ML19115A240

From kanterella
Jump to navigation Jump to search
Enclosure 6 - Statement of Proprietary Information
ML19115A240
Person / Time
Site: 07103052
Issue date: 12/05/2018
From: Oleyar P
TN Americas LLC, US Dept of Transportation, Pipeline & Hazardous Materials Safety Admin, US Dept of Transportation, Radioactive Materials Branch
To:
Office of Nuclear Material Safety and Safeguards
References
E-53126
Download: ML19115A240 (1)


Text

Enclosure 6 to E-53126 STATEMENT OF PROPRIETARY INFORMATION PURSUANT TO 49 CFR 7.14, 49 CFR 105.30, AND 10 CFR 2.390 TN Americas LLC State of Maryland County of Howard

)

)

SS.

)

I, Paul Oleyar, depose and say that I am a Vice President of TN Americas LLC, an Orano Group member, duly authorized to execute this statement of proprietary information on behalf of TN International, an Orano Group member, and have reviewed or caused to have reviewed the information which is identified as proprietary and referenced in the paragraph immediately below. TN Americas LLC on behalf of TN International, is submitting this statement of proprietary information in conformance with the provisions of 49 CFR 7.14 and 49 CFR 105.30 of the U.S. Department of Transportation's (DOT) regulations, and with the provisions of 10 CFR 2.390 of the U.S. Nuclear Regulatory Commission's (NRC) regulations. This information is exempt from public disclosure under the Freedom of Information Act, 5 U.S.C. 552, as amended, for withholding this information.

The information for which proprietary treatment is sought is contained in Enclosure 4, as listed below:

  • - NTC-07-00085519-000 Rev. 2, Test Report (English Translation)

This document has been appropriately designated as proprietary.

Pursuant to the provisions of paragraph 7.14 of Part 7 and paragraph (a) (3) of Part 105 of the U.S.DOT regulations, and the provisions of paragraph (b) (4) of Section 2.390 of the NRC regulations the following is furnished for consideration by the DOT and by the NRC 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 involves Test Report NTC-07-00085 519-000 Revision 2, related to the design and analysis of the TN-MTR Packaging. This Test report is owned and has been held in confidence by TN International.
2) The information is of a type customarily held in confidence by TN International and not customarily disclosed to the public. TN International has a rational basis for determining the types of information that is customarily held in confidence by it.
3) Public disclosure of the information is likely to cause substantial harm to the competitive position of TN International because the information consists of descriptions relating to analysis of the TN-MTR Packaging, as well as company business sensitive information, 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 International, take marketing or other actions to improve their product's position or impair the position of TN International's product, and avoid developing similar data and analyses in support of their processes, methods, or apparatus.

Further the deponent sayeth not. ~---

Paul Oleyar Vice President, TN Americas LLC efore me this 5th day of December, 2018.

My Commission Expires _jJ__; _lk} _Jj_

RONDA JONES NOTARY PUBLIC STATE OF MARYLAND My CcmRssion Expires Oclober 16, 2019 Page 1 of 1