ML18303A115
| ML18303A115 | |
| Person / Time | |
|---|---|
| Site: | 07200020 |
| Issue date: | 09/25/2018 |
| From: | Narayanan P TN Americas LLC, US Dept of Energy, Idaho Operations Office |
| To: | NRC/NMSS/SFST |
| Shared Package | |
| ML18303A125 | List: |
| References | |
| EM-NRC-18-024 | |
| Download: ML18303A115 (2) | |
Text
TN Americas LLC State of Maryland County of Howard
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SS.
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AFFIDAVIT PURSUANT TO 10 CFR 2.390 TN Americas LLC, E-52710 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 that 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 Commission's regulations for withholding this information.
The information for which proprietary treatment is sought is contained in drawings planned to be submitted to the U.S. NRC in a submittal related to the Three Mile Island Unit 2 Independent Spent Fuel Storage Installation License Renewal Application, Docket 72-0020, as listed below:
Drawing 219-02-1000, Revision 1, Dry Shielded Canister Basket Assembly Drawing 219-02-100 I, Revision 1, Dry Shielded Canister Shell Assembly Drawing 219-02-1002, Revision I, Dry Shielded Canister Basket-Shell Assembly Drawing 219-02-1003, Revision I, Dry Shielded Canister Main Assembly Drawing 219-02-10 I 0, Revision 2, Dry Shielded Canister Purge Port Filter Assembly Drawing 219-02-1011, Revision 2, Dry Shielded Canister Vent Port Filter Assembly Drawing 219-02-2000, Revision 2, Dry Shielded Canister Basket Assembly Safety Analysis Report Drawing 219-02-2001, Revision 2, Dry Shielded Canister Shell Assembly Safety Analysis Report Drawing 219-02-2002, Revision 2, Dry Shielded Canister Basket-Shell Assembly Safety Analysis Report Drawing 219-02-2003, Revision 2, Dry Shielded Canister Main Assembly Safety Analysis Report Drawing 219-02-2010, Revision 2, Purge/Pmt Filter Assembly Safety Analysis Report Drawing 219-02-2011, Revision 3, Vent Assembly Safety Analysis Report Drawing 219-02-5100, Revision I, Horizontal Storage Module ISFSI General Atnngement Drawing 219-02-5101, Revision 1, Standard Module Main Assembly Drawing 219-02-5103, Revision I, Horizontal Storage Module Standard Module Base Unit Drawing 219-02-5104, Revision 2, Horizontal Storage Module Roof Slab Drawing 219-02-5105, Revision 1, Horizontal Storage Module DSC Support Structure Drawing 219-02-5107, Revision 1, Horizontal Storage Module Erection Hardware and Misc Steel Doors & Fabricated Fasteners Drawing 219-02-5108, Revision 0, Horizontal Storage Module End Module Shield Wall Drawing 219-02-5200, Revision 3, Sheet I, Horizontal Storage Module Basemat Drawing 219-02-5200, Revision 2, Sheet 2, Horizontal Storage Module Basemat 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 Commission's regulations, the following is furnished for consideration by the Commission in determining whether the info1mation 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 on schematic drawing files related to the design of the NUHOMS technology for storage of dry spent nuclear fuel, which are owned and have been held in confidence by TN Americas LLC.
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TN Americas LLC, E-52710
- 2) The information is of a type customarily held in confidence by TN Americas LLC, and not customarily di~closed to the public. TN Americas LLC has a rational basis for determining the types of inf01mation customarily held in confidence by it.
- 3) Public disclosure of the information is likely to cause substantial hmm to the competitive position of TN Americas LLC, because the information consists of details and depictions of the design of a d1y spent fuel storage system, the application of which provide a competitive economic advantage. The availability of such information 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 Americas LLC's product, and avoid developing similar data and analyses in support of their processes, methods or apparatus.
Further the deponent sayeth not.
.A-P~~
Prakash Narayanan Chief Technical Officer, TN Americas LLC s-z~:*
thfa 25"' day of Septembe<, 2018.
Notary Public My Commission Expires Jb_! M _Jj_
RONDA JONl:S NOTARY PUBLIC STATE OF MARVLANC:
UyCarmllloA Expkll Oclober 16, 2019 Page 2 of2