ML22172A207

Affidavit Dated June 16, 2022

ML22172A207
Person / Time
Site:	Turkey Point
Issue date:	06/16/2022
From:	Elliott G Framatome
To:	Michael Mahoney NRC/NRR/DORL/LPL2-2
Mahoney M
References
Download: ML22172A207 (3)

Text

A F F I D A V I T

1. My name is Gayle Elliott. I am Deputy Director, Licensing and Regulatory

Affairs, for Framatome Inc. (Framatome) and as such I am authorized to execute this Affidavit.

2. I am familiar with the criteria applied by Framatome to determine whether

certain Framatome information is proprietary. I am familiar with the policies established by

Framatome to ensure the proper application of these criteria.

3. I am familiar with the Framatome information contained in a PowerPoint

presentation entitled, Turkey Point Unit 3 and Unit 4 License Amendment Request: Revise Fire

Protection Program in Support of Reactor Coolant Pump Seal Replacement Project

June 22, 2022, and referred to herein as Document. Information contained in this

Document has been classified by Framatome as proprietary in accordance with the policies

established by Framatome 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 Framatome 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 Framatome to determine

whether information should be classified as proprietary:

(a) The information reveals details of Framatomes 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 Framatome.

(d) The information reveals certain distinguishing aspects of a process,

methodology, or component, the exclusive use of which provides a

competitive advantage for Framatome in product optimization or marketability.

(e) The information is vital to a competitive advantage held by Framatome, would

be helpful to competitors to Framatome, and would likely cause substantial

harm to the competitive position of Framatome.

The information in this Document is considered proprietary for the reasons set forth in

paragraphs 6(d) and 6(e) above.

7. In accordance with Framatomes 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 Framatome only as required and under suitable agreement

providing for nondisclosure and limited use of the information.

8. Framatome 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.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on: June 16, 2022.

Gayle Elliott