ML21281A139

Request for Withholding Information from Public Disclosure Response to Request for Additional Information

ML21281A139
Person / Time
Site:	Brunswick
Issue date:	10/26/2021
From:	Stone Z NRC/NRR/DORL/LPL2-1
To:	Krakuszeski J Duke Energy Progress
Stone, Z, NRR/DORL
References
EPID L-2021-LLR-0014
Download: ML21281A139 (4)

Text

October 26, 2021

Mr. John A. Krakuszeski Site Vice President Brunswick Steam Electric Plant Duke Energy Progress, LLC 8470 River Rd. SE (M/C BNP001)

Southport, NC 28461

SUBJECT:

BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 - REQUES T FOR WITHHOLDING INFORMATION FROM PUBLIC DISCLOSURE RE:

RESPONSE TO REQUEST FOR A DDITIONAL INFORMATION (EPID L-2021-LLR-0014)

Dear Mr. Krakuszeski:

By letter dated October 4, 2021, Duke Energy Carolinas, LLC (Du ke Energy) submitted an affidavit dated September 21, 2021, executed by Scott Greenhaus of Structural Group, Inc.

(SGI), requesting that the information contained in the followi ng document be withheld from public disclosure pursuant to Section 2.390 of Title 10 of the Code of Federal Regulations (10 CFR):

Response to Request for Additional Information Proposed Alterna tive to ASME Section XI Requirements for Repair/Replacement of Buried Servic e Water Piping

A nonproprietary copy of this document has been placed in the U.S. Nuclear Regulatory Commissions (NRCs) Public Document Room and added to the NRC Library in the Agencywide Documents Access and Management System (ADAMS), Acce ssion No.

ML21277A306.

The affidavit stated that the submitted information should be w ithheld from public disclosure for the following reasons:

The information sought to be withheld from public disclosure is owned by and has been held in confidence by SGI [and... ] this information has substantial commercial value as follows:

1) The SGI plan to sell the use of this information to their cu stomers for the purpose of installing the V-Wrap TM Carbon Fiber Reinforced Polymer (CFRP) Composite System in safety related piping.

2) That SGI can self-support and defense of the technology to t heir customers in the licensing process.

J. Krakuszeski

3) The information requested to be withheld reveals the disting uishing aspects of a methodology which was developed by SGI.

4) Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of SGI because it would enhance the ability of competitors to provide similar licensing services for commercial power reactors without commensurate expenses.

5) Public disclosure of the information would enable others to use the information to meet USNRC requirements for licensing documentat ion without purchasing the right to use the information.

6) The development of the technology described in part by the p roprietary information is the result of applying the results of many years of experience in an intensive effort by SGI and the expenditure of a considerable sum of money and resources. In order for competit ors to duplicate this information, similar technical programs would ha ve to be performed including a significant expenditure [of] money and re sources.

We have reviewed your application and the material in accordanc e with the requirements of 10 CFR 2.390 and, on the basis of the statements in the affidav it, have determined that the submitted information sought to be withheld contains proprietar y commercial information and should be withheld from public disclosure.

Therefore, the version(s) of the submitted information marked a s proprietary will be withheld from public disclosure pursuant to 10 CFR 2.390(b)(5) and Secti on 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 arise s, 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 inspe ction should change in the future such that the information could then be made available for publ ic inspection, you should promptly notify the NRC. You also should understand that the N RC 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, i f the NRC makes a determination adverse to the above, you will be notified in advance of any pu blic disclosure.

J. Krakuszeski

If you have any questions, please contact me at (301) 415-0615 or by e-mail at Zackary.Stone@nrc.gov.

Sincerely,

Zackary Stone, Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Docket Nos. 50-325 and 50-324

cc: Scott Greenhaus Executive Vice President Structural Group, Inc.

10150 Old Columbia Road Columbia, MD 21046

Listserv

ML21281A139 OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-2/LA NRR/DEX/EMIB/BC NAME ZStone RButler ITseng (Acting)

DATE 10/5/2021 10/22/2021 10/26/2021 OFFICE NRR/DNRL/NPHP/BC NRR/DORL/LPL2-2/BC NRR/DORL/LPL2-1/PM NAME MMitchell DWrona ZStone DATE 10/21/2021 10/26/2021 10/26/2021