ML20153D659

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Forwards Affidavit Requesting Withholding of Proprietary Info from Semiannual Effluent & Waste Disposal Rept for 1988
ML20153D659
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 08/22/1988
From: House W
CHEM-NUCLEAR SYSTEMS, INC.
To: Grace J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19297G864 List:
References
RA-0467-8, RA-467-8, NUDOCS 8809020277
Download: ML20153D659 (3)


Text

TCHEM-NUCLEAR SYSTEMS, INC.

g220 Stoneridge Drive

  • Columna, South Carolina 29210 August 22, 1988 RA-0467-8 Dr. J. Nelson Grace Regional Administrator, Region II U. S. Nuclear Regulatory Comission 101 Harietta Street, Suite 3100 Atlanta, GA 30303

Dear Dr. Grace:

Attached to this latter is an affidavit in reference to the Semi-Annual Effluent and Waste Disposal Report for 1988 from South CarolTna uectrfc and Gas. The affidavit covers the CNSI proarietary procedures submitted as part of that report and the portion of tie report directly referencing the proprietary materials.

The procedures assure compliance with the regulatory requirements of 10 CFR Part 61.

If I can be of further assistance in this matter, please feel free to contact me.

Very truly yours, CHEM-NUCLEAR SYSTEMS, INC.

Md A William B. House Director, Licensing WBH:nhs Attachment c: D. A. Na"man, SCE&G J. H. Taylor, USNRC jjj90g 77 080029 R CK 0500o3 95 PNu (Bo3) 2564tM

  • Teles: 216947

l AFFIDAVIT SUBMITTED TO NUCLEAR REGULATORY COMMISSION CONCERNING CONFIDENTIAL INFORMATION AND TRADE SECRETS CONTAINED IN THE DEHATERING AND HASTE PROCESSING CONTROL PROCEDURES SUBMITTED l REFERENCE AS A PART OF THE SEMI-ANNUAL EFFLUENT AND HASTE DISPOSAL REPORT FOR 1988 FROM SOUTH CAROLINA ELECTRIC AND GAS STATE OF SOUTH CAROLINA)

) SS:

COUNTY OF RICHLAND ) l Hilliam B. House 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 Containers, Rev. L.

o FO-OP-014 Operating Procedure for Installing Closure Cans on 24-Inch Diameter Fiber-Glass Reinforced High Integrity Containers, Rev. F.

o FO-0P-022 Ecodex Pre-Coat /Powdex/Solka-Floc / Diatomaceous Earth Dewatering Procedure for CNSI 14-195 or Smaller Liners, Rev. D.

o SD-0P-003 Process Control Program for CNSI Cement Solidification Units, Rev. T.

These procedures are hereinafter called "the procedures."

3. South Carolina Electric & Gas (hereinafter "SCE&G") 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.

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 SCELG 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 of dewatering aqueous low-level radioactive waste streams because of its extensive experience in this field and financial commitment to research, development and design concerning container components 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 engineerir.g salaries and testing programs and has spent over two hundred fifty thousar) dollars approving this system and conducting certification testing. Additionally, the Company has 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.

/

R/81Ib~

H1111am B. House Director, Licensing STATE OF SOUTH CAROLINA)

) SS:

COUNTY OF RICHLAND )

On this 22nd day of August, 1988, before me, a Notary Public in and for the State of South Carolina, duly commissioned and sworn, personally appeared H1111am B. House, 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 HITNESS WHEREOF, I have set my hand and affixed my official seal the day and year first above written.

G$$naDds:, .,,

j Sharra L/Rollinson My Commission Expires March 11, 1990