ML23054A178
| ML23054A178 | |
| Person / Time | |
|---|---|
| Site: | 07109342 |
| Issue date: | 02/23/2023 |
| From: | Vexler A Orano USA |
| To: | Office of Nuclear Material Safety and Safeguards, Document Control Desk |
| References | |
| E-62104 | |
| Download: ML23054A178 (1) | |
Text
orono Orano TN 7160 Riverwood Drive Suite 200 Columbia, MD 21046 USA Tel: 410-910-6900 Fax: 434-260-8480 ATTN: Document Control Desk Director, Division of Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 February 23, 2023 E-62104
Subject:
Transfer of Certificate Holder of NRC Certificate of Compliance No. 9342 (Docket No. 71-9342) for Radioactive Material Packages Model No. Versa-Pac in two configurations: VP-55 and VP-110.
Orano USA LLC ("Orano"), on behalf of itself and its wholly owned subsidiaries, TN Americas LLC ("TN Americas") and Orano TLI lnc.1 ("Orano TLI" or the "Certificate Holder"), hereby notifies the U.S. Nuclear Regulatory Commission ("NRC") of an internal restructuring impacting the person ("Certificate Holder") that has been issued a certificate of compliance
("CoC") for a radioactive material package ("Package") by the NRC and requests NRC approval of a transfer of Certificate Holder pursuant to 10 CFR Part 71, Packaging and Transportation of Radioactive Materials. Orano TLI is the current Certificate Holder for CoC No. 9342 (Docket No. 71-9342) for Model No. Versa-Pac in two configurations: VP-55 and VP-110 ("Versa-Pac").
Orano TU operated a front-end freight forwarding company dedicated to transportation of radioactive material, and the CoC approved the use of the Versa-Pac for domestic shipment of radioactive material. By way of background, Orano acquired Orano TU-formerly named "Transport Logistics International, lnc."-on September 30, 2021, and Orano TLI became a wholly owned subsidiary of TN Americas, and an indirectly wholly owned subsidiary of Orano on such date. Orano is, in turn, a wholly owned subsidiary of French company Orano SA, and is a "known entity" to the NRC.2 To further effectuate the integration of Orano TU into the Orano organization, Orano decided to take the additional step of integrating Oranci TU business operations fully into those of TN 1 The Certificate Holder was recently merged with and into its direct parent, TN Americas LLC, with the surviving entity in the merger continuing under the name "TN Americas LLC" (effected by the filing of Articles of Merger with the State of Maryland, and a Certificate of Merger with the State of Delaware, each made effective on January 1, 2023). Previous to that merger, the Certificate Holder had been renamed "Drano TLI" (effected by an amendment to the corporate charter documents on file for the Certificate Holder with the State of Maryland that was made effective on February 4, 2022), and was formerly known as "Transport Logistics International, Inc.". Please note that, in the interest of efficiency, we are seeking a name change for the Certificate of Compliance to reflect the final name of the Certificate Holder as of January 1, 2023, which is "TN Americas LLC".
2 Drano (formerly AREVA Nuclear Materials, LLC), is headquartered in Bethesda, Maryland, and provides technology and services for nuclear facility decommissioning, used fuel management, federal site clean-up and closure, and the sale of uranium, conversion, and enrichment services to the U.S. commercial and government markets. In addition to the Drano TLI CoC, there are a number of other NRC CoC currently and previously held by Drano companies operating in the U.S.
E-62104 Americas. The internal restructuring occurred by consolidating Orano TU business operations with those of its immediate parent company, TN Americas. Therefore, effective as of January 1, 2023, all of Orano TU's assets and personnel were moved into TN Americas, including the CoC approved for such use of the Versa-Pac and personnel responsible for the Package design control activities. Post-merger, Orano TU no longer exists as a separate legal entity.
As Orano is the parent company of TN Americas equally inasmuch it exercised indirect control over Orano TU, post-restructuring, Orano will continue to remain the parent company over the Versa-Pac Certificate Holder. See Enclosure for pre-and post-restructuring organizational charts. Therefore, Orano reasonably believes that consolidating the Orano TU business operations fully into TN Americas constitutes a bona fide change of Certificate Holder for the Versa-Pac CoC.
TN Americas maintains a Quality Assurance Plan approved by the NRC for each of the applicable criteria of 10 CFR §§ 71.101 through 71.137. All the Orano TU employees, equipment, facilities, personnel, and procedures in place related to the Versa-Pac CoC have been incorporated within the broader business operations of TN Americas. The main substantive change to the CoC is the name and address of the certificate as issued to:
TN Americas LLC 7160 Riverwood Drive, Suite 200 Columbia, MD 21046 Other than the Certificate Holder name and address change, no changes should be made to the Versa-Pac Coe.
As neither TN Americas nor Orano TLI are NRC licensees for the purpose of offering a "Package" for transportation under 10 CFR §71.17 General license: NRG-approved package ("Registered User")
inasmuch Orano TLI should be removed as a Registered User for any NRC Coe.
If you have any questions or comments pertaining to this submission, please contact TN Americas' Licensing Manager, Don Shaw, via phone at: (240) 565-3452; or via email at: donis.shaw@orano.group.
I declare under penalty of perjury under the laws of the United States of America that to the best of my knowledge the information contained in this submittal pertaining to the parties herein is true and correct.
Executed on February 23, 2023
.JJ/41/4!:
Amir Vexler CEO, Orano USA LLC President, TN Americas LLC CEO, Orano TU Inc.
amir.vexler@orano.group
Enclosure:
Simplified Pre-and Post-Restructuring Organizational Charts cc:
Yoira K Diaz-Sanabria, STLB Branch Chief, NRC Aida Rivera, IOB Branch Chief, NRC Nishka Devaser, STLB Project Manager, NRC Pierre Saverot, STLB Project Manager, NRC Michael Woods, Orano USA LLC General Counsel Don Shaw, Licensing Manager, TN Americas E-62104
E-62104 Enclosure Simplified Organizational Charts Describing the Transaction
Simplified Pre-and Post-Restructuring Organizational Charts Pre-Restructuring Orano SA (PPB:-Chatillon, France)
(Incorporated in: France) 1, Orano USA LLC (Incorporated in: Delaware) 1' TN Americas LLC (Incorporated in: Delaware) l Orano TLI Inc. (Licensee)1 (Incorporated in: Maryland)
Post-Restructuring (Current)
Orano SA (PPB: Chatillon, France)
(Incorporated in: France) 1, Orano USA LLC (Incorporated in: Delaware) l TN Americas LLC (Licensee)2 (Incorporated in: Delaware) 1 As noted above, Orano TLI was formerly known as 'Transport Logistics International, Inc." and was renamed "Orano TLI Inc."
2 TN Americas LLC is the NRC Certificate Holder. Orano TLI no longer conducts business, or is engaged in Certificate Holder activity, after its business was merger into that of TN Americas on January 1, 2023.
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