ML18067A133
| ML18067A133 | |
| Person / Time | |
|---|---|
| Site: | 07109235 |
| Issue date: | 03/06/2018 |
| From: | Fowler W NAC International |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| ED20180025 | |
| Download: ML18067A133 (5) | |
Text
A NAC INTERNATIONAL Atlanta Corporate Headquarters 3930 East Jones Bridge Road, Suite 200 Norcross, GA 30092 Phone 770-447-1144 Fax 770-447-1797 March 6, 2018 www.nacintl.com U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 Attn:
Document Control Desk
Subject:
NAC's Request for a Revision to Certificate of Compliance (CoC) No. 9235 for the NAC-STC (Submittal 18A)
References:
Docket No. 71-9235
- 1. Model No. NAC-STC Package, U.S. Nuclear Regulatory Commission (NRC)
Certificate of Compliance (CoC) No. 9235, Revision 17, April 6, 2017
- 2.
Safety Analysis Report (SAR) for the NAC Storage Transport Cask (NAC-STC),
Revision 17, NAC International, April 2011
- 3. NUREG-1617, Standard Review Plan for Transportation Packages for Spent Nuclear Fuel, March 2000
- 4. NUREG/CR-3854, Fabrication Criteria for Shipping Containers, March 1985
- 5. ED20170024, Request for a Revision to Certificate of Compliance (CoC) No. 9235 for the NAC-STC Cask Gamma Scanning Requirements, March 16, 2017
- 6. NRC Letter, Application for the Model No. NAC-STC - First Request for Additional Information, June 16, 2017
- 7. ED20170026, Submission of Responses to the NRC Request for Additional Information for NAC's Request for a Revision to Certificate of Compliance (CoC)
No. 9235 for the NAC-STC (Submittal 17B), July 17, 2017
9235 for the NAC-STC (Submittal 17C), September 20, 2017
- 9. NRC Letter, Application for the Model No. NAC-STC-Request for Additional Information, February 8, 2018 NAC is hereby responding, in part, to the Request for Additional Information (RAI) issued on February 8, 2018 (reference 9). The remaining portions of the RAI will be responded to in a future submittal. This submittal contains the response to RAI question 8-6 and requests that the SAR alternate lead pour procedure be revised to include additional details. The following SAR sections have been revised in response to the RAI:
- 1. Revised SAR Section 8.4.3.2, Step 3 is revised to include the same heat up rate as described in the standarcl lead pour procedure. In addition, the phrase "approximately" has been deleted.
- 2. Revised SAR Section 8.4.3.2, Step 4 to include the same bottom end filler-tube location and description as described in the standard lead pour procedure.
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A NAC f INTERNATIONAL U.S. Nuclear Regulatory Commission March 6, 2018 Page 2 of2
- 3. Revised SAR Section 8.4.3.3, Steps 1 and 2 have been revised to include additional details for the cooldown process.
- 4. Deleted SAR Section 8.4.3.3, Step 3 and renumbered subsequent steps.
- 5. Deleted SAR Section 8.4.3.4, Step 3.
In addition to the items above, NAC is requesting that drawings for both the upper and lower impact limiters for the balsa and redwood designs be revised. The revisions, in part, would permit dimensions outsid.e of the specified tolerances for localized sections of the impact limiter as long as the net section of the impact limiters are not affected due to weld distortion. Also, the distance and tolerance for the lower impact limiter recess area has been revised.
This submittal package contains one hard copy of both the proprietary and non-proprietary versions, which includes the Revision STC-l 8A changed pages (Enclosure 6) to the Reference 2 SAR pages. contains a detailed list of drawing changes. Enclosure 3 contains calculation 30045-3000 which supports the RAI response and the additional requested changes. NAC is requesting the CoC list of drawings be revised to reference the current revision_ levels within this submittal (Enclosure 4). contains a brief summary of the changes to the SAR for Revision STC-18A. The proprietary version of this submittal is contained in a separate sealed envelope marked as "NAC Proprietary Information." An Affidavit pursuant to 10 CFR 2.390 is provided via Attachment 1 to this letter.
Consistent with NAC administrative practice, this proposed SAR revision is numbered to uniquely identify the applicable changed pages. Revision bars mark the SAR text changes on the Revision STC-18A pages. In accordance with NAC's administrative practices, upon final acceptance of this application, the STC-17 A, -17B, -l 7C and -l 8A changed pages will be reformatted and incorporated into the next revision of the NAC-STC SAR. If you have any comments or questions, please contact me on my direct line at 678-328-1236.
Sinc=ly,,r Wren Fowler Director, Licensing Engineering
Attachment:
-NAC International Affidavit Pursuant 10 CFR 2.390 - Partial RAI Responses, Revision 18A - List of Drawing Changes, NAC-STC SAR, Revision 18A - Supporting Calculation, Revision 18A - Proposed CoC Changes, Revision 18A - List of SAR Changes, NAC-STC SAR, Revision 18A - SAR Page Changes and LOEP, NAC-STC SAR, Revision 18A ED20180025 Page 2 of2
ANAC ffffllNTERNATIONAL NAC INTERNATIONAL AFFIDAVIT PURSUANT TO 10 CFR 2.390 George Carver (Affiant), Vice President, Engineering and Licensing, of NAC International, hereinafter referred to as NAC, at 3930 East Jones Bridge Road, Norcross, Georgia 30092, being duly sworn, deposes and says that:
- 1. Affiant has reviewed the information described in Item 2 and is personally familiar with the trade secrets and privileged information contained therein, and is authorized to request its withholding.
- 2. The information to be withheld includes the following NAC Proprietary Information that is being provided in this submittal.
- , NAC Supporting Calculation, 30045-3000 Rev. 0, NAC is the owner of the information contained in the aforementioned pages/document, so they are considered NAC Proprietary Information.
.3. NAC makes this application for withholding of proprietary information based upon the exemption from disclosure set forth in: the Freedom of Information Act ("FOIA"); 5 USC Sec. 552(b)(4) and the Trade Secrets Act; 18 USC Sec. 1905; and NRC Regulations 10 CFRPart 9.17(a)(4), 2.390(a)(4), and 2.390(b)(l) for "trade secrets and commercial financial information obtained from a person, and privileged or confidential" (Exemption 4). The information for which exemption from disclosure is herein sought is all "confidential commercial information," and some portions may also qualify under the narrower definition of "trade secret," within the meanings assigned to those terms for purposes of FOIA Exemption 4.
- 4. Examples of categories of information that fit into the definition of proprietary information are:
- a.
Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by competitors of NAC, without license from NAC, constitutes a competitive economic advantage over other companies.
- b. Information that, if used by a competitor, would reduce their expenditure of resources or improve their competitive position in the design, manufacture, shipment, installation, assurance of quality or licensing of a similar product.
- c. Information that reveals cost or price information, production capacities, budget levels or commercial strategies ofNAC, its customers, or its suppliers.
- d. Information that reveals aspects of past, present or future NAC customer-funded development plans and programs of potential commercial value to NAC.
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I NAC INTERNATIONAL NACINTERNATIONAL AFFIDAVIT PURSUANT TO 10 CFR 2.390 (continued)
- e. Information that discloses patentable subject matter for which it may be desirable to obtain patent protection.
The information that is sought to be withheld is considered to be proprietary for the reasons set forth in Items 4.a, 4.b, and 4.d.
- 5. The information to be withheld is being transmitted to the NRC in confidence.
- 6. The information sought to be withheld, including that compiled from many sources, is of a sort customarily held in confidence by NAC, and is, in fact, so held. This information has, to the best of my knowledge and belief, consistently been held in confidence by NAC. No public disclosure has been made, and it is not available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements, which provide for maintenance of the information in confidence. Its initial designation as proprietary information and the subsequent steps taken to prevent its unauthorized disclosure are as set forth in Items 7 and 8 following.
- 7. Initial approval of proprietary treatment of a document/information is made by the Vice President, Engineering, the Project Manager, the Licensing Engineer, or the Director, Licensing - the persons most likely to know the value and sensitivity of the information in relation to industry knowledge.
Access to proprietary documents within NAC is limited via "controlled distribution" to individuals on a "need to know" basis. The procedure for external release of NAC proprietary documents typically requires the approval of the Project Manager based on a review of the documents for technical content, competitive effect and accuracy of the proprietary designation. Disclosures of proprietary documents outside ofNAC are limited to regulatory agencies, customers and potential customers and their agents, suppliers, licensees and contractors with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.
- 8. NAC has invested a significant amount of time and money in the research, development, engineering and analytical costs to develop the information that is sought to be withheld as proprietary. This information is considered to be proprietary because it contains detailed descriptions of analytical approaches, methodologies, technical data and/or evaluation results not available elsewhere. The precise value of the expertise required to develop the proprietary information is difficult to quantify, but it is clearly substantial.
Public disclosure of the information to be withheld is likely to cause substantial harm to the competitive position ofNAC, as the owner of the information, and reduce or eliminate the availability of profit-making opportunities. The proprietary information is part of NAC's comprehensive spent fuel storage and transport technology base, and its commercial value extends beyond the original development cost to include the development of the expertise to determine and apply the appropriate evaluation process. The value of this proprietary information and the competitive advantage that it provides to NAC would be lost if the information were disclosed to the public. Making such information available to other parties, including competitors, without their having to make similar investments of time, labor and money would provide competitors with an unfair advantage and deprive NAC of the opportunity to seek an adequate return on its large investment.
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ANAC.
fffFIINTERNATIONAL NACINTERNATIONAL AFFIDAVIT PURSUANT TO 10 CFR 2.390 (continued)
STATE OF GEORGIA, COUN'(Y OF GWINNETT Mr. George Carver, being duly sworn, deposes and says:
That he has read the foregoing affidavit and the matters stated herein are true and correct to the best of his knowledge, information and belief.
Executed at Norcross, Georgia, this f.t?-1-(
day of YYxp.}lc.JL,, 2018.
George Carver Vice President, Engineering and Licensing NAC International Subscribed and sworn before me this (p +A_ day of yY\\,p.Jc.,c)_, 2018.
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