ML19084A054

Application for Amendment 1 to NUHOMS Eos Certificate of Compliance No. 1042, Revision 4 - Computer Files Associated with Certain CoC 1042 Amendment 1 Request for Additional Information Items (Docket No. 72-1042, CAC No. 001028, EPID: L-201

ML19084A054
Person / Time
Site:	07201042
Issue date:	03/21/2019
From:	Narayanan P Orano USA, TN Americas LLC
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
CAC 001028, E-53879, EPID L-2018-LLA-0043
Download: ML19084A054 (4)

Text

orano Columbia Office 7135 Minstrel Way Columbia, MD 21045 Tel: (410) 910-6900

@Orano_USA U. S. Nuclear Regulatory Commission Attn: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 March 21, 2019 E-53879

Subject:

Application for Amendment 1 to NUHOMS EOS Certificate of Compliance No. 1042, Revision 4 - Computer Files Associated with Certain CoC 1042 Amendment 1 Request for Additional Information Items (Docket No. 72-1042, CAC No. 001028, EPID: L-2018-LLA-0043)

References:

Letter from Prakash Narayanan (TN Americas LLC) to NRC Document Control Desk, "Application for Amendment 1 to NUHOMS EOS Certificate of Compliance No. 1042, Revision 3 - Response to Request for Additional Information (Docket No. 72-1042, CAC No.

001028, EPID: L-2018-LLA-0043)," dated February 19, 2019.

At the request of NRC, based on difficulty utilizing certain computer files associated with the request for additional information response referenced above, this submittal provides replacement computer files for NRC staff review. provides a listing of the computer files included herein. Enclosure 3 is a computer hard drive containing the computer files listed in Enclosure 2.

Certain portions of this submittal include proprietary information, which may not be used for any purpose other than to support the NRC staff's review of the application.

In accordance with 10 CFR 2.390, TN Americas LLC is providing an affidavit (Enclosure 1) specifically requesting that this proprietary information be withheld from public disclosure. Because Enclosure 3 is an entirely proprietary computer hard drive, no public version is provided.

TN Americas LLC is prepared to meet with the staff to resolve any additional questions the staff might have. Should the NRC staff require additional information to support review of this application, please contact Mr. Glenn Mathues by telephone at (410) 910-6538, or by email at Glenn.Mathues@orano.group.

Sincerely, u4-~

Prakash Narayanan Chief Technical Officer Enclosures transmitted herein contain SUNS!. When separated from enclosures, this transmittal document is decontrolled.

Document Control Desk March 21, 2019 cc:

Chris Jacobs (NRC SFM) as follows:

One paper copy of this cover letter and Enclosure 2 One computer hard drive with Enclosure 3

Enclosures:

1. Affidavit Pursuant to 10 CFR 2.390

2. Listing of Computer Files Contained in Enclosure 3 E-53879 Page 2 of 2

3. Computer files Associated with CoC 1042 Amendment 1, Revision 4 (Proprietary)

(One computer hard drive)

AFFIDAVIT PURSUANT TO 10 CFR 2.390 to E-53879 TN Americas LLC State of Maryland County of Howard

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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 Commission's regulations for withholding this information.

The information for which proprietary treatment is sought is contained in Enclosure 3, as listed below:

• - Certain computer files associated with CoC 1042 Amendment 1, Revision 4 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 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 design analysis computer files related to the design of the NUHOMS EOS 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 computer files associated with the design and analysis 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 product's position or impair the position of TN Americas LLC's product, and avoid developing similar data and analyses in support of their processes, methods or apparatus.

Further the deponent sayeth not. -A-hl~

Prakash Narayanan Chief Technical Officer, TN Americas LLC

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to E-53879 Listing of Computer Files Contained in Enclosure 3 Disk ID No.

Discipline System/Component Number (size)

File Series (topics) of Files One Updated NUHOMS Appendix A.4.5.7.1 (LC 1a-S-P in Table A.4-28)

Computer Folder: \\Thermal\\5-MATRIX-EOS-37PTH-LC1 a-Hard Drive MATRIX with EOS-S-Periodic-vs-SymmetricBC Thermal 37PTH DSC/ Normal Input and output files for the normal hot storage Total hot storage evaluation condition without wind, HLZC 7, and coarse mesh 15 (30.3 GB) with HLZC 7, coarse (ANSYS FLUENT Evaluation) mesh, without wind Subfolder LC1a-S-P: Load case with periodic Thermal boundary condition (30.3 GB)

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