ML20137S982
| ML20137S982 | |
| Person / Time | |
|---|---|
| Site: | 07109197, 071***** |
| Issue date: | 08/09/1985 |
| From: | Temus C NUCLEAR PACKAGING, INC. |
| To: | Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20137S988 | List: |
| References | |
| 25625, 4399, 850809, NUDOCS 8509300563 | |
| Download: ML20137S982 (6) | |
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PD K /s c RETURN TO 396-Ss nuumn P/R K,/lGli a b m., w.,u.,n August 9, 1985 File:
680-2 & WO #IY Ref:
4399 gw Mr. Charles E. MacDonald, Chief Transportation Certification Branch f4 Division of Fuel Cycle and Material Safety T"
U. S. Nuclear Regulatory Commission 7915 Eastern Avenue y
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SUBJECT:
NuPac 10/140MB Safety Analysis Report submittal'
Dear Mr. MacDonald:
Nuclear Packaging, Inc., is pleased to submit a Safety Analysis Report in application for. the use of the NuPac 10/140MB cask.
This cask reflects a major step forward in the design of general Type B waste casks.
Included'in this design are several new features that add versatility and greater positive containment g*o the package.
Some of these featurec such as the EnviroSeals and the EnviroLockstm are new and unique to the NuPac 10/140MB package.
For many of the features of this package Nuclear Packaging is pursuing patent protection.
Enclosed are eight proprietary copics and two non-proprietary copies of the Safety Analysis Report for-the NuPac 10/140MB package.
If additional copies are required we will supply them upon request.
Also enclosed is our check for $150.00 for the required application fee.
Much of the information required by the NRC to determine the compliance of the design to applicable -regulations require the disclosure of trade secrets.and patent information; and therefore, our company's competitive position.
Enclosed please find our notarized Affidavit to withhold this proprietary information from public disclosure.. We request that the proprietary versions of the report be withheld f rom the Public Documents Room or any other form of public disclosure per the enclosed affidavit.
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un August 9, 1985 Charles E. MacDonald, Chief U. S. Nuclear Regulatory Commission Page 2 Both the proprietary and the non-proprietary versions of the SAR are protected under the copyright laws as unpublished material.
Photostatic copies of this copyrighted material may be made by NRC review personnel for convenience and for record purposes within the commission files; however, permission to copy the material is expressly denied to persons other than commission personnel for any other reason.
Copies of the non-proprietary material may not be released by the commission except to the Public Documents Room.
As this cask was developed as part of a contractual requirement your timely review would be greatly appreciated.
If you have any questions please do not hesitate to contact myself or Stephen Goetsch.
Sincerely, NUCLEAR PACKAGING, INC.
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Charles J. Temus Technical Director
Enclosures:
(8) Proprietary 10/140MB SAR (2) Non-Proprietary 10/140MB SAR NuPac Check #
Affidavit CJT/bjc
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AFFIDAVIT Submitted to Nuclear Regulatory Commission Concerning confidential information Contained in NuPac's Safety Analysis Report for the NuPac 10/140MB Shipping Cask State of Washington
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I, Richard T. Haelsig, being first sworn, dispose and says 1.
That I am President and a duly elected officer of Nuclear Packaging, Inc.,
1010 South 336th Street, Federal Way, Washington 98003; 2.
That I have been specifically delegated the function of reviewing proprietary information sought to be withheld from public disclosure and am authorized on behalf of the company to apply for its withholding; 3.
That the information sought to be withheld contains trade secrets or privileged or confidential commercial or financial information, the release of which would cause substantial harm to the competitive position of Nuclear Packaging, Inc.; and 4.
That the information sought to be withheld from public disclosure is specifically identified below:
Appendix 1.3.1, Drawings Figures 2.1.2-1, Foam Stress-Strain Properties Figures 2.1. 2 - 2,
Foam Stress-Strain Properties used for Analysis Appendix 2.10.3, Tiedown Lug Loads and Stress Analysis t
Appendix 2.10.4, EnviroLock m Structural Italysi-Appendix 2.10.6, Cask Wall Buckling Analysis Appendix 2.10.7, End Drop Lid Analysis Appendix 2.10.8, Lid Puncture Analysis Appendix 2.10.9, ANSYS Analysis Output Appendix 3.6, Thermal Analysis Modelling Notes Nuclear Packaging Inc.1010 South 33fAh Stmet FederM W.u Washngton 9M03 12fN ft74 2235 Teles 152ui7 PNSI UD
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All the information referenced above may be found in " Safety Analysis Report for the NuPac 10/140MB Shipping Cask".
Further, and in response to 10 CFR 2.790 (b) (4):
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The information has heretofore been held in confidence by Nuclear Packaging, Inc.;
(ii) the information is customarily held in confidence by Nuclear Packaging, Inc. since, to disclose such information would benefit NuPac's competitors in future packaging designs; (iii) the information has been transmitted to and, to the best of our knowledge, received by the NRC in confidence; (iv) the information is not now, nor is it intended in the future to be, in the public domain; should any of NuPac's competitors obtain said proprietary information, they would benefit commercially and to the detriment of Nuclear Packaging, Inc.
(v) public disclosure of the information is likely to cause substantial harm to the competitive position of NuPac, particularly in light of the extensive engineering and financed effort which NuPac has put forth, to witz (1) NuPac has been in the business of designing, licensing and fabricating Type B transportation packages for over 8 years and during this time has developed and refined analytical and design techniques that enable said packages to meet or exceed all applicable federal codes and regulations including 10 CFR 71, (2).
NuPac has expended in excess of $500,000 over the past several years to develop the information sought to be withheld.
Public disclosure of said information would put NuPac's competitive position in jeopardy, as it would cause NuPac to lose the design and performance advantages over.Its competitors which it currently of fers to its customers.
This would result in substantial loss of sales revenue which, in part, are necessary to
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'0i5 offset the large expenditures which NuPac klas invested, or caused to be invested, in the development of transporta, ion packaging designs based on and utilizing t p oprietary design.
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' Richard T. Haelsig /
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Nuclear Packaging, Inc.
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Subscribed and sworn to me this
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, Notary Public in and for the l
State of Washington, residing at E r. / h,v b /t b rz 1'
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