ML21272A345

Shine Medical Technologies, LLC - Affidavit of James Costedio

ML21272A345
Person / Time
Site:	SHINE Medical Technologies
Issue date:	09/29/2021
From:	Jim Costedio SHINE Medical Technologies
To:	Office of Nuclear Reactor Regulation
Shared Package
ML21272A340	List: ML21272A341 ML21272A342 ML21272A344 ML21272A345
References
2021-SMT-0125
Download: ML21272A345 (3)

Text

SHINE MEDICAL TECHNOLOGIES, LLC

ENCLOSURE 4

SHINE MEDICAL TECHNOLOGIES, LLC APPLICATION FOR AN OPERATING LICENSE SUPPLEMENT NO. 8 AND RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION

AFFIDAVIT OF JAMES COSTEDIO

AFFIDAVIT OF JAMES COSTEDIO

STATE OF WISCONSIN COUNTY OF ROCK I, James Costedio, Vice President of Regulatory Affairs and Quality of SHINE Medical Technologies, LLC (SHINE), do hereby affirm and state:

)

) ss.

)

1.

I am authorized to execute this affidavit on behalf of SHINE. I am authorized to review information submitted to or discussed with the Nuclear Regulatory Commission (NRC) and apply for the withholding of information from public disclosure. The purpose of this affidavit is to provide the information required by 10 CFR 2.390(b) in support of SHINEâs request for proprietary treatment of certain confidential commercial and financial information submitted in the response to request for additional information by letter 2021-SMT-0125 with enclosures. SHINE requests that the confidential information contained in be withheld from public disclosure in their entirety.

2.

3.

I have knowledge of the criteria used by SHINE in designating information as sensitive, proprietary, or confidential.

Pursuant to the provisions of paragraph (a)(4) of 10 CFR 2.390, the following is furnished for consideration by the NRC in determining whether the information sought to be withheld from public disclosure should be withheld.

a. The information sought to be withheld from public disclosure contained in of 2021-SMT-0125 is owned by SHINE, its affiliates, or third parties to whom SHINE has an obligation to maintain its confidentiality. This information is and has been held in confidence by SHINE.

b. The information sought to be protected in Enclosure 2 is not available to the

public to the best of my knowledge and belief.

Page 1 of 2

c. The information contained in Enclosure 2 is of the type that is customarily

held in confidence by SHINE, and there is a rational basis for doing so. The information that SHINE is requesting to be withheld from public disclosure includes trade secret, commercial financial information, commercial information, or information that is subject to export controls. SHINE limits access to these elements to those with a âneed to know,â and subject to maintaining confidentiality.

d. The proprietary information sought to be withheld from public disclosure in includes, but is not limited to: structural configuration, primary and supporting systems of the medical isotope production facility, process and system locations, and process details. This would include information regarding the types, quantities, and locations of materials stored on site as would be referenced in facility configuration drawings. Public disclosure of the information in Enclosure 2 would create substantial harm to SHINE because it would reveal trade secrets owned by SHINE, its affiliates, or third parties to whom SHINE has an obligation to maintain its confidentiality.

e. Public disclosure of the information in Enclosure 2 would create substantial

harm to SHINE because it would reveal valuable business information regarding SHINE's competitive expectations, assumptions, processes, and current position. Its use by a competitor could substantially improve their competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product.

f. The information contained in Enclosure 2 of 2021-SMT-0125 is transmitted to

the NRC in confidence and under the provisions of 10 CFR 2.390; it is to be received in confidence by the NRC. The information is properly marked.

I declare under the penalty of perjury that the foregoing is true and correct.

Executed on September 29, 2021.

James Costedio Vice President of Regulatory Affairs and Quality SHINE Medical Technologies, LLC

Page 2 of 2