ML24285A183
| ML24285A183 | |
| Person / Time | |
|---|---|
| Site: | 07109383 |
| Issue date: | 09/26/2024 |
| From: | Bussmann D, Kattner F GNS Gesellschaft fur Nuklear-Service mbH |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| T1213-CO-00023, EPID L-2021-NEW-0002 | |
| Download: ML24285A183 (1) | |
Text
GNS Gesellschaft fur Nuktear-Service mbH
- Postfach 10 12 53. 4501 2 Essen Document Control Desk Director, Division of Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 USA Our reference:
T1213-CO-00023 Contact person:
Dominik Bussmann Phone:
+49 (0)201/ 109-1891 Fax:
+49 (0)201/ 109-1186 Ema it:
dominik.bussmann@gns.de Date:
26.09.2024
Subject:
10 CFR 71 Application of the CASTOR geo69 Spent Nuclear Fuel Transportation Package (Docket No. 71-9383; EPID No. L-2021-NEW-0002)
Submission of revised SAR sections By letter dated June 26, 2024 GNS submitted the response on the second request for additional information on the CASTOR geo69 Spent Nuclear Fuel Transportation Package. The NRC afterwards raised several issues which were discussed in clarification calls between NRC and GNS and resulted in required changes in the Safety Analyses Report. Enclosed to this letters are the on this basis revised sections of the SAR.
The revised SAR contain certain information that is proprietary, confidential and a trade secret to GNS. Therefore, a non-proprietary version of the SAR 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.
Should the NRC staff require additional information to support review of this response, 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 GNS i.V.
Digital signiert van Kattner, Franz Datum: 2024.09.26 10:03:44+02'00' : Affidavit pursuant to 10 CFR 2.390 GNS i.A.
Digital signiert van Bussmann, Dominik Datum: 2024.09.26 10:01 :25+02'00' : T1213-SR-00001, Rev. 5, Safety Analyses Report (Proprietary Version) : T1213-SR-00001, Rev. 5, Safety Analyses Report (Non-Proprietary Version)
GNS Gesellschaft fiir Nuklear-Service mbH Frohnhauser StraBe 67 DE-45127 Essen Telephone +49 201 109-0 Telefax +49 201109-1100 www.gns.de HRB Essen 11213 Commerzbank AG, Essen IBAN DE17 3604 0039 0124 3237 00, BIC COBADEFF Bayerische Landesbank Dusseldorf IBAN DE56 7005 0000 0004 3662 43, BIC BYLADEMM Deutsche Bank AG, Essen IBAN DE28 3607 0050 0151 7804 00, BIC DEUTDEDEXXX USt-ldNr. DE 171892160, Steuer-Nr. 111/5714/1234 Chairman of the Supervisory Board: Dr. Guido Knott Managing Directors:
Daniel Oehr (Chairman)
Dr.-lng. Jens Schr0der Dr.-lng. Martin Meyer ter Vehn to T1 L 13-C0-00023 AFFIDAVIT PURSUANT TO 10 CFR 2.390 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.
I, Dr.-lng. SASCHA KLAPPERT, depose and say that I am the 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.
We, Dr.-lng RAINER NORI NG and Dr.-lng. SASCHA KLAPPERT, 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 Commission's regulations for withholding this information.
The information sought to be withheld from public disclosure is contained in Enclosure 2 of letter T1213-C0-00023 and are listed below:
Safety Analyses Report (SAR), Type B(U)F Transport Package CASTOR geo69, GNS Report number 1014-SR-00001, Revision 5, Docket 71-9383, Proprietary Version This documents 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 package 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 cask for the dry storage and transport of spent 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, engineeri ng, 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: //(j_
Nuklear-Service mbH Dr.-lng. SASC
- Divisional Direc r of Engineering -
GNS Gesellschaft fi.ir Nuklear-Service mbH Subscribed and sworn to me before this.£.C!day of.J',.~~2024.
. a Notary Pu~
- t~
- chrift des Notars) l 2
Number GO-239 of Notary's List of Deeds for 2024 I herewith certify that the foregoing signatures are given by Dr.-lng. Rainer Noring,*born on November 27, 1968, personally known to me and previously identified in accordance with Section 12 (1) No. 1 of the German Money Laundering Act (GwG) by valid identity docu-ment with photo, and Dr.-lng. Sascha Klappert, born on August 21, 1972, personally known to me and previously identified in accordance with Section 12 (1) No. 1 of the German Money Laundering Act (GwG) by valid identity docu-ment with photo, both with their business address at Frohnhauser Str. 67, 45127 Essen.
The signatures were given today before me 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, September 16, 2024
APOSTILLE (Convention de La Haye du 5 octobre 1961)
- 1. Country/ Land:
Federal Republic of Germany/ Bundesrepublik Deutschland This public document/ Diese offentliche Urkunde
- 2. has been signed by/ ist unterschrieben von Notary Public Dr. Joachim Gores/ 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 / sie ist versehen mit dem Siegel of the Notary Public Dr. Joachim Gores in Essen/ des Notars Dr. Joachim Gores in Essen Ce rt if i e d /Best at i gt
- 5.
at I in E s s e n
- 6. the tam 2 6. Sep. 2024
- 7.
by/ durch the President of the Regional Court Essen/
die Prasidentin des Landgerichts Essen
- 8.
No./ unter Nr. 91 E 1 / ~h a_ ~5 ~ / ds__Ocl_ L{
- 9.
Seal / Stamp Siegel / Stempel:
- 10. Signature/ Unterschrift:
In Vertretung *
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