ML20212P861

Forwards RA Hedrick Affidavit Authorizing That Technology for Energy Corp Rev 0 to R-87-001, Analysis of Power Anamoly at Callaway Nuclear Station, Submitted by Util ,Be Withheld from Public Disclosure

ML20212P861
Person / Time
Site:	Callaway
Issue date:	01/23/1987
From:	Capone D UNION ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
ULNRC-1434, NUDOCS 8702020070
Download: ML20212P861 (5)

Text

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b. U n i o n LECTRIC m

1901 Grat of Street, St. Louis January 23, 1987 U. S. Nuclear Regulatory Commission ATTN:

Document Control Desk Washington, D.C.

20555

Dear Sir:

ULNRO-1434 DOCKET NUMBER 50-483 CALLAWAY PLANT CALLAWAY FLOW ANOMALY EVALUATION - PROPRIETARY SUBMITTAL

Reference:

ULNRC-1428 dated January 12, 1987 The referenced letter transmitted a report authored by Technology for Energy Corporation (TEC) entitled

" Analysis of a Power Anomaly at Callaway Nuclear Station, TEC Report No. R-87-001, Revision O".

Attached is an affidavit signed by Mr. R. A. Hedrick, President of TEC which sets forth the basis on which the information may.

be withheld from public disclosure by the Commission.

i Please contact us if there are any questions in this matter.

Very truly yours,

'h Donald W.

Capone Manager, Nuclear Engineering f

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8702020070 870123 PDR ADOCK 05000483 PDR g

P Manhng Addrest P.O. Box 149. St. Lours. MO 63166

s cc:

Gerald Charnoff, Esq.

Shaw, Pittman, Potts & Trowbridge 1800 M. Street, N.W.

Washington, D.C.

20036 Nicholas A.

Petrick Executive Director SNUPPS 5 Choke Cherry Road Rockville, Maryland 20850 W. L.

Forney Division of Projects and Resident Programs, Chief, Section lA U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Bruce Little Callaway Resident Office U.S. Nuclear Regulatory Commission RR#1 Steedman, Missouri 65077 Paul O'Connor (2)

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 316 7920 Norfolk Avenue Bethesda, MD 20014 Manager, Electric Department Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102 Dr. J. C. Robinson Senior Vice President Techno. logy for Energy Corporation One Energy Center Lexington Drive Knoxville, TN 37922 f

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AFFIDAVIT STATE OF TENNESSEE

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COUNTY OF KNOX

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4 I, R. A. Hedrick, being duly sworn, hereby say and depose:

1.

I as President of Technology for Energy Corporation, hereinafter known as TEC, and as authorized to execute this Affidavit.

2.

I as familiar with TEC's Corporate Procedures for preparation and control of design documentation.

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I as familiar with TEC Report No. R-87-001, " Analysis of a i

Power Anomaly at Callaway Nuclear Station," referred to as " Document."

Information contained in this Document has been classified as proprietary in accordance with the procedures established by TEC for the control and protection of information.

4.

The Document contains information of a proprietary and confidential nature which is not available in public sources. Based on my experience, I an aware that other companies regard information of the kind contained in the Document as proprietary and confidential.

i 5.

The information contained in the Document is considered by TEC to be proprietary because it reveals certain distinguishing aspects of methodologies used by TEC in Noise Analysis and hardware used in TEC Loose Part Monitoring (LPM) systems, which secure competitive advantage to TEC noise analysis and LPM systems. The Document also includes information which affords TEC an opportunity to obtain a competitive advantage over those who do not or may not know or use the information contained in the Document.

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6.

The Document provides information which reveals the methodologies used for noise analysis and hardware used for LPM systems.

TEC has invested many man years of effort in developing these methodologies and the LPM system.

7 The Document contains information which is vital as a competitive advantage to TEC and would be helpful to competitors of TEC.

The disclosure of the proprietary information contained in the Document i

i to a competitor would permit the competitor to reduce its expenditure of money and manpower and to improve its competitive position by giving it extremely valuable insights into the TEC LPM system. It would also l

result in substantial harm to the competitive position of TEC.

8.

Based on my experience, I do not believe that the background, data, and incentives of TEC's competitors are sufficiently similar to the corresponding background, data, and incentives of TEC to reasonably expect such competitors to be in a position to duplicate TEC's proprietary information contained in the Document without similar investments.

9 In accordance with TEC's policies governing the protection l

and control of information, proprietary information contained in the Document has been made available, on a limited basis, to others outside TEC only as required and under suitable agreement providing for i

nondisclosure and limited use of the information.

10. The Document has been made available to Union Electric and the U.S. Nuclear Regulatory Commission in confidence, with the stipulation that the information contained in the Document not be duplicated or disclosed, in whole or in part, without the express written consent of Union Electric and Technology for Energy Corporation.

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THAT the statements made hereinabove are, to the best of my knowledge, information and belief, truthful and complete.

/gI, J

.,1 R. A. '.iedrick Presicent Technology for Energy Corporation SWORN TO AND SUBSCRIBED N

before me this L day of 011/rijze -

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Yhud/dat NOTpYPUBLIC My Commission Expires:

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