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| issue date = 05/16/2014
| issue date = 05/16/2014
| title = Affidavits for Attachments 1 and 2
| title = Affidavits for Attachments 1 and 2
| author name = Opsal P A
| author name = Opsal P
| author affiliation = AREVA, Inc
| author affiliation = AREVA, Inc
| addressee name =  
| addressee name =  
Line 17: Line 17:


=Text=
=Text=
{{#Wiki_filter:AFFIDAVIT COMMONWEALTH OF VIRGINIA  
{{#Wiki_filter:AFFIDAVIT COMMONWEALTH OF VIRGINIA               )
)) ss.CITY OF LYNCHBURG  
                                          ) ss.
)1. My name is Philip A. Opsal. I am Manager, Product Licensing, for AREVAInc. (AREVA) and as such I am authorized to execute this Affidavit.
CITY OF LYNCHBURG                       )
: 2. I am familiar with the criteria applied by AREVA to determine whether certainAREVA information is proprietary.
: 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.
I am familiar with the policies established byAREVA to ensure the proper application of these criteria.
: 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:  
: 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.
"32-9215084-001,  
: 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
'ASME Section III End of Life Analysis of PVNGS3 RV BMINozzle Repair',"  
 
"32-9215089-001,  
public. Based on my experience, I am aware that other companies regard information of the kind contained in these Documents as proprietary and confidential.
'Weld Residual Stress Analysis for PVNGS3 RV BMI NozzleRepair',"  
: 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."
"32-9215090-001,  
: 6. The following criteria are customarily applied by AREVA to determine whether information should be classified as proprietary:
'ASME Section XI End of Life Analysis of PVNGS3 RV BMI NozzleRepair',"  
(a)   The information reveals details of AREVA's research and development plans and programs or their results.
"32-9216967-001,  
(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.
'Natural Frequency and Structural Integrity Analysis for PVNGS3 RVBMI Nozzle Repair',"
(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.
and "32-9217241-002,  
(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.
'Palo Verde Unit 3 -BMI Nozzle Crack GrowthAnalysis',"
(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.
and referred to herein as "Documents."
The information in these Documents is considered proprietary for the reasons set forth in paragraphs 6(c) and 6(d) above.
Information contained in these Documents have been classified by AREVA as proprietary in accordance with the policies established byAREVA for the control and protection of proprietary and confidential information.
Enclosure Affidavit for Attachment 1
: 4. These Documents contain information of a proprietary and confidential natureand is of the type customarily held in confidence by AREVA and not made available to theEnclosure 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.
public. Based on my experience, I am aware that other companies regard information of thekind contained in these Documents as proprietary and confidential.
: 8.       AREVA policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.
: 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.
: 9.       The foregoing statements are true and correct to the best of my knowledge, information, and belief.
The request for withholding of proprietary information ismade in accordance with 10 CFR 2.390. The information for which withholding from disclosure is requested qualifies under 10 CFR 2.390(a)(4)  
SUBSCRIBED before me this ./
"Trade secrets and commercial or financial information."
day of ....Aý2ri                 2014.
: 6. The following criteria are customarily applied by AREVA to determine whetherinformation should be classified as proprietary:
Ella F. Carr-Payne NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 8/31/2017 Reg. # 309873
(a) The information reveals details of AREVA's research and development plansand programs or their results.(b) Use of the information by a competitor would permit the competitor tosignificantly 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  
            ',OTARY "         ;
: aprocess, methodology, or component, the application of which results in acompetitive advantage for AREVA.(d) The information reveals certain distinguishing aspects of a process,methodology, or component, the exclusive use of which provides acompetitive advantage for AREVA in product optimization or marketability.
    ~ :: "   PUBLIC     "-   .
(e) The information is vital to a competitive advantage held by AREVA, would behelpful to competitors to AREVA, and would likely cause substantial harm tothe competitive position of AREVA.The information in these Documents is considered proprietary for the reasons set forth inparagraphs 6(c) and 6(d) above.Enclosure Affidavit for Attachment 1  
873
: 7. In accordance with AREVA's policies governing the protection and control ofinformation, 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.
: REG # 309 My cOMMISSION       <
: 8. AREVA policy requires that proprietary information be kept in a secured file orarea 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 ....A&#xfd;2ri 2014.Ella F. Carr-Payne NOTARY PUBLIC, COMMONWEALTH OF VIRGINIAMY COMMISSION EXPIRES:
  % * ",     EXPIRES
8/31/2017 Reg. # 309873',OTARY " ;:: " ~ PUBLIC "- .: REG # 309873My cOMMISSION  
    % "... 8131/120`17     4 $:
<% ", EXPIRES : :% "... 8131/120`17 4 $....;,-],Enclosure Affidavit for Attachment 1
LT**
AFFIDAVIT COMMONWEALTH OF VIRGINIA  
                .... ;,-],
)) ss.CITY OF LYNCHBURG  
Enclosure Affidavit for Attachment 1
)1. My name is Nathan E. Hottle. I am Manager, Product Licensing, for AREVAInc. (AREVA) and as such I am authorized to execute this Affidavit.
 
: 2. I am familiar with the criteria applied by AREVA to determine whether certainAREVA information is proprietary.
AFFIDAVIT COMMONWEALTH OF VIRGINIA               )
I am familiar with the policies established by AREVA toensure the proper application of these criteria.
                                        ) 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:
: 3. I am familiar with the AREVA information contained in the following document:
"51-9213061-001,  
"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.
'Corrosion Evaluation for Palo Verde Unit 3 Reactor Vessel Bottom MountedInstrument Nozzle Modification',"
: 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.
and referred to herein as "Document."
: 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
Information contained in this Document has been classified by AREVA as proprietary in accordance with the policiesestablished by AREVA for the control and protection of proprietary and confidential information.
 
: 4. This Document contains information of a proprietary and confidential natureand is of the type customarily held in confidence by AREVA and not made available to thepublic. Based on my experience, I am aware that other companies regard information of thekind contained in this Document as proprietary and confidential.
requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial information."
: 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 bewithheld from public disclosure.
: 6.       The following criteria are customarily applied by AREVA to determine whether information should be classified as proprietary:
The request for withholding of proprietary information is made inaccordance with 10 CFR 2.390. The information for which withholding from disclosure isEnclosure Affidavit for Attachment 2
(a)     The information reveals details of AREVA's research and development plans and programs or their results.
requested qualifies under 10 CFR 2.390(a)(4)  
(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.
"Trade secrets and commercial or financial information."
(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.
: 6. The following criteria are customarily applied by AREVA to determine whetherinformation should be classified as proprietary:
(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.
(a) The information reveals details of AREVA's research and development plansand programs or their results.(b) Use of the information by a competitor would permit the competitor tosignificantly 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  
(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.
: aprocess, methodology, or component, the application of which results in acompetitive advantage for AREVA.(d) The information reveals certain distinguishing aspects of a process,methodology, or component, the exclusive use of which provides acompetitive advantage for AREVA in product optimization or marketability.
The information in this Document is considered proprietary for the reasons set forth in paragraphs 6(c) and 6(d) above.
(e) The information is vital to a competitive advantage held by AREVA, would behelpful to competitors to AREVA, and would likely cause substantial harm tothe competitive position of AREVA.The information in this Document is considered proprietary for the reasons set forth inparagraphs 6(c) and 6(d) above.7. In accordance with AREVA's policies governing the protection and control ofinformation, proprietary information contained in this Document has been made available, on alimited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
: 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 orarea and distributed on a need-to-know basis.Enclosure Affidavit for Attachment 2  
: 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 6 drli ,2014.Sherry L. McFadenNOTARY PUBLIC, COMMONWEALTH OF VIRGINIAMY COMMISSION EXPIRES:
Enclosure Affidavit for Attachment 2
10/31/14Reg. # 7079129SHERRY L. MCFADENNotarV PublicCommonwealth of Virginia7079129My Commission Expires Oct 31, 2014Enclosure 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}}

Latest revision as of 20:50, 5 February 2020

Affidavits for Attachments 1 and 2
ML14149A097
Person / Time
Site: Palo Verde Arizona Public Service icon.png
Issue date: 05/16/2014
From: Opsal P
AREVA
To:
Office of Nuclear Reactor Regulation
Shared Package
ML14141A524 List:
References
102-06880-JJC/JHK/DCE
Download: ML14149A097 (6)
v • d • e


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

',OTARY "  ;

~ :: " PUBLIC "- .

873

REG # 309 My cOMMISSION <

% * ", EXPIRES

% "... 8131/120`17 4 $:

LT**

....  ;,-],

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

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