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| number = ML24051A090 | | number = ML24051A090 | ||
| issue date = 02/08/2024 | | issue date = 02/08/2024 | ||
| title = Statement of Withholding Determination for the Application for the Revalidation of the Model No. | | title = Statement of Withholding Determination for the Application for the Revalidation of the Model No. SKODA Package Design, February 8, 2024 | ||
| author name = Boyle R, King M | | author name = Boyle R, King M | ||
| author affiliation = Secured Transportation Services, US Dept of Transportation (DOT), Office of Hazardous Materials Safety | | author affiliation = Secured Transportation Services, US Dept of Transportation (DOT), Office of Hazardous Materials Safety | ||
| Line 21: | Line 21: | ||
{{#Wiki_filter:ENCLOSURE | {{#Wiki_filter:ENCLOSURE | ||
STATEMENT | STATEMENT OF PROPRIETARY INFORMATIO N PURSUANT TO 49 CFR 7.14, 49 CFR 105.30, AND 1 0 CFR 2.39 0 | ||
The NNSA has requested that this application be submitted, and is working directly with SKODA JS | The NNSA has requested that this application be submitted, and is working directly with SKODA JS to provide the required information. Certain drawings and diagrams provided by SKODA JS are marked as Proprietary information. Secured Transportation Services, LLC as a subcontractor to NNSA via Idaho National Laboratory is bound by any and all nondisclosure, confidentiality, and business sensitive agreements that may exist between SKODA JS and NNSA. Therefore Secured Transportation Services, LLC is submitting t his statement of proprietary information on behalf of SKODA JS, as empowered by NNSA in conformance with the provisions of 49 CFR 7.14 and 49 CFR 105.30 of the Department's regulations, and with the provisions of 10 CFR 2.390 of the Commission's regulations. This information is exempt from public disclosure under the Freedom of Information Act, 5 U.S.C. 552, as amended, for withholding this information | ||
The | The inform ation for which proprietary treatm ent is sought is listed in the enclosure to this letter statement. | ||
Business sensitive documents have been | Business sensitive documents have been appropriately designated as proprietary. | ||
Pursuant | Pursuant to the provisions of paragraph 7.14 of Part 7 and paragraph (a) (3) of Part I 05 of the Department regulations, and the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations the following is furnished for consideration by the Department and by the Com m ission in determ ining whether the inform ation sought to be withheld from public disclosure, included in the referenced documents, should be withheld. | ||
: 1. | : 1. The information sought to be withheld involves portions of the Safety Analysis Report, drawings, diagrams, figures and data which are owned and have been held in confidence by SKODA JS. | ||
: 2. | : 2. The information is of a type customarily held in confidence by SKODA JS and not customarily disclosed to the public. SKODA JS has a rational basis for determining the types of inform ation that is customarily held in confidence by it. | ||
: 3. | : 3. Public disclosure of the information is likely to cause substantial harm to the com petitive position of SKODA JS because the information consists of detailed descriptions, drawings, dimensions, and calculations about the SKODA VPVR/M package, as well as com pany business sensitive information, the application of which provides a competitive economic advantage. The availability of such information to competitors would enable them to m odify their product to better com pete with SKODA, take m arketing or other actions to im prove their product's position or impair the position of the SKODA product, and avoid developing similar data and analyses in support of their processes, methods, or apparatus. | ||
Signed | Signed | ||
| Line 40: | Line 40: | ||
Roy A Boyd II President, Secured Transportation Services Buford, GA ENCLOSURE | Roy A Boyd II President, Secured Transportation Services Buford, GA ENCLOSURE | ||
Notwithstanding the following list, any document marked with Protected right Intellectual Property Proprietary | Notwithstanding the following list, any document marked with Protected right Intellectual Property Proprietary information or similar language that is not listed below should be withheld due to the damage it may cause to SKODA JS for the reasons stated above. | ||
* The Safety Analysis Report titled Transport and Storage Cask for Spent Fuel From Research | * The Safety Analysis Report titled Transport and Storage Cask for Spent Fuel From Research Reactors (SKODA VPVR/M Cask); in its entirety and the following appendices o Appendix 1 - SKODA Cask Shielding Calc; in its entirety o Appendix 6 - Calculation of temperatures_Rev0; in its entirety o Appendix 7 - SKODA Stress Calcs; in its entirety o Appendix 8 - Drawings; in its entirety o Appendix 10 - Conformance Statement; in its entirety o Appendix 11 - Set of Inspection and Testing Operations; in its entirety o Appendix 12 - Quality and Environmental Integrated Management System Manual; In its entirety o Appendix 13 - SKODA Service and Handling Manual; In its Entirety o Appendix 15 - SKODA Brittle failure evaluation; In its entirety | ||
* The supplemental Safety Analysis Report titled: SKODA MRT | * The supplemental Safety Analysis Report titled: SKODA MRT -TRIGA Transport and Storage Cask; in its entirety o All drawings and "gures submitted as appendices to this SAE o Annex 564 Central Hinge 2 of the Basket o Annex 565 Grip o Annex 806 Shock Absorber o Annex 998 Strength check of the auxiliary equipment 2 for the SKODA VPVR/M Cask o Ancillary Document 21517 o Ancillary Document 21711 o Ancillary Document 21712 o Ancillary Document 21713 o Ancillary Document 21722 o Ancillary Document 21723 o Ancillary Document 21996 o Ancillary Document 22025 o Ancillary Document 22030 o Ancillary Document 22152 o Ancillary Document 114472}} | ||
Latest revision as of 14:09, 5 October 2024
| ML24051A090 | |
| Person / Time | |
|---|---|
| Site: | 07103103 |
| Issue date: | 02/08/2024 |
| From: | Boyle R, Mark King Secured Transportation Services, US Dept of Transportation (DOT), Office of Hazardous Materials Safety |
| To: | Boyle R, Garcia-Santos N, Mark King Storage and Transportation Licensing Branch, Secured Transportation Services, US Dept of Transportation (DOT), Office of Hazardous Materials Safety |
| Shared Package | |
| ML23349A155 | List: |
| References | |
| CAC 001794, EPID L-2023-DOT-0004 | |
| Download: ML24051A090 (2) | |
Text
ENCLOSURE
STATEMENT OF PROPRIETARY INFORMATIO N PURSUANT TO 49 CFR 7.14, 49 CFR 105.30, AND 1 0 CFR 2.39 0
The NNSA has requested that this application be submitted, and is working directly with SKODA JS to provide the required information. Certain drawings and diagrams provided by SKODA JS are marked as Proprietary information. Secured Transportation Services, LLC as a subcontractor to NNSA via Idaho National Laboratory is bound by any and all nondisclosure, confidentiality, and business sensitive agreements that may exist between SKODA JS and NNSA. Therefore Secured Transportation Services, LLC is submitting t his statement of proprietary information on behalf of SKODA JS, as empowered by NNSA in conformance with the provisions of 49 CFR 7.14 and 49 CFR 105.30 of the Department's regulations, and with the provisions of 10 CFR 2.390 of the Commission's regulations. This information is exempt from public disclosure under the Freedom of Information Act, 5 U.S.C. 552, as amended, for withholding this information
The inform ation for which proprietary treatm ent is sought is listed in the enclosure to this letter statement.
Business sensitive documents have been appropriately designated as proprietary.
Pursuant to the provisions of paragraph 7.14 of Part 7 and paragraph (a) (3) of Part I 05 of the Department regulations, and the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations the following is furnished for consideration by the Department and by the Com m ission in determ ining whether the inform ation sought to be withheld from public disclosure, included in the referenced documents, should be withheld.
- 1. The information sought to be withheld involves portions of the Safety Analysis Report, drawings, diagrams, figures and data which are owned and have been held in confidence by SKODA JS.
- 2. The information is of a type customarily held in confidence by SKODA JS and not customarily disclosed to the public. SKODA JS has a rational basis for determining the types of inform ation that is customarily held in confidence by it.
- 3. Public disclosure of the information is likely to cause substantial harm to the com petitive position of SKODA JS because the information consists of detailed descriptions, drawings, dimensions, and calculations about the SKODA VPVR/M package, as well as com pany business sensitive information, the application of which provides a competitive economic advantage. The availability of such information to competitors would enable them to m odify their product to better com pete with SKODA, take m arketing or other actions to im prove their product's position or impair the position of the SKODA product, and avoid developing similar data and analyses in support of their processes, methods, or apparatus.
Signed
Date
Roy A Boyd II President, Secured Transportation Services Buford, GA ENCLOSURE
Notwithstanding the following list, any document marked with Protected right Intellectual Property Proprietary information or similar language that is not listed below should be withheld due to the damage it may cause to SKODA JS for the reasons stated above.
- The Safety Analysis Report titled Transport and Storage Cask for Spent Fuel From Research Reactors (SKODA VPVR/M Cask); in its entirety and the following appendices o Appendix 1 - SKODA Cask Shielding Calc; in its entirety o Appendix 6 - Calculation of temperatures_Rev0; in its entirety o Appendix 7 - SKODA Stress Calcs; in its entirety o Appendix 8 - Drawings; in its entirety o Appendix 10 - Conformance Statement; in its entirety o Appendix 11 - Set of Inspection and Testing Operations; in its entirety o Appendix 12 - Quality and Environmental Integrated Management System Manual; In its entirety o Appendix 13 - SKODA Service and Handling Manual; In its Entirety o Appendix 15 - SKODA Brittle failure evaluation; In its entirety
- The supplemental Safety Analysis Report titled: SKODA MRT -TRIGA Transport and Storage Cask; in its entirety o All drawings and "gures submitted as appendices to this SAE o Annex 564 Central Hinge 2 of the Basket o Annex 565 Grip o Annex 806 Shock Absorber o Annex 998 Strength check of the auxiliary equipment 2 for the SKODA VPVR/M Cask o Ancillary Document 21517 o Ancillary Document 21711 o Ancillary Document 21712 o Ancillary Document 21713 o Ancillary Document 21722 o Ancillary Document 21723 o Ancillary Document 21996 o Ancillary Document 22025 o Ancillary Document 22030 o Ancillary Document 22152 o Ancillary Document 114472