ML19255E945
| ML19255E945 | |
| Person / Time | |
|---|---|
| Site: | 07201004 |
| Issue date: | 09/03/2019 |
| From: | Narayanan P Orano USA, TN Americas LLC |
| To: | Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML19255E934 | List: |
| References | |
| E-54825 | |
| Download: ML19255E945 (1) | |
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 Enclosure I to E-54825 1, Prakash Narayanan, depose and say that I am the 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 meets the provisions of paragraph (a) (4) of Section 2.390 of the Commission's regulations. The information is contained in Enclosure I 6, as listed below:
- 6 - Portions of ce1iain updated final safety analysis repo1i (UFSAR) chapters and appendices This document 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 po1iions of the UFSAR related to the design of the Standardized NUHOMS dry spent fuel storage system, 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 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 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.
Fu1iher the deponent sayeth not.
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Prakash Narayanan 0
Chief Technical Officer, TN Americas LLC Subscribed and sworn before me this 3rd day of September, 2019.
IA,z>hi le !iJ r _5 Notary Public My Commission Expires t7°/;.)..9;~
LESLIE LEFORS*
Notary PubHc,M:aryland M
Frederick County Y Commission Expires September 29, 2021 Page I of l