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Category:Legal-Affidavit
MONTHYEARML24179A0592024-06-26026 June 2024 Submittal of Responses to the Nuclear Regulatory Commission Request for Additional Information for NAC International Universal Storage System (Ums) Amendment No. 10 ML24044A2212024-02-13013 February 2024 NAC International, Supplement to the Amendment Request for the NAC International Universal Storage System (Ums) Amendment No. 10 ML23291A0952023-10-10010 October 2023 NAC International, Inc., Submittal of Data Files to Support the Nuclear Regulatory Commission'S (NRC) Review of NAC-UMS Amendment No. 1O (Submittal 23A) ML22209A0792022-07-28028 July 2022 NAC, Supplement to the Nuclear Regulatory Commission'S (NRC) Request for Additional Information for the Request to Renew the NAC-UMS Cask System Certificate of Compliance No. 1015 ML22062A7622022-03-0303 March 2022 NAC International, Inc., Submission of Responses to the Nuclear Regulatory Commission'S (NRC) Request for Additional Information for the Request to Renew the NAC-UMS Cask System Certificate of Compliance No. 1015 ML21222A1762021-07-30030 July 2021 NAC International, Inc., Submittal of a Request to Amend the U.S. Nuclear Regulatory Commission Certificate of Compliance No. 1015 for the NAC-UMS Cask System ML20310A1482020-11-0202 November 2020 NAC International Submission of Supplement Information to Nrc'S Pre-Decisional Enforcement Conference (Non-Proprietary Version) ML20293A1022020-10-13013 October 2020 NAC International, NAC-UMS System, Certificate of Compliance (CoC) Renewal Application ML20122A1942020-04-24024 April 2020 NAC International, Submittal of Supplement to Amend the NRC Certificate of Compliance No. 1015 for the NAC-UMS Cask System 2024-06-26
[Table view] Category:Letter
MONTHYEARML24179A0592024-06-26026 June 2024 Submittal of Responses to the Nuclear Regulatory Commission Request for Additional Information for NAC International Universal Storage System (Ums) Amendment No. 10 ML24141A1162024-05-20020 May 2024 Request for Additional Information for the Technical Review of the Application for Amendment Nos. 5 to 9, Rev. 1 & Amendment No. 10, Rev. 0 to Coc No. 1015 ML24082A1302024-04-18018 April 2024 NAC International - USNRC Inspection Report 0721031/2023201 Final Letter ML24094A0602024-03-28028 March 2024 Independent Spent Fuel Storage Installation, Request for Exemption from Certain Requirements of 10 CFR 72.212 and 10 CFR 72.214 for the Maine Yankee Independent Spent Fuel Storage Installation ML24039A2002024-02-16016 February 2024 Letter - Acceptance of NAC International LLC, Amendment Nos. 5 to 9, Revision 1, and Amendment 10, Revision 0, to Coc No. 1015 for the Model No. NAC-UMS, CAC 001028/EPID L-2023-LLA-0154 ML24044A2212024-02-13013 February 2024 NAC International, Supplement to the Amendment Request for the NAC International Universal Storage System (Ums) Amendment No. 10 ML23283A2382023-12-0707 December 2023 NAC International, Inc. - U.S. Nuclear Regulatory Commission Inspection Report 72-1031/2023-201 ML23283A2492023-10-10010 October 2023 Transmittal Letter and Affidavit, Submission of an Amendment Request for the NAC International Universal Storage System (Ums) Amendment No. 10 and Revisions to Amendments 5 to 9 ML23291A0952023-10-10010 October 2023 NAC International, Inc., Submittal of Data Files to Support the Nuclear Regulatory Commission'S (NRC) Review of NAC-UMS Amendment No. 1O (Submittal 23A) ML22355A1192022-12-21021 December 2022 NAC International - Request to Withdraw Administrative Controls for Adverse Weather Events During Operations from NAC-UMS CoC Renewal Application ML22209A0792022-07-28028 July 2022 NAC, Supplement to the Nuclear Regulatory Commission'S (NRC) Request for Additional Information for the Request to Renew the NAC-UMS Cask System Certificate of Compliance No. 1015 ML22202A0212022-07-22022 July 2022 Transmittal Letter NAC-UMS Amendment 9 ML22077A0762022-03-18018 March 2022 Replacement Page for Responses to the Nuclear Regulatory Commission'S (NRC) Request for Additional Information for the Request to Renew the NAC-UMS Cask System Certificate of Compliance No. 1015 ML22062A7622022-03-0303 March 2022 NAC International, Inc., Submission of Responses to the Nuclear Regulatory Commission'S (NRC) Request for Additional Information for the Request to Renew the NAC-UMS Cask System Certificate of Compliance No. 1015 ML21334A5092021-12-21021 December 2021 Request for Additional Information for the Technical Review of the Application for Renewal of the Certificate of Compliance No. 1015 (Cac/Epid Nos. 001028/L-2020-RNE-0031) ML21253A2402021-09-20020 September 2021 NAC-UMS Transmittal Letter ML21064A4092021-08-0909 August 2021 Congressional Letters: Amendment to List of Approved Spent Fuel Storage Casks: NAC-UMS, Certificate of Compliance No. 1015, Amendment 8 ML21222A1762021-07-30030 July 2021 NAC International, Inc., Submittal of a Request to Amend the U.S. Nuclear Regulatory Commission Certificate of Compliance No. 1015 for the NAC-UMS Cask System ML21102A0872021-05-0707 May 2021 NRC Review of NAC Internationals Response Letter to Inspection Report 07201015/2020201 Notice of Violation EA-20-066; and Response to Disputed Notice of Violation ML21060B2982021-03-25025 March 2021 Letter: NAC-UMS CoC 1015 Renewal Acceptance Letter ML21070A3242021-03-0404 March 2021 NAC International, Inc - 10 CFR 72.242 Reportable Licensing Basis Thermal Evaluation Deficiency (Fuel Rod Assembly Effective Thermal Conductivity) for the NAC-UMS Dry Cask Storage Systems ML21139A1212021-02-0909 February 2021 NAC Request for Clarification of LCO 3.1.6 for NAC-UMS Storage Cask ML21036A0372021-01-29029 January 2021 NAC International Reply to Notice of Violation (EA-20-066), January 29, 2021 (Docket Nos.: 72-1015, 72-1025, 72-1031) ML20330A2812020-12-21021 December 2020 NAC International Notice of Violation; U.S. Nuclear Regulatory Commission Inspection Report No.: 07201015/2020201 (EA-20-066) ML20328A1292020-11-23023 November 2020 Proprietary Determination Letter for 1015 Renewal 10-13-20 Submittal v00 - Letter ML20310A1482020-11-0202 November 2020 NAC International Submission of Supplement Information to Nrc'S Pre-Decisional Enforcement Conference (Non-Proprietary Version) ML20293A1022020-10-13013 October 2020 NAC International, NAC-UMS System, Certificate of Compliance (CoC) Renewal Application ML20225A0322020-09-0303 September 2020 NRC Choice Letter to NAC International with Attached Safety Inspection Report, IR 0721015/2020201, February 24-27, 2020 and July 22, 2020, Inspection of NAC International in Norcross, Georgia ML20170A8032020-06-25025 June 2020 Letter Issuing RAI for NAC-UMS Amendment 8 ML20122A1942020-04-24024 April 2020 NAC International, Submittal of Supplement to Amend the NRC Certificate of Compliance No. 1015 for the NAC-UMS Cask System ML20076A5462020-03-17017 March 2020 Letter-NAC-UMS Amendment 8 Acceptance ML19182A0322019-07-0505 July 2019 Letter to J. Brown Maine Yankee Atomic Power Company Exemption Request from Certain Requirements of 10 CFR 72.214 for the ISFSI ML19182A0402019-07-0505 July 2019 Letter to P. Dostie Maine Yankee Atomic Power Company Exemption Request from Certain Requirements of 10 CFR 72.212 and 10 CFR 72.214 for the ISFSI ML19183A2742019-07-0202 July 2019 Letter to W. Fowler Amendment No. 7 to Certificate of Compliance No. 1015 for the NAC-UMS Storage System ML19112A0242019-04-11011 April 2019 Independent Spent Fuel Storage Installation, Reference Correction - Request for Exemption from Certain Requirements of 10 CFR 72.212 and 10 CFR 72.214 ML19038A0572019-01-29029 January 2019 Independent Spent Fuel Storage Installation (ISFSI) - Request for Exemption from Certain Requirements of 10 CFR 72.212 and 10 CFR 72.214 ML19031B3412019-01-21021 January 2019 Request for Exemption from Certain Requirements of 10 CFR 72.212 and 10 CFR 72.214 for the Maine Yankee Independent Spent Fuel Storage Installation ML18333A2372018-12-0404 December 2018 Letter to W. Fowler Amendment No. 6 to Certificate of Compliance No. 1015 for the NAC-UMS Storage System ML19044A4532018-08-14014 August 2018 Rin 3150-AK12 Draft Congressional Letters for NAC CoC Amendment 6 081418 Rasb ML17356A2802017-12-22022 December 2017 Letter to W. Fowler Application for Amendment No. 6 to the Model No. NAC-UMS Storage Cask - Request for Additional Information (W/Enclosure) ML17244A8972017-08-31031 August 2017 ISFSI - Registration of Dry Spent Fuel Transportable Storage Canister, Identification Number AMZDFX151 and Vertical Concrete Cask Identification Number AMZDNE151 ML17235B2692017-08-23023 August 2017 Independent Spent Fuel Storage Installation - Registration of Dry Spent Fuel Transportable Storage Canister Identification Number AMZDFX150 and Vertical Concrete Cask Identification Number AMZDNE150 ML17216A8362017-08-0303 August 2017 ISFSI - Registration of Dry Spent Fuel Transportable Storage Canister Identification No. AMZDFX149 and Vertical Concrete Cask Identification No. AMZDNE149 ML17180A5082017-06-29029 June 2017 Independent Spent Fuel Storage Installation - Registration of Dry Spent Fuel Transportable Storage Canister Identification Nos. AMZDFX146 and AMZDFX147 and Vertical Concrete Cask Identification Nos.... ML17160A4722017-06-0909 June 2017 Independent Spent Fuel Storage Installation - Registration of Dry Spent Fuel Transportable Storage Canister ML17069A5072017-03-10010 March 2017 ISFSI- Registration of Dry Spent Fuel Transportable Storage Canister Identification No. AMZDFX144 and Vertical Concrete Cask Identification No. AMZDNE144 ML17062B0972017-03-0303 March 2017 Independent Spent Fuel Storage Installation - Registration of Dry Spent Fuel Transportable Storage Canister Identification No. AMZDFX143 and Vertical Concrete Cask Identification No. AMZDNE143 ML17053A1842017-02-22022 February 2017 Independent Spent Fuel Storage Installation - Registration of Dry Spent Fuel Transportable Storage Canister Identification No. AMZDFX141 and Vertical Concrete Cask Identification No. AMZDNE141 ML16308A3492016-11-0303 November 2016 Letter to J. S. Brown Maine Yankee Independent Spent Fuel Storage Installation Request for Exemption from Specific Requirements of 10 CFR 72.212 and 10 CFR 72.214-Withdrawal (CAC No. L25110) ML16285A2702016-09-27027 September 2016 Independent Spent Fuel Storage Installation - Withdrawal of Request for Exemption from Certain Requirements of 10 CFR 72.212 and 10 CFR 72.214 2024-06-26
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Atlanta Corporate Headquarters 2 Sun Court, Suite 220 Peachtree Corners, GA 30092 Phone 770-447-1144 www.nacintl.com February 13, 2024
U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738
Attn: Document Control Desk
Subject:
Supplement to the Amendment Request for the NAC International Universal Storage System (UMS) Amendment No. 10
Docket No. 72-1015
References:
- 1. U.S. Nuclear Regulatory Commission (NRC) Certificate of Compliance (CoC) No. 1015 for the NAC International Universal Storage System (UMS)
System, Amendment No. 9, July 22, 2022
- 2. NAC-UMS System Final Safety Analysis Report (FSAR), Revision 16, NAC International, November 14, 2022
- 3. ED20230029, 10 CFR 72.242 Reportable Licensing Basis Non-Mechanistic Tip-over Evaluation Deficiency for the NAC-UMS and MAGNASTOR Dry Cask Storage Systems, March 10, 2023
- 4. ED20230124, Submission of an Amendment Request for the NAC International Universal Storage System (UMS) Amendment No. 10, October 10, 2023
- 5. ED20230127, Submission of Data Files to Support the Nuclear Regulatory Commissions (NRC) Review of NAC -UMS Amendment No. 10 (Submittal 23A), October 10, 2023
NAC International (NAC) hereby submits a supplement to our request to revise Amendments 5 thru 9 via the issuance of a Certificate of Compliance (CoC) revisions (reference 4). This supplement provides an explanation of the changes being requested from calculation 71160-2025, revision 1, to 71160-2026, revision 1.
Per Attachment 1 to this letter, NAC requests information in Enclosures 1 to be withheld from public disclosure per 10 CFR 2.390. In accordance with NACs administrative practices, upon final acceptance of this application, 23A changed pages will be reformatted and incorporated into the next revision of the NAC-UMS SAR.
ED20240026 Atlanta Corporate Headquarters 2 Sun Court, Suite 220 Peachtree Corners, GA 30092 Phone 770-447-1144 www.nacintl.com U.S. Nuclear Regulatory Commission February 13, 2024 Page 2 of 2
If you have any comments or questions, please contact me on my direct line at 678-328-1252.
Sincerely,
Heath Baldner Director, Licensing Engineering
Attachment:
NAC International Inc. Affidavit Pursuant to 10 CFR 2.390
Enclosure:
Request for Clarification
ED20240026 NAC INTERNATIONAL
AFFIDAVIT PURSUANT TO 10 CFR 2.390
Doug Jacobs (Affiant), Vice President, Storage Projects, of NAC International, 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 to support the technical review of NACs Re quest for a Certificate of Compliance (CoC) (No.
1031) for the NAC International MAGNASTOR Cask System.
Enclosure 1 Request for Clarification
NAC is the owner of the information contained in the above documents. Thus, all of the above identified information is 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 of Informati on Act (FOIA); 5 USC Sec. 552(b)(4) and the Trade Secrets Act; 18 USC Sec. 1905; and NRC Regulations 10 CFR Part 9.17(a)(4), 2.390(a)(4), and 2.390(b)(1) for trade secrets and commercial fi nancial 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.
- 5. The information to be withheld is being transmitted to the NRC in confidence.
ED20240026 Page 1 of 3 NAC INTERNATIONAL
AFFIDAVIT PURSUANT TO 10 CFR 2.390
- 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 Sp ecialist, 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 limite d via controlled distribution to individuals on a need to know basis. The pro cedure 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 of NAC 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.
- 9. 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 of NACs comprehe nsive 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.
ED20240026 Page 2 of 3