ML24134A072

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E-62515 Oranos Transmittal Letter and Enclosure 2, Affidavit - Response to Requests for Additional Information for the Revalidation Review of the Model No. GP-01, Revision 2, Japanese Package
ML24134A072
Person / Time
Site: 07103098
Issue date: 07/25/2023
From: Shaw D
Orano TN Americas
To: Boyle R
Office of Nuclear Material Safety and Safeguards, US Dept of Transportation (DOT), Office of Hazardous Materials Safety
Shared Package
ML24134A071 List:
References
A33010, L-2023-DOT-0002, E-62515
Download: ML24134A072 (4)


Text

July 25, 2023 E-62515 Orano TN 7160 Riverwood Drive Suite 200 U.S. Department of Transportation Columbia, MD 21046 Attn: Mr. Richard W. Boyle USA Tel: 410-910-6900 Pipeline & Hazardous Materials Safety Administration Fax: 434-260-8480 Radioactive Materials Branch 1200 New Jersey Avenue, S.E.

East Building, PHH-20 Washington, DC 20590

Subject:

Additional Information for Review of the Application f or Revalidation of Competent Authority Certification J/2009/AF, GP-01

Reference:

[1] TN Americas LLC letter E-56661 dated April 30, 2 020,

Subject:

Application for Revalidation of Competent Authority Certificati on J/2009/AF-96, GP-01 (NRC ADAMS Accession No. ML23026A140)

[2] NRC Letter dated May 24, 2023,

Subject:

Request for Additi onal Information for Review of the Certificate of Compliance No. 309 8-Model No. GP-01(EPID L-2023-DOT-0002, NRC ADAMS Accession No. ML23118A008)

[3] Orano NPS letter COR-23-005391-000 (2.0), dated July 3, 202 3,

Subject:

GP validation of Japanese Certificate J/2009/AF

Dear Mr. Boyle:

TN Americas LLC, on behalf of Orano Nuclear Packages and Servic es (NPS),

applied in accordance with §173.473 for revalidation the Compet ent Authority of Japan, Certification for Approval of Package Design for Transpo rt of Radioactive Materials, Identification Mark: J/2009/AF-96 (Revision 1) [1]. The U.S. Nuclear Regulatory Commission (NRC) requested additional information to complete the review of the application [2].

Enclosure 1 is additional information provided by Orano NPS [3]. Enclosure 2 is a statement of proprietary information pursuant to 49 CFR 7.14, 4 9 CFR 105.30, and 10 CFR 2.390.for the additional information provided in Enclosu re 1.

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

E-62515 U.S. Department of Transportation Page 2 of 2

Should you have any questions or require additional information to support review of this application, please contact Peter Vescovi by telephone at 336-4 20-8325, or by e-mail at peter.vescovi@orano.group.

Sincerely,

Digitally signed by Don Shaw Don Shaw Date: 2023.07.25 10:11:23

-04'00'

Don Shaw Licensing Manager TN Americas LLC

cc: Brigitte Latour, Orano Nuclear Packages and Services Laurence Labbe, TN Americas LLC

Enclosures:

1. Orano NPS letter COR-23-005391-000 (Proprietary)
2. Statement of Proprietary Information

Enclosure 1 to E-62 515

Orano NPS letter COR-23 -005391 -000 (Proprietary)

Withheld Pursuant to 10 CFR 2.390 Enclosure 2 to E-62515

ORANO NPS STATEMENT OF PROPRIETARY INFORMATION PURSUANT TO 49 CFR 7.14, 49 CFR 105.30, AND 10 CFR 2.390

I, Jessica Boutteau, depose and say that I am the Director Transport Operations & Business of Orano Nuclear Packages and Services (NPS), duly authorized to execute this st atement of proprietary information and have reviewed or caused to have reviewed the information which is id entified as proprietary and referenced in the paragraph immediately below. TN A mericas LLC on behalf of Orano NPS, is submitting this statement of proprietary information in confor mance with the provisions of 4 9 CFR 7.14 and 49 CFR 105.30 of the U. S.

Department of Transportations (U.S. DOT) regulations, and with the provi sions of 10 CFR 2.390 of the Nu clear Regulatory Commission s (NRC) regulations. This information is exempt from public discl osure under the Freedom of Information Act, 5 U. S.C. 552, as amended, for withh olding this information.

The information for which proprietary treatment is sought is li sted below:

x Enclosure 1 - TNI Letter COR-23-005391-000 Version 2.0 (Proprie tary)

This document has been appropriately designated as proprietary.

Pursuant to the provisions of paragraph 7.14 of Part 7 and para graph (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 whet her the information sought to be withheld from public disclosure, included in the abo ve referenced document, s hould 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 i s owned and has been held in confidence by Orano NPS.
2) The information is of a type customarily held in confidence by Orano NPS and not customarily disclosed to the public. Orano NPS 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 subs tantial harm to the competitive positio n of Orano NPS because the information consists of descriptions of the des ign 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 Orano NPS, take marketing or other actions to improve their products position or impair the position of Orano NPS s product, and avoid developing similar data and analyses in support of their processes, methods, or apparatus.

Further the deponent sayeth not. BOUTTEAU Jessica

2023.07.25 10:57:16

______________________________ +02'00' Jessica Boutteau Director Transport Operations & Business Orano Nuclear Packages and Services Witnessedby DN : cn=LEFORT Arnaud, LEFORT email=arnaud.lefort@are va.com, c=FR Date : 2023.07.25

__________________________ Arnaud 11:07:02 +02'00'____

Arnaud Lefort DesignEngineer Orano Nuclear Packages and Services