ML18285A383
| ML18285A383 | |
| Person / Time | |
|---|---|
| Site: | 07200011 |
| Issue date: | 09/25/2018 |
| From: | Narayanan P TN Americas LLC |
| To: | Division of Spent Fuel Management |
| Shared Package | |
| ML18285A414 | List: |
| References | |
| DPG 18-166 | |
| Download: ML18285A383 (2) | |
Text
Enclosure 1 to DPG-18-166 Page 1 of 2 AFFIDAVIT PURSUANT TO 10 CFR 2.390 TN Americas LLC
)
State of Maryland
)
SS.
County of Howard
)
I, Prakash Narayanan, depose and say that I am Chief Technical Officer of TN Americas LLC, duly authorized to execute this affidavit, and have reviewed or caused to have reviewed the information which is identified as proprietary and referenced in the paragraph immediately below. I am submitting this affidavit in conformance with the provisions of 10 CFR 2.390 of the Commissions regulations for withholding this information.
The information for which proprietary treatment is sought is contained in Enclosures 2 through 8 and is listed below:
- - Input Supporting TN Calculation 502917-0501, Revision 0
- - Computer Input Files Supporting TN Calculation 502917-0500, Revision 0
- - Justification for Input Parameters
- - TN Calculation 60979-033, Revision 0
- - Drawings Cited in LRA Table 2-6
- - Drawings Cited in LRA Table 2-8
- - Scoping and AMR Results Tables in EXCEL Format These documents have been appropriately designated as proprietary.
I have personal knowledge of the criteria and procedures utilized by TN Americas LLC in designating information as a trade secret, privileged, or as confidential commercial or financial information.
Pursuant to the provisions of paragraph (b) (4) of Section 2.390 of the Commissions regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure, included in the above referenced document, should be withheld.
- 1) The information sought to be withheld from public disclosure involves details (including drawings) of the design of spent fuel storage systems and supporting analytical modeling input, calculations, and spent fuel storage system aging management studies associated with the renewal of systems using the NUHOMS technology. The NUHOMS technology is owned and has been held in confidence by TN Americas LLC.
- 2) The information is of a type customarily held in confidence by TN Americas LLC and not customarily disclosed to the public. TN Americas LLC has a rational basis for determining the types of information customarily held in confidence by it.
- 3) Public disclosure of the information is likely to cause substantial harm to the competitive position of TN Americas LLC because the information consists of details of the design of to DPG-18-166 spent fuel storage systems using the NUHOMS technology and details of spent fuel storage system aging management studies associated with the renewal of systems using the NUHOMS technology, the application of which provide a competitive economic advantage. The availability of such info1mation to competitors would enable them to modify their product to better compete with TN Americas LLC, take marketing or other actions to improve their product's position or impair the position of TN America LLC's product, and avoid developing similar data and analyses in suppmi of their processes, methods or apparatus.
Fmiher the deponent sayeth not.
RONDA JONES NOTARY PUBLIC STATE OF MARYLAND My Conm8ion Expil8e Oclobel' 16, 2019 vA -~--0-:
Prakash Narayanan Chief Technical Officer, TN Americas LLC Page 2 of2