NL-15-169, Browns Ferry, Units 1, 2, and 3, Areva Affidavits
Text
AFFIDAVIT STATE OF WASHINGTON ) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.
I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary.
I am familiar with the policies established by AREVA to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA information contained in the report ANP-2860P Revision 2, Supplement 2P Revision 1, "Browns Ferry Unit 1 -Summary of Responses to Request for Additional Information Extension for Use of ATRIUM 10XM Fuel for Extended Power Uprate," dated August 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA 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 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 AREVA to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA'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 AREVA (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above. 7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. AREVA 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. SUBSCRIBED before me this dayof ,2015.
Susan K. McCoy D NOTARY PUBLIC, STATE OF WASHINGTON MY COMMISSION EXPIRES: 1/14/2016 AFFIDAVIT STATE OF WASHINGTON ) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.
I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary.
I am familiar with the policies established by AREVA to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA information contained in the report ANP-3327P, Revision 1, "Evaluation of AREVA Fuel Thermal-hydraulic Performance for Browns Ferry at EPU," dated March 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA 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 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 1 O 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 AREVA to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA'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 AREVA (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above. 7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. AREVA 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. ......-:=:-------
SUBSCRIBED before me this day of '2015. Susan K. McCoy NOTARY PUBLIC, STATE OF INGTON MY COMMISSION EXPIRES: 1/14/2016 AFFIDAVIT STATE OF WASHINGTON ) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.
I am Manager, Product Licensing, for AREVA NP Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA NP to determine whether certain AREVA NP information is proprietary.
I am familiar with the policies established by AREVA NP to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA NP information contained in the report ANP-3342P, Revision 1, "Browns Ferry EPU (120% OL TP) Equilibrium Fuel Cycle Design," dated August 2015 and referred to herein as "Document." Information contained in this Document has been classified 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 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 1 O CFR 2.390. The information for which withholding from disclosure is requested qualifies under 1 O CFR 2.390(a)(4)
'Trade secrets and commercial or financial information." 6. The following criteria are customarily applied by AREVA NP to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA NP'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 AREVA NP. (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA NP in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA NP, would be helpful to competitors to AREVA NP, and would likely cause substantial harm to the competitive position of AREVA NP. The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above. 7. In accordance with AREVA NP's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA NP only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. AREVA NP 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. SUBSCRIBED before me this_:.....;/
/'-f1r-__ day of , 2015. Susan K. McCoy NOTARY PUBLIC, STATE OF WA NGTON MY COMMISSION EXPIRES: 1/14/2016
\ ----
AFFIDAVIT STATE OF WASHINGTON ) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.
I am Manager, Product Licensing, for AREVA NP Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA NP to determine whether certain AREVA NP information is proprietary.
I am familiar with the policies established by AREVA NP to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA NP information contained in the report ANP-3343P, Revision 0, "Nuclear Fuel Design Report Browns Ferry EPU (120% OL TP) Equilibrium Cycle ATRIUM 10XM Fuel," dated October 2014 and referred to herein as "Document." Information contained in this Document has been classified 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 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 AREVA NP to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA NP'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 AREVA NP. (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA NP in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA NP, would be helpful to competitors to AREVA NP, and would likely cause substantial harm to the competitive position of AREVA NP. The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above. 7. In accordance with AREVA NP's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA NP only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. AREVA NP 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. SUBSCRIBED before me this _9 ___ _ day of 0 , 2014. Susan K. McCoy NOTARY PUBLIC, STATE OF WASHIN ON MY COMMISSION EXPIRES: 1/14/2016 AFFIDAVIT STATE OF WASHINGTON ) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.
I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary.
I am familiar with the policies established by AREVA to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA information contained in the report ANP-3372P, Revision 1, "Browns Ferry Unit 3 Cycle 19 EPU (120% OL TP) LAR Reference Fuel Cycle Design," dated August 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA 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 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 1 O CFR 2.390(a)(4)
'Trade secrets and commercial or financial information." 6. The following criteria are customarily applied by AREVA to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA'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 AREVA. (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA. The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above. 7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. AREVA 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. SUBSCRIBED before me this day of "j'" j , 2015. I ) {4--
Susan K. McCoy b NOTARY PUBLIC, STATE OF WASHINGTON MY COMMISSION EXPIRES: 1/14/2016 AFFIDAVIT STATE OF WASHINGTON ) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.
I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary.
I am familiar with the policies established by AREVA to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA information contained in the report ANP-3377P, Revision 3, "Browns Ferry Units 1, 2, and 3 LOCA Break Spectrum Analysis for ATRIUM 10XM Fuel (EPU)," dated August 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA 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 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 AREVA to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA'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 AREVA (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above. 7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. AREVA 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. SUBSCRIBED before me this day of A-"'-'lfcJ , 2015.
Susan K. McCoy ' ' Cs NOTARY PUBLIC, STATE OF WASHINGTON MY COMMISSION EXPIRES: 1/14/2016 AFFIDAVIT STATE OF WASHINGTON ) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.
I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary.
I am familiar with the policies established by AREVA to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA information contained in the report ANP-3378P, Revision 3, "Browns Ferry Units 1, 2, and 3 LOCA-ECCS Analysis MAPLHGR Limits for ATRIUM 10XM Fuel (EPU)," dated August 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA 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 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 AREVA to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA'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 AREVA. (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA. The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above. 7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. AREVA 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. SUBSCRIBED before me this day of A lA. , 2015. (9f-L <n Susan K. McCoy NOTARY PUBLIC, STATE OFWA: GTON MY COMMISSION EXPIRES: 1/14/2016 AFFIDAVIT STATE OF WASHINGTON ) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.
I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary.
I am familiar with the policies established by AREVA to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA information contained in the report ANP-3384P, Revision 3, "Browns Ferry Units 1, 2, and 3 LOCA-ECCS Analysis MAPLHGR Limits for ATRIUM-10 Fuel (EPU)," dated August 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA 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 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 AREVA to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA'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 AREVA. (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA. The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above. 7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. AREVA 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. SUBSCRIBED before me this ( day of A , 2015. NOTARY PUBLIC, STATE OF WASHINGTON MY COMMISSION EXPIRES: 1/14/2016 AFFIDAVIT STATE OF WASHINGTON ) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.
I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary.
I am familiar with the policies established by AREVA to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA information contained in the report ANP-3385P, Revision 1, "Mechanical Design Report for Browns Ferry Units 1, 2 and 3 Extended Power Uprate (EPU) ATRIUM-10 Fuel Assemblies," dated August 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA for the control and protection of proprietary and confidential information.
- 4. This Document contains information ofa proprietary and confidential nature and is of the type customarily held in confidence by AREVA 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 AREVA to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA'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 AREVA. (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA. The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above. 7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. AREVA 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. l ., {'-SUBSCRIBED before me this o-__,.__ __ day of
..... ,.__, 2015. Susan K. McCoy NOTARY PUBLIC, STATE OF WA GTON MY COMMISSION EXPIRES: 1/14/2016 AFFIDAVIT STATE OF WASHINGTON ) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.
I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary.
I am familiar with the policies established by AREVA to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA information contained in the report ANP-3386P, Revision 1, "Mechanical Design Report for Browns Ferry Units 1, 2 and 3 Extended Power Uprate (EPU) ATRIUM 10XM Fuel Assemblies," dated August 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA 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 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 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 AREVA to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA'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 AREVA. (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA. The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above. 7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. AREVA 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. SUBSCRIBED before me this ----day of A "-f'*} , 2015. Susan K. McCoy NOTARY PUBLIC, STATE OF INGTON MY COMMISSION EXPIRES: 1/14/2016 AFFIDAVIT STATE OF WASHINGTON ) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.
I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary.
I am familiar with the policies established by AREVA to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA information contained in the report ANP-3388P, Revision 0, "Fuel Rod Thermal-Mechanical Evaluation for Browns Ferry Extended Power Uprate," dated May 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA 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 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 AREVA to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA'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 AREVA. (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA. The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above. 7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. AREVA 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. SUBSCRIBED before me this day of _W\ _
2015.
STATE OF :SHln: MY COMMISSION EXPIRES: 1/14/2016 AFFIDAVIT STATE OF WASHINGTON ) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.
I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary.
I am familiar with the policies established by AREVA to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA information contained in the report ANP-3403P, Revision 2, "Fuel Uprate Safety Analysis Report for Browns Ferry Units 1, 2, and 3," dated August 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA 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 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 1 O CFR 2.390. The information for which withholding from disclosure is requested qualifies under 1 O CFR 2.390(a)(4) "Trade secrets and commercial or financial information." 6. The following criteria are customarily applied by AREVA to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA'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 AREVA. (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA. The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above. 7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. AREVA 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. SUBSCRIBED before me this day of A "'iJ J-, 2015. Susan K. McCoy NOTARY PUBLIC, STATE OF WASHIN T N MY COMMISSION EXPIRES: 1/14/2016 AFFIDAVIT STATE OF WASHINGTON ) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.
I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary.
I am familiar with the policies established by AREVA to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA information contained in the report ANP-3404P, Revision 2, "Browns Ferry Unit 3 Cycle 19 Representative Reload Analysis at Extended Power Uprate," dated August 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA 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 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 1 O CFR 2.390(a)(4)
'Trade secrets and commercial or financial information." 6. The following criteria are customarily applied by AREVA to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA'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 AREVA. (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA. The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above. 7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. AREVA 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.
-SUBSCRIBED before me this do f/k day of , 2015.
Susan K. McCoy ' ts NOTARY PUBLIC, STATE OF WASHINGTON MY COMMISSION EXPIRES: 1/14/2016 AFFIDAVIT STATE OF WASHINGTON ) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.
I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary.
I am familiar with the policies established by AREVA to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA information contained in the report ANP-3409P, Revision 2, "Fuel-Related Emergent Regulatory Issues," dated August 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA 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 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 1 O CFR 2.390. The information for which withholding from disclosure is requested qualifies under 1 O CFR 2.390(a)(4) "Trade secrets and commercial or financial information." 6. The following criteria are customarily applied by AREVA to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA'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 AREVA. (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA. The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above. 7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information . . 8. AREVA 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. SUBSCRIBED before me this ;;).o day of A 'q*' ,.i I 2015.
Susan K. McCoy ' ' NOTARY PUBLIC, STATE OF WASHINGTON MY COMMISSION EXPIRES: 1/14/2016 AFFIDAVIT STATE OF WASHINGTON ) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.
I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary.
I am familiar with the policies established by AREVA to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA information contained in the report FS1-0019629, Revision 1, "Browns Ferry Unit 3 Cycle 19 MCPR Safety Limit Analysis With SAFLIM3D Methodology," dated March 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA 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 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 AREVA to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA'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 AREVA. (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA. The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above. 7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. AREVA 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. SUBSCRIBED before me this ;;)._ day of M Q.f""c..h. , 2015. -=L) ( l, Susan K. McCoy ' \3 NOTARY PUBLIC, STATE OF WASHINGTON MY COMMISSION EXPIRES: 1/14/2016
AFFIDAVIT STATE OF WASHINGTON ) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.
I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary.
I am familiar with the policies established by AREVA to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA information contained in the report ANP-2860P Revision 2, Supplement 2P Revision 1, "Browns Ferry Unit 1 -Summary of Responses to Request for Additional Information Extension for Use of ATRIUM 10XM Fuel for Extended Power Uprate," dated August 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA 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 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 AREVA to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA'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 AREVA (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above. 7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. AREVA 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. SUBSCRIBED before me this dayof ,2015.
Susan K. McCoy D NOTARY PUBLIC, STATE OF WASHINGTON MY COMMISSION EXPIRES: 1/14/2016 AFFIDAVIT STATE OF WASHINGTON ) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.
I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary.
I am familiar with the policies established by AREVA to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA information contained in the report ANP-3327P, Revision 1, "Evaluation of AREVA Fuel Thermal-hydraulic Performance for Browns Ferry at EPU," dated March 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA 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 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 1 O 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 AREVA to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA'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 AREVA (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above. 7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. AREVA 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. ......-:=:-------
SUBSCRIBED before me this day of '2015. Susan K. McCoy NOTARY PUBLIC, STATE OF INGTON MY COMMISSION EXPIRES: 1/14/2016 AFFIDAVIT STATE OF WASHINGTON ) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.
I am Manager, Product Licensing, for AREVA NP Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA NP to determine whether certain AREVA NP information is proprietary.
I am familiar with the policies established by AREVA NP to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA NP information contained in the report ANP-3342P, Revision 1, "Browns Ferry EPU (120% OL TP) Equilibrium Fuel Cycle Design," dated August 2015 and referred to herein as "Document." Information contained in this Document has been classified 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 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 1 O CFR 2.390. The information for which withholding from disclosure is requested qualifies under 1 O CFR 2.390(a)(4)
'Trade secrets and commercial or financial information." 6. The following criteria are customarily applied by AREVA NP to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA NP'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 AREVA NP. (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA NP in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA NP, would be helpful to competitors to AREVA NP, and would likely cause substantial harm to the competitive position of AREVA NP. The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above. 7. In accordance with AREVA NP's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA NP only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. AREVA NP 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. SUBSCRIBED before me this_:.....;/
/'-f1r-__ day of , 2015. Susan K. McCoy NOTARY PUBLIC, STATE OF WA NGTON MY COMMISSION EXPIRES: 1/14/2016
\ ----
AFFIDAVIT STATE OF WASHINGTON ) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.
I am Manager, Product Licensing, for AREVA NP Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA NP to determine whether certain AREVA NP information is proprietary.
I am familiar with the policies established by AREVA NP to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA NP information contained in the report ANP-3343P, Revision 0, "Nuclear Fuel Design Report Browns Ferry EPU (120% OL TP) Equilibrium Cycle ATRIUM 10XM Fuel," dated October 2014 and referred to herein as "Document." Information contained in this Document has been classified 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 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 AREVA NP to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA NP'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 AREVA NP. (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA NP in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA NP, would be helpful to competitors to AREVA NP, and would likely cause substantial harm to the competitive position of AREVA NP. The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above. 7. In accordance with AREVA NP's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA NP only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. AREVA NP 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. SUBSCRIBED before me this _9 ___ _ day of 0 , 2014. Susan K. McCoy NOTARY PUBLIC, STATE OF WASHIN ON MY COMMISSION EXPIRES: 1/14/2016 AFFIDAVIT STATE OF WASHINGTON ) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.
I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary.
I am familiar with the policies established by AREVA to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA information contained in the report ANP-3372P, Revision 1, "Browns Ferry Unit 3 Cycle 19 EPU (120% OL TP) LAR Reference Fuel Cycle Design," dated August 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA 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 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 1 O CFR 2.390(a)(4)
'Trade secrets and commercial or financial information." 6. The following criteria are customarily applied by AREVA to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA'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 AREVA. (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA. The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above. 7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. AREVA 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. SUBSCRIBED before me this day of "j'" j , 2015. I ) {4--
Susan K. McCoy b NOTARY PUBLIC, STATE OF WASHINGTON MY COMMISSION EXPIRES: 1/14/2016 AFFIDAVIT STATE OF WASHINGTON ) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.
I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary.
I am familiar with the policies established by AREVA to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA information contained in the report ANP-3377P, Revision 3, "Browns Ferry Units 1, 2, and 3 LOCA Break Spectrum Analysis for ATRIUM 10XM Fuel (EPU)," dated August 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA 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 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 AREVA to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA'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 AREVA (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above. 7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. AREVA 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. SUBSCRIBED before me this day of A-"'-'lfcJ , 2015.
Susan K. McCoy ' ' Cs NOTARY PUBLIC, STATE OF WASHINGTON MY COMMISSION EXPIRES: 1/14/2016 AFFIDAVIT STATE OF WASHINGTON ) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.
I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary.
I am familiar with the policies established by AREVA to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA information contained in the report ANP-3378P, Revision 3, "Browns Ferry Units 1, 2, and 3 LOCA-ECCS Analysis MAPLHGR Limits for ATRIUM 10XM Fuel (EPU)," dated August 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA 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 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 AREVA to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA'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 AREVA. (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA. The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above. 7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. AREVA 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. SUBSCRIBED before me this day of A lA. , 2015. (9f-L <n Susan K. McCoy NOTARY PUBLIC, STATE OFWA: GTON MY COMMISSION EXPIRES: 1/14/2016 AFFIDAVIT STATE OF WASHINGTON ) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.
I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary.
I am familiar with the policies established by AREVA to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA information contained in the report ANP-3384P, Revision 3, "Browns Ferry Units 1, 2, and 3 LOCA-ECCS Analysis MAPLHGR Limits for ATRIUM-10 Fuel (EPU)," dated August 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA 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 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 AREVA to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA'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 AREVA. (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA. The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above. 7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. AREVA 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. SUBSCRIBED before me this ( day of A , 2015. NOTARY PUBLIC, STATE OF WASHINGTON MY COMMISSION EXPIRES: 1/14/2016 AFFIDAVIT STATE OF WASHINGTON ) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.
I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary.
I am familiar with the policies established by AREVA to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA information contained in the report ANP-3385P, Revision 1, "Mechanical Design Report for Browns Ferry Units 1, 2 and 3 Extended Power Uprate (EPU) ATRIUM-10 Fuel Assemblies," dated August 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA for the control and protection of proprietary and confidential information.
- 4. This Document contains information ofa proprietary and confidential nature and is of the type customarily held in confidence by AREVA 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 AREVA to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA'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 AREVA. (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA. The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above. 7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. AREVA 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. l ., {'-SUBSCRIBED before me this o-__,.__ __ day of
..... ,.__, 2015. Susan K. McCoy NOTARY PUBLIC, STATE OF WA GTON MY COMMISSION EXPIRES: 1/14/2016 AFFIDAVIT STATE OF WASHINGTON ) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.
I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary.
I am familiar with the policies established by AREVA to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA information contained in the report ANP-3386P, Revision 1, "Mechanical Design Report for Browns Ferry Units 1, 2 and 3 Extended Power Uprate (EPU) ATRIUM 10XM Fuel Assemblies," dated August 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA 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 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 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 AREVA to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA'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 AREVA. (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA. The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above. 7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. AREVA 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. SUBSCRIBED before me this ----day of A "-f'*} , 2015. Susan K. McCoy NOTARY PUBLIC, STATE OF INGTON MY COMMISSION EXPIRES: 1/14/2016 AFFIDAVIT STATE OF WASHINGTON ) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.
I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary.
I am familiar with the policies established by AREVA to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA information contained in the report ANP-3388P, Revision 0, "Fuel Rod Thermal-Mechanical Evaluation for Browns Ferry Extended Power Uprate," dated May 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA 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 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 AREVA to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA'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 AREVA. (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA. The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above. 7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. AREVA 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. SUBSCRIBED before me this day of _W\ _
2015.
STATE OF :SHln: MY COMMISSION EXPIRES: 1/14/2016 AFFIDAVIT STATE OF WASHINGTON ) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.
I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary.
I am familiar with the policies established by AREVA to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA information contained in the report ANP-3403P, Revision 2, "Fuel Uprate Safety Analysis Report for Browns Ferry Units 1, 2, and 3," dated August 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA 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 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 1 O CFR 2.390. The information for which withholding from disclosure is requested qualifies under 1 O CFR 2.390(a)(4) "Trade secrets and commercial or financial information." 6. The following criteria are customarily applied by AREVA to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA'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 AREVA. (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA. The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above. 7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. AREVA 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. SUBSCRIBED before me this day of A "'iJ J-, 2015. Susan K. McCoy NOTARY PUBLIC, STATE OF WASHIN T N MY COMMISSION EXPIRES: 1/14/2016 AFFIDAVIT STATE OF WASHINGTON ) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.
I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary.
I am familiar with the policies established by AREVA to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA information contained in the report ANP-3404P, Revision 2, "Browns Ferry Unit 3 Cycle 19 Representative Reload Analysis at Extended Power Uprate," dated August 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA 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 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 1 O CFR 2.390(a)(4)
'Trade secrets and commercial or financial information." 6. The following criteria are customarily applied by AREVA to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA'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 AREVA. (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA. The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above. 7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. AREVA 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.
-SUBSCRIBED before me this do f/k day of , 2015.
Susan K. McCoy ' ts NOTARY PUBLIC, STATE OF WASHINGTON MY COMMISSION EXPIRES: 1/14/2016 AFFIDAVIT STATE OF WASHINGTON ) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.
I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary.
I am familiar with the policies established by AREVA to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA information contained in the report ANP-3409P, Revision 2, "Fuel-Related Emergent Regulatory Issues," dated August 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA 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 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 1 O CFR 2.390. The information for which withholding from disclosure is requested qualifies under 1 O CFR 2.390(a)(4) "Trade secrets and commercial or financial information." 6. The following criteria are customarily applied by AREVA to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA'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 AREVA. (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA. The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above. 7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information . . 8. AREVA 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. SUBSCRIBED before me this ;;).o day of A 'q*' ,.i I 2015.
Susan K. McCoy ' ' NOTARY PUBLIC, STATE OF WASHINGTON MY COMMISSION EXPIRES: 1/14/2016 AFFIDAVIT STATE OF WASHINGTON ) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.
I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary.
I am familiar with the policies established by AREVA to ensure the proper application of these criteria.
- 3. I am familiar with the AREVA information contained in the report FS1-0019629, Revision 1, "Browns Ferry Unit 3 Cycle 19 MCPR Safety Limit Analysis With SAFLIM3D Methodology," dated March 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA 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 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 AREVA to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA'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 AREVA. (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA. The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above. 7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8. AREVA 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. SUBSCRIBED before me this ;;)._ day of M Q.f""c..h. , 2015. -=L) ( l, Susan K. McCoy ' \3 NOTARY PUBLIC, STATE OF WASHINGTON MY COMMISSION EXPIRES: 1/14/2016