ML19204A242

Enclosure 1 to Dpg 19-087 - Tn Americas, LLC Affidavit

ML19204A242
Person / Time
Site:	07200011
Issue date:	07/10/2019
From:	Narayanan P Sacramento Municipal Utility District (SMUD), TN Americas LLC
To:	Office of Nuclear Material Safety and Safeguards
Shared Package
ML19204A239	List: ML19204A241 ML19204A242 ML19204A244 ML19204A248 ML19204A251
References
CAC 000993, CAC 001028, DPG 19-087, EPID: L-2018-LNE-0004, EPID: L-2018-RNW-0005
Download: ML19204A242 (2)

Text

Enclosure 1 to DPG 19-087 Page 1 of 2 AFFIDAVIT PURSUANT TO 10 CFR 2.390 TN Americas LLC

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State of Maryland

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SS.

County of Howard

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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, 4, 6 and 7 and are listed below:

• - Portions of the RAI clarifications and responses

• - Portions of various chapters and appendices of the Rancho Seco ISFSI License Renewal Application

• - Design drawings and Quality Category Assessment supporting the Rancho Seco ISFSI License Renewal Application

• - Calculation supporting the Rancho Seco ISFSI License Renewal Application 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 operating experience with spent fuel storage system aging and details of 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 operating experience with the aging degradation of systems using the NUHOMS technology and details of spent fuel storage system aging management studies and planned aging management strategies to DPG 19-087 associated with the renewal of systems using the NUHOMS technology, 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 America LLC's product, and avoid developing similar data and analyses in support of their processes, methods or apparatus.

Further the deponent sayeth not.

Prakash Narayanan Chief Technical Officer, TN Americas LLC Subscribed and sworn before me this 10th day of July, 2019.

Notary Public My Commission Expires _!!____/ __Jfj_l +/-)_

LESLIE LEFORS Notary Pubtic*Maryland

• Frederick County My Commission Expires September 29, 2021 Page2of2