ML22278A046

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Enclosure 4 - Statement of Proprietary Information
ML22278A046
Person / Time
Site: 07103100
Issue date: 07/26/2022
From: Roulleaux-Dugage O
Transnuclear
To:
Office of Nuclear Material Safety and Safeguards
BWHITE NMSS/DFM/STLB 3014156577
Shared Package
ML22278A043 List:
References
Download: ML22278A046 (1)


Text

Enclosure 4 to E-6117 4 TRANS UCLEAR, LTD.

STATEME T OF PROPRIETARY INFORMATION PURSUANT TO 49 CFR 7.14, 49 CFR 105.30, AND 10 CFR 2.390 I, Olivier Roulleaux-Dugage, depo e and say that I am the Chief Executive Officer ofTRANSNUCLEAR, LTD .,

duly authorized to execute this statement of proprietary information and bave reviewed or caused to bave reviewed the infonnation which is identified as proprietary and referenced in the paragraph immediately below. TN Americas LLC on behalf ofTRA SNUCLEAR, LTD. is submitting this statement of proprietary info1mation in conformance with the provisions of49 CFR 7.14 and 49 CFR 105.30 of the Department's regulation , and with the provisions of 10 CFR 2.390 of the Commission's regulations. Thi infotmation is exempt from public di closure 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 document(s), as listed below:

  • Enclosure 1- Responses to Request for Additional Information (Proprietary version)
  • Enclosure 3 - International and Foreign National Standards (Proprietary)

These docw11ents have been appropriately designated as prop1ietary.

Pursuant to the provisions of paragraph 7. 14 of Part 7 and paragraph (a) (3) of Part 105 of the Department regulations, and the provisions of paragraph (b) (4) of Section 2.390 of the Commission's regulations the following is furnished for con ideration by the Department and by the Commission in determining whether the infom1ation sought to be withheld from public disclosure, included in the above referenced documents, should be withheld.

I) The information sought to be withheld involves portions of the Application for MX-6P Nuclear Fuel Package Design Approval for Model MX-6P Package related to the design and analysis of the MX-6P Package, which are owned and have been held in confidence by TRANSNUCLEAR, LTD.

2) The information is of a type customari ly held in confidence by TRANSNUCLEAR, LTD. and not customarily disclosed to the public. TRANS UCLEAR, LTD. bas a rational basis for determining the types of info1mation that is customarily held in confidenc.e by it.
3) Public disclosure of the information is likely to cause substantial harm to the competitive position of TRANS NUCLEAR, LTD. because the info1mation consists of descriptions of the de ign and analysis of the MX-6P Package, as well as company business sensitive information, the application of which provides a competitive economic advan tage. The availability of such information to competitors would enab le them to modify their product to better compete with TRA SNUCLEAR, LTD., take marketing or other actions to improve their product's position or impair the position of TRANSNUCLEAR, LTD . product, and avoid developing similar data and analyses in support of their processes, methods, or apparatus.

Further the deponent sayetb not.

ROULLEAUX- Signature numerique de ROULLEAUX-DUGAGE Olivier DUGAGE Olivier Date : 2022.07.26 07:52:06 +02'00' Olivier ROULLEAUX-DUGAGE (Signature and date)

Ch ief Executive Officer of TRANSNUCLEAR, LTD.

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OTO (Signature and date)

.2..SL Chief Operating Officer TRANSNUCLEAR, LTD.

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