ML22118A342
| ML22118A342 | |
| Person / Time | |
|---|---|
| Site: | 07103092, 07100653 |
| Issue date: | 03/21/2022 |
| From: | Shaw D TN Americas LLC |
| To: | Boyle R US Dept of Transportation (DOT) |
| N DEVASER NRC/NMSS/DFM/STLB | |
| Shared Package | |
| ML22118A340 | List: |
| References | |
| E-60638, EPID L-2021-DOT-0005 | |
| Download: ML22118A342 (4) | |
Text
March 21, 2022 E-60638 Orano TN 7160 Riverwood Drive U.S. Department of Transportation Suite 200 Attn: Mr. Richard W. Boyle, Chief Columbia, MD 21046 USA Pipeline & Hazardous Materials Safety Administration Tel: 410-910-6900 Radioactive Materials Branch Fax: 434-260-8480 1200 New Jersey Avenue, S.E.
East Building, PHH-20 Washington, DC 20590
Subject:
Application for Revision to Competent Authority Certification, USA/0653/AF-96 for the Model No. TNF-XI, RAI Response Revision, Docket no. 71-3092 (EPID L-2021-DOT-0005)
Reference:
[1] TN Americas LLC Letter E-58966, dated July 12, 2021, Application for Revision to Competent Authority Certification, USA/0653/AF-96 for Validation of French Competent Authority Certificate F/381/AF-96 for the Model No. TNF-XI
[2] Letter dated March 14, 2022, from Nishka Devaser (U.S. Nuclear Regulatory Commission) to Richard W. Boyle (U.S. Department of Transportation), Request for Revalidation of French Certificate of Approval No. F/381/AF-96, Revision El for the Model No. TNF-XI Package - Request for Additional Information, Docket No. 71-3092
[3] Competent Authority Certification for a Type AF Fissile Radioactive Materials Package Design Certificate USA/0653/AF-96, Revision 12, Revalidation of French Competent Authority Certificate F/381/AF-96, dated August 20, 2019
Dear Mr. Boyle:
Based on TN Americas LLC (TN) letter dated July 12, 2021 [1], the NRC accepted the request to perform a review of French Approval Certificate Number F/381/AF-96, Revision El, for revision to Competent Authority Certification (CAC)
USA/0653/AF-96, Model No. TNF-XI transport package. The renewal and extension of French Certificate of Approval F/381/AF-96 (El) now includes Contents Nos. 2, 7, 8, and 9. The NRC requested additional information to perform the review [2]. Responses to the NRC Request for Additional Information are provided as Enclosure 3.
Enclosures transmitted herein contain SUNSI. When separated from enclosures, this transmittal document is decontrolled.
E-60638 Document Control Desk Page 2 of 2 Certain portions of this submittal include proprietary information, which may not be used for any purpose other than to support the NRC staff's review of the application. Accordingly, an affidavit (Enclosure 2) is provided requesting that this proprietary information be withheld from public disclosure.
TN requests to continue the review of the application for issuing a revision of the TNF-XI CAC
[3]. This request is to revise the CAC USA/0653/AF-96 to allow Content No. 9, non-irradiated uranium oxides, as described in Appendix 9, in the renewal and extension of French Certificate of Approval Certificate F/381/AF-96 as Revision El on or before May 20, 2022 in order to support shipments in June 2022.
Should you or your staff have any questions or require additional information to support review of this application, please contact Mr. Peter Vescovi by telephone at 336-420-8325, or by e-mail at Peter.Vescovi@Orano.group.
Sincerely, Don Shaw Licensing Manager TN Americas LLC cc: Michael Conroy, U.S. Department of Transportation
Enclosures:
- 1. Not used.
- 2. Orano NPS Statement of Proprietary Information Pursuant to 49 CFR 7.14, 49 CFR 105.30, and 10 CFR 2.390
- 3. Fax COR-22-001323-000, Request for Additional Information French Approval Certificate Number F/381/AF-96, Revision El, Docket No. 71-3092, Model No. TNF-XI Package
Enclosure 2 to E-60638 Orano NPS Statement of Proprietary Information Pursuant to 49 CFR 7.14, 49 CFR 105.30, and 10 CFR 2.390
Enclosure 2 to E-60638 ORANO NPS STATEMENT OF PROPRIETARY INFORMATION PURSUANT TO 49 CFR 7.14, 49 CFR 105.30, AND 10 CFR 2.390 I, Frederic De Agostini depose and say that I am the President of Orano NPS, duly authorized to execute this statement of proprietary information and have reviewed or caused to have reviewed the information which is identified as proprietary and referenced in the paragraph immediately below. TN Americas LLC on behalf of Orano NPS, is submitting this statement of proprietary information in conformance with the provisions of 49 CFR 7.14 and 49 CFR 105.30 of the U. S. Department of Transportations (U.S. DOT) regulations, and with the provisions of 10 CFR 2.390 of the Nuclear Regulatory Commissions (NRC) regulations. This information is exempt from public disclosure under the Freedom of Information Act, 5 U.S.C. 552, as amended, for withholding this information.
The information for which proprietary treatment is sought is listed below:
l Enclosure 3 COR-22-001323-000,
Subject:
Request for Additional Information, French Approval Certificate Number F/381/AF-96, Revision El, Docket No. 71-3092, Model No. TNF-XI Package Pursuant to the provisions of paragraph 7.14 of Part 7 and paragraph (a) (3) of Part 105 of the U.S.DOT regulations, and the provisions of paragraph (b) (4) of Section 2.390 of the NRC regulations the following is furnished for consideration by the U.S.DOT and by the NRC in determining whether the information sought to be withheld from public disclosure, included in the above referenced document, should be withheld.
- 1) The information sought to be withheld involves the Safety Analysis Report for Model TNF-XI Packaging related to the design and analysis of the TNF-XI Packaging, which is owned and has been held in confidence by Orano NPS.
- 2) The information is of a type customarily held in confidence by Orano NPS and not customarily disclosed to the public. Orano NPS has a rational basis for determining the types of information that is customarily held in confidence by it.
- 3) Public disclosure of the information is likely to cause substantial harm to the competitive position of Orano NPS because the information consists of material specification standards fo the TNF-XI Packaging, as well as company business sensitive information, the application of which provides a competitive economic advantage. The availability of such information to competitors would enable them to modify their product to better compete with Orano NPS, take marketing or other actions to improve their products position or impair the position of Orano NPSs product, and avoid developing similar data and analyses in support of their processes, methods, or apparatus.
Further the deponent sayeth not.
(Signature and date)
Name Frederic De Agostini President of Orano NPS Orano NPS Witnessed by Signé numériquement par : KLEIN Laurent KLEIN Laurent Nom DN : CN = KLEIN Laurent O =
ORANO OU = 0002 330956871 Date : 2022.03.11 08:10:37 +01'00' Name: (Signature and date)
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