|
---|
Category:Legal-Affidavit
MONTHYEARLR-N24-0042, Affidavit to Support Withholding the Core Operating Limits Report, Per 10 CFR 2.390(a)(4)2024-05-28028 May 2024 Affidavit to Support Withholding the Core Operating Limits Report, Per 10 CFR 2.390(a)(4) LR-N21-0040, Response to Request for Additional Information SNSB-RAI 1 License Amendment Request to Revise Low Pressure Safety Limit to Address General Electric Part 21 Safety Communication2021-05-27027 May 2021 Response to Request for Additional Information SNSB-RAI 1 License Amendment Request to Revise Low Pressure Safety Limit to Address General Electric Part 21 Safety Communication LR-N21-0042, Core Operating Limits Report, Reload 23, Cycle 24, Revision 212021-05-24024 May 2021 Core Operating Limits Report, Reload 23, Cycle 24, Revision 21 LR-N21-0018, Response to Requests for Additional Information SNSB-RAI 2 and SNSB-RAI 3 License Amendment Request to Revise Low Pressure Safety Limit to Address General Electric Part 21 Safety Communication2021-04-29029 April 2021 Response to Requests for Additional Information SNSB-RAI 2 and SNSB-RAI 3 License Amendment Request to Revise Low Pressure Safety Limit to Address General Electric Part 21 Safety Communication LR-N20-0023, License Amendment Request: Revise Hope Creek Generating Station Low Pressure Safety Limit to Address General Electric Nuclear Energy Part-21 Safety Communication SC05-032020-09-24024 September 2020 License Amendment Request: Revise Hope Creek Generating Station Low Pressure Safety Limit to Address General Electric Nuclear Energy Part-21 Safety Communication SC05-03 LR-N19-0101, Submittal of Core Operating Limits Report, Reload 22, Cycle 23, Revision 172019-11-12012 November 2019 Submittal of Core Operating Limits Report, Reload 22, Cycle 23, Revision 17 LR-N19-0074, Core Operating Limits Report, Reload 21, Cycle 22, Revision 162019-09-0303 September 2019 Core Operating Limits Report, Reload 21, Cycle 22, Revision 16 LR-N19-0015, Core Operating Limits Report, Reload 21, Cycle 22, Revision 152019-03-0606 March 2019 Core Operating Limits Report, Reload 21, Cycle 22, Revision 15 LR-N18-0055, Attachment 3 to LR-N18-0055, Affidavit for Core Operating Limits Report for Unit 12018-05-0909 May 2018 Attachment 3 to LR-N18-0055, Affidavit for Core Operating Limits Report for Unit 1 LR-N17-0181, Response to Request for Additional Information Regarding License Amendment Request for Measurement Uncertainty Recapture Power Uprate2017-12-19019 December 2017 Response to Request for Additional Information Regarding License Amendment Request for Measurement Uncertainty Recapture Power Uprate LR-N17-0126, Response to Request for Additional Information (Rai), P-T Limit Report License Amendment Application2017-09-0505 September 2017 Response to Request for Additional Information (Rai), P-T Limit Report License Amendment Application LR-N17-0044, Enclosure 7 to LR-N17-0044 and LAR H17-03 - Affidavits from GEH and the Electric Power Research Institute (EPRI) Supporting the Withholding of Information in Enclosure 6 from Public Disclosure2017-03-29029 March 2017 Enclosure 7 to LR-N17-0044 and LAR H17-03 - Affidavits from GEH and the Electric Power Research Institute (EPRI) Supporting the Withholding of Information in Enclosure 6 from Public Disclosure ML17188A2682017-03-29029 March 2017 Enclosure 13 of LR-N17-0044 and LAR H17-03 - Affidavits from Cameron International Corporation Supporting the Withholding of Information in Enclosures 9 and 11 from Public Disclosure LR-N17-0044, Enclosure 13 of LR-N17-0044 and LAR H17-03 - Affidavits from Cameron International Corporation Supporting the Withholding of Information in Enclosures 9 and 11 from Public Disclosure2017-03-29029 March 2017 Enclosure 13 of LR-N17-0044 and LAR H17-03 - Affidavits from Cameron International Corporation Supporting the Withholding of Information in Enclosures 9 and 11 from Public Disclosure ML17188A2622017-03-29029 March 2017 Enclosure 7 to LR-N17-0044 and LAR H17-03 - Affidavits from GEH and the Electric Power Research Institute (EPRI) Supporting the Withholding of Information in Enclosure 6 from Public Disclosure LR-N16-0202, PSEG Nuclear LLC (PSEG) - Board Resolutions - Foreign Ownership, Control, or Influence2016-11-0303 November 2016 PSEG Nuclear LLC (PSEG) - Board Resolutions - Foreign Ownership, Control, or Influence LR-N22-0083, Enclosure 3 - Global Nuclear Fuel - Americas Affidavit of Lukas Trosman2016-10-28028 October 2016 Enclosure 3 - Global Nuclear Fuel - Americas Affidavit of Lukas Trosman LR-N16-0204, Affidavit for Core Operating Limits Report, Reload 20, Cycle 21, Revision 132016-10-28028 October 2016 Affidavit for Core Operating Limits Report, Reload 20, Cycle 21, Revision 13 LR-N16-0113, GEH Affidavits Supporting the Withholding of Information in Enclosure 6 from Public Disclosure2016-08-16016 August 2016 GEH Affidavits Supporting the Withholding of Information in Enclosure 6 from Public Disclosure LR-N15-0071, Core Operating Limits Report, Reload 18, Cycle 19, Revision 102015-03-20020 March 2015 Core Operating Limits Report, Reload 18, Cycle 19, Revision 10 ML14204A7092014-07-23023 July 2014 Enclosure 3, Affidavit of Peter M. Yandow LR-N14-0157, PSEG Nuclear (PSEG) Response to NRC Regulatory Issue Summary (RIS) 2014-07, Enhancements to the Vendor Inspection Program - Vendor Information Request, Dated May 5, 20142014-06-19019 June 2014 PSEG Nuclear (PSEG) Response to NRC Regulatory Issue Summary (RIS) 2014-07, Enhancements to the Vendor Inspection Program - Vendor Information Request, Dated May 5, 2014 LR-N12-0075, Core Operating Limits Report, Reload 16, Cycle 17, Revision 62012-02-28028 February 2012 Core Operating Limits Report, Reload 16, Cycle 17, Revision 6 ML1127000682011-09-26026 September 2011 Enclosure 3, Mfn 10-245 R4, Affidavit LR-N11-0087, 2011 Annual Report - Guarantees of Payment of Deferred Premiums2011-03-31031 March 2011 2011 Annual Report - Guarantees of Payment of Deferred Premiums LR-N08-0224, Attachments 3 and 4 - Hope Creek Extended Power Uprate Power Ascension Test Report and Affidavit2008-10-31031 October 2008 Attachments 3 and 4 - Hope Creek Extended Power Uprate Power Ascension Test Report and Affidavit ML0831008272008-10-31031 October 2008 Attachments 3 and 4 - Hope Creek Extended Power Uprate Power Ascension Test Report and Affidavit LR-N08-0029, Transmittal of Proprietary Report 07-17P, Revision 3, Stress Assessment of Hope Creek Unit 1 Steam Dryer Based on Revision 4 Loads Model.2008-01-30030 January 2008 Transmittal of Proprietary Report 07-17P, Revision 3, Stress Assessment of Hope Creek Unit 1 Steam Dryer Based on Revision 4 Loads Model. LR-N08-0028, Responses to Requests for Additional Information Request for License Amendment - Extended Power Uprate2008-01-25025 January 2008 Responses to Requests for Additional Information Request for License Amendment - Extended Power Uprate LR-N08-0014, Responses to Requests for Additional Information Request for License Amendment - Extended Power Uprate2008-01-18018 January 2008 Responses to Requests for Additional Information Request for License Amendment - Extended Power Uprate LR-N07-0215, Supplement to License Amendment Request for Extended Power Uprate2007-08-27027 August 2007 Supplement to License Amendment Request for Extended Power Uprate LR-N07-0102, Response to Request for Additional Information Request for License Amendment - Extended Power Uprate2007-05-10010 May 2007 Response to Request for Additional Information Request for License Amendment - Extended Power Uprate LR-N07-0099, Response to Request for Additional Information Request for License Amendment, Extended Power Uprate2007-04-30030 April 2007 Response to Request for Additional Information Request for License Amendment, Extended Power Uprate LR-N07-0060, Response to Request for Additional Information Request for License Amendment - Extended Power Uprate2007-03-30030 March 2007 Response to Request for Additional Information Request for License Amendment - Extended Power Uprate ML0701702062006-11-0202 November 2006 Request for Withholding Proprietary Documentation of Material: White Paper: MRP Review of Implications of Wolf Creek Pressurizer Indications LR-N06-0192, Guaranteed Retrospective Premiums Following Nuclear Accident, Salem and Hope Creek2006-05-0101 May 2006 Guaranteed Retrospective Premiums Following Nuclear Accident, Salem and Hope Creek LR-N05-0448, Response to Request for Additional Information Re Request for Change to Technical Specifications Arts/Mellla Implementation2005-09-23023 September 2005 Response to Request for Additional Information Re Request for Change to Technical Specifications Arts/Mellla Implementation ML0520003282005-07-14014 July 2005 Surveillance Program for Channel-Control Blade Interference LR-N05-0247, Stations - Guaranteed Retrospective Premiums Following a Nuclear Accident2005-04-29029 April 2005 Stations - Guaranteed Retrospective Premiums Following a Nuclear Accident ML0419004262004-07-0101 July 2004 GE Nuclear Energy Request for Withholding - Hope Creek Fuel Vendor Change Response to NRC Request for Additional Information (Docket No. 50-354) LR-N03-0386, Transmittal of Information Relating to SVEA-96+ Modeling Dimensions in Support of the Nrc'S Review of GNF-A Proprietary Report, NEDC-33107P, GEXL80 Correlation for SVEA96+ Fuel, Dated September 20032003-09-0808 September 2003 Transmittal of Information Relating to SVEA-96+ Modeling Dimensions in Support of the Nrc'S Review of GNF-A Proprietary Report, NEDC-33107P, GEXL80 Correlation for SVEA96+ Fuel, Dated September 2003 2024-05-28
[Table view] |
Text
LR-N17-0044 LAR H17-03 Enclosure 7 Affidavits from GEH and the Electric Power Research Institute (EPRI) Supporting the Withholding of Information in Enclosure 6 from Public Disclosure GE-Hitachi Nuclear Energy Americas LLC NEDC-33871P Revision 0 Affidavit Page 1 of 3 AFFIDAVIT I, Lisa K. Schichlein, state as follows:
(1) I am a Senior Project Manager, NPP/Serv ices Licensing, Regulator y Affairs, GE-Hitachi Nuclear Energy Americas LLC (GEH), and have been delegated the function of reviewing the information described in paragraph (2) whic h is sought to be withheld, and have been authorized to apply for its withholding.
(2) The information sought to be withheld is contained in GEH proprietary report NEDC-33871P, "Safety Analysis Report for Hope Creek Generating Station Thermal Power Optimization," Revision 0, dated April 2017. GEH proprietary information in
NEDC-33871P is identified by a dotted underline inside double square brackets. [[
This sentence is an example.
{3}]]. GEH proprietary information in figures and large objects is identified by double square brackets before and after the object. In each case, the superscript notation
{3} refers to Paragraph (3) of this a ffidavit, which provides the basis for the proprietary determination.
(3) In making this application for withholding of proprietary informati on of which it is the owner or licensee, GEH relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 U.S.C. §552(b)(4), and the Trade Secrets Act , 18 U.S.C.
§1905, and NRC regulations 10 CFR 9.17(a)(4
), and 2.390(a)(4) for trade secrets (Exemption 4). The material for which exemption from disclosure is here sought also qualifies under the narrower definition of trade secret, within the meanings assigned to those terms for purposes of FOIA Exempti on 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulat ory Commission, 975 F.2d 871 (D.C. Cir. 1992), and Public Citizen Health Research Group v.
FDA, 704 F.2d 1280 (D.C. Cir. 1983).
(4) The information sought to be withheld is c onsidered to be proprieta ry 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 GEH's competitors without a license from GEH constitutes a competitive economic advantage over other companies; b. Information that, if used by a competitor, would reduce its expenditure of resources or improve its competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product; c. Information that reveals aspects of past, present, or future GEH customer-funded development plans and programs, resulting in potential pr oducts to GEH; GE-Hitachi Nuclear Energy Americas LLC NEDC-33871P Revision 0 Affidavit Page 2 of 3
- d. Information that discloses trade secret or potentially patentable subject matter for which it may be desirable to obtain patent protection.
(5) To address 10 CFR 2.390(b)(4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GEH, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GEH, not been disclosed publicly, and not been made available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions for proprietary or confidentiality agreements or both that provide for maintaining the information in confidence. The initial designation of this information as proprietary information, and the subsequent steps taken to prev ent its unauthorized disclosure, are as set forth in the following paragraphs (6) and (7).
(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, who is the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or who is the person most likely to be subject to the terms unde r which it was licensed to GEH.
(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist, or other equivalent authority for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GEH are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory
provisions or proprietary and/or confidentiality agreements.
(8) The information identified in paragraph (2) is classified as proprietary because it contains detailed GEH methodology for thermal power optimization for GEH Boiling Water Reactors (BWRs). Development of these methods, techniques, and information and their application for the design, modification, and analyses methodologies and processes was achieved at a significant cost to GEH.
The development of the evaluation processes along with the interpretation and application of the analytical results is derived from th e extensive experience and information databases that constitute major GEH assets.
(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEH's competitive position and fore close or reduce the availability of profit-making opportunities. The information is part of GEH's comprehensive BWR safety and
technology base, and its commercial value extends beyond the original development cost.
The value of the technology base goes be yond the extensive physical database and