ML081780682

Request for Withholding of Commercial Document, Analysis & Evaluation of St. Lucie Unit 1 Natural Circulation Cooldown, Nsac 16.

ML081780682
Person / Time
Site:	Saint Lucie, PROJ0669
Issue date:	06/23/2008
From:	Larsen C Electric Power Research Institute
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML081780682 (4)

Text

• ._I[211ELECTRIC POWER RESEARCH INSTITUTE CHRISTIAN B. LARSEN Vice President and Chief Nuclear Officer June 23, 2008 t j *O (o9 Document Control Desk Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Request for Withholding of the Following Commercial Document:

"Analysis & Evaluation of St. Lucie Unit 1 Natural Circulation Cooldown, NSAC 16 To Whom It May Concern:

This is a request under 10 C.F.R. §2.390(a)(4) that the U.S:, Nuclear Regulatory Commission

("NRC") withhold from public disclosure the information identified in the enclosed Affidavit consisting of the commercial information owned by Electric Power Research Institute, Inc.

("EPRI") identified above (the "Report"). Copies of the Report and the Affidavit in support of this request are enclosed.

EPRI desires to disclose the Report in confidence as requested by the NRC. The Report is not to be divulged to anyone outside of the NRC nor shall any copies be made of the Report provided herein. EPRI welcomes any discussions and/or questions relating to the information enclosed.

If you have any questions about the legal aspects of this request for withholding, please do not hesitate to contact me at (650) 855-2329. Questions on the content of the Report should be directed to Frank Rahn of EPRI at (650) 855-2037.

Sincerely, Together ... Shaping the Future of Electricity 3420 Hillview Avenue, Palo Alto, CA 94304-1338 USA e 650.855.2329

• Fax 650.855.8759 . cblarsen@epri.com

mELECTRIC POWER RESEARCH INSTITUTE AFFIDAVIT RE: Request for Withholding of the Following Commercial Document:

"Analysis & Evaluation of St. Lucie Unit 1 Natural Circulation Cooldown, NSAC 16 I, CHRISTIAN B. LARSEN, being duly sworn, depose and state as follows:

I am a Vice President and the Chief Nuclear Officer of Electric Power Research Institute, Inc. whose principal office is located at 3420 Hillview Avenue, Palo Alto, California ("EPRI")

and I have been specifically delegated responsibility for the above-listed Report that is sought under this Affidavit to be withheld (the "Re-port"). I am authorized to apply to the U.S. Nuclear Regulatory Commission ("NRC") for the withholding of the Report on behalf of EPRI.

EPRI requests that the Report be withheld from the public on the following bases:

Withholding Based Upon Privileged And Confidential Trade Secrets Or Commercial Or Financial Information:

a. The Report is owned by EPRI and constitutes commercial information which has not been placed in the public domain by EPRI.

b. EPRI made a substantial economic investment to develop the Report and, by prohibiting public disclosure, EPRI derives an economic benefit in the form of fees charged for the sale of the Report. The Report is entitled to the protection of the United States copyright laws. If the Report was publicly available to consultants and/or other businesses providing services in the electric and/or nuclear power industry at no cost, these entities would be able to use the Report for their own commercial benefit and profit and without expending the substantial economic resources required of EPRI to develop the Report.

c. EPRI made a substantial investment of both money and employee hours over an extended period of time in the development of the Report. As a result of such effort and cost, both in terms of dollars spent and dedicated employee time, the Report is highly valuable to EPRI.

d. A public disclosure of the Report would be highly likely to cause substantial harm to EPRI's competitive position and the ability of EPRI to sell the Report both domestically and internationally. If a party does not purchase the Report from EPRI, it would require an investment of money, time and effort equivalent to that expended by EPRI for the party to duplicate the Report.

I have read the foregoing and the matters stated herein are true and correct to the best of my knowledge, information and belief. I make this affidavit under penalty of perjury under the laws of the United States of America and under the laws of the State of California.

Executed at 3420 Hillview Avenue, Palo Alto, California being the premises and place of business of Electric Power Research Institute, Inc.

June 23, 2008 Christian B. Larsen Subscribed and sworn before me this day: June 23, 2008

_ _ _ _otary Public

CALIFORNIA JURAT WITH AFFIANT STATEMENT k] See Attached Document (Notary to cross out lines 1-6 below)

ED See Statement Below (Lines 1-5 to be completed only by document signer[s], not Notary) 3 4

6 Signature of Document Signer No. 1 Signature of Document Signer No. 2 (if any)

State of Californi County of 7-, . LF-_

Subscribed and sworn to (or affirmed) before me on this

&--_,)day of 20_<a&, by Date Month Year (1) t'J** / $ /,-d ,,J L

• r 'e ,,, ,j Name 6f Signer proved to me on the basis of satisfactory evidence to be the person who appeared before me (.) ..

Commbslon 0171329 (and eanto Ckmv County (2). Name o~i3 gn er proved to me on the basis of satisfactory evidence to be the person who appeared before me Signature -'S Z. .- Pu

-r l Place Notary Seal Above OPTIONAL Though the information below is not required by law, it may prove valuable to persons relying on the document and could prevent RIHTHUBPIN RIH THMPRN fraudulent removal and reattachment of this form to another document.

Further Description of Any Attached Document Title or Type of Document: 42 & ---' 4 .Al Document Date: / IA) /e"* Number of Pages: - .-

Signer(s) Other Than Named Above:

National Notary Association- 9350 De Soto Ave., P.O.Box 2402 -chatsworth, CA 91313-2402.www.NationaiNotary.org 2@207 Item#5910 Reorder: Call Toll-Free 1-800-876-6827