ML19024A173

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Enclosure 3 - Affidavit
ML19024A173
Person / Time
Site: 07109233
Issue date: 01/23/2019
From: Oleyar P
Orano USA, TN Americas LLC
To:
Office of Nuclear Material Safety and Safeguards
Shared Package
ML19024A167 List:
References
E-53386
Download: ML19024A173 (1)


Text

TN Americas LLC State of Maryland County of Howard

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AFFIDAVIT PURSUANT TO 10 CFR 2.390 to E-53386 I, Paul Oleyar, depose and say that I am a Vice President 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 CPR 2.390 of the Commission's regulations for withholding this information.

The information for which proprietary treatment is sought meets the provisions of paragraph (a) (4) of Section 2.390 of the Commission's regulations. The information is contained in Enclosures 2 as listed below:

  • - TN-RAM SAR Revision 18 Changed Pages This documents has 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 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 portions of the TN-RAM transportation packaging SAR-related to the design of the Model TN-RAM transportation packaging, which are owned and have 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 is related to the design of the Model TN-RAM transportation packaging, the application of which provides 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 the development of similar data and analyses in support of their processes, methods, or apparatus.

Further the deponent sayeth not.

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Vice President, TN Americas LLC efore me this 23rd day of January 2019.

My Commission Expires / D I JkJ _Jj___

RONDA JONES NOTARY PUBLIC STATE OF MARYLAND MyCtvMlission Expires October 16, 2019 Page 1of1