Letter Sequence Other |
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EPID:L-2022-LLA-0030, International, Submittal of License Amendment Request 9375-1 for the HI-STAR Atb 1T Non-Fuel Waste Transport System (Approved, Closed) |
Initiation
- Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request
- Acceptance, Acceptance
- Supplement, Supplement, Supplement, Supplement
Results
Other: ML22287A139, ML22287A141, ML22287A143, ML22287A146, ML22334A262, ML22334A263, ML22335A499, ML22335A501, ML22343A261, ML23068A377, ML23129A797, ML23206A199, ULNRC-06783, Enclosure 2: Affidavit for Withholding, ULNRC-06808, Affidavit
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MONTHYEARML22050A0012022-02-18018 February 2022 International, Submittal of License Amendment Request 9375-1 for the HI-STAR Atb 1T Non-Fuel Waste Transport System Project stage: Request ML22130A7052022-05-10010 May 2022 International - Resubmittal of License Amendment Request 9375-1 for the HI-STAR Atb 1T Non-Fuel Waste Transport System Project stage: Request ML22161A0582022-06-0909 June 2022 International, Modification of License Amendment Request 9375-1 for the HI-STAR Atb 1T Non-Fuel Waste Transport System Project stage: Request ML22161A0592022-06-0909 June 2022 International, Modification of License Amendment Request 9375-1 for the HI-STAR Atb 1T Non-Fuel Waste Transport System Project stage: Request ML22235A1152022-08-25025 August 2022 Enc - 9375 RAI 2022 Project stage: RAI ML22235A1132022-08-25025 August 2022 RAIs for the Model No. HI-STAR Atb 1T Package Project stage: Request ML22235A1142022-08-25025 August 2022 Letter - Request for Additional Information for the Review of the Atb 1T Package - 2022 Project stage: RAI ML22285A1152022-10-0707 October 2022, 12 October 2022 Application for Technical Specification Change and Exemption Request Regarding Use of Framatome Gaia Fuel (LDCN 22-0002) Project stage: Request ML22285A1252022-10-12012 October 2022 Attachment 8 to Enclosure 1: ANP-3969NP, Callaway Non-LOCA Summary Report, Revision 2, Dated October 2022 Project stage: Request ML22285A1222022-10-12012 October 2022 Attachment 5 to Enclosure 1: ANP-3947NP, Callaway Unit 1 License Amendment Request Inputs for Use of Framatome Fuel, Revision 3, Dated October 2022 Project stage: Request ML22285A1232022-10-12012 October 2022 Attachment 6 to Enclosure 1: ANP-3944NP, Callaway Realistic Large Break LOCA Analysis with Gaia Fuel Design, Revision 1, Dated October 2022 Project stage: Request ML22285A1242022-10-12012 October 2022 Attachment 7 to Enclosure 1: ANP-3943NP, Callaway Small Break LOCA Analysis with Gaia Fuel Design, Revision 1, Dated October 2022 Project stage: Request ML22287A1392022-10-14014 October 2022 Responses to HI-STAR Atb 1T Requests for Additional Information Project stage: Other ML22287A1412022-10-14014 October 2022 Attachment 2 - HI-STAR Atb 1T Amendment Request 1 RAI Responses Project stage: Other ML22287A1432022-10-14014 October 2022 Attachment 4 - Safety Analysis Report on the HI-STAR Atb 1T Non-Fuel Waste Transport System Project stage: Other ML22287A1382022-10-14014 October 2022 Responses to HI-STAR Atb 1T Requests for Additional Information Project stage: Request ML22287A1462022-10-14014 October 2022 Affidavit of Kimberly Manzione Project stage: Other ML22305A6042022-11-0101 November 2022 International - Supplemental Information for Responses to HI-STAR Atb 1T Requests for Additional Information Project stage: Supplement ML22335A5012022-11-16016 November 2022 Enclosure 3: ANP-4012NP, Revision 1, Callaway Rod Ejection Accident Analysis Project stage: Other ULNRC-06783, Enclosure 2: Affidavit for Withholding2022-11-16016 November 2022 Enclosure 2: Affidavit for Withholding Project stage: Other ML22335A4972022-11-16016 November 2022, 1 December 2022 Supplement to License Amendment and Exemption Request Regarding Use of Framatome Gaia Fuel (LDCN 22-0002) Project stage: Request ML22335A4992022-11-16016 November 2022 Enclosure 1: Responses to Requested Information Project stage: Other ML22322A0062022-11-17017 November 2022 NRR E-mail Capture - Final - LIC-109 Acceptance Review (Unacceptable for Review with Opportunity to Supplement) Callaway - LAR for Proposed Changes to TS and Exemption Request Use of Framatome Gaia Fuel - L-2022-LLA-0150 & L-2022-LLE-0030 Project stage: Acceptance Review ML22335A4982022-12-0101 December 2022 Supplement to License Amendment and Exemption Request Regarding Use of Framatome Gaia Fuel (LDCN 22-0002) Project stage: Supplement ML22343A2612022-12-0909 December 2022 International - Submittal of Final SAR for HI-STAR ATB-1T Amendment 1 Project stage: Other ML22334A2642022-12-13013 December 2022 Enclosure 2 - Safety Evaluation Report Project stage: Approval ML22334A2612022-12-13013 December 2022 Certificate of Compliance No. 9375, Revision No. 1, for the Model No. HI-STAR ATB1T Package Project stage: Request ML22334A2632022-12-13013 December 2022 Enclosure 1 - Certificate of Compliance Rev. No. 1 Project stage: Other ML22334A2622022-12-13013 December 2022 Cover letter- Certificate of Compliance No. 9375, Revision No. 1, for the Model No. HI-STAR ATB1T Package Project stage: Other ML22348A1162022-12-21021 December 2022 Acceptance of Requested Licensing Actions Application for License Amendment & Regulatory Exemptions for TS Change & Exemption Request Regarding Use of Framatome Gaia Fuel (EPID L-2022-LLA-0150 & EPID L-2022-LLE-0030) Project stage: Acceptance Review ML23068A3772023-03-20020 March 2023 Regulatory Audit Plan and Setup of Online Reference Portal for License Amendment Request and Exemption for Fuel Transition to Framatome Gaia Fuel (EPID L-2022-LLA-0150 and EPID L-2022-LLE-0030) - Nonproprietary Project stage: Other ML23107A1812023-04-17017 April 2023 NRR E-mail Capture - Regulatory Audit Questions - Callaway LAR and Exemption for Fuel Transition to Framatome Gaia Fuel - EPIDs - L-2022-LLA-0150 and L-2022-LLE-0030 Project stage: Approval ML23114A2302023-04-24024 April 2023 NRR E-mail Capture - Regulatory Audit Question - Callaway LAR and Exemption for Fuel Transition to Framatome Gaia Fuel - EPIDs - L-2022-LLA-0150 and L-2022-LLE-0030 Project stage: Approval ML23129A7932023-04-27027 April 2023, 9 May 2023 Post-Audit Supplement to License Amendment Request and Exemption to Allow Use of Framatome Gaia Fuel (LDCN 22-0002) (Iepid L-2022-LLA-0150 and EPID L-2022-LLE-0030) Project stage: Request ULNRC-06808, Affidavit2023-04-27027 April 2023 Affidavit Project stage: Other ML23118A3492023-05-0808 May 2023 Request for Withholding Information from Public Disclosure Project stage: Withholding Request Acceptance ML23129A7942023-05-0909 May 2023 Post-Audit Supplement to License Amendment Request and Exemption to Allow Use of Framatome Gaia Fuel (LDCN 22-0002) (Iepid L-2022-LLA-0150 and EPID L-2022-LLE-0030) Project stage: Supplement ML23129A7972023-05-0909 May 2023 Response to Audit Questions Project stage: Other ULNRC-06821, Post-Audit Follow-Up Information in Support of Callaway'S License Amendment Request and Proposed Exemption to Allow Use of Framatome Gaia Fuel (LDCN 22-0002) (EPID L-2022-LLA-0150 and EPID L-2022-LLE-00301)2023-06-21021 June 2023 Post-Audit Follow-Up Information in Support of Callaway'S License Amendment Request and Proposed Exemption to Allow Use of Framatome Gaia Fuel (LDCN 22-0002) (EPID L-2022-LLA-0150 and EPID L-2022-LLE-00301) Project stage: Request ML23215A1962023-08-0303 August 2023, 31 August 2023 Supplement to License Amendment and Exemption Request Regarding Use of Framatome Gaia Fuel (LDCN 22-0002) Project stage: Request ML23215A1972023-08-0303 August 2023 Supplement to License Amendment and Exemption Request Regarding Use of Framatome Gaia Fuel (LDCN 22-0002) Project stage: Supplement ML23219A1392023-08-15015 August 2023 Request for Withholding Information from Public Disclosure Project stage: Withholding Request Acceptance ML23215A1992023-08-31031 August 2023 ANP-4012NP, Callaway, Unit 1, Rod Ejection Accident Analysis Revision 2, August 2023 Project stage: Request ML23206A1992023-09-15015 September 2023 Regulatory Audit Summary Regarding License Amendment and Regulatory Exemptions Request for Fuel Transition to Framatome Gaia Fuel (Epids L-2022-LLA-0150 and L-2022-LLE-0030) Project stage: Other ML23234A1522023-10-0505 October 2023 Exemption from the Requirements of 10 CFR Part 50, Section 50.46, and Appendix K Regarding Use of M5 Cladding Material (EPID L-2022-LLE-0030) (Letter) Project stage: Approval ML23234A1532023-10-0505 October 2023 Exemption from the Requirements of 10 CFR Part 50, Section 50.46, and Appendix K Regarding Use of M5 Cladding Material (EPID L-2022-LLE-0030) (Exemption) Project stage: Approval ML23234A1542023-10-11011 October 2023 Exemption from the Requirements of 10 CFR Part 50, Section 50.46, and Appendix K Regarding Use of M5 Cladding Material (EPID L-2022-LLE-0030) (FRN) Project stage: Approval 2022-08-25
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Category:Legal-Affidavit
MONTHYEARML22287A1462022-10-14014 October 2022 Affidavit of Kimberly Manzione ML22130A7142022-05-10010 May 2022 Enclosure 9: Holtec International - Affidavit ML22050A0102022-02-18018 February 2022 Enclosure 9: Affidavit in Accordance with 10 CFR 2.390 ML21124A2082021-05-0303 May 2021 International - Affidavit for Kimberly Manzione ML20174A4972020-06-22022 June 2020 International, Affidavit Pursuant to 10 CFR 2.390 for Kimberly Manzione 2022-05-10
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Text
U.S. Nuclear Regulatory Commission Affidavit from Holtec International Holtec Letter 2404022 Attachment 7 AFFIDAVIT PURSUANT TO 10 CFR 2.390 I, Kimberly Manzione, being duly sworn, depose and state as follows:
(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 is Attachments 1, 3, 5, and 6 to Holtec Letter 2404022 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 10CFR Part 9.17(a)(4), 2.390(a)(4), and 2.390(b)(l) 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 Commission, 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 Affidavit from Holtec International Holtec Letter 2404022 Attachment 7 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 Affidavit from Holtec International Holtec Letter 2404022 Attachment 7 AFFIDAVIT PURSUANT TO 10 CFR 2.390 regulatory prov1s10ns 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 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 Affidavit from Holtec lnternational Holtec Letter 2404022 Attachment 7 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 Affidavit from Holtec International Holtec Letter 2404022 Attachment 7 AFFIDAVIT PURSUANT TO 10 CFR 2.390 STATE OF NEW JERSEY )
) ss:
COUNTY OF CAMDEN )
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 14th day of October, 2022.
1~~
Kimberly Manzione Director of Licensing Holtec International Subscribed and sworn before me this ~ day of {)c:16.e.R- ,2022.
Erika Grandrimo NOTARY PUBLIC STATE OF NEW JERSEY MY COMMISSION EXPIRES JANUARY 17, 2027
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