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MONTHYEARML20115E3782019-10-0303 October 2019 Independent Spent Fuel Storage Installation Exemption Safety Evaluation Report Project stage: Approval ML19276D3982019-10-0303 October 2019 Exemption Request to Load and Store Spent Fuel in HI-STORM FW Spent Fuel Casks Utilizing Amendment 1, Revision 1 to CoC No. 1032 Project stage: Other ML20014E6772020-01-0909 January 2020 Fws List of Threatened and Endangered Species That May Occur with Respect to the McGuire Exemption Request Project stage: Other ML20015A3142020-01-14014 January 2020 Package: Exemption Request McGuire Nuclear Facility Project stage: Request ML20049A0822020-01-31031 January 2020 Holtec International - HI-STORM 100 Storage CoC Renewal Application Project stage: Other ML20049A0812020-01-31031 January 2020 Holtec International - HI-STORM 100 Storage CoC Renewal Application Project stage: Request ML20055F3372020-02-20020 February 2020 Conversation Record - Clarification Call (02/20/2020) on RAI 1 for CoC 1040 Umax Amendment 4 Project stage: RAI ML20064F6162020-02-29029 February 2020 January 15, 2020, Summary of Meeting with Holtec International, Inc., to Discuss the Upcoming Submittal of the Application for Renewal of the Storage Certificate of Compliance No. 1014 for the HI-Storm 100 Cask System Project stage: Meeting ML20063M0152020-03-0303 March 2020 HI-STORM 100 Renewal Presubmittal Meeting (Holtec Slides, 1-15-20) Project stage: Meeting ML20064E6222020-03-0303 March 2020 U.S. Nuclear Regulatory Commission Approval of NAC International Request for Withholding Information from Public Disclosure for Coc 1025 Renewal (CAC No. 001028) Project stage: Withholding Request Acceptance ML20065J4272020-03-0505 March 2020 Submittal of Renewal Application for the TN-32 Dry Storage Cask - CoC 1021 Project stage: Request ML20071F1562020-03-0505 March 2020 Interim Storage Partners, LLC - Affidavit Project stage: Other ML20071F1532020-03-0505 March 2020 Interim Storage Partners, LLC - Supplemental Information in Support of Nrc'S Environmental Review Project stage: Supplement ML20071J0552020-03-0505 March 2020 Notice of Cancelled Meeting with the U.S. Department of Energy, Idaho Operations Office to Discuss the Upcoming Submittal of the Application for Renewal of the Idaho Spent Fuel Facility License (SNM-2512) Project stage: Meeting ML20065K2162020-03-0505 March 2020 Notice of Meeting with U.S. Department of Energy, Idaho Operations Office to Discuss the Upcoming Submittal of the Application for Renewal of the Idaho Spent Fuel Facility License (SNM-2512) Project stage: Meeting ML20065L3442020-03-0606 March 2020 Amendment No. 15 to Certificate of Compliance No. 1014 for the Hi-Storm 100 Multipurpose Canister Storage System - Request for Additional Information Project stage: RAI ML20066K5782020-03-0606 March 2020 Acceptance Review of Request for Amendment No. 7 to Certificate of Compliance No. 1032 for the HI-STORM Flood/Wind Multipurpose Canister Storage System Project stage: Acceptance Review ML20065N2812020-03-0909 March 2020 ISFSI Preamble-License Renewal Order Project stage: Other ML20065N2852020-03-0909 March 2020 ISFSI Renewed Technical Specifications Project stage: Other ML20065N2772020-03-0909 March 2020 ISFSI Renewal Cover Letter Project stage: Other ML20065N2782020-03-11011 March 2020 ISFSI FRN Notice of Issuance for License Renewal Project stage: Other ML20071D9942020-03-11011 March 2020 Submittal of HI-STAR 100 Updated FSAR, Revision 4 Project stage: Request ML20076D6962020-03-11011 March 2020 Interim Storage Partners, LLC - Submittal of Clarifications to Support Nrc'S Continued Review of the Safety Case for the WCS CISF Project stage: Other ML20104C0152020-03-30030 March 2020 International - Amendment No. 4 to the HI-STORM Umax Canister Storage System Project stage: Other ML20104C0202020-03-30030 March 2020 International - HI-STORM Umax Amendment 4 Responses to Requests for Additional Information - Supplemental Information Project stage: Supplement ML20104C0192020-03-30030 March 2020 International - Affidavit for Kimberly Manzione Project stage: Other ML20104C0182020-03-30030 March 2020 International - HI-STORM Umax Amendment 4 FSAR - Changed Pages Project stage: Other ML20104C0162020-03-30030 March 2020 International - Proposed HI-STORM Umax CoC Amendment 4 Appendix a - Changed Pages Project stage: Other ML20091L0642020-03-31031 March 2020 Enclosure 1 - Request for Additional Information - Non-Proprietary Project stage: RAI ML20091L0632020-03-31031 March 2020 Transmittal Letter - CoC 1042 Amendment Number 2 Request for Additional Information Project stage: RAI ML20065N2802020-03-31031 March 2020 ISFSI License Renewal SER Project stage: Other ML20104C0482020-03-31031 March 2020 International - HI-STORM Umax Amendment 3 Responses to Requests for Additional Information Project stage: Response to RAI ML20101P3992020-03-31031 March 2020 Interim Storage Partners, LLC - Submittal of Draft Responses for Several Rals and Associated Document Markups from First Request for Additional Information, Parts 1, 2 and Clarifications Project stage: Draft Request ML20105A1352020-03-31031 March 2020 Enclosure 1 - Affidavits Project stage: Other ML20099A1802020-04-0606 April 2020 Application for Renewal of the Certificate of Compliance No. 1014 for the Hi-Storm 100 Storage Cask System Accepted for Review (Cac/Epid Nos. 001028/L-2020-RNW-0007) Project stage: Other ML20105A1732020-04-0606 April 2020 Interim Storage Partners, LLC - Affidavits Project stage: Other ML20105A1722020-04-0707 April 2020 Interim Storage Partners, LLC - Submittal of Supplemental Information in Support of RAI, Part 3 Project stage: Supplement ML20105A1342020-04-0707 April 2020 Submission of ISP Responses for RAIs and Associated Document Markups from First Request for Additional Information, Parts 2, 3, and 4 Project stage: Request ML20105A1392020-04-0707 April 2020 Enclosure 8 - Referenced Documents Project stage: Other ML20105A1362020-04-0707 April 2020 Enclosure 3 - RAIs and Responses Project stage: Other ML20105A1372020-04-0707 April 2020 Enclosure 5 - La Changed Pages Project stage: Other ML20105A1382020-04-0707 April 2020 Enclosure 7 - SAR Changed Pages Project stage: Other ML20100F2952020-04-0909 April 2020 Tn Americas LLC - Submittal of Renewal Application for the TN-68 Dry Storage Cask - CoC 1027 Project stage: Request ML20104A0402020-04-10010 April 2020 Request for Additional Information for HI-STAR 100 CoC Renewal Application Project stage: RAI ML20111A2382020-04-13013 April 2020 International - HI-STORM Umax Amendment 4 Responses to Requests for Additional Information - Supplemental Information Project stage: Supplement ML20111A2392020-04-13013 April 2020 Attachment 1: HI-STORM Umax Amendment 4 RAI Supplemental Response (non-proprietary) Project stage: Supplement ML20111A2402020-04-13013 April 2020 Attachment 2: Proposed HI-STORM Umax CoC Amendment 4 Appendix a - Changed Pages (non-proprietary) Project stage: Other ML20094G4822020-04-15015 April 2020 GEH-Morris QAP Rev 4 Approval Project stage: Other ML20092L1732020-04-17017 April 2020 Safety Evaluation Report for the Pacific Gas and Electric Company Humboldt Bay Independent Spent Fuel Storage Installation Quality Assurance Plan HBI-L6 Revision 0 Project stage: Approval ML20120A2282020-04-29029 April 2020 Tn Americas LLC, Response to the Request for Additional Information to Application for Certificate of Compliance No. 1042, Amendment No. 2, to NUHOMS Eos System, (Docket No. 72-1042, CAC No. 001028 EPID: L-2019-LLA-0078)- Request for Extens Project stage: Request 2020-03-05
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Category:Legal-Affidavit
MONTHYEARML24179A0592024-06-26026 June 2024 Submittal of Responses to the Nuclear Regulatory Commission Request for Additional Information for NAC International Universal Storage System (Ums) Amendment No. 10 ML23291A0952023-10-10010 October 2023 NAC International, Inc., Submittal of Data Files to Support the Nuclear Regulatory Commission'S (NRC) Review of NAC-UMS Amendment No. 1O (Submittal 23A) ML22209A0792022-07-28028 July 2022 NAC, Supplement to the Nuclear Regulatory Commission'S (NRC) Request for Additional Information for the Request to Renew the NAC-UMS Cask System Certificate of Compliance No. 1015 ML22062A7622022-03-0303 March 2022 NAC International, Inc., Submission of Responses to the Nuclear Regulatory Commission'S (NRC) Request for Additional Information for the Request to Renew the NAC-UMS Cask System Certificate of Compliance No. 1015 ML21222A1762021-07-30030 July 2021 NAC International, Inc., Submittal of a Request to Amend the U.S. Nuclear Regulatory Commission Certificate of Compliance No. 1015 for the NAC-UMS Cask System ML20310A1482020-11-0202 November 2020 NAC International Submission of Supplement Information to Nrc'S Pre-Decisional Enforcement Conference (Non-Proprietary Version) ML20293A1022020-10-13013 October 2020 NAC International, NAC-UMS System, Certificate of Compliance (CoC) Renewal Application ML20122A1942020-04-24024 April 2020 NAC International, Submittal of Supplement to Amend the NRC Certificate of Compliance No. 1015 for the NAC-UMS Cask System 2024-06-26
[Table view] Category:Letter
MONTHYEARML24179A0592024-06-26026 June 2024 Submittal of Responses to the Nuclear Regulatory Commission Request for Additional Information for NAC International Universal Storage System (Ums) Amendment No. 10 ML24141A1162024-05-20020 May 2024 Request for Additional Information for the Technical Review of the Application for Amendment Nos. 5 to 9, Rev. 1 & Amendment No. 10, Rev. 0 to Coc No. 1015 ML23283A2382023-12-0707 December 2023 NAC International, Inc. - U.S. Nuclear Regulatory Commission Inspection Report 72-1031/2023-201 ML23283A2492023-10-10010 October 2023 Transmittal Letter and Affidavit, Submission of an Amendment Request for the NAC International Universal Storage System (Ums) Amendment No. 10 and Revisions to Amendments 5 to 9 ML23291A0952023-10-10010 October 2023 NAC International, Inc., Submittal of Data Files to Support the Nuclear Regulatory Commission'S (NRC) Review of NAC-UMS Amendment No. 1O (Submittal 23A) ML22355A1192022-12-21021 December 2022 NAC International - Request to Withdraw Administrative Controls for Adverse Weather Events During Operations from NAC-UMS CoC Renewal Application ML22209A0792022-07-28028 July 2022 NAC, Supplement to the Nuclear Regulatory Commission'S (NRC) Request for Additional Information for the Request to Renew the NAC-UMS Cask System Certificate of Compliance No. 1015 ML22202A0212022-07-22022 July 2022 Transmittal Letter NAC-UMS Amendment 9 ML22077A0762022-03-18018 March 2022 Replacement Page for Responses to the Nuclear Regulatory Commission'S (NRC) Request for Additional Information for the Request to Renew the NAC-UMS Cask System Certificate of Compliance No. 1015 ML22062A7622022-03-0303 March 2022 NAC International, Inc., Submission of Responses to the Nuclear Regulatory Commission'S (NRC) Request for Additional Information for the Request to Renew the NAC-UMS Cask System Certificate of Compliance No. 1015 ML21334A5092021-12-21021 December 2021 Request for Additional Information for the Technical Review of the Application for Renewal of the Certificate of Compliance No. 1015 (Cac/Epid Nos. 001028/L-2020-RNE-0031) ML21253A2402021-09-20020 September 2021 NAC-UMS Transmittal Letter ML21064A4092021-08-0909 August 2021 Congressional Letters: Amendment to List of Approved Spent Fuel Storage Casks: NAC-UMS, Certificate of Compliance No. 1015, Amendment 8 ML21222A1762021-07-30030 July 2021 NAC International, Inc., Submittal of a Request to Amend the U.S. Nuclear Regulatory Commission Certificate of Compliance No. 1015 for the NAC-UMS Cask System 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 ML21060B2982021-03-25025 March 2021 Letter: NAC-UMS CoC 1015 Renewal Acceptance Letter ML21070A3242021-03-0404 March 2021 NAC International, Inc - 10 CFR 72.242 Reportable Licensing Basis Thermal Evaluation Deficiency (Fuel Rod Assembly Effective Thermal Conductivity) for the NAC-UMS Dry Cask Storage Systems ML21139A1212021-02-0909 February 2021 NAC Request for Clarification of LCO 3.1.6 for NAC-UMS Storage Cask 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) ML20330A2812020-12-21021 December 2020 NAC International Notice of Violation; U.S. Nuclear Regulatory Commission Inspection Report No.: 07201015/2020201 (EA-20-066) ML20328A1292020-11-23023 November 2020 Proprietary Determination Letter for 1015 Renewal 10-13-20 Submittal v00 - Letter ML20310A1482020-11-0202 November 2020 NAC International Submission of Supplement Information to Nrc'S Pre-Decisional Enforcement Conference (Non-Proprietary Version) ML20293A1022020-10-13013 October 2020 NAC International, NAC-UMS System, Certificate of Compliance (CoC) Renewal Application ML20225A0322020-09-0303 September 2020 NRC Choice Letter to NAC International with Attached Safety Inspection Report, IR 0721015/2020201, February 24-27, 2020 and July 22, 2020, Inspection of NAC International in Norcross, Georgia ML20170A8032020-06-25025 June 2020 Letter Issuing RAI for NAC-UMS Amendment 8 ML20122A1942020-04-24024 April 2020 NAC International, Submittal of Supplement to Amend the NRC Certificate of Compliance No. 1015 for the NAC-UMS Cask System ML20076A5462020-03-17017 March 2020 Letter-NAC-UMS Amendment 8 Acceptance ML19182A0322019-07-0505 July 2019 Letter to J. Brown Maine Yankee Atomic Power Company Exemption Request from Certain Requirements of 10 CFR 72.214 for the ISFSI ML19182A0402019-07-0505 July 2019 Letter to P. Dostie Maine Yankee Atomic Power Company Exemption Request from Certain Requirements of 10 CFR 72.212 and 10 CFR 72.214 for the ISFSI ML19183A2742019-07-0202 July 2019 Letter to W. Fowler Amendment No. 7 to Certificate of Compliance No. 1015 for the NAC-UMS Storage System ML19112A0242019-04-11011 April 2019 Independent Spent Fuel Storage Installation, Reference Correction - Request for Exemption from Certain Requirements of 10 CFR 72.212 and 10 CFR 72.214 ML19038A0572019-01-29029 January 2019 Independent Spent Fuel Storage Installation (ISFSI) - Request for Exemption from Certain Requirements of 10 CFR 72.212 and 10 CFR 72.214 ML19031B3412019-01-21021 January 2019 Request for Exemption from Certain Requirements of 10 CFR 72.212 and 10 CFR 72.214 for the Maine Yankee Independent Spent Fuel Storage Installation ML18333A2372018-12-0404 December 2018 Letter to W. Fowler Amendment No. 6 to Certificate of Compliance No. 1015 for the NAC-UMS Storage System ML19044A4532018-08-14014 August 2018 Rin 3150-AK12 Draft Congressional Letters for NAC CoC Amendment 6 081418 Rasb ML17356A2802017-12-22022 December 2017 Letter to W. Fowler Application for Amendment No. 6 to the Model No. NAC-UMS Storage Cask - Request for Additional Information (W/Enclosure) ML17244A8972017-08-31031 August 2017 ISFSI - Registration of Dry Spent Fuel Transportable Storage Canister, Identification Number AMZDFX151 and Vertical Concrete Cask Identification Number AMZDNE151 ML17235B2692017-08-23023 August 2017 Independent Spent Fuel Storage Installation - Registration of Dry Spent Fuel Transportable Storage Canister Identification Number AMZDFX150 and Vertical Concrete Cask Identification Number AMZDNE150 ML17216A8362017-08-0303 August 2017 ISFSI - Registration of Dry Spent Fuel Transportable Storage Canister Identification No. AMZDFX149 and Vertical Concrete Cask Identification No. AMZDNE149 ML17180A5082017-06-29029 June 2017 Independent Spent Fuel Storage Installation - Registration of Dry Spent Fuel Transportable Storage Canister Identification Nos. AMZDFX146 and AMZDFX147 and Vertical Concrete Cask Identification Nos.... ML17160A4722017-06-0909 June 2017 Independent Spent Fuel Storage Installation - Registration of Dry Spent Fuel Transportable Storage Canister ML17069A5072017-03-10010 March 2017 ISFSI- Registration of Dry Spent Fuel Transportable Storage Canister Identification No. AMZDFX144 and Vertical Concrete Cask Identification No. AMZDNE144 ML17062B0972017-03-0303 March 2017 Independent Spent Fuel Storage Installation - Registration of Dry Spent Fuel Transportable Storage Canister Identification No. AMZDFX143 and Vertical Concrete Cask Identification No. AMZDNE143 ML17053A1842017-02-22022 February 2017 Independent Spent Fuel Storage Installation - Registration of Dry Spent Fuel Transportable Storage Canister Identification No. AMZDFX141 and Vertical Concrete Cask Identification No. AMZDNE141 ML16308A3492016-11-0303 November 2016 Letter to J. S. Brown Maine Yankee Independent Spent Fuel Storage Installation Request for Exemption from Specific Requirements of 10 CFR 72.212 and 10 CFR 72.214-Withdrawal (CAC No. L25110) ML16285A2702016-09-27027 September 2016 Independent Spent Fuel Storage Installation - Withdrawal of Request for Exemption from Certain Requirements of 10 CFR 72.212 and 10 CFR 72.214 ML16187A0512016-07-0101 July 2016 ISFSI - Registration of Dry Spent Fuel Transportable Storage Canister Identification No. AMZDFX138 ML16175A5782016-06-22022 June 2016 ISFSI - Registration of Dry Spent Fuel Transportable Storage Canister Id No. AMZDFX136 ML16162A7622016-06-10010 June 2016 ISFSI - Registration of Dry Spent Fuel Transportable Storage Canister Identification No. AMZDFX135 ML16160A4182016-06-0808 June 2016 ISFSI - Registration of Dry Spent Fuel Transportable Storage Canister Identification No. AMZDFX134 2024-06-26
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Atlanta Corporate Headquarters 3930 East Jones Bridge Road, Suite 200 Peachtree Corners, GA 30092 Phone 770-447-1144 www.nacintl.com October 13, 2020 U.S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Document Control Desk
SUBJECT:
NAC International, NAC-UMS System, 72-1015 Certificate of Compliance (CoC) Renewal Application Pursuant to 10 CFR 72.240(b) and (c), NAC International hereby submits an application for renewal of the NAC-UMS System Certificate of Compliance (CoC). The current CoC expires on November 20, 2020. The application for the renewal of the CoC is contained in Enclosure 1 and was prepared in accordance with applicable provisions of 10 CFR Part 72, Subpart L. NAC is requesting a CoC renewal period of 40 years.
If you have any comments or questions, please contact me on my direct line at 678-328-1236.
Director, Licensing Engineering
Enclosures:
- 1. Application for Renewal of the NAC-UMS System Coe
- 2. Appendix A Aging Management Programs
- 3. Appendix B Time-Limited Aging Analyses
- 4. Appendix C Final Safety Analysis Report Changed Pages
- 5. Appendix D Proposed Certificate of Compliance) and Technical Specification Changes
- 6. Appendix E Pre-Application Inspection Report
- 7. Appendix F Design Basis Document Review ED20200120
ANAC f"_INT~RNATIQNA~
STATE OF GEORGIA, COUNTY OF GWINNETT I, George Carver (Affiant), Vice President, Engineering and Support Services, of NAG International being duly sworn, state that I am duly authorized to execute and file this response on behalf of NAG. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other NAG employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to be re
George Carver Vice President, Engineering and Support Services NAG International Subscribed and sworn before me this )3 day of _D_c_-c_____, 2020.
~f#e:(~
Notary Public ED20200120
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 Corners, 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.
1015) for the NAC International UMS Cask System.
- Appendix B, Time-Limited Aging Analysis (TLAA) - Proprietary o Fatigue Evaluation of MPC and UMS Storage System Components for Extended Storage, 30013-2001, Revision 0 o Corrosion Analysis of UMS VCC Steel Components for Extended Storage, 30013-2002, Revision 2 o Aging Analyses for MPC/UMS Neutron Absorber and Neutron Shield Components (Storage/Transfer), 30013-5001, Revision 0Enclosure 4,
- Appendix E, Maine Yankee NAC-UMS System Pre-Application Inspection Report 30013-R-01 Revision 0 - Proprietary Version 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 of Information Act ("FOIA"); 5 USC Sec. 552(b)(4) and the Trade Secrets Act; 18 USC Sec. 1905; and NRC Regulations 10 CFR Part 9.17(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.
ED20200120 Page 1 of3
NACINTERNATIONAL AFFIDAVIT PURSUANT TO 10 CFR 2.390 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 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.
ED20200120 Page 2 of3
ANAC I, JNTERNATIQNA~
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.
Executed at Peachtree Comers, Georgia, this 13 day of DC--\:-- 2020.
George Carver Vice President, Engineering and Support Services NAC International Subscribed and sworn before me this l3 day of _D~e-~t~---' 2020.
Notary Public ED20200120 Page 3 of3