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Category:AFFIDAVITS
MONTHYEARML20203A1491986-03-10010 March 1986 Affidavit of Jh Taylor Demonstrating That Encls May Be Withheld Per 10CFR2.790 & Listing B&W Procedures for Withholding ML19343B1761980-11-13013 November 1980 Affidavit Supporting Proprietary Treatment for CEN-139(A)-P, Statistical Combination of Uncertainties.. ML20126M2581980-03-14014 March 1980 Affidavit for Withholding Proprietary Info Re Low Pressure Turbine Rotor (Ref 10CFR2.790).Nonproprietary Version Attached 1986-03-10
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20212L0841999-10-0101 October 1999 Exemption from 10CFR50,App R,Section III.G.2 to Ensure That Adequate Fire Protection Features Provided for Redundant Cables or Equipment Located in Same Fire Area Outside of Primary Containment ML20141D7351997-06-19019 June 1997 Comment Supporting Bulletin 96-001,suppl 1, Control Rod Insertion Problems. Reactor Operating W/Framatome Cogema Fuels Mark-B Fuel Requested to Be Excluded from Final Bulletin Suppl DD-97-15, Director'S Decision DD-97-15 Re Petitioners Request That NRC Prohibit Loading of VSC-24 Until Coc,Sar & SER Amended Following Independent third-party Review of VSC-24 Design. No Adequate Basis Exists for Granting Petitioners Request1997-06-18018 June 1997 Director'S Decision DD-97-15 Re Petitioners Request That NRC Prohibit Loading of VSC-24 Until Coc,Sar & SER Amended Following Independent third-party Review of VSC-24 Design. No Adequate Basis Exists for Granting Petitioners Request 0CAN049709, Comment Supporting Proposed Rev 3 to Reg Guide 1.134, Medical Evaluation of Licensed Personnel at Nuclear Power Plants1997-04-21021 April 1997 Comment Supporting Proposed Rev 3 to Reg Guide 1.134, Medical Evaluation of Licensed Personnel at Nuclear Power Plants ML20136E7591997-03-0707 March 1997 Comment Supporting Proposed Generic Communication, Effectiveness of Ultrasonic Testing Systems in Inservice Inspection Programs ML20128M3411996-09-30030 September 1996 Comment on Proposed Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20116G9431996-08-0707 August 1996 Comment Supporting Proposed Rule 10CFR26 Re, Mods to Fitness-For-Duty Program Requirements ML20099M4921995-12-18018 December 1995 Comment on Draft Suppl to GL 83-11, Licensee Qualification for Performing Safety Analyses 0CAN119504, Comment Opposing Proposed Rule 10CFR60,72,73 & 75 Re Requirements for Spent Nuclear Fuel or high-level Radwaste Stored as ISFSI1995-11-13013 November 1995 Comment Opposing Proposed Rule 10CFR60,72,73 & 75 Re Requirements for Spent Nuclear Fuel or high-level Radwaste Stored as ISFSI TXX-9522, Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources1995-08-26026 August 1995 Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources ML20086N6551995-07-14014 July 1995 Comment on Proposed Generic Ltr Re 10CFR50.54 Process for Changes to Security Plans W/O Prior NRC Approval. Agrees W/ Proposed Clarification of Language & W/Provided Screening Criteria in Notice ML20086D8841995-06-29029 June 1995 Comments on Proposed Rule Re, Review of NRC Insp Rept Content,Format & Style ML20085E5891995-06-0909 June 1995 Comment Supporting Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control ML20077E8231994-12-0808 December 1994 Comment Supporting Proposed Rules 10CFR2,51 & 54 Re Rev to NRC NPP License Renewal Rule ML20080A1331994-10-21021 October 1994 Comment Supporting Proposed Rule 10CFR2 Re Reexamination of NRC Enforcement Policy.Advises That Util of Belief That NRC Focus on Safety Significance in Insps & Enforcement Policy Can Be Achieved by Utilization of Risk Based Techniques ML20073M3261994-10-0303 October 1994 Comment on Pilot Program for NRC Recognition of Good Performance by Nuclear Power Plants ML20072B8521994-08-0505 August 1994 Comment Opposing Proposed Rule 10CFR26 Re Consideration of Changes to FFD Requirements.Licensee Believes Reduction in Amount of FFD Testing Warranted & Can Best Be Achieved in Manner Already Adopted by Commission ML20065P4121994-04-25025 April 1994 Comment on Proposed Rule 10CFR50 Rule Re Code & Stds Re Subsections IWE & Iwl.Expresses Deep Concern About Ramifications of Implementing Proposed Rule ML20058G6211993-12-0606 December 1993 Comment on Draft NUREG/BR-0058, Regulatory Analysis Guidelines,Rev 2. Concurs W/Numarc & Nubarg Comments ML20058D8581993-11-26026 November 1993 Comment on Proposed Rule 10CFR72 Re Notification of Events at Isfsi.Believes General Licenses Should Not Be Required to Use New 10CFR72.75 ML20056F3481993-08-23023 August 1993 Comment Opposing NRC Draft GL 89-10,suppl 6 0CAN059206, Comment Supporting Proposed Rule Re Elimination of Requirements Marginal to Safety1992-05-28028 May 1992 Comment Supporting Proposed Rule Re Elimination of Requirements Marginal to Safety ML20058E0251990-10-12012 October 1990 Comment Supporting Proposed Rule 10CFR51 Re Renewal of Nuclear Plant OLs & NRC Intent to Prepare Generic EIS ML20055E9871990-06-29029 June 1990 Comment Opposing Proposed Rule 10CFR55 Re Mod for fitness-for-duty Programs & Licensed Operators.Util Believes That High Stds of Conduct Will Continue to Be Best Achieved & Maintained by Program That Addresses Integrity ML20006C5721990-01-15015 January 1990 Comment Supporting Proposed Rule 10CFR50, Stabilization & Decontamination Priority,Trusteeship Provisions & Amount of Property Insurance Requirements. ML19353B2001989-12-0404 December 1989 Comment Supporting Opinions Expressed by NUMARC on Draft Reg Guide DG-1001, Maint Programs for Nuclear Power Plants. Util Supports Philosophy of Proper Maint as Important Part of Safe & Reliable Nuclear Power Plant Operation ML20247N1311989-07-0707 July 1989 Comment on Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components. Existing Regulations,Codes & Stds Including Industry Procurement Improvement Activities Are Adequate ML20235T4141989-02-24024 February 1989 Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20206M6171988-11-17017 November 1988 Comment Supporting Proposed Rule 10CFR26 Re NRC Rulemaking on Fitness for Duty Programs.Endorses NUMARC 881118 Comments on Subj Proposed Rule & Suggests Incorporation of NUMARC Suggested Changes ML20205P9691988-10-26026 October 1988 Comment Supporting Proposed Rule 10CFR50 Re NUREG-1317, Regulatory Options for Nuclear License Renewal. Supports Contents of NUREG-1317 & Endorses NUMARC Comments on Rulemaking & Position Paper by NUMARC Nuplex Working Group 0CAN088804, Comment Opposing Proposed Rules 10CFR170 & 171 Re License & Annual Fees.Nrc Portion of Cooperative Programs Should Be Taken from Remaining 55% of Funds Appropriated by Congress1988-08-0404 August 1988 Comment Opposing Proposed Rules 10CFR170 & 171 Re License & Annual Fees.Nrc Portion of Cooperative Programs Should Be Taken from Remaining 55% of Funds Appropriated by Congress ML20149E8581988-02-0404 February 1988 Order Imposing Civil Monetary Penalty in Amount of $75,000, Based on Licensee Response to Notice of Violation & Proposed Imposition of Civil Penalty by ML20236A0441987-10-13013 October 1987 Comment Opposing Proposed Rule 10CFR50 Re Rev to Backfitting Process for Power Reactors.Proposed Rule Devoid of Objective Guidance or Criteria for Distinguishing Between Cases Where cost-benefit Analysis Permissible & Where Not ML20215D6741987-06-12012 June 1987 Suppl 4 to Petition for Immediate Action to Relieve Undue Risk Posed by Nuclear Power Plants Designed by B&W.Ucs Reply to Responses from NRC & B&W Owners Group.* Certificate of Svc Encl ML20214Q6151987-06-0101 June 1987 Order Imposing Civil Monetary Penalty in Amount of $50,000 for Violation Noted in Insp on 860106-31.Evaluations & Conclusions Encl ML20210C4191987-04-0606 April 1987 Principal Response of B&W Owners Group to Petition Filed Under 10CFR2.206 by Ucs.* Petition Should Be Denied ML20205F2911987-03-23023 March 1987 Suppl 3 to Petition for Immediate Action to Relieve Undue Risk Posed by Nuclear Power Plants Designed by B&W.* Requests That Listed Names Be Added to List in Paragraph 1 of 870210 Petition ML20210C2691987-03-0606 March 1987 Initial Response of B&W Owners Group to Petition Filed Under 10CFR2.206 by Ucs.* Request for Immediate Suspension Should Be Summarily Denied.W/Certificate of Svc ML20211F5091987-02-20020 February 1987 Suppl 2 to Petition for Immediate Action to Relieve Undue Risk Posed by Nuclear Power Plants Designed by B&W.* Lists Names to Be Added to 870210 Petition & Corrects Address for Save Our State from Radwaste ML20210N4861987-02-10010 February 1987 Petition for Immediate Action to Relieve Undue Risk Posed by Nuclear Power Plants Designed by B&W Co.* OLs & CPs for Facilities Should Be Suspended Until Listed NRC Actions Taken ML20203A1491986-03-10010 March 1986 Affidavit of Jh Taylor Demonstrating That Encls May Be Withheld Per 10CFR2.790 & Listing B&W Procedures for Withholding ML20137L5911985-09-10010 September 1985 Response Opposing Jf Doherty 850611 Petition for Show Cause Order Requesting NRC to Institute Consolidated Proceeding Per 10CFR2.202.Certificate of Svc Encl ML20126A3531985-06-11011 June 1985 Petition/Request for Order to Show Cause Why Plants Should Not Be Shut Down Until CRD Mechanisms Inspected ML19343B1761980-11-13013 November 1980 Affidavit Supporting Proprietary Treatment for CEN-139(A)-P, Statistical Combination of Uncertainties.. ML20126M2581980-03-14014 March 1980 Affidavit for Withholding Proprietary Info Re Low Pressure Turbine Rotor (Ref 10CFR2.790).Nonproprietary Version Attached ML19326C6621978-09-28028 September 1978 Forwards Executed Amend 7 to Idemnity Agreement B-65, Including New Article Viii ML19326C6511978-08-0707 August 1978 Executed Amend 6 to Indemnity Agreement B-65,changing License Numbers ML19326C6531975-03-27027 March 1975 Executed Amend 3 to Indemnity Agreement B-65,increasing Liability Premiums ML19317H1351974-05-0303 May 1974 Acknowledgement of Svc of Amend 45 to Application for OL ML19326B8481973-08-10010 August 1973 Acknowledges Svc of Amend 40 to OL Application on 730810 1999-10-01
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Text
O Attachment 1 GA-CE-085
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AFFIDAVIT PURSUANT TO 10 CFR 2.790 Combustion Engineering, Inc. )
State of Connecticut )
County of Hartford ) SS.:
I, A. E. Scherer depose and say that I am the Director, Nuclear Licensing of Combustion Engineering, Inc., duly authorized to make this affidavit, and have reviewed or caused to have reviewed the information which is identified as proprietary and referenced in the paragraph immediately below. I am submitting this affidavit in confonnance with the provisions of 10 CFR 2.790 of the Commission's regulations and in conjunction with the application of Arkansas Power and Light Company, for withholding this information.
The information for which proprietary treatment is sought is contained in the following document:
CEN-139(A)-P, Statistical Combination of Uncertainties; Combination of System Parameter Uncertainties in Thermal Margin Analysis for Arkansas
( Nuclear One Unit 2, November 1980.
l l This document has been appropriately designated as proprietary.
l I have personal knowledge of the criteria and procedures utilized by Combustion Engineering in designating information as a trade secret, privileged or as confidential commercial or financial information.
Pursuant- to the provisions of paragraph (b) (4) of Section 2.790 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure, included in the above referenced document, .
I should be withheld.
- 1. Tne information sought to be withneld from public discicsure is I the method for combining uncertainties in the reference thermal margin j analysis, which is owned and has been held in confidence by Combustion Engineering.
- 2. The information consists of test data or other similar data
- concerning a process, method or component, the application of which results in a substantial competitive advantage to Combustion Engineering.
t
- 3. The information is of a type customarily held in confidence by i
Combustion Engineering and not customarily disclosed to the public.
Combustion Engineering has a rational basis for determining the types of
' information customarily held in confidence by it and, in that connection, l' utilizes a system to determiae when and whether to hold certain types of 1 information in confidence. The details of the aforementioned system were provided to the Nuclear Regulatory Commission via letter DP-537 from F.M. Stern to Frank Schroeder dated December 2,1974. This system was applied in determining that the subject documents herein are proprietary.
- 4. The information is being transmitted to the Commission in confidence i
- under the provisions of 10 CFR 2.790 with the understanding that it is to be received in confidence by the Commission.
- 5. The information, to the best of my knowledge and belief, is not l available in public sources, and any disclosure to third parties has been made pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence.
ti . Public disclosure of the information is likely to cause substantial harm to the competitive position of Combustion Engineering because:
- a. A similar product is manufactured and sold by najor. pressurized
water reactors competitors of Combustion Engineering.
- b. Development of this information by C-E required thousands of man-hours of effort and hundreds of thousands of dollars. To the best of my knowledge and belief a competitor would have to undergo similar expense in generating equivalent information.
- c. In order to acquire such information, a competitor would also require considerable time and inconvenience related to methods development, data reduction and uncertainty evalue+-ins.
- d. The information required significant effort and expense to obtain the licensing approvals necessary for. application of the information.
Avoidance of this expense would decrease a competitor's cost in applying the information and marketing the product to which the information is applicable.
I'
- e. -The information consists of the methodology and data for the statistical combination of uncertainties, the application of which provides i
a competitive economic advantage. The availability of such information to competitors would enable them to modify their product to better compete with Combustion Engineering, take marketing or cther actions to improve their product's position or impair the position of Combustion Engineering's product, and avoid developing similar data and analyses in support of their i
processes, methods or apparatus,
- f. In pricing Combustion Engineering's products and services, significant research, development, engineering, analytical, manufacturing, licensing, quality assuranc? and other costs and expenses must be included.
The ability of' Combustion Engineering's competitors to utilize such information l
without similar expenditure of resources may enable them to sell at prices
- e *--.,,,.c ,,e ,-.,,,m,_,__
reflecting significantly lower costs.
- g. Use of the information by competitors in the international marketplace would increase their ability to market nuclear steam supply systems by reducing the costs associated with their technology development.
In addition, disclosure would have an adverse economic impact on Combustion Engineering's potential for obtaining or maintaining foreign licensees.
Further the deponent sayeth not.
/
~ 4 A. E. Scfhfer Director Nuclear Licensing S en rr. to before me this f f>I' day of /bCMdG IIN j
_J LL.Mpv TA Y Ll1 Notary Public /
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