ML23212B250

2.390 Withholding Affidavit of Shanna Ramirez

ML23212B250
Person / Time
Site:	South Texas, 07201041
Issue date:	07/31/2023
From:	Ramirez S CPS Energy
To:	NRC/OCM
SECY RAS
References
72-1041-LT
Download: ML23212B250 (0)

Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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In the Matter of: ) Docket Nos. STN 50-498

) STN 50-499 South Texas Project Units 1 and 2 ) 72-104

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AFFIDAVIT OF SHANNA RAMIREZ

I, Shanna Ramirez, General Counsel, CPS Energy, do hereby affirm and state:

1. I am the General Counsel, Chief Legal & Ethics Officer, and Board Secretary for the City

Public Service Board of San Antonio (CPS Energy);

2. I am authorized to execute this affidavit on behalf of CPS Energy;

3. Exhibits A (Amended and Restated South Texas Project Participation Agreement

between City of San Antonio, Central Power and Light Co., Houston Lighting & Power

Co., and City of Austin) and Exhibit B (South Texas Project Operating Agreement) in the

above-captioned proceeding are marked confidential are subject to withholding from

public disclosure under the provisions of 10 C.F.R. § 2.390(a)(4).

4. These documents and materials contain confidential commercial and competitively

sensitive information, the disclosure of which would adversely affect CPS Energy.

5. This information has been held in confidence by CPS Energy and the other owners of the

South Texas Project. To the extent that CPS Energy has shared this information with

others, it has done so on a confidential basis.

6. CPS Energy customarily keeps such information in confidence, and there is a rational

basis for holding such information in confidence. The information is not available from public sources and could not be gathered readily from other publicly available

information.

7. Public disclosure of this information could cause substantial harm to CPS Energys

business interests because such information has significant commercial value to CPS

Energy and its disclosure could adversely affect other CPS Energy transactions.

I declare under penalty of perjury under the laws of the United States of America that the

foregoing is true and correct.

/Executed in Accord with 10 CFR 2.304(d)/

Shanna Ramirez General Counsel & CLEO CPS Energy 500 McCullough Ave.

San Antonio, Texas 78215 (210) 353-5689 smramirez@cpsenergy.com

Dated at San Antonio, Texas this 31st day of July, 2023