ML22046A030
| ML22046A030 | |
| Person / Time | |
|---|---|
| Site: | 07201052 |
| Issue date: | 02/07/2022 |
| From: | GNS Gesellschaft fur Nuklear-Service mbH |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| EPID L-2021-NEW-0006 | |
| Download: ML22046A030 (5) | |
Text
@ GNS GNS Gesellschaft fur Nuklear-Service mbH Postfach 10 12 53
- 45012 Essen Document Control Desk Our reference: T12 13-CO-00013 Director, Division of Fuel Management Contact pe rson: Dom inik Bussmann Office of Nuclear Material Safety and Safeguards Phone: +49 (0)201/ 109-1891 U.S. Nuclear Regulatory Commission Washington , DC 20555-0001 Fax: +49 (0)201/ 109-1186 USA Ema il: dom inik.bussmann@gns.de Date: 02/07//2022
Subject:
Application for 10 CFR 72 Approval for the CASTOR geo69 Spent Nuclear Fuel Dry Storage System (Docket No. 72-1052) -
Request for Technical Meeting
Reference:
Request for Supplemental Information dated October 18 2021 (EPID No. L-2021-NEW-0006)
With regard to above mentioned RSI, GNS is seeking for a Technical Meeting with the NRC staff.
Due to the ongoing COVID19 pandemic situation the meeting is supposed to be hold as virtual meeting via MS Teams and may be split up to several dates respecting the availability of the staff.
In order to support this request presentation slides with the relevant content to discuss are prepared by GNS and enclosed to this letter.
As propriety design information may be discussed, GNS respectively requests that relevant portions of the meeting and the proprietary version of the prepared presentation be closed to the public. A non-proprietary version of the slides together with an affidavit prepared pursuant to 10 CFR 2.390 providing the basis for withholding of the GNS proprietary information from public disclosure is enclosed to this letter.
For details on scheduling matters or in case of any questions related to this request, please do not hesitate to contact Mr. Dominik Bussmann at +49 201 109 1891, or by email at dominik.bussmann@gns.de.
Sincerely, GNS Gesellschaft fur Nuklear-Service mbH : Affidavit Pursuant to 10 CFR 2.390 : Presentation Slides, Proprietary Version : Presentation Slides, Non-Proprietary Version GNS Gesellschaft fi.ir Nuklear-Service mbH Frohnhauser Stral1e 67 Commerzbank AG, Essen USt-ldNr. DE 171892160, Steuer-Nr. 111 /5714/1234 DE -45127 Essen IBAN DE17 3604 0039 0124 3237 00, BIC COBADEFF Chairman of the Supervisory Board : Dr. Guido Knott Telephone +49 201 109-0 Bayerische Landesbank Dusseldorf Managing Directors :
Telefax +49 201109-1100 IBAN DE56 7005 0000 0004 3662 43, BIC BYLADEMM Georg Buth www.gns .de Deutsche Bank AG, Essen Daniel Oehr (Chairman)
HRBEssen 11213 IBAN DE 28 3607 0050 0151 7804 00, BIG DEUTDEDEXXX Dr.-lng . Jens Schroder to T1213-C0-00013 AFFIDAVIT PURSUANT TO 10 CFR 2.390 I, Dr.-lng . Sascha KLAPPERT , depose and say that I am Divisional Director of Engineering of GNS Gesellschaft fur Nuklear-Service mbH (a company duly organized under the German Law, having its seat at Frohnhauser Strasse 67 , 45127 Essen , Germany) , duly authorized to execute this affidavit.
I, Dr .-lng. Rainer NORI NG , depose and say that I am Divisional Director of Cask Projects of GNS Gesellschaft fur Nuklear-Service mbH (a company duly organized under the German Law, having its seat at Frohnhauser Strasse 67 , 45127 Essen , Germany) , duly authorized to execute this affidavit.
We , Dr. -lng. Sascha KLAPPERT and Dr.-lng . Rainer NORI NG , have reviewed or caused to have reviewed the information which is identified as confidential and referenced in the paragraph below.
We are submitting this affidavit in conformance with the provisions of 10 CFR 2.390 of the Comm ission's regulations for withholding th is information.
The information sought to be withheld from public disclosure is contained in Enclosure 2 of letter T1213-C0-00013 Presentation Slides , Technical Meeting , 10 CFR72 Application of CASTOR geo69 Dry Storage System , Proprietary Version The respective parts of the presentation slides has been appropriately designated as proprietary .
We have personal knowledge of the criteria and procedures utilized by GNS Gesellschaft fur Nuklear-Service mbH in designating information as a proprietary 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 certain design details associated with the SAR analyses and SAR drawings of the CASTOR geo69 dry storage system design , which are owned and have been held in confidence by GNS Gesellschaft fur Nuklear-Service mbH.
(2) The information is of a type customarily held in confidence by GNS Gesellschaft fur Nuklear-Service mbH and not customarily disclosed to the public. GNS Gesellschaft fur Nuklear-Service mbH has a rational basis for determining the types of information customarily held in confidence by it.
(3) The information is being transferred to the Commission in confidence under the provisions of 10 CFR 2.390 with the understanding that it is to be received in confidence by the Commission.
(4) The information , to the best of our knowledge and belief, is not available in public sources ,
and any disclosure to third parties has been made pursuant to regulatory provisions or confidentiality agreements which provide for maintenance of the information in confidence.
(5) Public disclosure of the information is likely to cause substantial harm to the competitive position of GNS Gesellschaft fur Nuklear-Service mbH because :
(a) A similar product is manufactured and sold by competitors of GNS Gesellschaft fur Nuklear-Service mbH_
(b) Development of this information by GNS Gesellschaft fur Nuklear-Service mbH required expenditure of considerable resources _To the best of our knowledge and belief, a competitor would have to undergo similar expense in generating equivalent information_
(c) In order to acquire such information , a competitor would also require considerable time and inconvenience related to the development of a design and analysis of a cask for the dry storage and transport of spent nuclear fuel.
(d) The information required significant effort and expense to obtain the licensing approvals necessary for application of the information _Avoidance of this expense would decrease a competitor's cost in applying the information and marketing of the product to which the information is applicable _
(e) The information consists of design features, analyses methods and calculation results related to the design and analyses of a dry storage system of spent nueclear fuel , the application of which provide a competitive economic advantage _The availability of such information to competitors would enable them to modify their product to unfairly get a better competitive position with GNS Gesellschaft fur Nuklear-Service mbH, take marketing or other actions to improve their product's position or impair the position of GNS Gesellschaft fur Nuklear-Service mbH's product, while avoiding the expense of developing similar data and analyses in support of their processes, methods or apparatus _
(f) In pricing GNS Gesellschaft fur Nuklear-Service mbH's products and services , significant research , development, engineering , analytical , licensing, quality assurance and other costs and expenses must be included _The ability of GNS Gesellschaft fur Nuklear-Service mbH's competitors to utilize such information without similar expenditure of resources may enable them to sell at prices reflecting significantly lower costs _
Date: /I"- M. 2ol.A
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Sascha KLA RT
- Divisio irector of ngineering - r of Cask Projects -
GNS Gesellscha Nuklear-Service mb Nuklear-Service mbH Notary Public (Un
Number 384 of Notary's Register of 2021 I herewith certify that the foregoing signatures are given by Dr.-lng. Sascha Klappert, born on 21.08.1972, of known identity, and Dr.-lng. Rainer Noring, born on 27.11.1968, of known identity, both with their business address at Frohnhauser Str. 67, 45127 Essen.
The signatures were given today in Frohnhauser Str. 67, 45127 Essen.
Obligatory Statement according to German law:
According to Sec. 3 Para. 1 S. 1 No. 7 German Notarisation Law the Notary Public asked the appearers whether he or any member of his firm had acted in the matter which is the subject of this instrument, except in a notarial capacity. The appearers replied in the negative.
Essen, November18, 2021 1197837
APOSTILLE (Convention de La Haye du 5 octobre 1961)
- 1. Country/ Land:
Federal Republic of Germany I Bundesrepublik Deutschland This public document/ Diese offentliche Urkunde
- 2. has been signed by/ ist unterschrieben von Notary Public Dr. Joachim Gores I Notar Dr. Joachim Gores
- 3. acting in the capacity of/ in seiner Eigenschaft als Notary Public in Essen / Notar in Essen
- 4. bears the seal I sie ist versehen mit dem Siegel of the Notary Public Dr. Joachim Gores in Essen / des Notars Dr. Joachim Gores in Essen Certified/Bestatigt
- 5. at I in E s s e n 6. the/ am
- 7. by/ durch the President of the Reg ional Court Essen /
die Prasidentin des Landgerichts Essen
- 8. No./ unter Nr. 91 E 1 /
- 9. Seal/ Stamp Siegel/ Stempel: 10. Signature/ Unterschrift:
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