ML19093A128
| ML19093A128 | |
| Person / Time | |
|---|---|
| Site: | Consolidated Interim Storage Facility |
| Issue date: | 04/01/2019 |
| From: | Boshoven J Consolidated Interim Storage Facility |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML19093A183 | List: |
| References | |
| E-53940 | |
| Download: ML19093A128 (4) | |
Text
INTERIM STORAGE PARTNERS April 1, 2019 E-53940 Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission
-,2--/050 Attn: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852
Subject:
Submission of ISP Draft Responses for RAls NP-2.4-x, NP-2.6-x, and P-2.6-x and Associated Document Markups for the April 11, 2019 Meeting
Reference:
- 1.
Letter from John-Chau Nguyen (NRG) to Jeffery D. 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 2
Letter from John-Chau Nguyen (NRG) to Jeffery D. Isakson, "Interim Storage Partners LLC's License Application to Construct and Operate the Waste Control Specialists Consolidated Interim Storage Facility, Andrews County, Texas, Docket 72-1050 - First Request for Additional Information, Part 2," dated March 6, 2019 Interim Storage Partners LLC hereby submits its draft RAI responses for the meeting scheduled for April 11, 2019 to discuss RAls NP-2.4-x, NP-2.6-x, and P-2.6-x.
RAl's NP-2.6-3, NP-2.6-4, NP-2.6-5, P-2.6-3, P-2.6-5 and P-2.6-6 are all related to settlement questions for the storage pads. While not all of these RAl's specifically address settlement in the question, the questions are related to investigation depth, material property selection, and analysis depth which all are inputs within the settlement calculations. As we discussed at our February 19th meeting, we are working with two suppliers to revise the settlement calculations to include the items outlined in the aforementioned RAl's. In addition, several RAls included in Reference 2 are also related to the storage pads and will most likely require updates to the same calculations to fully respond to the related RAls. Rather than make two updates to the storage pad calculations, ISP plans to respond to all of these related RAls at the same time.
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- interimstoragepartners.com
Document Control Desk E-53940 Page 2 of 2 Upon conclusion of the revised settlement analysis, the Report of Geotechnical Exploration will be revised to accommodate the changes as well as the settlement calculations provided in Chapter 7 of the SAR. These revised documents as well as the individual response to the RAl's for both Part 1 and Part 2 will be submitted at that time.. to this letter provides the draft responses to the Non-Proprietary RAls NP-2.4-x along with related SAR changes. Enclosure 3 provides the draft responses to the Non-Proprietary RAls NP-2.6-x, except RAls NP-2.6-3, NP-2.6-4 and NP-2.6-5 as discussed above. Enclosure 4 (Proprietary) provides responses to Proprietary RAls P-2.6-x, except RAls P-2.6-3, P-2,6-5 and P-2.6-6 as discussed above. An affidavit (Enclosure 1) is provided for the proprietary RAI responses. Finally, Enclosure 5 provides the updated drainage and floodplain analysis less the Appendices A through E which do not include any changes from the previous revision submitted with Revision 2 of the SAR. The drainage and floodplain analysis are Attachment B to Chapter 2 of the SAR.
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.
cc:
John-Chau Nguyen, Senior Project Manager, U.S. NRG Richard Turtil, U.S. NRG Jeff Isakson, ISP LLC Elicia Sanchez, ISP LLC Renee Murdock, ISP LLC
Enclosures:
- 1.
Affidavits Pursuant to 10 CFR 2.390
- a.
Interim Storage Partners
- 2.
Draft Response to RAI NP-2.4-x with SAR Markups
- 3.
Draft Respon_se to RAI NP-2.6-x with SAR Markups
- 4.
Draft Responses to RAI P-2.6-x (Proprietary)
- 5.
Attachment B to SAR Chapter 2 (Partial) associated with-Response to RAI NP-2.4-1
L' Affidavits Pursuant to 10 CFR 2.390
ISPLLC State of Maryland County of Howard
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AFFIDAVIT PURSUANT TO 10 CFR 2.390 I, Jeffery Isakson, depose and say that I am Chief Executive Officer/President, Interim Storage Partners 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 applies to the following documents listed below:
- of E-53940 Responses to Proprietary RAis P-2.6-x These documents have been appropriately designated as proprietary.
I have personal knowledge of the criteria and procedures utilized by Interim Storage Partners 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 information related to the design of the WCS CISF, which are owned and have been held in confidence by Interim Storage Partners LLC.
- 2) The information is of a type customarily held in confidence by Interim Storage Partners LLC, and not customarily disclosed to the public. Interim Storage Partners 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 Interim Storage Partners LLC, because the information 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 information 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 product, and avoid developing similar data and analyses in support of their processes, methods or apparatus.
Further the deponent sayeth not. ~
Jeffery Isakson Chief Executive Officer/President, Interim Storage Partners LLC Subscribed and sworn before me this 11th. day of March, 2019.
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Notary Public My Commission Expires _!j__j;).. 7 / :i./
LESLIE LEFORS Notary Pu~lic*Maryll!nd.
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