ML20216E035

Affidavit of FW Getman (Great Bay Power Corp) Requesting That NRC Withhold Util Response to NRC RAI Re Proposed Acceleration of Decommissioning Funding for Ownership Share of Seabrook Station

ML20216E035
Person / Time
Site:	Seabrook
Issue date:	04/13/1998
From:	Getman F AFFILIATION NOT ASSIGNED
To:
Shared Package
ML20216E007	List: ML20216E006 ML20216E035
References
NYN-96031, NUDOCS 9804160057
Download: ML20216E035 (3)

Text

i ~ j UNITED STATES OF AMERICA l ,

NUCLEAR REGULATORY COMMISSION

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l In the Matter of )

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North Atlantic Energy Service Corporation, ) Docket No. 50-443 g1a_L ) NYN-96031 l

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, (Seabrook Station, Unit 1) ) I

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Affidavit Of Frank W. Getman Jr. {

Pursuant to 10 C.F.R. 6 2.790 1

CITY OF BOSTON )

l ) SS:

STATE OF MASSACHUSETTS )

Frank W. Getman Jr., being duly sworn, states as follows:

! 1. I am Vice President and Chief Operating Officer for Great Bay Power Cor-poration (" Great Bay") located in Dover, New Hampshire. In that capacity, I am respon-i sible for operational and managerial matters of Great Bay.

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. 2. Great Bay has filed with the NRC a response for request for additional in-

formation regarding Great Bay's request for a determination by the NRC that its pro-l posed acceleration of decommissioning funding for its ownership share of the l Seabrook Station will provide reasonable assurance of decommissioning funding under the applicable NRC regulations. Most of the information contained in Great Bay's re-sponse is sensitive confidential commercial and financial information that could cause great harm to Great Bay if it were made publicly available. Accordingly, Great Bay re-quests the NRC to withhold this information, developed and owned by Great Bay, from public disclosure pursuant to 10 C.F.R @ 2.790 of its regulations. This affidavit supplies 1

9804160057 980413 PDR ADOCK 05000443 p PDR l

t the reasons why this information should be withheld from public disclosure as required by the regulation.

3. The complete unredacted version of Great Bay's response containing the sensitive, confidential commercial and financial information for which Great Bay re-quests the Commission to treat as proprietary and to withhold from public disclosure is attached behind Tab A to this affidavit. A redacted version of Great Bay's response de-l leting the sensitive, confidential commercial and financial information is attached be-hind Tab B to this affidavit . The redacted version behind Tab B can be made publicly l available without competitive harm to Great Bay, 1

4. I am familiar with the sensitive commercial and financial information con-

! tained in Great Bay's response attached at Tab A to this affidavit. I am authorized to speak to Great Bay's practice of maintaining such information confidential and the harm i

that would befall Great Bay if it were publicly disclosed.

5. Great Bay's response attached at Tab A to this affidavit contains cash j flow, balance sheet and income statement projections reflecting Great Bay's budget and forecast of revenues from the sale of electricity, and cash outlays for the cost of I

generating electricity, for the years 1998 through 2002. Great Bay's response also conte. ins assumptions concerning Great Bay's price for short term sales of electricity ar.d the capacity factors for Seabrook, on which these projections are based. This in-formation, consisting of revenue, cash flow, sales price and similar type projections, is information of the type customarily held in confidence by Great Bay, and this informa-tion is so held. Great Bay does not disclose this type of information to the public and it is not available from public sources. The rational basis for not disclosing this type of information is that the information is commercially sensitive to the conduct of Great l

l Bay's sale of power and its disclosure to competitors and 'stomers could cause Great Bay substantial competitive harm. If the information contained in Great Bay's response t

(behind Tab A to this affidavit) became available to Great Bay's competitors or custom-ers (both current and potential), those parties would learn of sensitive pricing and cost information which could be used against Great Bay in the negotiation of current and 1

future power sales. Such a result would place Great Bay at a significant competitive i disadyantage in the negotiations of current and future power sales and cause it sub-stantial commercial harm.

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6. Accordingly, the information included in Great Bay's response attached at l

Tab A to this affidavit has been transmitted to the Commission in confidence under the l

provisions of 10 C.F.R. @ 2.790 with the understanding that it will be received and held in confidence by the Commission and withheld from public disclosure.

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' .! /.,

l Frank W. Getman Jr.

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Sworn to before me this 10 day of April 1998 l

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k' .Lt A.1-]

Notary Public g.,w h . h cd l

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574611-01 , DMSCC1 1

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