ML20236D590

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Responds to 870619 Request for Info Re Proprietary Info Contained in DOE Forms 741 & 742.Forms Containing Info Re Matl Control & Accounting Info Automatically Exempt from Public Disclosure Per 10CFR2.790(d)
ML20236D590
Person / Time
Site: Palisades, Big Rock Point, 05000000
Issue date: 07/27/1987
From: Johnson B
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8707300537
Download: ML20236D590 (2)


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~ AIEMGAN'S MtOGRE55 oeneral officess ' 1945 West Parnall Road, Jackson, MI 49201 e (5171788-0550 ~

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' July 27, 1987) 1

-Nuclear R'egulatory Commission.

Document Control Desk Washington, DC 20555

. DOCKET 50-155 - LICENSE DPR BIG ROCK' POINT PLANT -

DOCKET'50-255 - LICENSE DPR PALISADES PLANT -

RESPONSE TO REQUEST FOR INFORMATION ON DOE /NRC FORMS 741 AND 742'-

l iNRC letter dated June 19, 1987 and received'by Consumt.rs Power Company June 29, 1987 requested answers to four questions regarding proprietary information contained on DOE /NRC forms 741 and 742. _These questions and

. Consumers Power Company's responses are as follows:-

1) Was the information' transmitted to, and received by, the'NRC in confi-dence? 'Please give details.

No explicit effort is made, during transmittal of the information to the NRC, to' treat it' as confidential.other than to restrict its distribution -

e to the subcontractor' handling the special nuclear material data system and l

to appropriate' locations within Consumers Power Company.

2) To the best of your knowledge, is the information currently available in f

public sources?

i To the best of our knowledge, this information is not currently available 9

in public sources.

3) Does your Company customarily. treat this 1nformation, or this type of i

information, as confidential? Please explain why.

No' explicit effort is made to declare the information confidential or to treat it'as such within Consumers Power Company other than to process the information within a relatively small group of knowledgeable individuals within the Company. Permanent (microfilm) storage.of the information is accessible by all Company employees. The information is therefore treated q

as not strictly confidential.

4) Would public disclosure of the information be likely to cause substantial harm to the competitive position of your Company? If so, how?

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Nuclear RegulGtory Commission 2

Big Rock Point and Palisades Planta Info on DOE /NRC Forms 741 and 742 j

July 27, 1987 Public disclosure of the information would not likely be detrimental to the competitive position of Consumers Power Company as special nuclear material inventories are maintained for use in facility operation as opposed to representing an end product fabricated for distribution outside the Company in a competitive market. However, vendors that supply SNM -

containing products to Consumers may consider this type of information on their products to be proprietary; this view has been confirmed with Consumers' present nuclear fuel vendor.

It should be noted that Consumers' treatment of the information on SNM is consistent with that used on certain otter vendor proprietary information (eg. fuel reload Facility Change packages).

In addition to the four areas above, the referenced letter requested that we specify whether the information on the DOE /NRC Forms 741 and 742 has been classified pursuant to an executive order or is considered unclassified safeguards information as defined in 10 CFR, Part 73.21.

The information has not been classified pursuant to an executive order to the best of our knowl-edge. Likewise, the information is not considered unclassiff.ed safeguards information as defined in 10 CFR, Part 73.2 and Part 73.21.

Finally, the reference requested our position as to which information, if any, j

on the DOE /NRC Forms 741 and 742 may be publicly disclosed.

Since the forms are records containing information on our material control and accounting programs, we believe they are automatically exempt from public disclosure according to 10 CFR, Part 2.790(d). This view is shared by our nuclear fuel vendor in their response to the same NRC inquiry letter.

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Brian D Johnson Staff Licensing Engineer CC Administrator, Region III, NRC NRC Resident Inspectors - Big Rock Point & Palisades OC0787-0112-NLO2

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