Similar Documents at Cook |
---|
Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217J4721999-10-15015 October 1999 Forwards NRC Physical Security Insp Repts 50-315/99-27 & 50-316/99-27 on 990920-24.Two Violations Noted & Being Treated as Ncvs,Consistent with App C of Enforcement Policy. Areas Examined Exempt from Disclosure,Per 10CFR73.21 IA-99-379, First Final Response to FOIA Request for Documents.Documents Listed in App a Being Released in Entirety1999-10-0808 October 1999 First Final Response to FOIA Request for Documents.Documents Listed in App a Being Released in Entirety ML20217D9241999-10-0808 October 1999 First Final Response to FOIA Request for Documents.Documents Listed in App a Being Released in Entirety ML17335A5511999-10-0707 October 1999 Forwards LER 99-023-00, Inadequate TS Surveillance Testing of ESW Pump ESF Response Time. Commitments Identified in LER Listed ML20217D9361999-09-30030 September 1999 FOIA Request for Document Re Section 9.7 of SE by Directorate of Licensing,Us Ae Commission in Matter of Indiana & Michigan Electric Co & Indiana & Michigan Power Co,Dc Cook Nuclear Plan,Units 1 & 2 ML17326A1541999-09-20020 September 1999 Provides Notification of Change in Senior Licensed Operator Status.Operating Licenses for CR Smith,License SOP-30159-4 & Tw Welch,License SOP-30654-2 Are No Longer Required & Should Be Withdrawn ML17326A1441999-09-17017 September 1999 Submits Trace on Second Shipment of Two Plant,Unit 2 Steam Generators.Info Re Shipment Submitted ML17326A1261999-09-17017 September 1999 Forwards LER 99-022-00 Re Electrical Bus Degraded Voltage Setpoints Too Low for Safety Related Loads.Listed Commitment Identified in Submittal ML17326A1531999-09-16016 September 1999 Submits Info Pertaining to Plant Proposed Operator Licensing Exam Requirements Through Yr 2003.NRC Form 536, Operator Licensing Exam Data, Which Provides Required Info Encl ML17326A1101999-08-27027 August 1999 Forwards LER 99-021-00, GL 96-01 Test Requirements Not Met in Surveillance Tests. List of Commitments Identified in LER Provided ML17326A0991999-08-26026 August 1999 Forwards LER 99-020-00,re EDGs Being Declared Inoperable. Commitments Made by Util Are Listed ML17326A1221999-08-23023 August 1999 Forwards Revised Page 2 to 1998 Annual Environ Operating Rept, for DC Cook Nuclear Plant,Correcting Omission to App I ML17326A0981999-08-23023 August 1999 Forwards fitness-for-duty Program Performance Data for Period of 990101-0630 for DC Cook Nuclear Plants,Units 1 & 2,per 10CFR26.71(d) ML17326A0891999-08-16016 August 1999 Forwards LER 99-019-00,re Victoreen Containment High Range Monitors Not Beign Environmentally Qualified to Withstand post-LOCA Conditions.Commitments Made by Util Are Listed ML17326A0811999-08-10010 August 1999 Notifies NRC of Changes in Commitments Made in Response to GL 98-01,supplement 1, Yr 2000 Readiness of Computer Sys Ar Npps, Dtd 990623 ML17326A0821999-08-0606 August 1999 Informs That Util Is Submitting Encl Scope & Objectives for 991026 DC Cook Nuclear Plant Emergency Plan Exercise to G Shear of NRC Plant Support Branch.Exercise Will Include Full State & County Participation ML17326A1451999-08-0404 August 1999 Requests Withholding of WCAP-15246, Control Rod Insertion Following Cold Leg Lbloca. ML17326A0751999-08-0404 August 1999 Forwards LER 98-029-01, Fuel Handling Area Ventilation Sys Inoperable Due to Original Design Deficiency. Supplemental Rept Represents Extensive Rev to Original LER & Replaces Rept in Entirely.Commitment Listed ML17326A0721999-07-29029 July 1999 Forwards LER 99-018-00 Re Refueling Water Storage Tank Suction Motor Operated Valves Inoperable,Due to Inadequate Design.Listed Commitments Were Identified in LER ML17326A0711999-07-27027 July 1999 Responds to 980123 RAI Re NRC GL 87-02, Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors,Unresolved Safety Issue (USI) A-46. ML17326A0601999-07-22022 July 1999 Forwards UFSAR, IAW 10CFR50.71(e) & Rept of Changes,Tests & Experiments as Required by 10CFR50.59(b)(2) for DC Cook Nuclear Plant,Units 1 & 2.Without UFSAR ML17326A0631999-07-22022 July 1999 Forwards LER 98-014-03, Response to High-High Containment Pressure Procedure Not Consistent with Analysis of Record. Revised Info Marked by Sidebars in Right Hand Margin. Commitments Made by Util,Listed ML17326A0311999-07-0101 July 1999 Forwards LER 99-004-01 Re Failure to Perform TS Surveillance Analyses of Reactor Coolant Chemistry with Fuel Removed. Commitments Made by Util Are Listed ML20196K5961999-06-30030 June 1999 Ltr Contract:Task Order 40, DC Cook Extended Sys Regulatory Review Oversight Insp, Under Contract NRC-03-98-021 ML17326A0281999-06-28028 June 1999 Provides Response to 981116 & 960228 RAIs Re GL 92-01. Revised Pressurized Thermal Shock Evaluation Based on New Weld Chemistry Info & Copy of W Rept WCAP-15074, Evaluation of 1P3571 Weld Metal from Surveillance Programs... Encl ML17326A0241999-06-23023 June 1999 Responds to GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants. Y2K Readiness Disclosure for Plant & List of Commitments Encl ML17326A0121999-06-18018 June 1999 Forwards LER 99-014-00 Re Requirement of TS 4.0.5 Not Met for Boron Injection Tank Bolting.Commitments Identified in Submittal Listed ML17326A0111999-06-11011 June 1999 Provides Response to NRC RAI Re GL 97-01, Degradation of Crdm/Cedm Nozzle & Other Vessel Closure Head Penetrations. ML17325B6281999-06-0101 June 1999 Forwards LER 99-S03-00,re Nonconforming Vital Area Barriers.Commitments Made by Util Are Listed ML17325B6401999-06-0101 June 1999 Forwards LER 99-013-00 Re Safety Injection & Centrifugal Charging Throttle Valve Cavitation During LOCA Could Lead to ECCS Pump Failure.Listed Commitments Identified in Submittal ML17325B6331999-05-28028 May 1999 Forwards LER 99-S02-00,re Vulnerability in Safeguard Sys That Could Allow Unauthorized or Undetected Access to Protected Area.Commitments Made by Util Are Listed ML17265A8201999-05-24024 May 1999 Forwards LER 98-037-01,representing Extensive Rev to Original LER & Replacing Rept in Entirety.Listed Commitments Identified in Submittal ML20207A9201999-05-21021 May 1999 Ack Receipt of 990319 Response to Notice of Violation & Proposed Imposition of Civil Penalty .On 981124, Licensee Remitted Check for Payment of Civil Penalties. Licensee Requests for Extension for Response,Granted ML17325B6111999-05-21021 May 1999 Forwards Annual Radioactive Effluent Release Rept for 980101-1231 for DC Cook Nuclear Plant,Units 1 & 2. Transmittal of Submittal Was Delayed Due to Administrative Error in Regulatory Affairs Dept ML17325B6031999-05-21021 May 1999 Provides Response to NRC GL 98-04, Potential for Degradation of ECCS & Containment Spray Sys After LOCA Because of Const & Protective Coating Deficiencies & Foreign Matl in Containment. ML17325B5971999-05-20020 May 1999 Forwards LER 99-012-00,re Auxiliary Building ESF Ventilation Sys Not Being Capable of Maintaining ESF Room Temps post-accident.Commitment,listed ML17335A5281999-05-12012 May 1999 Forwards DC Cook Nuclear Plant Fitness for Duty Program Performance Dtd for six-month Period of 980701-1231,IAW 10CFR26.71(d).Info Was Delayed Due to Administrative Error in Regulatory Affairs Dept ML17335A5271999-05-11011 May 1999 Forwards Details Re Sources & Levels of Insurance Maintained for DC Cook,Units 1 & 2,as of 990401,per 10CFR50.54(w)(3). Info Was Delayed Beyond Required Date Due to Internal Oversight ML17325B5841999-05-10010 May 1999 Forwards LER 99-002-00 Re TS 4.0.5 Requirements Not Being Met Due to Improperly Performed Test.Commitments Identified in Ler,Listed ML17325B5871999-05-0707 May 1999 Forwards Current Revs of Expanded Sys Readiness Review (Essr) Implementing Procedures,For Info Purposes to Support Current NRC Insps.Current Esrr Schedule Provided for Info Purposes,Reflecting Revised Target Dates ML17325B5791999-05-0404 May 1999 Forwards LER 99-011-00,concerning Air Sys for EDG Not Supporting Long Term Operability.Commitments Made by Util Listed ML17325B5821999-05-0404 May 1999 Provides Addl Background,Description & Clarification of Previous & Revised Commitments Re UFSAR Revalidation Effort. Commitment Change Involved Alignment of UFSAR Revalidation Program Methodology to Strategy Contained in Current Plan ML17325B5741999-05-0303 May 1999 Forwards LER 99-010-00 Re RCS Leak Detection Sys Sensitivity Not in Accoradnce with Design Requirements.Listed Commitments Identified in Submittal ML17325B5631999-04-22022 April 1999 Forwards Results of Independent Chemical Evaluations Performed from Sept 1997 Through Feb 1999,re Resolution of Issues Related to License Amend 227 ML17325B5561999-04-16016 April 1999 Forwards LER 99-006-00, Fuel Crane Loads Lifted Over SFP Could Impact Energies Greater than TS Limits, IAW 10CFR50.73.Submittal Was Delayed to Allow for Resolution of Questions.Commitment Made by Licensee,Listed ML20205P0591999-04-14014 April 1999 Ninth Partial Response to FOIA Request for Documents.App Records Already Available in Pdr.Records in App T Encl & Being Made Available in Pdr.App U Records Being Released in Part (Ref FOIA Exemption 7).App V Records Withheld Entirely ML17325B5451999-04-12012 April 1999 Forwards LER 99-009-00 Re as-found RHR Safety Relief Valve Lift Setpoint Greater than TS Limit.Commitments Identified in Submittal Listed ML17325B5301999-04-0707 April 1999 Forwards LER 99-S01-01, Vulnerability in Locking Mechanism of Four Vital Area Gates, Per 10CFR50.73.Commitments Made by Util,Listed ML17325B5241999-04-0505 April 1999 Forwards Revs 0 & 1 to Cook Nuclear Plant Restart Plan, Dtd 980307 & 0407.Rev 5 Is Current Cook Nuclear Plant Restart & Supercedes Previous Revs in All Respects ML17325B5121999-04-0101 April 1999 Forwards LER 99-007-00, Calculations Show That Divider Barrier Between Upper & Lower Containment Vols May Be Overstressed. Commitments Made by Util Are Listed 1999-09-30
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML17335A5511999-10-0707 October 1999 Forwards LER 99-023-00, Inadequate TS Surveillance Testing of ESW Pump ESF Response Time. Commitments Identified in LER Listed ML20217D9361999-09-30030 September 1999 FOIA Request for Document Re Section 9.7 of SE by Directorate of Licensing,Us Ae Commission in Matter of Indiana & Michigan Electric Co & Indiana & Michigan Power Co,Dc Cook Nuclear Plan,Units 1 & 2 ML17326A1541999-09-20020 September 1999 Provides Notification of Change in Senior Licensed Operator Status.Operating Licenses for CR Smith,License SOP-30159-4 & Tw Welch,License SOP-30654-2 Are No Longer Required & Should Be Withdrawn ML17326A1261999-09-17017 September 1999 Forwards LER 99-022-00 Re Electrical Bus Degraded Voltage Setpoints Too Low for Safety Related Loads.Listed Commitment Identified in Submittal ML17326A1441999-09-17017 September 1999 Submits Trace on Second Shipment of Two Plant,Unit 2 Steam Generators.Info Re Shipment Submitted ML17326A1531999-09-16016 September 1999 Submits Info Pertaining to Plant Proposed Operator Licensing Exam Requirements Through Yr 2003.NRC Form 536, Operator Licensing Exam Data, Which Provides Required Info Encl ML17326A1101999-08-27027 August 1999 Forwards LER 99-021-00, GL 96-01 Test Requirements Not Met in Surveillance Tests. List of Commitments Identified in LER Provided ML17326A0991999-08-26026 August 1999 Forwards LER 99-020-00,re EDGs Being Declared Inoperable. Commitments Made by Util Are Listed ML17326A1221999-08-23023 August 1999 Forwards Revised Page 2 to 1998 Annual Environ Operating Rept, for DC Cook Nuclear Plant,Correcting Omission to App I ML17326A0981999-08-23023 August 1999 Forwards fitness-for-duty Program Performance Data for Period of 990101-0630 for DC Cook Nuclear Plants,Units 1 & 2,per 10CFR26.71(d) ML17326A0891999-08-16016 August 1999 Forwards LER 99-019-00,re Victoreen Containment High Range Monitors Not Beign Environmentally Qualified to Withstand post-LOCA Conditions.Commitments Made by Util Are Listed ML17326A0811999-08-10010 August 1999 Notifies NRC of Changes in Commitments Made in Response to GL 98-01,supplement 1, Yr 2000 Readiness of Computer Sys Ar Npps, Dtd 990623 ML17326A0821999-08-0606 August 1999 Informs That Util Is Submitting Encl Scope & Objectives for 991026 DC Cook Nuclear Plant Emergency Plan Exercise to G Shear of NRC Plant Support Branch.Exercise Will Include Full State & County Participation ML17326A1451999-08-0404 August 1999 Requests Withholding of WCAP-15246, Control Rod Insertion Following Cold Leg Lbloca. ML17326A0751999-08-0404 August 1999 Forwards LER 98-029-01, Fuel Handling Area Ventilation Sys Inoperable Due to Original Design Deficiency. Supplemental Rept Represents Extensive Rev to Original LER & Replaces Rept in Entirely.Commitment Listed ML17326A0721999-07-29029 July 1999 Forwards LER 99-018-00 Re Refueling Water Storage Tank Suction Motor Operated Valves Inoperable,Due to Inadequate Design.Listed Commitments Were Identified in LER ML17326A0711999-07-27027 July 1999 Responds to 980123 RAI Re NRC GL 87-02, Verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors,Unresolved Safety Issue (USI) A-46. ML17326A0601999-07-22022 July 1999 Forwards UFSAR, IAW 10CFR50.71(e) & Rept of Changes,Tests & Experiments as Required by 10CFR50.59(b)(2) for DC Cook Nuclear Plant,Units 1 & 2.Without UFSAR ML17326A0631999-07-22022 July 1999 Forwards LER 98-014-03, Response to High-High Containment Pressure Procedure Not Consistent with Analysis of Record. Revised Info Marked by Sidebars in Right Hand Margin. Commitments Made by Util,Listed ML17326A0311999-07-0101 July 1999 Forwards LER 99-004-01 Re Failure to Perform TS Surveillance Analyses of Reactor Coolant Chemistry with Fuel Removed. Commitments Made by Util Are Listed ML17326A0281999-06-28028 June 1999 Provides Response to 981116 & 960228 RAIs Re GL 92-01. Revised Pressurized Thermal Shock Evaluation Based on New Weld Chemistry Info & Copy of W Rept WCAP-15074, Evaluation of 1P3571 Weld Metal from Surveillance Programs... Encl ML17326A0241999-06-23023 June 1999 Responds to GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants. Y2K Readiness Disclosure for Plant & List of Commitments Encl ML17326A0121999-06-18018 June 1999 Forwards LER 99-014-00 Re Requirement of TS 4.0.5 Not Met for Boron Injection Tank Bolting.Commitments Identified in Submittal Listed ML17326A0111999-06-11011 June 1999 Provides Response to NRC RAI Re GL 97-01, Degradation of Crdm/Cedm Nozzle & Other Vessel Closure Head Penetrations. ML17325B6401999-06-0101 June 1999 Forwards LER 99-013-00 Re Safety Injection & Centrifugal Charging Throttle Valve Cavitation During LOCA Could Lead to ECCS Pump Failure.Listed Commitments Identified in Submittal ML17325B6281999-06-0101 June 1999 Forwards LER 99-S03-00,re Nonconforming Vital Area Barriers.Commitments Made by Util Are Listed ML17325B6331999-05-28028 May 1999 Forwards LER 99-S02-00,re Vulnerability in Safeguard Sys That Could Allow Unauthorized or Undetected Access to Protected Area.Commitments Made by Util Are Listed ML17265A8201999-05-24024 May 1999 Forwards LER 98-037-01,representing Extensive Rev to Original LER & Replacing Rept in Entirety.Listed Commitments Identified in Submittal ML17325B6111999-05-21021 May 1999 Forwards Annual Radioactive Effluent Release Rept for 980101-1231 for DC Cook Nuclear Plant,Units 1 & 2. Transmittal of Submittal Was Delayed Due to Administrative Error in Regulatory Affairs Dept ML17325B6031999-05-21021 May 1999 Provides Response to NRC GL 98-04, Potential for Degradation of ECCS & Containment Spray Sys After LOCA Because of Const & Protective Coating Deficiencies & Foreign Matl in Containment. ML17325B5971999-05-20020 May 1999 Forwards LER 99-012-00,re Auxiliary Building ESF Ventilation Sys Not Being Capable of Maintaining ESF Room Temps post-accident.Commitment,listed ML17335A5281999-05-12012 May 1999 Forwards DC Cook Nuclear Plant Fitness for Duty Program Performance Dtd for six-month Period of 980701-1231,IAW 10CFR26.71(d).Info Was Delayed Due to Administrative Error in Regulatory Affairs Dept ML17335A5271999-05-11011 May 1999 Forwards Details Re Sources & Levels of Insurance Maintained for DC Cook,Units 1 & 2,as of 990401,per 10CFR50.54(w)(3). Info Was Delayed Beyond Required Date Due to Internal Oversight ML17325B5841999-05-10010 May 1999 Forwards LER 99-002-00 Re TS 4.0.5 Requirements Not Being Met Due to Improperly Performed Test.Commitments Identified in Ler,Listed ML17325B5871999-05-0707 May 1999 Forwards Current Revs of Expanded Sys Readiness Review (Essr) Implementing Procedures,For Info Purposes to Support Current NRC Insps.Current Esrr Schedule Provided for Info Purposes,Reflecting Revised Target Dates ML17325B5821999-05-0404 May 1999 Provides Addl Background,Description & Clarification of Previous & Revised Commitments Re UFSAR Revalidation Effort. Commitment Change Involved Alignment of UFSAR Revalidation Program Methodology to Strategy Contained in Current Plan ML17325B5791999-05-0404 May 1999 Forwards LER 99-011-00,concerning Air Sys for EDG Not Supporting Long Term Operability.Commitments Made by Util Listed ML17325B5741999-05-0303 May 1999 Forwards LER 99-010-00 Re RCS Leak Detection Sys Sensitivity Not in Accoradnce with Design Requirements.Listed Commitments Identified in Submittal ML17325B5631999-04-22022 April 1999 Forwards Results of Independent Chemical Evaluations Performed from Sept 1997 Through Feb 1999,re Resolution of Issues Related to License Amend 227 ML17325B5561999-04-16016 April 1999 Forwards LER 99-006-00, Fuel Crane Loads Lifted Over SFP Could Impact Energies Greater than TS Limits, IAW 10CFR50.73.Submittal Was Delayed to Allow for Resolution of Questions.Commitment Made by Licensee,Listed ML17325B5451999-04-12012 April 1999 Forwards LER 99-009-00 Re as-found RHR Safety Relief Valve Lift Setpoint Greater than TS Limit.Commitments Identified in Submittal Listed ML17325B5301999-04-0707 April 1999 Forwards LER 99-S01-01, Vulnerability in Locking Mechanism of Four Vital Area Gates, Per 10CFR50.73.Commitments Made by Util,Listed ML17325B5241999-04-0505 April 1999 Forwards Revs 0 & 1 to Cook Nuclear Plant Restart Plan, Dtd 980307 & 0407.Rev 5 Is Current Cook Nuclear Plant Restart & Supercedes Previous Revs in All Respects ML17325B5121999-04-0101 April 1999 Forwards LER 99-007-00, Calculations Show That Divider Barrier Between Upper & Lower Containment Vols May Be Overstressed. Commitments Made by Util Are Listed ML17325B5141999-03-30030 March 1999 Forwards Rept on Status of Decommissioning Funding.Attached Rept Includes Amount of Decommissioning Funds Estimated to Be Required Pursuant to 10CFR50.75(b) & (C) ML17325B5191999-03-29029 March 1999 Forwards LER 99-001-00,re Degraded Component Cw Flow to Containment Main Steam Line Penetrations.Commitment, Listed ML20204F6401999-03-19019 March 1999 Responds to NRC 981013 NOV & Proposed Imposition of Civil Penalty.Violations Cited in Subject NOV Were Initially Identified in Referenced Five Insp Repts.Corrective Actions: Ice Condensers Have Been Completely Thawed of Any Blockage ML17325B4751999-03-18018 March 1999 Forwards LER 99-004-00,re Failure to Perform TS Surveillance Analyses of Reactor Coolant Chemistry with Fuel Removed. Commitment Made by Util,Listed ML17325B4721999-03-18018 March 1999 Forwards LER 99-005-00,re Reactor Trip Breaker Manual Actuations During Rod Drop Testing Not Previously Reported. Listed Commitments Identified in Submittal ML17325B4641999-03-17017 March 1999 Withdraws Response to Issue 1 of NRC Cal,Dtd 970919. Comprehensive Design Review Effort in Progress to Validate Resolution of Issue for Future Operation 1999-09-30
[Table view] |
Text
2060 Fairfax Avenue, Cher Hill, NJ 08003-1666 HOLTEC Telephone 609424-0999 Telex 91 0-240-6663 Telefax 609424-171 0 18 March 1992 Dr. Thomas Murley, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 APPLICATION FOR WITHHOLDINGPROPRIETARY INFORMATIONFROM PUBLIC DISCLOSURE
Subject:
Application for Reracking of the Donald C. Cook Spent Fuel Pool
Dear Dr. Murley:
The proprietary information for which withholding is being requested by Indiana Michigan Power Company is further identified in an affidavit signed by the Owner of the proprietary information, Holtec International. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10CFR Section 2.790 of the Commission's regulations.
Accordingly, this letter authorizes the utilization of the accompanying affidavit by Indiana Michigan Power Company.
Correspondence with respect to the proprietary aspects of the application for withholding or the Holtec International affidavit should reference this letter and should be addressed to the undersigned.
Very truly yours, K.P. Singh President Enclosures 9204060138 920401 PDR ADOCK 05000315 P PDR
HOLTEC AFFIDAVIT STATE OF NEW JERSEY SS COUNTY OF CAMDEN Before me, the undersigned authority, personally appeared Krishna P. Singh, who, being by me duly sworn according to law, depose and says that he is authorized to execute this Affidavit on behalf of Holtec International ("Holtec") and that the averments of fact set forth in. this Affidavit are true and correct to the best of his knowledge, information and belief:
Krishna P. Singh President Sworn to and subscribed before me this /P + day of r - .1992 c~d'
';iMotiry Public 1
v'ARIA O. PEP E NOTARY PUBUC OF NEW JERSEY Page 1 of 5 My Con&sshn Exptres AprII 1y, ~995
,)(
C
,)
4
'-'"'" 3 DAM+"'i Y2PR N'Ll)ZOO,'4Y>> rUOA C":.".F,Tt f~ "%c.. ,pent .'.". -;cQy",4
H 0 LTEC (1) I am President of Holtec International and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing or rule-making proceedings, and am authorized to apply for its withholding on behalf of Holtec International. The information for which protection from public disclosure is being requested is identified as follows:
(a) Holtec Drawing 666 (b) Holtec Drawing 667 (c) Holtec Drawing 668 (d) Holtec Drawing 669 (e) Holtec Report HI-87161, "DYNARACKValidation Manual".
(f) Holtec Report HI-88243, "Fluid Coupling in Fuel Racks Correlation of Theory and Experiment".
(2) I am making this Affidavit in conformance with the provisions of 10CFR Section 2,790 of the Commission's regulations and in conjunction with the Holtec application for withholding accompanying his Affidavit.
(3) I have personal knowledge of the criteria and procedures utilized by Holtec in designating information as a trade secret, privileged or as confidential commercial or Qnancial information, (4) Pursuant to the provisions of paragraph (b)(4) of Section 2.790 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.
The information sought to be withheld from public disclosure is owned and has been held in confidence by Holtec.
The information is of a type customarily held in confidence by Holtec and not customarily disclosed to the public. Holtec has a rational basis for determining the types of information customarily held in confidence by it and in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence.
The application of that system and the substance of that system constitutes Holtec policy and provides the rational basis required.
Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:
Page 2 of 5
0 I
HO LTEC I N T E R N A T I 0 N A L (a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Holtec's competitors without license from Holtec constitutes a competitive economic advantage over other companies.
(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc,), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.
(c) Its use 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 a similar product.
(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Holtec, its customers or suppliers.
(e) It reveals aspects of past, present, or future Holtec or customer funded development plans and programs of potential commercial value to Holtec.
(f) It contains patentable ideas, for which patent protection may be desirable.
(g) It is not the property of Holtec, but must be treated as proprietary by Holtec according to agreements with the Owner.
There are sound policy reasons behind the Holtec system which include the following:
(a) The use of such information by Holtec gives Holtec a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Holtec competitive position.
(b) It is information which is marketable in many ways. The extent to which such information is available to competitors diminishes the Holtec ability to sell products and services involving the use of the information.
Page 3 of 5
~.
HOLTEC (c) Use by our competitor would put Holtec at a competitive disadvantage by reducing his expenditure of resources at our expense.
(d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Holtec of a competitive advantage.
(e) Unrestricted disclosure would jeopardize the position of prominence of Holtec in the world market, and thereby give a market advantage to the competition in those countries.
(f) The Holtec capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.
(g) The Information being provided is at the heart of Holtec's key business activity which provides over 70% of Holtec's revenue.
Its disclosure to the public will imperil Holtec's financial viability.
The information is being transmitted to the Commission in confidence and, under the provisions of 10CFR Section 2.790, it is to be received in confidence by the Commission.
(iv) The information is not available in public sources to the best of our knowledge and belief.
(v) The proprietary information sought to be withheld in this submittal enables Holtec to:
(a) Justify the Holtec design.
(b) Assist its customers to obtain licenses.
(c) Meet warranties.
(d) Provide greater operational flexibility to customers assuring them of safe and reliable operation.
Page 4 of 5
HOLTEC (e) Justify increased power capability or operating margin for plants while assuring safe and reliable operation.
Further, the information gained from the documents being provided herein is of significant commercial value as follows:
(a) Holtec uses the information to perform and justify analyses which are sold to customers.
(b) Holtec sells analysis services based on the experience gained and the methods developed.
Public disclosure of this information concerning design procedures is likely to cause substantial harm to the competitive position of Holtec because competitors could utilize this information to assess and justify their own designs without commensurate expense.
The analyses performed and documented in the reports represent a considerable amount of highly qualified development effort. This work was contingent upon a design method development program which consumed over 5 years. Altogether, a substantial amount of money and effort has been expended by Holtec which could only be duplicated by a competitor if he were to invest similar sums of money and provided he had the appropriate talent available.
Further the deponent sayeth not.
Page 5 of 5
~~ 4