ML23020A944
| ML23020A944 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 01/20/2023 |
| From: | Elliott G Entergy Nuclear Operations, Framatome |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML23020A940 | List: |
| References | |
| 2CAN012302 | |
| Download: ML23020A944 (1) | |
Text
ENCLOSURE 3 2CAN012302 AFFIDAVIT (3 Pages)
A F F I D A V I T
- 1.
My name is Gayle Elliott. I am Deputy Director, Licensing and Regulatory Affairs, for Framatome Inc. (Framatome) 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 documents:
x Calculation Summary Sheet 32-9348826-002, ASME Section III Stress &
Fatigue Analysis for ANO-2 CEDM Half Nozzle Repair (Penetration 46),
December 2022 x
Calculation Summary Sheet 32-9352239-001, IDTB Weld Anomaly Assessment at CEDM Nozzle No. 46 at ANO-2, December 2022 x
Calculation Summary Sheet 32-9352384-001, ANO-2 RVCH CEDM Penetration No. 46 IDTB Repair As-Left J-Groove Weld Analysis, December 2022 x
Engineering Information Record 51-9338948-001, Corrosion Evaluation of ANO-2 RVCH CEDM IDTB Weld Nozzle Penetration Repair, November 2021 x
Engineering Information Record 51-9352242-000, ANO-2 CEDM Penetration 46 Modification Assessment Summary, December 2022 x
Technical Report ANP-4023, Revision 0, Arkansas Nuclear One, Unit 2 Relief Request for Half-Nozzle Repair of RVCH Penetration #46, December 2022 These documents are referred to herein as Documents. Information contained in these Documents has been classified by Framatome as proprietary in accordance with the policies established by Framatome for the control and protection of proprietary and confidential information.
- 4.
These Documents contain information of a proprietary and confidential nature and is of the type customarily held in confidence by Framatome and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in these Documents as proprietary and confidential.
- 5.
These Documents have been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in these Documents 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 10 CFR 2.390(a)(4) Trade secrets and commercial or financial information.
- 6.
The following criteria are customarily applied by Framatome to determine whether information should be classified as proprietary:
(a)
The information reveals details of Framatomes 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.
(d)
The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for Framatome in product optimization or marketability.
(e)
The information is vital to a competitive advantage held by Framatome, would be helpful to competitors to Framatome, and would likely cause substantial harm to the competitive position of Framatome.
The information in these Documents is considered proprietary for the reasons set forth in paragraph 6(c), (d), and (e) above.
- 7.
In accordance with Framatomes policies governing the protection and control of information, proprietary information contained in these Documents has been made available, on a limited basis, to others outside Framatome only as required and under suitable agreement providing for nondisclosure and limited use of the information.
- 8.
Framatome 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.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on: December 15, 2022 Gayle Elliott ELLIOTT Gayle Digitally signed by ELLIOTT Gayle Date: 2022.12.15 16:35:35 -05'00'