ML25262A162
| ML25262A162 | |
| Person / Time | |
|---|---|
| Site: | 07201004 |
| Issue date: | 09/19/2025 |
| From: | Narayanan P Orano TN Americas |
| To: | Office of Nuclear Material Safety and Safeguards, Document Control Desk |
| Shared Package | |
| ML25262A160 | List: |
| References | |
| E-64890 | |
| Download: ML25262A162 (1) | |
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.
September 19, 2025 E-64890 U. S. Nuclear Regulatory Commission Attn: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852
Subject:
Supplemental Information for the Proposed Alternatives to NG-4323 and IX QW-191.2.1, Docket 72-1004, Certificate of Compliance No. 1004, CAC/ EPID: 001029/L-2025-LLA-0016
Reference:
Letter from Prakash Narayanan (TN) to John-Chau Nguyen (NRC)
Proposed Alternatives to NG-4323 and IX QW-191.2.1, Docket 72-1004, Certificate of Compliance No. 1004, dated May 9, 2025 Based on recent interactions with the NRC, the purpose of this submittal is to provide supplemental information in support of our request for Dry Shielded Canister (DSC) S/N BNP-61BTH-2-F-2H-CH52 code alternatives. Specifically, the supplemental information provided includes Procedure Qualification Record (PQR) No. 120716 Revision 1 (Enclosure 2), Welding Procedure Specification (WPS) No. 08081-112 Revision 4 (Enclosure 3), and Ultrasonic Testing Inspector Qualifications (Enclosure 4).
Enclosures 2, 3, and 4 contain proprietary information, which may not be used for any purpose other than to support NRC staff review of the proposed code alternative. In accordance with 10 CFR 2.390, an affidavit (Enclosure 1) is provided specifically requesting that this proprietary information be withheld from public disclosure. Because Enclosures 2, 3 and 4 are entirely proprietary, no public versions are provided.
If the NRC staff has any questions regarding this submittal, please contact Mr.
Doug Yates at (434) 832-3101, or by email at douglas.yates@orano.group.
Sincerely, Prakash Narayanan Chief Technical Officer
E-64890 Document Control Desk Page 2 of 2 cc:
Heath Stroud (NRC-DFM)
Enclosures:
- 1. Affidavit Pursuant to 10 CFR 2.390
- 2. Procedure Qualification Record No. 120716 Revision 1
- 3. Welding Procedure Specification No. 08081-112 Revision 4
- 4. Ultrasonic Testing Inspector Qualifications to E-64890 Page 1 of 1 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 10 CFR 2.390 of the Commissions regulations for withholding this information.
The information for which proprietary treatment is sought is listed below:
- - Procedure Qualification Record No. 120716 Revision 1
- - Welding Procedure Specification No. 08081-112 Revision 4
- - Ultrasonic Testing Inspector Qualifications 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 2.390 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 documents, should be withheld.
- 1) The information sought to be withheld from public disclosure involves supporting files, all related to the fabrication of the Standardized NUHOMS dry spent fuel storage 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 fabrication of dry spent fuel storage systems, 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 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 19, 2025 Prakash Narayanan Chief Technical Officer, TN Americas LLC to E-64890 Procedure Qualification Record No. 120716 Revision 1 (Proprietary)
Withheld Pursuant to 10 CFR 2.390 to E-64890 Welding Procedure Specification No. 08081-112 Revision 4 (Proprietary)
Withheld Pursuant to 10 CFR 2.390 to E-64890 Ultrasonic Testing Inspector Qualifications (Proprietary)
Withheld Pursuant to 10 CFR 2.390