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Category:Legal-Affidavit
MONTHYEARL-2023-034, Relief Request 4RA-22-001, Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2)2023-02-24024 February 2023 Relief Request 4RA-22-001, Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2) SBK-L-22094, Relief Request 4RA-22-001, Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2)2022-10-26026 October 2022 Relief Request 4RA-22-001, Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2) ML18151A1442018-05-31031 May 2018 Hearing File Update ML15149A2832015-05-26026 May 2015 PWROG-15042-P, Revision 0, Appendix a, NextEra Energy, Seabrook, Unit 1, Summary Report for the Cold Work Assessment (Non-Proprietary). Application for Withholding Proprietary Information from Disclosure and Affidavit ML15072A0372015-03-0909 March 2015 Enclosures 1 and 2 - Response to Request for Additional Information for License Amendment Request 14-04 Revised Reactor Coolant System Pressure - Temperature Limits Applicable for 55 Effective Full Power Years and Affidavit SBK-L-12176, Response to Request for Additional Information Regarding Relief Request for Service Water Piping2012-09-0707 September 2012 Response to Request for Additional Information Regarding Relief Request for Service Water Piping SBK-L-12054, Response to Request for Additional Information Regarding License Amendment Request 10-02, Application for Change to the Technical Specifications for the Containment Enclosure Emergency Air Cleanup System2012-03-15015 March 2012 Response to Request for Additional Information Regarding License Amendment Request 10-02, Application for Change to the Technical Specifications for the Containment Enclosure Emergency Air Cleanup System SBK-L-11190, Supplement to Request for Closed Meeting to Discuss Proprietary Test2011-09-19019 September 2011 Supplement to Request for Closed Meeting to Discuss Proprietary Test SBK-L-11184, Response to Request for Additional Information Regarding License Amendment Request 10-02, Regarding the Containment Enclosure Emergency Air Cleanup System2011-09-16016 September 2011 Response to Request for Additional Information Regarding License Amendment Request 10-02, Regarding the Containment Enclosure Emergency Air Cleanup System ML11223A4462011-08-0808 August 2011 (Friends of the Coast, New England Coalition) Declaration of Dr. Arjun Makhijani Regarding Safety and Environmental Significance of NRC Task Force Report Regarding Lessons Learned from Fukushima Daiichi Nuclear Power Station Accident ML11223A3772011-08-0808 August 2011 (Beyond Nuclear, Seacoast Antipollution League, Sierra Club of Nh) Declaration of Dr. Arjun Makhijani Safety and Environmental Significance of NRC Task Force Report Regarding Lessons Learned from Fukushima Daiichi Nuclear Power Station Acci ML1111000032011-04-20020 April 2011 Declaration and Cv of Dr. Arjun Makhijani in Support of Emergency Petition to Suspend All Pending Reactor Licensing Decisions and Related Rulemaking Decisions Pending Investigation of Lessons Learned from Fukushima Daiichi Power Station Acc ML1111000052011-04-19019 April 2011 Letter to Commissioners Transmitting Declaration and Cv of Dr. Arjun Makhijani in Support of Emergency Petition to Suspend All Pending Reactor Licensing Decisions and Related Rulemaking Decisions . . ML1110504752011-04-15015 April 2011 Certificate of Service for Emergency Petition to Suspend All Pending Reactor Licensing Decisions and Related Rulemaking Decisions Pending Investigation of Lessons Learned from Fukushima Daiichi Nuclear Power Station Accident ML1106805352011-03-0909 March 2011 Certificate of Service for Commonwealth of Massachusetts' Request to Participate as an Interested State, and Notice of Appearance of Matthew Brock on Behalf of the Commonwealth of Massachusetts SBK-L-08039, License Amendment Request 08-01, Application for Change to the Technical Specification Surveillance Requirements for Nuclear Instrumentation2008-03-0707 March 2008 License Amendment Request 08-01, Application for Change to the Technical Specification Surveillance Requirements for Nuclear Instrumentation SBK-L-08005, License Amendment Request 07-04 Application for Amendment to Delete Post-Maintenance Testing Surveillance Requirement for Containment Isolation Valves2008-02-0808 February 2008 License Amendment Request 07-04 Application for Amendment to Delete Post-Maintenance Testing Surveillance Requirement for Containment Isolation Valves SBK-L-07112, License Amendment Request 07-02, Application to Revise the Technical Specifications Regarding Control Room Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process.2007-07-17017 July 2007 License Amendment Request 07-02, Application to Revise the Technical Specifications Regarding Control Room Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process. SBK-L-07042, License Amendment Request 07-01 Setpoint Change for Reactor Trip System Interlock P-92007-03-29029 March 2007 License Amendment Request 07-01 Setpoint Change for Reactor Trip System Interlock P-9 SBK-L-06166, Proprietary Information to Support Response to Request for Additional Information Re License Amendment Request 05-08, Limited Inspection of Steam Generator Tube Portion within the Tubesheet.2006-08-0808 August 2006 Proprietary Information to Support Response to Request for Additional Information Re License Amendment Request 05-08, Limited Inspection of Steam Generator Tube Portion within the Tubesheet. ML0534903472005-12-12012 December 2005 Caldon Inc. Proprietary Information Package, INFO-18 SBK-L-05186, License Amendment Request 05-08, Limited Inspection of the Steam Generator Tube Portion within the Tubesheet2005-09-29029 September 2005 License Amendment Request 05-08, Limited Inspection of the Steam Generator Tube Portion within the Tubesheet SBK-L-04052, Re-submittal of Proprietary Information to Support License Amendment Request 04-03, Application for Stretch Power Uprate2004-09-13013 September 2004 Re-submittal of Proprietary Information to Support License Amendment Request 04-03, Application for Stretch Power Uprate 2023-02-24
[Table view] Category:Letter
MONTHYEARML24009A1152024-01-29029 January 2024 Exemption from Select Requirements of 10 CFR Part 73 (EPID L 2023 LLE-0043 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) L-2024-010, Point Units 3 and 4, Seabrook, Duane Arnold, and Point Beach Units 1 and 2, Nuclear Property Insurance - 10 CFR 50.54(w)(3)2024-01-25025 January 2024 Point Units 3 and 4, Seabrook, Duane Arnold, and Point Beach Units 1 and 2, Nuclear Property Insurance - 10 CFR 50.54(w)(3) ML24022A0652024-01-22022 January 2024 Senior Reactor and Reactor Operator Initial License Examinations L-2024-003, NextEra Energy Seabrook, LLC - 10 CFR 50.46 - Emergency Core Cooling System LBLOCA 30-Day Report2024-01-11011 January 2024 NextEra Energy Seabrook, LLC - 10 CFR 50.46 - Emergency Core Cooling System LBLOCA 30-Day Report ML23312A1822023-12-22022 December 2023 Issuance of Amendment No. 172 Revision to Cooling Tower Service Water Loop or Cell Requirements L-2023-173, Quality Assurance Topical Report (FPL-1) Revision 30 Update2023-12-15015 December 2023 Quality Assurance Topical Report (FPL-1) Revision 30 Update L-2023-180, Submittal of Changes to the Technical Specification Bases2023-12-13013 December 2023 Submittal of Changes to the Technical Specification Bases L-2023-177, Supplement to Seabrook Exemption Request Regarding Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Final Rule2023-11-29029 November 2023 Supplement to Seabrook Exemption Request Regarding Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Final Rule L-2023-155, Supplement to Response to Request for Additional Information, Revised NextEra Common Emergency Plan, and Revised Site-Specific Emergency Plan Annexes Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-06542023-11-28028 November 2023 Supplement to Response to Request for Additional Information, Revised NextEra Common Emergency Plan, and Revised Site-Specific Emergency Plan Annexes Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, L-2023-160, Part 73 Exemption Request Regarding Enhanced Weapons, Firearms, Background Checks, and Security Event Notifications Final Rule2023-11-16016 November 2023 Part 73 Exemption Request Regarding Enhanced Weapons, Firearms, Background Checks, and Security Event Notifications Final Rule ML23318A0772023-11-14014 November 2023 Request for Information and Notification of Conduct of IP 71111.21.N.04, Age-Related Degradation, Reference Inspection Report 05000443/2024011 IR 05000443/20234032023-11-0707 November 2023 Security Baseline Inspection Report 05000443/2023403 and Independent Spent Fuel Storage Installation 07200063/2023401 IR 05000443/20230032023-11-0606 November 2023 Integrated Inspection Report 05000443/2023003 IR 05000443/20230102023-10-19019 October 2023 Triennial Fire Protection Inspection Report 05000443/2023010 ML23346A1322023-10-0606 October 2023 Communication from C-10 Research & Education Foundation Regarding NextEra Common Emergency Fleet Plan License Amendment Request and Related Documents Subsequently Published ML23275A0522023-10-0202 October 2023 Requalification Program Inspection IR 05000443/20234012023-09-0808 September 2023 Cybersecurity Inspection Report 05000443/2023401 (Cover Letter Only) IR 05000443/20234202023-09-0505 September 2023 Security Baseline Inspection Report 05000443/2023420 IR 05000443/20230052023-08-31031 August 2023 Updated Inspection Plan for Seabrook Station (Report 05000443/2023005) L-2023-114, Proposed Turkey Point Units 6 and 7; Seabrook Station; Point Beach Units 1 and 2 - Official Service List Update2023-08-17017 August 2023 Proposed Turkey Point Units 6 and 7; Seabrook Station; Point Beach Units 1 and 2 - Official Service List Update IR 05000443/20233022023-08-16016 August 2023 Operator Licensing Retake Examination Report 05000443/2023302 IR 05000443/20230022023-08-0808 August 2023 Integrated Inspection Report 05000443/2023002 L-2023-098, and Point Beach Units 1 and 2 - Response to Request for Additional Information Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 22023-08-0707 August 2023 and Point Beach Units 1 and 2 - Response to Request for Additional Information Regarding License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 2 ML23201A0872023-08-0303 August 2023 Audit Plan in Support of Review of License Amendment L-2023-104, Preparation and Scheduling of Operator Licensing Examinations2023-08-0303 August 2023 Preparation and Scheduling of Operator Licensing Examinations L-2023-103, Inservice Inspection Examination Report2023-08-0303 August 2023 Inservice Inspection Examination Report ML23192A0782023-07-11011 July 2023 Operator Licensing Retake Examination Approval L-2023-087, Florida Power & Light/Nextera Energy, Results of the Safety Culture Program Effectiveness Review, March 20, 2023 (ADAMS Accession No. ML22340A452)2023-06-29029 June 2023 Florida Power & Light/Nextera Energy, Results of the Safety Culture Program Effectiveness Review, March 20, 2023 (ADAMS Accession No. ML22340A452) SBK-L-23053, Radiological Emergency Plan (Ssrep), Revision 802023-06-22022 June 2023 Radiological Emergency Plan (Ssrep), Revision 80 ML23157A0722023-06-0606 June 2023 Notification of Conduct of a Fire Protection Team Inspection L-2023-074, Addendum to 2021 Decommissioning Funding Status Reports / Independent Spent Fuel Storage Installation Ctsfsi) Financial Assurance Update2023-06-0202 June 2023 Addendum to 2021 Decommissioning Funding Status Reports / Independent Spent Fuel Storage Installation Ctsfsi) Financial Assurance Update L-2023-071, NextEra Energy Quality Assurance Topical Report (FPL-1) Revision 29 and Florida Power and Light Company Quality Assurance Program Description for 10 CFR Part 52 Licenses (FPL-2) Revision 11, Annual Submittal2023-05-22022 May 2023 NextEra Energy Quality Assurance Topical Report (FPL-1) Revision 29 and Florida Power and Light Company Quality Assurance Program Description for 10 CFR Part 52 Licenses (FPL-2) Revision 11, Annual Submittal IR 05000443/20233012023-05-15015 May 2023 Initial Operator Licensing Examination Report 05000443/2023301 L-2023-064, License Amendment Request 23-01, Revision 1, Update the Period of Applicability (Poa) for the Pressure-Temperature Limits (PTL) and Low Temperature Overpressure Protection (L Top) Curves2023-05-11011 May 2023 License Amendment Request 23-01, Revision 1, Update the Period of Applicability (Poa) for the Pressure-Temperature Limits (PTL) and Low Temperature Overpressure Protection (L Top) Curves IR 05000443/20230012023-05-11011 May 2023 Integrated Inspection Report 05000443/2023001 ML23129A0312023-05-0909 May 2023 Reactor Operator Retake License Examination ML23117A3652023-05-0404 May 2023 Supplemental Information Needed for Acceptance of Requested Licensing Action Amendment Request to Remove Period of Applicability from PTL and Low Temperature Over Pressure Protection Curves SBK-L-23044, 2022 Annual Radiological Environmental Operating Report2023-04-28028 April 2023 2022 Annual Radiological Environmental Operating Report SBK-L-23031, 2022 Annual Radioactive Effluent Release Report2023-04-28028 April 2023 2022 Annual Radioactive Effluent Release Report SBK-L-23033, 2022 Annual Environmental Operating Report2023-04-11011 April 2023 2022 Annual Environmental Operating Report L-2023-053, Core Operating Limits Report for Cycle 232023-04-0505 April 2023 Core Operating Limits Report for Cycle 23 ML23088A1522023-03-29029 March 2023 Summary of Meeting Between Nrc/Region I and C-10 - Questions Regarding Seabrook 4Q2022 Inspection Report L-2023-021, Units, 1 and 2, Turkey Point, Units 3 and 4, Seabrook Station and Point Beach, Units 1 and 2 - Decommissioning Funding Status Reports / Independent Spent Fuel Storage Installation (ISFSI) Financial Assurance Update2023-03-28028 March 2023 Units, 1 and 2, Turkey Point, Units 3 and 4, Seabrook Station and Point Beach, Units 1 and 2 - Decommissioning Funding Status Reports / Independent Spent Fuel Storage Installation (ISFSI) Financial Assurance Update L-2023-028, and Point Beach Units 1 and 2, 10 CFR 50.46 Annual Reporting of Changes to, or Errors in Emergency Core Cooling System Models or Applications2023-03-27027 March 2023 and Point Beach Units 1 and 2, 10 CFR 50.46 Annual Reporting of Changes to, or Errors in Emergency Core Cooling System Models or Applications ML23073A1562023-03-23023 March 2023 Relief Request 4RA-22-01, Relief from the Requirements of the ASME Code L-2023-012, License Amendment Request 23-01, Remove Period of Applicability (Poa) from Pressure Temperature Limits (PTL) and Low Temperature Overpressure Protection (L Top) Curves2023-03-15015 March 2023 License Amendment Request 23-01, Remove Period of Applicability (Poa) from Pressure Temperature Limits (PTL) and Low Temperature Overpressure Protection (L Top) Curves L-2023-025, Fleet Relief Request (Frr) 23-01, Proposed Alternative to ASME Section XI Authorizing Implementation of ASME Code Case N-752-12023-03-15015 March 2023 Fleet Relief Request (Frr) 23-01, Proposed Alternative to ASME Section XI Authorizing Implementation of ASME Code Case N-752-1 L-2023-029, and Point Beach Units 1 and 2 Nuclear Property Insurance - 10 CFR 50.54(w)(3)2023-03-10010 March 2023 and Point Beach Units 1 and 2 Nuclear Property Insurance - 10 CFR 50.54(w)(3) L-2023-023, Revised Steam Generator Tube Inspection Report2023-03-0303 March 2023 Revised Steam Generator Tube Inspection Report ML23020A1002023-03-0303 March 2023 OEDO-22-00419 - 2.206 Petition for Seabrook Station Structure Concrete Concerns (EPID L-2022-CRS-0000)- Closure Letter 2024-01-29
[Table view] Category:Proprietary Information Review
MONTHYEARML17088A6742018-08-17017 August 2018 Request for Withholding Information from Public Disclosure ML17017A3742017-02-27027 February 2017 Request for Withholding Information from Public Disclosure ML16230A1822016-09-0101 September 2016 Proprietary Information Determination ML15173A1202015-07-14014 July 2015 Request for Withholding Information from Public Disclosure ML15128A1482015-06-0505 June 2015 Request for Withholding Information from Public Disclosure Regarding License Amendment Request 14-04 for Seabrook Station, Unit 1 ML15084A3752015-04-0303 April 2015 Request for Withholding Information from Public Disclosure Regarding License Amendment Request 14-04 for Seabrook Station, Unit 1 (TAC Nos. MF4576 and MF4577) ML14168A2472014-07-17017 July 2014 Request for Withholding Information from Public Disclosure for Seabrook Station, Unit No. 1 ML14078A1062014-04-18018 April 2014 Request for Withholding Information from Public Disclosure Regarding License Amendment Request 13-05, Fixed Incore Detector System Analysis Methodology ML14078A6242014-04-18018 April 2014 Request for Withholding Information from Public Disclosure Regarding License Amendment Request 11-04, Changes to Technical Specifications for New Fuel Vault ML13263A1382013-10-21021 October 2013 Request for Withholding Information from Public Disclosure Regarding License Amendment Request 13-05, Fixed Incore Detector System Analysis Methodology ML13156A1252013-06-0404 June 2013 Request for Withholding Information from Public Disclosure (Seabrook Nuclear Power Station: Response to Confirmatory Action Letter - CAL No. 2012-002) ML13094A4092013-05-0202 May 2013 Request for Withholding Information from Public Disclosure Regarding License Amendment Request 11-04, Changes to Technical Specifications for New and Spent Fuel Storage ML13095A1012013-05-0202 May 2013 Request for Withholding Information from Public Disclosure Regarding License Amendment Request 11-04, Changes to Technical Specifications for New and Spent Fuel Storage ML13095A0262013-04-26026 April 2013 Request for Withholding Information from Public Disclosure Regarding License Amendment Request 11-04, Changes to Technical Specifications for New and Spent Fuel Storage ML13095A1222013-04-26026 April 2013 Request for Withholding Information from Public Disclosure Regarding License Amendment Request 11-04, Changes to Technical Specifications for New and Spent Fuel Storage ML13088A2622013-04-0303 April 2013 Request for Withholding Information from Public Disclosure (Seabrook Nuclear Power Station - Response to Confiromatory Action Letter - CAL No. 2012-002) ML12270A4312012-10-0202 October 2012 Request for Withholding Infomation from Public Disclosure Regarding License Amendment Request 11-04, Changes to Technical Specifications for New and Spent Fuel Storage ML12256B0372012-09-26026 September 2012 Request for Withholding Information from Public Disclosure Regarding Relief Request for Service Water Piping ML1126404932011-10-0606 October 2011 Request for Withholding Information from Public Disclosure ML0722000282007-08-21021 August 2007 Westinghouse Electric Company, Request for Withholding Information from Public Disclosure for Seabrook Station, Unit No. 1 ML0626804622006-09-27027 September 2006 Westinghouse Electric Company, LLC, Request for Withholding Information from Public Disclosure for Seabrook Station, Unit No. 1 ML0625100622006-09-19019 September 2006 Westinghouse Electric Company, LLC - Request for Withholding Information from Public Disclosure for Seabrook Station, Unit No. 1 ML0534701812005-12-16016 December 2005 Caldon, Inc., Request for Withholding Information from Public Disclosure During NRC Meeting to Discuss Seabrook Measurement Uncertainty Recapture License Amendment Request ML0534903472005-12-12012 December 2005 Caldon Inc. Proprietary Information Package, INFO-18 ML0532601922005-11-28028 November 2005 FPL Energy Seabrook, LLC, Request for Withholding Information from Public Disclosure for Seabrook Station ML0430803222004-11-19019 November 2004 Withholding from Public Disclosure, Westinghouse Responses to NRC Requests for Additional Information (Rais) for Seabrook Station Stretch Power Uprate (Proprietary) ML0409804772004-10-14014 October 2004 Request for Withholding Information from Public Disclosure, Stretch Power Uprate NSSS Licensing Report Supplemental Information, WCAP-16223-NP 2018-08-17
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Caldon, Inc.
December 12,2005 Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
Caldon Inc. Proprietary Information Package, INFO-18 Gentlemen, The enclosed information is provided along with an application for withholding proprietary information from public disclosure. The material will be used to support a presentation to the NRC Staff during the Seabrook/NRC Meeting on Friday December 16th, 2005. A copy of the application for withholding has been faxed to Mr. Ed Miller, NRC Project Manager for Seabrook Station.
Processing of this information expediently is appreciated.
Regards, c aALOwl Leeanne Jozwiak Sales Engineer 40D 1070 Banksville Avenue
- Pittsburgh, PA 15216 Tel: 412-341-9920. Fax: 412-341-9951 . Web: www.caldon.net
Caldon, Inc.
December 12, 2005 CAW 05-01 Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
"Proprietary Information Package for Seabrook/NRC Meeting December 16, 2005, INFO-1 8" Gentlemen:
This application for withholding is submitted by Caldon, Inc. ("Caldon") pursuant to the provisions of paragraph (b)(1) of Section 2.390 of the Commission's regulations. It contains trade secrets and/or commercial information proprietary to Caldon and customarily held in confidence.
The proprietary information for which withholding is being requested is identified in the subject submittal. In conformance with 10 CFR Section 2.390, Affidavit CAW-05-01 accompanies this application for withholding setting forth the basis on which the identified proprietary information may be withheld from public disclosure.
Accordingly, it is respectfully requested that the subject information, which is proprietary to Caldon, be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.
Correspondence with respect to this application for withholding or the accompanying affidavit should reference CAW-05-01 and should be addressed to the undersigned.
Very truly yours, e6o4 Calvin R. Hastings President and CEO Enclosures 1070 Banksville Avenue
- Pittsburgh, PA 15216 Tel: 412-341-9920
Caldon Proprietary Information Package for Seabrook/NRC Meeting December 16, 2005 INFO-18 Table of Content Attachment to Affidavit of Calvin R. Hastings, dated December 12, 2005
- 1. ER275 Rev. 2, Bounding UncertaintyAnalysis For Thermal Power DeterminationAt DC Cook Unit 1 NPP Using the LEFM$+ System
- 2. ER-486 Rev. 1, Representative CalibrationDataforLEFM CheckAnd CheckPlus Flow Elements
- 3. ER-293 Rev. 0, Vandellos Flow Measurement Evaluation
- 4. CIB 11O Rev. 1, Evaluation of the Effects on LEFMSystems of FeedwaterSystem Noise Sources, Including But Not Limited to the "Signal Contamination" Identified by Westinghouse/AMAG in Crossflow Systems
- 5. ALD-1 081 Rev. 1, Hydraulic CalibrationPlan - SeabrookLEFM$+
- 6. ER-482 Rev. 1, Bounding UncertaintyAnalysisfor Thermal Power Determinationat Seabrook NPP Using the LEFMV+ System
- 7. EFP-61 Rev. 16 Blank, CommissioningProcedureforLEFM Check andLEFM CheckPlus Systems
- 8. FCDP-1 18 Rev. 0, Field CommissioningDataPackagefor DC Cook Unit I
- 9. ER-287 Rev. 1, Profile factor Calculationand Accuracy Assessmentfor the ,DC Cook Unit 1 LEFMV+ Spool Piece (Alden Report No. 121-02/C730) and - Related Correspondence letter datedFebruary 06, 2005.
- 10. FP&L Purchase Specification S-X-I-E-0139 Rev. 00, UltrasonicFeedwaterFlow Metering System INFO-18
December 12, 2005 CAW-05-01 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF ALLEGHENY:
Before me, the undersigned authority, personally appeared Calvin R. Hastings, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Caldon, Inc. ("Caldon") and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:
Calvin R. Hastings, President and CEO Caldon, Inc.
Sworn to and subscribed before me this j d day of
,2005
,eM~O EALTH OF PENNSYLVANIA N tiNobl Seal Joann . Thomas, Notay Public City of ittsburgh Allegheny County My Commission ipires July 29, 2007 Member, Pennsylvaena Assodation of Notarles I
- 1. I am the President and CEO of Caldon, Inc. and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rulemaking proceedings, and am authorized to apply for its withholding on behalf of Caldon.
- 2. I am making this Affidavit in conformance with the provisions of 10CFR Section 2.390 of the Commission's regulations and in conjunction with the Caldon application for withholding accompanying this Affidavit.
- 3. I have personal knowledge of the criteria and procedures utilized by Caldon in designating information as a trade secret, privileged or as confidential commercial or financial information.
- 4. Pursuant to the provisions of paragraph (b) (4) of Section 2.390 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 should be withheld.
(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Caldon.
(ii) The information is of a type customarily held in confidence by Caldon and not customarily disclosed to the public. Caldon has a rational basis for determining the types of information customarily held in confidence by it and, in that connection utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Caldon policy and provides the rational basis required. Furthermore, the information is submitted voluntarily and need not rely on the evaluation of any rational basis.
Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential advantage, as follows:
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(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Caldon's competitors without license from Caldon constitutes a competitive economic advantage over other companies.
(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.
(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, and assurance of quality, or licensing a similar product.
(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Caldon, its customer or suppliers.
(e) It reveals aspects of past, present or future Caldon or customer funded development plans and programs of potential customer value to Caldon.
(f) It contains patentable ideas, for which patent protection may be desirable.
There are sound policy reasons behind the Caldon system, which include the following:
(a) The use of such information by Caldon gives Caldon a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Caldon competitive position.
(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Caldon ability to sell products or services involving the use of the information.
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(c) Use by our competitor would put Caldon at a competitive disadvantage by reducing his expenditure of resources at our expense.
(d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Caldon of a competitive advantage.
(e) Unrestricted disclosure would jeopardize the position of prominence of Caldon in the world market, and thereby give a market advantage to the competition of those countries.
(f) The Caldon capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.
(iii) The information is being transmitted to the Commission in confidence, and, under the provisions of 10CFR Section 2. 390, it is to be received in confidence by the Commission.
(iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same manner or method to the best of our knowledge and belief.
(v) The proprietary information sought to be withheld in this submittal is that which is titled "Caldon Proprietary Information Package for Seabrook/NRC Meeting December 16, 2005, INFO-18" The information sought to be withheld is appropriately marked pursuant to 10 CFR § 2.390(b)(1)(i)(A, B) and is applicable to INFO-18 in its entirety. A listing of all the documents contained in INFO-18 is attached. This information is voluntarily submitted for use by the NRC Staff in their review of the accuracy assessment of the proposed methodology for LEFM CheckPlus Systems used by Seabrook for an MUR UPRATE.
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Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Caldon because it would enhance the ability of competitors to provide similar flow and temperature measurement systems and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without the right to use the information.
The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Caldon effort and the expenditure of a considerable sum of money.
In order for competitors of Caldon to duplicate this information, similar products would have to be developed, similar technical programs would have to be performed, and a significant manpower effort, having the requisite talent and experience, would have to be expended for developing analytical methods and receiving NRC approval for those methods.
Further the deponent sayeth not.
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