ML18057A591
| ML18057A591 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/16/1990 |
| From: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18057A592 | List: |
| References | |
| NUDOCS 9011270245 | |
| Download: ML18057A591 (4) | |
Text
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consumers Power l'OWERINli MICHlliAN'S l'ROliRESS Palisades Nuclear Plant:
27780 Blue Star Memorial Highway, Covert, Ml 49043 November 16, 1990 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
GB Slade General Manager REQUEST FOR ADDITIONAL INFORMATION - RELOAD M FUEL SEISMIC ANALYSIS
{TAC NO. 08621)
Consumers Power Company (CPC) letter dated August 16, 1990 provided additional information as requested by the July 16, 1990 NRC Telefax.
Part of the information provided was a copy of Advanced Nuclear Fuels Report ANF-88-119-(P), Rev. 1, "Palisades Reload-M Seismic Mechanical Test Description and Results".
Our August 16, 1990 letter committed Consumers Power Company to submit a revised copy of ANF-88-119(P) as soon as CPC had completed review of Revision 2.
CPC comments on Revision 2 have resulted in ANF-88-119(P) Revision 3, a copy of which is enclosed.
Advanced Nuclear Fuels considers the information contained in report ANF 119(P), Revision 3, to be proprietary.
In accordance with the Commission's Regulation 10 CFR 2.790(b), the enclosed affidavit provides necessary information to support withholding of this topical report from public disclosure.
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Gerald B Slade General Manager CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades
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STATE OF WASHINGTON COUNTY OF BENTON SS.
AFFIDAVIT I, R. A. Copeland being duly sworn, hereby say and depose:
- 1.
I am Manager, Reload Licensing, for Advanced Nuclear Fuels Corporation,
("ANF"), and as such I am authorized to execute this Affidavit.
- 2.
I am familiar with ANF's detailed document control system and policies which govern the protection and control of information.
- 3.
I am familiar with the report ANF-88-119(P) Rev. 3, entitled "Palisades Reload M Seismic Mechanical Test Description and Results," referred to as "Document." Information contained in this Document has been classified by ANF as proprietary in accordance with the
- control system and policies established by ANF for the control and protection of information.
- 4.
The Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by ANF 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 proprietary and confidential.
- 5.
The Document has been made available to the U.S. Nuclear Regulatory Commission in confidence, with the request that the information contained in the Document will not be disclosed or divulged.
- 6.
The Document contains information which is vital to a competitive advantage of ANF and would be helpful to competitors of ANF when competing with ANF.
AFFIDAVIT Page 2
- 7.
The information contained in the Document is considered to be proprietary by ANF because it reveals certain distinguishing aspects of ANF licensing methodology which secure competitive advantage to ANF for fuel design optimization and marketability, and includes information utilized by ANF in its business which affords ANF an opportunity to obtain a competitive advantage over its 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 competitor to reduce its expenditure of money and manpower and to improve its competitive position by giving it valuable insights into ANF licensing methodology and would result in substantial harm to the competitive position of ANF.
- 9.
The Document contains proprietary information which is held in confidence by ANF and is not available in public sources.
- 10.
In accordance with AN F's policies governing the protection and control of information, proprietary information contained in the Document has been made available, on a limited basis, to others outside ANF only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 11.
ANF policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.
- 12.
Information in this Document provides insight into ANF licensing methodology developed by ANF. ANF has invested significant resources in developing the methodology as well as the strategy for this application.
Assuming a competitor had available the same background data and incentives as ANF, the competitor might, at a minimum, develop the information for the same expenditure of manpower and money as ANF.
THAT the statements made hereinabove are, to the best of my knowledge, information, and belief, truthful and complete.
FURTHER AFFIANT SAYETH NOT.
SUBSCRIBED before me this I r2._,J day of T(_tu.Lvn !JM.. 1990.
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AFFIDAVIT Page 3