ML19252A130

Interim Storage Partners, Llc., Submission of Draft Responses for Several Rals and Associated Document Markups from First Request for Additional Information, Part 2

ML19252A130
Person / Time
Site:	Consolidated Interim Storage Facility
Issue date:	08/30/2019
From:	Boshoven J Consolidated Interim Storage Facility
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
Shared Package
ML19252A132	List: ML19252A130 ML19252A131 ML19252A133
References
CAC 001028, E-54837, EPID L-2017-NEW-0002
Download: ML19252A130 (4)

Text

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lQl INTERIM STORAGE PARTNERS August 30, 2019 E-54837 Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U. S. Nuclear Regulatory Commission Attn: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852

Subject:

Submission of ISP Draft Responses for Several RAls and Associated Document Markups from First Request For Additional Information, Part 2, Docket 72-1050 CAC/EPID 001028/L-2017-NEW-0002

Reference:

1.

Letter from John-Chau Nguyen (NRC) to Jeffery D. Isakson, "Interim Storage Partners LLC's License Application To Construct And Operate The Waste Control Specialists Consolidated Interim Storage Facility, Andrews County, Texas, Docket No. 72-1050 -

First Request For Additional Information, Part 3," dated April 23, 2019

2.

Letter from Jack Boshoven to John-Chau Nguyen (NRC), "Interim Storage Partners (ISP) First Request for Additional Information (RAI) Proposed Submittal Schedule, Docket 72-1050 CAC/EPID 001028/L-2017-NEW-0002," E-54395, dated May 31, 2019 Interim Storage Partners LLC hereby submits its draft responses to RAls from Reference [1] in preparation for meetings to be scheduled with NRC staff for discussion.

The draft responses and associated application change pages being submitted are consistent with those identified in Table 4 of Reference [2]. Enclosure 2 (proprietary) contains the draft responses to the RAls and associated marked up pages for the Environmental Report and Safety Analysis Report. Enclosure 3 (non-proprietary) is the non-proprietary version of Enclosure 2. Affidavits (Enclosure 1) are provided for the proprietary information.

Please note that the referenced Enclosures in the RAI responses that include reports, spreadsheets, Maps, and the Waste Control Specialists LLRW License Application are not included in this submittal, but will be included when the final responses to these f}Jv/ 5

~ Z D tJN5>2b P.O. Box 1129

• Andrews, Texas 79714

• interimstoragepartners.com

Document Control Desk E-54837 Page 2 of 2 RAls are submitted following our meetings with the NRC Staff to discuss the draft responses.

The following RAls, which were listed in Table 4 of Reference [2] for submittal with this batch are being rescheduled for submittal at a latertime as listed below.

• RAls SOC-1, Cl-1 Cl-2, CB-1, CB-2, CB-3, and CB-4 will be submitted within the next month. While these RAls are all associated with a revised Cost Benefit Analysis that is being performed in support of the WCS CISF project. ISP requires a more time provide complete and high quality responses.

Should you have any questions regarding this submission, please contact me by telephone at (410) 910-6955, or by email at jack.boshoven@orano.group.

Sincerely, Jack Boshoven Chief Engineer CISF, Licensing and Engineering Interim Storage Partners LLC cc:

John-Chau Nguyen, Senior Project Manager, U.S. NRC Jeff Isakson, ISP LLC Elicia Sanchez, ISP LLC

Enclosures:

1.

Affidavits Pursuant to 10 CFR 2.390

a.

Interim Storage Partners

2.

Draft RAI Responses with associated application change pages (Proprietary)

3.

Draft RAI Responses with associated application change pages (Public)

• to E-54837 Affidavits Pursuant to 10 CFR 2.390

a.

Interim Storage Partners

terim Storage Pattners LLC ate of Maryland ounty of Howard

)

)

)

ss.

AFFIDAVIT PURSUANT TO 10 CFR 2.390 I, Jeffery Isakson, depose and say that I am Chief Executive Officer/President, Interim Storage Partners LLC duly authorized to execute this affidavit, and have reviewed or caused to have reviewed the information that is identified as proprietary and referenced in the paragraph immediately below. I am submitting this affidavit in conformance with the provisions of 10 CFR 2.390 of the Commission's regulations for withholding this information.

The information for which proprietary treatment is sought applies to the following documents listed below:

• of E-54837 RAJ GS-4

• of E-54837 RAI LU-2 Attachment LU-2-1

• ofE-54837 RAI WR-5 Attachment WR-5-1

• of E-54837 RAI CHR-2 Environmental Report Markup Pages Attachment 3-4

• of E-54837 RAI ECO-I Environmental Report Markup Pages Attachment 3-6

• of E-54837 RAI GS-4 Environmental Rep01t Markup Pages Table 3.1-3

• ofE-54837 RAI LU-2 Environmental Rep01t Markup Pages Figures 3.1-5, 3.1-6, 3.1-7, and 3.1-8 These documents have been appropriately designated as proprietary.

I have personal knowledge of the criteria and procedures utilized by Interim Storage Partners LLC in designating information as a trade secret, privileged or as confidential commercial or financial information.

Pursuant to the provisions of paragraph (b) (4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure, included in

.e above referenced document, should be withheld.

1) The information sought to be withheld from public disclosure involves ecological, geological, and geophysical information and data -

including maps - concerning location of wells, cultural and historic resources, ecological resources, and geophysical features related to the siting of the WCS CISF, which are owned and have been held in confidence by Interim Storage Partners LLC.

2) The information is of a type customarily held in confidence by Interim Storage Partners LLC, and not customarily disclosed to the public. Interim Storage Partners LLC has a rational basis for determining the types of information customarily held in confidence by it.

3) Public disclosure of the information is likely to cause substantial harm to the competitive position oflnterim Storage Partners LLC, because the information consists of descriptions of the ecological, geological, and geophysical resources on and adjacent to the WCS CISF, the application of which provide a competitive economic advantage. The availability of such information to competitors would enable them to modify their product or project to better compete with Interim Storage Partners LLC, take marketing or other actions to improve their product's or project's position or impair the position of Interim Storage Partners LLC product or project, and avoid developing similar data in support of their processes, methods or apparatus.

Further the deponent sayeth not.

Jeffery Isaks Chief Executive Officer/President, Interim Storage Pattners LLC CYNTHIA RENEE GREY NOTARY PUBLIC CARROLL COUNTY MARYLAND MY COMMISSION EXP. APR 7, 2020 Page 1 of 1