ML22094A208
| ML22094A208 | |
| Person / Time | |
|---|---|
| Site: | 07201004 |
| Issue date: | 03/16/2022 |
| From: | Narayanan P TN Americas LLC |
| To: | Office of Nuclear Material Safety and Safeguards |
| W ALLEN NRC/NMSS/DFM/STLB 3014156877 | |
| Shared Package | |
| ML22094A199 | List: |
| References | |
| E-60640 | |
| Download: ML22094A208 (1) | |
Text
TN Americas LLC State of Maryland County of Baltimore
)
)
SS.
)
AFFIDAVIT PURSUANT TO 10 CFR 2.390 E-60640 I, Prakiish Narayanan, depose and say that I am the Chief Technical Officer of TN Americas LLC, duly authorized to execute this affidavit, and have reviewed or caused to have reviewed the information which 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 certain presentation slides to be used in an upcoming meeting, as listed below:
Certain marked slides contained in the "TN Americas slides for CoC 1004 Amendment 18 Pre-Application Meeting, April 2022."
Portions of this slide presentation 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 2.3 90 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.
I) The information sought to be withheld from public disclosure involves presentation slides for a public meeting, related to the licensing, design and analysis of dry spent fuel storage systems, which are owned and have been held in confidence by TN Americas LLC.
- 2) The information 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 is related to design details, methodology and licensing approach of the CoC 1004 Standardized NUHOMS Amendment 18 application and provides 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.
Further the deponent sayeth not.
Prakash Narayanan Chief Technical Officer, TN Americas LLC
~
Subscribed and sworn before me this,, day of March, 2022.
'D,~g0 W \\\\\\ NtS Notary Public My Commission Expires 1i}_; 30 I.2SfJ 3 Page I of I