ML100830053

Proprietary Presentation Materials for the March 19, 2010 NRC Meeting Regarding Control Rod Drive Nozzle Idtb Repair for

ML100830053
Person / Time
Site:	Davis Besse, PROJ0728
Issue date:	03/22/2010
From:	Gardner R AREVA NP
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC:10:021
Download: ML100830053 (4)

Text

A AREVA March 22, 2010 NRC:10:021 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Proprietary Presentation Materials for the March 19, 2010 NRC Meeting Regarding Control Rod Drive Nozzle IDTB Repair for Davis Besse Nuclear Power Station This letter provides AREVA NP Inc.'s (AREVA NP) presentation materials for the March 19, 2010 meeting with the NRC staff regarding the Control Rod Drive Nozzle IDTB Repair for Davis Besse.

AREVA NP considers the material contained in the enclosure to be proprietary. As required by 10 CFR 2.390(b), an affidavit is enclosed to support the withholding of the information from public disclosure. As the documents are proprietary in their entirety, non-proprietary versions are not included.

If you have any questions related to this submittal, please contact me by telephone at 434-832-5089 or by e-mail at Ronnie.,qardneraareva.com Sincerely, Ronnie L. Gardner, Manager Corporate Regulatory Affairs AREVA NP Inc.

Enclosures cc: J. W. Collins H.D. Cruz T. R. Lupold J. C. Tsao Project 728 AD~O AREVA NP INC.

An AREVA and Slemena company 3315 Old Forest Road, P.O. Box 10935, Lynchburg, VA 24506-0935 Tel.: 434 832 3000 - Fax: 434 832 3840 - www.areva.com

AFFIDAVIT COMMONWEALTH OF VIRGINIA )

) ss.

CITY OF LYNCHBURG )

1. My name is Ronnie L. Gardner. I am Manager, Corporate Regulatory Affairs for AREVA NP Inc. 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 presentation materials and drawing 02-9134305E, Revision 000 associated with AREVA NP letter, NRC:10:021, dated March 22, 2010, entitled "Proprietary Presentation Materials for the March 19, 2010 NRC Meeting Regarding Control Rod Drive Nozzle IDTBRepair for Davis Besse Nuclear Power Station" 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 are 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 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(b) and 6(c) above.

7. In accordance with AREVA NP's policies governing the protection and control of information, proprietary information contained in these Documents has 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 / 2010.

Sherry L. McFaden NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 10/31/2010 Registration # 7079129 SDEY L. MCPACM "C"oi Public commo woamtOf [h~m MY Commission7079129 Explre8 Oct 31. 4010~l v v*