ML26055A001
| ML26055A001 | |
| Person / Time | |
|---|---|
| Site: | 07109337 |
| Issue date: | 02/23/2026 |
| From: | Mary Johnson Croft Associates Limited |
| To: | Office of Nuclear Material Safety and Safeguards |
| References | |
| Download: ML26055A001 (0) | |
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 evidence as part of the SAFKEG-LS 3979A SARP submission Docket No 07109337. This information contains proprietary commercial information both of Croft and also relating to users of the package.
- 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 of a type that is customarily held in confidence by users of the package 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 development of radiopharmaceuticals and the prevention of its use by the users competitors gives the Croft package users a competitive economic advantage.
iv) This information is being transmitted to the NRC voluntarily and in confidence.
v) This information is not available in public sources.
vi) Public disclosure of this information is likely to cause substantial harm to the competitive position of Croft or users of the package because of the reasons outlined below.
- a. Similar products are manufactured and sold by competitors of Croft.
- b. Similar radiopharmaceuticals are being developed by competitors of the users of the Croft package.
- c. 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 of Croft or of the package users would have to undertake similar effort and expense to generate equivalent information.