ML22202A431

Enclosure a: Affidavit

ML22202A431
Person / Time
Site:	Davis Besse
Issue date:	04/25/2019
From:	Opsal P Energy Harbor Nuclear Corp, Framatome
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML22201A429	List: ML22202A431
References
L-22-141
Download: ML22202A431 (4)

Text

Enclosure A L-22-141 Affidavit Pursuant to 10 CFR 2.390 for ANP-2718-007 (4 Pages Follow)

0414-12-F01 (Rev. 002 01/15/2018) framatome LICENSING DOCUMENT APPROVAL Licensing Document Approval for:

77-2718P and 77-2718NP-007, Appendix G Pressure-Temperature limits for 52 EFPY for Davis-Besse Nuclear Power Station Document Number/TIiie Document Preparer:

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4/11bcJ19 Mark A. Rinckel Print Name Signature Date Preparer's Technical Manager:

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if /Ii JI 1 Jeffrey M. Fleck Print Name

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Date Reviewer:

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Ashok D. Nana 4/1~ Ii 9

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bate Print Name Signature Project Manager:

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Beverly J. Watson AWA/~

Print Name Signature Date Regulatory Affairs:

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'1 /21 )1'1 Philip A Opsal Print Name Signature I

'Date Page 1 of 1

AFFIDAVIT COMMONWEAL TH OF VIRGINIA

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CITY OF LYNCHBURG

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1.

My name is Philip A. Opsal. I am Manager, Product Licensing, for Framatome Inc., (formally known as AREVA Inc.), and as such I am authorized to execute this Affidavit.

2.

I am familiar with the criteria applied by Framatome Inc., to determine whether certain Framatome Inc. information is proprietary. I am familiar with the policies established by Framatome Inc. to ensure the proper application of these criteria.

3.

I am familiar with the Framatome Inc. information contained in the following document: Framatome (formally AREVA Inc.) Document No. 77-2718P-007, "Appendix G Pressure-Temperature Limits for 52EFPY for Davis-Besse Nuclear Power Station," ANP-2718P, Rev. 007, April 2019, referred to herein as "Document." Information contained in this Document has been classified by Framatome Inc. as proprietary in accordance with the policies established by Framatome Inc. 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 Framatome Inc. and not made available to the public. Based Ot'1 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 0 CFR 2.390(a)(4) "Trade secrets and commercial or financial information."

6.

The following criteria are customarily applied by Framatome Inc. to determine whether information should be classified as proprietary:

(a)

The information reveals details of Framatome lnc.'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 Framatome Inc.

(d)

The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for Framatome Inc. in product optimization or marketability.

(e)

The information is vital to a competitive advantage held by Framatome Inc.,

would be helpful to competitors to Framatome Inc., and would likely cause substantial harm to the competitive position of Framatome Inc.

The information in this Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(c) and 6(d) above.

7.

In accordance with Framatome lnc.'s policies governing the protection and control of information, proprietary information contained in this Document has been made available, on a limited basis, to others outside Framatome Inc. only as required and under suitable agreement providing for nondisclosure and limited use of the information.

8.

Framatome Inc. 's 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 25 day of Apr1 l

, 2019.

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Heidi Hamilton Elder NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 12/31/2022 Reg. # 7777873