ML083430311

Susquehanna Steam Electric Station Revised Affidavit for Requested Amendment to Unit 2 License NPF-22: MCPR Safety Limits

ML083430311
Person / Time
Site:	Susquehanna
Issue date:	11/21/2008
From:	Spence W H Susquehanna
To:	Document Control Desk, Office of Nuclear Reactor Regulation
RES-Library
References
PLA-6458
Download: ML083430311 (6)

Text

William H. Spence Executive Vice President and Chief Operating Officer/Chief Nuclear Officer Tel. 610.774.3683 Fax 610.774.5019 Whspence@pplweb.com PPL Corporation Two North Ninth Street Allentown, PA 18101-1179 Tel. 610.774.5151 www.pplweb.com P PI NOV 2 1. 2008 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop OPl-17 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION REVISED AFFIDAVIT FOR REQUESTED AMENDMENT TO UNIT 2 LICENSE NPF-22: MCPR SAFETY LIMITS PLA-6458 Docket No. 50-388

Reference:

1) PLA-6438, Mr. B. T. McKinney (PPL) to Document Control Desk (USNRC),"Proposed Amendment No. 274 To Unit 2 License NPF-22: MCPR Safety Limits," dated October 30, 2008.In accordance with the provisions of 10 CFR 50.90, PPL Susquehanna, LLC (PPL)submitted a request for an amendment to the Technical Specifications for Susquehanna Steam Electric Station (SSES) Unit 2 in Reference

1. An affidavit from AREVA NP, Inc. was included in Reference 1 that identified the AREVA proprietary information.

Subsequent discussions between PPL and the NRC identified that the affidavit required revision to include the address of the affidavit executor and the method used to mark the proprietary information.

Therefore, the revised affidavit, which includes the requested additional information, is included as Attachment 1 to this letter.A typographical error was also noted in Enclosure 2 to Reference

1. The No Significant Hazards Consideration is numbered 1-2-4, but should be numbered 1-2-3.If you have any questions, please contact Mr. Charlie Manges at (570)-542-3089.

74-bC I' Document Control Desk PLA-6458 I declare, under penalty of perjury, that the foregoing is true and correct.Executed on: // V- W. H. Spence

Attachment:

Revised AREVA NP, Inc., Affidavit for Proprietary Information cc: NRC Region I Mr. R. Janati, DEP/BRP Mr. F. W. Jaxheimer, NRC Sr. Resident Inspector Mr. B. K. Vaidya, NRC Project Manager Attachment to PLA-6458 Revised AREVA NP, Inc., Affidavit for Proprietary Information AFFIDAVIT COMMONWEALTH OF VIRGINIA )) ss.CITY OF LYNCHBURG

)1. My name is Gayle F. Elliott, 3315 Old Forest Road, Lynchburg, Va. 24501. I am Manager, Product Licensing, for AREVA NP Inc. and as such I am authorized to execute this Affidavit.

2. I am familiar with the criteria applied by AREVA NP to determine whether certain AREVA NP information is proprietary.

I am familiar with the policies established by AREVA NP to ensure the proper application of these criteria.3. I am familiar with the AREVA NP information contained in Enclosure 1 to a letter to the U.S. Nuclear Regulatory Commission from Mr. Britt T. McKinney (PPL Susquehanna, LLC) entitled, "Susquehanna Steam Electric Station Proposed Amendment to Unit 2 License NPF-22: MCPR Safety Limits," dated October 2008 and referred to herein as"Document." Information contained in this Document has been classified by AREVA NP as proprietary in accordance with the policies established by AREVA NP for the control and protection of proprietary and confidential information.

Proprietary information in Enclosure 1 is enclosed by brackets [J. Enclosure 2 is the non-proprietary version of the information.

4. This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by AREVA NP and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.

5. This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure.

The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial information." 6. The following criteria are customarily applied by AREVA NP to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA NP's research and development plans and programs or their results.(b) Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.(c) The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for AREVA NP.(d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA NP in product optimization or marketability.(e) The information is vital to a competitive advantage held by AREVA NP, would be helpful to competitors to AREVA NP, and would likely cause substantial harm to the competitive position of AREVA NP.The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b) and 6(c) above.7. In accordance with AREVA NP's policies governing the protection and control of information, proprietary information contained in .this Document have been made available, on a limited basis, to others outside AREVA NP only as required and under suitable agreement providing for nondisclosure and limited use of the information.

8. AREVA NP policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.9. The foregoing statements are true and correct to the best of my knowledge, information, and belief.SUBSCRIBED before me this "0 day of November, 2008.Sherry L. McFaden NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 10/31/10 Reg. # 7079129 SHER- Y L. MCFADIt N~obly PUbli fglC Commonwealth of Vlfla 7079129 My CommTissionf Expires Oct 31, 201011