ML21244A487

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Orano Federal Services, LLC, Affidavit
ML21244A487
Person / Time
Site: 07109393
Issue date: 09/01/2021
From: Rousseau G
Orano Federal Services
To:
Office of Nuclear Material Safety and Safeguards
Shared Package
ML21244A485 List:
References
EPID L-2021-NEW-0003, FS-21-0108
Download: ML21244A487 (2)


Text

Orano Federal Services LLC

)

State of Maryland

)

SS.

County of Montgomery

)

AFFIDAVIT PURSUANT TO 10 CFR 2.390 to FS-21-0108 I, Gilles Rousseau, depose and say that I am Chief Operations Officer of Orano Federal Services 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 Enclosure 2, Safety Analysis Report for the CR3 Middle Package (CR3MP), NRC Docket No. 71-9393. This document has been appropriately designated as proprietary.

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)

Proprietary information that was received by our client (Orano Decommissioning Services LLC) and/or shared with Orano Federal Services LLC under a Non-Disclosure Agreement and cannot legally be shared (e.g. Reactor Vessel and/or Reactor Vessel Internals dimensions, Neutron Activation Analysis information and results).

2)

Information customarily held in confidence by our client and not customarily disclosed to the public. Our client has a rational basis for determining the types of information customarily held in confidence by it.

3)

Information which would likely cause substantial harm to the competitive position of our client because the information consists of their proprietary information such as trade secrets, ideas, techniques, know-how, inventions or any information which has commercial value in their business. The availability of such information to competitors would enable them to improve their products and services and/or take actions to adversely impact the position of our client and avoid research and development costs associated with improving their offering.

Further the deponent sayeth not.

Gilles ROUSSEAU Chief Operations Officer, Orano Federal Services LLC

,.,uH Se tember, 2021.

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