Letter Sequence Other |
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Initiation
- Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, ... further results|Request]]
- Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance
- Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, ... further results|Supplement]]
Administration
- Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance
- Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting
Results
- Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, ... further results|Approval]]
Other: L-18-006, ISFSI - Site-Specific License Renewal Application, Revision 0, July 2018, L-23-005, Independent Spent Fuel Storage Installation License Renewal Application, Revision 1 (Cac/Epid No. 001028/L-2022-RNW-0007), ML17311A450, ML17318A087, ML18022A077, ML18022A078, ML18022A079, ML18087A058, ML18087A059, ML18087A060, ML18087A061, ML18087A062, ML18100A188, ML18100A190, ML18100A191, ML18100A193, ML18101A024, ML18108A052, ML18131A047, ML18141A561, ML18141A562, ML18141A564, ML18141A567, ML18179A258, ML18179A260, ML18179A266, ML18201A455, ML18205A179, ML18222A351, ML18228A533, ML18234A012, ML18255A094, ML18255A098, ML18255A101, ML18255A102, ML18324A594, ML18347B336, ML18347B337, ML18351A173, ML18351A175, ML18351A176, ML18351A177, ML18351A178, ML18355A373, ML18355A379, ML18355A380, ML18355A382, ML18362A303, ML19028A402, ML19028A403... further results
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MONTHYEARML19255E7911997-05-31031 May 1997 Enclosure 1 - Ecological Assessment of the Low Level Waste Depository, Andrews County, Tx Project stage: Other ML19255E7952004-10-25025 October 2004 Enclosure 2 - Habitat Characterization and Rare Species Survey for the Proposed Low Level Waste Repository, Andrews County, Tx Project stage: Other ML19337B5182007-03-16016 March 2007 Enclosure 10 - Applicable Sections of LLRW License Project stage: Other ML19255E7982007-03-16016 March 2007 Enclosure 3 - Supplemental Survey to Ecological Assessment of the Low Level Waste Depository, Andrews County, Texas Project stage: Supplement ML19255E8002008-07-0303 July 2008 Enclosure 4 - Environmental Assessment Report Prepared for Application for Renewal of Radioactive Material License R04971 Waste Control Specialists LLC Andrews County, Texas Project stage: Request ML19217A2142008-07-28028 July 2008 Enclosure 4 - Report on Activities to Satisfy Byproduct RML Conditions 41A, 41C, and 43, July 2008 (Public) Project stage: Other ML19217A2132011-02-22022 February 2011 Enclosure 3 - Oag Water Levels: Empirical and Modeled Relationships Between Precipitation and Infiltration, 2011 (Public) Project stage: Other ML18100A1882013-04-11011 April 2013 Enclosure 7 - Procedure 12751-MNGP-QP-9.201, Revision 0, Visual Weld Examination Project stage: Other ML18100A1912014-01-30030 January 2014 Enclosure 9 - Structural Integrity Associates, Inc. Report 130415.402, Revision 0, Review of Trivis Inc. Welding Procedures Used for Field Welds on the Transnuclear NUHOMS 61BTH Type 1 & 2 Transportable Canister for BWR Fuel Project stage: Other ML18100A1902014-05-22022 May 2014 Enclosure 8 - Structural Integrity Associates, Inc. Report 130415.403, Revision 2, Assessment of Monticello Spent Fuel Canister Closure Plate Welds Based on Welding Video Records Project stage: Other ML17318A0872017-11-0909 November 2017 Intent to Pursue Subsequent License Renewal Project stage: Other BVY 17-041, Supplement to Exemption Request from Certain Requirements of 10 CFR 72.212 and 10 CFR 72.214 to Support the Dry Fuel Loading Campaign2017-12-0707 December 2017 Supplement to Exemption Request from Certain Requirements of 10 CFR 72.212 and 10 CFR 72.214 to Support the Dry Fuel Loading Campaign Project stage: Supplement ML18011A1582017-12-22022 December 2017 International HI-STORE Cis (Consolidated Interim Storage Facility) License Application Responses to Safeguards Related Requests for Supplemental Information Project stage: Supplement ML17249A1572018-01-11011 January 2018, 16 January 2018 Package: Vermont Yankee Nuclear Power Station ISFSI Environmental Assessment and Finding of No Significant Impact Related to Issuance of Exemption to Allow a New Loading Pattern and Loading Fuel Cooled for at Least 2 Years Project stage: Request ML18022A1542018-01-16016 January 2018 Enclosure 3: Handout-PG&E Presentation on Humboldt Bay ISFSI LRA (Memo to A. Hsia Summary of December 12, 2017, Meeting) Project stage: Meeting ML18022A1532018-01-16016 January 2018 Enclosure 2: Agenda (Memo to A. Hsia Summary of December 12, 2017, Meeting with Pacific Gas & Electric Company to Discuss the Upcoming Submittal of the Application for Renewal of the Humboldt Bay ISFSI License) Project stage: Meeting ML17249A1592018-01-16016 January 2018 Letter to C. C. Chappell Vermont Yankee Nuclear Power Station ISFSI Environmental Assessment and Finding of No Significant Impact Related to Issuance of Exemption to Allow a New Loading Pattern and Loading Fuel Cooled for at Least 2 Years Project stage: Approval ML18018B2972018-01-19019 January 2018 Federal Registered Notice: Correction of Certificate of Compliance No. 1004, Renewed Amendments No. 11, Revision 1 and No. 13, Revision 1 Project stage: Request ML18022A0782018-01-22022 January 2018 Enclosure 1: Revised Title for Figure 1-5 Corrected Technical Specifications for Certificate of Compliance No. 1004 Renewed Amendment No. 11, Revision 1 Enclosure 1 Project stage: Other ML18022A0792018-01-22022 January 2018 Enclosure 2: Revised Title for Figure 1-5 Corrected Technical Specifications for Certificate of Compliance No. 1004 Renewed Amendment No. 13, Revision 1 Project stage: Other ML18022A0772018-01-22022 January 2018 Letter to J. Bondre Correction to Tn Americas LLC Technical Specifications for Renewed Amendments No. 11, Revision 1 and No. 13, Revision 1 to Standardized NUHOMS Certificate of Compliance No. 1004 for Spent Fuel Storage Casks Project stage: Other ML18024A2732018-01-24024 January 2018 Letter to D. G. Stoddard U.S. NRC Approval of Virginia Electric and Power Company Request for Withholding Information from Public Disclosure for North Anna Power Station ISFSI (Cac/Epid Nos. 001028/L-2017-RNW-0010 and 000993/L-2017-LNE-0008 Project stage: Withholding Request Acceptance ML17311A4502018-01-31031 January 2018 ISFSI License Renewal Final Environmental Assessment Project stage: Other ML18031A4572018-01-31031 January 2018 Submittal Date for Response to NRCs Requests for Additional Information (Rais) for License Amendment Request 1032-4 to HI-STORM FW CoC No. 1032 (CAC No. 001028) Project stage: Request ML17298A1352018-02-0202 February 2018 Safety Evaluation Report (Letter to C. C. Chappell Vermont Yankee Nuclear Power Station Independent Spent Fuel Storage Installation, Issuance of Exemption (CAC No.: 001028, Docket Nos. 50-271, 72-59, and 72-1014; EPID L-2017-LLE-0005) Project stage: Approval ML17298A1332018-02-0202 February 2018 Package: Vermont Yankee Nuclear Power Station Independent Spent Fuel Storage Installation, Issuance of Exemption (CAC No.: 001028, Docket Nos. 50-271, 72-59, and 72-1014; EPID L-2017-LLE-0005) Project stage: Request ML17298A1342018-02-0202 February 2018 Letter to C. C. Chappell Vermont Yankee Nuclear Power Station Independent Spent Fuel Storage Installation, Issuance of Exemption (CAC No.: 001028, Docket Nos. 50-271, 72-59, and 72-1014; EPID L-2017-LLE-0005) Project stage: Approval ML18031A2222018-02-0606 February 2018 Letter to D. G. Stoddard Issuance of Renewed Materials License No. SNM-2507 for the North Anna Power Station Independent Spent Fuel Storage Installation (Cac/Epid Nos. 001028/L-2017-RNW-0010 and 000993/L-2017-LNE-0008) Project stage: Approval ML18031A2242018-02-0606 February 2018 Enclosure 1: Preamble-SNM-2507 License Renewal Order (Letter to D. G. Stoddard Issuance of Renewed Materials License No. SNM-2507 for the North Anna Power Station Independent Spent Fuel Storage Installation) Project stage: Approval ML18031A2282018-02-0606 February 2018 Enclosure 2: Safety Evaluation Report (Letter to D. G. Stoddard Issuance of Renewed Materials License No. SNM-2507 for the North Anna Power Station ISFSI) Project stage: Approval ML18031A2252018-02-0606 February 2018 Enclosurenewed License SNM-2507 (Letter to D. G. Stoddard Issuance of Renewed Materials License No. SNM-2507 for the North Anna Power Station Independent Spent Fuel Storage Installation) Project stage: Approval ML18031A2272018-02-0606 February 2018 Enclosurenewed License SNM-2507 Technical Specifications (Letter to D. G. Stoddard Issuance of Renewed Materials License No. SNM-2507 for the North Anna Power Station ISFSI) Project stage: Approval ML18031A2212018-02-0606 February 2018, 8 February 2018 Package: Issuance of Renewed Materials License No. SNM-2507 for the North Anna Power Station Independent Spent Fuel Storage Installation (Cac/Epid Nos. 001028/L-2017-RNW-0010 and 000993/L-2017-LNE-0008) Project stage: Request ML18031A2312018-02-0808 February 2018 Federal Register Notice - Notice of Issuance for License Renewal (Letter to D. G. Stoddard Issuance of Renewed Materials License No. SNM-2507 for the North Anna Power Station ISFSI) Project stage: Approval ML18058A0562018-02-23023 February 2018 Letter to J. Giddens Request for Additional Information Regarding Entergy Operations, Inc.S Decommissioning Funding Plan Update Project stage: RAI ML18058A6082018-02-23023 February 2018 HI-2177593, Rev 0, Holtec International & Eddy Lea Energy Alliance (Elea) Underground CISF - Financial Assurance & Project Life Cycle Cost Estimates Project stage: Request ML18058A0232018-02-23023 February 2018 Letter to G. Van Noordennen Request for Additional Information Regarding Zionsolutions, LLCs Decommissioning Funding Plan Update for Zion Independent Spent Fuel Storage Installation Project stage: RAI ML18057A2172018-02-23023 February 2018 Letter to A. Zaremba Request for Additional Information for Review of Duke Energys Decommissioning Funding Plan Update Project stage: RAI ML18058A0242018-02-23023 February 2018 Enclosurequest for Additional Information (Letter to G. Van Noordennen Request for Additional Information Regarding Zionsolutions, LLCs Decommissioning Funding Plan Update for Zion Independent Spent Fuel Storage Installation) Project stage: RAI ML18057A2182018-02-23023 February 2018 Enclosurequest for Additional Information (Letter to A. Zaremba Request for Additional Information for Review of Duke Energys Decommissioning Funding Plan Update) Project stage: RAI ML18057A2162018-02-23023 February 2018 Package: Request for Additional Information for Review of Duke Energy'S Decommissioning Funding Plan Update Project stage: Request ML18058A0572018-02-23023 February 2018 Enclosurequest for Additional Information (Letter to J. Giddens Request for Additional Information Regarding Entergy Operations, Inc.S Decommissioning Funding Plan Update) Project stage: RAI ML18058A6072018-02-23023 February 2018 HI-2177565, Rev 0, Holtec International & Eddy Lea Energy Alliance (Elea) Cis Facility - Decommissioning Cost Estimate and Funding Plan Project stage: Request ML18058A0532018-02-27027 February 2018 Letter: Request for Additional Information Regarding Florida Power and Light/Nextera Decommissioning Funding Plan Updates for St. Lucie, Units 1 and 2; Seabrook Station; Duane Arnold Energy Center; and Point Beach Units 1 and 2 ISFSI Project stage: RAI ML18058A0522018-02-27027 February 2018 Enclosurequest for Additional Information (Letter: RAI Regarding Florida Power and Light/Nextera Decommissioning Funding Plan Updates for St. Lucie, Units 1 & 2; Seabrook Station; Duane Arnold Energy Center; and Point Beach, Units 1 and 2) Project stage: RAI ML18058A0822018-02-27027 February 2018 Letter: RAI for Review of Southern Nuclear Operating Companys Decommissioning Funding Plan Updates for Joseph M. Farley, Unit 1 and 2; Edwin I. Hatch, Units 1 and 2; and Vogtle Electric Generating Plant, Units 1 and 2 ISFSI Project stage: RAI ML18058A0812018-02-27027 February 2018 Enclosurequest for Additional Information(Rai for Review of Southern Nuclear Operating Companys Decommissioning Funding Plan Updates for Joseph M. Farley,Unit 1 and 2;Edwin I. Hatch,Units 1 and 2; and Vogtle Electric Generating Plant, Units Project stage: RAI ML18060A0212018-02-28028 February 2018 Enclosurequest for Additional Information (Request for Additional Information Regarding Indiana Michigan Power Companys Decommissioning Funding Update for Donald C Cook Nuclear Plant Units 1 and 2 ISFSI) Project stage: RAI ML18060A1492018-02-28028 February 2018 Letter to T. J. Palmisano Request for Additional Information Regarding Southern California Edisons Decommissioning Funding Plan for San Onofre Nuclear Generating Station ISFSI Project stage: RAI ML18060A0262018-02-28028 February 2018 Letter to J. Shaw Request for Additional Information Regarding Nebraska Public Power Districts Decommissioning Funding Plan Update for Cooper Nuclear Station Independent Spent Fuel Storage Installation Project stage: RAI 2017-12-07
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Category:Legal-Affidavit
MONTHYEARML21341A4852021-11-22022 November 2021 Affidavits ML21105A7882021-04-12012 April 2021 Enclosure 1: Wsc Consolidated Interim Storage Facility - Affidavits ML21014A0632021-01-14014 January 2021 Interim Storage Partners, LLC - Submittal of Supplemental Information to Support NRCs Continued Review of the Safety Case for the WCS CISF, Docket 72-1050 Cac/Epid 001028/L-2017-NEW-0002 ML20261H4222020-09-0202 September 2020 WCS CISF - Affidavit ML20237F4702020-08-24024 August 2020 Interim Storage Partners, LLC, Submittal of Revision 3 of the License Application for the WCS CISF ML20188A3902020-07-0606 July 2020 Fasken Land and Minerals, Ltd.S and Permian Basin Land and Royalty Owners Motion to Reopen the Record ML20128J3062020-04-27027 April 2020 Attachment 12: Affidavit Pursuant to 10 CFR 2.390 to Withhold Information from Public Disclosure ML20104C0542020-04-13013 April 2020 Attachment 6: Holtec International - Affidavit ML20105A1732020-04-0606 April 2020 Interim Storage Partners, LLC - Affidavits ML20105A1352020-03-31031 March 2020 Enclosure 1 - Affidavits ML20104C0192020-03-30030 March 2020 International - Affidavit for Kimberly Manzione ML20076D6982020-03-0505 March 2020 Interim Storage Partners, LLC - Affidavit ML20071F1562020-03-0505 March 2020 Interim Storage Partners, LLC - Affidavit ML20052E1482020-02-13013 February 2020 Interim Storage Partners, LLC - Affidavit Pursuant to 10 CFR 2.390 ML20052E0502020-02-11011 February 2020 Affidavits Pursuant to 10 CFR 2.390 for Interim Storage Partners, LLC, & NAC International ML20028E8452020-01-17017 January 2020 Enclosure 1 - Affidavits ML19337B5042019-11-21021 November 2019 Enclosure 1 - Affidavit ML19252A1302019-08-30030 August 2019 Interim Storage Partners, Llc., Submission of Draft Responses for Several Rals and Associated Document Markups from First Request for Additional Information, Part 2 ML19211D0252019-07-26026 July 2019 Submission of ISP Draft Responses for Several RAIs and Associated Document Markups from First Request for Additional Information, Part 2, Docket 72-1050 Cac/Epid 001028/L-2017-NEW-0002 ML19190A1832019-06-19019 June 2019 Enclosure 1 - Affidavits ML19156A0392019-05-31031 May 2019 Enclosure 1: Affidavits Pursuant to 10 CFR 2.390 ML19095B5512019-04-0303 April 2019 Interim Storage Partners, LLC - Submittal of Draft Responses for Rals NP-15-x and P-15-x and Associated Document Markups for the April 16, 2019 Meeting ML19093A1282019-04-0101 April 2019 Interim Storage Partners - Submission of Draft Responses for RAIs NP-2.4-x, NP-2.6-x, and P-2.6-x and Associated Document Markups for the April 11, 2019 Meeting. with Enclosure 1: Affidavit 2021-04-12
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Text
Enclosure 1 to E-55362 Affidavits Pursuant to 10 CFR 2.390
- a. Interim Storage Partners
- b. NAC International
- c. TN Americas
Interim Storage Partners LLC State of Maryland County of Howard
)
)
)
SS.
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 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-55362 License Application Markup Pages (Section 1.6.4)
This document has 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.
I)
The information sought to be withheld from public disclosure involves information related to the ISP Business case for 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 Patiners 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 oflnterim Storage Partners LLC, because the information consists of descriptions of the financial basis for 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 business plan or project to better compete with Interim Storage Partners LLC, take marketing or other actions to improve their product's or project's position or impair the position of Interim Storage Partners LLC product or project, and avoid developing a similar approach in support of their business plan.
Further the deponent sayeth not. ~
Jeffery Isakson Chief Executive Officer/President, Interim Storage Pattners LLC re me this 14th day of January, 2020.
My Commission Expires J2.JJJg_jcJoJ,S RONDA JONES NOTARY PUBLIC MONTGOMERY COUNTY MARYLAND MY COMMISSION EXPIRES OCT. 16, 2023 Page I of I
I NAC INTERNATIONAL NACINTERNATIONAL AFFIDAVIT PURSUANT TO 10 CFR 2.390 George Carver (Affiant), Vice President, Engineering and Licensing, hereinafter referred to as NAC, at 3930 East Jones Bridge Road, Peachtree Comers, 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 support of the NRC review of SAR Revision 2 for Interim Storage Partners (ISP)
Centralized Interim Storage Facility (CISF) site-specific license application (NRC Docket No. 72-1050).
- to E-55362, RAI responses to P-9-1, P-9-2, and P-9-7
- 0 to E-55362, Input/output files for NAC Calculation 30039-2010 NAC is the owner of this information that is considered to be 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 CFR Part 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 of NAC, 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.
- e. Information that discloses patentable subject matter for which it may be desirable to obtain patent protection.
ED20200001 Page 1 of 3
ANAC INTERNATIONAL NACINTERNATIONAL AFFIDAVIT PURSUANT TO 10 CFR 2.390 (continued)
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.
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 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.
ED20200001 Page 2 of 3
ANAC INTERNATIONAL NACINTERNATIONAL AFFIDAVIT PURSUANT TO 10 CFR 2.390 (continued)
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 Norcross, Georgia, this rlR day of q:OJ),.Ll_~,
2020.
George Carver Vice President, Engineering and Licensing NAC International Subscribed and sworn before me this /i..J-M. day of Cja...JU.,,(D.Jt<:;t, 2020.
ED20200001 Page 3 of 3
TN Americas LLC State of Maryland County of Howard
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)
ss.
)
AFFIDAVIT PURSUANT TO 10 CFR 2.390 I, Prakash Narayanan, depose and say that I am the ChiefTechnical Officer of TN Americas LLC, duly authorized to execute this affidavit, and have reviewed or caused to have reviewed the information which 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 is contained in Enclosures 8 and 9 and is listed below:
- to E-55362, RAJ responses to P-9-6 and P-9-7
- ofE-55362 Safety Analysis Repo1t Markup Pages (Section D.7.3.1.5)
- to E-55362, Calculations WCS0l-0201, Revision 0, WCS0l -0202, Revision 1, WCS0l-0208, Revision 0, WCS0l-0209, Revision 0, and WCS0l-0212, Revision 0
- 0 to E-55362, Excel' spreadsheet suppo1ting TN Calculation WCS0 1-0502 Revision 0 These documents have been appropriately designated as proprietaiy.
I have personal knowledge of the criteria and procedures utilized by TN Americas 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 technical details of spent fuel storage system associated with the NUHOMS technology, which are owned and have been held in confidence by TN Americas LLC.
- 2) The information is of a type customarily held in confidence by TN Americas LLC, and not customarily disclosed to the public. TN Americas 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 TN Americas LLC, because the information consists of details of NUHOMS storage systems, 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 TN Americas LLC, take marketing or other actions to improve their product's position or impair the position of TN Americas LLC's product, and avoid developing similar data and analyses in suppo1t of their processes, methods or apparatus.
Further the deponent sayeth not.
Prakash Narayanan Chief Technical Officer, TN Americas LLC
. :i efore me this 14th day of January, 2020.
My Commission Expires
}l:> I_&/ P6:J...3 Page I of I RONDA JONES NOTARY PUBLIC MONTGOMERY COUNTY MARYLAND MY COMMISSION EXPIRES OCT. 16, 2023
-