ML19283B556

Submission of Interim Storage Partners LLC Draft Responses for Several RAIs and Associated Document Markups from First Request for Additional Information, Part 3

ML19283B556
Person / Time
Site:	Consolidated Interim Storage Facility
Issue date:	10/08/2019
From:	Isakson J Consolidated Interim Storage Facility
To:	Document Control Desk, Division of Spent Fuel Management
References
CAC 001028, E-55033, EPID L-2017-NEW-0002
Download: ML19283B556 (4)

Text

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I ltt INTERIM STORAGE PARTNERS October 8, 2019 E-55033 Director, Division ofSpent 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 Several RAls and As.sociated Document Markups from First Request For Additional Information, Part 3, Docket 72-1050 CAC/EPID 001028/L-2017-NEW-0002

Reference:

1.

Letter from John-Chau Nguyen (NRC) to Jeffery 0. Isakson, "Interim Storage Partners LLC's Llc.ense Application to Construct and Operate the Waste Control Specialists Cons.olidated lriterim Storage Facility, Andrews County, Texas, Docket No. 72-1050 -

First Request For Additional Information, Part 3," dated April 23, 2019

2.

Letter from Jack Boshoven to John-Chau Nguyen (NRC), "Interim Storage Partners (ISP) First Request for Additional Information (RAI) Proposed Submittal Schedule, Docket 72-1050 CAC/EPID 001028/L-2017-NEW-0002," E-54395, dated May 31; 2019 Interim Storage Partners LLC (ISP) hereby submits its draft responses to RAls from Reference [1] ih preparation for meetings to be scheduled with NRC staff for discussion.

The draft responses and associated application changed pages being submitted are the remaining portion of those identified in Table 4 of Reference [2] associated with the Environmental Report (ER); the rest were submitted earlier in accordance with the timeline in the table. Enclosure 2 (proprietary) contains the draft responses to the RAls and associated marked up pages for the ER. Enclosure 3 (public) is the non-proprietary version of Enclosure 2.

Certain portions of this submittai 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 1 O CFR 2.390, ISP is providing an affidavit (Enclosure 1), specifically requesting that this proprietary information be withheld from public disclosure.

P.O, Box 1129

• Andrews, Texas 79714

• interimstorc!gepartners.co(!I

Document Control Desk E-55033 Page 2 of 2 The following RAls are the subject of this submittal. Please note that the ER markups included in Enclosures 2 and 3 also may contain markups supporting other RAls addres.sed in an earlier submittal.

RAls SOC-1, Cl-1 Cl-2, CB-1, CB-2, CB-3, and CB-4, associated with a revised Cost Benefit Analysis performed in support of the WCS CISF project Should you have any questions regarding this submission, please contact me by telephone at (410) 910-6897, or by email at christopher.olsen@orano.group.

Sincerely, Jeffery Isakson Chief Executive Officer lnteri.m Storage Partners LLC cc:

John-Chau Nguyen, Senior Project Manager, U.S. NRG Elicia Sanchez, ISP LLC

Enclosures:

1.

Affidavits Pursuant to 10 CFR 2.390

a.

Interim Storage Partners

2.

Draft RAI Responses with.associated application changed pages (Proprietary)

3.

Draft RAI Responses with associated application changed pages (Public)

• to E-55033 Affidavits Pursuant to 10 CFR 2.390

a.

Interim Storage Partners

AFFIDAVIT PURSUANT TO iOCFR2.390 erim Storage Partners LLC te ofMaryland

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)

)

ss.

County of Howard I, Jeffery Isakson, depose and say that I am Chief ExecutiW Officer/President, Interiin Storage Pa1tners LLC duly authorized to execute this affidavit, and have reviewed or caused to have reviewed the infonnation that is identifJed as proptietary and referenced in the paragraph immediately below. I am submitting this affidavit in conformance witb 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:

• of E-'55033 RAI CB-1 (In pmt)

• ofE-55033 RAI CI3'-2 (ih patt)

• of E-55033 RAI CB-3 (in part)

Endosure2 ofE-55033 Envfronmental Report Markup Pages Section 7.. 2..1 (in part)

• of E-55033 Environmental Repmt Markup Pages Table 7.2..,5 (in pmt)

Th~se doclimt;Jhts have been appt'optiately designated as proprietary.

I have personal knowledge of the criteria and procedures utilized by Ititeriin Storage Partners LLC in designating information as_ a trade s~ci;¢t, privileged or as confidential commercial or financial information.

Pursuant to the provisions of paragraph (b) (4) ofSection 2.390 of the Commission's regulatiol)s, the following is furnished for consideration by the Commission in determining whether the infonnation sought to pe withheld frprn public disclosure, inch)ded in the above i"eferenced document, should_ be withheld.

I) The information sought to be withheld from public disclosure involves trade secrets and commercial or financia] inforination obtained from a person relating to the WCS CISF, which are owned and have b~en held in confidence by lQterim Storage Partners LLC,

2) The information is of a type customadly held in confidence by Interim Stc,rage Partners LLC, and not custO(ilarily disclosed to the public. Interim Storage Partners LLC has a rational basis for detenriining t11e types of information cµstomadly held in confidence by it.

3) Public disclosure of the information is likely to cause substantial harm to the competitive position oflnterii.n Storage Partners LLC, because the information consists of trade secrets and commercial or financial information obtained from a person relating to the WCS CISF, application of which would provide a competitive economic advantage. The availability of such information to competitors would enable them to* modify their product or project to bettei' compete with Intedm Storage Partners LLC, take marketing or other actions to improve their product's or project's position or itnpair the position of Interim Storage Partners LLC product or project, and avoid developing similar data in support of their processes, methods or apparatus.

Further the deponent sayeth not. ~----_---

Jeffery Isakson ChiefExecµtive Officer/President, Intt:ldm Storage f>artners LLC Subscribed and sworn.b_ ore me this 7'1' day of October, 2019. _

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Notary'Public -

.Commission Expires / CJ;..11..e.J _j_:J_

RONDA JONES NOTARY PUBLIC'STATE OF MARYLAND

-My Ccmm!sslon Expires October 10. 2010 Page I of I