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MONTHYEARM170193, GE-Hitachi Nuclear Energy Americas, LLC - Submittal of Response to NRC Request for Additional Information2017-07-31031 July 2017 GE-Hitachi Nuclear Energy Americas, LLC - Submittal of Response to NRC Request for Additional Information Project stage: Response to RAI ML17312B3592018-01-18018 January 2018 Information Needed for the GE Hitachi Exemption Request for Alternate Decommissioning Schedules for Licenses DPR-1, DR-10 and TR-1 at the Vallecitos Nuclear Center (EPID No. L-2017-LLA-0052) (Docket Numbers: 50-18, 50-183, 50-70; License Nu Project stage: Other M180064, GEH Response Plan for NRC Request for Additional Information2018-03-28028 March 2018 GEH Response Plan for NRC Request for Additional Information Project stage: Request ML18123A3042018-05-21021 May 2018 GE Hitachi Response Plan for NRC Request for Additional Information Project stage: RAI M190202, GEH - Third Reply to NRC Request for Information Needed for GE-Hitachi Exemption Request for Alternate Decommissioning Schedules2019-11-15015 November 2019 GEH - Third Reply to NRC Request for Information Needed for GE-Hitachi Exemption Request for Alternate Decommissioning Schedules Project stage: Request ML20071G4112020-03-16016 March 2020 Request for Additional Information, GE Hitachi Request for Alternate Decommissioning Schedules for the Shutdown Reactors at the Vallecitos Nuclear Center Project stage: RAI M200102, GEH - Response to NRC Request for Additional Information (Rai), March 16, 20202020-07-15015 July 2020 GEH - Response to NRC Request for Additional Information (Rai), March 16, 2020 Project stage: Response to RAI ML20197A0122020-07-15015 July 2020 GEH - Response to NRC Request for Additional Information (Rai), March 16, 2020 Project stage: Response to RAI ML20174A1162020-07-15015 July 2020 Vbwr Request for Additional Information Enclosure Project stage: RAI ML20174A1152020-07-15015 July 2020 GE Hitachi Nuclear Energy - Vallecitos Nuclear Center, Vbwr Alternate Decommissioning Schedule - Request for Additional Information - License Numbers: DPR-1 (Docket Number 50-18); DR-10 (Docket Number 50-183); and TR-1 (Docket Number 50-70) Project stage: RAI 2018-05-21
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Category:Legal-Affidavit
MONTHYEARML23338A1312023-12-0404 December 2023 GE-Hitachi Nuclear Energy Americas, LLC, Additional Information to Geha and GNF-A Application for Order Consenting to Indirect Transfer of Control (Reference 1) ML23292A3362023-10-19019 October 2023 Northstar Vallecitos, LLC, Supplemental Information - Financial Qualifications ML23229A5122023-08-17017 August 2023 GE-Hitachi Nuclear Energy Americas, LLC, Response to NRC Staff Observations Enclosed with NRC Acceptance Letter (Reference 2) Related to GE, Geha and GNF-A Application (Reference 1) ML23123A0752023-04-12012 April 2023 Response to NRC Request for Inspection Documents ML23104A4172023-03-31031 March 2023 GNF-AGEH Financial Assurance of Decommissioning Funds - Surety Bond Riders Cover Letter and Affidavit ML22084A5782022-03-23023 March 2022 GNF-A/GEH Financial Assurance of Decommissioning Funds - Surety Bond Riders Cover Letter and Affidavit ML22080A1322022-03-21021 March 2022 GE-Hitachi Nuclear Energy Americas, LLC, NRC Request for Inspection Documents ML22061A0652022-03-0202 March 2022 GE-Hitachi Nuclear Energy Americas, LLC, NRC Request for Documents - Vallecitos Nuclear Center (Vnc) ML20197A0122020-07-15015 July 2020 GEH - Response to NRC Request for Additional Information (Rai), March 16, 2020 M200102, GEH - Response to NRC Request for Additional Information (Rai), March 16, 20202020-07-15015 July 2020 GEH - Response to NRC Request for Additional Information (Rai), March 16, 2020 M190202, GEH - Third Reply to NRC Request for Information Needed for GE-Hitachi Exemption Request for Alternate Decommissioning Schedules2019-11-15015 November 2019 GEH - Third Reply to NRC Request for Information Needed for GE-Hitachi Exemption Request for Alternate Decommissioning Schedules M190065, GE-Hitachi Nuclear Energy Americas, LLC - Second Reply to NRC Request for Information Needed for GE-Hitachi Exemption Request for Alternate Decommissioning Schedules2019-03-28028 March 2019 GE-Hitachi Nuclear Energy Americas, LLC - Second Reply to NRC Request for Information Needed for GE-Hitachi Exemption Request for Alternate Decommissioning Schedules M180200, GE-Hitachi Nuclear Energy Americas, LLC - Response to NRC Request for Additional Information (RAI) Interim Status Report2018-10-23023 October 2018 GE-Hitachi Nuclear Energy Americas, LLC - Response to NRC Request for Additional Information (RAI) Interim Status Report M180115, GEH Response to NRC Request for Additional Information (RAI)2018-05-31031 May 2018 GEH Response to NRC Request for Additional Information (RAI) M180053, GEH/GNF-A Financial Assurance of Decommissioning Funds - Supplemental Information2018-03-19019 March 2018 GEH/GNF-A Financial Assurance of Decommissioning Funds - Supplemental Information ML0702505252007-01-19019 January 2007 Request for NRC Consent to the Transfer of Control of GE Licenses to GE-Hitachi Nuclear Energy America, LLC, and for Approval of Conforming Amendments 2023-08-17
[Table view] Category:Letter type:M
MONTHYEARM220026, GE-Hitachi Nuclear Energy Americas, LLC - GEH Notification of GE Company Stock Beneficial Ownership Filings2022-02-11011 February 2022 GE-Hitachi Nuclear Energy Americas, LLC - GEH Notification of GE Company Stock Beneficial Ownership Filings M210154, GEH Notification of GE Company Stock Beneficial Ownership Filing2021-11-22022 November 2021 GEH Notification of GE Company Stock Beneficial Ownership Filing M210146, GEH - Description of Process for Decommissioning the Vallecitos Nuclear Center Shutdown Reactors2021-11-11011 November 2021 GEH - Description of Process for Decommissioning the Vallecitos Nuclear Center Shutdown Reactors M200167, Amended GEH Annual Shutdown Reactor Reports for the Year 20192020-12-16016 December 2020 Amended GEH Annual Shutdown Reactor Reports for the Year 2019 M200102, GEH - Response to NRC Request for Additional Information (Rai), March 16, 20202020-07-15015 July 2020 GEH - Response to NRC Request for Additional Information (Rai), March 16, 2020 M200062, GEH Request to Extend RAI Response Due Date to July 15, 20202020-04-14014 April 2020 GEH Request to Extend RAI Response Due Date to July 15, 2020 M200045, GE-Hitachi Nuclear Energy Americas, LLC - Transmittal of Annual Shutdown Reactor Reports for the Year 20192020-03-25025 March 2020 GE-Hitachi Nuclear Energy Americas, LLC - Transmittal of Annual Shutdown Reactor Reports for the Year 2019 M200039, GEH - Vallecitos Nuclear Center Getr Site Specific Cost Estimate and Decommissioning Funding Plan2020-03-0606 March 2020 GEH - Vallecitos Nuclear Center Getr Site Specific Cost Estimate and Decommissioning Funding Plan M190202, GEH - Third Reply to NRC Request for Information Needed for GE-Hitachi Exemption Request for Alternate Decommissioning Schedules2019-11-15015 November 2019 GEH - Third Reply to NRC Request for Information Needed for GE-Hitachi Exemption Request for Alternate Decommissioning Schedules M190146, GE Hitachi Nuclear Energy - License Amendment Request - Revision to Radiological Emergency Plan (REP) Public Supplement2019-08-23023 August 2019 GE Hitachi Nuclear Energy - License Amendment Request - Revision to Radiological Emergency Plan (REP) Public Supplement M190131, GE Hitachi Nuclear Energy License Amendment Request - Revision to Radiological Emergency Plan (REP) Public2019-07-17017 July 2019 GE Hitachi Nuclear Energy License Amendment Request - Revision to Radiological Emergency Plan (REP) Public M190065, GE-Hitachi Nuclear Energy Americas, LLC - Second Reply to NRC Request for Information Needed for GE-Hitachi Exemption Request for Alternate Decommissioning Schedules2019-03-28028 March 2019 GE-Hitachi Nuclear Energy Americas, LLC - Second Reply to NRC Request for Information Needed for GE-Hitachi Exemption Request for Alternate Decommissioning Schedules M190066, GE-Hitachi Nuclear Energy Americas, LLC - Annual Shutdown Reactor Reports for the Year 20182019-03-27027 March 2019 GE-Hitachi Nuclear Energy Americas, LLC - Annual Shutdown Reactor Reports for the Year 2018 M190044, GEH Response to NRC Request for Additional Information2019-02-26026 February 2019 GEH Response to NRC Request for Additional Information M180219, (Vnc) Organization Change2018-12-17017 December 2018 (Vnc) Organization Change M180214, GE-Hitachi Nuclear Energy - Unconditional Release of Route 84 Frontage Section of Vallecitos Nuclear Center (Vnc) Site2018-12-14014 December 2018 GE-Hitachi Nuclear Energy - Unconditional Release of Route 84 Frontage Section of Vallecitos Nuclear Center (Vnc) Site M180200, GE-Hitachi Nuclear Energy Americas, LLC - Response to NRC Request for Additional Information (RAI) Interim Status Report2018-10-23023 October 2018 GE-Hitachi Nuclear Energy Americas, LLC - Response to NRC Request for Additional Information (RAI) Interim Status Report M180115, GEH Response to NRC Request for Additional Information (RAI)2018-05-31031 May 2018 GEH Response to NRC Request for Additional Information (RAI) M180070, GEH Annual Shutdown Reactor Reports for the Year 20172018-03-29029 March 2018 GEH Annual Shutdown Reactor Reports for the Year 2017 M180064, GEH Response Plan for NRC Request for Additional Information2018-03-28028 March 2018 GEH Response Plan for NRC Request for Additional Information M180053, GEH/GNF-A Financial Assurance of Decommissioning Funds - Supplemental Information2018-03-19019 March 2018 GEH/GNF-A Financial Assurance of Decommissioning Funds - Supplemental Information M188002, GEH Request for Additional Time to Respond to NRC Request for Additional Information2018-02-0707 February 2018 GEH Request for Additional Time to Respond to NRC Request for Additional Information M170193, GE-Hitachi Nuclear Energy Americas, LLC - Submittal of Response to NRC Request for Additional Information2017-07-31031 July 2017 GE-Hitachi Nuclear Energy Americas, LLC - Submittal of Response to NRC Request for Additional Information M170158, GEH Request for Additional Time to Respond to NRC Request for Additional Information2017-06-21021 June 2017 GEH Request for Additional Time to Respond to NRC Request for Additional Information M170124, (Vnc) Organization Change2017-05-0909 May 2017 (Vnc) Organization Change 2022-02-11
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GE Hitachi Nuclear Energy Matt J. Feyrer
- HITACHI Site Manager, VaUecitos Nuclear Center 6705 Vallecitos Rd Sunol, CA 94586 Proprietary Information Notice USA Attachments 2 through 5 to this letter contain GE Hitachi Nuclear T 925 918 6018 Matt.feyrer@ge.com Energy proprietary information which is to be withheld from public disclosure in accordance with lD CFR 2.390. Upon removal of attachments 2 through 5, the balance of this letter may be made public.
M190202 November 15, 2019 Jack D. Parrott, Senior Project Manager Reactor Decommissioning Branch Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 ATTN: Document Control Desk
Subject:
GEH Third Reply to NRG Request for Information Needed for GE-Hitachi Exemption Request for Alternate Decommissioning Schedules
References:
- 1. NRC License DPR-1, Vallecitos Boiling Water Reactor (VBWR), Docket 50-18, NRC License DR-10, ESADA Vallecitos Experimental Superheat Reactor (EVESR), Docket 50-183, NRC License TR-1, General Electric Test Reactor (GETR), Docket 50-70
- 2. Letter, GEH Vallecitos Nuclear Center (VNC) Request for Alternate Decommissioning Schedules for DPR-1, DR-1 O and TR-1 Licenses, Exemption Request, 7/15/16
- 3. Letter, J.D. Parrott (NRC) to S.P. Murray (GEH) Request for Additional Information, 1/18/18
- 4. Letter, S.P. Murray to J.D. Parrott (NRG), GEH Response Plan for NRC Request for Additional Information, 3/28/18
- 5. Letter, S.P. Murray to J.D. Parrott (NRC), GEH First Response to NRC Request for Additional Information, 5/31/18
- 6. GEH Interim Status Report to NRC Request for Additional Information (RAI),
10/23/18
- 7. Letter, M.J. Feyrer to J.D. Parrott (NRC), GEH Second Response to NRC Request for Additional Information, 3/28/19
- 8. NAC/GEH Telecom, Third Response to NRC Request for Additional Information, 11/12/19 As discussed with NRC staff on November 12, 2019 (Reference 8), attached is the GE-Hitachi Nuclear Energy, LLC (GEH) third response to the NRC request for additional information needed for GE-Hitachi's exemption request to support alternate decommissioning schedules for the three shutdown reactors at the Vallecitos Nuclear Center (VNC) (Reference 1).
M190202 U.S. NRC November 15, 2019 Page 2 Attachments 2 through 5 to this letter provide the additional requested information for RAls 5 and 6 as described in References 4 and 7. Please note Attachments 2 through 5 contain company proprietary information that is requested to be withheld from public disclosure.
If you have any questions regarding this matter, please contact me at (925) 918-6018.
Sincerely, Matt Feyrer, Site Manager Vallecitos Nuclear Center Attachments: 1) GEH Affidavit
- 2) GEH Additional Requested Information, Third Supplement, 11/15/19
- 3) Seismic Evaluation of the Vallecitos Boiling Water Reactor (VBWR)
Shutdown Facility, Tier 1 Report, Revision O, Issued 7/3/19
- 4) Maintenance and Surveillance Plan, Vallecitos Nuclear Center Shutdown Reactors, Revision 0, Issued 8/5/19
- 5) Radiological Characterization and Source Term for the Shutdown Reactors at Vallecitos Nuclear Cente~, Revision 1, Issued 11 /13/19 cc: S. Anderson, USNRC RIV MJF 19-011
Attachment 1 - AFFIDAVIT I, Matt J. Fcyrer, state as follows:
( 1) I am the Site Manager of the Vallecitos Nuclear Center and have been delegated the function by GEH of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.
(2) The information sought to be withheld is contained in Attachments 2 through 5 to GEH*s letter, M 190202, Matthew J. Feyrer to Jack D. Parrott, Reactor Decommissioning Branch entitled "GEH Third Reply to NRC Request for Information Needed for GE-Hitachi Exemption Request for Alternate Decommissioning Schedules". GEH proprietary infonnation is contained in Attachments 2 through 5 and is identified by the statement "GEH Proprietary Information".
(3) In making this application for withholding of proprietary information of which it is the owner or licensee, GEH relies 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 9.17(a)(4), and 2.390(a)(4) fortrade secrets (Exemption 4). The material for which exemption from disclosure is here sought also qualifies under the narrower definition of trade secret, within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Proiect v. Nuclear Regulatory Commission, 975 F2d 871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F2d 1280 (DC Cir. 1983).
(4) The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. Some examples of categories of information that fit into the definition of proprietary infonnation are:
- a. Information that discloses financial, a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GEH' s competitors without license from GEH constitutes a competitive economic advantage over GEH and/or 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.
(5) To address 10 CFR 2.390(b)(4), the information sought to be withheld is being submitted to the NRC in confidence. The information is of a sort customarily held in confidence by GEH, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GEH, not been disclosed publicly, and not been made 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 and/or confidentiality agreements that provide for maintaining the information in confidence. The initial designation of this information as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure are as set forth in the following paragraphs (6) and (7).
(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, who is the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or who is the person most likely to be subject to the terms under which it was licensed to GEH. Access to such documents within GEH is limited to a uneed to know" basis.
(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist, or other equivalent authority for technical content,
competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GEH are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary and/or confidentiality agreements.
(8) The information identified in paragraph (2) above is classified as proprietary because it contains details of GEH's processes, design and manufacturing facilities.
(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEH' s competitive position and foreclose or reduce the availability of profit-making opportunities. The facility design and licensing methodology is part of GEH's comprehensive safety and technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.
The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GEH. The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial. GEH's competitive advantage will be Jost if its competitors are able to use the results of the GEH experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can anive at the same or similar conclusions.
The value of this information to GEH would be lost if the information were disclosed to the public.
Making such information available to competitors without there having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GEH of the* opportunity to exercise its competitive advantage to seek* an adequate return on its large investment in developing and obtaining these very valuable analytical tools.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on this 15th day of November 2019.
Matt J. eyrer GE Hitachi Nuclear Energy Americas, L.L.C.