ULNRC-06586, Attachment 4 - Affidavit

Attachment 4 - Affidavit

ML20178A674
Person / Time
Site:	Callaway
Issue date:	06/24/2020
From:	Elliott G Ameren Missouri, Framatome, Union Electric Co
To:	Office of Nuclear Reactor Regulation
Shared Package
ML20178A668	List: ML20178A669 ML20178A671 ML20178A673 ML20178A675 ML20178A676 ULNRC-06586, Attachment 4 - Affidavit
References
ULNRC-06586
Download: ML20178A674 (4)

Text

Attachment 4 to U LN RC-06586 Affidavit

AFFIDAVIT I . My name is Gayle Elliott. I am Deputy Director, Licensing & Regulatory Affairs for Framatome Inc. (Framatome), formerly AREVA NP Inc., 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 Engineering Information Record, Document No. 51-9312589-000, entitled, Callaway Unit 1 Steam Generator Operational Assessment to Support Deferral of Planned Inspections from 1 R24 to 1 R25, dated May 2020, and referred to herein as Document. Information contained in this Document 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. This Document contains 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 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 I 0 CFR 2.390. The information for which withholding from disclosure is requested qualifies under I 0 CFR 2.390(a)(4) Trade secrets and commercial or financial information.

6. The following crteria 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 this Document is considered proprietary for the reasons set forth in paragraphs 6(d) and 6(e) above.

7. In accordance with Framatomes 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 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: June 24, 2020 Gayle Elliott