ML13078A292

Areva Affidavit for Areva Calculations #32-9199805-000, Diablo Canyon Power Plant Unit 2 Pzr Safety and Spray Nozzles Planar Flaw Analysis (Proprietary) and #32-9199937-000, DCPP Unit 2 - Evaluation of Laminar Indications in Pressurizer Noz

ML13078A292
Person / Time
Site:	Diablo Canyon
Issue date:	03/05/2013
From:	Elliott G F AREVA NP
To:	Office of Nuclear Reactor Regulation
Shared Package
ML130780374	List: DCL-13-021, Areva Affidavit for Areva Calculations 32-9199805-000, Diablo Canyon Power Plant Unit 2 Pzr Safety and Spray Nozzles Planar Flaw Analysis (Proprietary) and 32-9199937-000, DCPP Unit 2 - Evaluation of Laminar Indications in Pressurizer N DCL-13-021, Areva Calculation 32-9200249-000, Diablo Canyon Power Plant Unit 2 Pzr Safety and Spray Nozzles Planar Flaw Analysis - Non Proprietary DCL-13-021, Areva Calculation 32-9200291-000, DCPP Unit 2 - Evaluation of Laminar Indications in Pressurizer Nozzles (Non-Proprietary) DCL-13-021, Performance Demonstration Initiative (POI) Program Alternatives and Their Bases with Respect to ASME Code Section Xi, Appendix Viii Supplement 11 Requirements ML13078A291 ML13078A292 ML13078A293 ML13078A294 ML13078A297
References
DCL-13-021
Download: ML13078A292 (4)

Text

Enclosures 3 and 4 contain Proprietary Information

-Withhold Under 10 CFR 2.390 Enclosure 5 PG&E Letter DCL-13-021 AREVA Affidavit for AREVA Calculation

1. 32-9199805-000, "Diablo Canyon Power Plant Unit 2 PZR Safety and Spray Nozzles Planar Flaw Analysis" (Proprietary)

And AREVA Calculation

1. 32-9199937-000, "DCPP Unit 2 -Evaluation of Laminar Indications in Pressurizer Nozzles" (Proprietary)

Enclosures 3 and 4 contain Proprietary Information When separated from Enclosures 3 and 4 , this document is decontrolled.

AFFIDAVIT COMMONWEALTH OF VIRGINIA ) ) ss. CITY OF LYNCHBURG ) 1. My name is Gayle F. Elliott. I am Manager, Product Licensing, for AREVA NP Inc. (AREVA NP) and as such I am authorized to execute this Affidavit.

2. I am familiar.

with the criteria applied by AREVA NP to determine whether certain AREVA NP information is proprietary.

I am familiar with the. policies established by AREVA NP to ensure the proper application of these criteria.

3. I am familiar with the AREVA NP information contained in the Calculation Summary Sheets (CSS) 32-9199805-000, entitled "Diablo Canyon Power Plant Unit 2 PZR Safety and Spray Nozzles Planar Flaw Analysis" dated March 2013, and 32-9199937-000, entitled "DCPP-2 Unit 2 -Evaluation of Laminar Indications on Pressurizer Nozzles," dated March 2013 and referred to herein as "Documents." Information contained in these Documents has been classified by AREVA NP as proprietary in accordance with the policies established by AREVA NP 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 AREVA NP 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 I information." 6. The following criteria are customarily applied by AREVA NP to determine whether information should be classified as proprietary: (a) The information reveals details of AREVA NP'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 AREVA NP. (d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA NP in product optimization or marketability. (e) The information is vital to a competitive advantage held by AREVA NP, would be helpful to competitors to AREVA NP, and would likely cause SUbstantial harm to the competitive position of AREVA NP. The information in these Documents is considered proprietary for the reasons set forth in paragraphs 6(c) and 6(d) above. 7. In accordance with AREVA NP's policies governing the protection and control of information, proprietary information contained in these Documents have been made available, on a limited basis, to others outside AREVA NP only as required and under suitable agreement providing for nondisclosure and limited use of the information.

8. AREVA NP 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

__ day of mJU1;\v ,2013. Sherry L. McFaden NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 10/31/14 . Reg. # 7079129

l. MCFADEN Public commonwea,*th of Vlrgtnia 7079129 My Commission Expires Oct 31. 2Q14