ML24326A076

Model 1100 Application Letter (Public)

ML24326A076
Person / Time
Site:	07109405
Issue date:	10/03/2024
From:	Podolak L QSA Global
To:	Yoira Diaz-Sanabria Document Control Desk, Storage and Transportation Licensing Branch
Shared Package
ML24326A072	List: ML24326A075 ML24326A076
References
Download: ML24326A076 (1)

Text

QSA GLOBAL.

3 October 2024 ATTN: Document Control Desk Ms. Yoira Diaz-Sanabria, Chief Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 RE:

New Type B(U) Application for the Model 1100 Transport Package Design

Dear Chief:

QSA Global, Inc. requests Type B(U) review and approval for the Model 1100 transport container. This submission contains proprietary documentation for which we request withholding from public disclosure under the provisions of 10 CFR §2.390(a)(4). The attachments to this letter include Attachment 1 which is the Affidavit required for proprietary documentation under §2.390; Attachment 2 which includes all submission documents covered by the proprietary request for withholding under the affidavit in Attachment 1; and Attachment 3 which includes all submission documents that can be released for public disclosure related to these packages.

It is noted that this package submission includes two drawings, one submitted for use by NRC staff in evaluation of the package designs and containing proprietary information; and the second submitted for reference under the Type B(U) package certification for use by preparers of the package for transport and open for public disclosure.

The SAR included with this submission has been formatted to comply with the recommended guidance in NUREG 1886 (Final - March 2009). This package design will also be submitted to the Canadian Nuclear Safety Commission to allow Type B(U) transport in Canada after obtaining USNRC and USDOT approval for Type B(U) transport. Should you have any additional questions or wish to discuss this submission after receipt please feel free to contact me.

Sincerely, E-SIGNED by Lori Podolak on 2024-10-03 15:05:28 GMT Lori Podolak Senior Regulatory Affairs Specialist Regulatory Affairs Department Ph: (781) 505-8241 Fax: (781) 359-9191 Email: Lori.Podolak@qsa-global.com E-SIGNED by Mary Flanigan on 2024-10-0315:18:58 GMT RA/QA Approval E-SIGNED by Paul Benson on 2024-10-03 16:13:45 GMT Engineering Approval www.qsa-global.com

Enclosures:

(1-Hard Copy Original containing copies of this letter and the following files):

• : Affadavit Pursuant to §2.390

• : Proprietary Documents

• : Non-proprietary Documents cc (CD):

Nishka Devaser Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852 Page2

Affavit Pursuant to 10 CFR §2.390 www.qsa-global.com

AFFIDAVIT Pursuant to 10 CFR §2.390 I, Lori Podolak, Senior RA/QA Specialist of QSA Global, Inc. hereby affirm and state:

1. I have been specifically delegated the function of reviewing the information sought to be withheld and am authorized to apply for its withholding on behalf of QSA Global, Inc.

2. QSA Global, Inc. is providing NRC with a detailed drawing (R1100 Rev A) and technical details, specifications and product related information as parts of the SAR Revision O for the Model 1100 transport package. (The full list of proprietary pages in the SAR Revision O are identified in QSA Global, Inc. letter dated 3 October 2024.) These documents contain proprietary commercial information.

3. The information sought to be withheld pursuant to the provisions of 10 CFR §2.390(a)(4) are marked as follows in Attachment 2 of our application letter "Proprietary information submitted under 10 CFR §2.390 to be withheld from public disclosure under 10 CFR

§2.390."

4. These documents should be held in confidence by the NRC per 10 CFR §2.390(a)(4) based on the following justifications:

a. This information is owned and been held in confidence by QSA Global, Inc.

b. This information is of a type that QSA Global, Inc. has determined should be held in confidence since its release for public disclosure could result in a loss of an existing or potential competitive advantage as follows:

i. The information reveals the distinguishing aspects of the design (including its design function in the package). The prevention of its use by QSA Global, Inc. competitors gives QSA Global, Inc. a competitive economic advantage.

ii. The information reviews testing, assessment or other evaluations (including calculations) that demonstrate and/or justify compliance of the design/design components to the transport requirements.

iii. The information, if used by a competitor, is likely to reduce the competitor's expenditure of resources or improve their advantage in design, quality and manufacture of a similar product.

c. This information is being transmitted to the NRC voluntarily and in confidence for use in evaluation and approval of this package design for Type B(U) transport certification.

d. This information is not available in public sources.

e. Public disclosure of this information is likely to cause substantial harm to the competitive position of QSA Global, Inc. because of the reasons outlined below:

i. Similar products are manufactured and sold by competitors of QSA Global, Inc.

ii. The development of this information by QSA Global, Inc., including tesUevaluation documentation supporting this package design, is the result of significant expenditure of staff effort and a considerable amount of money. It is our belief that a competitor would have to undertake similar effort and expense to generate equivalent information.

iii. In order to generate such information, a competitor would also require considerable time (e.g., in excess of 1 year).

iv. If a competitor used this information and did not have to undertake the work required to generate this information, they are likely to have lower overall costs and so are likely to have an unfair economic advantage over QSA Global, Inc. in offering a similar product to the market.

5. QSA Global has spent considerable commercial and technical resources to design and build this transport package design which incorporates improvements and design innovations over our other package designs. These design changes are unique to the package's ability to function as an industrial radiographic exposure device intended for worldwide distribution. Access to the technical information for this unique design would give a competitor an unfair advantage ih expanding their ddmeistic and international market*

without having to perform their ciwn research *and development cifthe market needs and the ideal configuration of the transport package to meet a wide:"i,1ariety of customer needs.

Accordingly, QSA Global, Inc. requests that the designated information be withheld from public disclosure pursuant to 10 CFR §2.390.

Executed on ____.l_o_(_~--+-'-r "'"--O.;l.;;;...........+Y---

1. r Lori Podolak Senior RA/QA Specialist

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