ML18046A997
| ML18046A997 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/22/1981 |
| From: | Johnson B CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML18046A998 | List: |
| References | |
| NUDOCS 8110280239 | |
| Download: ML18046A997 (5) | |
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consumers Power company General Offices: 212 West Michigan Avenue, Jackson, Ml 49201 * (517) 788-0550 October 22, 1981 Director, Nuclear Reactor Regulation Att Mr Dennis M Crutchfield, Chief Operating Reactors Branch No 5 US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 -
LICENSE DPR PALISADES PLANT -
SUBMITTAL OF PR9PRIETARX )::QPY OF THE EXXON NUCL~ CORP. REPORT XN-NF-79-61~ "SUPPLEMENTARY SAFETY ANALYSIS REPORT, PALISADES GADOLINIA DEMONSTRATION PROGRAM, CYCLE.4 11
- Consumers Power Company submitta.1L dat.ed July 21, 1981 r~ferenced Exxon Report XN-NF-79-61.
As attachment 1 to this let~er, the. proprietary versfon of Exxon Report XN-NF-79-61* entitled "Supplementary Safety Analysis Report, Palisades Gadolinia Demonstration Program, Cycle 4" is enclosed.
This report.contains information which is proprietary. to Exxon Nuclear Corp. and is exempt from disclosure under Section. 2. 7*9o(a) (4) of the NRC Rules of Practice, Part 2,.
Title 10, Code of Federal Regulations. It is therefore requested.that attachment 1 be withheld from public disclosure.
Brian D Johnson Senior Licensing Engineer CC JGKeppler, USNRC NRC Resident Inspector-Palisades Attachment
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STATE OF.Washingt~n)
COUNTY OF Benton SS.
A F F I D A V I T I, James N. Morgan, being duly s~orn;*hereby say and depose:
- 1.
I am* Manager, Licensing and Safety Engineeril')g, for Exxon Nuclear Compa!ly, Inc., (
11 ENC 11 ) and* as such I am authorjz~d to execute this Affidavit.
- 2.
I am familiar with ENC's detailed document control system and policies which govern the protection and control of information.
- 3.
I am familiar with the document XN-NF-79-6l(P), entitled
__.. ~~--
11Suppiementary Safety Analysis Report - Palisades Gadolinia Demonstration Program, Cycle 4, 11 referred to as 11Document 11
- Information contained in this Document has been classified by ENC as proprietary in accordance with the control system and policies established by ENC for the control and protection of inf ormat,ion.
- 4.
Th~ Document contains information of a proprietary and con-fidential nature and is of the type customarily held in confidence by ENC and not made available to the _public.. Based on my experience, I am aware that other companies regard information of the kind contained in the Document as.
being proprietary and confidential.
- 5.
The Document has been made available to the United States Nuclear Regulatory Commission in confidence, with the request that t~e information contained in the Document not be disclosed or divulged.
- 6.
The Document contains. information which is vital to a com-petitive advantage of ENC an~-~~~- be helpful to competitors of ENC when
_...;:.;,.:---competing with ENC.
- 7.
The information cont~ined'in the Document is considered to be
.Proprietary by ENC because it reveals certain distinguishing aspects of fuel properties and operating characteristics which secure competitive ~conomic advantage to ENC for,fuel design optimi~atiori and improved marketability, and includes information utilize~ _by ENC in its bus_iness which affords ENC an
~
opportun~ty to obtain a competitive advantage o~er it~ competitors who do not or may not.know or use the information contained in the Document.
- 8.
The disclosure of the proprietary information contained in the.
Document to a competitor would permit the compe~itor to redu~e it~ expenditure of money and manpower and to improve its*competitive position by giving it
. I extremely valuable insights into.fuel properties and operating.character-istic~~ and would result.in substantial harm to the competitive position of ENC.
- 9.
The Document contains proprietary information which is held in confidence by ENC and is -not available fn public sources.
10..
In accordance with ENC's policies governing the protection and control of information~ ~roprietary information contained in the Do~ument has been made available, on a limited basis, to others outside ENC only as required-and under suitable agreement providing for non-disclosure and limited use of the information.
- 11.
ENC_policy requires that pr~prietary information be kept in a secured file or area and distributed on a need-to-know basis.
e* 12.
This Document provides information which revea_ls fuel properties and operating characteristics developed by ENC over the,_past
~everal year~.
ENC has invested hundreds of thousands of dollars and many man-years of effort in obtaining the fuel properties informatio~ and developing the methodology for use in designing fuel. Assuming a competitor had available the same background data and incentives as ENC, the competitor might,* at a minimum, develop the information for.,the same expenditure of
- manpower and money as ENC.
- 13.
Based on my experience in the industry, I do not be'l ieve that the background datii and incentives of ENC's competitors are sufficiently similar to_the corresponding-background data and incentives of ENC to reasonably expect such competitors would be. in a position to duplicate ENC's proprietary information contained in the Document.
THAT the statements made hereinabove are, to the best of my knowledge, *information, and belief, truthful and complete.
FURTHER AFFIANT SAYETH NOT.
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