ML24134A072
| ML24134A072 | |
| Person / Time | |
|---|---|
| Site: | 07103098 |
| Issue date: | 07/25/2023 |
| From: | Shaw D Orano TN Americas |
| To: | Boyle R Office of Nuclear Material Safety and Safeguards, US Dept of Transportation (DOT), Office of Hazardous Materials Safety |
| Shared Package | |
| ML24134A071 | List: |
| References | |
| A33010, L-2023-DOT-0002, E-62515 | |
| Download: ML24134A072 (4) | |
Text
Orano TN 7160 Riverwood Drive Suite 200 Columbia, MD 21046 USA Tel: 410-910-6900 Fax: 434-260-8480 Enclosures transmitted herein contain SUNSI. When separated from enclosures, this transmittal document is decontrolled.
July 25, 2023 E-62515 U.S. Department of Transportation Attn: Mr. Richard W. Boyle Pipeline & Hazardous Materials Safety Administration Radioactive Materials Branch 1200 New Jersey Avenue, S.E.
East Building, PHH-20 Washington, DC 20590
Subject:
Additional Information for Review of the Application for Revalidation of Competent Authority Certification J/2009/AF, GP-01
Reference:
[1] TN Americas LLC letter E-56661 dated April 30, 2020,
Subject:
Application for Revalidation of Competent Authority Certification J/2009/AF-96, GP-01 (NRC ADAMS Accession No. ML23026A140)
[2] NRC Letter dated May 24, 2023,
Subject:
Request for Additional Information for Review of the Certificate of Compliance No. 3098-Model No. GP-01(EPID L-2023-DOT-0002, NRC ADAMS Accession No. ML23118A008)
[3] Orano NPS letter COR-23-005391-000 (2.0), dated July 3, 2023,
Subject:
GP validation of Japanese Certificate J/2009/AF
Dear Mr. Boyle:
TN Americas LLC, on behalf of Orano Nuclear Packages and Services (NPS),
applied in accordance with §173.473 for revalidation the Competent Authority of Japan, Certification for Approval of Package Design for Transport of Radioactive Materials, Identification Mark: J/2009/AF-96 (Revision 1) [1]. The U.S. Nuclear Regulatory Commission (NRC) requested additional information to complete the review of the application [2]. is additional information provided by Orano NPS [3]. Enclosure 2 is a statement of proprietary information pursuant to 49 CFR 7.14, 49 CFR 105.30, and 10 CFR 2.390.for the additional information provided in Enclosure 1.
E-62515 U.S. Department of Transportation Page 2 of 2 Should you have any questions or require additional information to support review of this application, please contact Peter Vescovi by telephone at 336-420-8325, or by e-mail at peter.vescovi@orano.group.
Sincerely, Don Shaw Licensing Manager TN Americas LLC cc:
Brigitte Latour, Orano Nuclear Packages and Services Laurence Labbe, TN Americas LLC
Enclosures:
- 1. Orano NPS letter COR-23-005391-000 (Proprietary)
- 2. Statement of Proprietary Information Don Shaw Digitally signed by Don Shaw Date: 2023.07.25 10:11:23
-04'00'
to E-62515 Orano NPS letter COR-23-005391-000 (Proprietary)
Withheld Pursuant to 10 CFR 2.390 to E-62515 ORANO NPS STATEMENT OF PROPRIETARY INFORMATION PURSUANT TO 49 CFR 7.14, 49 CFR 105.30, AND 10 CFR 2.390 I, Jessica Boutteau, depose and say that I am the Director Transport Operations & Business of Orano Nuclear Packages and Services (NPS), duly authorized to execute this statement of proprietary 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 behalf of Orano NPS, is submitting this statement of proprietary information in conformance with the provisions of 49 CFR 7.14 and 49 CFR 105.30 of the U. S.
Department of Transportations (U.S. DOT) regulations, and with the provisions of 10 CFR 2.390 of the 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 listed below:
x - TNI Letter COR-23-005391-000 Version 2.0 (Proprietary)
This document has been appropriately designated as proprietary.
Pursuant to the provisions of paragraph 7.14 of Part 7 and paragraph (a) (3) of Part 105 of the U.S.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 U.S.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 responses to request for additional information (RAI) for Model GP-01 Packaging. The information in the response to RAI is owned and has been held in confidence by Orano NPS.
- 2) The information is of a type customarily held in confidence by Orano NPS and not customarily disclosed to the public. Orano NPS has 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 Orano NPS because the information consists of descriptions of the design and analysis of the GP-01 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 Orano NPS, take marketing or other actions to improve their products position or impair the position of Orano NPSs product, and avoid developing similar data and analyses in support of their processes, methods, or apparatus.
Further the deponent sayeth not.
Jessica Boutteau Director Transport Operations & Business Orano Nuclear Packages and Services Witnessed by Arnaud Lefort Design Engineer Orano Nuclear Packages and Services BOUTTEAU Jessica 2023.07.25 10:57:16
+02'00' LEFORT Arnaud DN : cn=LEFORT Arnaud, email=arnaud.lefort@are va.com, c=FR Date : 2023.07.25 11:07:02 +02'00'