3F0319-02, Request for Closed Pre-Submittal Meeting for a License Amendment Request

Request for Closed Pre-Submittal Meeting for a License Amendment Request

ML19063C112
Person / Time
Site:	Crystal River
Issue date:	03/04/2019
From:	Dixon P Duke Energy Florida
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
3F0319-02
Download: ML19063C112 (4)

Text

l(_~ DUKE Crystal River Nuclear Plant 15760 W . Power Line Street

~ ENERGY Crystal River, FL 34428 Docket 50-302 Docket 72-1035 Operating License No. DPR-72 10 CFR 2.390 March 4, 2019 3F0319-02 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Crystal River Unit 3 - Request for Closed Pre-Submittal Meeting for a License Amendment Request

Dear Sir:

In accordance with 10 CFR 2.390, Duke Energy Florida, LLC (DEF), requests a closed pre-submittal meeting with the NRC to discuss a planned license amendment application associated with Crystal River Nuclear Plant decommissioning.

The basis for this request is the sensitive trade secret and commercial or financial information (proprietary information) which will be discussed and contained in meeting materials.

Attachment 1, of this letter, is an affidavit which contains the basis for the proprietary requirement for the meeting and the meeting documents.

This correspondence contains no new regulatory commitments.

If you have any questions regarding this submittal, please contact Mr. Mark Van Sicklen, Licensing Lead, Nuclear Regulatory Affairs, at (352) 501-3045.

Sincerely,

~ ,-1~

Phyllis A. Dixon Manager- SAFSTOR Technical Support Crystal River Nuclear Plant PAD/mvs Attachments:

1. Duke Energy Florida, LLC Affidavit xc: NMSS Project Manager Regional Administrator, Region I

DUKE ENERGY FLORIDA, LLC DOCKET NUMBER 50 - 302 / DOCKET NUMBER 72 - 1035 LICENSE NUMBER DPR - 72 ATTACHMENT 1 DUKE ENERGY FLORIDA, LLC AFFIDAVIT

AFFIDAVIT of Ronald Reising

1. I am Senior Vice President Operations Support, Duke Energy and as such have the responsibility of reviewing the proprietary information sought to be withheld from public disclosure relating to Crystal River Nuclear Plant licensing and am authorized to apply for its withholding on behalf of Duke Energy.

2. I am making this affidavit in conformance with the provisions of 10 CFR 2.390 of the regulations of the Nuclear Regulatory Commission (NRC) and in conjunction with Duke Energy's request for withholding which accompanies this affidavit.

3. I have knowledge of the criteria used by Duke Energy in designating information as proprietary or confidential. I am familiar with the Duke Energy information that will be discussed and the materials that will be presented. Duke Energy considers this information as sensitive trade secret and commercial or financial information (proprietary information}.

4. Pursuant to the provisions of 10 CFR 2.390 and regulatory guidance, the following is furnished for consideration by the NRC in determining whether the information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned by Duke Energy or is subject to a non-disclosure agreement and has been held in confidence by Duke Energy and its consultants.

(ii) The information is of a type that would customarily be held in confidence by Duke Energy. Information is held in confidence if It falls in one or more of the following categories.

(a) The information requested to be withheld reveals distinguishing aspects of a process (or component, structure, tool, method, etc.) whose use by a vendor or consultant, without a license from Duke Energy, would constitute a competitive economic advantage to that vendor or consultant.

(b) The information requested to be withheld consist of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.),

and the application of the data secures a competitive economic advantage for example by requiring the vendor or consultant to perform test measurements, and process and analyze the measured test data.

(c) Use by a competitor of the information requested to be withheld would reduce the competitor's expenditure of resources, or improve its competitive position, in the design, manufacture, shipment, installation assurance of quality or licensing of a similar product.

(d) The information requested to be withheld reveals cost or price information, production capacities, budget levels or commercial strategies of Duke Energy or its customers or suppliers.

(e) The information requested to be withheld reveals aspects of the Duke Energy funded (either wholly or as part of a consortium) development plans or programs of commercial value to Duke Energy.

(f) The information requested to be withheld consists of patentable ideas.

The information in this submittal is held in confidence for the reasons set forth in paragraphs 4(ii)(d) above. Rationale for this declaration is the untimely public interest and involvement that can significantly and adversely affect the future cost of decommissioning Crystal River Nuclear Plant with the potential of adversely affecting the Crystal River Nuclear Plant Nuclear Decommissioning Trust (iii) The information was transmitted to the NRC in confidence and under the provisions of 10CFR 2.390, it is to be received in confidence by the NRC.

(iv) The information sought to be protected Is not available in public to the best of our knowledge and belief.

(v) The proprietary information sought to be withheld is that which will be discussed at the meeting along with the handouts provided for the meeting.

(vi) The proprietary information sought to be withheld from public disclosure has substantial commercial value to Duke Energy.

(a) Untimely public interest or involvement could create a significant Increase in the cost of decommissioning activities.

5. Public disclosure of this information is likely to cause harm to Duke Energy because it would provide publicly the Duke Energy commercial strategy associated with future decommissioning of Crystal River Nuclear Plant prior to any decision made by the Duke Energy Board of Directors.

Ronald Reising affirms that he Is the person who subscribed his name to the foregoing statement, and that all the matters and facts set forth herein are true and correct to the best of his knowledge.

I declare under penalty of perjury that the foregoing is true and correct.

~g Executed on March 4, 2019.