ML23339A062
| ML23339A062 | |
| Person / Time | |
|---|---|
| Site: | 07109313 |
| Issue date: | 12/05/2023 |
| From: | Shaw D Orano TN Americas, TN Americas LLC |
| To: | Office of Nuclear Material Safety and Safeguards, Document Control Desk |
| Shared Package | |
| ML23339A061 | List: |
| References | |
| E-62984 | |
| Download: ML23339A062 (1) | |
Text
December 5, 2023 E-62984 Orano TN 7160 Riverwood Drive Suite 200 U. S. Nuclear Regulatory Commission Columbia, MD 21046 Attn: Document Control Desk USA One White Flint North Tel: 410-910-6900 Fax: 434-260-8480 11555 Rockville Pike Rockville, MD 20852
Subject:
Supplemental Information for the Application for Revision 4 to Certificate of Compliance No. 9313 for the Model No. TN-40 Packaging, Docket No. 71-9313
References:
(1) TN Letter E-59049, Application for Revision 4 to Certificate of Compliance No. 9313 for the Model No. TN-40 Packaging, Docket No. 71-9313, dated December 16, 2021 (Agencywide Documents Access and Management System [ADAMS] Package Accession No. ML21350A282)
(2) TN Letter E-62022, Response to Request for Additional Information for the Application for Revision 4 to Certificate of Compliance No. 9313 for the Model No. TN-40 Packaging, Docket No. 71-9313, dated June 6, 2023 (ADAMS Package Accession Nos.
(3) TN Letter E-62829, Supplemental Information for the Application for Revision 4 to Certificate of Compliance No. 9313 for the Model No. TN-40 Packaging, Docket No. 71-9313, dated November 14, 2023 (ADAMS Package Accession No. ML23318A179)
In accordance with 10 CFR 71.31, TN Americas LLC (TN Americas) submitted an application for Revision 4 to Certificate of Compliance (CoC) No. 9313 for the TN-40 packaging [1], as supplemented to provide additional information requested by the NRC to complete the review in accordance with 10 CFR 71.38 [2], and as supplemented to provide additional changes [3]. The purpose of this submission is to provide a supplement to provide clarification to responses provided previously for additional information as requested by the NRC.
Enclosure 1 provides the response to the supplemental Request for Additional Information. Enclosure 2 provides a public version of Enclosure 1.
Enclosures transmitted herein contain SUNSI. When separated from enclosures, this transmittal document is decontrolled.
E-62984 Document Control Desk Page 2 of 2 Preliminary changed Safety Analysis Report (SAR) pages are provided as Revision 17D in . SAR Revision 17D changes are indicated by Revision 17, 12/23 in the header of the changed page. Each changed page includes italicized text and revision bars adjacent to the text change. Additionally, text changes are gray shaded to distinguish them from Revision 17A, Revision 17B, and Revision 17C changes. A public version of the Revision 17D SAR changed pages with proprietary information redacted is provided for public availability as Enclosure 4. A consolidated SAR Revision 17 will be submitted upon completion of the NRC review.
The NRC Electronic Information Exchange (EIE) system is used for submission of this supplement to the application.
Certain portions of this submittal include proprietary information. In accordance with 10 CFR 2.390, TN Americas is providing an affidavit (Enclosure 5) requesting that this proprietary information be withheld from public disclosure.
Should the NRC staff have any questions or require additional information regarding this submittal, please contact Mr. Peter Vescovi by telephone at (336) 420-8325, or by e-mail at peter.vescovi@orano.goup.
Sincerely, Digitally signed by SHAW Donis SHAW Donis Date: 2023.12.05 09:50:55 -05'00' Don Shaw Licensing Manager TN Americas LLC cc: Pierre Saverot, Senior Project Manager, U.S. Nuclear Regulatory Commission Scott Bomar, Senior Project Manager, Orano TN Americas
Enclosures:
- 1. Supplemental RAI and Response (Proprietary Version)
- 2. Supplemental RAI and Response (Public Version)
- 3. TN-40 Transportation Packaging SAR, Revision 17D, Changed Pages (Proprietary version)
- 4. TN-40 Transportation Packaging SAR, Revision 17D, Changed Pages (Public version)
- 5. Affidavit Pursuant to 10 CFR 2.390
Enclosure 1 to E-62984 Supplemental RAIs and Responses (Proprietary version)
Withheld Pursuant to 10 CFR 2.390
Supplemental RAIs and Responses (Public) Enclosure 2 to E-62984 Proprietary Information on Pages 1 through 15 Withheld Pursuant to 10 CFR 2.390 Page 1 of 15
Enclosure 3 to E-62984 TN-40 Transportation Packaging SAR, Revision 17D, Changed Pages (Proprietary version)
Withheld Pursuant to 10 CFR 2.390
TN-40 Transportation Packaging Safety Analysis Report Rev. 17, 12/23 Proprietary Information on This Page Withheld Pursuant to 10 CFR 2.390 Page 2.10.7-3 All indicated changes on this page are in response to RAI 2.1-V2
TN-40 Transportation Packaging Safety Analysis Report Rev. 17, 12/23 Proprietary Information on This Page Withheld Pursuant to 10 CFR 2.390 Page 2.10.7-6 All indicated changes on this page are in response to RAI 2.1-V2
TN-40 Transportation Packaging Safety Analysis Report Rev. 17, 12/23 Proprietary Information on Pages 2.10.7-8 through 2.10.7-12 Withheld Pursuant to 10 CFR 2.390 Page 2.10.7-8 All indicated changes on this page are in response to RAI 2.1-V2
TN-40 Transportation Packaging Safety Analysis Report Rev. 17, 12/23 Proprietary Information on This Page Withheld Pursuant to 10 CFR 2.390 Page 2.10.7-15 All indicated changes on this page are in response to RAI 2.1-V2
Enclosure 5 to E-62984 TN AMERICAS LLC AFFIDAVIT PURSUANT TO 10 CFR 2.390 State of Maryland:
County of HOWARD 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 listed below:
- Enclosure I - Portions of TN-40 Application for Approval, Responses to Supplemental (V2) RAis (Proprietary)
- Enclosure 3 - Portions of TN-40 Transportation Package Safety Analysis Report, Revision 17D (Proprietary)
These documents have 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 2.3 90 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.
I) The information sought to be withheld from public disclosure involves certain design details associated with the SAR analyses, SAR drawings, and analysis computer files for the TN-40 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.
I declare that the statements set forth in this affidavit are true and correct to the best of my knowledge, information, and belief. I declare under penalty of perjury that the foregoing is true and correct.
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