NOC-AE-03001541, Bottom Mounted Instrumentation Forced Outage Confidential Information

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Bottom Mounted Instrumentation Forced Outage Confidential Information
ML031560490
Person / Time
Site: South Texas STP Nuclear Operating Company icon.png
Issue date: 06/02/2003
From: Jordan T
South Texas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-03001541
Download: ML031560490 (8)


Text

Nuclear Operating Company South TexwsIrt Electrlc Generatn Station P ox 289 adsvorth Tas 77483AAA June 2, 2003 NOC-AE-03001541 10CFR2.790 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 South Texas Project Unit I Docket No. STN 50-498 Bottom Mounted Instrumentation Forced Outage Confidential Information This letter formally submits information regarding the bottom mounted instrumentation (BMI) forced outage that STPNOC proposes to discuss in a closed portion of the June 5, 2003 BMI progress meeting. to this letter provides an application for withholding confidential information that identifies the information sought to be withheld and provides the reasons that the information should be withheld. provides a copy of the confidential information previously submitted by e-mail. provides a non-confidential version of Attachment 3.

If there are any questions regarding this submittal, please contact Mr. Scott Head at (361) 972-7136 orme at (361) 972-7902.

T. ordan Vice President, Engineering & Technical Services jtc Attachments: (1) Application and Affirmation for Withholding Confidential Information (2) BMI Outage Schedule and Milestones (Non-Confidential)

(3) BMI Outage Schedule and Milestones (Confidential)

A,, C STI: 31613762

NOC-AE-03001541 Page 2 of 2 cc: w/o Attachment 3 (except *)

(paper copy) (electronic copy)

Ellis W. Merschoff A. H. Gutterman, Esquire Regional Administrator, Region IV Morgan, Lewis & Bockius LLP U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 L. D. Blaylock Arlington, Texas 76011-8064 City Public Service

  • U. S. Nuclear Regulatory Commission Mohan C. Thadani Attention: Document Control Desk U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike R. L. Balcom Rockville, MD 20852 Texas Genco, LP Richard A. Ratliff A. Ramirez Bureau of Radiation Control City of Austin Texas Department of Health 1100 West 49th Street C. A. Johnson Austin, TX 78756-3189 AEP Texas Central Company
  • Cornelius F. O'Keefe Jon C. Wood U. S. Nuclear Regulatory Commission Matthews & Branscomb P. 0. Box 289, Mail Code: MN1 16 Wadsworth, TX 77483 C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704

NOC-AE-03001541 ATTACHMENT 1 Application and Affirmation for Withholding Confidential Information

NOC-AE-03001541 Attachment 1 Page 1 of 3 Application and Affirmation for Withholding Confidential Information The confidential information for which withholding is being requested is in Attachment 3 to this letter and is further identified in the attachment signed under affirmation by the owner of the information, STP Nuclear Operating Company. The attachment sets forth the basis on which the information may be withheld from public disclosure by the NRC and addresses with specificity the considerations listed in OCFR2.790(b)(4).

NOC-AE-03001541 Attachment I Page 2 of 3 (1) I am Thomas J. Jordan, Vice President, Engineering & Technical Services, STP Nuclear Operating Company (STPNOC). I have been specifically delegated the function of reviewing the confidential information sought to be withheld from public disclosure in connection with the South Texas Project Unit I return to service and I am authorized to apply for its withholding on behalf of STPNOC.

(2) I am making this affidavit in accordance with the provisions of 10CFR2.790 and in conjunction with the STPNOC application for withholding accompanying this affidavit.

(3) I have personal knowledge of the criteria and Administrative Policy utilized by STPNOC in designating this information as confidential.

(4) The confidential information sought to be withheld is schedule information that would indicate the dates upon which actions will be taken, the ending date of the outage, or the duration of the outage.

(5) Pursuant to the provisions of paragraph (b)(4) of 10CFR2.790, the following is furnished for consideration by the NRC in determining whether the information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned by and has been withheld from the general public by STPNOC.

(ii) The information is of a type customarily held in confidence by STPNOC and not customarily disclosed to the general public. STPNOC has a rational basis for determining the types of information customarily held in confidence and uses an Administrative Policy to determine when and whether to hold certain types of information in confidence. Under that Policy, information is held in confidence if it falls into one or more of several types, the release of which might result in financial damage STPNOC or the Owners of STP, as follows:

(a) The information is "confidential" data or information concerning the operations of STPNOC that is not in the public domain.

(b) The information is "inside information" about an Owner or its business activities that has not been generally disclosed to the public and which could affect the market value of the Owners' stocks or the value of the South Texas Project.

(c) The release to outside parties of "confidential" information such as unit operating schedules that has not been publicly announced can constitute a conflict of interest.

NOC-AE-0300 1541 Attachment 1 Page 3 of 3 There are sound reasons behind the STPNOC Policy:

(a) Information regarding the dates and durations of outages could have an adverse impact on the price paid for replacement power during the outage.

(b) Information regarding the dates and durations of outages could have an adverse impact on the Owners' stock prices.

(c) Information regarding the dates and durations of outages could have an adverse impact on the value of the South Texas Project and the bidding price for sale of Owner's shares of the South Texas Project.

(iii) The information is being transmitted to the NRC in confidence and, under the provisions of 10CFR2.790, it is to be received in confidence by the NRC.

(iv) The information sought to be withheld is not available in public sources.

(v) STPNOC believes that public disclosure of the information sought to be withheld is likely to cause substantial harm to the competitive position of STPNOC and the Owners of the South Texas Project.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on: June 2, 2003 Vice President, Engineering & Technical Services

NOC-AE-03001541 ATTACHMENT 2 Bottom Mounted Instrumentation Outage Schedule and Milestones (Non-Confidential)

NOC-AE-03001541

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