Letter Sequence Supplement |
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EPID:L-2020-LLA-0158, Submission of Responses to the Nrc'S Request for Additional Information for the NAC International Magnastor Cask System Amendment No. 11 (Open) |
Results
Other: ML21242A052, ML23250A325, ML23250A326, ML23250A327, ML23250A328, ML23250A329, ML23250A330, ML23250A331, ML23250A332, ML23250A333, ML23250A334, ML23250A335, ML23250A336, ML23250A337, ML23250A338, ML23250A339, ML23250A340, ML23250A341, ML23250A342, ML23250A343, ML23250A344, ML23250A345, ML23250A346, ML23250A347, ML23250A348, ML23250A349, ML23250A350, ML23250A351, ML23250A353, ML23250A354, ML23250A355, ML23250A357, ML23250A358, ML23250A359, ML23250A361, ML23250A362, ML23250A363
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Category:Legal-Affidavit
MONTHYEARML22194A9082022-07-13013 July 2022 NAC, Submittal of an Amendment Request for the NAC International Magnastor Cask System, Amendment No. 13 ML22201A0662022-07-13013 July 2022 NAC International, Inc., Submittal of Data Disk for the Magnastor Cask System, Amendment No. 13 RA-22-0080, Independent Spent Fuel Storage Installation, McGuire, Units 1 & 2, Independent Spent Fuel Storage Installation, Request for an Exemption to the Requirements of Certificate of Compliance No. 1031 for the NAC Magnastor Storage System2022-04-0707 April 2022 Independent Spent Fuel Storage Installation, McGuire, Units 1 & 2, Independent Spent Fuel Storage Installation, Request for an Exemption to the Requirements of Certificate of Compliance No. 1031 for the NAC Magnastor Storage System ML22077A7692022-03-18018 March 2022 Supplement to Nac'S Amendment Request for the NAC International Magnastor Cask System Amendment No. 12 ML22018A0592022-01-11011 January 2022 NAC International, Inc., Submittal of Supplemental Information to the Nrc'S Request for Additional Information for the NAC International Magnastor Cask System Amendment No.11 ML21277A0452021-09-24024 September 2021 Submittal of Final Safety Analysis Report (Fsar), Revision 12, for the NAC Magnastor Cask System ML21251A5302021-09-0202 September 2021 Supplemental Responses to the NRCs Request for Additional Information for the NAC International Magnastor Cask System Amendment No. 10 ML21118A0432021-04-20020 April 2021 NAC International, Inc., Supplemental Responses to the NRCs Request for Additional Information for the Cask System Amendment No. 10 ML21067A0422021-02-25025 February 2021 Submission of Responses to the Nrc'S Request for Additional Information for the NAC International Magnastor Cask System Amendment No. 10 ML20310A1482020-11-0202 November 2020 NAC International Submission of Supplement Information to Nrc'S Pre-Decisional Enforcement Conference (Non-Proprietary Version) ML20318A0842020-11-0202 November 2020 Submission of Supplemental Information to Nac'S Pre-Decisional Enforcement Conference ML20202A2932020-07-14014 July 2020 NAC International, Inc., Submission of a Request to Amend the U.S. Nuclear Regulatory Commission Certificate of Compliance No. 1031 for the NAC International Magnastor Cask System ML20108F3172020-04-0909 April 2020 Submission of Responses to the U.S. Nuclear Regulatory Commission Request for Additional Information for Amendment No. 9 to the Certificate of Compliance No. 1031 for the NAC International Magnastor Cask System RA-20-0080, Response to Requests for Additional Information for Exemption Request to the Requirements of Certificate of Compliance No. 1031 for the NAC Magnastor Storage System2020-03-12012 March 2020 Response to Requests for Additional Information for Exemption Request to the Requirements of Certificate of Compliance No. 1031 for the NAC Magnastor Storage System RA-20-0037, Response to Nrg Request for Additional Information (RAI) Regarding NAC Magnastor Cask Loaded to Incorrect Helium Backfill Density2020-02-0303 February 2020 Response to Nrg Request for Additional Information (RAI) Regarding NAC Magnastor Cask Loaded to Incorrect Helium Backfill Density RA-19-0471, Request for an Exemption to the Requirements of Certificate of Compliance No. 1031 for the NAC Magnastor Storage System2020-01-0909 January 2020 Request for an Exemption to the Requirements of Certificate of Compliance No. 1031 for the NAC Magnastor Storage System RA-19-0215, Exemption Request for NAC Magnastor Cask Loaded to Incorrect Helium Backfill Density2019-09-12012 September 2019 Exemption Request for NAC Magnastor Cask Loaded to Incorrect Helium Backfill Density 2022-07-13
[Table view] Category:Letter
MONTHYEARML24008A2482024-01-0808 January 2024 NAC International, Response to Apparent Violations (a and B) in NRC Inspection Report 72-1031/2023-201; EA-2023-069 ML23283A2382023-12-0707 December 2023 NAC International, Inc. - U.S. Nuclear Regulatory Commission Inspection Report 72-1031/2023-201 ML23250A3242023-09-12012 September 2023 1. Transmittal Letter Magnastor Issuance of Amendment Nos 11 and 12 and Revision of Amendment Nos 0 Through 9 ML23166B0832023-07-0505 July 2023 Independence Spent Fuel Storage Installation - Issuance of Exemption ML23143A3912023-05-23023 May 2023 Independent Spent Fuel Storage Installation - Request for Exemption from NAC-MAGNASTOR Certificate of Compliance 72-1031 - Cask Lid Batch 3 Design Requirements ML23074A2522023-03-29029 March 2023 Application for Amendment No. 13 to the Model No. Magnastor Storage Cask Request for Additional Information ML23076A2272023-03-17017 March 2023 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Transportable Storage Canister Identification Numbers AMZDFX165 and AMZDFX166 and Vertical Concrete Cask Identification Numbers ML23005A2572023-01-0505 January 2023 Request to Withdraw Administrative Controls for Adverse Weather Events During Operations from Magnastor Amendment 12 Supplement ML22349A4682022-12-19019 December 2022 Amendment No. 10 to Certificate of Compliance No. 1031 for the Magnastor Storage System ML22340A5902022-12-0808 December 2022 Acknowledgement Letter - Magnastor Amendment 13 ML22327A2252022-11-23023 November 2022 NAC International - Magnastor Cask System Users CoC Amendment 12 Supplement and Intent to Adopt Letters ML22321A2682022-11-17017 November 2022 Supplement to the Submission of an Amendment Request for the NAC International Magnastor Cask System, Amendment No. 13 ML22308A1942022-11-0909 November 2022 NAC International, Inc. - U.S. Nuclear Regulatory Commission Report No. 72-1031/2022-201 ML22287A0382022-10-13013 October 2022 Supplement to the Submission of an Amendment Request for the NAC International Magnastor Cask System, Amendment No. 13 ML22257A2562022-09-14014 September 2022 Registration of Dry Spent Fuel Transportable Storage Canisters Identification Numbers AMZDFX170 and AMZDFX174 and Vertical Concrete Cask Identification Numbers AMZDNE170 and AMZDNE174 ML22230D0802022-08-18018 August 2022 Independent Spent Fuel Storage Installation - Registration of Dry Spent Fuel Transportable Storage Container ML22216A1102022-08-0404 August 2022 Magnastor Cask System Users CoC Amendments 0 Thru 9 Intent to Adopt Letters ML22208A0782022-07-27027 July 2022 Registration of Use of Cask to Store Spent Fuel ML22196A0232022-07-15015 July 2022 Submittal of Supplemental Information to the Nrc'S Request for Additional Information for the NAC International Magnastor Cask System Amendment No. 11 ML22201A0662022-07-13013 July 2022 NAC International, Inc., Submittal of Data Disk for the Magnastor Cask System, Amendment No. 13 ML22194A9082022-07-13013 July 2022 NAC, Submittal of an Amendment Request for the NAC International Magnastor Cask System, Amendment No. 13 ML22111A3572022-05-16016 May 2022 Letter Issuing Exemption to Catawba ML22111A3112022-05-16016 May 2022 Letter Issuing Exemption to McGuire ML22111A2842022-05-13013 May 2022 Independence Spent Fuel Storage Installation - Issuance of Exemption ML22110A1112022-05-13013 May 2022 Letter Issuing Exemption to TMI-1 ML22125A1532022-05-0505 May 2022 Registration of Use of Casks to Store Spent Fuel ML22118B1622022-04-28028 April 2022 Request for Exemption from NAC-MAGNASTOR Certificate of Compliance 72-1031 - Cask Lid Design Requirements - Supplement RS-22-062, Supplemental Information to Exemption to the Requirements of Certificate of Compliance No. 1031 for the NAC Magnastor Storage System2022-04-26026 April 2022 Supplemental Information to Exemption to the Requirements of Certificate of Compliance No. 1031 for the NAC Magnastor Storage System ML22108A1972022-04-18018 April 2022 RAI Response to Nac'S Amendment Request for the NAC International Magnastor Cask System Amendment No. 12 ML22095A1012022-04-12012 April 2022 Application for Amendment No. 12 to the Model No. Magnastor Storage Cask - Request for Additional Information ML22101A0042022-04-0707 April 2022 Registration of Use of Casks to Store Spent Fuel ML22090A0982022-03-31031 March 2022 Independent Spent Fuel Storage Installation - Request for Exemption from NAC-MAGNASTOR Certificate of Compliance 72-1031 - Cask Lid Design Requirements ML22082A2762022-03-23023 March 2022 Independent Spent Fuel Storage Installation - Registration of Dry Spent Fuel Transportable Storage Canister Identification Numbers AMZDFX164 and AMZDFX168 and Vertical Concrete Cask Identification Numbers ML22077A7692022-03-18018 March 2022 Supplement to Nac'S Amendment Request for the NAC International Magnastor Cask System Amendment No. 12 ML22024A3742022-01-24024 January 2022 Submission of an Amendment Requestfor the NAC International Magnastor Cask System Amendment No. 12 ML22018A0592022-01-11011 January 2022 NAC International, Inc., Submittal of Supplemental Information to the Nrc'S Request for Additional Information for the NAC International Magnastor Cask System Amendment No.11 ML21277A0452021-09-24024 September 2021 Submittal of Final Safety Analysis Report (Fsar), Revision 12, for the NAC Magnastor Cask System ML21251A5302021-09-0202 September 2021 Supplemental Responses to the NRCs Request for Additional Information for the NAC International Magnastor Cask System Amendment No. 10 ML21242A0502021-08-23023 August 2021 Submission of Responses to the Nrc'S Request for Additional Information for the NAC International Magnastor Cask System Amendment No. 11 ML21174A0732021-07-12012 July 2021 Application for Amendment No. 10 to the Model No. Magnastor Storage Cask - Second Request for Additional Information ML21183A1872021-07-0202 July 2021 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Transportable Storage Canister Identification Number AMZDFX163 and Vertical Concrete Cask Identification Number AMZDNE163 ML21102A0872021-05-0707 May 2021 NRC Review of NAC Internationals Response Letter to Inspection Report 07201015/2020201 Notice of Violation EA-20-066; and Response to Disputed Notice of Violation ML21118A0432021-04-20020 April 2021 NAC International, Inc., Supplemental Responses to the NRCs Request for Additional Information for the Cask System Amendment No. 10 ML21078A5142021-03-19019 March 2021 Independent Spent Fuel Storage Installation - Registration of Dry Spent Fuel Transportable Storage Canister Identification Number AMZDFX161 and Vertical Concrete Cask Identification Number AMZDNE161 ML21047A1992021-02-26026 February 2021 Application for Amendment No. 11 to the Model No. Magnastor Storage Cask - First Request for Additional Information ML21067A0422021-02-25025 February 2021 Submission of Responses to the Nrc'S Request for Additional Information for the NAC International Magnastor Cask System Amendment No. 10 ML21050A3262021-02-19019 February 2021 Independent Spent Fuel Storage Installation - Registration of Dry Spent Fuel Transportable Storage Canister ML21036A0372021-01-29029 January 2021 NAC International Reply to Notice of Violation (EA-20-066), January 29, 2021 (Docket Nos.: 72-1015, 72-1025, 72-1031) ML20351A4512020-12-16016 December 2020 License Amendment Request, Proposed Revision to License Conditions and Permanently Defueled Technical Specifications for Permanent Removal of Irradiated Fuel from the Spent Fuel Pool (ISFSI-Only Tech Specs) ML20307A1172020-11-10010 November 2020 Transmittal Letter - Amendment No. 9 to Certificate of Compliance No. 1031 for Magnastor Storage System 2024-01-08
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Text
Atlanta Corporate Headquarters ANAC 3930 East Jones Bridge Road, Suite 200 f .. INT~RNATIONA~ Norcross, GA 30092 Phone 770-447-1144 www.nacintl.com January 11, 2022 U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 Attn: Document Control Desk
Subject:
Submission of Supplemental Information to the NRC's Request for Additional Information for the NAC International MAGNASTOR Cask System Amendment No.11 Docket No. 72-1031 EPID No. L-2020-LLA-0158
References:
- 1. U.S. Nuclear Regulatory Commission (NRC) Certificate of Compliance (CoC)
No. 1031 for the NAC International MAGNASTOR Cask System, Amendment No. 9, December 7, 2020
- 2. MAGNASTOR Cask System Final Safety Analysis Report (FSAR),
Revision 10, NAC International, February 2019
- 3. ED20200085, Submission of a Request to Amend the U.S. Nuclear Regulatory Commission Certificate of Compliance No. 1031 for the NAC International MAGNASTOR Cask System, July 14, 2020
- 4. U.S. Nuclear Regulatory Commission (NRC), Application for Amendment No. 11 to the Model No. MAGNASTOR Storage Cask- First Request for Additional Information, February 26, 2021
- 5. ED20210128, Submission of Responses to the NRC's Request for Additional Information for the NAC International MAGNASTOR Cask System Amendment No. 11, August 23, 2021 NAC International (NAC) hereby submits supplemental information to the NRC's Request for Additional Information (RAI) (Reference 4). Enclosure 1 of this supplement contains NAC proprietary calculation 71160-3085 Revision 3 along with the associated data files. Enclosure 2 of this supplement contains the MAGNASTOR Thermal Test Report, 71160-R-04 Rev 0. The requested Emissivity Report Form is Attachment B of the Thermal Test Report document. Enclosure 3 contains the requested Peterson Procedure PSP-100189-02, Rev. 2. As previously discussed, the maximum average helium temperature reported in Section 4.11.2.2.1 of the revised FSAR in submittal 21B is correct. The previous submittal' s value was a typographical error. The 21B submittal corrected this. The corrected value is also below the bounding value in the currently updated FSAR Revision 12. NAC requests that NAC proprietary information contained in Enclosures 1, 2, and 3 to be withheld from public disclosure. In accordance with 10 CFR 2.390 an affidavit is provided in Attachment 1 specifically requesting the NRC withhold this proprietary information from public disclosure.
ED20220002
ANAC fdfll NTERNATIONAL U.S. Nuclear Regulatory Commission January 11, *2022
-Page 2 of2 Ifyou have any comments or questions, please contact me onmy direct line at 678-328-1236.
Sincere~
Wren Fowler Director, Licensing Engineering
Attachment:
Attachm*ent 1 - NAC International Affidavit Pursuant to 10 CFR 2.390
Enclosures:
- Supplemental MAGNASTOR Calculation, 71160-30~5 Rev 3 Enclosure 2 - MAGNASTOR Thermal Test Repoit, 71 I 60~R-04 Rev 0 Enclosure 3 - Peterson Procedure PSP-100189-02, Revision 2, February 5, 2018 ED20220002
NAC AINT~RNATIQNA~ NAC INTERNATIONAL AFFIDAVIT PURSUANT TO 10 CFR 2.390 George Carver (Affiant), Vice President, Engineering and Support Services, of NAC International, hereinafter referred to as NAC, at 3930 East Jones Bridge Road, Peachtree Comers, Georgia 30092, being duly sworn, deposes and says that:
- 1. Affiant has reviewed the information described in Item 2 and is personally familiar with the trade secrets and privileged information contained therein, and is authorized to request its withholding.
- 2. The information to be withheld includes the following NAC Proprietary Information that is being provided to support the technical review of NAC's Request for a Certificate of Compliance (CoC)
(No. 1031) for the NAC International MAGNASTOR Cask System.
- Enclosure 1, NAC International Proprietary Calculation and Data Disk lof 1 o 71160-3085, Rev 3, MAGNASTOR Concrete Cask and PWR Canister Thermal Evaluation for High Heat Loads
- Enclosure 2 - MAGNASTOR Thermal Test Report, 71160-R-04 Rev 0
- Enclosure 3 - Peterson Procedure PSP-100189-02, Revision 2, February 5, 2018 NAC is the owner of the information contained in the above documents. Thus, all of the above identified information is considered NAC Proprietary Information.
- 3. NAC makes this application for withholding of proprietary information based upon the exemption from disclosure set forth in: the Freedom oflnformation Act ("FOIA"); 5 USC Sec. 552(b)(4) and the Trade Secrets Act; 18 USC Sec. 1905; and NRC Regulations 10 CFR Part 9.l 7(a)(4), 2.390(a)(4), and 2.390(b)(l) for "trade secrets and commercial financial information obtained from a person, and privileged or confidential" (Exemption 4). The information for which exemption from disclosure is herein sought is all "confidential commercial information," and some portions may also qualify under the narrower definition of "trade secret," within the meanings assigned to those terms for purposes of FOIA Exemption 4.
- 4. Examples of categories of information that fit into the definition of proprietary information are:
- a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by competitors of NAC, without license from NAC, constitutes a competitive economic advantage over other companies.
- b. Information that, if used by a competitor, would reduce their expenditure of resources or improve their competitive position in the design, manufacture, shipment, installation, assurance of quality or licensing of a similar product.
- c. Information that reveals cost or price information, production capacities, budget levels or commercial strategies of NAC, its customers, or its suppliers.
- d. Information that reveals aspects of past, present or future NAC customer-funded development plans and programs of potential commercial value to NAC.
- e. Information that discloses patentable subject matter for which it may be desirable to obtain patent protection.
The information that is sought to be withheld is considered to be proprietary for the reasons set forth in Items 4.a, 4.b, and 4.d.
- 5. The information to be withheld is being transmitted to the NRC in confidence.
- 6. The information sought to be withheld, including that compiled from many sources, is of a sort customarily held in confidence by NAC, and is, in fact, so held. This information has, to the best of ED20220002 Page 1.of 3
INAC .
- 1. !NTERNATIONA~
NACINTERNATIONAL AFFIDAVIT PURSUANT TO 10 CFR 2.390 my knowledge and belief, consistently been held in confidence by NAC. No public disclosure has been made, and it is not available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements, which provide for maintenance of the information in confidence. Its initial designation as proprietary information and the subsequent steps taken to prevent its unauthorized disclosure are as set forth in Items 7 and 8 following.
- 7. Initial approval of proprietary treatment of a document/information is made by the Vice President, Engineering, the Project Manager, the Licensing Specialist, or the Director, Licensing - the persons most likely to know the value and sensitivity of the information in relation to industry knowledge.
Access to proprietary documents within NAC is limited via "controlled distribution" to individuals on a "need to know" basis. The procedure for external release of NAC proprietary documents typically requires the approval of the Project Manager based on a review of the documents for technical content, competitive effect and accuracy of the proprietary designation. Disclosures of proprietary documents outside of NAC are limited to regulatory agencies, customers and potential customers and their agents, suppliers, licensees and contractors with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.
- 8. NAC has invested a significant amount of time and money in the research, development, engineering and analytical costs to develop the information that is sought to be withheld as proprietary. This information is considered to be proprietary because it contains detailed descriptions of analytical approaches, methodologies, technical data and/or evaluation results not available elsewhere. The precise value of the expertise required to develop the proprietary information is difficult to quantify, but it is clearly substantial.
- 9. Public disclosure of the information to be withheld is likely to cause substantial harm to the competitive position of NAC, as the owner of the information, and reduce or eliminate the availability of profit-making opportunities. The proprietary information is part of NAC's comprehensive spent fuel storage and transport technology base, and its commercial value extends beyond the original development cost to include the development of the expertise to determine and apply the appropriate evaluation process. The value of this proprietary information and the competitive advantage that it provides to NAC would be lost if the information were disclosed to the public. Making such information available to other parties, including competitors, without their having to make similar investments of time, labor and money would provide competitors with an unfair advantage and deprive NAC of the opportunity to seek an adequate return on its large investment.
ED20220002 Page 2 of 3
ANAC
~, .INTERNATIQNA~
NAC INTERNATIONAL AFFIDAVIT PURSUANT TO 10 CFR 2.390 STATE OF GEORGIA, COUNTY OF GWINNETT Mr. George Carver, being duly sworn, deposes and says:
That he has read the foregoing affidavit and the matters stated herein are true and correct to the best of his knowledge, information and belief. ~
ee Comers, Georgia, this ~ d a y o f ~ , 2022.
George Carver Vice President, Engineering and Support Services NAC International ~- -c-~---**
ED20220002 Page 3 of3