ML19319B046
| ML19319B046 | |
| Person / Time | |
|---|---|
| Site: | 07109302 |
| Issue date: | 11/07/2019 |
| From: | Prakash P Orano USA, TN Americas LLC |
| To: | Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML19319B037 | List: |
| References | |
| E-55464 | |
| Download: ML19319B046 (1) | |
Text
TN Americas LLC State of Maryland County of Howard
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AFFIDAVIT PURSUANT TO 10 CFR 2.390 to E-55464 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 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(s) 2 and 5, as listed below:
- - Portions of Replacement Pages and Drawings for the NUHOMS-MP 197HB UFSAR, Revision 20 (Proprietary Version).
- - Calculation Computer Files for NUHOMS-MP 197HB, Revision 20.
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 specifications of the Model NUHOMS-MPl97 transportation packaging, related to the design of the Model NUHOMS-MP197 transportation packaging and commercially sensitive schedules, 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 is related to the design and analysis of the Model NUHOMS-MP197 transportation packaging, 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 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 the development of similar data and analyses in suppo1t 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 ?11, day ofNovember 2019.
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