ML18066A080

Submittal of Response to Request for Holding Information from Public Disclosure

ML18066A080
Person / Time
Site:	Aerotest
Issue date:	02/28/2018
From:	Slaughter D Aerotest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML18066A080 (3)

Text

AEROTEST OPERATIONS, INC.

3455 FOSTORIA WAY

• SAN RAMON, CA 94583 * (925) 866-1212

• FAX (925) 866-1716 February 28, 2017 ATTENTION: Document Control Desk U.S. Nuclear Regulatory Commission White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 AEROTEST RADIOGRAPHY AND RESEARCH REACTOR DOCKET NO. 50-228/LICENSE NO. R-98.

RESPONSE TO REQUEST FOR HOLDING INFORMATION FROM PUBLIC DISCLOSURE Ladies and Gentlemen:

Enclosed please find Aerotest's affidavit with corrected requests for a hold on proprietary information in Chapter 15, USAR from public disclosure.

Should you have any questions or require additional information regarding this submission, please contact AO President David M. Slaughter, Ph.D. at (801) 631 5919 or dmsraven@gmail.com Since David M.

laughter, Ph.D.

President, Aerotest Operations, Inc.

Enclosures:

1.

Non-Proprietary Chapter 15, USAR

2.

Proprietary Chapter 15, USAR

3.

AO Affidavit NOTE: Enclosures to this document contain confidential information submitted under 10 CFR 2.390(a)(4).

AFFIDAVIT I, David M. Slaughter, hereby affirm and state as follows:

1. I am the President of Aerotest Operations, Inc authorized to execute this affidavit on behalf of Aerotest Operations.

2. The information contained in brackets found in Chapter 15, USAR dated 2017. The proprietary information includes sensitive business information related to Aerotest Operations. This information should be held in confidence by the NRC and withheld from public disclosure.

3. In making this application for withholding of proprietary information of which it is the Aerotest President believes that the information qualifies for withholding under the exemption from disclosure set forth in the Freedom of Information At ("FOIA"), 5 U.S.C. Section 552(b)(4), the Trade Secrets Act, 18 U.S.C. Section 1905, and NRC regulations 10 CFR 2.390(a)(4) for trade secrets and commercial information because:

i.

This information is and has been held in confidence by Aerotest Operations.

11.

This information is of a type that is customarily held in confidence by Aerotest, and there is a rational basis for doing so because the information includes sensitive business information pertaining to the strategic nature of research, development and investigative services.

111.

The information is being transmitted to the NRC in confidence.

1v.

This information is not available in public sources and could not be gathered readily from other publicly available information.

v.

• Public disclosure of this information would create substantial harm to the competitive position of Aerotest by disclosing certain business decisions Aerotest has made or is considering and the analysis that went behind those decisions.

Development and evaluation of this commercial information was achieved at, and disclosure could lead to additional, significant cost to Aerotest.

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Subscribed and sworn before me, a Notary Public, in and for the State of California, thi~* day of February 2018.

Witness my hand and Notarial Seal.

My Commission Expires:

Notary Public Date:

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Jurat Certificate -California* only A notary public or other officer completing this certificate verifies only the identity of the individual who signed the document to Which this certificate is attached, and not the truthfulness, accuracy, or validity of that document.

State of California

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proved to me on the basis of satisfactory evidence to be the person(s) who appeared before me.

Place Seal Here Description of Attached Document Type or Title of Document

• I Document Date Signer(s) Other Than Named Above DSG 3018 CA (Rev 02-2/lS)

Signature __

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