ML20336A061

Request for Withholding Information from Public Disclosure

ML20336A061
Person / Time
Site:	Columbia
Issue date:	01/07/2021
From:	Mahesh Chawla Plant Licensing Branch IV
To:	Sawatzke B Energy Northwest
Chawla M
References
EPID L-2020-LLR-0068
Download: ML20336A061 (4)

Text

January 7, 2021 Mr. Bradley J. Sawatzke Chief Executive Officer Energy Northwest Mail Drop 1023 76 North Power Plant Loop P.O. Box 968 Richland, WA 99352

SUBJECT:

COLUMBIA GENERATING STATION - REQUEST FOR WITHHOLDING INFORMATION FROM PUBLIC DISCLOSURE (EPID L-2020-LLR-0068)

Dear Mr. Sawatzke:

By letter dated April 22, 2020, (Agencywide Documents and Access Management System (ADAMS) Package Accession No. ML20114E235), you requested relief from the inspection requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, Table IWB-2500-1 at Columbia Generating Station. Pursuant to Title 10 of the Code of Federal Regulations Section 50.55a(z)(1)), you submitted Relief Request 4ISI-09 for the alternate examination of reactor vessel feedwater nozzle inner radii and associated nozzle-to-shell welds (feedwater nozzle assemblies) on the basis that the proposed alternative would provide an acceptable level of quality and safety. In the April 22, 2020, request, you submitted an affidavit dated March 27, 2020, executed by Structural Integrity Associates, Inc.

(SIA), requesting that the U.S. Nuclear Regulatory Commission (NRC) withhold the proprietary document in Enclosure 2 from public disclosure pursuant to 10 CFR 2.390 By letter dated November 17, 2020 (ADAMS) Accession No. ML20322A447), you submitted an affidavit dated November 11, 2020, executed by Do Jun Shim, Director, Analytical Services, Structural Integrity Associates, Inc. (SIA), requesting that the NRC withhold the following proprietary document contained in Enclosure 1 of the letter dated November 17, 2020, from public disclosure pursuant to 10 CFR 2.390.

1801567.301P, R1, Probabilistic Fracture Mechanics Evaluation for Columbia Feedwater Nozzle The above proprietary document in Enclosure 1 of the letter dated November 17, 2020, replaces the original version of the above proprietary document in Enclosure 2 of the letter dated April 22, 2020.

A non-proprietary version of this document (Enclosure 2 of the letter dated November 17, 2020) has been placed in the NRCs Public Document Room and added to the NRC Library in the above referenced ADAMS Accession No. ML20322A447. Enclosure 2 of the letter dated November 17, 2020, replaces the non-proprietary version of the above document in Enclosure 3 of the letter dated April 22, 2020.

B. Sawatzke The affidavit stated that the submitted information should be considered exempt from mandatory public disclosure for the following reasons:

a. The Calculations are owned by SIA and constitutes commercial information which has not been placed in the public domain by SIA.

b. SIA made a substantial economic investment to develop the Calculations and, by prohibiting public disclosure, SIA derives an economic benefit. The Calculations are entitled to the protection of the United States copyright laws.

If the Calculations were publicly available to consultants and/or other businesses providing services in the electric and/or nuclear power industry at no cost, these entities would be able to use the Calculations for their own commercial benefit and profit and without expending the substantial economic resources required of SIA to develop the Calculations.

c. SIA made a substantial investment of both money and employee hours over an extended period of time in the development of the Calculations. As a result of such effort and cost, both in terms of dollars spent and dedicated employee time, the Calculations are highly valuable to SIA.

d. A public disclosure of the Calculations would be highly likely to cause substantial harm to SIA's competitive position. If a party does contract with SIA to obtain the information contained herein, it would require an investment of money, time and effort equivalent to that expended by SIA for the party to duplicate the Calculations.

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 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.

B. Sawatzke If you have any questions regarding this matter, please contact me at 301-415-8371 or by e-mail at Mahesh.Chawla@nrc.gov.

Sincerely,

/RA/

Mahesh L. Chawla, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-397 cc: Do Jun Shim, Ph.D.

Director, Analytical Services Structural Integrity Associates, Inc.

5215 Hellyer Avenue, Suite 210 San Jose, CA 95138 Listserv

ML20336A061 *via e-mail OFFICE NRR/DORL/LPL4/PM* NRR/DORL/LPL4/LA* NRR/DNRL/NVIB/BC*

NAME MChawla PBlechman HGonzales DATE 01/06/2021 12/03/2020 12/09/2020 OFFICE NRR/DORL/LPL4/BC* NRR/DORL/LPL4/PM*

NAME JDixon-Herrity MChawla DATE 01/07/2021 01/07/2021