ML20236A647

Forwards Affidavit Requesting That Encl Change C to Rev 7 to PCP-001, Process Control Program for Progressive Wet Waste Be Withheld from Public Disclosure (Ref 10CFR2.790)

ML20236A647
Person / Time
Site:	Summer
Issue date:	02/21/1989
From:	House W CHEM-NUCLEAR SYSTEMS, INC.
To:	Ernst M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19302D673	List: ML20236A605 ML20236A626 ML20236A647
References
RA-0090-9, RA-90-9, NUDOCS 8903200088
Download: ML20236A647 (4)

Text

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HEM-NUCLEAR SYSTEMS, INC. H 220 Stoneridge Drive

• Columbia, South Carolina 29210 l February 21, 1989 RA-0090-9 l

Mr. M.L. Ernst  ?

Regional Administrator, Region II '

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U. S. Nuclear Regulatory Commission 101 Marietta Street, Suite 3100 i Atlanta, GA 30303 i

Dear Mr. Ernst:

Attached to.this letter is an affidavit in reference to the Semi-Annual -l Effluent and Haste Disoosal Reoort for 1988 from South Carolina Electric i and Gas. The affidavit covers the CNSI proprietary procedure submitted as part of.that report and the portion of the report directly referencing the proprietary materials.

If I can be of further assistance in this matter, please feel free'to .

contact me.

Very truly yours, CHEM-NUCLEAR SYSTEMS, INC.

6 W Hilliam B. House Director, Licensing HBH/nhs Attachment--

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• AFFIDAVITLSUBMITTED TO NUCLEAR' REGULATORY.: COMMISSION ~'

.CONCERNING CONFIDENTIAL INFORMATION AND TRADE SECRETS L* CONTAINED IN THE DEHATERING'AND' HASTE PROCESSING CONTROL PROCEDURES SUBMITTED

' REFERENCE AS'A PART.0F THE SEMI-ANNUAL EFFLUENT AND HASTE DISPOSAL' REPORT. FOR 1988 FROM . SOUTH CAROLINA ELECTRIC AND GAS' o.

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STATE OF SOUTH CAROLINA)

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COUNTY OF RICHLAND )

Hilliam.B. House states as follows on behalf of Chem-Nuclear Systems, Inc.:

1. I am the Director.of Licensing for Chem-Nuclear Systems, Inc.

2.. I have reviewed and am familiar with _the contents of the procedure

-listed below prepared by Chem-Nuclear. Systems, Inc. (hereinafter "CNSI")..

o F0-0P-019 Polyethylene High-Integrity Container 0verpack Handling.

~ Procedure Rev. C.

This procedure is hereinafter called "the procedure." , i

/ 3. - South Carolina Electric-& Gas (hereinafter "SCE&G")'has submitted the:

. procedure to the Nuclear Regulatory Commission.containing proprietary

.information which~should be withheld from public disclosure.

4.- CNSI,:as part of its radioactive _ waste disposal services,lprovides ai variety of containers and procedures which in most respects are unique.

Detailed information concerning the design, operation, and certification data has always been held in confidence by CNSI and includes. company trade secrets incorporated into the designs.

Employees-of CNSI sign an agreement regarding protection of trade secret.

< information at the time of entering company employment and the data contained in the proprietary version of the procedures being submitted to the Commission by SCE&G contains the type of information CNSI regards as protected and of the type not to be disclosed to unauthorized persons, including especially competitors, by present or former employees.

5. CNSI has obtained a competitive edge in the field of container designs because of its extensive experience in this field and financial commitment to research, development and design concerning container components and certifications. CNSI container design, procedures, and certifications are presently superior to equipment and processes used by competitors for similar processes and this superiority is the basis on which procedure details are being withheld.

The information contained in the procedure is not available from public sources.

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6. Public-disclosure.of the' procedure would causeLsubstantial harm to i the competitive-position.of CNSI. The Company has-invested significant ,

1 amounts of. money over the last several years in engineering salaries and-

~ testing programs and conducting certification testi.ng. Additionally, the Company has substantial capital investment in operating systems supporting the.

procedures. Competitors of CNSI would have great difficulty in duplicating the operation developed.by CNSI, due not only to the financial investment of the Company,-but also to the unique skills, talents and expertise of CNSI employees.

i Hilliam B. House. I Director, Licensing STATE OF SOUTH CAROLINA)

) SS:

COUNTY OF RICHLAND )

0n this 21st day of February, 1989, before me, a Notary Public in and.

- for'the State'of South Carolina, duly' commissioned and sworn, personally appeared Hilliam B. House, to me known to be the Director of Licensing for.

Chem-Nuclear' Systems, Inc., and on oath stated that he was authorized to make this affidavit on behalf of the corporation.

IN WITNESS HHEREOF, I have set my hand and affixed my official seal the day and year first above written.

Dj Sharra' AMAC$ hd& & -

L. Ro111nso'n My Commission Expires March 11, 1990

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