L-22-141, Enclosure D: Affidavit of Elliott Gayle
| ML22202A434 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/08/2022 |
| From: | Elliott G Energy Harbor Nuclear Corp, Framatome |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML22202A429 | List: |
| References | |
| L-22-141 | |
| Download: ML22202A434 (4) | |
Text
Enclosure D L-22-141
Affidavit Pursuant to 10 CFR 2.390 for 32-9271138-001
(3 Pages Follow)
- 1. My name is Gayle Elliott. I am Deputy Director, Licensing and Regulatory
Affairs, for Framatome Inc. (Framatome) and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by Framatome to determine whether
certain Framatome information is proprietary. I am familiar with the policies established by
Framatome to ensure the proper application of these criteria.
- 3. I am familiar with the Framatome information contained in the Calculation
Summary Sheet (CSS) 32-9271138-001, entitled, "Updated Inputs to 52 EFPY P-T Operating
Curves," dated November 2017 and referred to herein as "Document." Information
contained in this Document has been classified by Framatome as proprietary in accordance with
the policies established by Framatome for the control and protection of proprietary and
confidential information.
- 4. This Document contains information of a proprietary and confidential nature
and is of the type customarily held in confidence by Framatome and not made available to the
public. Based on my experience, I am aware that other companies regard information of the
kind contained in this Document as proprietary and confidential.
- 5. This Document has been made available to the U.S. Nuclear Regulatory
Commission in confidence with the request that the information contained in this Document be
withheld from public disclosure. The request for withholding of proprietary information is made in
accordance with 10 CFR 2.390. The information for which withholding from disclosure is
requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial
information."
- 6. The following criteria are customarily applied by Framatome to determine
whether information should be classified as proprietary:
(a) The information reveals details of Framatome's research and development
plans and programs or their results.
(b) Use of the information by a competitor would permit the competitor to
significantly reduce its expenditures, in time or resources, to design, produce,
or market a similar product or service.
(c) The information includes test data or analytical techniques concerning a
process, methodology, or component, the application of which results in a
competitive advantage for Framatome.
(d) The information reveals certain distinguishing aspects of a process,
methodology, or component, the exclusive use of which provides a
competitive advantage for Framatome in product optimization or marketability.
(e) The information is vital to a competitive advantage held by Framatome, would
be helpful to competitors to Framatome, and would likely cause substantial
harm to the competitive position of Framatome.
The information in this Document is considered proprietary for the reasons set forth in
paragraphs 6 (a) and 6(e) above.
- 7. In accordance with Framatome's policies governing the protection and control
of information, proprietary information contained in this Document has been made available, on
a limited basis, to others outside Framatome only as required and under suitable agreement
providing for nondisclosure and limited use of the information.
- 8. Framatome policy requires that proprietary information be kept in a secured
file or area and distributed on a need-to-know basis.
- 9. The foregoing statements are true and correct to the best of my knowledge,
information, and belief.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on : April 8, 2022.
Digitally signed by ELLIOTT ELLIOTT Gayle ~:~~\\022.04.os 14:1s:21
-04'00' Gayle Elliott