ML14149A097

Affidavits for Attachments 1 and 2

ML14149A097
Person / Time
Site:	Palo Verde
Issue date:	05/16/2014
From:	Opsal P A 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 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.

I am familiar with the policies established byAREVA 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 BMINozzle Repair',"

"32-9215089-001,

'Weld Residual Stress Analysis for PVNGS3 RV BMI NozzleRepair',"

"32-9215090-001,

'ASME Section XI End of Life Analysis of PVNGS3 RV BMI NozzleRepair',"

"32-9216967-001,

'Natural Frequency and Structural Integrity Analysis for PVNGS3 RVBMI Nozzle Repair',"

and "32-9217241-002,

'Palo Verde Unit 3 -BMI Nozzle Crack GrowthAnalysis',"

and referred to herein as "Documents."

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.

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

public. Based on my experience, I am aware that other companies regard information of thekind 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 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)

"Trade secrets and commercial or financial information."

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

(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

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.

(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

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.

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 ....Aý2ri 2014.Ella F. Carr-Payne NOTARY PUBLIC, COMMONWEALTH OF VIRGINIAMY COMMISSION EXPIRES:

8/31/2017 Reg. # 309873',OTARY " ;:: " ~ PUBLIC "- .: REG # 309873My cOMMISSION

<% ", EXPIRES : :% "... 8131/120`17 4 $....;,-],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 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.

I am familiar with the policies established by AREVA toensure 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 MountedInstrument Nozzle Modification',"

and referred to herein as "Document."

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.

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.

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

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 whetherinformation should be classified as proprietary:

(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

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.

(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.

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

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:

10/31/14Reg. # 7079129SHERRY L. MCFADENNotarV PublicCommonwealth of Virginia7079129My Commission Expires Oct 31, 2014Enclosure Affidavit for Attachment 2