ML26019A043
| ML26019A043 | |
| Person / Time | |
|---|---|
| Site: | 07201042 |
| Issue date: | 01/19/2026 |
| From: | Narayanan P Orano TN Americas |
| To: | Office of Nuclear Material Safety and Safeguards, Document Control Desk |
| Shared Package | |
| ML26019A042 | List: |
| References | |
| E-65191 | |
| Download: ML26019A043 (0) | |
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.
January 19, 2026 E-65191 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 Additional Alternative to the ACI Code, Concrete Temperature Testing, Docket 72-1042, CoC 1042 Amendment 1, Amendment 2, Amendment 3, and Amendment 4
Reference:
Letter dated December 18, 2025, from Prakash Narayanan (TN Americas LLC) to John Nguyen (NRC), Proposed Additional Alternative to the ACI Code, Concrete Temperature Testing, Docket 72-1042, CoC 1042 Amendment 1, Amendment 2, Amendment 3, and Amendment 4 Based on recent interactions with the NRC, the purpose of this submittal is to provide supplemental information in support of our request for an ACI 349-06 code alternative.
Specifically, the supplemental information provides responses to questions posed by NRC staff during a clarification call held on January 9th, 2026 (Enclosure 3). Additionally included is a Summary of HSM Construction and Testing (Enclosure 1), which was previously provided as Enclosure 1 to the Reference letter and has been revised to include requested additional concrete testing parameters. Enclosure 2 contains the Failure Mode Analysis discussed and requested on 1/9/26.
Enclosures 1, 2, and 3 contain TN commercial confidential information that may not be used for any purpose other than to support the NRC staffs review of the application. In accordance with 10 CFR 2.390, an affidavit is provided as Enclosure 4, specifically requesting that this commercial confidential information be withheld from public disclosure. Because Enclosures 1, 2, and 3 are entirely proprietary, no public versions are provided.
If the NRC staff has any questions regarding this submittal, please do not hesitate to contact Ms. Jess Gee at 440-389-3194 or Jess.Gee@Orano.Group.
Sincerely, Prakash Narayanan Chief Technical Officer
E-65191 Document Control Desk Page 2 of 2 cc:
John-Chau Nguyen (NRC-DFM)
Enclosures:
- 1. Summary of HSM Construction and Testing (Proprietary)
- 2. Failure Mode Analysis (Proprietary)
- 3. Responses to NRC Discussion Questions (Proprietary)
- 4. Affidavit Pursuant to 10 CFR 2.390
to E-65191 Summary of HSM Construction and Testing (Proprietary)
Withheld Pursuant to 10 CFR 2.390
to E-65191 Failure Mode Analysis (Proprietary)
Withheld Pursuant to 10 CFR 2.390
to E-65191 Responses to NRC Discussion Questions (Proprietary)
Withheld Pursuant to 10 CFR 2.390 to E-65191 Page 1 of 1 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 10 CFR 2.390 of the Commissions regulations for withholding this information.
The information for which proprietary treatment is sought meets the provisions of paragraph (a) (4) of Section 2.390 of the Commission's regulations. The information is contained in Enclosures 1, 2 and 3 as listed below:
- - Summary of HSM Construction and Testing (Proprietary)
- - Failure Mode Analysis (Proprietary)
- - Responses to NRC Discussion Questions (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. These documents have been appropriately designated as proprietary.
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 concrete mix testing data related to the design of the NUHOMS EOS System, which is owned by and has 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 validation 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: January 16th, 2026 Prakash Narayanan Chief Technical Officer, TN Americas LLC