ML19273B712
| ML19273B712 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 05/23/1979 |
| From: | Kreider H UNITED ENGINEERS & CONSTRUCTORS, INC. |
| To: | |
| Shared Package | |
| ML19273B706 | List: |
| References | |
| NUDOCS 7906120164 | |
| Download: ML19273B712 (3) | |
Text
- AF 'IDAVIT
- 1. I, Harry G, Kreider, am the Project Manager of United Engineers &
Constructors Inc. ("UE&C") for Brunswick Steam Electric Plant Units 1 and 2 owned and cperated by Carolina Power and Light Company and am authorized to apply for the withholding from public disclosure of proprietary information.
+. 2. This Af fidavit is submitted under the provisions of 10 C.F.R. Section
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' 2.790.
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- 3. I have knowledge of the criteria and procedures used by UE&C to il
- ' designate information as a trade secret or privileged or confidential commercial or financial information.
- 4. Pursuant to 10 C.F.R. Sec tion 2.790(b) (4) , the following is furnished p for consideration by the Commission in determiaing whether the infor-I. I mation sought to be withheld from public disclosure should be withhold:
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- a. The information sought to be withheld is owned by UE&C and consists of source program listings in whole or in part cf j a computer program named UE&C ADLPIPE 2.
- b. The information sought to be withheld is of a type custom-arily held in confidence by UE&C. Among these types of information are computer program source listings.
- c. There is a rational basis for UE&C's holding this informa-tion in confidence:
79061201G4 i
q (1) The use of such information gives UE&C an advantage h over its competitors. Withholding such information from disclosure protects LT&C's competitive position.
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f C0!O!ONWEALTH OF PENNSYLVANIA )
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COUNTY OF PHIIADELPHIA )
Harry G. Kreider being duly sworn according to law, deposes and says that he is authorized to execute this AFFIDAVIT on behalf of United Engineers & Cons truc tors Inc. , and tha t the averments of facts set forth l in this AFYIDAVIT are true and correct to the best of his knowledgc,
!i l, information, and belie f.
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i Sworn to and Subscribed before me
- this 91ra day of uw , 19 70 .
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. Notary Public My Commission Expires Janua rv 31, 1981 Irerte Etzpatnck, +/are Puthe
}t 30 South 17th 5:rcet PMadelonia Pa.13101f n , N { p I i
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(ii) Se information is marketable to licensees. Wi th-holdin; the information from disclosure proteca i UE&C's ability to sell the information to license .s.
- d. The information has been submit.ed to the Courtission in confidence, and under 10 C.F.R. Section 2.790, it is to be i received in confidence by the Commission.
i e. ne information sought to be withheld is not available in k pub!ic sources.
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- f. ne O sc losure of the information sought to be withheld is likely to Tuse subs tantial harm to the compe titive pos t-o tion of UE&C, based on:
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, (1) 3e value of the information to UE&C.
i ' ! A. 3e use of the infor-ation gives UE&C advantages ; o
] over its competitors. It reduces costs by ' in- !
q creasing the productivity of UE&C's engineers 6i and o ther personnel. Public disclosure of this information would enable competitors to exploit {
! advantages now possessed exclusively by UE&C and its licensees.
(ii) The amount of ef fort and money expended by CESC in developing this information. (iii) The difficulty entailed by others in duplicating the informa tion. A competiter of UE&C would have to ex-pend resources comparable to those expended by UELC i to duplicate the information sought to be withheld. 1 It is therefore respectfully requested that the aforementioned information be withheld from public disclo;ure. I y 'b d/
- g Harry G. L'e[ der (/
' Project Manager
;! "nited Engineers & Cons truc tors Inc. l t ,l i
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