ML20151G139
| ML20151G139 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/19/1988 |
| From: | Wambach T Office of Nuclear Reactor Regulation |
| To: | Lingren C GAMMETRICS |
| References | |
| TAC-66901, NUDOCS 8807280153 | |
| Download: ML20151G139 (6) | |
Text
boc/4a/ Et
'o,t UNITED STATES 4
i NUCLEAR REGULATORY COMMISSION
{
W ASHINGTON, D. C. 20655
%.....,/
July 19, 1988 Docket No.
50-255 Mr. Clinton L. Lingren Vice President Reactor Instrumentation Gamma-Metrics 5550 Oberlin Drive San Diego, California 92121
Dear Mr. Lingren:
SUBJECT:
PALISADES PLANT - REACTOR PROTECTION SYSTEM MODIFICATION, REQUEST FOR: WITHHOLDING 0F PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE (TAC 66901)
Consumers Power Company, the licensee for Palisades Plant, applied for a license amendment by submittal dated March 25, 1988.
In support of that application the licensee submitted documents regarding hardware and software to be used in modifying the reactor protection system.
This hardware and software is being provided by Gamma-Metrics (GM) and you provided affidavits requesting that the material be withheld from public disclosure pursuant to 10 CFR 2.790.
The documents were submitted on March 25, June 17 and June 27, 1988 and are identified on the enclosed list.
You stated that the submitted information should be considered exempt from mandatory public disclosure for the following reasons:
The Documents contain information of proprietary and confidential nature and are of the type customarily held in confidence by GM and not made available to the public.
I have engaged in research and development activities with a variety of employers for more than 20 years.
Based on that experience, I state that other companies similarly situated would regard information of the kind contained in the Documents to be proprietary and confidential.
l GM has held the Documr.nts in confidence and has released them
(
only (i) as necessary to comply with applicable law, and (ii) under confidential disclosure agreements.
GM follows a variety of customary procedures for the safeguarding of its proprietary l
information, including the information set forth in the Documents.
l h
l 8807280153 880719 d}
l DR ADOCK OSOO 5
/
I 0
l
Mr. Lingren O GM is making the Documents available to the United States Nuclear Regulatory Commission in confidence, with the request, hereby made, that the information contained in the Documents will not be disclosed or divulged for the reasons set forth herein, which are intended to be responsive to 10 CFR 2.790(b)(1).
The information contained in the Documents is not available in public sources.
GM has expended substantial amounts to create the information set forth in the Documents.
That information is vital to GM's competitive advantages and would be extremely helpful to GM's competitors if it were known by them.
GM believes the information in the Documents is proprietary because it reveals the details of the implementation of the functions performed by the thermal margin monitor and includes information used by GM in its business whic' affords GM an opportunity to obtain a competitive advantage over its competitors who do not or may not know or use the information contained in the Documents.
The disclosure to a competitor of the proprietary information contained in the Documents would permit the competitor to reduce its research and development expenditures and thereby unfairly improve its competitive position by giving it extremely valuable insights into GM's proprietary information, resulting in substantial and irremediable harm to GM's competitive position.
We have reviewed your request and the material in accordance with the requirements of 10 CFR 2.790 and, on the basis of your statements, have determined that the submitted information sought to be withheld contains trade secrets or proprietary commercial information.
i Therefore, the documents listed in the Enclosure to this letter will be withheld l
from public disclosure pursuant to 10 CFR 2.790(b)(5) and Section 103(b) of the Atomic Energy Act of 1954, as amended.
l Withholding from public inspection shall not affect the right, if any, of persons properly and directly concerned to inspect the documents.
If the need arises, we may send copies of this information to our consultants working in this area.
We will, of course, ensure that the consultants have signed the appropriate agreements for handling proprietary information.
If the basis for withholding this information from public inspection should change in the future such that the information could then be made available for pubi P insp4ction, you should promptly notify the NRC.
You also should understand that the NRC may have cause to review this determination in the future, for e.vamnlc, if the scope of a Freedom of Information Act request l
l
' Mr. Lingren '
includes your information.
In all review situations, if the NRC makes a determination adverse to the above, you will be notified in advance of any public disclosure.
Sincerely, Thomas V. Wambach, Project Manager Project Directorate III-1 Division of Reactor Projects - III, IV, V
& Special. Projects
Enclosure:
List of documents cc: See next page
}
Mr. Lingren. includes your ir.cormation.
In all review situations, if the NRC makes a determination adverse to the above, you will be notified in advance of any public d 6 1osure.
Sincerely, ill@li)ESMi Thomas V. Wambach, Project Manager Project Directorate III-1 Division of Reactor Projects - III, IV, V-
& Special Projects
Enclosure:
List of documents cc: See next page DISTRIBUTION DUCKF.TFILE-DCRUTCHFIELD TWAMBACH BGRIMES NRC & LOCAL PDRs GHOLAHAN OGC ACRS (10)
PD31 GRAY FILE RINGRAM EJ0RDAN OGC,,T. kW Q
PM/ 31:DRSP Aptr : DEST D/PD31:DR P TWAMBACH EWBl!RRY MVIRGILIO ESH0 MAKER 7/ }]/88
}/
/ II /88 7//Lf/88 7/t1/88 f
Mr. Kenneth W. Berry Palisades Plant Director, Nuclear Licensing Consumers Power Company 1945 West Parnall Road Jackson, Michigan 49201 M. I. Miller, Esquire Sidley & Austin Nuclear Facilities and 54th Floor Environmental Monitoring One First National Plaza Section Office Chicago, Illinois 60603 Division of Radiological Health Mr. Thomas A. McNish, Secretary P.O. Box 30035 Consurrers Power Company Lansing Michigan 48909 212 West Michigan Avenue Jackson, Michigan 49201 Judd L. Bacon, Esquire Consurners Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Regional Administrator, Region III U.S. Nuclear Regulatory Comission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Jerry Sarno Township Supervisor Covert Township 36197 M-140 Highway Covert, Michigan 49043 Office of the Governor Room 1 - Capitol Building Lansing, Michigan 48913 Mr. Gerald B. Slade Plant General Manager Palisades Plant 27780 Blue Star Memorial Hwy.
Covert, Michigan 49043 Resident Inspector c/o U.S. Nuclear Regulatory Comission Palisades Plant 27782 Blue Star Memorial Hwy.
Covert, Michigan 49043
O ENCLOSURE w
LIST OF DOCUMENTS l'
HARDWARE SPECIFICATION DOCUMENT N0. 056 SOFTWARE REQUIREMENTS SPECIFICATION DOCUMENT NO. 055 SOFTWARE DESIGN DESCRIPTION DOCUMENT NO. 089 INSTRUCTION MANUAL DOCUMENT NO. 070, VOLUMES I, II, III & IV TMM SOFTWARE QUALITY ASSURANCE AND DEVELOPMENT PLAN DOCUMENT NO. 068 RCS-50 TMC QUALIFICATION TEST PLAN DOCUMENT NO. 066 VERIFICATION-SOFTWARE INTEGRATION PLAN DOCUMENT N0. 067 HARDWARE-SOFTWARE INTEGRATION PLAN DOCUMENT NO. 073 VALIDATION PLAN DOCUMENT N0. 088 VERIFICATION REPORT FORMS FOR EACH OF THE FOLLOWING:
HARDWARE SPECIFICATION DOCUMENT NO. 056 SOFTWARE REQUIREMENTS SPECIFICATION DOCUMENT NO. 055 SOFTWARE DESIGN DESCRIPTION DOCUMENT NO. 089 THM SOFTWARE QUALITY ASSURANCE AND DEVELOPMENT PLAN DOCUMENT NO. 068 HARDWARE-SOFTWARE INTEGRATION PLAN DOCUMENT 073 VALIDATION PLAN DOCUMENT NO. 088 SOURCE CODE EXECUTABLE CODE