ML19028A061
| ML19028A061 | |
| Person / Time | |
|---|---|
| Site: | 07201004 |
| Issue date: | 01/22/2019 |
| From: | Narayanan P Orano USA, TN Americas LLC |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML19028A070 | List: |
| References | |
| E-53140 | |
| Download: ML19028A061 (3) | |
Text
Columbia Office 7135 Minstrel Way Columbia, MD 21045 Tel: (410) 910-6900
@Orano_USA U. S. Nuclear Regulatory Commission Attn: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 January 22, 2019 E-53140
Subject:
NUH-003, Updated Final Safety Analysis Report (UFSAR) for the Standardized NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel, Revision 18
Reference:
NUH-003, Updated Final Safety Analysis Report (UFSAR) for the Standardized NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel, Revision 17, March 12, 2018 (E-50936)
In order to formally incorporate Certificate of Compliance (CoC) No. 1004 Amendment 15 (which was approved by the NRC and became effective on January 22, 2019), TN Americas LLC has updated the referenced UFSAR and herewith submits the subject UFSAR Revision 18. In addition, pursuant to 10 CFR 72.248(c)(5), this update to the UFSAR incorporates changes to the Standardized NU HOMS System implemented by TN Americas LLC under 10 CFR 72.48 from March 13, 2018 up to and including January 22, 2019.
I certify that this submittal accurately presents changes made from March 13, 2018 up to and including January 22, 2019.
The changed areas are marked as follows.
- New or changed pages show "Revision 18" and "January 2019" in their footer area.
Changed areas are generally indicated using single revision bars in the right-hand margin. Newly inserted text is generally shown by italics.
Pages that are only changed by Amendment 15 include a text box with bold text in the footer, which states "All changes on this page are Amd 15."
Revision bars on Revision 18 pages with no annotation represent 1 O CFR 72.48 changes.
Pages changed by both Amendment 15 and 10 CFR 72.48 are annotated with "Amd 15" adjacent to the applicable revision bars in the right-hand margin for the Amendment 15 changes, and "72.48" adjacent to the applicable revision bar for 72.48. This is to distinguish Amendment 15 changes from 10 CFR 72.48 changes.
UFSAR drawings have indicators to distinguish 1 O CFR 72.48 changes from Amendment 15 changes.
Document Control Desk January 22, 2019 E-53140 Page 2 of 2 This submittal includes proprietary information which may not be used for any purpose other than NRC staff use of the UFSAR. In accordance with 10 CFR 2.390, I am providing an affidavit (Enclosure 1) specifically requesting that you withhold this proprietary information from public disclosure.
This submittal also includes security-related information.
Accordingly, public versions of all replacement UFSAR pages and drawings are provided as Enclosure 3.
Should you have any questions regarding this submittal, please do not hesitate to contact Mr. Don Shaw at 410-910-6878 or me at 410-910-6859.
Sincerely,
~;f~
Prakash Narayanan Chief Technical Officer cc:
Christian Jacobs (NRC SFM) as follows, in a separate_ mailing:
One paper copy of Enclosure 1 and this transmittal letter Two electronic copies (computer disk) of the Standardized NUHOMS UFSAR, Revision 18 (Proprietary Version)
Enclosures:
- 1. Affidavit Pursuant to 10 CFR 2.390
- 2. Replacement Pages and Drawings for the Standardized NUHOMS System UFSAR, Revision 18 (Proprietary Version)
- 3. Replacement Pages and Drawings for the Standardized NUHOMS System UFSAR, Revision 18 (Public Version)
1N Americas LLC State of Maryland County of Howard
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AFFIDAVIT PURSUANT TO 10 CFR 2.390 Enclosure I to E-53140 I, Prakash Narayanan, depose and say that I am Chief Technical Officer of 1N 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 meets the provisions of paragraph (a) (4) of Section 2.390 of the Commission's regulations. The information is contained in Enclosure 2, as listed below:
- - Portions of Replacement Pages and Drawings for the Standardized NUHOMS System UFSAR, Revision 18 (Proprietary Version)
I have personal knowledge of the criteria and procedures utilized by 1N Americas LLC in designating information as a trade secret, privileged or as confidential commercial or financial information. This document has been appropriately designated a~ proprietary.
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 updated final safety analysis report related to the design of the Standardized NUHOMS dry spent fuel storage system, which is owned by and has been held in confidence by 1N Americas LLC.
- 2) The information is of a type customarily held in confidence by 1N Americas LLC, and not customarily disclosed to the public. 1N Americas LLC has a rational basis for determining the types of information customarily held in confidence by it.
- 3) Publid disclosure of the information is likely to cause substantial harm to the competitive position of 1N Americas LLC, because the information consists of descriptions of the design of dry spent fuel storage systems, 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 1N Americas LLC, take marketing or other actions to improve their product's position or impair the position of 1N Americas LLC's product, and avoid developing similar data and analyses in support of their processes, methods or apparatus.
Further the deponent sayeth not.
v4-P.~l Prakash Narayanan
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Chief Technical Officer, 1N Americas LLS~rl 1rJ Subscribed and sworn before me this 22nd day of January 2019.
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Notary Public 7
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