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Category:Legal-Affidavit
MONTHYEARML23317A1192023-11-10010 November 2023 Constellation Energy Generation, LLC - 2023 Annual Report - Guarantees of Payment of Deferred Premiums ML22320A5592022-11-16016 November 2022 2022 Annual Report - Guarantees of Payment of Deferred Premiums ML22301A1742022-10-28028 October 2022 Global Nuclear Fuel Americas, LLC (GNF) - Part 21 60-Day Interim Report Notification: GNF3 Raised Water Rod (SC-22-04 Rt) ML21307A0542021-11-0202 November 2021 Annual Report - Guarantees of Payment of Deferred Premiums ML21272A2772021-09-29029 September 2021 Update to Application for Order Approving License Transfers and Proposed Conforming License Amendments ML21182A1002021-06-30030 June 2021 Proposed Alternative to Utilize Code Case N-893 RS-21-070, Proposed Alternative to Utilize Code Case N-8932021-06-30030 June 2021 Proposed Alternative to Utilize Code Case N-893 ML21057A2732021-02-25025 February 2021 Application for Order Approving License Transfers and Proposed Conforming License Amendments NMP1L3371, Summary of Changes, Quality Assurance Topical Report, NO-AA-10 & Decommissioning Quality Assurance Program, NO-DC-102021-02-10010 February 2021 Summary of Changes, Quality Assurance Topical Report, NO-AA-10 & Decommissioning Quality Assurance Program, NO-DC-10 ML20310A1152020-11-0404 November 2020 Annual Report - Guarantees of Payment of Deferred Premiums ML19318G1702019-11-14014 November 2019 2019 Annual Report - Guarantees of Payment of Deferred Premiums ML18316A0032018-11-0707 November 2018 Submittal of 2018 Annual Report - Guarantees of Payment of Deferred Premiums ML16088A3962016-03-28028 March 2016 Transmittal of Exelon Nuclear Radiological Emergency Plan Addendum Revision RS-16-058, Clinton, Unit 1 - Transmittal of Exelon Nuclear Radiological Emergency Plan Addendum Revision2016-03-28028 March 2016 Clinton, Unit 1 - Transmittal of Exelon Nuclear Radiological Emergency Plan Addendum Revision ML14321A7052014-11-14014 November 2014 2014 Annual Report - Guarantees of Payment of Deferred Premiums ML14204A7092014-07-23023 July 2014 Enclosure 3, Affidavit of Peter M. Yandow RS-14-160, Co. - Submission of Standard Practice Procedure Plans and Foreign Ownership Control or Influence Package2014-07-0202 July 2014 Co. - Submission of Standard Practice Procedure Plans and Foreign Ownership Control or Influence Package RS-14-112, Reports Associated with Results of Post-Irradiation Examination (Pie) of Global Nuclear Fuel (Gnf) GE14i Isotope Test Assembly (ITA)2014-03-27027 March 2014 Reports Associated with Results of Post-Irradiation Examination (Pie) of Global Nuclear Fuel (Gnf) GE14i Isotope Test Assembly (ITA) RS-12-227, Exelongeneration, Submission of Standard Practice Procedure Plans and Updated Foreign Ownership Control or Influence Package2012-12-19019 December 2012 Exelongeneration, Submission of Standard Practice Procedure Plans and Updated Foreign Ownership Control or Influence Package ML1127000682011-09-26026 September 2011 Enclosure 3, Mfn 10-245 R4, Affidavit ML1031904262010-11-0808 November 2010 Corp. - 2010 Annual Report - Guarantees of Payment of Deferred Premiums ML0520003282005-07-14014 July 2005 Surveillance Program for Channel-Control Blade Interference RS-05-068, Affidavit for Withholding of Global Nuclear Fuel Proprietary Information in Support of Onsite Spent Fuel Storage Expansion2005-05-25025 May 2005 Affidavit for Withholding of Global Nuclear Fuel Proprietary Information in Support of Onsite Spent Fuel Storage Expansion RS-05-019, Reactor Core Shroud Repair Relief Request2005-03-15015 March 2005 Reactor Core Shroud Repair Relief Request RS-03-185, Additional Information Supporting the Request for Amendment to Technical Specifications 3.6.5.1, Drywell, and 5.5.13, Primary Containment Rate Testing Program.2003-09-15015 September 2003 Additional Information Supporting the Request for Amendment to Technical Specifications 3.6.5.1, Drywell, and 5.5.13, Primary Containment Rate Testing Program. RS-02-013, Response to Request for Additional Information Regarding Risk Aspects of Inclined Fuel Transfer System License Amendment Request for Clinton Power Station2002-01-15015 January 2002 Response to Request for Additional Information Regarding Risk Aspects of Inclined Fuel Transfer System License Amendment Request for Clinton Power Station 2023-11-10
[Table view] Category:Letter type:RS
MONTHYEARRS-23-097, Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans2023-10-12012 October 2023 Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans RS-23-090, Annual Report of Emergency Core Cooling System Evaluation Model Changes and Errors for Clinton Power Station2023-09-0707 September 2023 Annual Report of Emergency Core Cooling System Evaluation Model Changes and Errors for Clinton Power Station RS-23-080, Constellation Energy Generation, LLC, Application to Revise Technical Specifications to Adopt TSTF-264-A, Revision 0, 3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs2023-08-30030 August 2023 Constellation Energy Generation, LLC, Application to Revise Technical Specifications to Adopt TSTF-264-A, Revision 0, 3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs RS-23-081, Request for License Amendment to Revise Technical Specifications Related to Reactor Water Cleanup Isolation Instrumentation2023-08-21021 August 2023 Request for License Amendment to Revise Technical Specifications Related to Reactor Water Cleanup Isolation Instrumentation RS-23-085, Supplemental Information Related to Request for Partial Site Release2023-08-0303 August 2023 Supplemental Information Related to Request for Partial Site Release RS-23-077, Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations2023-06-16016 June 2023 Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations RS-23-073, Request for Partial Site Release2023-06-0707 June 2023 Request for Partial Site Release RS-23-042, Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling2023-05-25025 May 2023 Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling RS-23-049, Constellation Energy Generation, LLC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations2023-03-23023 March 2023 Constellation Energy Generation, LLC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations RS-23-039, Request for License Amendment to Revise Technical Specifications Section 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air2023-03-0101 March 2023 Request for License Amendment to Revise Technical Specifications Section 3.8.3, Diesel Fuel Oil, Lube Oil, and Starting Air RS-23-045, Constellation Energy Generation, LLC Submittal of Fitness for Duty Performance Data Reports for 2022 Per 10 CFR 26.717(c) & 10 CFR 26.2032023-02-28028 February 2023 Constellation Energy Generation, LLC Submittal of Fitness for Duty Performance Data Reports for 2022 Per 10 CFR 26.717(c) & 10 CFR 26.203 RS-23-003, Constellation Energy Generation, LLC, Summary of Changes to Quality Assurance Topical Report, NO-AA-10, and Decommissioning Quality Assurance Program, NO-DC-102023-01-31031 January 2023 Constellation Energy Generation, LLC, Summary of Changes to Quality Assurance Topical Report, NO-AA-10, and Decommissioning Quality Assurance Program, NO-DC-10 RS-23-002, Application to Adopt TSTF-332, ECCS Response Time Testing2023-01-13013 January 2023 Application to Adopt TSTF-332, ECCS Response Time Testing RS-22-126, Constellation Energy Generation, LLC - Request to Use Provisions of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI2022-11-30030 November 2022 Constellation Energy Generation, LLC - Request to Use Provisions of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI RS-22-121, Notice of Intent to Pursue Subsequent License Renewal Applications2022-11-0909 November 2022 Notice of Intent to Pursue Subsequent License Renewal Applications RS-22-092, Nine and Quad Cities - Application to Revise Primary Containment Isolation Instrumentation Technical Specifications in Accordance with TSTF-306, Revision 2, Add Action to LCO 3.3.6.1 to Give Option to Isolate the Penetration2022-10-0303 October 2022 Nine and Quad Cities - Application to Revise Primary Containment Isolation Instrumentation Technical Specifications in Accordance with TSTF-306, Revision 2, Add Action to LCO 3.3.6.1 to Give Option to Isolate the Penetration RS-22-107, Annual Report of Emergency Core Cooling System Evaluation Model Changes and Errors for Clinton Power Station2022-09-29029 September 2022 Annual Report of Emergency Core Cooling System Evaluation Model Changes and Errors for Clinton Power Station RS-22-093, Advisement of Leadership Changes for Constellation Energy Generation, LLC and Submittal of Updated Standard Practice Procedures Plans2022-08-18018 August 2022 Advisement of Leadership Changes for Constellation Energy Generation, LLC and Submittal of Updated Standard Practice Procedures Plans RS-22-089, Additional Information Supporting Request for License Amendment to Revise the Secondary Containment Design Basis to Credit the Fuel Building Railroad Airlock2022-07-25025 July 2022 Additional Information Supporting Request for License Amendment to Revise the Secondary Containment Design Basis to Credit the Fuel Building Railroad Airlock RS-22-061, Request for License Amendment to Adopt TSTF-269, Revision 2, Allow Administrative Means of Position Verification for Locked or Sealed Valves2022-05-24024 May 2022 Request for License Amendment to Adopt TSTF-269, Revision 2, Allow Administrative Means of Position Verification for Locked or Sealed Valves RS-22-060, Request for License Amendment to Adopt TSTF-230, Revision 1, Add New Condition B to LCO 3.6.2.3, RHR Suppression Pool Cooling2022-05-24024 May 2022 Request for License Amendment to Adopt TSTF-230, Revision 1, Add New Condition B to LCO 3.6.2.3, RHR Suppression Pool Cooling RS-22-068, Constellation Radiological Emergency Plan Addendum Revision2022-05-19019 May 2022 Constellation Radiological Emergency Plan Addendum Revision RS-22-055, Submittal of Preliminary Decommissioning Cost Estimate and Spent Fuel Management Plan2022-04-18018 April 2022 Submittal of Preliminary Decommissioning Cost Estimate and Spent Fuel Management Plan RS-22-051, Constellation Energy Generation, LLC - Update to Correspondence Addressees and Service Lists2022-04-12012 April 2022 Constellation Energy Generation, LLC - Update to Correspondence Addressees and Service Lists RS-22-020, Request for License Amendment to Revise the Secondary Containment Design Basis to Credit the Fuel Building Railroad Airlock2022-04-0707 April 2022 Request for License Amendment to Revise the Secondary Containment Design Basis to Credit the Fuel Building Railroad Airlock RS-22-049, Constellation Energy Generation, LLC, Supplemental Information to Correct Typographical Errors in Constellation'S Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for2022-04-0404 April 2022 Constellation Energy Generation, LLC, Supplemental Information to Correct Typographical Errors in Constellation'S Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for V RS-22-045, Constellation Energy Generation, LLC, Response to NRC Regulatory Issue Summary 2022-01, Preparation and Scheduling of Operator Licensing Examinations2022-03-25025 March 2022 Constellation Energy Generation, LLC, Response to NRC Regulatory Issue Summary 2022-01, Preparation and Scheduling of Operator Licensing Examinations RS-22-027, Constellation, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated2022-02-23023 February 2022 Constellation, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated P RS-22-023, Constellation Energy Generation, LLC, Executed Trust Fund Agreement Amendment and Subordinate Trust Agreement2022-02-23023 February 2022 Constellation Energy Generation, LLC, Executed Trust Fund Agreement Amendment and Subordinate Trust Agreement RS-22-019, Constellation Energy Generation, LLC - Update to Correspondence Addressees and Service Lists2022-02-16016 February 2022 Constellation Energy Generation, LLC - Update to Correspondence Addressees and Service Lists RS-22-015, Notification of Completion of License Transfer and Request to Continue Processing Pending NRC Actions Previously Requested by Exelon Generation Company, LLC2022-02-0101 February 2022 Notification of Completion of License Transfer and Request to Continue Processing Pending NRC Actions Previously Requested by Exelon Generation Company, LLC RS-22-004, Supplement to Application to Adopt TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements2022-01-0404 January 2022 Supplement to Application to Adopt TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements RS-21-121, Proposed Changes to Decommissioning Trust Agreements and Master Terms2021-12-15015 December 2021 Proposed Changes to Decommissioning Trust Agreements and Master Terms RS-21-102, Annual Report of Emergency Core Cooling System Evaluation Model Changes and Errors2021-09-29029 September 2021 Annual Report of Emergency Core Cooling System Evaluation Model Changes and Errors RS-21-091, Implementation of Insider Threat Program Requirements Associated with the Voluntary Security Clearance Program and Advisement of Leadership Changes2021-09-13013 September 2021 Implementation of Insider Threat Program Requirements Associated with the Voluntary Security Clearance Program and Advisement of Leadership Changes RS-21-087, Additional Information Supporting Request for License Amendment to Revise Degraded Voltage Relay Allowable Values2021-08-31031 August 2021 Additional Information Supporting Request for License Amendment to Revise Degraded Voltage Relay Allowable Values RS-21-078, Response to Request for Additional Information for Application to Revise Technical Specification to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements, and TSTF-583-T, TSTF-582 Diesel2021-08-19019 August 2021 Response to Request for Additional Information for Application to Revise Technical Specification to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements, and TSTF-583-T, TSTF-582 Diesel RS-21-076, Application to Adopt TSTF-273, Safety Function Determination Program Clarifications2021-07-30030 July 2021 Application to Adopt TSTF-273, Safety Function Determination Program Clarifications RS-21-070, Proposed Alternative to Utilize Code Case N-8932021-06-30030 June 2021 Proposed Alternative to Utilize Code Case N-893 RS-21-063, Application to Adopt TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements2021-06-30030 June 2021 Application to Adopt TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements RS-21-069, Third Inservice Inspection Interval Relief Request I3R-182021-06-28028 June 2021 Third Inservice Inspection Interval Relief Request I3R-18 RS-21-054, Response to NRC Regulatory Issue Summary 2021-01, Preparation and Scheduling of Operator Licensing Examinations2021-04-29029 April 2021 Response to NRC Regulatory Issue Summary 2021-01, Preparation and Scheduling of Operator Licensing Examinations RS-21-039, Supplemental Information Regarding Application for Order Approving Transfers and Proposed Conforming License Amendments2021-03-25025 March 2021 Supplemental Information Regarding Application for Order Approving Transfers and Proposed Conforming License Amendments RS-21-037, Response to Request for Additional Information Regarding License Amendment Request to Adopt TSTF-505, Revision 22021-03-23023 March 2021 Response to Request for Additional Information Regarding License Amendment Request to Adopt TSTF-505, Revision 2 RS-21-028, Fitness for Duty Performance Data Reports - Annual 20202021-02-26026 February 2021 Fitness for Duty Performance Data Reports - Annual 2020 RS-21-032, Amended Decommissioning Trust Agreements2021-02-25025 February 2021 Amended Decommissioning Trust Agreements RS-21-014, License Amendment Request for One-Time Extension of the Containment Type a Integrated Leakage Rate Test Frequency2021-02-24024 February 2021 License Amendment Request for One-Time Extension of the Containment Type a Integrated Leakage Rate Test Frequency RS-21-030, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations2021-02-24024 February 2021 Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations RS-21-005, Request for License Amendment to Revise Degraded Voltage Relay Allowable Values2021-01-20020 January 2021 Request for License Amendment to Revise Degraded Voltage Relay Allowable Values RS-21-001, Revised Proposed Alternative to Utilize Code Cases N-878 and N-880 for Carbon Steel Piping2021-01-0404 January 2021 Revised Proposed Alternative to Utilize Code Cases N-878 and N-880 for Carbon Steel Piping 2023-09-07
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AmerGen Energy Company, LLC www.exeloncorp.com AmerGen An Exelon Company SM 4300 Winfield Road Warrenville, IL60555 RS-05-068 10 CFR 2.390 10 CFR 50.90 May 25, 2005 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Clinton Power Station Facility Operating License No. NPF-62 NRC Docket No. 50461
Subject:
Affidavit for Withholding of Global Nuclear Fuel Proprietary Information in Support of Onsite Spent Fuel Storage Expansion
Reference:
Letter from Keith R. Jury (AmerGen Energy Company, LLC) to U. S. Nuclear Regulatory Commission, "Request for Technical Specification Change to Support Onsite Spent Fuel Storage Expansion," dated August 18, 2004 In the referenced letter, AmerGen Energy Company, LLC (AmerGen) requested a change to the Technical Specifications for Clinton Power Station (CPS), Unit 1, to reflect the addition of fuel storage capacity in the fuel cask storage pool and increased fuel storage capacity in the spent fuel pool. Specifically, the proposed expansion will increase the total storage space at CPS from 2,512 to 4,159 fuel assemblies. This extra capacity is expected to allow operation without loss of full core discharge capability until the 15t refueling outage (i.e., C1 RI5) in the year 2016.
The referenced letter contained information that was proprietary to Holtec International and an affidavit was provided with the referenced letter requesting the withholding of the proprietary information from public disclosure. However, a portion of this information (i.e., Table 4-1 of Attachment 5 to the referenced letter) was actually proprietary to Global Nuclear Fuel (GNF) and it was determined that a separate affidavit from GNF was required to withhold the GNF information from public disclosure. Therefore, AmerGen requests that the information be withheld from public disclosure in accordance with 10 CFR 2.390, "Public inspections, exemptions, requests for withholding," and 10 CFR 9.17, "Agency records exempt from public disclosure," paragraph (a)(4). The required affidavit is provided as Attachment 1 to this letter.
Attachment 2 provides the table containing proprietary information marked in accordance with the requirements of 10 CFR 2.390. Attachment 3 provides the non-proprietary version of the table.
May 25, 2005 U. S. Nuclear Regulatory Commission Page 2 If you have any questions concerning this letter, please contact Mr. Timothy A. Byam at (630) 657-2804.
Respectfully, Patrick R. Simpson Manager - Licensing Attachments:
- 1. Affidavit
- 2. Table 4-1 'Fuel Assembly Design Specifications Used in the Analyses" (Proprietary Version)
- 3. Table 4-1 "Fuel Assembly Design Specifications Used in the Analyses" (Non-Proprietary Version)
ATTACHMENT I Affidavit
Affidavit Affidavit I, Margaret E. Harding, state as follows:
(1) I am Manager, Fuel Engineering Services, Global Nuclear Fuel - Americas, L.L.C. ("GNF-A") and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.
(2) The information sought to be withheld is contained in the attachment, "HI-2033124." GNF proprietary information is indicated by enclosing it in double brackets. In each case, the superscript notation 131 refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.
(3) In making this application for withholding of proprietary information of which it is the owner or licensee, GNF-A relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4) and 2.390(a)(4) for "trade secrets and commercial or financial information obtained from a person and privileged or confidential" (Exemption 4). The material for which exemption from disclosure is here sought is all "confidential commercial information," and some portions also qualify under the narrower definition of "trade secret," within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatorv Commission. 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704F2dl280 (DC Cir. 1983).
(4) Some examples of categories of information which fit into the definition of proprietary information are:
- a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GNF-A's competitors without license from GNF-A constitutes a competitive economic advantage over other companies;
- b. Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;
- c. Information which reveals cost or price information, production capacities, budget levels, or commercial strategies of GNF-A, its customers, or its suppliers;
- d. Information which reveals aspects of past, present, or future GNF-A customer-funded development plans and programs, of potential commercial value to GNF-A;
- e. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.
The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b., above.
Affidavit (5) To address the 10 CFR 2.390 (b) (4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GNF-A, and is in fact so held. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in (6) and (7) following. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GNF-A, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence.
(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or subject to the terms under which it was licensed to GNF-A. Access to such documents within GNF-A is limited on a "need to know" basis.
(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GNF-A are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.
(8) The information identified in paragraph (2) is classified as proprietary because it contains details of GNF-A's fuel designs.
(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GNF-A's competitive position and foreclose or reduce the availability of profit-making opportunities. The fuel design and licensing methodology is part of GNF-A's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost.
The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.
The research, development, engineering, analytical, and NRC review costs comprise a substantial investment of time and money by GNF-A or its licensor.
The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.
GNF-A's competitive advantage will be lost if its competitors are able to use the results of the GNF-A experience to normalize or verify their own process or if
Affidavit they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.
The value of this information to GNF-A would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GNF-A of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable analytical tools.
I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.
Executed at Wilmington, North Carolina, this 24th day of February, 2005.
MarlNucl E.arFlA c Global Nuclear Fuel - Amerc
ATTACHMENT 3 Table 4-1 "Fuel Assembly Design Specifications Used in the Analyses" (Non-Proprietary Version)
Table 4-1 FUEL ASSEMBLY DESIGN SPECIFICATIONS USED IN THE ANALYSES FUEL ROD DATA GE-6 GE-7 GE-8 GE-10 GE-14 Cladding outside (( ] (( )) E[ ))
diameter, in. R 1 1 1 1 Cladding inside diameter, in.
Cladding material Pellet diameter, in.
E[ 1] Er 1] E[ 1] (( )) Er ))
Enrichment (design basis) Er 1] Er 1] Er )) Er )) (( ))
U0 2 density (stack), g/cc U0 2 Er 11 11 1[E I Er [1 [r11 1 WATER ROD DATA Number of water rods (( )) Er 1] ff )) [I )) (( ]1 Inside diameter, inch E 1 1] E JI Er 1] Er 1] Er 1]
Outside diameter Er )) [E )) [E R ] Er )) [I 1]
Material Er )) EE )) EE )) [ I] Er ))
FUEL ASSEMBLY DATA Fuel rod array [E 1]
Er 1] Er 1] Er 1] Er ))
Number of fuel rods EE )) EE )) Er )) Er )) E[ ))
Fuel rod pitch, inch (( )) it )) Er' )) Er )) Er ))
Fuel channel, material (( )) (( )) (( )) EE )) Er ))
Inside dimension, inch Er )) Er 1 Efi ] Er )) EE ))
Channel Thickness, inch EE I] EE 1] Er 1] Er 1 EE 1]
Holtec Report HI-2033124 4-20 1342 The data enclosed in double brackets are Proprietary to GNF Company