ML23243A849

NAC International, Submittal of Data Files to Support the Request to Amend the U.S. Nuclear Regulatory Commission Certificate of Compliance No. 1031 for Magnastor Cask System, Amendment No.15

ML23243A849
Person / Time
Site:	07201031
Issue date:	08/29/2023
From:	Baldner H NAC International
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
ED20230123
Download: ML23243A849 (1)

Text

Atlanta Corporate Headquarters 2 Sun Court, Suite 220 Peachtree Corners, GA 30092 Phone 770-447-1144 www.nacintl.com August 29, 2023 U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738

Attention: Document Control Desk

Subject:

Submission Data Files to Support the Request to Amend the U.S. Nuclear Regulatory Commission Certificate of Compliance No. 1031 for the NAC International MAGNASTOR Cask System, Amendment No.15

Docket No. 72-1031

References:

1. U.S. Nuclear Regulatory Commission (NRC) Certificate of Compliance (CoC) No.

1031 for the NAC International MAGNASTOR Cask System, Amendment No. 10, January 18, 2023

2. MAGNASTOR Cask System Final Safety Analysis Report (FSAR), Revision 13, NAC International, January 2023

3. ED20230099, Submission of an Amendment Request for the NAC International MAGNASTOR Cask System Amendment No. 15, August 29, 2023 NAC International Inc. (NAC) herewith is providing proprietary calculation data files to support the review of MAGNASTOR Amendment No. 15 Certificate of Compliance (CoC) No. 1031 (Reference 3).

The list of data files being provided on the data disk can be found in Enclosure 1. The data files are proprietary and marked "NAC Proprietary Information". An Affidavit pursuant to 10 CFR 2.390 is provided via Attachment 1 to this letter.

Should there be any questions regarding this request, please contact me via email at hbaldner@nacintl.com or via phone at 678-328-1252.

Sincerely,

~' Digitally signed by Heath M. Baldner Heath M. Baldner }*"'Bate: 2023.08.29 15:58:59 -04'00' Heath Baldner Director, Licensing Engineering

Attachment - NAC International Affidavit Pursuant 10 CFR 2.390

Enclosures - MAGNASTOR (Submittal 23A) Proprietary Data Disk 1 of 1

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NAC INTERNATIONAL AFFIDAVIT PURSUANT TO 10 CFR 2.390

George Carver (Affiant), Vice President, Engineering and Support Services, of NAC International Inc.,

hereinafter referred to as NAC, at 2 Sun Court, Suite 220, Peachtree Corners, 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 this submittal.

Enclosure 1 -MAGNASTOR Proprietary Calculation -Data Disk 1 of 1

NAC is the owner of the information contained in the aforementioned pages/document, so they are considered NAC Proprietary Information.

3. NAC makes this application for withholding of proprietary information based upon the exemption from disclosure set forth in: the Freedom oflnformation Act ("FOIA"); 5 USC Sec. 552(b)(4) and the Trade Secrets Act; 18 USC Sec. 1905; and NRC Regulations 10 CPR 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.

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.

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NAC INTERNATIONAL AFFIDAVIT PURSUANT TO 10 CFR 2.390 (continued)

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 Engineer, 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 ofNAC 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 ofNAC'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.

£D20230123 to ED20230123 Page 3 of 3

NAC INTERNATIONAL 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 P~~chtree Corners, Georgia, this, 2023.

• . em;g~ Carver Vice President, Engineering and Support Services NAC International Inc.

Subscribed and sworn before me this

Notary Public

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Enclosure 1

MAGNASTOR,

(Submittal 23A)

Proprietary Data Disk

ED20230123 Enclosure I to ED20230123 Page 2 of2 Data Disk Contents

Structural

• 71160-2021 Revision 1, Structural Evaluation of CC3, CC5, CC7 and CC8 Concrete Casks with Heat Shield

• 71160-2024 Revision 1, LS-DYNA Tip-Over Analysis for CC3, CC4, CC5, CC6, and CC7 Concrete Casks

• 71160-2027 Revision 2, LMTC Structural Evaluation

• 71160-2029 Revision 5, MAG Passive Transfer Cask Lift Evaluation

• 71160-2030 Revision 2, Structural Evaluation for PWR Basket with Square Pins for Storage Conditions

• 71160-2032 Revision 7, BWR Square Pin Basket Structural Evaluation

• 71160-2033 Revision 1, BWR DF Basket Structural Evaluation for Storage Condition

• 71160-2034 Revision 1, LS-DYNA Tip-Over Analysis for CCI and CC5 Concrete Casks

• 71160-2047 Revision 0, Tip-Over Analysis of CC8 High Heat Cask with Long Canister

• 71160-2048 Revision 2, MAG Reduced Width LMTC Evaluation

• 71160-2061 Revision 0, MAG Canister Structural Analysis for Improved High Heat Storage Conditions

Thermal

• 71160-3021 Revision 5, MAG Internal Pressure Analysis

• 71160-3151 Revision 1, Steady State Thermal Evaluation for the PMTC with 35.5 kW PWR Canister

• 71160-3156 Revision 1, Transient Thermal Evaluation for the PMTC with 35.5 kW PWR Canister

• 71160-3285 Revision 1, MAG Concrete Cask and PWR Canister Thermal Eval for IHH

• 71160-3286 Revision 0, MAG PWR Transfer Cask and Canister Thermal Eval for IHH

• 71160-3287 Revision 0, MAG Transfer Cask Transient Thermal Analyses for PWR for IHH

• 71160-3288 Revision 0, MAG VCC Vent Blocked Evaluation for PWR IHH

• 71160-3290 Revision 1, MAG VCC/BWR Canister Thermal Evaluation for IHH

• 71160-3291 Revision 0, MAG Transfer Cask Steady State Thermal Evaluation for BWR IHH

• 71160-3292 Revision 1, MAG Transfer Cask Transient Thermal Analyses for BWR Preferential Loading for IHH

• 71160-3293 Revision 0, MAG VCC Vent Blocked Evaluation for BWR IHH

• 71160-3295 Revision 0, MAG VCC/BWR DF Canister Thermal Evaluation for IHH

• 71160-3296 Revision 0, MAG Transfer Cask Steady State Thermal Evaluation for BWR-DF IHH

• 71160-3297 Revision 1, Transient Thermal Analyses for BWR DF Preferential Loading for IHH

• 71160-3298 Revision 0, MAG VCC Vent Blocked Evaluation for BWR DF IHH

Shielding

• 30032-5002 Revision 0, Load (35.5kW) Shielding Evaluation

• 71160-5031 Revision 5, MAGNASTOR PWR Lightweight Transfer Cask Shielding Evaluation

• 71160-5032 Revision 4, MAGNASTOR PWR-37 High Heat Storage Shielding Analysis (CC3/7)

• 71160-5033 Revision 3, MAGNASTOR BWR-89 High Heat Storage Shielding Analysis (CC3/5/7)

• 71160-5034 Revision 2, MAGNASTOR BWR-81 High Heat Storage Shielding Analysis (CC3/5/7)

• 71160-5035 Revision 2, MAGNASTOR BWR-89 and -81 High Heat Storage Shielding Analysis (LMTC)

• 71160-5053 Revision 1, MAGNASTOR High Heat Occupational Exposure Evaluation - PWR/BWR Transfer

• 71160-5065 Revision 1, MAGNASTOR CC High Heat Site Boundary Dose Rate Analysis

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