional Information Proposed Technical Specifications (TS) Change TS-510 - Request for License Amendments - Maximum Extended Load Line Limit Analysis Plus - Supplement 42018-12-13013 December 2018 Response to Request for Additional Information Proposed Technical Specifications (TS) Change TS-510 - Request for License Amendments - Maximum Extended Load Line Limit Analysis Plus - Supplement 4 CNL-18-131, Extended Power - Uprate Replacement Steam Dryer Core Flow Sweep Report - Supplemental Information2018-11-15015 November 2018 Extended Power - Uprate Replacement Steam Dryer Core Flow Sweep Report - Supplemental Information CNL-18-124, Extended Power Uprate - Replacement Steam Dryer Final Load Definition and Stress Reports2018-10-24024 October 2018 Extended Power Uprate - Replacement Steam Dryer Final Load Definition and Stress Reports CNL-18-125, Extended Power Uprate - Replacement Steam Dryer Revised Analysis and Limit Curves Report2018-10-24024 October 2018 Extended Power Uprate - Replacement Steam Dryer Revised Analysis and Limit Curves Report CNL-18-103, Topical Report TVA-NPG-AWA16, TVA Overall Basin Probable Maximum Precipitation and Local Intense Precipitation Analysis, Calculation CDQ0000002016000041,.2018-09-0606 September 2018 Topical Report TVA-NPG-AWA16, TVA Overall Basin Probable Maximum Precipitation and Local Intense Precipitation Analysis, Calculation CDQ0000002016000041,. CNL-18-106, Extended Power Uprate Replacement Steam Dryer Core Flow Sweep Test Report2018-08-13013 August 2018 Extended Power Uprate Replacement Steam Dryer Core Flow Sweep Test Report CNL-18-081, Request for Review and Approval of Topical Report TVA-NPG-AWA16, TVA Overall Basin Probable Maximum Precipitation and Local Intense Precipitation Analysis, Calculation CDQ0000002016000041, Revision 12018-06-22022 June 2018 Request for Review and Approval of Topical Report TVA-NPG-AWA16, TVA Overall Basin Probable Maximum Precipitation and Local Intense Precipitation Analysis, Calculation CDQ0000002016000041, Revision 1 CNL-18-042, Proposed Technical Specifications Change TS-510 - Request for License Amendments - Maximum Extended Load Line Limit Analysis Plus, Supplement 12018-03-0707 March 2018 Proposed Technical Specifications Change TS-510 - Request for License Amendments - Maximum Extended Load Line Limit Analysis Plus, Supplement 1 CNL-16-145, Revised Responses to Requests for Additional Information Regarding Proposed Technical Specifications Change TS-505 - Extended Power Uprate - Supplement 302016-09-23023 September 2016 Revised Responses to Requests for Additional Information Regarding Proposed Technical Specifications Change TS-505 - Extended Power Uprate - Supplement 30 CNL-16-056, Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 9, Responses to Requests for Additional Information2016-04-0404 April 2016 Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 9, Responses to Requests for Additional Information CNL-15-247, Brown Ferry Unit 1, Submittal of Response to NRC Request for Additional Information Re Application to Modify Technical Specification 2.1.1.2, Reactor Core Minimum Critical Power Ratio Safety Limits (TS-506). Enclosure 2 ANP-3458NP Enclose2015-12-28028 December 2015 Brown Ferry Unit 1, Submittal of Response to NRC Request for Additional Information Re Application to Modify Technical Specification 2.1.1.2, Reactor Core Minimum Critical Power Ratio Safety Limits (TS-506). Enclosure 2 ANP-3458NP Enclosed CNL-15-250, Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 2, MICROBURN-B2 Information, Including Enclosures 2, 4, 6, and 72015-12-15015 December 2015 Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 2, MICROBURN-B2 Information, Including Enclosures 2, 4, 6, and 7 CNL-15-249, Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 1, Spent Fuel Pool Criticality Safety Analysis Information2015-12-15015 December 2015 Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 1, Spent Fuel Pool Criticality Safety Analysis Information ML15282A2582015-09-17017 September 2015 General Electric Hitachi Affidavits NL-15-169, Browns Ferry, Units 1, 2, and 3, General Electric Hitachi Affidavits2015-09-17017 September 2015 Browns Ferry, Units 1, 2, and 3, General Electric Hitachi Affidavits CNL-15-169, Electric Power Research Institute Affidavit2015-09-14014 September 2015 Electric Power Research Institute Affidavit ML15282A2592015-08-12012 August 2015 Areva Affidavits NL-15-169, Browns Ferry, Units 1, 2, and 3, Areva Affidavits2015-08-12012 August 2015 Browns Ferry, Units 1, 2, and 3, Areva Affidavits CNL-15-103, Enclosure 2, ANP-3414NP Revision 0, Areva RAI Responses for Browns Ferry, Unit 3, Cycle 18 MCPR Safety Limits (Non-proprietary), and Enclosure 3, Affidavit2015-07-0707 July 2015 Enclosure 2, ANP-3414NP Revision 0, Areva RAI Responses for Browns Ferry, Unit 3, Cycle 18 MCPR Safety Limits (Non-proprietary), and Enclosure 3, Affidavit CNL-15-085, Response to NRC Request for Additional Information Regarding Proposed Technical Specification Change to Modify Technical Proposed Technical Specification Change to Modify Technical2015-06-0303 June 2015 Response to NRC Request for Additional Information Regarding Proposed Technical Specification Change to Modify Technical Proposed Technical Specification Change to Modify Technical ML14204A7092014-07-23023 July 2014 Enclosure 3, Affidavit of Peter M. Yandow ML13276A0632013-09-30030 September 2013 Response to Request for Additional Information on Technical Specification Change TS-478 ML1127000682011-09-26026 September 2011 Enclosure 3, Mfn 10-245 R4, Affidavit ML1121500962011-06-0808 June 2011 Appeal of Final Significance Determination of a Red Finding and Reply to a Notice of Violation; EA-11-018 ML1011602992010-04-16016 April 2010 Affidavit of Alan B. Meginnis Regarding Supplemental Information for Technical Specification Change TS-473 - Areva Fuel Transition Amendment Request ML0902203942009-01-0808 January 2009 Response to Round 23 RAI Technical Specifications Changes TS-431 and TS-418, Extended Power Uprate, Enclosure 2 - Structural Integrity Associates, Inc. Calculation Package 0006982.304, Revision 1 and Encls 4 and 5 ML0807104982008-03-0606 March 2008 (BFN) - Units 1, 2, and 3 - Technical Specifications (TS) Change TS-418 and TS-431 - Extended Power Uprate (EPU) - Response to Round 16 Request for Additional Information (RAI) - SRXB-74/86 and SRXB-87 Through SRXB-90 ML0721303712007-07-27027 July 2007 Technical Specifications Changes TS-431 and TS-418, Extended Power Uprate - Steam Dryer Evaluations ML0621700042006-08-21021 August 2006 Proprietary Letter, Request for Withholding Information on EPU Round 3 (TS-431) ML0619506702006-07-0606 July 2006 Technical Specifications (TS) Change TS-431 - Extended Power Uprate (EPU) - Response to NRC Round 6 Request for Additional Information on GE Methods ML0613004362006-05-0505 May 2006 Transmittal of Browns Ferry, Units 1, 2 & 3 - Technical Specifications Changes TS-431 and TS-418 - Extended Power Uprate - Steam Dryer Stress Report ML0520003282005-07-14014 July 2005 Surveillance Program for Channel-Control Blade Interference ML0517201312005-07-0101 July 2005 Enclosure, Framatone Non-Propreitary Presentation 2023-12-14
[Table view] Category:Letter type:CNL
MONTHYEARCNL-24-017, Tennessee Valley Authority - Central Emergency Control Center Emergency Plan Implementing Procedure and Emergency Preparedness Department Procedure Revisions2024-01-17017 January 2024 Tennessee Valley Authority - Central Emergency Control Center Emergency Plan Implementing Procedure and Emergency Preparedness Department Procedure Revisions CNL-23-071, Response to Request for Additional Information Regarding Browns Ferry Nuclear Plant, Units 1, 2, and 3, Inservice Inspection and Augmented Program Interval Revised Request for Alternative 0-ISI-472024-01-11011 January 2024 Response to Request for Additional Information Regarding Browns Ferry Nuclear Plant, Units 1, 2, and 3, Inservice Inspection and Augmented Program Interval Revised Request for Alternative 0-ISI-47 CNL-23-070, Submittal of Fifth 10-Year Interval Inservice Testing Program Plan2023-11-29029 November 2023 Submittal of Fifth 10-Year Interval Inservice Testing Program Plan CNL-23-067, Central Emergency Control Center Emergency Plan Implementing Procedure Revisions2023-11-27027 November 2023 Central Emergency Control Center Emergency Plan Implementing Procedure Revisions CNL-23-061, Tennessee Valley Authority - Central Emergency Control Center Emergency Plan Implementing Procedure Revision2023-09-20020 September 2023 Tennessee Valley Authority - Central Emergency Control Center Emergency Plan Implementing Procedure Revision CNL-23-057, Central Emergency Control Center Emergency Plan Implementing Procedure Revisions. Includes CECC-EPIP-1, Revision 76 and CECC-EPIP-9, Revision 642023-09-0505 September 2023 Central Emergency Control Center Emergency Plan Implementing Procedure Revisions. Includes CECC-EPIP-1, Revision 76 and CECC-EPIP-9, Revision 64 CNL-23-055, Tennessee Valley Authority - Emergency Preparedness Department Procedure Revision. Includes EPDP-3, Revision 3, Emergency Plan Exercises and Preparedness Drills2023-07-25025 July 2023 Tennessee Valley Authority - Emergency Preparedness Department Procedure Revision. Includes EPDP-3, Revision 3, Emergency Plan Exercises and Preparedness Drills CNL-23-053, Tennessee Valley Authority - Radiological Emergency Plan Revisions2023-07-18018 July 2023 Tennessee Valley Authority - Radiological Emergency Plan Revisions CNL-23-025, American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section XI, Inservice Inspection and Augmented Program Interval Revised Request for Alternative 0-ISI-472023-07-0303 July 2023 American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section XI, Inservice Inspection and Augmented Program Interval Revised Request for Alternative 0-ISI-47 CNL-23-049, Tennessee Valley Authority - Radiological Emergency Plan and Central Emergency Control Center Emergency Plan .2023-06-26026 June 2023 Tennessee Valley Authority - Radiological Emergency Plan and Central Emergency Control Center Emergency Plan . CNL-23-046, Revision to Notice of Intent to Pursue Subsequent License Renewal - Schedule Submittal2023-06-0606 June 2023 Revision to Notice of Intent to Pursue Subsequent License Renewal - Schedule Submittal CNL-23-037, Response to Request for Additional Information Regarding Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Request to Use a Later Edition of the American Society of Mechanical Engineers Operation and Maintenance Code and Alternative Request2023-06-0101 June 2023 Response to Request for Additional Information Regarding Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Request to Use a Later Edition of the American Society of Mechanical Engineers Operation and Maintenance Code and Alternative Requests CNL-23-042, Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revisions2023-05-16016 May 2023 Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revisions CNL-23-030, Tennessee Valley Authority - Hydrologic Engineering Center River Analysis System Project Milestone Status Update2023-04-27027 April 2023 Tennessee Valley Authority - Hydrologic Engineering Center River Analysis System Project Milestone Status Update CNL-23-032, Clinch River, Sequoyah, Units 1 and 2, Watts Bar, Unit 1 and 2, Nuclear Quality Assurance Plan, TVA-NQA-PLN89-A, Revision 412023-04-27027 April 2023 Clinch River, Sequoyah, Units 1 and 2, Watts Bar, Unit 1 and 2, Nuclear Quality Assurance Plan, TVA-NQA-PLN89-A, Revision 41 CNL-23-034, 10 CFR 50.46 Annual Report2023-04-26026 April 2023 10 CFR 50.46 Annual Report CNL-23-033, Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revision2023-04-24024 April 2023 Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revision CNL-23-029, Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revisions2023-04-11011 April 2023 Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revisions CNL-23-018, Request for Amendment Regarding Technical Specification Surveillance Requirements 3.4.3.2 and 3.5.1.11 Regarding Safety Relief Valves (BFN TS-540)2023-03-30030 March 2023 Request for Amendment Regarding Technical Specification Surveillance Requirements 3.4.3.2 and 3.5.1.11 Regarding Safety Relief Valves (BFN TS-540) CNL-23-023, Annual Insurance Status Report2023-03-30030 March 2023 Annual Insurance Status Report CNL-23-027, Second Supplement to License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505-A, Revision 2, Provide Risk-Informed Extended Completion Times RITSTF Initiative 4b (BFN TS-524)2023-03-29029 March 2023 Second Supplement to License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505-A, Revision 2, Provide Risk-Informed Extended Completion Times RITSTF Initiative 4b (BFN TS-524) CNL-23-022, Decommissioning Funding Status Report2023-03-29029 March 2023 Decommissioning Funding Status Report CNL-23-024, TVA Guarantee of Payment of Deferred Premiums - 2022 Annual Report2023-03-29029 March 2023 TVA Guarantee of Payment of Deferred Premiums - 2022 Annual Report CNL-23-019, Response to Request for Additional Information Regarding Browns Ferry Nuclear Plant, Units 1, 2, and 3, American Society of Mechanical Engineers Boiler and Pressure Vessel Code Section XI, Request for Alternative BFN-0-ISI-322023-03-11011 March 2023 Response to Request for Additional Information Regarding Browns Ferry Nuclear Plant, Units 1, 2, and 3, American Society of Mechanical Engineers Boiler and Pressure Vessel Code Section XI, Request for Alternative BFN-0-ISI-32 CNL-22-045, Application to Revise Technical Specifications to Adopt TSTF-566-A, Revise Actions for Inoperable RHR Shutdown Cooling Subsystems, and TSTF-580-A, Revision 1, Provide Exception from Entering Mode 42023-03-10010 March 2023 Application to Revise Technical Specifications to Adopt TSTF-566-A, Revise Actions for Inoperable RHR Shutdown Cooling Subsystems, and TSTF-580-A, Revision 1, Provide Exception from Entering Mode 4 CNL-23-021, Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revisions2023-03-0808 March 2023 Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revisions CNL-22-037, Application to Revise Technical Specifications to Adopt TSTF-541-A, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position (BFN TS-533)2023-01-31031 January 2023 Application to Revise Technical Specifications to Adopt TSTF-541-A, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position (BFN TS-533) CNL-23-003, Browns Nuclear Plant, Units 1, 2 & 3; Sequoyah Nuclear Plant, Units 1 & 2; and Watts Bar Nuclear Plant, Units 1 & 2 - Organizational Topic Report TVA-NPOD89-A2023-01-30030 January 2023 Browns Nuclear Plant, Units 1, 2 & 3; Sequoyah Nuclear Plant, Units 1 & 2; and Watts Bar Nuclear Plant, Units 1 & 2 - Organizational Topic Report TVA-NPOD89-A CNL-23-008, Tennessee Valley Authority Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revisions2022-12-22022 December 2022 Tennessee Valley Authority Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revisions CNL-22-089, License Amendment Request for Adoption of TSTF-478, Revision 2, BWR Technical Specification Changes That Implement the Revised Rule for Combustible Gas Control (BFN TS-546)2022-12-20020 December 2022 License Amendment Request for Adoption of TSTF-478, Revision 2, BWR Technical Specification Changes That Implement the Revised Rule for Combustible Gas Control (BFN TS-546) CNL-22-090, Request to Use a Later Edition of the American Society of Mechanical Engineers Operation and Maintenance Code and Alternative Requests for the Fifth Inservice Testing Interval2022-12-12012 December 2022 Request to Use a Later Edition of the American Society of Mechanical Engineers Operation and Maintenance Code and Alternative Requests for the Fifth Inservice Testing Interval CNL-22-100, to Request for License Amendment Regarding Application of Advanced Framatome Methodologies, and Adoption of TSTF-564 Revision 2 for Browns Ferry Nuclear Plant Units 1, 2, and 3,in Support of Atrium 11 Fuel Use at Browns Ferry (TS-535)2022-12-0909 December 2022 to Request for License Amendment Regarding Application of Advanced Framatome Methodologies, and Adoption of TSTF-564 Revision 2 for Browns Ferry Nuclear Plant Units 1, 2, and 3,in Support of Atrium 11 Fuel Use at Browns Ferry (TS-535) CNL-22-097, Response to Request for Additional Information and Supplement to License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide .2022-12-0101 December 2022 Response to Request for Additional Information and Supplement to License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide . CNL-22-106, Tennessee Valley Authority - Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revision. Includes CECC EPIP-14, Revision 38, Nuclear Emergency Public Information Organization and Operat2022-11-28028 November 2022 Tennessee Valley Authority - Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revision. Includes CECC EPIP-14, Revision 38, Nuclear Emergency Public Information Organization and Operatio CNL-22-105, Physical Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program, Revision 222022-11-0808 November 2022 Physical Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program, Revision 22 CNL-22-099, Tennessee Valley Authority - Hydrologic Engineering Center River Analysis System Project Milestone Status Update2022-10-31031 October 2022 Tennessee Valley Authority - Hydrologic Engineering Center River Analysis System Project Milestone Status Update CNL-22-098, Tennessee Valley Authority - Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revisions. Includes CECC EPIP-7, Rev. 45 & CECC EPIP-8, Rev. 552022-10-17017 October 2022 Tennessee Valley Authority - Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revisions. Includes CECC EPIP-7, Rev. 45 & CECC EPIP-8, Rev. 55 CNL-22-055, Application to Delete Acreage Value Discussion from Technical Specifications (BFN TS-543)2022-09-29029 September 2022 Application to Delete Acreage Value Discussion from Technical Specifications (BFN TS-543) CNL-22-096, to Request for License Amendment Regarding Application of Advanced Framatome Methodologies, and Adoption of TSTF-564 Revision 2 for Browns Ferry Nuclear Plant Units 1, 2, and 3, in Support of Atrium 11 Fuel Use at Browns Ferry (TS-535)2022-09-29029 September 2022 to Request for License Amendment Regarding Application of Advanced Framatome Methodologies, and Adoption of TSTF-564 Revision 2 for Browns Ferry Nuclear Plant Units 1, 2, and 3, in Support of Atrium 11 Fuel Use at Browns Ferry (TS-535) CNL-22-083, to Request for License Amendment Regarding Application of Advanced Framatome Methodologies, and Adoption of TSTF-564 Revision 2 for Browns Ferry Nuclear Plant Units 1, 2, and 3, in Support of Atrium 11 Fuel Use at Browns Ferry (TS-535).2022-09-13013 September 2022 to Request for License Amendment Regarding Application of Advanced Framatome Methodologies, and Adoption of TSTF-564 Revision 2 for Browns Ferry Nuclear Plant Units 1, 2, and 3, in Support of Atrium 11 Fuel Use at Browns Ferry (TS-535). CNL-22-075, Response to Request for Additional Information Regarding Browns Ferry Nuclear Plant, Unit 2, Request for Alternative, BFN-21-ISI-02, Alternative to American Society of Mechanical Engineers, Boiler and Pressure Vessel Code, Section Xi,.2022-09-12012 September 2022 Response to Request for Additional Information Regarding Browns Ferry Nuclear Plant, Unit 2, Request for Alternative, BFN-21-ISI-02, Alternative to American Society of Mechanical Engineers, Boiler and Pressure Vessel Code, Section Xi,. CNL-22-025, American Society of Mechanical Engineers Boiler and Pressure Vessel Code Section XI, Request for Alternative BFN-0-ISI-322022-08-22022 August 2022 American Society of Mechanical Engineers Boiler and Pressure Vessel Code Section XI, Request for Alternative BFN-0-ISI-32 CNL-22-077, Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revisions2022-08-11011 August 2022 Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revisions CNL-22-065, Response to Request for Confirmation of Information and Additional Information and Second Supplement Regarding Application Requesting NRC Prior Approval of a Proposed Chilled-Water Cross-tie.2022-08-0101 August 2022 Response to Request for Confirmation of Information and Additional Information and Second Supplement Regarding Application Requesting NRC Prior Approval of a Proposed Chilled-Water Cross-tie. CNL-22-076, to Request for License Amendment Regarding Application of Advanced Framatome Methodologies, and Adoption of TSTF-564 Revision 2 in Support of Atrium 11 Fuel2022-07-28028 July 2022 to Request for License Amendment Regarding Application of Advanced Framatome Methodologies, and Adoption of TSTF-564 Revision 2 in Support of Atrium 11 Fuel CNL-22-066, Request for License Amendment Regarding Application of Advanced Framatome Methodologies, and Adoption of TSTF-564 Revision 2 for in Support of Atrium 11 Fuel Use Supplement 3, Response to Request for Additional Information2022-07-18018 July 2022 Request for License Amendment Regarding Application of Advanced Framatome Methodologies, and Adoption of TSTF-564 Revision 2 for in Support of Atrium 11 Fuel Use Supplement 3, Response to Request for Additional Information CNL-22-039, Application to Revise Technical Specifications to Adopt TSTF-554-A, Revision 1, Revise Reactor Coolant Leakage Requirements (BFN TS-537) (SQN-21-05) (WBN-TS-21-04)2022-07-13013 July 2022 Application to Revise Technical Specifications to Adopt TSTF-554-A, Revision 1, Revise Reactor Coolant Leakage Requirements (BFN TS-537) (SQN-21-05) (WBN-TS-21-04) CNL-22-008, and Watts Bar Nuclear Plant - Application to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules (BFN-TS-541, SQN-TS-21-09, and WBN-TS-22-002)2022-06-13013 June 2022 and Watts Bar Nuclear Plant - Application to Revise Technical Specifications to Adopt TSTF-529, Clarify Use and Application Rules (BFN-TS-541, SQN-TS-21-09, and WBN-TS-22-002) CNL-22-064, Response to Request for Additional Information Regarding Tennessee Valley Authority License Amendment Request to Revise Emergency Plan Implementing Procedure Regarding Seismic Event Emergency Action Level Change2022-06-0909 June 2022 Response to Request for Additional Information Regarding Tennessee Valley Authority License Amendment Request to Revise Emergency Plan Implementing Procedure Regarding Seismic Event Emergency Action Level Change CNL-22-068, Tennessee Valley Authority - Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revisions2022-06-0808 June 2022 Tennessee Valley Authority - Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revisions 2024-01-17
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Proprietary Information Withhold from Public Disclosure Under 10 CFR 2.390 This letter is decontrolled when separated from Enclosures 1 and 2 Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-18-124 October 24, 2018 10 CFR 50.4 10 CFR 2.390 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Browns Ferry Nuclear Plant, Unit 3 Renewed Facility Operating License No. DPR-68 NRC Docket No. 50-296
Subject:
Extended Power Uprate - Unit 3 Replacement Steam Dryer Final Load Definition and Stress Reports
Reference:
NRC Letter to TVA, Browns Ferry Nuclear Plant, Units 1, 2, and 3 -
Issuance of Amendments Regarding Extended Power Uprate (CAC Nos. MF6741, MF6742, and MF6743), dated August 14, 2017 (ML17032A120)
In accordance with 10 CFR 50.92, the NRC issued Reference 1, License Amendment Nos.
299, 323 and 283 to the Browns Ferry Nuclear Plant (BFN) Units 1, 2 and 3 Renewed Facility Operating Licenses (RFOLs) to increase the authorized maximum power level from 3458 megawatts thermal (MWt) to 3952 MWt. This change to power level is considered an extended power uprate (EPU).
The amended RFOLs contain specific license conditions that control the monitoring, evaluating, and taking prompt action in response to potential adverse flow effects as a result of the EPU on plant structures, systems, and components (including verifying the continued structural integrity of the replacement steam dryer (RSD)) during initial EPU power ascension. This letter satisfies BFN Unit 3 License Condition 2.C(14)(b)4.a by providing, within 90 days following completion of EPU power ascension testing for the BFN Unit 3, final load definition and stress reports, including the results of a complete re-analysis using BFN-specific end-to-end biases and uncertainties and transfer function.
The BFN-specific bias and uncertainties summary includes both Plant Based Load Evaluation Method 1 and Method 2. BFN Unit 3 completed EPU power ascension testing on July 26, 2018. As a result, the due date for this submittal is October 24, 2018.
U.S. Nuclear Regulatory Commission CNL-18-124 Page 2 October 24, 2018 General Electric - Hitachi Nuclear Energy Americas LLC (GEH) considers portions of the information provided in Enclosures 1 and 2 of this letter to be proprietary and, therefore, exempt from public disclosure pursuant to 10 CFR 2.390. Affidavits for withholding information, executed by GEH, are provided in Enclosure 3. Therefore, on behalf of GEH, TVA requests that Enclosures 1 and 2 be withheld from public disclosure in accordance with the GEH affidavit and the provisions of 10 CFR 2.390.
There are no new regulatory commitments associated with this submittal. If there are any questions or if additional information is needed, please contact Michael A. Brown at (423) 751-3275.
Respectfully, E. K. Henderson Director, Nuclear Regulatory Affairs
Enclosures:
- 1. NEDC-33894P, Browns Ferry Nuclear Plant Unit 3 Replacement Steam Dryer EPU Full Re-analysis and Benchmarking Report (PBLE01) (proprietary)
- 2. NEDC-33895P, Browns Ferry Nuclear Plant Unit 3 Replacement Steam Dryer EPU Full Re-analysis and Benchmarking Report (PBLE02) (proprietary)
- 3. Affidavits cc (Enclosures):
NRC Regional Administrator - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant State Health Officer, Alabama State Department of Public Health
Enclosure 1 NEDC-33894P, Browns Ferry Nuclear Plant Unit 3 Replacement Steam Dryer EPU Full Re-analysis and Benchmarking Report (PBLE01)
(proprietary)
Enclosure 2 NEDC-33895P, Browns Ferry Nuclear Plant Unit 3 Replacement Steam Dryer EPU Full Re-analysis and Benchmarking Report (PBLE02)
(proprietary)
Affidavits
GE-Hitachi Nuclear Energy Americas, LLC AFFIDAVIT I, Lisa K. Schichlein, state as follows:
(1) I am a Senior Project Manager, NPP/Services Licensing, Regulatory Affairs, GE-Hitachi Nuclear Energy Americas LLC (GEH), 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 GEH report NEDC-33894P Revision 0, Browns Ferry Nuclear Plant Unit 3 Replacement Steam Dryer EPU Full Re-Analysis and Benchmarking Report (PBLE01), October 2018. This document is deemed proprietary in its entirety. The header of each page in this document carries the notation GEH Proprietary Information - Non-Public{3}. 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, GEH 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 2.390(a)(4) for trade secrets (Exemption 4). The material for which exemption from disclosure is here sought 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, 975 F2.d 871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F2.d 1280 (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 GEHs competitors without license from GEH 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 aspects of past, present, or future GEH customer-funded development plans and programs, resulting in potential products to GEH;
- d. 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) To address the 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 GEH, and is in fact so held. The information sought to be withheld has, to NEDC-33894P Revision 0 Affidavit Page 1 of 3
GE-Hitachi Nuclear Energy Americas, LLC the best of my knowledge and belief, consistently been held in confidence by GEH, 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 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 GEH.
(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. Disclosures outside GEH 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) above, is classified as proprietary because it contains detailed GEH design information of the methodology used in the design, analysis, and testing of the steam dryers for the GEH Boiling Water Reactor (BWR). Development of these methods, techniques, and information and their application for the design, modification, testing, and analyses methodologies and processes was achieved at a significant cost to GEH.
The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GEH asset.
(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEHs competitive position and foreclose or reduce the availability of profit-making opportunities. The fuel design and licensing methodology is part of GEHs 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 GEH.
NEDC-33894P Revision 0 Affidavit Page 2 of 3
GE-Hitachi Nuclear Energy Americas, 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.
GEHs competitive advantage will be lost if its competitors are able to use the results of the GEH 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 GEH 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 GEH 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 15th day of October 2018.
Lisa K. Schichlein Senior Project Manager NPP/Services Licensing Regulatory Affairs GE-Hitachi Nuclear Energy Americas, LLC 3901 Castle Hayne Road Wilmington, NC 28401 lisa.schichlein@ge.com NEDC-33894P Revision 0 Affidavit Page 3 of 3
GE-Hitachi Nuclear Energy Americas, LLC AFFIDAVIT I, Lisa K. Schichlein, state as follows:
(1) I am a Senior Project Manager, NPP/Services Licensing, Regulatory Affairs, GE-Hitachi Nuclear Energy Americas LLC (GEH), 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 GEH report NEDC-33895P Revision 0, Browns Ferry Nuclear Plant Unit 3 Replacement Steam Dryer EPU Full Re-Analysis and Benchmarking Report (PBLE02), October 2018. This document is deemed proprietary in its entirety. The header of each page in this document carries the notation GEH Proprietary Information - Non-Public{3}. 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, GEH 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 2.390(a)(4) for trade secrets (Exemption 4). The material for which exemption from disclosure is here sought 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, 975 F2.d 871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F2.d 1280 (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 GEHs competitors without license from GEH 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 aspects of past, present, or future GEH customer-funded development plans and programs, resulting in potential products to GEH;
- d. 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) To address the 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 GEH, and is in fact so held. The information sought to be withheld has, to NEDC-33895P Revision 0 Affidavit Page 1 of 3
GE-Hitachi Nuclear Energy Americas, LLC the best of my knowledge and belief, consistently been held in confidence by GEH, 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 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 GEH.
(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. Disclosures outside GEH 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) above, is classified as proprietary because it contains detailed GEH design information of the methodology used in the design, analysis, and testing of the steam dryers for the GEH Boiling Water Reactor (BWR). Development of these methods, techniques, and information and their application for the design, modification, testing, and analyses methodologies and processes was achieved at a significant cost to GEH.
The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GEH asset.
(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEHs competitive position and foreclose or reduce the availability of profit-making opportunities. The fuel design and licensing methodology is part of GEHs 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 GEH.
NEDC-33895P Revision 0 Affidavit Page 2 of 3
GE-Hitachi Nuclear Energy Americas, 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.
GEHs competitive advantage will be lost if its competitors are able to use the results of the GEH 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 GEH 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 GEH 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 15th day of October 2018.
Lisa K. Schichlein Senior Project Manager NPP/Services Licensing Regulatory Affairs GE-Hitachi Nuclear Energy Americas, LLC 3901 Castle Hayne Road Wilmington, NC 28401 lisa.schichlein@ge.com NEDC-33895P Revision 0 Affidavit Page 3 of 3