Letter Sequence Other |
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EPID:L-2019-LLA-0231, Rulemaking Package: Certificate of Compliance No. 1032, Amendment 6, Model No. HI-STORM FW (Approved, Closed) |
Results
Other: ML20140A191, ML20182A863, ML20182A864, ML20182A865, ML20182A866, ML20182A870, ML20205L597, ML20315A017, ML20356A328, ML20356A330, ML20356A332, ML20356A336, ML21333A141, ML21333A142, ML21333A143, ML22145A407, ML22290A147, ML23041A466, ML23041A467, ML23041A468, ML23041A469
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MONTHYEARML20140A1912020-05-19019 May 2020 Application for the Model No. Hi-Storm FW: Storage System, Amendment No. 6 - Supplemental Information Needed Project stage: Other ML20182A8622020-06-30030 June 2020 Responses to HI-STORM FW Amd. 6 Requests for Supplemental Information Project stage: Supplement ML20182A8632020-06-30030 June 2020 Attachment 1: HI-STORM FW Amendment 6 Rsi Responses Project stage: Other ML20182A8642020-06-30030 June 2020 Attachment 2: HI-STORM FW Amendment 6 CoC - RSI-Related Changes Project stage: Other ML20182A8652020-06-30030 June 2020 Attachment 3 - HI-STORM FW Amendment 6 CoC, Appendix a - RSI-Related Changes Project stage: Other ML20182A8662020-06-30030 June 2020 Attachment 4: HI-STORM FW Amendment 6 CoC, Appendix B - RSI-Related Changes Project stage: Other ML20182A8702020-06-30030 June 2020 Attachment 8 - Affidavit Project stage: Other ML20205L5972020-08-10010 August 2020 Transmittal Letter: Application for the Model Hi-Storm FW Storage System, Amendment No. 6 - Accepted for Review Project stage: Other ML20267A1662020-09-24024 September 2020 Transmittal Letter and Rais: Application for the Model No. HI-STORM FW Storage System, Amendment No. 6 - Staggered First Request for Additional Information, Thermal Evaluation Project stage: RAI ML20315A0172020-10-31031 October 2020 Fuelsolutions Spent Fuel Management System Certificate of Compliance Renewal Application Project stage: Other ML20280A7412020-11-0606 November 2020 Transmittal Letter: Application for the Model No. Historm FW, Amendment 6 - Structural and Materials Evaluation, Final Staggered Request for Additional Information Project stage: RAI ML20280A7432020-11-0606 November 2020 Enclosure (Rais) to Transmittal Letter: Application for the Model No. Historm FW, Amendment 6 - Structural and Materials Evaluations, Final Staggered Request for Additional Information Project stage: RAI ML20356A3322020-12-21021 December 2020 Attachment 4 - Acceptance Tests and Maintenance Project stage: Other ML20356A3362020-12-21021 December 2020 Affidavit for Kimberly Manzione Project stage: Other ML20356A3302020-12-21021 December 2020 Attachment 2 - SFSC Heat Removal System Project stage: Other ML20356A3292020-12-21021 December 2020 Attachment 1 - Responses to Request for Additional Information Certificate of Compliance No. 1032 Docket No. 72-1032 HI-STORM FW Storage System Amendment No. 6 Project stage: Response to RAI ML20356A3282020-12-21021 December 2020 International Responses to HI-STORM FW Amd. 6 Requests for Additional Information Project stage: Other ML21146A0962021-07-0202 July 2021 Application for the Westinghouse Sentry Dry Storage Cask System, Certificate of Compliance No. 1026, Amendment No. 5 - Request for Additional Information Project stage: RAI ML21214A1322021-08-0202 August 2021 International, Supplemental Responses to HI-STORM FW Amendment 6 Requests for Additional Information Project stage: Supplement ML21333A1392021-11-29029 November 2021 Attachment 1 - HI-STORM FW Amendment 6 RAI Supplemental Responses Revised November 29, 2021 (Non-Proprietary) Project stage: Supplement ML21333A1382021-11-29029 November 2021 International Revised Supplemental Responses for HI-STORM FW Amd. 6 Requests for Additional Information Project stage: Supplement ML21333A1412021-11-29029 November 2021 Attachment 3 - HI-STORM FW FSAR Proposed Revision 7.D Revised November 29, 2021 (Non-Proprietary) Project stage: Other ML21333A1422021-11-29029 November 2021 Attachment 4 - HI-STORM FW Amendment 6 CoC, Appendix a - Revised November 29, 2021 (Non-Proprietary) Project stage: Other ML21333A1432021-11-29029 November 2021 Attachment 5 - Affidavit of Kimberly Manzione Project stage: Other ML22145A4072022-10-13013 October 2022 User Need Memorandum for Rulemaking for the Holtec HI-STORM Flood/Wind Multipurpose Canister Storage System, Amendment No. 6 Project stage: Other ML22145A3132022-10-13013 October 2022, 9 December 2022 Rulemaking Package: Certificate of Compliance No. 1032, Amendment 6, Model No. HI-STORM FW Project stage: Request ML22290A1472022-11-0808 November 2022 Approval of Holtec International Request Withholding Information from Public Disclosure of the Application for Holtec HI-STORM Flood/Wind Multipurpose Canister Storage System, Amendment No. 6 (Docket No. 72-1032) Project stage: Other ML22145A4082022-12-0909 December 2022 Rulemaking Memorandum, Enclosure 1: Draft Certificate of Compliance No. 1032, Amendment No. 6, HI-STORM Flood/Wind Multipurpose Canister Storage System Project stage: Draft Other ML22145A4092022-12-0909 December 2022 Rulemaking Memorandum, Enclosure 2: Draft Appendix a, Technical Specifications, Certificate of Compliance No. 1032, Amendment No. 6, HI-STORM Flood/Wind Multipurpose Canister Storage System Project stage: Draft Other ML22145A4102022-12-0909 December 2022 Rulemaking Memorandum, Enclosure 3: Draft Appendix B, Technical Specifications, Approved Contents and Design Features, CoC No.1032, Amendment No. 6, HI-STORM Flood/Wind Multipurpose Canister Storage System Project stage: Draft Other ML22145A4112022-12-0909 December 2022 Rulemaking Memorandum, Enclosure 4: Preliminary Safety Evaluation Report, Certificate of Compliance. No, 1032, Amendment No. 6, HI-STORM Flood/Wind Multipurpose Canister Storage System Project stage: Approval ML23041A4692023-02-15015 February 2023 Enclosure 3 - Final Appendix B, Technical Specifications, Approved Contents and Design Features, CoC No.1032, Amendment No. 6, HI-STORM Flood/Wind Multipurpose Canister Storage System Project stage: Other ML23041A4702023-02-15015 February 2023 Enclosure 4 - Final Safety Evaluation Report, Certificate of Compliance. No, 1032, Amendment No. 6, HI-STORM Flood/Wind Multipurpose Canister Storage System Project stage: Approval ML23041A4682023-02-15015 February 2023 Enclosure 2 - Final Appendix a, Technical Specifications, Certificate of Compliance No. 1032, Amendment No. 6, HI-STORM Flood/Wind Multipurpose Canister Storage System Project stage: Other ML23041A4672023-02-15015 February 2023 Enclosure 1 - Final Certificate of Compliance No. 1032, Amendment No. 6, HI-STORM Flood/Wind Multipurpose Canister Storage System Project stage: Other ML23041A4662023-02-15015 February 2023 Amendment No. 6 to Certificate of Compliance No. 1032 for the Holtec International Storage Module (Hi-Storm) Flood and Wind (FW) Multipurpose Canister (MPC) Storage System (Docket No. 72-1032, CAC No. 001028, EPID: L-2019-LLA-0231) Project stage: Other 2020-09-24
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Category:Legal-Affidavit
MONTHYEARML24100A0382024-04-0505 April 2024 Attachment 10: Affidavit ML24109A2632024-02-29029 February 2024 Attachment 13: Affidavit in Accordance with 10 CFR 2.390 ML24047A3292024-02-16016 February 2024 International, Affidavit ML24018A2022024-01-18018 January 2024 Attachment 3: Affidavit Pursuant to 10CFR2.390 ML23321A2542023-11-17017 November 2023 Attachment 8: Holtec International - Affidavit ML23227A2522023-08-15015 August 2023 Attachment 3: Affidavit in Accordance with 10CFR2.390 ML23192A0332023-07-10010 July 2023 International, Affidavit ML23181A2012023-06-30030 June 2023 Attachment 8 - Affidavit of Kimberly Manzione ML23170A0302023-06-19019 June 2023 International, Affidavit ML23128A3132023-05-0808 May 2023 Attachment 10: Affidavit in Accordance with 10CFR2.390 ML23006A2742023-01-0606 January 2023 Attachment 10: Affidavit of Kimberly Manzione Pursuant to 10 CFR 2.390 ML22276A2852022-10-0303 October 2022 International - Affidavit ML22258A2622022-09-15015 September 2022 International, Affidavit in Accordance with 10CFR2.390 ML22210A1532022-07-29029 July 2022 Attachment 7: Affidavit in Accordance with 10CFR2.390 ML22194A9572022-07-13013 July 2022 Attachment 3: Affidavit in Accordance with 10CFR2.390 ML22192A2252022-07-11011 July 2022 Attachment 9: Affidavit in Accordance with 10CFR2.390 ML21333A1432021-11-29029 November 2021 Attachment 5 - Affidavit of Kimberly Manzione ML21288A5422021-10-15015 October 2021 Attachment 19: Affidavit of Kimberly Manzione ML21302A1482021-09-29029 September 2021 Attachment 3: Affidavit Pursuant to 10CFR2.390 ML21214A1372021-08-0202 August 2021 Attachment 5: Holtec International, Affidavit ML21169A0412021-06-18018 June 2021 International - Affidavit for Kimberly Manzione ML21126A2972021-05-0606 May 2021 Attachment 29: Affidavit of Kimberly Manzione in Accordance with 10 CFR 2.390 ML21092A1672021-04-0202 April 2021 Attachment 5: Affidavit Pursuant to 10 CFR 2.390 to Withhold Information from Public Disclosure ML21007A0172021-01-0606 January 2021 Thermal Validation Test of HI-STORM FW MPC Storage System Pursuant to Certificate of Compliance No. 72-1032 Amendment 3 Condition 8 ML20356A3362020-12-21021 December 2020 Affidavit for Kimberly Manzione ML20280A7782020-10-0606 October 2020 International - Affidavit ML20225A2022020-08-10010 August 2020 Attachment 12: Holtec International - Affidavit ML20182A8702020-06-30030 June 2020 Attachment 8 - Affidavit ML20101N1762020-03-19019 March 2020 Attachment 4 Affidavit (Non-Proprietary) ML20003D8922020-01-0303 January 2020 International_Affidavit 2024-04-05
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U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Document ID 5018078 Non-Proprietary Attachment 8 AFFIDAVIT PURSUANT TO 10 CFR 2.390
, -...--imber-ly-Manz-iene,being-clu-l-y-s-w0m, clep0se-and--s-tate-as-fel-low-s-: ---------
(1)
I have reviewed the information described in paragraph (2) which is sought to be withheld, and am authorized to apply for its withholding.
(2)
The information sought to be withheld are Attachments 5 & 7 to Holtec Letter 5018078, which contain Holtec Proprietary information.
(3)
In making this application for withholding of proprietary information of which it is the owner, Holtec International relies 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 1 0CFR Part 9.17(a)( 4), 2.390(a)(4), and 2.390(b )(1) for "trade secrets and commercial or financial information obtained from a person and privileged or confidential" (Exemption 4). The material for which exemption from disclosure is here sought is all "confidential commercial information",
and some portions also qualify under the narrower definition of "trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Conunission, 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704F2d1280 (DC Cir. 1983).
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U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Document ID 5018078 Non-Proprietary Attachment 8 AFFIDAVIT PURSUANT TO 10 CFR 2.390 (4)
Some examples of categories of information which 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 Holtec's competitors without license from Holtec International constitutes a competitive economic advantage over other companies;
- b.
Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product.
- c.
Information which reveals cost or price information, production, capacities, budget levels, or commercial strategies of Holtec International, its customers, or its suppliers;
- d.
Information which reveals aspects of past, present, or future Holtec International customer-funded development plans and programs of potential commercial value to Holtec International;
- e.
Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.
The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs 4.a and 4.b above.
( 5)
The information sought to be withheld is being submitted to the NRC in confidence. The information (including that compiled from many sources) is of a sort customarily held in confidence by Holtec International, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by Holtec International. 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 2 of 5
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Document ID 5018078 Non-Proprietary Attachment 8 AFFIDAVIT PURSUANT TO 10 CFR 2.390
- - - - - -----f** 1egulat0ry=- f}Fe-visiens-e-F-----f)re13r-ie-tary-agr-eemeH-ts-w-h-ieh-prev-ide-f-e-*t-----
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 paragraphs ( 6) and (7) following.
( 6)
Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to such documents within Holtec International is limited on a "need to know" basis.
(7)
The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function ( or his designee ), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside Holtec International are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.
(8)
The information classified as proprietary was developed and compiled by Holtec International at a significant cost to Holtec International. This information is classified as proprietary because it contains detailed descriptions of analytical approaches and methodologies not available elsewhere. This information would provide other parties, including competitors, with information from Holtec International's technical database and the results of evaluations performed by Holtec International. A substantial effort has been expended by Holtec International to develop this information. Release of this information would improve a competitor's position because it would enable Holtec's competitor to copy our technology and offer it for sale in competition with our company, causing us financial lllJUry.
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U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Document ID 5018078 Non-Proprietary Attachment 8 AFFIDAVIT PURSUANT TO 10 CFR 2.390 (9)
Public disclosure of the information sought to be withheld is likely to cause substantial harm to Holtec International's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of Holtec International's comprehensive spent fuel storage technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology, and includes development of the expertise to determine and apply the appropriate evaluation process.
The research, development, engineering, and analytical costs comprise a substantial investment of time and money by Holtec International.
The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.
Holtec International's competitive advantage will be lost if its competitors are able to use the results of the Holtec International experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.
The value of this information to Holtec International would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive Holtec International of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing these very valuable analytical tools.
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U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Document ID 5018078 Non-Proprietary Attachment 8 AFFIDAVIT PURSUANT TO 10 CFR 2.390 STATE OF NEW JERSEY COUNTY OF CAMDEN
)
)
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ss:
Kimberly Manzione, being duly sworn, deposes and says:
That she has read the foregoing affidavit and the matters stated therein are true and correct to the best of her knowledge, information, and belief.
Executed at Camden, New Jersey, this 30th day of June, 2020.
Kimberly Manzione Licensing Manager Holtec International Erika Grandrimo NOTARY PUBLIC STATE OF ~E\\V JERSEY MY COMMISSION EXPIRES January 17, 2022 5 of 5