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
+.
f 2.790.
b li 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:
r
'I 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
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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.
2350 316
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f C0!O!ONWEALTH OF PENNSYLVANIA
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ss.
COUNTY OF PHIIADELPHIA
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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,
! il, information, and belie f.
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i Sworn to and Subscribed before me
, 19 70 this 91ra day of uw l
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v.,
Notary Public
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My Commission Expires Janua rv 31, 1981 Irerte Etzpatnck, +/are Puthe
}t 30 South 17th 5:rcetf PMadelonia Pa.13101 n N { p I i !i l i I d ll l
l-i e ( 'l l (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 received in confidence by the Commission. i i e. ne information sought to be withheld is not available in k pub!ic sources. ,N 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: f ]li I (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 q ' in-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 'b d/ y g Harry G. L'e[ der (/ Project Manager "nited Engineers & Cons truc tors Inc. l t ,l i ~. l 2350 3181 I t}}