ML15027A258

Request for Withholding Information from Public Disclosure Submission Dated 1/14/15, for Supplement to Response to RAI - Submittal of Post Extended Power Uprate Steam Dryer Inspection Results (MF4559)

ML15027A258
Person / Time
Site:	Nine Mile Point
Issue date:	02/03/2015
From:	Bhalchandra Vaidya Plant Licensing Branch 1
To:	Orphanos P Exelon Generation Co
Vaidya B, NRR/DORL/LPL1-1, 415-3308
References
TAC MF4559
Download: ML15027A258 (4)

Text

Mr. Peter M. Orphanos UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 3, 2015 Site Vice President-Nine Mile Point Nuclear Station Exelon Generation Company, LLC 348 Lake Road Oswego, New York 13126

SUBJECT:

NINE MILE POINT NUCLEAR STATION, UNIT NO.2-REQUEST FOR WITHHOLDING INFORMATION FROM PUBLIC DISCLOSURE RE: SUBMISSION DATED JANUARY 14, 2015, FOR SUPPLEMENT TO RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION -SUBMITTAL OF POST EXTENDED POWER UPRATE STEAM DRYER INSPECTION RESULTS IN ACCORDANCE WITH OPERATING LICENSE CONDITION 2.C.(20)(f)

AND 2.C.(20)(g) (TAG NO. MF4559)

Dear Mr. Orphanos:

By letter dated January 14, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15023A030 and ADAMS Package Accession No. ML15023A070), Exelon Generation Company, LLC (Exelon, the licensee) submitted the following affidavits requesting that the information contained in the following documents be withheld from public disclosure pursuant to Title 10 of the Code of Federal Regulations (1 0 CFR), Part 2, Section 2.390(a)(4):

(1) Affidavit executed by Alan J. Bilanin, President and Senior Associate, Continuum Dynamics, Inc. (C.D.I.), 34 Lexington Avenue, Ewing, NJ 08618-2302, on November 18, 2014. The information sought to be withheld is contained in Enclosure 1 of C. D. I. Letter No. 14110 "Transmittal of C. D. I. Technical Note No.14-04P "Computation of Cumulative Usage Factor for the 115% CL TP Power Level at Nine Mile Point Unit 2 with the Inboard RCIC Valve Closed" Revision 0 dated 18 November 2014. (Your letter dated January 14, 2015, Attachment 6, ADAMS Accession No. ML15022A664).

(2) Affidavit executed by Alan J. Bilanin, President and Senior Associate, Continuum Dynamics, Inc. (C.D.I.), 34 Lexington Avenue, Ewing, NJ 08618-2302, on November 18, 2014. The information sought to be withheld is contained in Enclosure 1 of C.D.I. Letter No. 14108 "Transmittal of C.D.I. Report No.14-08P "Stress Re-Evaluation of Nine Mile Point Unit 2 Steam Dryer at 115% CL TP," Revision 0 dated 18 November 2014. (Your letter dated January 14, 2015, Attachment 7, ADAMS Accession No. ML15022A665).

(3) Affidavit executed by Alan J. Bilanin, President and Senior Associate, Continuum Dynamics, Inc. (C.D.I.), 34 Lexington Avenue, Ewing, NJ 08618-2302, on November 18, 2014. The information sought to be withheld is contained in Enclosure 1 of C.D.I Letter No. 14109 "Transmittal of C. D. I. Report No.14-09P "Acoustic and Low Frequency Hydrodynamic Loads at CL TP Target Power Level on Nine Mile Point Unit 2 Steam Dryer to 250 Hz Using ACM Rev. 4.1 R" Revision 1 dated 18 November 2014.

P.M. Orphanos (Your letter dated January 14, 2015, Attachment 8, ADAMS Accession No. ML15022A666). . (4) Affidavit executed by Alan J. Bilanin, President and Senior Associate, Continuum Dynamics, Inc. (C.D.I.), 34 Lexington Avenue, Ewing, NJ 08618-2302, on November 18, 2014. The information sought to be withheld is contained in Enclosure 1 of C.D.I. Letter No. 14107 "Transmittal of Continuum Dynamics, Inc. Nonconformance Report No. 0343 dated 18 November 2014. (Your letter dated January 14, 2015, Attachment 9, ADAMS Accession No. ML15022A667).

All the above mentioned affidavits stated that the submitted information should be considered exempt from mandatory public disclosure for the following reasons: (4) The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. Some examples of categories of information that fit into the definition of proprietary information are: a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by C. D. I.'s competitors without a license from C.D.I. constitutes a competitive economic advantage over other companies;

b. Information that, if used 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 of a similar product; (8) The information identified in paragraph (2) [of the affidavit], above, is classified as proprietary because it contains C.D.I. methodology steam dryer analyses.

These methods, techniques, and data along with their application to the design, modification, and analyses associated with pressure loading on steam dryers were achieved at a significant cost to C. D. I. The development of the evaluation processes along with the interpretation and application of the analytical results is derived from the extensive experience and information databases that constitute major C.D.I. assets. We have reviewed your application and the material in accordance with the requirements of 1 0 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 submitted information in Attachments 6, 7, 8, and 9 of the submission, marked as proprietary, will be withheld from public disclosure pursuant to 10 CFR 2.390(b)(5) and Section 1 03(b) of the Atomic Energy Act of 1954, as amended.

P.M. Orphanos 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 Nuclear Regulatory Commission (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.

The nonproprietary versions of Attachments 6, 7, 8, and 9 of the licensee submittal (Attachments 1, 2, 3, and 4 of the licensee's submittal, (part of ADAMS Accession Nos. ML15023A031, ML15022A661, ML15022A662, and ML15022A663, respectively))

have been placed in the NRC's Public Document Room and added to the ADAMS Public Electronic Reading Room. If you have any questions regarding this matter, I may be reached at 301-415-3308.

Docket No. 50-41 0 cc: Alan J. Bilanin President

& Senior Associate Continuum Dynamics, Inc. 34 Lexington Avenue Ewing, NJ 08618-2302 Additional Distribution via Listserv Sincerely, Bhalchandra K. Vaidya, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation P.M. Orphanos 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 Nuclear Regulatory Commission (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.

The nonproprietary versions of Attachments 6, 7, 8, and 9 of the licensee submittal (Attachments 1, 2, 3, and 4 of the licensee's submittal, (part of ADAMS Accession Nos. ML15023A031, ML15022A661, ML15022A662, and ML15022A663, respectively))

have been placed in the NRC's Public Document Room and added to the ADAMS Public Electronic Reading Room. If you have any questions regarding this matter, I may be reached at 301-415-3308 Docket No. 50-410 cc: Alan J. Bilanin President

& Senior Associate Continuum Dynamics, Inc. 34 Lexington Avenue Ewing, NJ 08618-2302 Additional Distribution via Listserv DISTRIBUTION:

PUBLIC RidsNrrDorllpl1-1 Resource RidsRgn1 MaiiCenter Resource DSchroeder, Region 1 Sincerely, IRA/ Bhalchandra K. Vaidya, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation LPL 1-1 R/F RidsNrrLAKGoldstein Resource RidsAcrsAcnw_MaiiCTR Resource BChakrapani, NRR/EMCB RidsNrrDssStsb Resource RidsNrrPMNineMilePoint Resource RidsNrrDeEmcb Resource ADAMS Accession No.: ML15027A258 OFFICE NRR/LPL 1-1\PM NRR/LPL 1-1\LA NRR/EMCB/BC NRR/LPL 1-1/BC NRR/LPL 1-1/PM NAME BVaidya KGoldstein TLupold BBeasley BVaidya DATE 1/28/2015 01/28/2015 1/30/2015 2/03/2015 2/03/2015 OFFICIAL RECORD COPY