ML22271A184

E-61283 Enclosure 5, Orano NPS Statement of Proprietary Information for the Application for the Validation Request for the FCC-3 Package

ML22271A184
Person / Time
Site:	Orano USA
Issue date:	08/02/2022
From:	Boutteau J ORANO Nuclear Packages and Services (NPS)
To:	Division of Fuel Management
Garcia-Santos N
Shared Package
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References
A33010, E-61283, EPID L-2022-DOT-0007
Download: ML22271A184 (1)

Text

Enclosure 5 to E-61283 ORNO XPS STATEMENT 0F PROPRIETARY INFORMATION PURSUANT TO 49 CFR 7.14,49 CFR 105.30, AND 10 CFR 2.390 T, Jessica Boutteau, depose and say that I am the Director of Transport Operations and Business for ORANO Nuclear Packages and Services (NPS), duly authorized to execute this statement ofproprietary 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 behalfofORANO NPS, is submitting this statement of proprietary information in conformance with the provisions of 49 CFR 7.14 and 49 CFR 105.30 ofthe U. S.

Department ofTransportations (US. DOT) regulations, and with the provisions of 10 CFR 2.390 ofthe US.

Nuclear Rcgulatory Conimissions (NRC) regulations. This information is exempt from public disclosure under the Freedorn of Information Act, 5 U.S.C. 552. as amended. for withholding this information.

The information for which proprietary treatment is sought is contained in Enclosures 3, as listed below:

ORANO NPS Safety Analysis Report for FCC-3 These documents have been appropriately designated as proprietary.

Pursuant to the provisions ofparagraph 7.14 of Part 7 and paragraph (a) (3) ofPart 105 ofthe US. 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 US. 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 (SAR) for Model FCC-3 Packaging. This SAR is owned and has been held in confidence by ORANO NPS.

2)

The information is ofa type customarily held in confidence by ORANO NPS and not customarily disclosed to the public. ORANO NPS bas 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 ORNO NPS because the information consists of descriptions of the design and analysis of the FCC-3 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 ORNO NPS, take marketing or other actions to improve their products position or impair the position ofORANO NPSs product, and avoid developing similar data and analyses in support of their processes, methods, or apparatus.

Further the deponent sayeth not.

13 2L22 CL Jessica Boutteau (Signature and date)

Director of Transport Operations and Business ORANO NPS

\\Vitnessed by

. ii SCHMIOTIsabe0e

>.AU.U-.

2022.0802 16:1229 i-0200 Laurent Klein (Signature and date)

Project Manager ORANO NPS Page I of I