ML19045A483
| ML19045A483 | |
| Person / Time | |
|---|---|
| Site: | 07109372 |
| Issue date: | 02/14/2019 |
| From: | Travis Tate Framatome |
| To: | Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML19045A481 | List: |
| References | |
| TJT:19:009 | |
| Download: ML19045A483 (2) | |
Text
STATE OF WASHINGTON ss COUNTY OF BENTON Timothy J. Tate, being duly sworn on oath, states as follows:
- 1. I am employed by Framatome Inc. (Framatome) as Manager, Environmental, Health, Safety and Licensing in Richland, Washington. I am responsible for the overall administration of the safety programs at Framatome's Richland, Washington nuclear fuel fabrication facility, including regulatory licensing and permitting. This affidavit is based on my first hand, personal knowledge and is submitted in my capacity as Manager, Environmental, Health, Safety and Licensing.
- 2. I am familiar with the Framatome information contained in Attachment A FS1-0014159-9.0, Framatome TN-81 Docket No. 71-9372 Safety Analysis Report, and Attachment C list of changes and justification, which provide nuclear fuel and packaging design information for the Framatome, Richland, Washington Fuel Fabrication Facility as required by 10 CFR § 71.0. Information contained in this document is considered by Framatome as "Proprietary" by Framatome in accordance with the document control system and policies established by Framatome for the control and protection of proprietary and confidential information.
- 3. Framatome is engaged in the business of designing and manufacturing nuclear fuel assemblies for commercial nuclear reactors. Within the United States, there are two additional firms that design and manufacture nuclear fuel for commercial nuclear reactors and there are several other companies outside of the United States that engage in the same business as Framatome. Competition among these companies including Framatome is fierce and manufacturing costs of the nuclear fuel are critical to the maintenance of market share and to the growth of market share among utility customers.
- 4. The application for Certificate of Compliance for "Framatome TN-81 Docket 71-9372 Safety Analysis Report, USA/9372/AF-96", FS1-0014159-9.0 contains commercial information of a confidential nature that is not available in public sources or available to the public. This information contained in this report is commercial and confidential because it Affidavit of Timothy J. Tate Page 1 of 2 NRC Application Supplement 2/14/19
reveals specific information about the Framatome Richland manufacturing facility relative to its production throughput. All of this information can be used by competitors to gain undue insight into Framatome's commercial relationships, probable cost structure, operations and business.
- 5. Framatome Inc. will suffer considerable competitive harm if the contents of the license amendment package are made available to Framatome domestic and international competitors. Finally, this material cannot be reasonably segregated from other material which may not meet the criteria set forth in 1 0 CFR § 2.390.
Dated this 14th day of February, 2019.
STATE OF WASHINGTON COUNTY OF BENTON Timothy J. Tate Manager, Environmental, Health, Safety and Licensing
)
)
ss On this 14th day of February, 2019, before me, the undersigned, a Notary Public in and for the State of Washington, duly commissioned and sworn, personally appeared Timothy J. Tate to me known to be the Manager, Environmental, Health, Safety, and Licensing of Framatome Inc., the corporation that executed the foregoing instrument, and acknowledged the said instrument to be the free and voluntary act and deed of said corporation, for the uses and purposes therein mentioned, and on oath stated that he is authorized to execute the said instrument.
Witness my hand and official seal hereto affixed the day and year first above written.
Affidavit of Timothy J. Tate Page 2 of 2 NRC Application Supplement 2/14/19