ML25241A002

Croft Associates Ltd - Affidavit

ML25241A002
Person / Time
Site:	07109337
Issue date:	08/27/2025
From:	Mary Johnson Croft Associates Limited
To:	Office of Nuclear Material Safety and Safeguards
Shared Package
ML25241A001	List: ML25241A002 ML25241A003
References
Download: ML25241A002 (1)

Text

Croft Associates Ltd F4 Culham Science Centre Culham, Abingdon, Oxon, United Kingdom OX14 3DB Registered in England No: 1698337 T:

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+44 (0)1865 407740

+44 (0)1865 407449 info@croftltd.com www.croftltd.com FM 28718 - ISO9001 EMS 720456 - ISO14001 Page 1 of 2 AFFIDAVIT PURSUANT TO 10 CFR 2.390 I, Mark Johnson, Managing Director of Croft Associates Limited (Croft) hereby affirm and state

1. I have been specifically delegated the function of reviewing the information sought to be withheld and am authorized to apply for its withholding on behalf of Croft.

2. Croft is providing NRC with test evidence as part of the Safkeg-HS 3979A SARP submission Docket No 071-9337. This information contains proprietary commercial information.

3. The information sought to be withheld pursuant to the provisions of paragraph (a)(4) of 10 CFR 2.390 are the documents listed below, which are marked as follows in the SARP submissions Proprietary information submitted under 10 CFR 2.390 to be withheld from public disclosure under 10 CFR 2.390.

4. These documents should be held in confidence by the NRC based on paragraph (b)(4) of 10 CFR 2.390 because:

i) This information is and has been held in confidence by Croft.

ii) This information is of a type that is customarily held in confidence by Croft and there is a rational basis for doing so because this information if released might result in the loss of an existing or potential competitive advantage as follows.

a. The information reveals the distinguishing aspects of the design and the prevention of its use by Crofts competitors gives Croft a competitive economic advantage.

b. The information, if used by a competitor, is likely to reduce the competitors expenditure of resources or improve their advantage in the design, quality and manufacture of a similar product.

iii) This information is being transmitted to the NRC voluntarily and in confidence.

iv) This information is not available in public sources.

v) Public disclosure of this information is likely to cause substantial harm to the competitive position of Croft because of the reasons outlined below.

a. Similar products are manufactured and sold by competitors of Croft.

b. The development of this information by Croft is the result of significant expenditure of staff effort and a considerable amount of money. It is my belief that a competitor would have to undertake similar effort and expense to generate equivalent information.

c. In order to generate such information, a competitor would also require considerable time.

d. If a competitor used this information and did not have to undertake the work required to generate this information they are likely to have lower overall costs and so are likely to have an unfair economic advantage over Croft in offering a similar product to the market.

5. Accordingly, Croft requests that the designated information be withheld from public disclosure pursuant to paragraph (a)(4) of CFR 10 2.390.

Croft Associates Ltd F4 Culham Science Centre Culham, Abingdon, Oxon, United Kingdom OX14 3DB Registered in England No: 1698337 T:

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+44 (0)1865 407740

+44 (0)1865 407449 info@croftltd.com www.croftltd.com FM 28718 - ISO9001 EMS 720456 - ISO14001 Page 2 of 2 Documentation to be withheld from public disclosure:

Document Reference Issue/

Rev Title Comments 1

CTR2008-10-Rev9-v13-Safety Analysis Report LS 3979A.pdf 9

Safety Analysis Report for Packaging, Safkeg-LS Design No.

3979A, Package Docket No.

07109337 Including all referenced supporting documentation marked in accordance with 3 above.

2 CTR 2025-04-A-v2-SARP LS 3979A Revision History (Package Docket No.

07109337).pdf A

SARP LS 3979A Revision History (Package Docket No. 07109337) 3 6040J - licensing drawings.pdf J

COVER SHEET FOR SAFKEC DESIGN No. 3979A (LICENSING DRAWING)

Including all referenced supporting documentation marked in accordance with 3 above.

4 CTN 2025-01-A-d6 - L7 bolt material.pdf A

Comparison between ASTM A320 Grade L7 and Grade L43 5

CTR 2024-08-B-d2 -

3979A Periodic design review.pdf B

Periodic Design Review for SAFKEG-LS 3979A (2025) 6 CTR 2024-09-A-d5 -

3979A Ageing -

Clean.pdf A

SAFKEG 3979A-LS Package Design Life Assessment 7

ETR 566-B - C.02086-CROFT-PACK-B02-C01-I1.pdf B

Transport Shielding Assessment for the Croft SAFKEG-LS Package DN 3979 A 8

M1049 - modifications to licensing drawings.pdf A

Change Control Document and Mod Sheet 9

PCS 036-E-v4 SAFKEG-LS Contents.pdf E

Package Contents Specification for SAFKEG-LS Package Design No 3979A Executed on August 27, 2025 Mark Johnson Managing Director Croft Associates Limited

[3979A Affidavit November 2021.docx]