ML18057A860
| ML18057A860 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/16/1991 |
| From: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18057A861 | List: |
| References | |
| TAC-08621, TAC-8621, NUDOCS 9104240039 | |
| Download: ML18057A860 (5) | |
Text
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consumers Power POW ERi Nii MICHlliAN'S PROliRESS Palisades Nuclear Plant:
27780 Blue Star Memorial Highway, Covert, Ml 49043 April 16, 1991 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
GB Slade General Manager RELOAD M FUEL SEISMIC ANALYSIS {TAC NO 08621) - ADDITIONAL INFORMATION On December 11, 1990, the NRC (via facsimile) requested additional information on seven items regarding the seismic analysis of the Palisades high thermal performance fuel design.
The request resulted from the NRC review of Advanced Nuclear Fuel's report ANF-89-115(P), Rev 2, "Seismic Analysis of Palisades HTP Fuel Design."
The attachment to this letter responds to items 1, 3, 4, 6 and 7 from the NRC request.
Preparation of response to Items 2 and 5 has necessitated revision of some parts of ANF-89-115(P), Rev 2.
Revision 3 of ANF-89-115(P), along with our complete response including Items 2 and 5, will be submitted for NRC review in June 1991.
Advanced Nuclear Fuels considers the information contained in the responses to NRC questions on ANF-89-115(P), Revision 2, "Seismic Analysis of Palisades High Thermal Performance Fuel Design" to be proprietary.
In accordance with the Commission's Regulation 10CFR2.790(b), to support the NRC withholding proprietary information, an affidavit from ANF is attached.
~At:_-_
Gerald B Slade General Manager CC Administrator, Region III, USNRC NRC Resident Inspector, Palisades A CMS eNE'RGY COMPANY
ATTACHMENT Consumers Power Company Palisades Plant Docket 50-255 RESPONSE TO ITEMS 1, 3, 4, 6 AND 7 OF THE NRC's 12/11/90 RAI 9 Pages
AFFIDAVIT STATE OF WASHINGTON
)
)
SS.
COUNTY OF BENTON
)
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 revised responses to the NRC questions on ANF-89-115(P),
Revision 2 entitled "Seismic Analysis of Palisades High Thermal Performance Fuel Design,"
referred to as "Responses." Information contained in these Responses 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 Responses contain 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 Responses as proprietary and confidential.
- 5.
The Responses have been made available to the U.S. Nuclear Regulatory Commission in confidence, with the request that the information contained in the Responses will not be disclosed or divulged.
AFFIDAVIT Page 2
- 6.
The Responses contain information which is vital to a competitive advantage of ANF and would be helpful to competitors of ANF when competing with ANF.
- 7.
The information contained in the Responses is considered to be proprietary by ANF because it reveals certain distinguishing aspects of ANF seismic 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 Responses.
- 8.
The disclosure of the proprietary information contained in the Responses 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 seismic methodology and would result in substantial harm to the competitive position of ANF.
- 9.
, The Responses contain proprietary information which is held in confidence by ANF and is not available in public sources.
1 O.
In accordance with AN F's policies governing the protection and control of information, proprietary information contained in the Responses 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 these Responses provides insight into ANF seismic 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
~-.
AFFIDAVIT Page 3 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 j__-!}-
day of ~'
j
, 1991.
Susan K. McCoy
~
NOTARY PUBLIC, STATE OF~SHINGTON MY COMMISSION EXPIRES: 1/10/92