L-12-399, Submittal of Contractor Root Cause Assessment Report
| ML12334A232 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 11/16/2012 |
| From: | Lieb R FirstEnergy Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-12-399, TAC S00301 | |
| Download: ML12334A232 (6) | |
Text
FENOCTM FEA -%
5501 North State Route 2 FirstEnergy Nuclear Operating Company Oak Harbor, Ohio 43449 Raymond A. Lieb 419-321-7676 Vice President, Nuclear Fax: 419-321-7582 November 16, 2012 L-12-399 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Davis-Besse Nuclear Power Station, Unit No. 1 Docket No. 50-346, License Number NPF-3 Submittal of Contractor Root Cause Assessment Report (Proprietary Version)
By letter dated May 14, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12138A037), FirstEnergy Nuclear Operating Company (FENOC) provided a nonproprietary (redacted) version of a contractor root cause assessment report, "Root Cause Assessment Davis-Besse Shield Building Laminar Cracking," developed by Performance Improvement International (PII).
Following the September 19, 2012, meeting with the Advisory Committee on Reactor Safeguards License Renewal Subcommittee regarding the Davis-Besse License Renewal Application, a member of the committee requested that FENOC provide a proprietary (non-redacted) version of the PII report.
Enclosure B provides a proprietary version of the PII report, "Root Cause Assessment Davis-Besse Shield Building Laminar Cracking." The PII report contains proprietary information that is to be withheld from public disclosure pursuant to 10 CFR 2.390. The report also contains personally identifiable information that is to be withheld from public disclosure pursuant to 10 CFR 2.390. Enclosure A provides the PII affidavit to support the disclosure request for the proprietary assessment report.
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Davis-Besse Nuclear Power Station, Unit No. 1 L-1 2-399 Page 2 There are no regulatory commitments contained in this letter. If there are any questions or if additional information is required, please contact Mr. Clifford I. Custer, Fleet License Renewal Project Manager, at 724-682-7139.
Sincere y, Raymond A. Lieb
Enclosure:
A.
Affidavit for Performance Improvement International Report, "Root Cause Assessment Davis-Besse Shield Building Laminar Cracking" B.
Performance Improvement International Report, "Root Cause Assessment Davis-Besse Shield Building Laminar Cracking" (Proprietary) cc:
w/o Enclosures NRC DLR Project Manager NRC Region III Administrator NRC DLR Director NRR DORL Project Manager NRC Resident Inspector Utility Radiological Safety Board
Enclosure A Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse)
Letter L-12-399 Affidavit for Performance Improvement International Report, "Root Cause Assessment Davis-Besse Shield Buildinq Laminar Cracking" 3 pages follow
AFFIDAVIT State of California
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County of San Diego
- 1.
My name is Chong Chiu. I am the Founder of Performance Improvement International, LLC (PII) and as such I am authorized to execute this Affidavit
- 2.
I am familiar with the criteria applied by PlH to determine whether certain P11 information is proprietary and confidential. I am familiar with the policies established by PIl to ensure the proper application of these criteria.
- 3.
I am familiar with the PII information contained in "Root Cause Assessment Davis-Besse Shield Building Laminar Cracking", dated April 18, 2012, and referred to herein as "Document." Information contained in this Document has been classified by PIt as proprietary and confidential in accordance with the policies established by PII for the control and protection of proprietary and confidential information.
- 4.
This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by PII and not made available to the public.
Based upon my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.
- 5.
This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure. The request for withholding of proprietary and confidential information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial information":
- 6.
The following criteria are customarily applied by PII to determine whether information should be classified as proprietary and confidential:
(a)
The information reveals details of P1l's research and development plans and programs or their results.
(b)
Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resource, to design, produce, or market a similar product or service.
(c)
The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for P11 (d)
The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for PII in product optimization or marketability.
(e)
The information is vital to a competitive advantage held by P11, would be helpful to competitors to PII, and would likely cause substantial harm to the competitive position of PII.
The information in the Document is considered proprietary and confidential for the reasons set forth in paragraphs 6(a) through 6(e) above.
- 7.
In accordance with P11's policies governing the protection and control of information, proprietary and confidential information contained in this Document have been made available, on a limited basis, to others outside PHI only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8.
PHI policy requires that proprietary and confidential information be kept in a secured file or area and distributed on a need-to-know basis.
- 9.
The foregoing statements are true and correct to the best of my knowledge, information, and belief.
Subscribed before me this day of 2012
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