ML19073A251
| ML19073A251 | |
| Person / Time | |
|---|---|
| Site: | Consolidated Interim Storage Facility |
| Issue date: | 03/12/2019 |
| From: | Boshoven J Consolidated Interim Storage Facility |
| To: | Document Control Desk, Division of Spent Fuel Management |
| Shared Package | |
| ML19073A272 | List: |
| References | |
| E-53819 | |
| Download: ML19073A251 (5) | |
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INTERIM STORAGE PARTNERS March 12, 2019 E-53819 Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Attn: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852
Subject:
Submission of ISP Draft Responses for RAls NP-2.2-1, NP-2.2-2 and EP-X and Associated Document Markups for March 20, 2019 Meeting
Reference:
- 1.
Letter from John-Chau Nguyen (NRC) to Jeffery p. Isakson, "Interim Storage Partners' License Application to Construct and Operate the Waste Control Specialists Consolidated Interim Storage Facility, Andrews County, Tx, Docket 72-1050 - First Request for Additional Information, Part 1," dated November 16, 2018 Interim Storage Partners LLC hereby submits its draft RAI respon!5es for the meeting scheduled for March 20, 2019. to discuss RAls NP-2.2-1 and NP-2.2-2 and all of the RAls related to the Consolidated Emergency Response Plan.
The proprietary RAI responses are provided in Enclosures 2 through 4. The draft Consolidated Emergency Response Plan incorporating the changes described in the RAI responses is provided in Enclosure 5. Enclosure 6 includes the proprietary report which forms the basis for the response to RAI NP-2.2-1 and the proprietary calculation that supports the response to RAP NP-2.2-2. Affidavits (Enclosure 1) are provided for the proprietary information. Enclosure 7 provides the non-proprietary versions of the all of the RAI responses. The Enclosure 6 documents are entirely proprietary and no non-proprietary versions are included.
Should you have any questions regarding this submission, please contact me by telephone at (410) 910-6955, or by email at jack.boshoven@orano.group.
P.O. Box 1129
- Andrews, Texas 79714
- interimstoragepartners.com
Document Control Desk Sincerely, ack Boshoven Chief Engineer CISF, Licensing and Engineering Interim Storage Partners LLC cc:
John-Chau Nguyen, Senior Project Manager, U.S. NRC Richard Turtil, U.S. NRC Jeff Isakson, ISP LLC Elicia Sanchez, ISP LLC Renee Murdock, ISP LLC
Enclosures:
- 1.
Affidavits Pursuant to 10 CFR 2.390
- a.
Waste Control Specialists
- b.
Interim Storage Partners E-53819 Page 2 of 2
- 2.
Draft Response to RAI NP-2.2-1 with SAR Markups (Proprietary Version)
- 3.
Draft Response to RAI NP-2.2-2 with SAR Markups (Proprietary Version)
- 4.
Draft Responses to RAI EP-X (Proprietary Version)
- 5.
Draft Consolidated Emergency Plan Revision 2.08.2019
- 6.
Calculations (Proprietary)
- a.
Aircraft Hazard Evaluation Report Revision 0
- b.
WCS01-0211 Revision 0
- 7.
Draft RAI Responses to RAls NP-2.2-1, NP-2.2-2 and EP-X (Non-Proprietary Version)
Affidavits Pursuant to 10 CFR 2.390
WASTE CONTROL SPECIALISTS LLC AFFIDAVIT I, Elicia Sanchez, Senior Vice President of Key Initiatives and Communication at Waste Control Specialists LLC (WCS), am making the following representations that to the best of my knowledge and beliefs:
- 1.
The following document which WCS wishes to have withheld from public disclosure is:
a) Emergency Information List which is part of the RAJ EP-8 response.
b) Marked SAR sections associated with RAis NP-2.2-1 and NP-2.2-2 responses.
- 2.
The information contained in the document cited in 1 above is considered confidential information pursuant to Title 10 of the Code of Federal Regulations (CFR), Part 2.390(a)(4) and is thereby protected from public disclosure by regulation.
- 3.
Pursuant to 10 CFR 2.390, the information contained in the document cited in 1 above is protected from public disclosure by regulation because it includes correspondences and reports to the NRC which contain trade secrets or commercial information pursuant to 10 CFR 2.390(a)(4).
- 4.
The information contained in the document cited in 1 above has not been made available to public sources by wcs, nor has wcs authoriz' ed ~at ~.*t b~ r5available.
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Elicia Sanchez
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- Date Senior VP of Key Initiatives and Communication I certify the above named person appeared before me and e
- ~ed this document on this the ___!__L day of March, 2019 My commission expires:
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AFFIDAVIT PURSUANT TO 10 CFR 2.390 A161\\/nf ~
E.e.y I, Jeffery Isakson, de~ose and say that I am Chief Executive Officer/President; Interim Storage Pi;irtners LLC duly authodzed 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 IO CFR 2.390 of the Commission's regulations for withholding this information.
The information for which proprietary treatment is sought applies to the following documents listed below:
o Calculation WCSOI-0211, Hazard Analysis of Gas Pipeline for WCS CISF, Revision 0 (l
Calculation IBA TSDOO 1-CALC-O 1, Airci*aft Hazard Evaluation Of The Consolidated Interim Storage Facility (CISF), Revision 0 These documents have been appropriately designated as proprieta1y.
I have personal knowledge of the criteria and procedures utilized by Interim Storage Pa1tners 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 calculations related to the design of the WCS CISF, which are owned and have been held in confidence by Interim Storage Paitners LLC.
- 2) The information is of a type customarily held. iii confidence by Intet'im Storage Parh)ers LLC, and not customarily disclosed to the public. Interim Storage Partners LLC has a rational basis for determining the types of information custom~ily held in confidence by it.
- 3) Public disclosure of the information is likely to cause substantial harm to the competitive position of Interim Storage Partners
- LLC, because the inf01mation consists of descriptions of the design and analysis of the WCS CISF, the application of which provide a competitive economic advantage. The availability of such infonnation to competitors would enable them to modify their product to better compete with Interim Storage Partners LLC, take marketing or other actions to improve their product's position or impair the position of Interim Storage Partners LLC produ~t, an.d avoid developing similai; data and analyses in support of their processes, methods or apparatus.
Futiher the deponent sayeth not.
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Chief Executive Officer/President, Interim Storage Partners LLC Subscribed and sworn before 1 is 111h day of March, 2019.
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Notary Public My Commission E~pirestJ.!J/.Z~. :k>1 LBl\\liS A. PICCOLINO NOTARY PUBLIC.
MONTGOMERY COUNTY MARYLAND MY COMMISSION EXPIRES MARCH 26, 2022 Pagel ofl