ML24306A044
| ML24306A044 | |
| Person / Time | |
|---|---|
| Site: | 07103043 |
| Issue date: | 10/23/2024 |
| From: | Nakajima I Mitsubishi Nuclear Fuel Co, Ltd, Orano TN Americas |
| To: | Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML24306A041 | List: |
| References | |
| E-63985 | |
| Download: ML24306A044 (1) | |
Text
Enclosure 2 to E-63985
STATEMENT OF PROPRIETARY INFORMATION PURSUANT TO 49 CFR 7.14, 49 CFR 105.30, AND 10 CFR 2.390
I, Isao Nakajima, depose and say that I am the General Manager of the Transportation and Service Department of Mitsubishi Nuclear Fuel Co., Ltd. (MNF), 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 MNF, 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 Transportation's (U.S. DOT) regulations, and with the provisions of 10 CFR 2.390 of the Nuclear Regulatory Commission's (NRC) regulations. This information is exempt from public disclosure under the Freedom oflnformation Act, 5 U.S.C. 552, as amended, for withholding this information.
The information for which withholding is requested is listed below:
- Enclosure 1 - Response to Request for Supplemental Information for Revalidation of MFC-1
These documents have 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 contains trade secret or confidential or privileged commercial for Model MFC-1 Packaging. The information in the Revalidation request is owned and has been held in confidence by MNF.
- 2) The information is of a type customarily held in confidence by MNF and not customarily disclosed to the public. MNF 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 MNF because the information consists of descriptions of the design and analysis of the MFC-1 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 MNF, take marketing or other actions to improve their product's position or impair the position of MNF product, and avoid developing similar data and analyses in support of their processes, methods, or apparatus.
Further the deponent sayeth not.
ai:r Isao Nakajima General ager of Transportation and Service Department Mitsubishi Nuclear Fuel Co., Ltd.