RA-09-052, Submittal of Affidavit Pertaining to Root Cause Report 00907846-08, Tritium Identified in Emergency Service Water (ESW) Vault
| ML091890427 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 07/07/2009 |
| From: | Jury K Exelon Generation Co, Exelon Nuclear |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 00907846-08, RA-09-052 | |
| Download: ML091890427 (4) | |
Text
RA-09-052 July 7,2009 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 - 0001 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRC Docket No. 50-219
Reference:
Root Cause Report 00907846 "Tritium Identified in Emergency Service Water (ESW) Vaulf' Exelon Generation Company, LLC considers the referenced Root Cause Report to be proprietary. Please see attached affidavit pertaining to this matter.
If you have any further questions or require additional information, please contact us.
Respectfully,
~!'4 Vice President, Licensing and Regulatory Affairs Exelon Generation Company, LLC
Attachment:
Exelon Generation Company, LLC Affidavit cc:
Regional Administrator - NRC Region I NRC Senior Resident Inspector - Oyster Creek NRC Project Manager. NRR - Oyster Creek NRC Regional Counsel-Region I
ATTACHMENT Exelon Generation Company, LLC Oyster Creek Nuclear Geneiratiing Station Docket No. 50-219 Root Cause Report 00901846-08 "Tritium Identified in Emergency Service Water (ESW) Vault" Affidavit
AFFIDAVIT I, Keith R. Jury, Vice President of Licensing and Regulatory Affairs, do hereby affirm and state:
1.
I am the Vice President of Licensing and Regulatory Affairs for Exelon Generation Company, LLC (EGC) and authorized to execute this affidavit on behalf of the Oyster Creek Nuclear Generating Station (OCNGS). I am further authorized to review information submitted to the Nuclear Regulatory Commission (NRC) and apply to the NRC for the withholding of information from disclosure.
2.
The information sought to be withheld is the following document in its entirety:
OCNGS Root Cause Report (RCR) titled, "Tritium Identified in Emergency Service Water (ESW) Vault," designated with the unique identifier 00907846-08.
3.
In making this application for withholding of proprietary information of which it is the owner, EGC relies on provisions of NRC regulation 10 CFR 2.390(a)(4). The information for which exemption from disclosure is sought is confidential commercial information.
4.
The proprietary information provided by OCNGS should be held in confidence by the NRC pursuant to the policy reflected in 10 CFR 2.390(a)(4) because:
a.
The information sought to be withheld in the OCNGS root cause report (see paragraph 2 above) is and has been held in confidence intemally by EGC.
b.
The information is of a type that is customarily held in confidence by EGC and the principle for the confidentiality is for the continued ability of EGC to be frank, candid, and self-critical in evaluations of station issues so that effective corrective actions can be implemented to prevent recurrence.
This is the foundation of our Corrective Action Program (CAP). To preserve the ability to be frank and self-critical with commentary and opinions that form the basis for improving performance, personnel must be confident that statements and analyses are not taken out of context by an organization without regulatory accountability for honest assessment of factual information. Making a root cause document publicly available is inappropriate, as it may serve to undermine the high level of thoroughness, candor, and self-critical nature of the document, because the document would be subject to scrutiny that is not held to a regulatory standard of accountability.
c.
The information was submitted to the NRC voluntarily and in confidence.
Affidavit Page 2 of 2 d.
The information sought to be withheld, to the best of my knowledge and belief, is not available in public sources and no public disclosure has been made.
5.
Approval of proprietary treatment of a CAP document can be made by the Vice President of Licensing and Regulatory Affairs, the person most likely to be familiar with the value and sensitivity of the corrective action processes and its relation to EGC's and OCNGS' ability to remain frank and self-critical in future investigations.
6.
Accordingly, EGC requests that the designated document be withheld from public disclosure pursuant to 10 CFR 2.390(a)(4).
I declare under penalty of perjury that the foregoing affidavit and statements therein are true and correct to the best of my knOWledge, information, and belief.
~~f.ky Vice President, Licensing and RegUlatory Affairs Exelon Generation Company, LLC Date: 4 1, ZO02