ML20315A419

Enclosure 1 - Affidavit Pursuant to 10 CFR 2.390

ML20315A419
Person / Time
Site:	07201042
Issue date:	10/29/2020
From:	Narayanan P Orano TN Americas, TN Americas LLC
To:	Office of Nuclear Material Safety and Safeguards
Shared Package
ML20315A417	List: ML20315A418 ML20315A419 ML20315A420 ML20315A421 ML20315A422 ML20315A424 ML20315A425 ML20315A426 ML20315A427 ML20315A428
References
E-57418, EPID L-2019-LLA-0078
Download: ML20315A419 (1)

Text

TN Ameri~a~LC- __.,----

State of Maryland County of Howard

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AFFIDAVIT PURSUANT TO 10 CFR 2.390 to E-57418 I, Prakash Narayanan, depose and say _that l 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 is contained in Enclosures 2, 6, and 9 as listed below:

• - Responses to Request for Additional lnfo1mation Enclosw-e 6 - Portions of certain updated final safety analysis report (UFSAR) chapters and drawings

• - Computer files associated with Proposed Certificate of Compliance 1042 Amendment 2, Revision 6 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 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 portions of the RAis and responses, portions of the UFSAR files and computer analysis files, all related to the design of the NUHOMS EOS System, which are owned and have been held in confidence by TN Americas LLC.

2) The infom1ation 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 and analysis 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.

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Further the deponent sayeth not.

Prakash Narayanan Chief Technical Officer, TN Americas LLC RONDA JONES Notary Public My Commission Expires /0; /& ;;)o/13

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NOTARY PUBLIC MONTGOMERY COUNTY MARYLAND MY COMMISSION EXPIRES OCT. 16, 2023 Page 1 of 1