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MONTHYEARML12053A3322012-02-20020 February 2012 License Renewal Commitment to Submit a Time Limiting Aging Analysis for the Reactor Vessel Internals to the NRC for Review Project stage: Other ML12187A2142012-06-28028 June 2012 Proposed License Amendment Request for the Reactor Vessel Internals Inspection Plan, License Amendment Request Number 2010-06 - Supplement 1 Project stage: Supplement ML12256A7902012-09-18018 September 2012 Request for Withholding Information from Public Disclosure Project stage: Withholding Request Acceptance ML12333A3172012-11-16016 November 2012 Response to Request for Additional Information for Time Limited Aging Analysis on Reactor Vessel Internals Project stage: Response to RAI ML13032A1862013-01-30030 January 2013 E-mail Oconee Nuclear Station, Units 1, 2 and 3, Time Limiting Aging Analysis for the Reactor Vessel Internals, TACs ME8436, ME8437, ME8438 Project stage: Other ML13032A2362013-02-0505 February 2013 Request for Withholding Information from Public Disclosure Project stage: Withholding Request Acceptance ML13045A4892013-02-19019 February 2013 Approval of Time-Limited Aging Analysis for Reactor Vessel Internals Project stage: Other 2012-09-18
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Category:Letter
MONTHYEARML23304A1422024-02-0101 February 2024 Issuance of Environmental Scoping Summary Report Associated with the U.S. Nuclear Regulatory Commission Staffs Review of the Oconee Nuclear Station, Units 1, 2, & 3, Subsequent License Renewal Application ML24005A2492024-01-24024 January 2024 Exemption from Select Requirements of 10 CFR Part 73 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting) IR 05000269/20243012024-01-11011 January 2024 Notification of Licensed Operator Initial Examination 05000269/2024301, 05000270/2024301, and 05000287/2024301 ML23331A7982023-12-14014 December 2023 Review of the Fall 2022 Steam Generator Tube Inspection Report (01R32) ML23262A9672023-12-13013 December 2023 Alternative to Use RR-22-0174, Risk-Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 and 3 Systems Section XI, Division 1 ML23317A3462023-11-14014 November 2023 Duke Fleet - Correction Letter to License Amendment Nos. 312 & 340 Issuance of Amendments Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-554, Revision 1 IR 05000269/20230032023-11-14014 November 2023 Integrated Inspection Report 05000269/2023003, 05000270/2023003, and 05000287/2023003; and IR 07200040/2023001; and Exercise of Enforcement Discretion ML23219A1402023-10-10010 October 2023 Audit Report Proposed Alternative to Use ASME Code Case N-752, Risk Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 and 3 Systems XI, Division 1 ML23269A1102023-10-0606 October 2023 Letter to Steven Snider-Revised Schedule for the Environmental Review of the Oconee Nuclear Station, Unit 1, 2, and 3, Subsequent License Renewal Application ML23256A0882023-09-25025 September 2023 Issuance of Alternative to Steam Generator Welds ML23195A0782023-08-29029 August 2023 Issuance of Amendments Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-554, Revision 1 IR 05000269/20230112023-08-25025 August 2023 Comprehensive Engineering Team Inspection Report 05000269/2023011 and 05000270/2023011 and 05000287/2023011 IR 05000269/20230052023-08-25025 August 2023 Updated Inspection Plan for Oconee Nuclear Station Units 1, 2 and 3 (Report 05000269/2023005, 05000270/2023005, and 05000287/2023005) IR 05000269/20230022023-07-28028 July 2023 Integrated Inspection Report 05000269/2023002, 05000270/2023002 and 05000287/2023002 ML23208A0972023-07-27027 July 2023 Subsequent License Renewal List of Threatened and Endangered Species That May Occur in Your Proposed Project Location or May Be Affected IR 05000269/20230102023-07-19019 July 2023 Biennial Problem Identification and Resolution Inspection Report 05000269/2023010 and 05000270/2023010 and 05000287/2023010 and Notice of Violation ML23178A0682023-07-0303 July 2023 Audit Plan Proposed Alternative to Use ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 & 3 Systems Section XI, Division 1 ML23132A2392023-06-0101 June 2023 Summary of the April 2023 Remote Environmental Audit Related to the Review of the Subsequent License Renewal Application ML23144A0192023-05-25025 May 2023 Review of the Spring 2022 Steam Generator Tube Inspection Report (O3R31) IR 05000269/20230012023-05-12012 May 2023 Integrated Inspection Report 05000269/2023001 and 05000270/2023001 and 05000287/2023001 ML23121A0552023-05-0303 May 2023 Acknowledgement of Withdrawal Request to Revise TS 5.5.2 Containment Leakage Rate Testing Program ML23118A0762023-05-0101 May 2023 Approval for Use of Specific Provision of a Later Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section XI ML23117A0432023-04-20020 April 2023 Framatome, Inc., Part 21 Notification of Existence of a Defect ML23075A0732023-04-0505 April 2023 License Renewal Regulatory Audit Regarding the Environmental Review of the Subsequent License Renewal Application Supplement (EPID Number L-2021-SLE-0002) ML23045A1432023-03-15015 March 2023 Request for Scoping Comments Concerning the Supplemental Environmental Review of Oconee Nuclear Station, Units 1, 2, and 3, Subsequent License Renewal Application - State Tribe Letter ML23045A1402023-03-15015 March 2023 Request for Scoping Comments Concerning the Supplemental Environmental Review of Oconee Nuclear Station, Units 1, 2, and 3, Subsequent License Renewal Application - Shpo Letter ML23045A1332023-03-15015 March 2023 Request for Scoping Comments Concerning the Supplemental Environmental Review of Oconee Nuclear Station, Units 1, 2, and 3, Subsequent License Renewal Application - Achp Letter ML22332A4932023-03-10010 March 2023 William States Lee III 1 and 2 - Issuance of Amendments Regarding the Relocation of the Emergency Operations Facility ML23069A1102023-03-10010 March 2023 Notification of Inspection and Request for Information for NRC Problem Identification and Resolution Inspection ML23061A1772023-03-0303 March 2023 Notification of Oconee Nuclear Station Comprehensive Engineering Team Inspection - NRC Inspection Report 05000269/2023011, 05000270/2023011 and 05000287/2023011 IR 05000269/20220062023-03-0101 March 2023 Annual Assessment Letter for Oconee Nuclear Nuclear Station, Units 1, 2 and 3 (NRC Inspection Report 05000269/2022006, 05000270/2022006, and 05000287/2022006) ML23039A1632023-02-0808 February 2023 Requalification Program Inspection ML23037A0772023-02-0606 February 2023 402 Cyber Notification and RFI Letter Final IR 05000269/20220042023-02-0202 February 2023 Integrated Inspection Report 05000269 2022004 and 05000270/2022004 and 05000287/2022004 ML22363A3942023-01-12012 January 2023 Subsequent License Renewal Environmental Report Supplement - Proposed Review Schedule ML22356A0512022-12-14014 December 2022 Curtiss-Wright Nuclear Division, Letter Regarding Potential Efect in a Configuration of the 11/2 Inch Quick Disconnect Connector Cable Assemblies Supplied to Duke Energy (See Attached Spreadsheet) for a Total of 460 of Connectors Only Suppl ML22321A0492022-12-0808 December 2022 Issuance of Amendment Nos. 426, 428 and 427, Additional Mode Change Limitations Applicable to the Adoption of TSTF- 359, Revision 9, Increase Flexibility in Mode Restraints ML22329A1042022-11-29029 November 2022 Review of the Fall 2021 Steam Generator Tube Inspection Report ML22321A1582022-11-22022 November 2022 Summary of Conference Call Regarding the Fall 2022 Steam Generator Tube Inspections ML22096A0032022-11-18018 November 2022 McGuire Nuclear Station and Shearon Harris Nuclear Power Plant Authorization of RA-19-0352 Regarding Use of Alternative for RPV Head Closure Stud Examinations ML22256A2532022-11-14014 November 2022 Issuance of Amendments Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-541, Rev. 2 IR 05000269/20220032022-11-0707 November 2022 Integrated Inspection Station 05000269/2022003 and 05000270/2022003 and 05000287/2022003 ML22301A0112022-11-0303 November 2022 Request for Withholding Information from Public Disclosure Regarding the SLR Application - September 2, 2022 ML22298A0752022-10-27027 October 2022 Request for Withholding Information from Public Disclosure Regarding the Subsequent License Renewal Application Duke Energy Letter Dated July 25, 2022 ML22264A0322022-10-20020 October 2022 _Request for Withholding Information from Public Disclosure Regarding the Subsequent License Renewal Application - Duke Energy Letter Dated July 8, 2022 IR 05000269/20220112022-09-26026 September 2022 NRC Inspection Report 05000269/2022011 and 05000270/2022011 and 05000287/2022011 ML22258A0302022-09-15015 September 2022 Evacuation Time Estimate Reports ML22222A0072022-09-14014 September 2022 Request for Withholding Information from Public Disclosure Regarding the Subsequent License Renewal Application ML22231B1362022-09-0101 September 2022 Review of the Draft Environmental Assessment and Findings of No Significant Impact for Catawba Nuclear Station, H.B. Robinson Steam Electric Plant, and Oconee Nuclear Station Independent Spent Fuel Storage Installation Decommissioning Fundi ML22234A0062022-08-30030 August 2022 SLRA - Closed Public Meeting Summary - August 18, 2022 2024-02-01
[Table view] Category:Legal-Affidavit
MONTHYEARRA-22-0192, Subsequent License Renewal Application Response to ONS SLRA Second Round RAI B2.1.7-4a2022-09-0202 September 2022 Subsequent License Renewal Application Response to ONS SLRA Second Round RAI B2.1.7-4a RA-22-0193, Subsequent License Renewal Application Response to ONS SLRA Second Round RAI B2.1.7-4b2022-07-0808 July 2022 Subsequent License Renewal Application Response to ONS SLRA Second Round RAI B2.1.7-4b RA-22-0036, Responses to NRC Request for Additional Information Set 22022-02-14014 February 2022 Responses to NRC Request for Additional Information Set 2 RA-21-0219, Response to Request for Additional Information for Request for Alternative for Implementation of Extended Reactor Vessel Inservice Inspection Intervals2021-08-0505 August 2021 Response to Request for Additional Information for Request for Alternative for Implementation of Extended Reactor Vessel Inservice Inspection Intervals ML19242C7282019-08-28028 August 2019 Attachments 5 - 12: Thermal-Hydraulic Models for High Energy Line Break Transient Analysis, Duke Energy/Framatome Affidavits, Regulatory Requirements, Definitions, Time Critical Operator Actions and Feasibility Assessment for New Proposed T RA-19-0301, Proposed Amendment to Renewed Facility Operating Licenses Regarding Revisions to Final Safety Analysis Report Sections Associated with Oconee Tornado Licensing Basis -Responses to Request for Additional Information2019-07-31031 July 2019 Proposed Amendment to Renewed Facility Operating Licenses Regarding Revisions to Final Safety Analysis Report Sections Associated with Oconee Tornado Licensing Basis -Responses to Request for Additional Information RA-19-0086, Proposed Amendment to the Renewed Facility Operating Licenses Regarding Revisions to the Updated Final Safety Analysis Report Sections Associated with the Oconee Tornado Licensing Basis - License Amendment Request No. 2018-022019-01-24024 January 2019 Proposed Amendment to the Renewed Facility Operating Licenses Regarding Revisions to the Updated Final Safety Analysis Report Sections Associated with the Oconee Tornado Licensing Basis - License Amendment Request No. 2018-02 RA-18-0026, Proposed Amendment to the Renewed Facility Operating Licenses Regarding Revisions to the Updated Final Safety Analysis Report Sections Associated with the Oconee Tornado Licensing Basis2018-09-14014 September 2018 Proposed Amendment to the Renewed Facility Operating Licenses Regarding Revisions to the Updated Final Safety Analysis Report Sections Associated with the Oconee Tornado Licensing Basis RA-18-0098, (Ons), Units 1, 2, and 3 - Response to Request for Additional Information Related to Proposed Revisions to the Updated Final Safety Analysis Report Section for the Standby Shutdown Facility; License Amendment Request No. ...2018-07-20020 July 2018 (Ons), Units 1, 2, and 3 - Response to Request for Additional Information Related to Proposed Revisions to the Updated Final Safety Analysis Report Section for the Standby Shutdown Facility; License Amendment Request No. ... ML18155A3402018-05-31031 May 2018 Framatome, Inc., Response to Request for Comment on Draft Safety Evaluation for ANP-10297P-A Revision 0, Supplement 1, the Arcadia Reactor Analysis System for PWRs Methodology Description and Benchmarking Results. ML18059A7812018-02-26026 February 2018 Framatome, Inc., Publication of ANP-10338P-A, Revision 0, Area - Arcadia Rod Ejection Accident. ML16209A2232016-07-21021 July 2016 Amendment Request to Add the Copernic Fuel Performance Code to Technical Specifications 2.1.1.1, Reactor Core Safety Limits, and 5.6.5, Core Operating Limits Report (COLR) ONS-2016-008, Response to Request for Additional Information Regarding the License Amendment Request to Change to Emergency Plan to Upgrade Emergency Action Levels Based on NEI 99-01, Revision 62016-02-0404 February 2016 Response to Request for Additional Information Regarding the License Amendment Request to Change to Emergency Plan to Upgrade Emergency Action Levels Based on NEI 99-01, Revision 6 RA-13-1007, 30-Day Report Pursuant to 10 CFR 50.46, Changes to or Errors in an Evaluation Model2013-12-16016 December 2013 30-Day Report Pursuant to 10 CFR 50.46, Changes to or Errors in an Evaluation Model ML12053A3322012-02-20020 February 2012 License Renewal Commitment to Submit a Time Limiting Aging Analysis for the Reactor Vessel Internals to the NRC for Review ML0733000082007-11-20020 November 2007 Evaluation Results Confirming Existing Boron Precipitation Analyses of Record Have Sufficient Margin and Remain in Compliance with the Regulations and Plant Design Basis ML0703900532007-01-31031 January 2007 License Amendment Request for Removal of Out of Date Requirements Associated with the Completion of the Control Room Intake / Booster Fan Modifications ML0635303692006-12-0808 December 2006 Affidavit for Meeting Handout ML0628502692006-10-0303 October 2006 License Amendment Request Applicable to Technical Specification 3.8.1, AC Sources - Operating Request for Additional Information, LAR 2006-16 ML0523802302005-08-22022 August 2005 Response for Additional Information for Technical Specification 3.8.1, AC Sources - Operating Technical Specification Change (TSC) 2005-07 2022-09-02
[Table view] |
Text
Dukle Duke T. PRESTON Vice PresidentGILLESPIE, JR.
- Energy, Oconee Nuclear Station Duke Energy ON01 VP / 7800 Rochester Hwy.
Seneca, SC 29672 864-873-4478 February 20, 2012 864-873-4208 fax T.Gillespie@duke-energy.corn U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington DC 20555-0001
Subject:
Duke Energy Carolinas, LLC Oconee Nuclear Station (ONS), Units 1, 2, and 3 Docket Numbers 50-269, 50-270, and 50-287 License Renewal Commitment to Submit a Time Limiting Aging Analysis for the Reactor Vessel Internals to the NRC for Review By letter to the NRC dated December 17, 1999, Duke Energy Carolinas, LLC (Duke Energy) committed to perform a plant-specific analysis and develop data to demonstrate that the reactor vessel internals will meet the deformation limits at expiration of the renewal license. The Enclosure provides the required information. This commitment is described in NUREG-1723, Safety Evaluation Report Related to the License Renewal of Oconee Nuclear Station, Units 1, 2, and 3, March 2000 (refer to page 4-24 of Section 4.2.5.3) as follows:
"The TLAA described as 'reduction in fracture toughness' is related to the acceptability of the reactor vessel internals under LOCA and seismic loading. BAW-2248 states that Appendix E to BAW-10008, Part 1, Revision 1, 'Reactor Internals Stress & Deflection Due to LOCA & Max Hypothetical Earthquake,' concludes 'that at the end of 40 years, the internals will have adequate ductility to absorb local strain at the regions of maximum stress intensity, and that irradiation will not adversely affect deformation limits.' BAW also states that this TLAA will be resolved on a plant-specific basis per 10 CFR 54.21 (c)(1)(iii) based on results and conclusions of the planned B&WOG RVIAMP. Duke has stated that appropriate action will be taken in a timely manner to ensure continued validity of the design of the ONS reactor vessel internals. Plant-specific analysis is required to demonstrate that, under LOCA and seismic loading and irradiation accumulated at the expiration of the period of extended operation, the internals have adequate ductility to absorb local strain at the region of maximum stress intensity and will meet the deformation limits. The applicant must provide a plan to develop data to demonstrate that the internals will meet the deformation limits through the period of extended operation. This was identified as Open Item 4.2.5.3-1 in the June 16, 1999, SER. Subsequently, in a letter dated December 17, 1999, Duke committed to perform the plant-specific analysis and develop data to demonstrate that the internals will meet the deformation limits at the expiration of the renewal license. The Staff has determined this program will adequately manage the irradiation aging effects in accordance with 10 CFR 54.21 (c)(1)9iii). Thus, Open Item 4.2.5.3-1 is closed."
As part of Oconee Nuclear Stations' participation as a beta plant for MRP-227, Electric Power Research Institute (EPRI) contracted AREVA to update BAW-1 0008, Part 1, Revision 1 The enclosure to this letter contains proprietary information.
Withhold From Public Disclosure Under 10 CFR 2.390. A-Up o n re m o va l o f th e e n clo s u re s , th is lette r is u n co ntro lled . w wd k - n r y c www. duke-energy, corn
The enclosure to this letter contains proprietary information.
Withhold From Public Disclosure Under 10 CFR 2.390.
Upon removal of the enclosures, this letter is uncontrolled.
U.S. Nuclear Regulatory Commission February 20, 2012 Page 2 generically for B&W designed internals for 60 years. EPRI submitted the non-proprietary version of the update to BAW-10008, Part 1, Revision 1, as part of an RAI response to MRP-227. AREVA submitted the proprietary version to the NRC by letter dated October 29, 2010. However, the NRC declined to review the updated version citing site-specific reviews as an alternative. AREVA Document No. 51-9038244-002 titled "Update of Irradiation Embrittlement in BAW-1 0008 Part 1 Rev. 1" was the Proprietary version AREVA sent to the NRC. AREVA Document No. 47-9048125-002 is the non-proprietary version. The proprietary and non-proprietary versions, along with the AREVA letter to the NRC that accompanied the proprietary version, are contained in enclosed Duke Energy Calculation OSC-10237. This calculation provides the plant-specific analysis and data to demonstrate that the internals will meet the deformation limits at the expiration of the renewal license and fulfills the commitment made in Duke Energy letter to the NRC dated December 17, 1999 and restated in the ONS Safety Evaluation Report for License Renewal.
AREVA Document No. 51-9038244-002 is classified by AREVA NP as proprietary. The appropriate affidavit from AREVA NP was provided in the AREVA letter to the NRC dated October 29, 2010, in accordance with the provisions of 10 CFR 2.390. As such, Duke Energy considers the enclosed calculation, which contains the AREVA document, proprietary and requests it be withheld from public disclosure.
There are no additional regulatory commitments associated with this submittal. Inquiries on this submittal should be directed to Boyd Shingleton, Oconee Regulatory Compliance Group, (864) 873-4716.
Sincerely, T. Preston Gillespie, Jr.
Vice President Oconee Nuclear Station
Enclosure:
ONS Calculation OSC-10237
The enclosure to this letter contains proprietary information.
Withhold From Public Disclosure Under 10 CFR 2.390.
Upon removal of the enclosures, this letter is uncontrolled.
U.S. Nuclear Regulatory Commission February 20, 2012 Page 3 cc w/ enclosure:
Mr. Victor McCree, Regional Administrator U. S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257 Mr. John Stang, Project Manager Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-8 G9A Washington, DC 20555 Mr. Andy Sabisch Senior Resident Inspector Oconee Nuclear Site Ms. Susan E. Jenkins, Manager Radioactive & Infectious Waste Management Division of Waste Management South Carolina Department of Health and Environmental Control 2600 Bull St.
Columbia, SC 29201
ARE VA October 29, 2010 NRC:A0:099 Document Control: Desk U.S. Nuclear: Regulatory Commission Washington, D.C. 20555-0001.
Information In Support of the EPRI MaterialsReliability Program (MRP): Pressurized Water ReactorInternals Inspection and Evaluation:Guidelines (MPR-227-Rev. 0) Review AREVA NP Inc. (AREVA) is hereby :providing :the:enclosed Engineering Information' Record, Document Number 51-9038244-002, entitled "Update of Irradiation Embrittlement in: BAW-1:0008 Part 1 Rev. 1" to the NRC for information. This document is provided to:the NRC in support of the EPRI Materials Reliability Program: Pressurized Water Reactor Internals.
Inspection and: Evaluation:Guidelihes ::(MPR-227-Rev. O) review. This document demonstrates:
that for the irradiation levels at the: end of 60-year lifetime, there will be adequate ductility at operating temperature to absorb local strains at the regions of maximum stress intensity and that irradiation will not adverselyvaffect:deform:ation::limnits.:
This document is being submitted: for information only. No safety evaluation (SE): is expected and therefore, no review fees should be Incurred.
The non-proprietary report, AREVA Document Number 47-9048125-002, is being provided underza separate submittal through the EPRI MRP.
AREVA:considers some of the material :contained in the enclosed document to be proprietary.
AS requir.ed by410 CFR 2390(b), an affidavit:is :enclosed to :support the withholding of the information:from public disclosure.
Ifyou have: any:questions related to this submittal, please contact: Ms. GayleaElliott, Product Licensing Manager. She may be reached :by telephone at 434-832-3347,: or by e-mall at payle.eiliott(,areva.com.
Sincerely, 4
Ronnie L. Gardner, Manager Corporate Regulatory Affairs AREVAXNP Inc.
Enclosure cc: H. D. Cruz Project 728.
AREVA NP INC.
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CITY OF LYNCHBURG 1, Myname IstGayle:F. Elliott. I am Manager, Product Licensing, for AREVA NP Inc. and as such I am authorized to:execute this.Affidavit.
- 2. Iamn familiar with the criteria applied by AREVANPtodeterminewhether certain AREVA:NP:informiation: is poprietary. I am familiar with the policies established by:
AREVA NP to ensure1the proper application of these criteria. F
- 3. 1am familiar with the AREVA NP Engineering Information: Record, Document Number 51-9038244, Revision 002,: entitled "Update of Irradiation Embrittlement in BAW-10008 Part I Rev. V," dated October:2010 and referred to herein as "Document."
Information contained in this: Document has been ciassified by:AREVA NP as proprietary in accordance:with the policies: established by AREVA:NP 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 AREVA NP and not made available to the public :Based on: my:experience, I am aware that other companies. regard Information of the kind contalned In this Document :as proprietary and confidential.
- 5. This Document. has been made available.to the: U.S. Nuclear RegulatoryT 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 Informationjfor which withholding from disclosure is Pk7 r 3 al
I requested .qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial.
information.'
- 6. The following criteria are customarily applled by AREVA NP to determine.
whether: Information.0should be classified as proprietary:
- (a)! The. information reveals details of AREVA NP's research anddevelopment plans and programs or thelr results.
(b): Use of the information:by a competitor would permit the competitor to significantly redUce its:expenditures,, In: time
.or resources, toý 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 AREVA NP.
(d)ý The Information reveals: certain distinguishing: aspects: ofa process, j:I methodology, or component,Athe exclusive use of which provides. a competitive advantage: for AREVA NP in product optimization Or marketability.:I (e) The Information Is: vital to a competitive. advantage: held by AREVA. NP,: Would be ýhelpful to competitors to AREVA NP,:and would likely cause substantial harm to the competitivle position: of AREVA NP; The information in the Document Isconsidered proprietary for the reasons set:forth In paragraphs 6(b) and 6(c) above.
- 7. Inmaccordance with AREVA NP's policies governing the protection and control of Information, proprletary information contained In: this Document have been. made available, on a limited basis, to othems outside AREVA NP only as required. and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. :AREVA NPpollicy requires: thatlproprietary Information be kept In asecured file or: area aniddistributed on a need-to-know. basis.
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- 9. The foregoing statements are true and correct to the: best of my knowledge, Information, and bellef.
SUBSORIBE0 before nme thlsc;-
day of i ~ .210.
Kathleen Ann Bennett NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MYCOMMISSION EXPIRES: 8/31/111 Reg. #110864 I-INAjefw AJcc Wo 0 t: ibrow I
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