ML20156A374

Affidavit

ML20156A374
Person / Time
Site:	Framatome ANP Richland
Issue date:	06/03/2020
From:	Wilbricht M Framatome
To:	Office of Nuclear Material Safety and Safeguards
Shared Package
ML20156A370	List: ML20156A372 ML20156A374
References
MJW:20:016
Download: ML20156A374 (3)

Text

AFFIDAVIT STATE OF WASHINGTON )

ss COUNTY OF BENTON )

Michael Wilbricht, being duly sworn on oath, states as follows:

1. I am employed by Framatome Inc. (Framatome) as the Sr Safeguards Specialist in Richland, Washington. I am responsible for the overall administration of the nuclear material control and accounting at Framatome's Richland, Washington nuclear fuel fabrication facility. This affidavit is based on my first hand, personal knowledge and is submitted in my capacity as the Sr Safeguards Specialist. This affidavit is submitted in accordance with the provisions of 10 CFR § 2.390.

2. I am familiar with the contents of the "Special Nuclear Material (SNM) and Source Material (SM) Physical Inventory Summary Report", dated June 3, 2020 (MJW-20-016) for the Framatome Inc., Richland, Washington Fuel Fabrication Facility, which provides summary reporting of the plant's annual SNM LEU and HEU inventory as required by 10 CFR § 74.17. This notification is designated 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 and delivering SNM to other nuclear fuel fabricators in foreign countries for inclusion in nuclear fuel assemblies. 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 Affidavit of Michael Wilbricht Page 1 of 3

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 "Special Nuclear Material (SNM) and Source Material (SM)

Physical Inventory Summary Report" 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 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 will suffer considerable competitive harm if the content of the "Special Nuclear Material (SNM) and Source Material (SM) Physical Inventory Summary Report" is made available to Framatome's domestic and international competitors because of the potential to undermine the financial position of Framatome. Finally, this information cannot be reasonably segregated from other material which may not meet the criteria set forth in 10 CFR § 2.390.

Dated this 3 rd day of June, 2020 Michael Wilbricht Sr. Safeguards Specialist Affidavit of Michael Wilbricht Page 2 of 3

STATE OF WASHINGTON )

ss COUNTY OF BENTON )

On this 3 rd day of June, 2020, before me, the undersigned, a Notary Public in and for the State of Washington, duly commissioned and sworn, personally appeared Michael Wilbricht to me known to be the Sr Safeguards Specialist 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. ,,,,1111,,,,,,1

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Affidavit of Michael Wilbricht Page 3 of 3