ML22119A106
| ML22119A106 | |
| Person / Time | |
|---|---|
| Site: | 07109358 |
| Issue date: | 04/29/2022 |
| From: | Narayanan P Orano TN Americas |
| To: | Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML22119A102 | List: |
| References | |
| E-60900, EPID L-2020-LLA-0086 | |
| Download: ML22119A106 (1) | |
Text
Enclosure 3 to E-60900 AFFIDAVIT PURSUANT TO 10 CFR 2.390 TN Americas LLC )
State of North Carolina ) ss.
County of Guilford )
I, Prakash Narayanan, depose and say that I am 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 Enclosure 1 and is listed below:
- Portions of certain chapters and appendices of the Safety Analysis Report (SAR) for Certificate of Compliance No. 9358 TN-LC, Revision 10, Docket 71-9358 (Proprietary Version)
This document has 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 2.390 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) The information sought to be withheld from public disclosure involves certain design details associated with the SAR analyses and SAR drawings for the TN-LC System, 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 consists of descriptions of the design and analysis of a radioactive material transportation system, the application of which provide 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 America LLC's product, and avoid developing similar data and analyses in support of their processes, methods or apparatus.
~ -?Ao, Further the deponent sayeth not.
~ /41, Prakash Narayanan Chief Technical Officer, TN Americas LLC North Carolina
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