ML24313A076
| ML24313A076 | |
| Person / Time | |
|---|---|
| Site: | 07201052 |
| Issue date: | 10/31/2024 |
| From: | Bussmann D, Kattner F GNS Gesellschaft fur Nuklear-Service mbH |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML24313A078 | List: |
| References | |
| EPID L-2021-NEW-0006, T1213-CO-00024 | |
| Download: ML24313A076 (1) | |
Text
GNS Gesellschaft fur Nuklear-Service mbH
- Postfach 10 12 53 45012 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 GNS Our reference:
T1213-CO-00024 Contact person:
Dominik Bussmann Phone:
+49 (0)201 / 109-1891 Fax:
+49 (0)201 / 109-11 86 Email:
dominik.bussmann@gns.de Date:
31.10.2024
Subject:
Response on request for additional information for 10 CFR 72 Application of the CASTOR geo69 Dry Storage System - Submission of final response and revised SAR (Docket No. 72-1052; EPID No. L-2021-NEW-0006)
By letter dated August 30, 2024 GNS submitted a preliminary response on the request for additional information on the application for approval acc. to 10 CFR 72 of the CASTOR geo69 dry storage system. The final response and the corresponding revised SAR sections are enclosed to this letter.
For section 2.1 of the SAR only the revised pages are attached to enclosure 2, as other parts of the section are subject to dual-use regulations and the necessary export license is actually still pending.
However all implemented changes based on the RAI response are included in the enclosures to this letter. A comprehensive version of the SAR will be submitted as soon as the export license regarding the dual-use regulations is granted.
The response and the SAR contain certain information that is proprietary, confidential and a trade secret to GNS. Therefore, a non-proprietary version of the response and 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 also 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
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GNS Digital signiert van Kattner, Franz Datum:
2024.10.31 14:35:38+01 '00' GNS Gesellschaft fi.ir Nuklear-Service mbH Frohnhauser Stralle 67 DE-45127 Essen Telephone +49 201 109-0 Telefax +49 201 109-1100 www.gns.de HRS Essen 1121 3 Commerzbank AG, Essen ISAN DE17 3604 0039 0124 3237 00, SIC COSADEFF Bayerische Landesbank DUsseldorf ISAN DE56 7005 0000 0004 3662 43, SIC SYLADEMM Deutsche Bank AG, Essen ISAN DE28 3607 0050 0151 7804 00, SIC DEUTDEDEXXX
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.5 5 Digital signiert von
- Bussmann, Dominik Datum: 2024.10.31 14:29:34+01 '00' USt-ldNr. DE 171892160, Steuer-Nr. 111/5714/1234 Chairman of the Supervisory Board: Dr. Guido Knott Managing Directors:
Daniel Oehr (Chairman)
Dr.-tng. Jens Schroder Dr.-lng. Martin Meyer ter Vehn
page 2/2 to T1213-CO-00024 : Affidavit Pursuant to 10 CFR 2.390 : Final response on request for additional information, Proprietary Version :
Final response on request for additional information, Non-Proprietary Version : Safety Analyses Report (SAR), Dry Storage System CASTOR geo69, GNS Report number 1014-SR-00002, Revision 2, Docket 72-1052, Proprietary Version : Safety Analyses Report (SAR), Dry Storage System CASTOR geo69, GNS Report number 1014-SR-00002, Revision 2, Docket 72-1052, Non-Proprietary Version to T1213-C0-00024 and T1213-C0-00025 AFFIDAVIT PURSUANT TO 10 CFR 2.390 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.
I, Dr.-lng. Rainer NORING, 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 NORING, 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 the following documents listed below: of letter T1213-C0-00024, Final Response to Request for additional information, Proprietary Version of letter T1213-C0-00024 Safety Analyses Report (SAR), Dry Storage System CASTOR geo69, GNS Report number 1014-SR-00002, Revision 2, Docket 72-1052, Proprietary Version Presentation, Supplemental Information on Criticality Validation Analysis, dated September 25th 2024 of letter T1213-C0-00025, Safety Analyses. Report (SAR), Type B(U)F Transport Package CASTOR geo69, GNS Report number 1014-SR-00001, Revision 6, 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 transport package and 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.
2
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Dr.-lng. Sasch;KLA~ERT *
- Divisional Director of Engineering -
GNS Gesellschaft fi.ir Nuklear-Service mbH Date:
Dr.-lng. Rainer N
- Divisional Direct r Subscribed and sworn to me before this./.$.~~day of. O~,>.~-<<": 2024.
(Unterschrift des Notars) 3
Number GO-263 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, October 15, 2024
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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 rtified/Bestati gt
- 5.
at I in E s s e n
- 7.
by/ durch the President of the Regional Court Essen/
die Prasidentin des Landgerichts Essen
- 8.
No./unterNr.91 E1/ S'dh 3jb9/ QsxJ-~
- 9.
Seal / Stamp Siegel / Stempel:
- 10. Signature/ Unterschrift:
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