ULNRC-06695, Affidavit of Morris Byram, Framatome, Inc
| ML21279A287 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 09/30/2021 |
| From: | Byram M Framatome |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML21279A285 | List: |
| References | |
| ULNRC-06695 | |
| Download: ML21279A287 (4) | |
Text
Enclosure to ULNRC-06695
Affidavit A F F I D A V I T
- 1. My name is Morris Byram. I am Product Manager, Licensing & Regulatory
Af f airs f or F ramatome Inc. (F ramatome) and as such I am authorized to execute this Af fidavit.
2. I am f amiliar with th e cr ite r ia ap p lie d b y F r amato me to d e te r min e wh e th e r
certain Framatome inf ormation is proprietary. I am f amiliar with the policies established by
Framatome to ensure the proper application of these criteria.
- 3. I am f amiliar with the F r amatome inf or mation contained in the
slide presentation entitled Callaway VQP Pre-Submittal Meeting and ref erred to herein as
Document. Inf ormation contained in this Document has been classif ied by Framatome as
proprietary in accordance with the policies established by Framatome f or the control and
protection of proprietary and conf idential inf ormation.
- 4. This Document contains inf ormation of a proprietary and confidential nature
and is of the type customarily held in conf idence by Framatome and not made available to the
public. Based on my experience, I am aware that other companies regard inf ormation of the
kind contained in this Document as proprietary and conf idential.
- 5. This Document has been made available to the U.S. Nuclear Regulatory
Commission in conf idence with the request that the inf ormation contained in this Document be
withheld f rom public disclosure. The request f or withholding of proprietary inf ormation is made in
accordance with 10 CFR 2.390. The inf ormation f or which withholding f rom disclosure is
requested qualif ies under 10 CFR 2.390(a)(4) Trade secrets and commercial or f inancial
inf ormation.
- 6. The f ollowing criteria are customarily applied by Framatome to determine
whether inf ormation should be classif ied as proprietary:
(a) The inf ormation reveals details of Framatomes research and development
plans and programs or their results.
(b) Use of the inf ormation by a competitor would permit the competitor to
signif icantly reduce its expenditures, in time or resources, to design, produce,
or market a similar product or service.
(c) The inf ormation includes test data or analytical techniques concerning a
process, methodology, or component, the application of which results in a
competitive advantage f or Framatome.
(d) The inf ormation reveals certain distinguishing aspects of a process,
methodology, or component, the exclusive use of which provides a
competitive advantage f or Framatome in product optimization or marketability.
(e) The inf ormation is vital to a competitive advantage held by Framatome, would
be helpf ul to competitors to Framatome, and would likely cause substantial
harm to the competitive position of Framatome.
The inf ormation in this Document is considered proprietary f or the reasons set forth in
paragraph 6(d) above.
- 7. In accordance with Framatomes policies governing the protection and control
of inf ormation, 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 f or nondisclosure and limited use of the inf ormation.
- 8. Framatome policy requires that proprietary information be kept in a secured
f ile or area and distributed on a need-to-know basis.
- 9. The f oregoing statements are true and correct to the best of my knowledge,
inf ormation, and belief.
I declare under penalty of perjury that the f oregoing is true and correct.
Executed on: (9/30/2021)
____________________________________ BYRAM Morris Digitally signed by BYRAM Morris Date: 2021.09.30 15:06:22 -07'00' (NAME)