Text

Enclosure 9, Areva Affidavits
	ML15348A220
Person / Time
Site:	Monticello
Issue date:	08/26/2015
From:	; AREVA
To:	; Office of Nuclear Reactor Regulation
Shared Package
ML15348A222	List: L-MT-15-057, License Amendment Request for Areva Extended Flow Window Supplement to Respond to NRC Staff Questions; ML15348A214; ML15348A215; ML15348A217; ML15348A219; ML15348A220;
References
	L-MT-15-057
	Download: ML15348A220 (7)
	v • d • e

AFFIDAVIT STATE OF WASHINGTON

) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.

I am Manager, Product Licensing, for AREVA Inc. 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 report ANP-3424P, Revision 0, "AREVA Responses to RAI from SCVB on MNGP EFW LAR," dated August 2015 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 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 the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 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 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 dayof lko1 '2015. Susan K. McCoy NOTARY PUBLIC, STATE OFWA INGTON MY COMMISSION EXPIRES:

1/14/2016 AFFIDAVIT STATE OF WASHINGTON

) ) SS. COUNTY OF BENTON ) 1. My name is Alan B. Meginnis.

I am Manager, Product Licensing, for AREVA Inc. 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 report ANP-3434P, Revision 1, "AREVA Responses to RAI from SRXB and SNPB on MNGP EFW LAR," CD Entitled, "AREVA Response to EFW LAR-SRXB/SNPB RAl-6," and CD Entitled, "AREVA Response to EFW LAR-SRXB/SNPB RAl-12" dated August 2015 and referred to herein as "Documents."

Information contained in these Documents 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. These Documents contain information of a proprietary and confidential nature and are 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 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(b), 6(d) and 6(e) above. 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 d_ /, f.;\-__ dayof ,2015. Susan K. McCoy NOTARY PUBLIC, STATE OF WASHIN MY COMMISSION EXPIRES:

1/14/2016 N