ML22277A729

E-61285 Enclosure 5 Orano NPS Statement of Proprietary Information, FCC-4 Application Submitted on August 18, 2022 (Public)

ML22277A729
Person / Time
Site:	07103097
Issue date:	08/02/2022
From:	Boyle R, Shaw D TN Americas LLC
To:	Division of Fuel Management
Garcia-Santos N
Shared Package
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References
A33010, L-2022-DOT-0008
Download: ML22277A729 (1)

Text

Enclosure 5 to E-61283 ORANO NPS STATEMENT 0F PROPRIETARY INFORMATION PURSUANT TO 49 CFR 7.14,49 CFR 105.30, AND 10 CFR 2.390

1. Jessica Boutteau. depose and say that I am the Director of Transport Operations and Business for ORANO Nuclcar Packages and Services (NPS), duly authorized to execute this statement ofproprietary information and have revicwed or caused 10 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 (DOT) regulations, and with the provisions of 10 CFR 2.390 ofthe US. 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 contained in Enclosures 3, as listed below:

ORANO NPS Safety Analysis Report for FCC-4 These documents have been appropriately designated as proprietary.

Pursuant 10 the provisions ofparagraph 7.14 of Part 7 and paragraph (a) (3) ofPart 105 ofthe 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 DOT and by the NRC in determining whether the information sought 10 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-4 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 flot customarily disclosed 10 the public. ORANO NPS has a rational basis for determining the types of information that is customarily held in confidence by il.

3)

Public disclosure of Ihe information is likely to cause substantial harm to the competitive position of ORANO NPS because the information consists of descriptions of the design and analysis of the FCC-4 Packaging, as well as company business sensitive information, the application of which provides a competitive econornic advantage. The availability ofsuch 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 ofORANO NPSs product, and avoid developing similar data and analyses in support of their processes, methods, or apparalus.

Further the deponent sayeth not.

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ç ao222S.D2 Jessica Boutteau (Signature and date)

Director of Transport Operations and Business ORANO NPS Witnessed by SCHMIDT 2022 08 02 16 0930 +0200 Laurent Klein (Signature and date)

Project Manager ORANO NPS Page I of I