ML19242B431
| ML19242B431 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 08/03/1979 |
| From: | Andognini G BOSTON EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 79-157, NUDOCS 7908080510 | |
| Download: ML19242B431 (3) | |
Text
L BOSTON EDISON COMPANY G EN ER A. oFFICEE 09 3 BOYLETON STREET 83STON. M AGEAUNuBETT5 0 2199 August 3, 1979 C.CARw A N DO 3 PolN,
S J 8E RI NT E N D E N T
~mC,E.R D.ER. vion. DERARmE"'
BECo. 1.tr. #79-157 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Com:nission k' ashing t on, D. C.
20555 Licent.a No. DPR-35 Docket No. 50-293 Review of Corporate Capabilities
Dear Mr. Denten:
In a letter dated June 29, 1979, you requested Boston Edison Company to provide our technical and management resources available to anticipate and preclude or respond to unusual events of the type experienced at Three Mile Island - 2.
This informat:on is provided in attachements I and II of this letter.
However, due to the personal and proprietary nature of this information we are requesting that certain portions as delineated in the enclosed affidavit be withheld from public disclosure pursuant to 10 CFR 2.790.
Should you have any further questions or concerns please contact us at your convenience.
Very truly yours, y:/
(/
w.[75.a a & we
/l
,'/'
.,/
Attachments 7 >
3 cg i J'
-qo8080 W 4 -
e s
License No. DPE-35 Do cke t No 50-293 AFFIDAVIT PURSUANT TO 10 CFR 2.790 RELPECTING CERTAIN PROPRIETARY INFORMATION I, G.
Carl Andognini, being duly sworn, hereby depose and say as follows :
I am the Manager, Nuclear Operations Department of Boston Edison Company.
I am duly authorized to make this affidavit by Boston Edison Company, and have reviewed or caused to be reviewed the information which is identified as proprietary and referenced in the paragraph immediately below.
This infor-mation consists of a listing of the personal qualifications and experience of certain individuals who are employees of Boston Edison Company.
The information for which proprietary treatment is sought consists of Attachments I & II in the letter of G.
C. Andognini, Boston Edison Company, to H. R. Denton, U. S. Nuclear Regulatory Commission entitled " Review of Corporate Capabilities," dated August 3, 1979.
Pursuant to the provisions of paragraph (b) (4) of Section 2.790 of the Commission's reculations, the following is furnished for consideration by the Commission in determining whether the informatior_ sought to be with-held from public disclosure should be withheld.
1.
The inf ormation sought to be withheld from public disclosure is owned by and has been held in confidence by Boston Edison Company.
2.
This type of information is normally held in confidence by Boston Edison Company both to protect the privacy of its employees and to protect the proprietary interest of Boston Edison Company in the maintenance of a highly trained, skilled labor force during a time period when there is a high degree of competition for the services of such skilled personnel in the open job market.
3.
Public disclosure of this information would cause a clearly unwarranted invasion of the personal privacy of the indivi-duals involved.
Although the names of the individuals are not included in this document, the names of individuals in these positions are known throughout the Nuclear industry and could easily be matched to the information sought to be withheld from public disclosure.
In addition, the recruiting, developing and training of these individuals to make a highly trained and efficient work-force has required thousands of manhours and the expenditure of hundreds of thousands of dollars by Boston Edison Company.
Use of this information by competing employers and employment agencies could result in personnel losses with Boston Edison Company bearing the burden of cost and manhours necessary for replacement.
77 5,09 a3
4.
The inf ormation, to the best of my knowledge and belief, is not available in public sources, and any disclosure to third parties has been made pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence.
5.
This information is being transmitted herewith to the Commission in confidence and with the expectation that proprietary treatment will be afforded in accordance with the Commis sion 's regulations.
G.
Carl Andognini, being duly sworn, deposes and says he has read the foregoing af fidavit and the matters stated therein are true and correct to the best of his knowledge, information and belief.
j'
/h,/ //
/
<JJh-J i;/,' 'v/V
.,s G,' Carl Andognin'i
~
s' us Subscribed and sworn before me this day of August, 1979.
//
^* 'r 9,
My Commission Expires:
July 6, 1954 Notary Public S09
\\ J'