ML20345A117

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Tn Americas, LLC - Affidavit
ML20345A117
Person / Time
Site: 07109358
Issue date: 12/08/2020
From: Narayanan P
TN Americas LLC
To:
Office of Nuclear Material Safety and Safeguards
Shared Package
ML20345A111 List:
References
E-57948
Download: ML20345A117 (1)


Text

Enclosure 3 to j7 AFFIDAVIT PURSUANT TO 10 CFR 2,390 TN Am ricas LLC )

State of Maryland )

County of H ard )

I, Prakash Nara~anan dep<> e and say th~t I am hiefTechnical Officer of TN Ameri LLC, duly n which

  • authorized to execut th, affidavit, and have reviewed or caused to have reviewed the infonnatio in the paragraph immediate ly below. I am submitting this affidavit in identified as proprietary and referenced ions of IO CFR 2.390 of the ommissio n's regulation s for withholdin g thi confonnance with the provi infonnation.

The infonnation for which proprietary treatment is ought is contained in Enclosure I and i listed below:

  • Portion of certain chapters and appendices of the Safety Analysis Report (SAR) for Certificate of Compliance o. 9358 TN-LC, Revision 9, Docket 71-9358 (Proprietary Version)

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 sought to following is furnished for consideration by the Commi ion in detennining whether the information be withheld from public disclosure, included in the above referenced document, should be withheld.

I) The information sought to be withheld from public disclosure involves certain d ign detai ls associated with the SAR analyses and SAR drawings for the TN-LC System, which are owned and have been held in confidence by TN Americas LLC.

2) The infonnation 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 determini ng the type:S of information customari ly held in confidenc e by it.
3) Public disclosure of the information is likely to cause substantial hann to the competitive position of TN Americas LLC because the informatio n consists of descriptio ns of the design and analysis of a radioactive material transportation system, the application of which provide a competiti ve 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 America LLC's product, and a oid de eloping similar data and analyses in support of their proces es methods or apparatus.

Further the deponent sayeth not.

Prakash arayanan Chief Technical Officer, TN Americas LLC th 8 day of December, 2020.

Notary Public/

My Commission Expires ..JQ_/ I IP I~

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