ML22028A192

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Attachment 7: Proprietary Affidavit for Timothy J. Tate
ML22028A192
Person / Time
Site: 07109372
Issue date: 01/28/2022
From: Travis Tate
Framatome
To:
Office of Nuclear Material Safety and Safeguards
Shared Package
ML22028A184 List:
References
TJT:22:003
Download: ML22028A192 (3)


Text

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

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ss; COUNTY OF BENTON

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1.

My name is Timothy J. Tate. I am the Manager, Environmental, Health, Safety and Licensing for Framatome Inc. (Framatome) at Framatomes 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 in the following attachments:

  • , FS1-0014159, Revision 10.0, Framatome TN-B1 Docket No. 71-9372 Safety Analysis Report.
  • , List of Drawing Changes,
  • , FS1-0027837, Revision 6.0, Criticality Analysis for the TN-B1 Shipping Container with the ATRIUM-11 Fuel Design.
  • , E04-10-004, Version 1.0, TN-B1 Sensitivity Studies.

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 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.

Affidavit of Timothy Tate Page 1 of 3 NRC Application 1/28/2022

Proprietary Information submitted under 10 CFR § 2.390

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.

5.

The application for the License Amendment utilizing Framatome TN-B1 Docket No. 71-9372 Safety Analysis Report, FS1-0014159 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 Framatomes 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.

Affidavit of Timothy Tate Page 2 of 3 NRC Application 1/28/2022

Proprietary Information submitted under 10 CFR § 2.390

9. The foregoing statements are true and correct to the best of my knowledge, information, and belief.

Dated this 28th day of January 2022 Timothy J. Tate, Manager Environmental, Health, Safety and Licensing Framatome Inc.

SUBSCRIBED before me this 28th day of January 2022.

NOTARY PUBLIC, MY COMMISSION TArWlZ_____

STATE OF WASHINGTON EXPIRES: April 26, 2022 J

DEBBIE COYNER Notary Public State of Washington My Commission Expires April ?022 j.............. imiiiiKwr--'.-

l Affidavit of Timothy Tate Page 3 of 3 NRC Application 1/28/2022