ML21090A323

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Framatome, Inc. - Affidavit
ML21090A323
Person / Time
Site: 07109319
Issue date: 03/31/2021
From: Travis Tate
Framatome
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards
Shared Package
ML21090A321 List:
References
TJT:21:007
Download: ML21090A323 (2)


Text

Proprietary Information submitted under 10 CFR § 2.390 AFFIDAVIT STATE OF WASHINGTON )

ss:

COUNTY OF BENTON )

1. My name is Timothy J. Tate. I am the Manager, Environmental, Health, Safety and Licensing for Framatome Inc. ("Framatome") at Framatome's Richland, Washington facility and as such I am authorized to execute this Affidavit.
2. I am familiar with the criteria applied by Framatome to determine whether certain Framatome information is proprietary. I am familiar with the policies established by Framatome to ensure the proper application of these criteria.
3. I am familiar with the Framatome information contained Attachment A, FS1-0038397-5.0 "MAP PWR Fuel Shipping Package -

USA/9319/B(U)-96" (Proprietary); which provides nuclear fuel and packaging design information for the Framatome, Richland, Washington Fuel Fabrication Facility as required by 10 CFR § 71.0. Information contained in these documents 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.

4. 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.

Affidavit of Timothy Tate NRC Application 03/31/2021 Page 1 of 2

Proprietary Information submitted under 10 CFR § 2.390

5. The application for Certificate of Compliance for "MAP PWR Fuel Shipping Package - USA/9319/B(U)-96", FS1-0038397 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.
6. 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 10 CFR § 2.390.
9. The foregoing statements are true and correct to the best of my knowledge, information, and belief.

Dated this 31 st day of March, 2021 Timothy J. Tate, Manager Environmental, Health, Safety and Licensing Framatome Inc.

SUBSCRIBED before me this 31 st day of March, 2021. ,,,,,,,u,,,,,,,

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,,, ,,,r*. ,,,,, 1 Affidavit of Timothy Tate NRG Application 03/31/2021 Page 2 of 2