ML20190A137

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Enclosure 1: Tn Americas LLC - Affidavit
ML20190A137
Person / Time
Site: 07201042
Issue date: 06/26/2020
From: Narayanan P
TN Americas LLC
To:
Office of Nuclear Material Safety and Safeguards
Shared Package
ML20190A135 List:
References
E-56684
Download: ML20190A137 (2)


Text

Enclosure 1 to E-56684 Affidavit Pursuant to 10 CFR 2.390

Enclosure I to E-56684 AFFIDAVIT PURSUANT TO 10 CFR 2.390 TN Ameri~LC )

State of Maryland County of Howard )

I Prakash arayanan depose and say that I am Chief Technical Officer of TN Americas. L~C, ~uly authorized' to execute this affidavit, and have reviewed or caused to have reviewed th e *~onna

  • -~ ti 0 ~ that 1s identified as proprietary and referenced in the paragraph immediately below. I am ~ubmitt_ing ~1s. affidavt~ ID conformance with the provisions of 10 CFR 2.390 of the Commission's regulations for w1thholdmg this mformatJon.

The infonnation for which proprietary treatment is sought is contained in Enclosures 2, 7, and IO as listed below:

  • Enclosure 2 - Responses to Request for Additional Information .
  • Enclosure 10- Computer files associated with Proposed Certificate of Compliance 1042 Amendment 2, Revision S 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 infonnation.

Pursuant to the provisions of paragraph (b) (4) of Section 2.390 of the Commission's regulations, the following is furrtlshed for consideration by the Commission in determining whether the information sought t.o 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 portions ofth.e RAls and responses, portions of the UFSAR files and computer analysis files, all related to the design of the NU HOMs* EOS 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 cust0marily 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 and analysis of dry spent fuel storage systems, the application of which provide a competitive economic advantage. The availability of such (nformation to com~itors would e~ble th~m to modi!Y their product to better compete with TN Amencas _LLC, tak~ marketmg or oth~r actions t~ un~ro~e their product's position or impair the position of TN Amencas LLC s product, and av01d developing s1mtlar data and analyses in support of their processes, methods or apparatus.

Further the deponent sayeth not.

Prakash Narayanan Chief Technical Officer, TN Americas LLC ore me this 26th day of June, 2020.

RONDA JONES NOTARY PUBLIC MONTGOMERY COUNTY My Commission Expires ..lJlJJkJ~$ MARYLAND 1 MY COMMISSION EXPIRES OCT. 16, 2023 1 Page 1 of 1