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| | number = ML14056A120 | | | number = ML14056A120 |
| | issue date = 03/05/2014 | | | issue date = 03/05/2014 |
| | title = Columbia, Request for Withholding Information from Public Disclosure (TAC MF3055) | | | title = Request for Withholding Information from Public Disclosure |
| | author name = Lyon C F | | | author name = Lyon C |
| | author affiliation = NRC/NRR/DORL/LPLIV-1 | | | author affiliation = NRC/NRR/DORL/LPLIV-1 |
| | addressee name = Reddeman M E | | | addressee name = Reddeman M |
| | addressee affiliation = Energy Northwest | | | addressee affiliation = Energy Northwest |
| | docket = 05000397 | | | docket = 05000397 |
| | license number = NPF-021 | | | license number = NPF-021 |
| | contact person = Lyon C F | | | contact person = Lyon C |
| | case reference number = TAC MF3055 | | | case reference number = TAC MF3055 |
| | document type = Letter, Proprietary Information Review | | | document type = Letter, Proprietary Information Review |
| | page count = 4 | | | page count = 4 |
| | project = TAC:MF3055, TAC:MF3055 | | | project = TAC:MF3055 |
| | stage = Other | | | stage = Withholding Request Acceptance |
| }} | | }} |
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| =Text= | | =Text= |
| {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Mark E. Reddemann Chief Executive Officer Energy Northwest P.O. Box 968 (Mail Drop 1023) Richland, WA 99352-0968 March 5, 2014 SUBJECT: COLUMBIA GENERATING STATION-REQUEST FOR WITHHOLDING INFORMATION FROM PUBLIC DISCLOSURE (TAC NO. MF3055) Dear Mr. Reddemann: By letter dated October 31, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 13316A009), Energy Northwest (EN) submitted an affidavit executed by Linda C. Dolan, GE-Hitachi Nuclear Energy Americas LLC (GEH), dated September 20, 2013, requesting that information contained in the following document be withheld from public disclosure pursuant to Title 1 0 of the Code of Federal Regulations (1 0 CFR), Part 2, Section 2.390: NEDC-33813P, "Technical Specification Change Support for RHR/LPCI [residual heat removal/ low pressure core injection] and LPCS [low pressure core spray] Flow Rate Long-Term LOCA [loss-of-coolant accident] Containment Response and ECCS [emergency core cooling system] /Non-LOCA Evaluations," Revision 2, dated September 2013. The information is included in Enclosure 2 to EN's letter dated October 31, 2013. A nonproprietary version of Enclosure 2, designated as NED0-33813 in Enclosure 3 to EN's letter dated October 31, 2013, has been placed in the U.S. Nuclear Regulatory Commission's (NRC's) Public Document Room and added to ADAMS in the NRC Library at Accession No. ML 13316A010. The affidavit stated that the submitted information should be considered exempt from mandatory public disclosure for the following reasons: | | {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 5, 2014 Mr. Mark E. Reddemann Chief Executive Officer Energy Northwest P.O. Box 968 (Mail Drop 1023) |
| * The information ... is classified as proprietary because it contains detailed results of analytical models, methods and processes, including computer codes, which GEH has developed, obtained NRC approval of, and applied to perform evaluations of RHR/LPCI and LPCS flow rates for the GEH Boiling Water Reactor (BWR). Development of these methods, techniques, and information and their application to the design, and to any modification, analyses methods or processes was achieved at a significant cost to GEH. The development of the evaluation processes along with the interpretation and application of the analytical results is derived from the M. Reddemann -2-extensive experience and information databases that constitute major GEH assets. | | Richland, WA 99352-0968 |
| * 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 information 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 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. 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. 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 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. We have reviewed your application and the material in accordance with the requirements of 10 CFR 2.390 and, on the basis of the statements in the affidavit, have determined that the submitted information sought to be withheld contains proprietary commercial information and should be withheld from public disclosure. Therefore, the version of the submitted information marked as proprietary will be withheld from public disclosure pursuant to 10 CFR 2.390(b)(5) and Section 103(b) of the Atomic Energy Act of 1954, as amended. Withholding from public inspection shall not affect the right, if any, of persons properly and directly concerned to inspect the documents. If the need arises, we may send copies of this information to our consultants working in this area. We will, of course, ensure that the consultants have signed the appropriate agreements for handling proprietary information. If the basis for withholding this information from public inspection should change in the future such that the information could then be made available for public inspection, you should promptly notify the NRC. You also should understand that the NRC may have cause to review M. Reddemann -3 -this determination in the future, for example, if the scope of a Freedom of Information Act request includes your information. In all review situations, if the NRC makes a determination adverse to the above, you will be notified in advance of any public disclosure. If you have any questions regarding this matter, I may be reached at (301) 415-2296 or via e-mail at fred.lyon@nrc.gov. Docket No. 50-397 cc: Linda C. Dolan Manager, Regulatory Compliance Regulatory Affairs Sincerely, Carl F. Lyon, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation GE-Hitachi Nuclear Energy Americas LLC 3901 Castle Hayne Road Wilmington, NC 28401 Distribution via Listserv M. Reddemann -3-this determination in the future, for example, if the scope of a Freedom of Information Act request includes your information. In all review situations, if the NRC makes a determination adverse to the above, you will be notified in advance of any public disclosure. If you have any questions regarding this matter, I may be reached at (301) 415-2296 or via e-mail at fred.lyon@nrc.gov. Docket No. 50-397 cc: Linda C. Dolan Manager, Regulatory Compliance Regulatory Affairs Sincerely, /RAJ Carl F. Lyon, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation GE-Hitachi Nuclear Energy Americas LLC 3901 Castle Hayne Road Wilmington, NC 28401 Distribution via Listserv DISTRIBUTION: PUBLIC LPLIV Reading RidsAcrsAcnw_MaiiCTR Resource RidsNrrDssSrxb Resource RidsNrrDorllpl4 Resource RidsNrrPMColumbia Resource RidsNrrLAJBurkhardt Resource RidsRgn4MaiiCenter Resource MHardgrove, NRR/DSS/SRXB ADAMS Accession No.: ML 14056A120 OFFICE NRR/DORLILPL4-1/PM NRR/DORLILPL4-1/LA NAME Flyon JBurkhardt DATE 2/25/14 2/25/14 NRR/DORLILPL4-1/BC MMarkley 3/5/14 OFFICIAL RECORD COPY NRR/DORL/LPL4-1/PM Flyon 3/5/14 | | |
| }} | | ==SUBJECT:== |
| | COLUMBIA GENERATING STATION- REQUEST FOR WITHHOLDING INFORMATION FROM PUBLIC DISCLOSURE (TAC NO. MF3055) |
| | |
| | ==Dear Mr. Reddemann:== |
| | |
| | By letter dated October 31, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13316A009), Energy Northwest (EN) submitted an affidavit executed by Linda C. Dolan, GE-Hitachi Nuclear Energy Americas LLC (GEH), dated September 20, 2013, requesting that information contained in the following document be withheld from public disclosure pursuant to Title 10 of the Code of Federal Regulations (1 0 CFR), Part 2, Section 2.390: |
| | NEDC-33813P, "Technical Specification Change Support for RHR/LPCI [residual heat removal/ low pressure core injection] and LPCS [low pressure core spray] |
| | Flow Rate Long-Term LOCA [loss-of-coolant accident] Containment Response and ECCS [emergency core cooling system] /Non-LOCA Evaluations," Revision 2, dated September 2013. |
| | The information is included in Enclosure 2 to EN's letter dated October 31, 2013. A nonproprietary version of Enclosure 2, designated as NED0-33813 in Enclosure 3 to EN's letter dated October 31, 2013, has been placed in the U.S. Nuclear Regulatory Commission's (NRC's) |
| | Public Document Room and added to ADAMS in the NRC Library at Accession No. ML13316A010. |
| | The affidavit stated that the submitted information should be considered exempt from mandatory public disclosure for the following reasons: |
| | * The information ... is classified as proprietary because it contains detailed results of analytical models, methods and processes, including computer codes, which GEH has developed, obtained NRC approval of, and applied to perform evaluations of RHR/LPCI and LPCS flow rates for the GEH Boiling Water Reactor (BWR). Development of these methods, techniques, and information and their application to the design, and to any modification, analyses methods or processes was achieved at a significant cost to GEH. |
| | The development of the evaluation processes along with the interpretation and application of the analytical results is derived from the |
| | |
| | M. Reddemann extensive experience and information databases that constitute major GEH assets. |
| | * 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 information 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 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. 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. 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 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. |
| | We have reviewed your application and the material in accordance with the requirements of 10 CFR 2.390 and, on the basis of the statements in the affidavit, have determined that the submitted information sought to be withheld contains proprietary commercial information and should be withheld from public disclosure. |
| | Therefore, the version of the submitted information marked as proprietary will be withheld from public disclosure pursuant to 10 CFR 2.390(b)(5) and Section 103(b) of the Atomic Energy Act of 1954, as amended. |
| | Withholding from public inspection shall not affect the right, if any, of persons properly and directly concerned to inspect the documents. If the need arises, we may send copies of this information to our consultants working in this area. We will, of course, ensure that the consultants have signed the appropriate agreements for handling proprietary information. |
| | If the basis for withholding this information from public inspection should change in the future such that the information could then be made available for public inspection, you should promptly notify the NRC. You also should understand that the NRC may have cause to review |
| | |
| | M. Reddemann this determination in the future, for example, if the scope of a Freedom of Information Act request includes your information. In all review situations, if the NRC makes a determination adverse to the above, you will be notified in advance of any public disclosure. |
| | If you have any questions regarding this matter, I may be reached at (301) 415-2296 or via e-mail at fred.lyon@nrc.gov. |
| | Sincerely, Carl F. Lyon, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-397 cc: Linda C. Dolan Manager, Regulatory Compliance Regulatory Affairs GE-Hitachi Nuclear Energy Americas LLC 3901 Castle Hayne Road Wilmington, NC 28401 Distribution via Listserv |
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| | ML14056A120 OFFICE NRR/DORLILPL4-1/PM NRR/DORLILPL4-1/LA NRR/DORLILPL4-1/BC NRR/DORL/LPL4-1/PM NAME Flyon JBurkhardt MMarkley Flyon DATE 2/25/14 2/25/14 3/5/14 3/5/14}} |
Letter Sequence Withholding Request Acceptance |
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MONTHYEARGO2-13-151, NEDO-33813, Rev. 2, Technical Specification Change Support for Rhr/Lpci and LPCS Flow Rate. Long-Term LOCA Containment Response and ECCS/Non-LOCA Evaluations.2013-09-30030 September 2013 NEDO-33813, Rev. 2, Technical Specification Change Support for Rhr/Lpci and LPCS Flow Rate. Long-Term LOCA Containment Response and ECCS/Non-LOCA Evaluations. Project stage: Other ML13316A0092013-10-31031 October 2013 License Amendment Request for Change to Emergency Core Cooling Systems Surveillance Requirements Project stage: Request ML14038A0262014-02-0707 February 2014 NRR E-mail Capture - Acceptance Review Project stage: Acceptance Review ML14056A1202014-03-0505 March 2014 Request for Withholding Information from Public Disclosure Project stage: Withholding Request Acceptance ML14111A0832014-04-29029 April 2014 Request for Additional Information, License Amendment Request to Modify Emergency Core Cooling Systems Surveillance Requirements for Low Pressure Core Spray and Low Pressure Coolant Injection Pump Flows Project stage: RAI ML14163A4822014-05-29029 May 2014 Response to Request for Additional Information Regarding License Amendment Request to Change Emergency Core Cooling Systems Surveillance Requirements Project stage: Response to RAI ML14192B0312014-08-13013 August 2014 Redacted, Request for Additional Information, Nrr/Dss/Scvb, Request to Modify Emergency Core Cooling Systems Surveillance Requirements for Low Pressure Core Spray and Low Pressure Coolant Injection Pump Flows Project stage: RAI ML14335A1892015-01-0707 January 2015 Redacted, Issuance of Amendment No. 229, Revise Emergency Core Cooling Systems Surveillance Requirements for Low Pressure Core Spray and Low Pressure Coolant Injection Pump Flows Project stage: Approval 2014-03-05
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Category:Letter
MONTHYEARGO2-24-004, License Amendment Request to Revise Emergency Plan2024-01-30030 January 2024 License Amendment Request to Revise Emergency Plan IR 05000397/20230042024-01-29029 January 2024 Integrated Inspection and Independent Spent Fuel Storage Installation Report 05000397/2023004 and 07200035/2023001 GO2-24-003, Relief Requests for the Columbia Generating Station Fifth Ten-Year Interval Inservice Testing2024-01-29029 January 2024 Relief Requests for the Columbia Generating Station Fifth Ten-Year Interval Inservice Testing ML24011A1522024-01-10010 January 2024 March 2024 Emergency Preparedness Exercise Inspection-Request for Information GO2-24-005, Docket No. 50-397 Supplement to Reply to a Notice of Violation; EA-21-1702024-01-0808 January 2024 Docket No. 50-397 Supplement to Reply to a Notice of Violation; EA-21-170 GO2-23-136, Guarantee of Payment of Deferred Premium2023-12-20020 December 2023 Guarantee of Payment of Deferred Premium GO2-23-135, Notice of Readiness for Supplemental Inspection2023-12-14014 December 2023 Notice of Readiness for Supplemental Inspection GO2-23-130, Reply to a Notice of Violation; EA-23-0542023-12-14014 December 2023 Reply to a Notice of Violation; EA-23-054 GO2-23-105, Licensing Basis Document Update and Biennial Commitment Change Report2023-12-12012 December 2023 Licensing Basis Document Update and Biennial Commitment Change Report ML23288A0002023-12-0707 December 2023 Issuance of Amendment No. 272 to Adopt TSTF-541, Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position GO2-23-107, Application to Revise Technical Specifications to Adopt TSTS-584, Eliminate Automatic RWCU System Isolation on SLC Initiation2023-12-0505 December 2023 Application to Revise Technical Specifications to Adopt TSTS-584, Eliminate Automatic RWCU System Isolation on SLC Initiation GO2-23-126, Docket No. 50-397 Voluntary Response to Regulatory Issue Summary 2023-012023-11-28028 November 2023 Docket No. 50-397 Voluntary Response to Regulatory Issue Summary 2023-01 GO2-23-121, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-11-27027 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation IR 05000397/20230122023-11-20020 November 2023 Commercial Grade Dedication Inspection Report 05000397/2023012 ML23311A2082023-11-0909 November 2023 Reassignment of U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch IV IR 05000397/20230102023-11-0909 November 2023 Biennial Problem Identification and Resolution Inspection Report 05000397/2023010 IR 05000397/20230932023-11-0101 November 2023 Final Significance Determination of a White Finding, Notice of Violation and Follow-Up Assessment Letter; NRC Inspection Report 05000397/2023093 ML23299A2072023-10-26026 October 2023 Biennial Requalification Inspection Request for Information IR 05000397/20230032023-10-25025 October 2023 Integrated Inspection Report 05000397/2023003 IR 05000397/20230112023-10-0404 October 2023 License Renewal Phase 2 Report 05000397/2023011 IR 05000397/20234012023-09-11011 September 2023 Security Baseline Inspection Report 05000397/2023401 GO2-23-097, In-Service Inspection Summary Report for the Twenty-Sixth Refueling Outage (R26)2023-09-0606 September 2023 In-Service Inspection Summary Report for the Twenty-Sixth Refueling Outage (R26) ML24032A2182023-09-0101 September 2023 Information Request, Security IR 2024401 GO2-23-100, Technical Specification Section 5.6.4 Post Accident Monitoring Instrumentation 14-Day Report for Inoperable Suppression Pool Level Indication2023-08-31031 August 2023 Technical Specification Section 5.6.4 Post Accident Monitoring Instrumentation 14-Day Report for Inoperable Suppression Pool Level Indication GO2-23-056, Application to Revise Technical Specifications to Adopt TSTF-230, Add New Condition B to LCO 3.6.2.3, RHR Suppression Pool Cooling2023-08-29029 August 2023 Application to Revise Technical Specifications to Adopt TSTF-230, Add New Condition B to LCO 3.6.2.3, RHR Suppression Pool Cooling IR 05000397/20230052023-08-22022 August 2023 Updated Inspection Plan for Columbia Generating Station (Report 05000397/2023005) - Mid Year Letter IR 05000397/20230022023-08-0101 August 2023 Integrated Inspection Report 05000397/2023002 GO2-23-093, Supplement to Reply to a Notice of Violation: EA-21-1702023-07-27027 July 2023 Supplement to Reply to a Notice of Violation: EA-21-170 ML23206A2442023-07-25025 July 2023 Energy Northwest Columbia Generating Station, Response to Apparent Violation in NRC Inspection Report 05000397/2023092; EA-23-054 GO2-23-068, Notification of Completion of Commitments Required Prior to Entry Into the Period of Extended Operation2023-07-19019 July 2023 Notification of Completion of Commitments Required Prior to Entry Into the Period of Extended Operation GO2-23-090, Reply to a Notice of Violation2023-07-12012 July 2023 Reply to a Notice of Violation ML23143A1202023-06-27027 June 2023 Request Number 4ISI-11 to the American Society of Mechanical Engineers Boiler and Pressure Vessel Code Regarding Alternate Examination of Reactor Vessel Welds GO2-23-073, Notification of NPDES Permit Issuance2023-06-26026 June 2023 Notification of NPDES Permit Issuance ML23163A2502023-06-12012 June 2023 Summary of Changes and Analysis for Revision 41 of Plant Procedures Manual 13.8.1 Emergency Dose Projection System Operations GO2-23-072, Cycle 27 Core Operating Limits Report2023-06-0505 June 2023 Cycle 27 Core Operating Limits Report ML23157A2702023-06-0101 June 2023 4-2022-011 -022 Letter - OI Closure to Licensee IR 05000397/20230922023-06-0101 June 2023 NRC Inspection Report 05000397/2023092 and Preliminary White Finding IR 05000397/20230902023-06-0101 June 2023 Final Significance Determination of a White Finding, Notice of Violation and Follow-Up Assessment Letter; NRC Inspection Report 05000397/2023090 GO2-23-055, Independent Spent Fuel Storage Installation, 2022 Annual Radiological Environmental Operating Report2023-05-15015 May 2023 Independent Spent Fuel Storage Installation, 2022 Annual Radiological Environmental Operating Report IR 05000397/20230012023-05-0505 May 2023 Integrated Inspection Report 05000397/2023001 - April 26, 2023 GO2-23-006, License Amendment Request to Clean-Up Operating License and Appendix a Technical Specifications2023-05-0101 May 2023 License Amendment Request to Clean-Up Operating License and Appendix a Technical Specifications IR 05000397/20233012023-05-0101 May 2023 NRC Examination Report 05000397/2023301 GO2-23-053, 2022 Annual Environmental Operating Report2023-04-26026 April 2023 2022 Annual Environmental Operating Report GO2-23-057, 2022 Annual Radioactive Effluent Release Report2023-04-25025 April 2023 2022 Annual Radioactive Effluent Release Report ML23110A2642023-04-20020 April 2023 Request for Information License Renewal Phase 2 Inspection GO2-23-012, Application to Revise Technical Specifications to Adopt Tstf-541, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position2023-03-27027 March 2023 Application to Revise Technical Specifications to Adopt Tstf-541, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position GO2-23-041, Generation Station - Level of Financial Protection - Annual Reporting Requirement2023-03-15015 March 2023 Generation Station - Level of Financial Protection - Annual Reporting Requirement GO2-23-038, Plant Decommissioning Fund Status Report2023-03-15015 March 2023 Plant Decommissioning Fund Status Report ML23013A0812023-03-15015 March 2023 Issuance of Amendment No. 270 Revision to Technical Specifications to Adopt TSTF 505, Revision 2, Provide Risk-Informed Extended Completion Times-RITSTF Initiative 4B GO2-23-034, Report of Changes or Errors in Emergency Core Cooling System Loss of Coolant Accident Analysis Models Pursuant to 10 CFR 50.462023-03-13013 March 2023 Report of Changes or Errors in Emergency Core Cooling System Loss of Coolant Accident Analysis Models Pursuant to 10 CFR 50.46 2024-01-08
[Table view] Category:Proprietary Information Review
MONTHYEARML22200A2612022-08-0909 August 2022 Request for Withholding Information from Public Disclosure ML22048C2142022-02-22022 February 2022 Request for Withholding Information from Public Disclosure ML20336A0612021-01-0707 January 2021 Request for Withholding Information from Public Disclosure ML17087A5692017-04-12012 April 2017 Request for Withholding Information from Public Disclosure for Columbia Generating Station ML16207A0332016-09-14014 September 2016 Request for Withholding from Public Disclosure - 5/18/16 Affidavit Executed by E. Hauser, Caldon Ultrasonics Technology Center, Cameron Engineering Report ER-1049, Revision 3 ML16207A0162016-09-14014 September 2016 Request for Withholding from Public Disclosure - 5/18/16 Affidavit Executed by E. Hauser, Caldon Ultrasonics Technology Center, Cameron Engineering Report ER-1074, Revision 0 ML16246A2812016-09-14014 September 2016 Request for Withholding Information from Public Disclosure, 6/9/16 Affidavit Executed by J. Harrison, GE-Hitachi and 6/14/16 Affidavit Executed by N. Wilmshurst, EPRI, Related to NEDC-33853P, Revision 0 ML15191A3602015-09-0101 September 2015 Request for Withholding Information from Public Disclosure - 2/20/15 Affiidavit Executed by L. Schichlein, GE-Hitachi Jet Pump 17/18 Riser Evaluation Dated February 2015 ML15086A0562015-04-14014 April 2015 Request for Withholding Information from Public Disclosure, 3/13/15 Affidavit Executed by L. Trosman, General Electric-Hitachi Nuclear Energy Americas, GNF-001N8896-R2-P ML15040A1382015-02-26026 February 2015 Request for Withholding Information from Public Disclosure, 10/21/14 Affidavit Executed by J. Harrison, General Electric-Hitachi Nuclear Energy Americas, GNF-001N8896-R2-P ML14056A1202014-03-0505 March 2014 Request for Withholding Information from Public Disclosure ML13235A0032013-08-23023 August 2013 Request for Withholding Information from Public Disclosure - 7/25/13 Affidavit Executed by L. Dolan, GEH; Enclosures 1 of Geh'S Response to Request for Additional Information Round 4 ML13109A1632013-04-26026 April 2013 Request for Withholding Information from Public Disclosure - 4/2/13 and 4/10/13 Affidavits Executed by L. Dolan, GEH; Enclosures 1 and 3 of Geh'S Request for Additional Information Responses ML13025A3512013-02-21021 February 2013 Request for Withholding Information from Public Disclosure, Affidavit Dated 12/12/12, Executed by L. Dolan, GE Hitachi Americas LLC, NEDC-33685P, Revision 2 ML13025A3612013-02-21021 February 2013 Request for Withholding Information from Public Disclosure, Affidavit Dated 12/12/12, Executed by L. Dolan, GE Hitachi Americas LLC, NEDC-33698P, Revision 2 ML12345A3662012-12-18018 December 2012 Request for Withholding Information from Public Disclosure, Affidavit Dated 11/1/12 Executed by E. Schrull, GEH-Hitachi, NEDC-33789P, Revision 0 ML12345A3582012-12-18018 December 2012 Request for Withholding Information from Public Disclosure, 9/26/12 Affidavit Executed by E.Schrull, GEH-Hitachi, GEH 10/5/12 Responses to Nrc/De/Eicb 9/5/12 Request for Additional Information ML12229A4712012-12-18018 December 2012 Request for Withholding Information from Public Disclosure, 6/29/12 and 10/22/12 Affidavits Executed by E. Schrull, GEH-Hitachi, NEDC-33751P, Revisions 2 and 3 ML12192A4812012-11-13013 November 2012 Request for Withholding Information from Public Disclosure, Affidavits Dated 11/16/11 and 7/26/12, Executed by E. Schrull, GE Hitachi Americas LLC, NEDC-33696P, Revisions 0 and 1 ML12229A4902012-11-13013 November 2012 Request for Withholding Information from Public Disclosure, 6/12/12 Affidavit Executed by E. Schrull, GEH-Hitachi, Letter GE-MS-CT-106244-JC14 ML12229A4682012-11-13013 November 2012 Request for Withholding Information from Public Disclosure, 6/4/12 Affidavit Executed by E. Schrull, GEH-Hitachi, NEDC-33750P, Revision 0 ML12229A4762012-11-13013 November 2012 Request for Withholding Information from Public Disclosure, 6/7/12 Affidavit Executed by E. Schrull, GEH-Hitachi, NEDC-33753P, Revision 0 ML12229A4802012-11-13013 November 2012 Request for Withholding Information from Public Disclosure, 6/7/12 Affidavit Executed by E. Schrull, GEH-Hitachi, NEDC-33754P, Revision 0 ML12229A4822012-11-13013 November 2012 Request for Withholding Information from Public Disclosure, 6/27/12 Affidavit Executed by E. Schrull, GEH-Hitachi, NEDC-33756P, Revision 0 ML12229A4832012-11-13013 November 2012 Request for Withholding Information from Public Disclosure, 6/7/12 Affidavit Executed by E. Schrull, GEH-Hitachi, NEDC-33758P, Revision 0 ML12193A1092012-07-30030 July 2012 Request for Withholding Information from Public Disclosure, Affidavit Dated 1/27/12, Executed by E. Schrull, GE Hitachi Americas LLC, NEDC-33507P, Revision 1 ML12192A5892012-07-30030 July 2012 Request for Withholding Information from Public Disclosure, Affidavit Dated 1/5/12, Executed by E. Schrull, GE Hitachi Americas LLC, NEDC-33698P, Revision 1 ML12192A5352012-07-30030 July 2012 Request for Withholding Information from Public Disclosure, Affidavit Dated 1/5/12, Executed by E. Schrull, GE Hitachi Americas LLC, NEDC-33697P, Revision 1 ML12192A4542012-07-30030 July 2012 Request for Withholding Information from Public Disclosure, Affidavit Dated 1/5/12, Executed by E. Schrull, GE Hitachi Americas LLC, NEDC-33694P, Revision 1 ML12192A4332012-07-30030 July 2012 Request for Withholding Information from Public Disclosure, Affidavit Dated 11/1/11, Executed by E. Schrull, GE Hitachi Americas LLC, NEDC-33690P, Revision 0 ML12192A3612012-07-30030 July 2012 Request for Withholding Information from Public Disclosure, Affidavit Dated 1/5/12 Executed by E. Schrull, GE Hitachi Americas LLC, NEDC-33685P, Revision 1 ML12192A3252012-07-30030 July 2012 Request for Withholding Information from Public Disclosure, Affidavit Dated 10/31/11 Executed by E. Schrull, GE Hitachi Americas LLC, 0000-0101-7647-R3 Plant-Specific Responses Required by NEDC-32410P-P-A ML0900602232009-01-0808 January 2009 Request for Withholding Information from Public Disclosure ML0820504672008-09-0303 September 2008 Request for Withholding Information from Public Disclosure ML0422304932004-08-10010 August 2004 Withholding from Public Disclosure, NEDC-33144P, Pressure-Temperature Curves for Energy Northwest Columbia 2022-08-09
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 5, 2014 Mr. Mark E. Reddemann Chief Executive Officer Energy Northwest P.O. Box 968 (Mail Drop 1023)
Richland, WA 99352-0968
SUBJECT:
COLUMBIA GENERATING STATION- REQUEST FOR WITHHOLDING INFORMATION FROM PUBLIC DISCLOSURE (TAC NO. MF3055)
Dear Mr. Reddemann:
By letter dated October 31, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13316A009), Energy Northwest (EN) submitted an affidavit executed by Linda C. Dolan, GE-Hitachi Nuclear Energy Americas LLC (GEH), dated September 20, 2013, requesting that information contained in the following document be withheld from public disclosure pursuant to Title 10 of the Code of Federal Regulations (1 0 CFR), Part 2, Section 2.390:
NEDC-33813P, "Technical Specification Change Support for RHR/LPCI [residual heat removal/ low pressure core injection] and LPCS [low pressure core spray]
Flow Rate Long-Term LOCA [loss-of-coolant accident] Containment Response and ECCS [emergency core cooling system] /Non-LOCA Evaluations," Revision 2, dated September 2013.
The information is included in Enclosure 2 to EN's letter dated October 31, 2013. A nonproprietary version of Enclosure 2, designated as NED0-33813 in Enclosure 3 to EN's letter dated October 31, 2013, has been placed in the U.S. Nuclear Regulatory Commission's (NRC's)
Public Document Room and added to ADAMS in the NRC Library at Accession No. ML13316A010.
The affidavit stated that the submitted information should be considered exempt from mandatory public disclosure for the following reasons:
- The information ... is classified as proprietary because it contains detailed results of analytical models, methods and processes, including computer codes, which GEH has developed, obtained NRC approval of, and applied to perform evaluations of RHR/LPCI and LPCS flow rates for the GEH Boiling Water Reactor (BWR). Development of these methods, techniques, and information and their application to the design, and to any modification, analyses methods or processes was achieved at a significant cost to GEH.
The development of the evaluation processes along with the interpretation and application of the analytical results is derived from the
M. Reddemann extensive experience and information databases that constitute major GEH assets.
- 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 information 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 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. 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. 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 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.
We have reviewed your application and the material in accordance with the requirements of 10 CFR 2.390 and, on the basis of the statements in the affidavit, have determined that the submitted information sought to be withheld contains proprietary commercial information and should be withheld from public disclosure.
Therefore, the version of the submitted information marked as proprietary will be withheld from public disclosure pursuant to 10 CFR 2.390(b)(5) and Section 103(b) of the Atomic Energy Act of 1954, as amended.
Withholding from public inspection shall not affect the right, if any, of persons properly and directly concerned to inspect the documents. If the need arises, we may send copies of this information to our consultants working in this area. We will, of course, ensure that the consultants have signed the appropriate agreements for handling proprietary information.
If the basis for withholding this information from public inspection should change in the future such that the information could then be made available for public inspection, you should promptly notify the NRC. You also should understand that the NRC may have cause to review
M. Reddemann this determination in the future, for example, if the scope of a Freedom of Information Act request includes your information. In all review situations, if the NRC makes a determination adverse to the above, you will be notified in advance of any public disclosure.
If you have any questions regarding this matter, I may be reached at (301) 415-2296 or via e-mail at fred.lyon@nrc.gov.
Sincerely, Carl F. Lyon, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-397 cc: Linda C. Dolan Manager, Regulatory Compliance Regulatory Affairs GE-Hitachi Nuclear Energy Americas LLC 3901 Castle Hayne Road Wilmington, NC 28401 Distribution via Listserv
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