ULNRC-06716, Presentation Information for Third Pre-Application Meeting Regarding Use of Framatome Fuel - Affidavit
| ML22047A097 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 02/11/2022 |
| From: | Morris B Framatome |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML22047A092 | List: |
| References | |
| ULNRC-06716 | |
| Download: ML22047A097 (4) | |
Text
Enclosure 4 to ULNRC-06716
Affidavit A F F I D A V I T
- 1. My name is Morris Byram. I am Product Manager, Lice nsing & Regulatory
Affairs for Framatome Inc. (Framatome) and as such I a m authorized to execute this Affidavit.
- 2. I am familiar with the criteria applied by Frama tome to determine whether
certain Framatome information is proprietary. I am fa miliar with the policies established by
Framatome to ensure the proper application of these cri teria.
- 3. I am familiar with the Framatome information contai ned in the
slide presentation entitled Callaway VQP Pre-Submit tal Meeting dated February 28, 2022,
and referred to herein as Document. Information con tained in this Document has been
classified by Framatome as proprietary in accordance with th e policies established by
Framatome for the control and protection of propriet ary and confidential information.
- 4. This Document contains information of a proprieta ry and confidential nature
and is of the type customarily held in confidence by Frama tome and not made available to the
public. Based on my experience, I am aware that other co mpanies regard information of the
kind contained in this Document as proprietary and confid ential.
- 5. This Document has been made available to the U.S. Nuclear Regulatory
Commission in confidence with the request that the infor mation contained in this Document be
withheld from public disclosure. The request for withho lding of proprietary information is made in
accordance with 10 CFR 2.390. The information for wh ich 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 F ramatome to determine
whether information should be classified as proprietary:
(a) The information reveals details of Framatomes resea rch and development
plans and programs or their results.
(b) Use of the information by a competitor would permi t 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 techn iques concerning a
process, methodology, or component, the application of wh ich 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 provi des a
competitive advantage for Framatome in product optimizat ion or marketability.
(e) The information is vital to a competitive advantage held by Framatome, would
be helpful to competitors to Framatome, and would like ly cause substantial
harm to the competitive position of Framatome.
The information in this Document is considered propriet ary for the reasons set forth in
paragraph 6(d) above.
- 7. In accordance with Framatomes policies governing th e 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 req uired and under suitable agreement
providing for nondisclosure and limited use of the info rmation.
- 8. Framatome policy requires that proprietary informa tion 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 t he best of my knowledge,
information, and belief.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on: (2/11/2022)
Digitally signed by BYRAM Morris
____________________________________ BYRAM MorrisDate: 2022.02.11 08:21:55 -08'00' (NAME)
morris.byram@framatome.com