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Category:Fuel Cycle Reload Report
MONTHYEARSVPLTR 23-0037, Core Operating Limits Report for Cycle 292023-11-29029 November 2023 Core Operating Limits Report for Cycle 29 ML22326A0322022-11-17017 November 2022 Core Operating Limits Report for Dresden Unit 3 Cycle 28 SVPLTR 21-0061, Core Operating Limits Report for Dresden Unit 2 Cycle 282021-11-19019 November 2021 Core Operating Limits Report for Dresden Unit 2 Cycle 28 ML20318A0902020-11-0505 November 2020 Core Operating Limits Report for Dresden Unit 3 Cycle 27 ML19322A7522019-11-13013 November 2019 Core Operating Limits Report for Dresden Unit 2 Cycle 27 ML18318A3032018-11-0909 November 2018 Core Operating Limits Report for Unit 3 Cycle 26 ML17320A1232017-11-13013 November 2017 Core Operating Limits Report for Unit 2 Cycle 26 SVPLTR 16-0061, Core Operating Limits Report for Unit 3 Cycle 252016-11-21021 November 2016 Core Operating Limits Report for Unit 3 Cycle 25 RS-16-206, Annual Report of Emergency Core Cooling System Evaluation Model Changes and Errors2016-10-21021 October 2016 Annual Report of Emergency Core Cooling System Evaluation Model Changes and Errors ML16294A1172016-10-18018 October 2016 Core Operating Limits Report for Dresden Unit 2 Cycle 25 Rev. 1 SVPLTR 16-0056, Cycle 24A Core Operating Limits Report Revision 12016-10-18018 October 2016 Cycle 24A Core Operating Limits Report Revision 1 SVPLTR 15-0070, Core Operating Limits Report for Cycle 24A2015-12-15015 December 2015 Core Operating Limits Report for Cycle 24A SVPLTR 15-0065, Core Operating Limits Report for Cycle 252015-11-16016 November 2015 Core Operating Limits Report for Cycle 25 SVPLTR 15-0059, Core Operating Limits Report, Cycle 242015-10-25025 October 2015 Core Operating Limits Report, Cycle 24 SVPLTR 14-0055, Core Operating Limits Report for Cycle 242014-11-0707 November 2014 Core Operating Limits Report for Cycle 24 SVPLTR 14-0017, Unit, 2 - Transmittal of Core Operating Limits Report for Unit 2 Cycle 242014-03-28028 March 2014 Unit, 2 - Transmittal of Core Operating Limits Report for Unit 2 Cycle 24 SVPLTR 14-0009, Core Operating Report for Cycle 232014-01-31031 January 2014 Core Operating Report for Cycle 23 SVPLTR 13-0047, Core Operating Limits Report for Unit Cycle 242013-11-22022 November 2013 Core Operating Limits Report for Unit Cycle 24 SVPLTR 12-0056, Transmittal of Core Operating Limits Report for Cycle 23, Revision 02012-12-0606 December 2012 Transmittal of Core Operating Limits Report for Cycle 23, Revision 0 SVPLTR 11-0045, Core Operating Limits Report for Unit 2 Cycle 23, Revision 02011-11-11011 November 2011 Core Operating Limits Report for Unit 2 Cycle 23, Revision 0 SVPLTR 11-0038, Core Operating Limits Report for Cycle 22, Revision 12011-10-10010 October 2011 Core Operating Limits Report for Cycle 22, Revision 1 SVPLTR 11-0013, Submittal of Core Operating Limits Report Cycle 22, Revision 22011-03-22022 March 2011 Submittal of Core Operating Limits Report Cycle 22, Revision 2 SVPLTR 10-0048, Core Operating Limits Report for Unit 3 Cycle 22, Revision 02010-11-24024 November 2010 Core Operating Limits Report for Unit 3 Cycle 22, Revision 0 SVPLTR 10-0015, Core Operating Limits Report for Cycle 22, Revision 12010-03-16016 March 2010 Core Operating Limits Report for Cycle 22, Revision 1 SVPLTR 09-0058, Core Operating Limits Report, Cycle 22, Revision 02009-11-25025 November 2009 Core Operating Limits Report, Cycle 22, Revision 0 SVPLTR 08-0063, Core Operating Limits Report for Cycle 21, Revision 02008-11-14014 November 2008 Core Operating Limits Report for Cycle 21, Revision 0 SVPLTR 08-0061, Core Operating Limits Report for Unit 2 Cycle 21, Revision 12008-11-0404 November 2008 Core Operating Limits Report for Unit 2 Cycle 21, Revision 1 SVPLTR 07-0051, Core Operating Limits Report for Unit 2 Cycle 21, Revision 02007-11-0707 November 2007 Core Operating Limits Report for Unit 2 Cycle 21, Revision 0 SVPLTR 07-0047, Core Operating Limits Report for Unit 3 Cycle 20 Revision 12007-10-0101 October 2007 Core Operating Limits Report for Unit 3 Cycle 20 Revision 1 SVPLTR 06-0006, Core Operating Limits Report for Plant Cycle 20 Revision 12006-02-17017 February 2006 Core Operating Limits Report for Plant Cycle 20 Revision 1 SVPLTR 05-0045, Core Operating Limits Report for Unit 2 Cycle 20 Revision 02005-11-29029 November 2005 Core Operating Limits Report for Unit 2 Cycle 20 Revision 0 SVPLTR 05-0029, Core Operating Limits Report for Cycle 19 Revision 22005-07-19019 July 2005 Core Operating Limits Report for Cycle 19 Revision 2 ML0511502892005-04-12012 April 2005 Attachment B, Core Operating Limits Report for Dresden Unit 2 Cycle 19 SVPLTR 04-0080, Letter Transmitting Core Operating Limits Report for Unit 3 Cycle 19 Revision 02004-12-0202 December 2004 Letter Transmitting Core Operating Limits Report for Unit 3 Cycle 19 Revision 0 ML0412805202004-04-30030 April 2004 Core Operating Limits Report for Dresden Unit 3 Cycle 18A - Revision 1 (Non - Proprietary Information) ML0336405852003-12-23023 December 2003 Core Operating Limits Report for Cycle 18A, Revision 0 ML0332301912003-11-0707 November 2003 Attachments C and D - Core Operating Limits Report for Dresden Unit 2 Cycle 19 Revision 0 and Unit 3 Cycle 18 Revision 1, Non-Proprietary Version ML0332301892003-11-0707 November 2003 Core Operating Limits Report for Unit 2 Cycle 19 Revision 0 and Unit 3 Cycle 18 Revision 1 ML0400901502003-10-31031 October 2003 0000-0006-9848-SRLR,Rev. 2 Class I, Supplemental Reload Licensing Report for Dresden Unit 3 Reload 17, Cycle 18 ML0313605732003-05-0909 May 2003 Core Operating Limits Report for Unit 2 Cycle 18, Revision 4 ML0309702932003-03-28028 March 2003 Core Operating Limits Report for Unit 2 Cycle 18, Revision 3 ML0236505462002-12-23023 December 2002 Core Operating Limits Report for Unit 2 Cycle 18, Revision 2 ML0230801052002-10-22022 October 2002 Core Operating Limits Report for Dresden Unit 3 Cycle 18 2023-11-29
[Table view] Category:Letter
MONTHYEARIR 05000237/20230042024-02-0202 February 2024 Integrated Inspection Report 05000237/2023004 and 05000249/2023004 IR 05000010/20230012024-01-17017 January 2024 NRC Inspection Report 05000010/2023001 (Drss) ML23354A2812024-01-0404 January 2024 Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0031 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) ML23305A1402023-12-13013 December 2023 Units 1 & 2; Nine Mile Point, Unit 2; Peach Bottom, Units 2 & 3; and Quad Cities, Units 1 and 2 - Issuance of Amendments to Adopt Traveler TSTF-580 RS-23-121, Sixth Ten-Year Interval Inservice Testing Program2023-11-30030 November 2023 Sixth Ten-Year Interval Inservice Testing Program SVPLTR 23-0037, Core Operating Limits Report for Cycle 292023-11-29029 November 2023 Core Operating Limits Report for Cycle 29 RS-23-119, Supplemental Information Letter for Part 73 Exemption Request - Responses to Request for Confirmatory Information2023-11-10010 November 2023 Supplemental Information Letter for Part 73 Exemption Request - Responses to Request for Confirmatory Information ML23317A1192023-11-10010 November 2023 Constellation Energy Generation, LLC - 2023 Annual Report - Guarantees of Payment of Deferred Premiums RS-23-107, Relief Request I5R-22, Inservice Inspection Program Relief Request Regarding Examination Coverage for the Fifth Inservice Inspection Interval2023-11-0808 November 2023 Relief Request I5R-22, Inservice Inspection Program Relief Request Regarding Examination Coverage for the Fifth Inservice Inspection Interval RS-23-102, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-10-16016 October 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML23285A2342023-10-13013 October 2023 Confirmation of Initial License Examination RS-23-097, Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans2023-10-12012 October 2023 Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans ML23279A0712023-10-0606 October 2023 Response to NRC Dresden Nuclear Power Station, Units 2 and 3 - Comprehensive Engineering Team Inspection Report 05000237/2023011 and 05000249/2023011 ML23269A0662023-09-28028 September 2023 Proposed Alternative Request RV-23H Associated with the Sixth 10-Year Inservice Testing Interval ML23265A1322023-09-27027 September 2023 Proposed Alternative Request RV-03 Associated with the Sixth 10-Year Inservice Testing Interval ML23205A1362023-09-20020 September 2023 Proposed Alternative Request RV-02D Associated with the Sixth IST Interval IR 05000237/20230112023-09-0606 September 2023 Comprehensive Engineering Team Inspection Report 05000237/2023011 and 05000249/2023011 RS-23-071, Application to Adopt TSTF-564, Safety Limit MCPR2023-08-30030 August 2023 Application to Adopt TSTF-564, Safety Limit MCPR RS-23-080, Constellation Energy Generation, LLC, Application to Revise Technical Specifications to Adopt TSTF-264-A, Revision 0, 3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs2023-08-30030 August 2023 Constellation Energy Generation, LLC, Application to Revise Technical Specifications to Adopt TSTF-264-A, Revision 0, 3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs IR 05000237/20234022023-08-29029 August 2023 Security Baseline Inspection Report 05000237/2023402 and 05000249/2023402 IR 05000237/20230022023-08-0808 August 2023 Integrated Inspection Report 05000237/2023002 and 05000249/2023002 ML23212A9892023-08-0303 August 2023 Subsequent License Renewal Application Public Meeting Summary of Pre-Submittal Meeting ML23174A1502023-08-0303 August 2023 Issuance of Amendment Nos. 282 and 275 Control Rod Scram Times ML23193A0052023-07-28028 July 2023 Subsequent License Renewal Application Public Meeting Summary of Pre-Submittal Meeting ML23192A6292023-07-11011 July 2023 Correction Letter - Issuance of Amendment Nos. 281 and 274 Regarding Transition to GNF3 Fuel (EPID L-2022-LLA-0121) (Non-Proprietary) ML23144A3142023-07-0606 July 2023 Issuance of Amendment Nos. 281 and 274 Transition to GNF3 Fuel (EPID L-2022-LLA-0121) - Nonproprietary ML23187A0462023-07-0606 July 2023 Notification of NRC Baseline Inspection and Request for Information; Inspection Report 05000237/2023004 ML23178A2422023-06-28028 June 2023 Reassignment of the U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch III SVPLTR 23-0021, Registration of Use of Casks to Store Spent Fuel2023-06-20020 June 2023 Registration of Use of Casks to Store Spent Fuel RS-23-078, Supplement to License Amendment Request to Revise Technical Specification 3.1.4, Control Rod Scram Times2023-06-16016 June 2023 Supplement to License Amendment Request to Revise Technical Specification 3.1.4, Control Rod Scram Times RS-23-077, Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations2023-06-16016 June 2023 Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations IR 05000237/20233012023-05-30030 May 2023 NRC Initial License Examination Report 05000237/2023301; 05000249/2023301 RS-23-042, Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling2023-05-25025 May 2023 Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling ML23132A0932023-05-17017 May 2023 Information Meeting (Public Open House) with a Question and Answer Session to Discuss NRC 2022 End-Of-Cycle Plant Performance Assessment of Dresden Power Station, Units 2 and 3 RS-23-070, Supplement to License Amendment Request Regarding Transition to GNF3 Fuel2023-05-16016 May 2023 Supplement to License Amendment Request Regarding Transition to GNF3 Fuel SVPLTR 23-0018, Submittal of 2022 Annual Radiological Environmental Operating Report2023-05-15015 May 2023 Submittal of 2022 Annual Radiological Environmental Operating Report IR 05000237/20230012023-05-0404 May 2023 Integrated Inspection Report 05000237/2023001 and 05000249/2023001 SVPLTR 23-0019, ILT 22-1 (2023-301) Svpltr 23-0019 Post-Exam Submittal Letter (1)2023-05-0101 May 2023 ILT 22-1 (2023-301) Svpltr 23-0019 Post-Exam Submittal Letter (1) ML23118A3472023-05-0101 May 2023 County, 1 & 2; Nine Mile Point, 2; and Quad Cities, 1 & 2 - Correction of Amendment No. 193 Adoption of TSTF-306, Revision 2, Add Action to LCO 3.3.6.1 to Give Option to Isolate the Penetration EPID L-2022-LLA-0143 ML23114A2522023-04-28028 April 2023 Request to Use a Provision of a Later Edition of the ASME Boiler & Pressure Vessel Code, Section XI IR 05000237/20234012023-04-26026 April 2023 Cyber Security Inspection Report 05000237/2023401 and 05000249/2023401 ML23081A0382023-04-25025 April 2023 County, 1 & 2; Nine Mile Point, 2; and Quad Cities, 1 & 2 - Issuance of Amendments to Adopt TSTF-306, Rev. 2, Add Action to LCO 3.3.6.1 to Give Option to Isolate the Penetration IR 05000237/20235012023-04-21021 April 2023 Emergency Preparedness Biennial Exercise Inspection Report 05000237/2023501 and 05000249/2023501 ML23110A3202023-04-21021 April 2023 Information Request to Support the NRC Annual Baseline Emergency Action Level and Emergency Plan Changes Inspection RS-23-057, Supplement to License Amendment Request Regarding Transition to GNF3 Fuel2023-04-17017 April 2023 Supplement to License Amendment Request Regarding Transition to GNF3 Fuel SVPLTR 23-0014, Annual Dose Report for 20222023-04-15015 April 2023 Annual Dose Report for 2022 ML23088A2242023-04-0505 April 2023 Regulatory Audit Report Regarding License Amendment Request to Transition to GNF3 Fuel ML23087A0482023-03-28028 March 2023 Operator Licensing Examination Approval - Dresden Nuclear Power Station, April 2023 2024-02-02
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Exek¢n'..
Exelon Generation www.exeloncorp.com Nuclear Dresden Generating Station 6500 North Dresden Road Morris, IL 60450-9765 Tel 815-942-2920 November 7, 2003 RHLTR: #03-0073 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington D.C. 20555-0001 Dresden Nuclear Power Station, Units 2 and 3 Facility Operating License Nos. DPR-19 and 25 NRC Docket Nos. 50-237 and 249
Subject:
Core Operating Limits Report for Unit 2 Cycle 19 Revision 0 and Unit 3 Cycle 18 Revision 1 The purpose of this letter is to transmit Revision 0 of the Core Operating Limits Report (COLR) for Dresden Nuclear Power Station (DNPS) Unit 2 operating cycle 19 (D2C19) and Revision 1 of the COLR for DNPS Unit 3 operating cycle 18 (D3C18) in accordance with Technical Specifications Section 5.6.5, "CORE OPERATING LIMITS REPORT (COLR)"
The Unit 2 COLR is being issued for reload cycle parameters for operating cycle D2C19. This COLR includes information to add Linear Heat Generation Limit (LHGR) multipliers for Single Loop Operation (SLO) which was not included in previous COLRs. The Unit 2 COLR contains proprietary information of the type that General Electric (GE) maintains in confidence and withholds from public disclosure. The information has been handled and classified as proprietary to GE as indicated in the affidavit included as Attachment A. Exelon Generation Company, LLC (EGC) hereby requests that Attachment B be withheld from public disclosure in accordance with 10 CFR 2.790, "Public inspections, exemptions, requests for withholding," and 10 CFR 9.17, "Agency records exempt from public disclosure." The non-proprietary COLR version is contained in Attachment C to this letter.
The Unit 3 COLR was revised to include modified LHGR limits to account for control blade history on a specific fresh fuel bundle type and to add LHGR multipliers for SLO. The Unit 3 COLR is contained in Attachment D to this letter.
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Should you have any questions concerning this letter, please contact Mr. J. Hansen at (815) 416-2800.
Respectfully,
$11 R.J. Hovey Site Vice President Dresden Nuclear Power Station Attachments: A - GE Proprietary Information Affidavit B - Core Operating Limits Report for Dresden Unit 2 Cycle 19, Revision 0, GNF Proprietary Version C - Core Operating Limits Report for Dresden Unit 2 Cycle 19, Revision 0, GNF Non-Proprietary Version D - Core Operating Limits Report for Dresden Unit 3 Cycle 18, Revision 1 cc: Regional Administrator- NRC Region III NRC Senior Resident Inspector - Dresden Nuclear Power Station
Attachment A GE Proprietary Information Affidavit
- GI-Global Nuclear Fuel A Joint Venture of GE Toshiba. &Hitachi F. Russell Lindquist Global Nuclear Fuel - Americas, LLC Exelon Account Leader Castle Hayne Road, Wilmington, NC 28401 (910) 675.5082, Fax (910) 675-5684 Russell.Lindquist@gnf.com October 16, 2003 FRL-EXN-EB2-03-01 2 Mr. Kevin Donovan Exelon Nuclear 4300 Winfield Way Warrenville, IL 60555
SUBJECT:
Dresden Unit 2 Cycle 19 COLR
REFERENCES:
- 1. Core Operating Limits Report for Dresden Unit 2 Cycle 19, Revision 0.
- 2. "Contract between Exelon and Global Nuclear Fuel for Fuel Fabrication and Related Components and Services for the Quad Cities Nuclear Power Station", October 14 1999, as amended.
Dear Kevin:
Enclosed is the Core Operating Limits Report (COLR), Revision 0 for Dresden Unit 2 Cycle 19, Reference 1.
Please note that the referenced attachment contains Global Nuclear Fuel Proprietary Information contained within the double brackets and should be handled in accordance with Reference 2. Please note that the information denoted as Global Nuclear Fuel Proprietary Information does not conform to the recently agreed upon standard with the additional red highlighting.
In addition, a non-proprietary version is also included.
If you have any questions regarding this information, please contact me.
Sincerely, F. Russell Lindquist Exelon Account Leader fr/enclosures
Affidavit Affidavit I, Margaret E. Harding, state as follows:
(1) I am Manager, Fuel Engineering Services, Global Nuclear Fuel - Americas, L.L.C. ("GNF-A") and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.
(2) The information sought to be withheld is contained in the attachment, "Core Operating Limits Report for Dresden Unit 2: Cycle 19, Revision 0,". GNF proprietary information is indicated by enclosing it in double brackets. In each case, the superscript notation 131 refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.
(3) In making this application for withholding of proprietary information of which it is the owner or licensee, GNF-A relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4) and 2.790(a)(4) for "trade secrets and commercial or financial information obtained from a person and privileged or confidential" (Exemption 4). The material for which exemption from disclosure is here sought is all "confidential commercial information," and some portions also qualify under the narrower definition of "trade secret," within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission. 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA. 704F2d1280 (DC Cir. 1983).
(4) Some examples of categories of information which fit into the definition of proprietary information are:
- a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where pr vention of its use by GNF-A's competitors without license from GNF-A constitutes a competitive economic advantage over other companies;
- b. Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;
- c. Information which reveals cost or price information, production capacities, budget levels, or commercial strategies of GNF-A, its customers, or its suppliers;
- d. Information which reveals aspects of past, present, or future GNF-A customer-funded development plans and programs, of potential commercial value to GNF-A;
- e. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.
Affidavit The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b., above.
(5) To address the 10 CFR 2.790 (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 GNF-A, and is in fact so held. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in (6) and (7) following. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GNF-A, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence.
(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or subject to the terms under which it was licensed to GNF-A. Access to such documents within GNF-A is limited on a "need to know" basis.
(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, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GNF-A 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 agreements.
(8) The information identified in paragraph (2) is classified as proprietary because it contains details of GNF-A's fuel design and licensing methodology.
The development of the methods used in these analyses, along with the testing, development and approval of the supporting methodology was achieved at a significant cost, on the order of several million dollars, to GNF-A or its licensor.
(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GNF-A's competitive position and foreclose or reduce the availability of profit-making opportunities. The fuel design and licensing methodology is part of GNF-A's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost.
The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evalua:ion process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.
The research, development, engineering, ar.alytical, and NRC review costs comprise a substantial investment of time and money by GNF-A or its licensor.
Affidavit The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.
GNF-A's competitive advantage will be lost if its competitors are able to use the results of the GNF-A experience to normali ze or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusion;.
The value of this information to GNF-A would be lost if the information were.
disclosed to the public. Making such inforration available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide-competitors with a windfall, and deprive GNF-A of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable, analytical tools.
I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.
Executed at Wilmington, North Carolina, this I6th day of October, 2003.
Margaret E. Harding Global Nuclear Fuel - AmericasC
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