ML22006A366

From kanterella
Jump to navigation Jump to search

Enclosure 1: Affidavit Pursuant to 10 CFR 2.390
ML22006A366
Person / Time
Site: 07109393
Issue date: 12/22/2021
From: Faldowski J
Orano Federal Services
To:
Office of Nuclear Material Safety and Safeguards
Shared Package
ML22006A364 List:
References
EPID L-2021-NEW-0003, FS-21-0147
Download: ML22006A366 (1)


Text

Enclosure 1 to FS-21-0147 AFFIDAVIT PURSUANT TO 10 CFR 2.390 Orano Federal Services LLC

)

State of Maryland SS.

County of Montgomery

)

I, Joseph A Faldowski, 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

~eview~d the information th~t. is id_entifi~d ~s. proprietary and. referenced in the paragraph 1mmed1ately below. I am submitting this aff1dav1t m 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, "CR3MP Transport Package Safety Analysis Report (Revision 1), NRC Docket No. 71-9393" and Enclosure 3, "Orano Federal Services Response to Request For Supplemental Information for the Review of the Model No.

CR3MP Package". These documents have 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 LLq 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 ior determining the types ofinformation customarily held in confidence by it.

3) Information which would likely cause substantial harm to the competitive position ofour 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.

oseph A Faldowski Chief Operations Officer, Orano Federal Services LLC My Commission expires OS' / 2. 3 / '2.o1-'f'""

Page 1 of 1