ML19291B714
| ML19291B714 | |
| Person / Time | |
|---|---|
| Site: | 07109382 |
| Issue date: | 10/15/2019 |
| From: | Narayanan P TN Americas LLC |
| To: | Office of Nuclear Material Safety and Safeguards |
| References | |
| E-55299 | |
| Download: ML19291B714 (1) | |
Text
TN Americas LLC
)
State of Maryland
)
SS.
County ofHowar6
)
"ft:> AJT~tJM e111i,1 AFFIDAVIT PURSUANT TO 10 CFR 2.390 to E-55299 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 Commission's regulations for withholding this information.
The infonnation for which proprietary treatment is sought is contained in Enclosure 3 including separate video files to be included with the presentation is listed below:
- , TN Eagle Pre-Application NRC Meeting, Proprietary Information.
The above document, including the video files, 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 infonnation.
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 descriptions of the design ofa 10 CFR Part 71 transportation packaging for radioactive material, related to the design of the TN Eagle, 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 a 10 CFR Part 71 transportation packaging for radioactive material, the application of which provide a competitive economic advantage. The availability of such infonnation 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.
Further the deponent sayeth not.
A -~~
Prakash Narayanan Chief Technical Officer, TN Americas LLC Subscribed and swor11 before me this 15tl' day of October, 2019.
L-e;:~~
Notary Public My Commission Expires t j /J. ~ / t,I) ~V Pagel of I LEWIS A. PICCOLINO NOTARY PUBLIC MONTGOMERY COUNTY MARYLAND 22 MY COMMISSION EXPIRES MARCH 26, 20