ML23291A205
| ML23291A205 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 10/18/2023 |
| From: | Travis Tate Framatome |
| To: | Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML23291A203 | List: |
| References | |
| TJT:23:025 | |
| Download: ML23291A205 (1) | |
Text
STATE OF WASHINGTON )
COUNTY OF BENTON ) AFFIDAVIT ss Timothy J. Tate, being duly sworn on oath, states as follows:
1.I am employed by Framatome Inc. (Framatome) as Manager, Environmental, Health, Safety and Licensing in Richland, Washington. I am responsible for the overall administration of the safety programs at Framatome's Richland, Washington nuclear fuel fabrication facility, including regulatory licensing and permitting. This affidavit is based on my firsthand, personal knowledge and is submitted in my capacity as Manager, Environmental, Health, Safety and Licensing.
2.I am familiar with the contents of Attachment 1) (E04-04-010, Ver. 2.0),
"SCALE 6.2.2 20 wt.% Enrichment Benchmark Validation Report", Attachment 2)
(FS1-0067669, Rev. 2.0), "SCALE 6.2.2 Criticality Safety Validation to 20 wt%
Enrichment" and Attachment 3) "Framatome Response to Request for Additional Information". These documents have been classified and designed 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. 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.
4.These documents contain commercial information of a confidential nature that is not available in public sources or available to the public. This information is commercial and confidential because it:
Affidavit of Timothy J. Tate Page 1 of 2 A.Reveals distinguishing aspects of Framatome's business which a competitor within the field of nuclear fuel manufacturing may adapt for their business plans, thereby gaining a competitive advantage to the disadvantage of Framatome.
B.Reveals technical work performed by Framatome which a competitor could readily use without expenditure of funds and replicate this work thereby gaining a competitive advantage to the disadvantage of Framatome.
5.Framatome Inc. will suffer considerable competitive harm if the contents of these documents are made available to Framatome domestic and international competitors.
Dated this __ I _8-day of October 2023.
Timothy J. Tate Manager, Environmental, Health, Safety and Licensing STATE OF WASHINGTON )
COUNTY OF BENTON )ss On this / f day of October, 2023, before me, the undersigned, a Notary Public in and for the State of Washington, duly commissioned and sworn, personally appeared Timothy J. Tate to me known to be the Manager, Environmental, Health, Safety and Licensing 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.
gh'l rJ Sand Mariscal Notary Public in and for the State of Washington, residing at Benton, Washington.
My Commission Expires: 02/10/2027