ML19357A176

NAC International - Submission of a Request to Renew the U.S. Nuclear Regulatory Commission Certificate of Compliance No. 1025 for the NAC-MPC Cask System

ML19357A176
Person / Time
Site:	07201025
Issue date:	12/18/2019
From:	Fowler W NAC International
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
Shared Package
ML19357A178	List: ML19357A175 ML19357A176
References
Download: ML19357A176 (7)

Text

R NAC rr""INTERNATIQNA~

December 18, 2019 U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 Attn: Document Control Desk Atlanta Corporate Headquarters 3930 East Jones Bridge Road, Suite 200 Norcross, GA 30092 Phone 770-447-1144 www.nacintl.com

Subject:

Submission of a Request to Renew the U.S. Nuclear Regulatory Commission Certificate of Compliance No. 1025 for the NAC-MPC Cask System Docket No. 72-1025 Pursuant to 10 CFR 72.240(b) and ( c ), NAC International hereby submits an application for renewal of the NAC-MPC System Certificate of Compliance (CoC). The current CoC expires on April 10, 2020. The application for the renewal of the CoC is contained in Enclosure 1 and was prepared in accordance with applicable provisions of 10 CPR Part 72, Subpart L. NAC is requesting a CoC renewal period of 40 years.

Consistent with NAC administrative practice, this proposed PSAR revision is numbered to uniquely identify the applicable changed pages. Enclosure 4 contains a summary of the changes to the SAR revision. Revision bars mark the PSAR text changes on the Revision NAC-MPC 19A pages (Enclosure 4). Enclosure 4 also contains a newly added Chapter 14 which does not contain revision bars throughout the chapter. The headers do however indicate Revision 19A and the submittal month and year in the new chapter. The proposed changes to the CoC are contained in. contains proprietary NAC calculations used to support the CoC renewal. Enclosure 6 contains a CoC renewal pre-application inspection report. Per Attachment 1 to this letter, NAC requests information in Enclosure 3 and 6 to be withheld from public disclosure per 10 CPR 2.390.

In Enclosure 7 NAC performed a design basis document review as part of the CoC renewal to identify and document any existing Time Limited Aging Analysis (TLAAs) in the original design.

ED20190141

A NAC

._ INT~RNATIQNA~

U.S. Nuclear Regulatory Commission December 18, 2019 Page 2 of 2 In accordance with NAC's administrative practices, upon final acceptance of this application, the 19A changed pages will be reformatted and incorporated into the next revision of the NAC-MPC FSAR.

If you have any comments or questions, please contact me on my direct line at 678-328-1236.

Wren Fowler Director, Licensing Engineering

Attachment:

- NAC International Affidavit Pursuant to 10 CFR 2.390

Enclosures:

1. Application for Renewal of the NAC-MPC System CoC

2. Appendix A Aging Management Programs

3. Appendix B Time-Limited Aging Analyses

4. Appendix C FSAR Changed Pages and LOEP for, NAC-MPC FSAR, 19A

5. Appendix D Proposed Changes for the NAC-MPC Certificate of Compliance (CoC) and Technical Specification (TS)

6. Appendix E Pre-Application Inspection Report

7. Appendix F Design Basis Document Review Report ED20190141

NAC INTERNATIONAL AFFIDAVIT PURSUANT TO 10 CFR 2.390 George Carver (Affiant), Vice President, Engineering and Licensing, of NAG International, hereinafter referred to as NAG, 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 NAG Proprietary Information that is being provided to support the technical review of NAC's Request to Renew the Certificate of Compliance (CoC) (No. 1025) for the NAG International MPG Cask System.

• , Appendix B, 30013-2001, Fatigue Evaluation of MPC and UMS Storage System Components for Extended Storage, Rev. 0

• , Appendix B, 30013-2003, Corrosion Analysis of MPC VCC Steel Components for Extended Storage, Rev. 0

• , Appendix B, 30013-5001, Aging Analysis for MPC/UMS Neutron Absorber and Neutron Shield Components (Storage/Transfer), Rev. 0

• , Appendix E, 30013-R-01, Maine Yankee NAC-UMS System Pre-Application Inspection Report, Rev. 0

3. NAG 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 NRG Regulations 10 CFR Part 9.17(a)(4), 2.390(a)(4), and 2.390(b)(1) 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 NAG, without license from NAG, 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 of NAG, its customers, or its suppliers.

d. Information that reveals aspects of past, present or future NAG customer-funded development plans and programs of potential commercial value to NAG.

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NAC INTERNATIONAL AFFIDAVIT PURSUANT TO 10 CFR 2.390

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 Specialist, 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 of NAC 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.

9. Public disclosure of the information to be withheld is likely to cause substantial harm to the competitive position of NAC, 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 ED20190141 Page2 of 4

NAC INTERNATIONAL AFFIDAVIT PURSUANT TO 1 O CFR 2.390 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 ED2019014I Page3 of 4

NAC INTERNATIONAL AFFIDAVIT PURSUANT TO 1 O CFR 2.390 STATE OF GEORGIA, COUNTY 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 Norcro s, Georgia, this I g& day of l fu ~

2019.

7 George Carver Vice President, Engineering and Licensing NAC International Subscribed and sworn before me this J 8-/:!i day of JJ.-&'~ v::::::

, 2019.

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ENCLOSURE 1 APPLICATION FOR RENEWAL OF THE NAC-MPC SYSTEM Coe STATE OF GEORGIA, COUNTY OF GWINNETT I, George Carver (Affiant), Vice President, Engineering and Licensing, of NAC International being duly sworn, state that I am duly authorized to execute and file this response on behalf of NAC. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other NAC employees and/or consultants. Such information has been reviewed i accordance with company practice and I believe it to be reliable.

George Carver Vice President, Engineering and Licensing NAC International Subscribed and sworn before me this / % fb day of J. o...ge ~

kc, 2019.

I Notary Public ED20190141