ML15180A039
| ML15180A039 | |
| Person / Time | |
|---|---|
| Site: | Robinson, Harris  |
| Issue date: | 11/03/2014 |
| From: | Frisco J Duke Energy Corp |
| To: | |
| Barillas M DORL/LPL2-2 301-415-2760 | |
| References | |
| Download: ML15180A039 (2) | |
Text
AFFIDAVIT of Joseph Michael Frisco, Jr.
- 1. I am Acting Senior Vice President of Nuclear Engineering, Duke Energy Corporation, and as such have the responsibility of reviewing the proprietary information sought to be withheld from public disclosure in connection with 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 application for withholding which accompanies this affidavit.
- 3. I have knowledge of the criteria used by Duke Energy in designating information as proprietary or confidential.
- 4. Pursuant to the provisions of paragraph (b) (4) of 10 CFR 2.390, 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 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. The information consists of analysis methodology details, analysis results, supporting data, and aspects of development programs, relative to a method of analysis that provides a competitive advantage to Duke Energy.
(iii) The information was transmitted to the NRC in confidence and under the provisions of 1 O CFR 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 in the presentation material is that which is marked in the proprietary version of the November 12, 2014 NRC presentation DPC-NE-2005 Appendices for Robinson and Harris Nuclear Plants. This information enables Duke Energy to:
Perform future reload design calculations on Robinson and Harris reactor cores.
(vi) The proprietary information sought to be withheld from public disclosure has substantial commercial value to Duke Energy.
(a) Duke Energy uses this information to reduce vendor and consultant expenses associated with supporting the operation and licensing of nuclear power plants.
(b) Duke Energy can sell the information to nuclear utilities, vendors, and consultants for the purpose of supporting the operation and licensing of nuclear power plants.
Page 1of2
( c) The subject information could only be duplicated by competitors at similar expense to that incurred by Duke Energy.
- 5. Public disclosure of this information is likely to cause harm to Duke Energy because it would allow competitors in the nuclear industry to benefit from the results of a significant development program without requiring a commensurate expense or allowing Duke Energy to recoup a portion of its expenditures or benefit from the sale of the information.
Joseph Michael Frisco, Jr. 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.
Subscribed and sworn to me: ___
_ J_)~
......... 0_,__Lf _____ _
/
Date
])ebra ~ee' r Notary Public My commission expires:
.Sep /em her &;;; d-0 IS--
Page 2 of 2