ML20137P544
| ML20137P544 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 09/09/1985 |
| From: | Poppe L CHEM-NUCLEAR SYSTEMS, INC. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| RA-0432-5, RA-432-5, NUDOCS 8509190698 | |
| Download: ML20137P544 (3) | |
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CHEM-NUCLEAR SYSTEMS. INC.
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220 Stoneridge Drive
- Columbia, South Carolina 29210 C" SE? l6 P 2 : 3 6 September 9, 1985 RA-0432-5 Dr. J. Nelson Grace Regional Administrator, Region II U.S. Nuclear Regulatory Comission 101 Marietta St., Suite 3100 Atlanta, Ga. 30303
Dear Dr. Grace:
Attached to this letter is an affidavit in reference to the Semi-Annual Effluent and Waste Disposal Report from South Carolina Electric and Gas, dated August 30, 1985.
The affidavit covers the CNSI proprietary procedures submitted as a part of that report.
The procedures assure compliance with the regulatory requirement of 10 CFR Part 61 and supports the proprietary topical report accepted by the NRC Division of Licensing in letter dated June 11, 1985.
The topical report is entitled, " Dewatering Topical: Chem-Nuclear Systems, Inc. CNS-DW-llll8-01-P,"
and is considered proprietary under an affidavit made with the original submittal.
If I can be of further assistance in this matter, please feel free to contact me.
Very truly yours, CHEM-NUCLEAR SYSTEMS, INC.
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7N L. K. Poppe Director Licensing LKP:ggp Attachment cc:
- 0. W. Dixon, SCE&G 8509190698 850909 l
PDR ADOCK 05000395 R
PDR (803) 256-0450
- Telex: 216947
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1 AFFIDAVIT SUBMITTED TO NUCLEAR REGULATORY COMMISSION CONCERNING CONFIDENTIAL INFORMATION AND TRADE SECRETS CONTAINED IN THE DEWATERING AND WASTE PROCESSING CONTROL PROCEDURES SUBMITTED AS A PART OF THE LETTER FROM 0. W. DIXON, JR. TO J. NELSON GRACE AUGUST 30, 1985 STATE OF SOUTH CAROLINA)
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SS:
COUNTY OF RICHLAND
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Leslie K. Poppe states as follows on behalf of Chem-Nuclear Systems, Inc.:
1 I am the Director of Licensing for Chem-Nuclear Systems, Inc.
2.
I have reviewed and am familiar with the contents of the procedures listed below prepared by Chem-Nuclear Systems, Inc. (hereinafter "CNSI"),
o FO-AD-002 Operating Guidelines for Use of Polyethylene High-Integrity Container, Dated 11/23/83 o
FO-0P-001 Dewatering Procedure for 24-Inch Diameter Pressure Demineralizer Vessel Containing Activated Carbon 0.5%
Free-Standing Water, Dated 5/27/83 o
FO-0P-004 Dewatering Procedure for 24-Inch Diameter Pressure Demineralizer Vessel Containing Ion Exchange Resins 0.5%,
Dated 5/27/83 o
F0-0P-009 Dewatering Procedure for 76-Inch Diameter Pressure Demineralizer Containing Ion Exchange Resins 0.5%
Free-Standing Water, Dated 11/5/84 o
F0-0P-022 Ecodex Pre-Coat / Diatomaceous Earth Dewatering Procedure for CNSI 14-195 or Smaller Liners, Dated 11/5/84 o
FO-0P-023 Bead Dewatering Procedure for CNSI 14-195 or Smaller Liners, Dated 11/5/84 o
SD-OP-003 Process Control Program for CNSI Cement Solidification Units, Dated 1/27/84 These procedures are hereinafter called "the procedures."
3 South Carolina Electric & Gas (hereinafter "SCE8G") has submitted the procedures to the Nuclear Regulatory Commission containing proprietary information which should be withheld from public disclosure.
4 CNSI, as part of its radioactive waste disposal services, provides a variety of dewatering containers, dewatering systems and procedures which in most respects are unique.
Detailed information concerning the design operation and certification data has always been held in confidence by CNSI.
The specific container internals, the types of filter arrays, and the procedures used to certify the total system are considered confidential Information that include company trade _ secrets incorporated into such designs and processes.
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Employees of CNSI sign an agreement regarding protection of trade secret information at the time of entering company employment and the data contained in the proprietary version of the procedures being submitted to the Commission by SCE8G contains the type of information CNSI regards as protected and of the type not to be disclosed to unauthorized persons, including especially competitors, by present or former employees.
5 CNSI has obtained a competitive edge in the field cf dewatering aqueous low-level radioactive waste streams because of its extensive experience in this field and financial comitment to research, development and design concerning container componen:s and certifications. CNSI dewatering systems, container design, procedures, and certifications are presently superior to equipment and processes used by competitors for similar processes and this superiority is the basis on which procedure details are being withheld.
The information contained in the procedures is not available from public sources.
6.
Public disclosure of the procedures would cause substantial harm to the competitive position of CNSI. The Company has invested approximately one million dollars over the last several years in engineering salaries and testing programs and has spent over two hundred fifty thousand dollars approving this system and conducting certification testing. Additionally, the Company ha: nearly one-half million dollars in capital investment for operating systems supporting the procedures. Competitors of CNSI would have great difficulty in duplicating the operation developed by CNSI, due not only to the financial investment of the Company, but also to the unique skills, talents and expertise of CNSI employees.
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v L(K. Poppe/
Director Licensing STATE OF SOUTH CAROLINA)) SS:
COUNTY OF RICHLAND
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On this 9th day of September 1985, before me, a Notary Public in and for the State of South Carolina, duly commissioned and sworn, personally appeared L. K. Poppe, to me known _to be the Director of Licensing for Chem-Nuclear Systems, Inc., and on oath stated that he was authorized to make this affidavit on behalf of the corporation.
IN WITNESS WHEREOF, I have set'my hand and affixed my official seal the day and year first above written.
%.Ja L Micnael A.
Mann' My Commission Expires February 26, 1992 a