ML21013A497
| ML21013A497 | |
| Person / Time | |
|---|---|
| Site: | 07103098 |
| Issue date: | 01/06/2021 |
| From: | Division of Fuel Management, TN Americas LLC |
| To: | |
| Garcia-Santos N | |
| Shared Package | |
| ML21013A481 | List: |
| References | |
| E-58116, EPID L-2021-DOT-0000 | |
| Download: ML21013A497 (1) | |
Text
Enclosure 2 to E-58116 TN INTERNATIONAL STATEMENT OF PROPRIETARY INFORMATION PURSUANT TO 49 CFR 7.14, 49 CFR 105.30, AND 10 CFR 2.390 I, Eric Delaunay, depose and say that I am the Senior Vice President Nuclear Logistic Operation of TN International, 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 TN International, 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 contained in Enclosures 1, as listed below:
TNI Letter COR-20-033226-001 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 TN International.
- 2) The information is of a type customarily held in confidence by TN International and not customarily disclosed to the public. TN International 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 TN International 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 TN International, take marketing or other actions to improve their products position or impair the position of TN Internationals product, and avoid developing similar data and analyses in support of their processes, methods, or apparatus.
Further the deponent sayeth not.
Eric Signature numérique de Eric Delaunay Delaunay Date : 2021.01.06 18:52:17 +01'00' Eric Delaunay Senior Vice President Nuclear Logistic Operation TN International Witnessed by LATOUR 2021.01.07 08:51:02 Brigitte
__________________________ +01'00' Brigitte LATOUR Project Manager TN International