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EPID:L-2021-LLR-0014, Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Service Water (SW) System Buried Piping in Accordance with 10 CFR 50.55a(z)(1) (Approved, Closed) |
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Category:Legal-Affidavit
MONTHYEARRA-21-0194, Additional Information Regarding Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/ Replacement of Service Water (SW) System Buried Piping in Accordance.2021-06-22022 June 2021 Additional Information Regarding Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/ Replacement of Service Water (SW) System Buried Piping in Accordance. RA-21-0138, Additional Information Regarding Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Pair/Replacement of Service Water (SW) System Buried Piping in Accordance with2021-05-0303 May 2021 Additional Information Regarding Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Pair/Replacement of Service Water (SW) System Buried Piping in Accordance with RA-20-0353, Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Service Water (SW) System Buried Piping in Accordance with 10 CFR 50.55a(z)(1)2021-02-24024 February 2021 Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Service Water (SW) System Buried Piping in Accordance with 10 CFR 50.55a(z)(1) RA-21-0021, 30-Day Report Pursuant to 10 CFR 50.46, Changes to or Errors in an Acceptable Loss of Coolant Evaluation Model2021-02-0909 February 2021 30-Day Report Pursuant to 10 CFR 50.46, Changes to or Errors in an Acceptable Loss of Coolant Evaluation Model RA-19-0431, Application to Revise Technical Specifications to Adopt TSTF 564, Safety Limit MCPR2020-03-0909 March 2020 Application to Revise Technical Specifications to Adopt TSTF 564, Safety Limit MCPR RA-19-0479, Supplement to Request for License Amendment Regarding Application of Advanced Framatome Methodologies2019-12-31031 December 2019 Supplement to Request for License Amendment Regarding Application of Advanced Framatome Methodologies RA-19-0411, Supplement to Request for License Amendment Regarding Application of Advanced Framatome Methodologies2019-10-23023 October 2019 Supplement to Request for License Amendment Regarding Application of Advanced Framatome Methodologies RA-19-0243, Supplement to Request for License Amendment Regarding Application of Advanced Framatome Methodologies2019-07-0202 July 2019 Supplement to Request for License Amendment Regarding Application of Advanced Framatome Methodologies RA-19-0241, Response to Request for Additional Information Regarding Advanced Framatome Methodologies License Amendment Request2019-06-18018 June 2019 Response to Request for Additional Information Regarding Advanced Framatome Methodologies License Amendment Request RA-19-0240, Response to Request for Additional Information Regarding Advanced Framatome Methodologies License Amendment Request2019-05-29029 May 2019 Response to Request for Additional Information Regarding Advanced Framatome Methodologies License Amendment Request RA-19-0139, Supplement to Request for License Amendment Regarding Application of Advanced Framatome Methodologies2019-03-18018 March 2019 Supplement to Request for License Amendment Regarding Application of Advanced Framatome Methodologies RA-18-0241, Update to Request for License Amendment Regarding Application of Advanced Framatome Methodologies2018-11-28028 November 2018 Update to Request for License Amendment Regarding Application of Advanced Framatome Methodologies RA-18-0202, Transmittal for NRC Confirmatory Calculations2018-10-17017 October 2018 Transmittal for NRC Confirmatory Calculations RA-18-0163, Response to Request for Additional Information - Request for License Amendment to Revise the Technical Specifications to Relocate the Pressure-Temperature Limit Curves to a Pressure and Temperature Limits Report2018-09-27027 September 2018 Response to Request for Additional Information - Request for License Amendment to Revise the Technical Specifications to Relocate the Pressure-Temperature Limit Curves to a Pressure and Temperature Limits Report BSEP 18-0034, Corrected Affidavit Relating to the Request for License Amendment Regarding Core Flow Operating Range Expansion2018-03-16016 March 2018 Corrected Affidavit Relating to the Request for License Amendment Regarding Core Flow Operating Range Expansion BSEP 17-0093, Response to Request for Additional Information Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion2017-11-0101 November 2017 Response to Request for Additional Information Regarding Request for License Amendment Regarding Core Flow Operating Range Expansion BSEP 16-0101, Response to Request for Supplemental Information for License Amendment Request Regarding Core Flow Operating Range Expansion2016-11-0909 November 2016 Response to Request for Supplemental Information for License Amendment Request Regarding Core Flow Operating Range Expansion BSEP 16-0098, Duke Energy- Transmit Information for NRC Model Development Per Licensee September 6, 2016 Request for License Amendment Regarding Core Flow Operating Range Expansion2016-10-27027 October 2016 Duke Energy- Transmit Information for NRC Model Development Per Licensee September 6, 2016 Request for License Amendment Regarding Core Flow Operating Range Expansion ML15023A0442015-01-13013 January 2015 Submittal of Confirmatory Calculation for Unit 2, Cycle 22 ML14204A7092014-07-23023 July 2014 Enclosure 3, Affidavit of Peter M. Yandow ML12348A0152012-11-29029 November 2012 Response to Request for Additional Information Re License Amendment Request for Addition of Analytical Methodology Topical Report to Technical Specification 5.6.5, Core Operating Limits Report, and Revision to Technical. ML12076A0622012-03-0606 March 2012 Request for License Amendments - Addition of Analytical Methodology Topical Report to Technical Specification 5.6.5, Core Operating Limits Report (Colr) and Revision to Technical Specification 2.1.1.2 ML1127000682011-09-26026 September 2011 Enclosure 3, Mfn 10-245 R4, Affidavit RA-11-008, Progress Energy - Evidence of Guarantee of Payment of Deferred Premiums2011-04-14014 April 2011 Progress Energy - Evidence of Guarantee of Payment of Deferred Premiums BSEP 10-0133, Response to Additional Information Request Supporting License Amendment Requests for Addition of Analytical Methodology Topical Reports to Technical Specification 5.6.5 (NRC TAC Nos. ME3856, ME3857, ME3858, and ME3859)2010-11-18018 November 2010 Response to Additional Information Request Supporting License Amendment Requests for Addition of Analytical Methodology Topical Reports to Technical Specification 5.6.5 (NRC TAC Nos. ME3856, ME3857, ME3858, and ME3859) ML0909702482008-07-31031 July 2008 Enclosure 4 and 6 to BSEP 09-0034 - ANP-2729(NP), Rev. 0, Brunswick, Unit 2, Thermal-Hydraulic Design Report for ATRIUM-10 Fuel Assemblies, and Areva Affidavit Withholding ANP-2727(P), Rev. 0 Form Public Disclosure ML0909702462008-06-30030 June 2008 Enclosure 7 and 9 to BSEP 09-0034 - ANP-2727(NP), Rev. 0, Brunswick, Unit 2, Cycle 19 Fuel Cycle Design, and Areva Affidavit Re Withholding ANP-2771(P), Rev. 0 from Public Disclosure BSEP 08-0009, Additional Information in Support of Request for License Amendments Regarding Linear Heat Generation Rate and Core Operating Limits Report References for Areva Fuel2008-01-24024 January 2008 Additional Information in Support of Request for License Amendments Regarding Linear Heat Generation Rate and Core Operating Limits Report References for Areva Fuel ML0729503662007-10-15015 October 2007 Additional Information in Support of Request for License Amendments Regarding Linear Heat Generation Rate and Core Operating Limits Report References for Areva Np Fuel ML0728402172007-09-28028 September 2007 Additional Information in Support of Request for License Amendments Regarding Fuel Design and Storage Requirements for Areva Np Fuel ML0721803702007-07-31031 July 2007 Additional Information in Support of Request for License Amendment Regarding Linear Heat Generation Rate and Core Operating Limits Report References for Areva Np Fuel ML0720703052007-07-18018 July 2007 Additional Information in Support of Request for License Amendment Regarding Linear Heat Generation Rate and Core Operating Limits Report References for Areva Np Fuel BSEP 05-0152, Re-Submittal of Calculation Supporting Revised Main Steam Isolation Valve Leakage Limit2005-12-12012 December 2005 Re-Submittal of Calculation Supporting Revised Main Steam Isolation Valve Leakage Limit BSEP 05-0132, Submittal of Supporting Calculations Regarding Revised Main Steam Isolation Valve Leakage Limit2005-10-11011 October 2005 Submittal of Supporting Calculations Regarding Revised Main Steam Isolation Valve Leakage Limit ML0520003282005-07-14014 July 2005 Surveillance Program for Channel-Control Blade Interference 2021-06-22
[Table view] Category:Letter type:RA
MONTHYEARRA-24-0178, Independent Spent Fuel Storage Installation (ISFSI) Docket No. 72-06 - Registration for Use of General License Spent Fuel Casks2024-07-10010 July 2024 Independent Spent Fuel Storage Installation (ISFSI) Docket No. 72-06 - Registration for Use of General License Spent Fuel Casks RA-24-0166, Revision to Emergency Plan Implementing Procedure2024-06-27027 June 2024 Revision to Emergency Plan Implementing Procedure RA-24-0163, Registration for Use of General License Spent Fuel Casks2024-06-19019 June 2024 Registration for Use of General License Spent Fuel Casks RA-24-0164, Inservicee Inspection Program Owners Activity Report Refueling Outage 252024-06-19019 June 2024 Inservicee Inspection Program Owners Activity Report Refueling Outage 25 RA-24-0030, Duke Energy - Annual Radioactive Effluent Release Report - 20232024-04-29029 April 2024 Duke Energy - Annual Radioactive Effluent Release Report - 2023 RA-24-0083, Annual Report of Changes Pursuant to 10 CFR 50.462024-04-25025 April 2024 Annual Report of Changes Pursuant to 10 CFR 50.46 RA-24-0031, Annual Radiological Environmental Operating Report - 20232024-04-23023 April 2024 Annual Radiological Environmental Operating Report - 2023 RA-24-0094, Request for Approval of Duke Energy Corporation Transition to ANSI/ANS3.1-2014, American National Standard for Selection and Training of Nuclear Power Plant Personnel and Revision 4 of Regulatory Guide 1.8, Rev. 4 Qualification and Traini2024-04-17017 April 2024 Request for Approval of Duke Energy Corporation Transition to ANSI/ANS3.1-2014, American National Standard for Selection and Training of Nuclear Power Plant Personnel and Revision 4 of Regulatory Guide 1.8, Rev. 4 Qualification and Training RA-24-0015, Submittal of 2023 Sea Turtle Annual Report2024-01-10010 January 2024 Submittal of 2023 Sea Turtle Annual Report RA-23-0306, Procedures CSD-EP-BNP-0101-01, EAL Technical Basis Document, Revision 006 and CSD-EP-CNS-0101-01, EAL Technical Basis Document, Revision 005, Summary Of.2023-12-12012 December 2023 Procedures CSD-EP-BNP-0101-01, EAL Technical Basis Document, Revision 006 and CSD-EP-CNS-0101-01, EAL Technical Basis Document, Revision 005, Summary Of. RA-23-0318, Supplement to Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-12-0404 December 2023 Supplement to Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation RA-23-0284, RA-23-0284 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-11-16016 November 2023 RA-23-0284 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation RA-23-0281, Procedure EP-ALL-EPLAN, Duke Energy Common Emergency Plan, Revision 5, Summary of Changes2023-11-0101 November 2023 Procedure EP-ALL-EPLAN, Duke Energy Common Emergency Plan, Revision 5, Summary of Changes RA-23-0225, Procedure AD-EP-ALL-0109, Offsite Protective Action Recommendations, Revision 9, and the Joint Information Center (JIC) Relocation, Summary of Changes2023-09-20020 September 2023 Procedure AD-EP-ALL-0109, Offsite Protective Action Recommendations, Revision 9, and the Joint Information Center (JIC) Relocation, Summary of Changes RA-23-0199, Response to Request for Additional Information (RAI) Regarding Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) for Inservice Inspection of the Torus Metallic Liner2023-08-18018 August 2023 Response to Request for Additional Information (RAI) Regarding Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) for Inservice Inspection of the Torus Metallic Liner RA-23-0122, License Amendment Request to Revise the 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors, Categorization Process to .2023-08-17017 August 2023 License Amendment Request to Revise the 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors, Categorization Process to . RA-23-0045, Inservice Inspection Program Owner'S Activity Report for Unit 2 Refueling Outage 262023-06-28028 June 2023 Inservice Inspection Program Owner'S Activity Report for Unit 2 Refueling Outage 26 RA-23-0145, Independent Spent Fuel Storage Installation (Isfsi), Registration for Use of General License Spent Fuel Casks2023-06-15015 June 2023 Independent Spent Fuel Storage Installation (Isfsi), Registration for Use of General License Spent Fuel Casks RA-23-0135, Submittal of 30 Day Report Per 10 CFR 26.719(c), Unsatisfactory Performance of Health and Human Services Certified Laboratory2023-06-0707 June 2023 Submittal of 30 Day Report Per 10 CFR 26.719(c), Unsatisfactory Performance of Health and Human Services Certified Laboratory RA-23-0139, Registration for Use of General License Spent Fuel Casks2023-06-0606 June 2023 Registration for Use of General License Spent Fuel Casks RA-23-0041, Response to NRC Regulatory Issue Summary 2023-01 Preparation and Scheduling of Operator Licensing Examinations2023-05-30030 May 2023 Response to NRC Regulatory Issue Summary 2023-01 Preparation and Scheduling of Operator Licensing Examinations RA-23-0044, Aduke Energy Annual Report of Changes Pursuant to 10 CFR 50.462023-04-26026 April 2023 Aduke Energy Annual Report of Changes Pursuant to 10 CFR 50.46 RA-23-0047, Duke Energy Annual Radiological Environmental Operating Report - 20222023-04-26026 April 2023 Duke Energy Annual Radiological Environmental Operating Report - 2022 RA-23-0046, Annual Radioactive Effluent Release Report - 20222023-04-24024 April 2023 Annual Radioactive Effluent Release Report - 2022 RA-23-0096, Post Accident Monitoring (PAM) Instrumentation Report2023-04-12012 April 2023 Post Accident Monitoring (PAM) Instrumentation Report RA-23-0063, Notification of Deviation from BWRVIP Guidelines2023-04-11011 April 2023 Notification of Deviation from BWRVIP Guidelines RA-23-0039, 10 CFR 140.21 Licensee Guarantees of Payment of Deferred Premiums2023-03-30030 March 2023 10 CFR 140.21 Licensee Guarantees of Payment of Deferred Premiums RA-23-0040, Onsite Property Insurance Coverage2023-03-30030 March 2023 Onsite Property Insurance Coverage RA-23-0036, Biennial Decommissioning Financial Assurance Reports2023-03-30030 March 2023 Biennial Decommissioning Financial Assurance Reports RA-23-0021, Unit 2 Cycle 26 Core Operating Limits Report (COLR)2023-02-22022 February 2023 Unit 2 Cycle 26 Core Operating Limits Report (COLR) RA-22-0091, Application to Revise Technical Specifications to Adopt TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements2023-02-16016 February 2023 Application to Revise Technical Specifications to Adopt TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements RA-23-0001, Request to Use a Provision of a Later Edition and Addenda of the ASME Boiler and Pressure Vessel Code, Section XI2023-02-0202 February 2023 Request to Use a Provision of a Later Edition and Addenda of the ASME Boiler and Pressure Vessel Code, Section XI RA-23-0010, 2022 Sea Turtle Annual Report2023-01-0909 January 2023 2022 Sea Turtle Annual Report RA-22-0616, Revision to Brunswick Snubber Program Plan2023-01-0505 January 2023 Revision to Brunswick Snubber Program Plan RA-22-0308, Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) for Inservice Inspection of the Torus Metallic Liner2022-12-16016 December 2022 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) for Inservice Inspection of the Torus Metallic Liner RA-22-0342, Revision to Emergency Plan On-Shift Staffing Analysis2022-12-0808 December 2022 Revision to Emergency Plan On-Shift Staffing Analysis RA-22-0335, Submittal of 30-Day Report Per 10CFR26.719(c)(1) - Unsatisfactory Performance of a Health & Human Services Certified Lab2022-12-0505 December 2022 Submittal of 30-Day Report Per 10CFR26.719(c)(1) - Unsatisfactory Performance of a Health & Human Services Certified Lab RA-22-0344, Notification of Deviation from BWRVIP Guidelines2022-11-30030 November 2022 Notification of Deviation from BWRVIP Guidelines RA-22-0261, Independent Spent Fuel Storage Installation (ISFSI) Registration for Use of General License Spent Fuel Casks2022-09-15015 September 2022 Independent Spent Fuel Storage Installation (ISFSI) Registration for Use of General License Spent Fuel Casks RA-22-0271, Accident Monitoring Instrumentation Special Report2022-09-13013 September 2022 Accident Monitoring Instrumentation Special Report RA-22-0252, Registration for Use of General License Spent Fuel Casks2022-08-25025 August 2022 Registration for Use of General License Spent Fuel Casks RA-22-0190, Submittal of Updated Final Safety Analysis Report (UFSAR) Revision 28, 10 CFR 54.37 Update, Technical Requirements Manuals, Quality Assurance Program Description, Technical Specification Bases, 10 CFR 50.59 and 10 CFR .2022-08-11011 August 2022 Submittal of Updated Final Safety Analysis Report (UFSAR) Revision 28, 10 CFR 54.37 Update, Technical Requirements Manuals, Quality Assurance Program Description, Technical Specification Bases, 10 CFR 50.59 and 10 CFR . RA-22-0165, Inservice Inspection Program Owner'S Activity Report for Refueling Outage 242022-06-0909 June 2022 Inservice Inspection Program Owner'S Activity Report for Refueling Outage 24 RA-22-0175, Post Accident Monitoring (PAM) Instrumentation Report2022-06-0101 June 2022 Post Accident Monitoring (PAM) Instrumentation Report RA-22-0155, Revision to Emergency Plan Annex and Implementing Procedure2022-05-26026 May 2022 Revision to Emergency Plan Annex and Implementing Procedure RA-22-0134, Unit 1 Cycle 23 Mellla+ Eigenvalue Tracking Data2022-05-25025 May 2022 Unit 1 Cycle 23 Mellla+ Eigenvalue Tracking Data RA-22-0151, Duke Energy Common Emergency Plan, Revision 2, Summary of Changes2022-05-24024 May 2022 Duke Energy Common Emergency Plan, Revision 2, Summary of Changes RA-22-0148, 10 CFR 26.719(c)(1) Report - Unsatisfactory Performance of a Health and Human Services Certified Laboratory2022-05-16016 May 2022 10 CFR 26.719(c)(1) Report - Unsatisfactory Performance of a Health and Human Services Certified Laboratory RA-22-0147, Duke Energy Carolinas, LLC, and Duke Energy Progress, LLC, Response to Request for Additional Information (RAI) Regarding License Amendment Request for Relocating the Duke Energy Emergency Operations Facility2022-05-13013 May 2022 Duke Energy Carolinas, LLC, and Duke Energy Progress, LLC, Response to Request for Additional Information (RAI) Regarding License Amendment Request for Relocating the Duke Energy Emergency Operations Facility RA-22-0028, Annual Report of Changes Pursuant to 10 CFR 50.462022-04-27027 April 2022 Annual Report of Changes Pursuant to 10 CFR 50.46 2024-07-10
[Table view] |
Text
John A. Krakuszeski fa DUKE Vice President Brunswick Nuclear Plant
~ ENERGY 8470 River Rd SE Southport, NC 28461 o: 910.832.3698 June 22, 2021 Serial: RA-21-0194 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-71 and DPR-62 Docket Nos. 50-325 and 50-324
Subject:
Additional Information Regarding Proposed Alternative to ASME Boiler &
Pressure Vessel Code Section XI Requirements for Repair/Replacement of Service Water (SW) System Buried Piping in Accordance with 10 CFR 50.55a(z)(1)
Reference
- 1. Letter from John A. Krakuszeski (Duke Energy) to the U.S. Nuclear Regulatory Commission Document Control Desk, "Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Service Water (SW)
System Buried Piping in Accordance with 10 CFR 50.55a(z)(1)," dated February 24, 2021, ADAMS Accession Number ML21055A797.
- 2. Letter from John A. Krakuszeski (Duke Energy) to the U.S. Nuclear Regulatory Commission Document Control Desk, "Additional Information Regarding Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Service Water (SW) System Buried Piping in Accordance with 10 CFR 50.55a(z)(1)," dated May 3, 2021, ADAMS Accession Number ML21123A293.
Ladies and Gentlemen:
On February 24, 2021 (i.e., Reference 1), Duke Energy Progress, LLC (Duke Energy) requested approval to allow the use of the V-Wrap' Carbon Fiber Reinforced Polymer (CFRP) Composite System for the internal repair of the buried Service Water (SW) System piping at Brunswick Steam Electric Plant (BSEP). This request contained information which is proprietary to Structural Group, Inc. and Simpson Gumpertz & Heger, Inc. Enclosure 10 of the Reference contained affidavits requesting withholding of the proprietary information per 10 CFR 2.390. On May 3, 2021 (i.e., Reference 2), revised affidavits were provided.
This submittal provides a revised affidavit from Structural Group, Inc. The enclosed affidavit supersedes the Structural Group, Inc affidavit provided in Reference 2.
U.S. Nuclear Regulatory Commission Page 2 of 2 This document contains no new regulatory commitments. Please refer any questions regarding this submittal to Mr. Art Zaremba, Director - Nuclear Fleet Licensing, at (980) 373-2062.
Sincerely, John A. Krakuszeski MAT/mat
Enclosure:
Revised Affidavit from Structural Group, Inc cc:
Ms. Laura Dudes, Regional Administrator, Region II Mr. Andrew Hon, Project Manager Mr. Gale Smith, NRC Senior Resident Inspector Chair - North Carolina Utilities Commission
Enclosure RA-21-0194 Revised Affidavit from Structural Group, Inc.
struc\ural group U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD 20852 RE: Application for Withholding Proprietary Information from Public Disclosure Ladies and Gentlemen:
Structural Group, Inc. (SGI), has provided certain proprietary information for Brunswick Electric Steam Plant (BSEP) Unit Nos. 1 and 2 in connection with a request by Duke Energy Progress, LLC for authorization from the U. S. Nuclear Regulatory Commission (USNRC) to use an alternative to the requirements of American Society of Mechanical Engineers (ASME), Boiler &
Pressure Vessel Code,Section XI, IWA-4221(b), pursuant to 10 CFR 50.55a(z)(1) (Reference 4). This application requests that proprietary information of SGI be protected from public disclosure. The proprietary information for which withholding is being requested in the reference is further identified in the attached affidavit signed by the owner of the proprietary information, SGI, on behalf of itself and any wholly-owned subsidiaries or affiliated companies.
An affidavit accompanies this letter, setting forth the basis on which the information may be withheld from public disclosure by the USNRC and addressing with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390 (Reference 5) of the USNRC regulations.
A request for withholding proprietary information has been previously approved by the USNRC at the Surry Nuclear Station (Reference 1), South Texas Project (Reference 2) and Arkansas Nuclear One (Reference 3). Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Duke Energy Progress, LLC. Correspondence with respect to the proprietary aspects of the Application or the Affidavit should reference this letter and be addressed to Scott Greenhaus, Executive Vice President, Structural Group, Inc., 10150 Old Columbia Road, Columbia, MD 21046.
Scott Greenhaus, Executive Vice President
REFERENCES:
- 1. USNRC letter to Virginia Electric & Power Company, "Surry Power Station, Unit Nos. 1 and 2 - Relief from the Requirements of the ASME Code (CAC Nos. MF8987 and MF8988; EPID L-2016-LLR-0019)", (ML17303A068), dated December 20, 2017.
- 2. USNRC letter to South Texas Project Nuclear Operating Company, "South Texas Project Units 1 and 2 - Proposed Alternative RR-ENG-3-24 to ASME Boiler & Pressure
Code Requirements for Repair of Essential Cooling Water (ECW) System Class 3 Buried Piping", (EPID- L-2019-LLR-0096), dated
- 3. Letter from Entergy Operations, Inc. to USNRC Document Control Desk, " Proposed Alternative to ASME Boiler & Pressure
"' Vessel Code Section XI Requirements for Repair/Replacement of Service Water (SW) System Piping in Accordance with 10 CFR 50.55a(z)(1)," Docket Nos. 50-313 and 50-368, Document No. 0CAN072001.
- 4. Letter from Duke Energy Progress, LLC to USN RC Document Control Desk, " Proposed Alternative to ASME Boiler & Pressure
- 5. 10 CFR 2.390, "Public Inspections, Exemptions, Requests for Withholding."
Structural Group, Inc.
10150 Old Columbia Road Columbia, MD 21046 AFFIDAVIT State of Maryland )
County of Howard )
Before me, the undersigned authority, personally appeared Scott Greenhaus, who, being by me duty sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Structural Group, Inc. and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief.
Executive Vice President Swor to and subscribed before me this 7th of June 2021.
I, Scott Greenhaus, am Executive Vice President of Structural Group, Inc. (SGI). In my capacity as Executive Vice President I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in conjunction with nuclear plant licensing and rulemaking proceedings and am authorized to apply for its withholding on behalf of SGI and its affiliates.
I am making this Affidavit in conformance with the provisions of 10 CFR 2.390 of the U. S.
Nuclear Regulatory Commission (USNRC) regulations and in conjunction with SGIs Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.
I have personal knowledge of the criteria and procedures utilized by SGI in designating information as a trade secret, privileged or as confidential commercial or financial information.
Pursuant to the provisions of paragraph (b)(4) of 10 CFR 2.390 of the USNRC's regulations, the following is furnished for consideration by the USNRC in determining whether the information sought to be withheld from public disclosure should be withheld.
The information sought to be withheld from public disclosure is owned by and has been held in confidence by SGI. Specific portions of the Duke Energy Progress, LLC request which include SGI proprietary information are: - Request for Relief RA-20-0353 for a Proposed Alternative to ASME Boiler &
Pressure Vessel Code Section XI Requirements for Repair/Replacement of Service Water System Piping in Accordance with 10 CFR 50.55a(z)(1)
- Section 8 - Proposed Alternative and Basis for Use
- Section 9 - Material Manufacturing and Material Qualification
- Section 11 - Installation
- Section 12 - QA/QC Program
- Section 13 - Qualifications and Training
- Section 14 - Failure Modes & Effects Analysis (FMEA) and Operating Experience - Material Manufacture and Material Qualification (withheld in its entirety including all attachments) - Sample Procedures (withheld in its entirety including all attachments) - Sample Training Plans (withheld in its entirety including all attachments) - Failure Modes Effects Analysis (withheld in its entirety including all attachments) - Operating Experience (withheld in its entirety including all attachments)
The information is of a type customarily held in confidence by SGI and not disclosed to the public. SGI has a rational basis for determining the types of information customarily held in confidence by it and utilizes a system to determine when and whether to hold certain types of
information in confidence. The application of that system and the substance of that system provides a rational basis for maintaining confidentiality and justifies the USNRC withholding the information from public disclosure.
Under SGl's system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:
- 1. The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by a competitor of SGI without license constitutes a competitive advantage over other companies.
- 2. It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.
- 3. Its use by a competitor would reduce their expenditure of resources or improve their competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.
- 4. It reveals cost or price information, production capacities, budget levels, or commercial strategies of SGI, their customers or suppliers.
- 5. It reveals aspects of past, present, or future development plans funded by SGI or its customer, and programs of potential commercial value to SGI.
- 6. It contains patentable ideas, for which patent protection may be desirable.
There are sound policy reasons behind the SGI system which include the following:
- 1. The use of such information by SGI gives it a competitive advantage over competitors. It is, therefore, withheld from disclosure to protect SGl's competitive position.
- 2. It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes SGl's ability to sell products and services involving the use of the information.
- 3. Use by a competitor would put SGI at a competitive disadvantage by reducing the competitor's expenditure of resources and capital.
- 4. Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire process, thereby depriving SGI of its competitive advantage.
- 5. Unrestricted disclosure would jeopardize the position of prominence of SGI in the world marketplace, and thereby give a market advantage to competitor in those countries in which SGI operates.
- 6. SGl's capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.
The information is being transmitted to the USNRC in confidence and, under the provisions of 10 CFR 2.390, it is to be received in confidence by the USNRC. The information sought to be protected is not available in public sources and, to the best of our knowledge and belief, available information has not been previously employed in the same original manner or method.
The proprietary information sought to be withheld in this submittal is that which is appropriately marked in Duke Energy Progress, LLC letter to the USNRC, "Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI Requirements for Repair/Replacement of Service Water (SW) System Piping in Accordance with 10 CFR 50.55a(z)(1)", Docket Nos. 50-325/324, Document No. RA-20-0353 being transmitted by Duke Energy Progress, LLC letter and reflected in SGl's Application for Withholding Proprietary Information from Public Disclosure addressed to the USNRC Document Control Desk. The proprietary information as submitted by SGI is that associated with the "Proposed Alternative to ASME Boiler & Pressure Vessel Code Section XI, Requirements for Repair/Replacement of Service Water (SW) System Piping in Accordance with 10 CFR 50.55a(z)(1)" for Brunswick Electric Steam Plant (BSEP}, Unit Nos. 1 and 2, and may be used only for that purpose.
This information is part of that which will enable SGI to:
- 1. Provide input to Duke Energy Progress, LLC. to provide to the USNRC for review of the Brunswick Electric Steam Plant (BSEP), Unit Nos. 1 and 2, 10 CFR 50.46 submittal; and
- 2. Provide licensing support for the Duke Energy Progress, LLC submittal.
SGI owns or is permitted to use the proprietary information referenced in this Affidavit under agreements that include Duke Energy Progress, LLC maintaining the confidentiality of such information, as contemplated in this Affidavit.
Further this information has substantial commercial value as follows:
- 1. The SGI plan to sell the use of this information to their customers 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 their customers in the licensing process.
- 3. The information requested to be withheld reveals the distinguishing 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 documentation without purchasing the right to use the information.
- 6. The development of the technology described in part by the proprietary 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 competitors to duplicate this information, similar technical programs would have to be performed including a significant expenditure money and resources.
Further the deponent sayeth not.