ML17207A171

Enclosure 2: Affidavit of Areva Np, Inc

ML17207A171
Person / Time
Site:	North Anna
Issue date:	10/31/2016
From:	Marshall E AREVA NP
To:	Office of Nuclear Reactor Regulation
Shared Package
ML17207A161	List: ML17207A170 ML17207A171 ML17207A172 ML17207A173 ML17207A174
References
16-383A
Download: ML17207A171 (5)

Text

Serial No. 16-383A Docket Nos.: 50-338/339 Enclosure 2 AFFIDAVIT OF AREVA NP, Inc.

VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2

A AREVA October 31, 2016 FAB16-00630 Mr. Brian Vitiello Dominion Resources Services, Inc.

Innsbrook Technical Center, 3rd, SW 5000 Dominion Boulevard Glen Allen, VA 23060

Subject:

Affidavit Supporting AREVA Proprietary Information Contained in Dominion's North Anna Power Station Licensing Amendment Request Reference 1: Fuel Fabrication and Related Services Contract between Dominion Nuclear Connecticut, Inc and AREVA NP, Inc. dated February 1, 2011 as amended through Amendment 3, dated November 2, 2015.

Reference 2: Request for Proprietary Affidavit to Support North Anna Power Station Licensing Amendment Request, CORRES-OUT-AREVA-20160065 Rev. 0, dated October 12, 2016, from Mike Lico. AREVA document 38-9264076-000.

Dear Mr. Vitiello,

The attached Affidavit supports Dominion's use of AREVA proprietary information in Dominion's Licensing Amendment Request (LAR) that will revise the North Anna Power Statior:i spent fuel poof criticality analysis. The information identified as proprietary in Reference 2 had previously beeri supplied to Dominion in AREVA documents as proprietary.

Note that the attached contains AREVA Proprietary data and is to be treated according to Reference

1. If you have any questions*or comments, feel free to call me at (434) 832-5029, or you can e-mail me at Hunter.Marshall@areva.com.

Sincerely,

~41-~

E. Hunter Marshall Project Manager Cc: Chris Clemens Tom Brookmire Cary Laroe John Harrell Stacey Nelson Michael Lico AREVA INC.

33 \5 Old Forest Roa:d: Lynchburg. VA 24601 Tel.: 4 3'1* 83:2 3000

• www.areva.com ARE.VA PROPRIETARY This document end any lnfonnaUon contained herein, Is the property or AAEl/A Inc. (AAEVA) and Is to be considered proprfetruy and ccnnden!lal and may not be reproduced or copied In whole or In part. Nor may ltbe furnished to others wlt11out U1e expres* wrlUen con*E!11t and permls*lon of AREVA, nor may It be u*ed in anyway that Is or may be detrimental to AREVA. This doC<Jment end any copies !hat may have been made must be returned to AREVA upon re(!uest,

AFFIDAVIT COMMONWEALTH OF VIRGINIA )

) SS.

CITY OF LYNCHBURG )

1. My name is Gayle Elliott. I am Deputy Director, Licensing & Regulatory Affairs, for AREVA Inc. (AREVA) and as such I am authorized to execute this Affidavit.

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

3. I am familiar with the AF}.EVA Information contained in the Attachment to a letter from Mr. Mark Sartain (Dominion Generation) to U.S. NRC entitled, "Virginia Electric and Power Company North Anna Power Station Units 1and2 Proposed Technical Specification Change for Spent Fuel Storage and New Fuel Storage," Cover Letter# 16-383, 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 Inc. for the control and protection of proprietary and confidential information.

4. This Document contains information of a pr<;>prietary an.d 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 avaUable 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 ls 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 info~mation 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 l.

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 optimlzati':>n or marketability.

(e) The Information is vital to a competitive advantage held by AR~VA, 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), 6(d) and 6(e) above.

7. In accordance with AREVA's policies governing the protection and control of information, proprietary Information contained in this Document has been made avallable, on a liryiited basis, to others outside AREVA only as re~uired 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 st~tements are true and correct to the best of my knowledge, information, and belief.

SUBSCRIBED before me this dayof ()~ I 2016, Sherry L. McFaden NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 10/31/18 Reg. # 7079129 i SHERRY t:.. MOFADEN Notiry* P1,1biii:

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