ML14149A097

Affidavits for Attachments 1 and 2

ML14149A097
Person / Time
Site:	Palo Verde
Issue date:	05/16/2014
From:	Opsal P AREVA
To:	Office of Nuclear Reactor Regulation
Shared Package
ML14141A524	List: ML14141A545 ML14149A097
References
102-06880-JJC/JHK/DCE
Download: ML14149A097 (6)

Text

AFFIDAVIT COMMONWEALTH OF VIRGINIA )

) ss.

CITY OF LYNCHBURG )

1. My name is Philip A. Opsal. I am Manager, Product Licensing, for AREVA Inc. (AREVA) and as such I am authorized to execute this Affidavit.

2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary. I am familiar with the policies established by AREVA to ensure the proper application of these criteria.

3. I am familiar with the AREVA information contained in the following documents: "32-9215084-001, 'ASME Section III End of Life Analysis of PVNGS3 RV BMI Nozzle Repair'," "32-9215089-001, 'Weld Residual Stress Analysis for PVNGS3 RV BMI Nozzle Repair'," "32-9215090-001, 'ASME Section XI End of Life Analysis of PVNGS3 RV BMI Nozzle Repair'," "32-9216967-001, 'Natural Frequency and Structural Integrity Analysis for PVNGS3 RV BMI Nozzle Repair'," and "32-9217241-002, 'Palo Verde Unit 3 - BMI Nozzle Crack Growth Analysis'," and referred to herein as "Documents." Information contained in these Documents have been classified by AREVA as proprietary in accordance with the policies established by AREVA 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 and not made available to the Enclosure Affidavit for Attachment 1

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 AREVA to determine whether information should be classified as proprietary:

(a) The information reveals details of AREVA'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.

(d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability.

(e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA.

The information in these Documents is considered proprietary for the reasons set forth in paragraphs 6(c) and 6(d) above.

Enclosure Affidavit for Attachment 1

7. In accordance with AREVA'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 only as required and under suitable agreement providing for nondisclosure and limited use of the information.

8. AREVA 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 ....Aý2ri 2014.

Ella F. Carr-Payne NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 8/31/2017 Reg. # 309873

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Enclosure Affidavit for Attachment 1

AFFIDAVIT COMMONWEALTH OF VIRGINIA )

) ss.

CITY OF LYNCHBURG )

1. My name is Nathan E. Hottle. I am Manager, Product Licensing, for AREVA Inc. (AREVA) and as such I am authorized to execute this Affidavit.

2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary. I am familiar with the policies established by AREVA to ensure the proper application of these criteria.

3. I am familiar with the AREVA information contained in the following document:

"51-9213061-001, 'Corrosion Evaluation for Palo Verde Unit 3 Reactor Vessel Bottom Mounted Instrument Nozzle Modification'," and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA 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 AREVA 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 10 CFR 2.390. The information for which withholding from disclosure is Enclosure Affidavit for Attachment 2

requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial information."

6. The following criteria are customarily applied by AREVA to determine whether information should be classified as proprietary:

(a) The information reveals details of AREVA'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.

(d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability.

(e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA.

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

7. In accordance with AREVA's 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 AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.

8. AREVA policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.

Enclosure Affidavit for Attachment 2

9. The foregoing statements are true and correct to the best of my knowledge, information, and belief.

SUBSCRIBED before me this ____

day of 6 drli ,2014.

Sherry L. McFaden NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 10/31/14 Reg. # 7079129 SHERRY L.MCFADEN NotarV Public Commonwealth of Virginia 7079129 My Commission Expires Oct 31, 2014 Enclosure Affidavit for Attachment 2