ML24256A044
| ML24256A044 | |
| Person / Time | |
|---|---|
| Site: | 07201004 |
| Issue date: | 09/05/2024 |
| From: | Narayanan P TN Americas LLC |
| To: | Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML24256A043 | List: |
| References | |
| E-63874 | |
| Download: ML24256A044 (1) | |
Text
E-63874
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 that is identified as proprietary and referenced in the paragraph immediately below. I am submitting this affidavit in conformance with the provisions of 10CFR 2.390 of the Commissions regulations for withholding this information.
The information for which proprietary treatment is sought is listed below:
- Certain marked slides contained in the TN Americas slides for CoC 1004 Amendment 19 Pre-Application Meeting, October 2024 Portions of this slide presentationhave 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 2.390 of the Commissions 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.
- 1) The information sought to be withheld from public disclosure involves presentation slides for a public meeting, related to the licensing, design and analysis of dry spent fuel storage systems, 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 is related to design details, methodology and licensing approach of the CoC 1004 Standardized NUHOMS Amendment 18 application and provides 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 products position or impair the position of TN Americas LLCs 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.
Executed on: September 5 th, 2024
Prakash Narayanan Chief Technical Officer, TN Americas LLC
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