ML23016A003

Application for Revision 11 to Certificate of Compliance No. 9302 for the Model No. NUHOMS-MP197 Packaging, Docket No. 71-9302-Submission of the Consolidated SAR Revision 21 (Docket No. 71-9302, EPID-L-2020-LLA-0260)

ML23016A003
Person / Time
Site:	07109302
Issue date:	01/16/2023
From:	Shaw D Orano TN Americas, TN Americas LLC
To:	Office of Nuclear Material Safety and Safeguards, Document Control Desk
Shared Package
ML23016A002	List: ML23016A003 ML23016A004
References
EPID-L-2020-LLA-0260, E-61405
Download: ML23016A003 (1)

Text

January 16, 2023 E-61405 Orano TN 7160 Riverwood Drive Suite 200 U. S. Nuclear Regulatory Commission Columbia, MD 21046 Attn: Document Control Desk USA One White Flint North Tel: 410-910-6900 Fax: 434-260-8480 11555 Rockville Pike Rockville, MD 20852

Subject:

Application for Revision 11 to Certificate of Compliance No. 9302 for the Model No. NUHOMS-MP197 Packaging, Docket No. 71-9302-Submission of the consolidated SAR Revision 21 (Docket No. 71-9302, EPID-L-2020-LLA-0260)

References:

[1] TN Letter E-57283 dated November 30, 2020, Application for Revision 11 to Certificate of Compliance No. 9302 for the Model No.

NUHOMS-MP197 Packaging, Docket No. 71-9302

[2] NRC Letter dated April 7, 2020, Request for Additional Information for the Review of the Model No. MP-197HB Package (Docket No. 71-9302, EPID-L-2020-LLA-0260)

[3] TN Letter E-58681 dated May 28, 2021, Application for Revision 11 to Certificate of Compliance No. 9302 for the Model No.

NUHOMS-MP197 Packaging, Docket No. 71-9302

[4] NRC Letter dated August 6, 2021, Second Request for Additional Information for the Review of the Model No. MP-197HB Package (Docket No. 71-9302, EPID-L-2020-LLA-0260)

[5] TN Letter E-59461 dated May 31, 2022, Application for Revision 11 to Certificate of Compliance No. 9302 for the Model No.

NUHOMS-MP197 Packaging, Docket No. 71-9302 In accordance with 10 CFR 71.31(b), TN Americas LLC (TN) submitted an application for revision to Certificate of Compliance (CoC) No. 9302 for the Model No. NUHOMS-MP197 Packaging [1]. The NRC staff determined that additional information was required to complete the technical review of the application [2]. TN provided the additional information requested [3], and the NRC issued a second request for additional information (RAI) [4].

After submitting responses to the second RAI [5], TN discovered that other clarifications were needed and certain information in the application needed to be corrected. TN is providing an explanation of these clarifications and additional changes to the SAR in Enclosure 1.

Enclosures transmitted herein contain SUNSI. When separated from enclosures, this transmittal document is decontrolled.

E-61405 Document Control Desk Page 2 of 2 All SAR Revision 21 changes are indicated by revision bars in the margin and associated insertions are shown in italics. A consolidated SAR Revision 21 is provided as Enclosure 2, which includes the changes and clarifications made subsequent to the second RAI responses. A public version of Enclosure 2 is provided as Enclosure 3.

Certain portions of this submittal include proprietary and security related information, which 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, TN Americas LLC is providing an affidavit as Enclosure 4 to request that proprietary information be withheld from public disclosure.

Should the NRC staff have any questions or require additional information regarding this submittal, please contact Mr. Peter Vescovi by telephone at (336) 420-8325, or by e-mail at peter.vescovi@orano.goup.

Sincerely, Digitally signed by Don Shaw Don Shaw Date: 2023.01.16 13:27:23 -05'00' Don Shaw Licensing Manager TN Americas LLC cc: Pierre Saverot, Senior Project Manager, U.S. Nuclear Regulatory Commission Eric Pernice, Senior Project Manager, Orano TN Americas

Enclosures:

1. Explanation of Additional SAR Changes

2. NUHOMS-MP197HB SAR, Revision 21 (Proprietary Version)

3. NUHOMS-MP197HB SAR, Revision 21 (Public Version)

4. Affidavit Pursuant to 10 CFR 2.390

Enclosure 1 to E-61405 Explanation of clarifications to the SAR (Docket No. 71-9302, EPID-L-2020-LLA-0260)

Clarifications are provided for ITEMS numbered 1 through 10. Items in the SAR needing clarifications are shown in bold font, and explanations for these clarifications are shown in regular font. Excerpts from the SAR drawing or text are provided along with the affected drawings and sections of the SAR.

Changes to the SAR as a result of these clarifications are included in the consolidated SAR Revision 21. Changes are indicated by italicized text and revision bars in the left margin.

1. Gap sizes and how specified or identified in the drawings Drawings are revised to indicate that radial gaps do not exceed those assumed in the shielding evaluation. The shielding evaluation considers up to a 0.25-inch radial gap shielding at the top and bottom of the radioactive waste container (RWC) in addition to streaming paths from vent or drain penetrations in the top shielding materials.

a. RWC-BA - between shield plug and shield ring RWC-BA-71-1001 SHEET 1 OF 7, DETAIL 1 .09 MAX RWC-BA-71-1002 SHEET 1 OF 4, DETAIL 1 .25 MAX DIAMETRICAL GAP There is a larger 0.625-inch radial gap between the SHIELD RING (ITEM 3) and TOP SHIELD PLUG (ITEM 4). This gap is acceptable because the BOLTING RING (ITEM 1) thickness of 2.00 inches and TOP COVER PLATE (ITEM 5) thickness of 5.55 inches stack up above this gap and the combined thickness of these two items exceeds the shielding thickness represented in the shielding evaluation as 7.00 inches of steel.

b. RWC-24PT1 - between the top shield plug/inner top cover plate and the RWC shell/vent block RWC-24PT1-71-1001 SHEET 3 OF 5, DETAIL 1 .25 MAX RADIAL GAP TOP END FIT-UP

c. RWC-24PT4 - between the top shield plug and the RWC shell/vent block RWC-24PT4-71-1001 SHEET 1 OF 8, NOTE 20 SHALL NOT EXCEED 1/8 and 26 INCH or 0.12 SHEET 4 OF 8, DETAIL 2 .25 MAX RADIAL GAP TOP END FIT-UP 1 of 14

Enclosure 1 to E-61405

d. RWC-WA - between RWC shell and Items 2, 3, 11, 12, and 13 on the drawing RWC-WA-71-1001 SHEET 2 OF 6, .25 MAX RADIAL GAP SECTION A1-A1 between shell and outer bottom cover plate (item 11),

bottom shield plug (item 12),

and inner bottom cover Plate (item 13)

SHEET 3 OF 6, .25 MAX RADIAL GAP DETAIL 2 between shell (item 1) and outer top cover plate (item 2) and inner top cover plate (item 3)

There is a radial gap between the liner (ITEM 17) and shell (ITEM 1), but all activity is confined to the liner.

e. RWC-DD RWC-DD-71-1001 SHEET 2 OF 7, .12 MAX RADIAL GAP SECTION B-B between shell and top shield plug,

.13 MAX RADIAL GAP between lid shell (item 9) and plate lid (item 10)

SHEET 3 OF 7, DETAIL 5 .25 MAX DIAMETRICAL GAP between shell and Bottom shield plug PLATE (ITEM 6).

2 of 14

Enclosure 1 to E-61405

2. Lead gaps and thickness specifications for the RWC-24PT4 should include axial and radial gaps and minimum thickness dimensions.

a. Note 26 of RWC-24PT4-71-1001 has some details, but ITEM 10 is not used in the drawing. So, it is not clear what the note is referring to.

The SAR drawing has been revised to only show Section A-A as one part ITEM 3 and remove ITEM 10 from Parts List and Note 26.

b. Also, it is not clear if there are gaps between the lead and ITEMS 3, 6, 8, 9, 12, and 13 and how the drawing addresses those.

Drawing RWC-24PT4-71-1001 Note 26 has been revised to include ITEMS 3, 6, 9, 11, and 13.

No radial gap exists between the lead and the inner top cover plate (ITEM 12) and the inner bottom cover plate (ITEM 8).

RWC-24PT4-71-1001 Revision 0A RWC-24PT4-71-1001 Revision 0B

c. It is not clear how diamond Note 20 is used or to what it is applied, whether radial gaps, axial gaps, both.

Note 20 is meant for the axial gap between lead surface and cover plates (ITEMS 3, 8, 11, and 12). The note has been revised to clarify to which parts the axial gap applies.

RWC-24PT4-71-1001 Revision 0A RWC-24PT4-71-1001 Revision 0B

d. The minimum thickness of the lead in the top shield plug is not clear (needed for Section 8.1.6.1 acceptance criteria); the drawing specifies a nominal thickness only. Also, confirm that the thickness dimensions are for the lead and the lead cavity and that there would not be an axial gap between the lead and lead cavity surfaces, only a radial gap.

Note 2 on SAR drawing has been revised to include lead. .PLATES/SHELLS/LEAD RWC-24PT4-71-1001 Revision 0A RWC-24PT4-71-1001 Revision 0B 3 of 14

Enclosure 1 to E-61405

3. Explain the meaning of 1/8-inch (laminar) flaw in the Section 8.1.6.1 acceptance test criteria. It is not clear if this means that there is an extra 1/8 inches of axial void (lead is 1/8 inch thinner than minimum specified on the drawings) or how this flaw may be radially limited in size/area (there is no criterion for that).

The laminar flaw is allowed to be present in the minimum thickness for lead specified on the drawings. There are no criteria for the size or area of the flaw because the flaw is not included in the shielding evaluation. If any flaw up to 1/8-inch is detected, it is assumed to reduce the entire area thickness by 1/8 inch. There is sufficient shielding thickness in the minimum specified on the drawing for the shield plugs to allow for a 1/8-inch overall reduction in lead thickness and still meet the minimum steel thickness evaluated in the shielding evaluation.

Furthermore, this reduced lead thickness that is included in the total shielding material thickness is more effective as a shielding material than the minimum steel thickness used in the shielding evaluation.

4. Clarify how the Section 8.1.6.1 acceptance criteria applies to DSCs with lead in bottom and top shield plugs.

Shielding analyses for DSCs, like the 24PT4, that have lead in the bottom and top shield plugs is treated as being bounded by the 37PTH and 69BTH DSCs, which are entirely steel. It is not clear that the HAC analysis is bounding for DSCs like the 24PT4 when lead slump is evaluated to the extent that the Section 8.1.6.1 acceptance criteria will allow.

An analysis has been added to the shielding evaluation for the 24PTH/24PT4 Dry Shielded Canister (DSC). The revised evaluation for hypothetical accident condition (HAC) has been done with a maximum plausible top and bottom shield plug lead slump condition to examine the impact of this scenario on the top and bottom HAC total dose rates. The analysis was performed using a modified version of the 37PTH DSC shielding model by changing the top and bottom shield plug configurations from that of the 37PTH DSC to that of the 24PTH DSC. Note that the 24PTH DSC top and bottom shield plugs bound those of the 24PT4 DSC.

Two sets of examinations were performed, one with the design basis neutron dominated source terms used in the other normal conditions of transport (NCT) and HAC 37PTH DSC analyses, and a second set using a gamma dominated source term to verify that the analysis bounds both 4 of 14

Enclosure 1 to E-61405 source scenarios. The node size of the mesh tallies for the RWC analysis are the same size as for the DSC analysis. SAR Chapter A.5 pages have been revised and indicate changes associated with this clarification.

5. Clarify how estimated radiation levels versus the limits for 2 meters from the package front and the occupied space positions for the 1.7-inch thick RWC are affected when cask lid and base tolerances are considered.

The margins for the radiation levels at 2 meters from the package front and for the occupied space results for both the front and rear of the package are fairly small and may not be enough to account for the radiation level impacts due to package tolerances in the package front and rear locations. The analysis uses nominal cask lid and base thicknesses. Tolerances could be as much as 1/4 inch on the steel in the lid and base per the drawings.

The shielding evaluation performed an investigation into how an axial reduction of 0.05 inches in the MP197HB top lid thickness and 0.25 inches in the MP197HB bottom lid thickness impacts the axial dose rates and occupied space minimum distances by using the first principles correlation µ , where µ is the attenuation coefficient for steel ( = 7.86 g/cc) for a 1.25 MeV gamma particle (1.085 in-1) and t is the thickness reduction in inches. A 0.05-inch reduction in the steel shielding material yields a 5.6% increase in dose rate, and a 0.25-inch reduction in the steel shielding material yields a 31.2% increase in dose rate. The process described here is introduced in SAR Section A.5.5.6.4.1.2 and detailed in Section A.5.5.6.5.1, and the NCT axial dose rates and minimum required distances for occupied space placement for the 1.7-inch RWC analysis reported in Table A.5-64 have been adjusted.

6. Section A.7.1 package operations for a DSC in a NUHOMS transfer cask The text in Section A.7.1 states that the procedures address operations with a DSC in a NUHOMS transfer cask. It is not clear that the operations chapter includes such operations elements.

NUHOMS-MP197HB package and NUHOMS-MP197HB cask are used to both mean the MP197HB transportation package. The transfer cask is a different design designated as NUHOMS-OS197 or OS200 transfer cask. NUHOMS transfer cask has been removed from Section A.7.1

7. Maximum axial gap in cask cavity for DSCs Based on the drawing specifications, the total spacer lengths for top plus bottom result in axial gaps less than 0.5 inch with about 0.15 inch to spare, and this remaining gap is based on the minimum cask cavity length and maximum DSC 5 of 14

Enclosure 1 to E-61405 lengths. Confirm the gap will remain less than 0.5 inch for the DSCs at their minimum lengths and the cask cavity is at its maximum length for the specified spacer lengths.

SAR Table A.7-1, Axial Spacer Heights, has been deleted. Experience with loading RWC-DD has revealed that there are variations in the canister overall dimensions due to irregularities in the flatness of the bottom that require spacer heights to be adjusted to accommodate the as-built canister. A statement has been added to SAR Section A.7.1.2, Step 10; A.7.1.2.2, Step 5a; and A.7.1.3.2, Step 2c that requires all spacers heights to be determined using actual as-built dimensions. The revised step includes criteria previously stated as notes for Table A.7-1.

8. Confirm that the front vehicle/cask surface radiation levels for the 0.5-inch and 1.7-inch thick RWCs in Tables A.5-64 and A.5-65 are consistent.

Patterns of differences between radiation levels for the two RWCs are consistent with each other for the two RWCs with the exception of the radiation levels at front vehicle/cask surface.

These patterns of differences in radiation levels are consistent with differences in features that affect the calculated radiation levels, for example, radial gaps and penetrations for vent and drain. These features affect the external radiation levels on the front surfaces of the cask, or front or back-end locations on the vehicle.

9. Changes to Chapter A.7 as follows:

a. Table A.7-2b specifications on specific activity are modified to read as: shall not exceed 6.46 Ci Co-60 or equivalent per kilogram of material and shall not exceed 3.78 Ci Co-60 or equivalent per kilogram of material. The term material in these two places should be written as contents material.

Specific activities have been revised and the term material changed to read contents material.

b. Section A.7.1.2, Step 10 needs to be modified to address spacers for DSCs and RWCs now that Table A.7-1 is removed.

Reference to SAR Table A7-1 has been replaced with instructions for spacer heights.

c. Section A.7.1.3.2, Step 22a needs to be modified now that Table A.7-1 is removed.

Reference to SAR Table A7-1 has been replaced with instructions for spacer heights.

d. Notes on fuel spacers and basket spacers from the deleted Table A.7-1 and moved to Table A.7-3. Notes for the RWC/DSC spacers should be moved to the loading operations steps where these spacers would be used in each of the Chapter A.7 appendices identified in Table A.7-3.

Notes 1 and 2 from SAR Table A.7-1 for the RWC/DSC spacers have been incorporated into the procedure loading steps in SAR Section A.7.1.3.2 Step 2 (Note that two steps use number

2. This step has been renumbered as Step 3 and the following step is renumbered as Step 4),

and Step 22a, SAR Section A.7.1.2.2 Step 5a, and A.7.1.2 Step 10. Notes 3 and 4 are 6 of 14

Enclosure 1 to E-61405 incorporated in SAR Table A.7-3 as Notes 1 and 2, and Table A.7-3 is now referenced in SAR A.7.1.2 Step 13a instead of in Table A.7-1.

10. In addition to the ITEMS numbered 1 through 9 above, there are several miscellaneous corrections for the drawings and text.

a. RWC-BA-71-1001, Note 13: ITEM 3 in the note should be ITEM 4 RWC-BA-71-1001 Revision 0A RWC-BA-71-1001 Revision 0B

b. RWC-24PT1-71-1001, Note 10: ITEM 3 in the note should be ITEM 13 RWC-24PT1-71-1001 Revision 0A RWC-24PT4-71-1001 Revision 0B 7 of 14

Enclosure 1 to E-61405

c. RWC-24PT4-71-1001: Correction to Notes 11 and 12; the text (e.g., Note 14) regarding ITEMS 24 and 27 (there does not appear to be an ITEM 27); and the references to baskets (e.g., top view on Sheet 3)

SAR Drawing RWC-24PT4-71-1001, Note 14 has been revised to refer to ITEMS 3 or ITEM 8 only. ITEM 24 and ITEM 27 were for an alternate outer and inner bottom cover plate that is not used.

RWC-24PT4-71-1001 Revision 0A RWC-24PT4-71-1001 Revision 0B Note 11 has been deleted since ITEM 24 is not used for the RWC. Likewise, ITEM 24 has been deleted from Note 12 RWC-24PT4-71-1001 Revision 0A RWC-24PT4-71-1001 Revision 0B References to top shield plug and baskets have been deleted in the TOP VIEW on SHEET 3 OF 8.

RWC-24PT4-71-1001 Revision 0B 8 of 14

Enclosure 1 to E-61405

d. RWC-DD-71-1001: Correction to Note 22 (it does not match with the parts list or spots on the drawing sheets) and Note 10 (fasteners means lid bolts)

RWC-DD-71-1001, Note 22 has been revised to reference the correct sections that show the port configurations.

RWC-DD-71-1001 Revision 0A RWC-DD-71-1001 Revision 0B Note 10 has been revised to change FASTENERS to BOLTS, which is consistent with nomenclature for ITEM 16 shown as LID BOLT/SCREW in the parts list.

RWC-DD-71-1001 Revision 0A RWC-DD-71-1001 Revision 0B 9 of 14

Enclosure 1 to E-61405

e. RWC-WA-71-1001: Details 5 and 6 are missing, though there is a Detail 5A The drawing has been revised to remove the DETAIL 5 and 6 call-out on SAR Drawing RWC-WA-71-1001, SHEET 4 OF 6, SECTION C-C. Detail of the canister bottom previously called out as DETAIL 5 is SECTION E-E, and an alternate SECTION E-E replaces DETAIL 5A, as shown on SHEET 5 OF 6. Details of the canister top previous called out as DETAIL 6 are shown as SECTION B-B on SHEET 3 OF 6.

f. References in several locations within Section A.5.5.6 (e.g., see Section A.5.5.6.2) and its subsections to Section A.5.3.1.3. Section A.5.3.1.3 has been deleted and marked as Not Used.

All references to SAR Section A.5.3.1.3 have either been updated or removed. The other cross-references in SAR Section A.5.5.6 have been verified to be accurate.

g. Clarification of text to ensure correct descriptions of the information presented in referenced figures, tables, and sections. For example, unlike is stated in Section A.5.5.6.4.1, Table A.5-66 does not include thicknesses of cask shielding components; it only has that information for the RWCs.

This specific error was corrected as described, and all other such descriptions in SAR Section A.5.5.6 are verified to be accurate or updated as needed.

h. Clarification of items such as application of response function method and mesh tallies from DSCs to RWCs; there are some differences in the method and the mesh tallies between application to DSCs and application to RWCs though Section A.5.5.6.4.1 states the response function method is retained and Section A.5.5.6.4.1.5 states that the mesh tallies are identical for the DSCs and RWCs.

For tallies, SAR Section A.5.5.6.4.1.5 has been updated to contain a detailed description of the tallies used in the shielding models for NCT dose rates, HAC dose rates, and minimum distance to occupied spaces verification.

10 of 14

Enclosure 1 to E-61405

i. The limit for HAC is 1 meter from the package surfaces and not the vehicle surfaces as is written in Section A.5.5.6.5.1.2.

SAR Section A.5.5.6.5.1.2 has been revised to replace the word vehicle with package.

j. Description at the top of page A.7-5 about RWCs loaded/stored under Part 72. Unless the Part 72 license is a specific license, the RWC was not loaded under a Part 72 license, but instead under a Part 50/52 license (RWCs cannot be stored under Part 72 general licenses since Part 72 does not include certified casks for storage of materials like what RWCs contain).

SAR Section A.7.1.2 (page A.7-5) has been revised to clarify that DSCs are loaded under a Part 72 license and RWCs are not stored under the Part 72 license.

k. For SAR Table A.7-2b, max quantity section, ITEM c, the word shielding at the beginning of the sentence should be deleted since this is the contents materials.

11 of 14

Enclosure 1 to E-61405 The word shielding has been removed from the third paragraph under Table A.7-2b, ITEM (c).

12 of 14

Enclosure 1 to E-61405

l. For the new NOTE in Section 8.1.6.1, add and requires revision of the CoC at the end of the last sentence of the first paragraph. Also, change the reference in the second paragraph to Chapter 1, Appendix 1.4.10 should be to Chapter A.1, Appendix A.1.4.10.

SAR Section 8.1.6.1 has been revised to distinguish between criteria for poured and rolled lead shielding material. The Note applies only to the poured lead shielding material and the Note is revised to add the requirement for prior NRC approval by revision of the CoC. The reference to SAR Chapter 1 has been changed to Chapter A.1.

13 of 14

Enclosure 1 to E-61405

m. A note is added to page A.7-5c (note for RWC-B and threaded plug) in response to the first round RAIs. This note needs to be modified based on the design changes in drawings.

The note was removed in response to the second round RAI 1.1.b because the transport configuration shown on SAR drawings no longer allowed a vent plug for transportation.

n. The tolerance for the cask lid (0.05) needs to be added to the package drawings.

This tolerance is important in the shielding analysis for the 1.7-inch shell RWC to meet the regulatory radiation level limits.

A tolerance for the cask lid has been added to SAR Drawing MP197HB-71-1006, Section F-F, by showing 4.50 nominal and 4.45 minimum for the thickness.

14 of 14

Enclosure 2 to E-61405 NUHOMS-MP197HB SAR, Revision 21 (Proprietary Version)

Transmitted Separately

Enclosure 3 to E-61405 NUHOMS-MP197HB SAR, Revision 21 (Public Version)

Transmitted Separately

Enclosure 4 to E-61405 AFFIDAVIT PURSUANT TO 10 CFR 2.390 TN Americas LLC )

State of Maryland ) SS.

County of Howard )

I, P~~sh 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 which 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 Commission' s regulations for withholding this information.

The information for which proprietary treatment is sought is listed below:

• Enclosure 2 - Portions of certain chapters and appendices of the Safety Analysis Report (SAR) for Certificate of Compliance No. 9302 MP197 and MP197HB, Revision ~l These documents or files have been appropriately designated as proprietary.

I have personal knowledge of the criteria and procedures utilized by 1N Americas LLC in designating infonnation as a trade secret, privileged, or as confidential commercial or financial information.

Pursuant to the provisions of paragraph (b) ( 4) of Section 2.3 90 of the Commission' s 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 certain design details associated with the SAR analyses, calculations, and SAR drawings for the MP 197HB System, which are owned and have been held in confidence by 1N 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 analysis of a radioactive material transportation system, 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 1N Americas LLC, take marketing or other actions to improve their product' s position or impair the position of TN America LLC ' s product, and avoid developing similar data and analyses in support of their processes, methods or apparatus.

Further the deponent sayeth not.

Prakash Narayanan Chief Technical Officer, 1N Americas LLC 4"'

Subscribed and sworn before me this I~ day ofJanuary, 2023.

Notary Public My Commission Expires 1Q_;_5_1-2.5_ KHYNESYA TAYLOR Notary Public Howard County Maryland My Commission Expires Oct. 5, 2025 Page I of I