ML19031C829
| ML19031C829 | |
| Person / Time | |
|---|---|
| Site: | Erwin |
| Issue date: | 01/24/2019 |
| From: | Freudenberger R Nuclear Fuel Services |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| 21G-19-0005, ACF-19-0004, GOV-01-55-04 | |
| Download: ML19031C829 (8) | |
Text
OFFICIAL USE ONLY Nuclear Fuel Services, Inc.
21 G-19-0005 GOV-01-55-04 ACF-19-0004 January 24, 2019 Director, Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555
References:
- 1)
- 2)
Docket No.70-143; SNM-124 Letter from R. J. Freudenberger to NRC, Revisions to Classified Integrated Safety Analysis Summaries for Calendar Year 2018 (21Y-19-0001), dated January 23, 2019
Subject:
Revisions to Unclassified Integrated Safety Analysis Summaries for Calendar Year 2018 In accordance with Title 10, Code of Federal Regulations, Part 70.72(d)(3), and SNM-124, Section 3.1.4, paragraph 3, Nuclear Fuel Services, Inc. (NFS), hereby submits revisions to the subject Integrated Safety Analysis (ISA) Summaries that reflect changes implemented in Calendar Year 2018. Changes are denoted by vertical lines in the right margin of affected pages and are summarized in the Record of Revision of the affected ISA Summary. Additional classified ISA Summaries are being submitted under separate cover letter (Reference 2). A review of the changes incorporated in the Calendar Year 2018 submittal was performed, and none of the changes implemented in the summaries were associated with licensing actions processed since the NFS license (SNM-124) was renewed in 2012.
Information contained in the attached ISA Summaries includes sensitive information and is marked as "Official Use Only" in accordance with 5 U.S.C. 552, and is not suitable for public release.
OFFICIAL USE ONLY May be exempt from public release under the Freedom of Information Act (5 U.S.C. 552)
Exemption number_**=,-__
Nuclear Regulatory Commission review required before
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Name and organization of pers n m king determination Date of Determination
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l OFFICIAL USE ONL V WHEN DETACHED, HANDLE THIS PAGE AS DECONTROLLED 1205 Banner Hill Rd, Erwin, TN 37650 People Strong INNOVATION DRIVEN >
t: +1.423.743.9141 f: +1.423.743.0140 www.nuclearfuelservices.com
OFFICIAL USE ONLY 21 G-19-0005 GOV-01-55-04 ACF-19-0004 The ISA Summaries for the following buildings have not changed and are, therefore, not included in this submittal:
Building 300 Warehouse Building 100 NDA Laboratory Laboratories 11 OA, 11 OB, 11 OD, and 131 The CD Line summary has been merged with the BPF summary since remaining equipment supports BPF processing. The CD Line summary is now obsolete.
Decommissioning of the BLEU Complex is complete and the Oxide Conversion/Effluent Processing Buildings and the Uranyl Nitrate Building summaries are now considered obsolete.
The documents and drawings enclosed herewith are being submitted to the NRC for docketing in the NFS Erwin License Docket (Reference 1 ). Said enclosures contain NFS proprietary information, as set forth in the enclosed affidavit in accordance with 10 CFR 2.390(a)(4).
The drawings_ enclosed herewith have the following statement affixed:
"This drawing and all information contained herein is the property of Nuclear Fuel Services, Inc.. and, shall not be used or disclosed for any purpose other than that for which it has been furnished without the express written consent of NFS."
Notwithstanding the language of this restriction, NFS acknowledges that reproduction and controlled distribution of submitted documents, in accordance with NRC regulations and requirements, is necessary in order for the NRC to carry out its legal and regulatory responsibilities. Further, NFS acknowledges that reproduction and controlled distribution of these drawings by a third party authorized by the NRC is allowable by this language.
Therefore, it is NFS' position that the enclosed drawings may be reproduced and distributed in a controlled manner, by a third party authorized by the NRC, for NRC's purposes and use without violation of the statement above.
OFFICIAL USE ONLY WHEN DETACHED, HANDLE THIS PAGE AS DECONTROLLED
OFFICIAL USE ONLY 21 G-19-0005 GOV-01-55-04 ACF-19-0004 If you or your staff have any questions, require additional information, or wish to discuss this further, please contact me at (423) 743-1705, or Mr. Robert Maurer, ISA and Fire Protection Manager, at (423) 735-5583. Please reference our unique document identification number (21 G-19-0005) in any correspondence concerning this letter.
/pdj Sincerely, NUCLEAR FUEL SERVICES, INC.
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Richard J. Freudenberger, Director Safety and Safeguards
Enclosure:
Attachment:
Revisions to Unclassified Integrated Safety Analysis Summaries for Calendar Year 2018:
BPF ISA Summary, Rev 16, (211-19-0013)
NFS Site ISA Summary, Rev 16, (211-19-0014)
Building 310 Warehouse ISA Summary, Revision 10, (211-19-0012)
OFFICIAL USE ONLY WHEN DETACHED, HA_NDLE THIS PAGE AS DECONTROLLED
OFFICIAL USE ONLY
.QQ.Qy:
Regional Administrator U.S. Nuclear Regulatory Commission Region II 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257 (LETTER ONLY)
Mr. Leonard Pitts Senior Fuel Facility Inspector US Nuclear Regulatory Commission Region II 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257 (LETTER ONLY)
Mr. Omar Lopez Chief, Projects Branch I Division of Fuel Facility Inspection U.S. Nuclear Regulatory Commission, Region II 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, GA 30303-1257 Mr. Kevin Ramsey Senior Project Manager Fuel Manufacturing Branch Division of Fuel Cycle Safety, Safeguards, and Environmental Review Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Two White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 Mr. Larry Harris Senior Resident Inspector U.S. Nuclear Regulatory Commission OFFICIAL USE ONL V WHEN DETACHED, HANDLE THIS PAGE AS DECONTROLLED 21 G-19-0005 GOV-01-55-04 ACF-19-0004
OFFICIAL USE ONLY ENCLOSURE AFFIDAVIT TRADE SECRETS OR COMMERICAL INFORMATION (2 pages)
OFFICIAL USE ONLY WHEN DETACHED, HANDLE THIS PAGE AS DECONTROLLED 21 G-19-0005 GOV-01-55-04 ACF-19-0004
OFFICIAL USE ONLY AFFIDAVIT 21 G-19-0005 GOV-01-55-04 ACF-19-0004 TRADE SECRETS OR COMMERCIAL INFORMATION I, Richard J. Freudenberger, representing the Safety and Safeguards Department at Nuclear Fuel Services, Inc. (NFS), that to the best of my knowledge and beliefs, make the following representation contained herein:
A. The following document which Nuclear Fuel Services, Inc. (NFS) wishes to have withheld from public disclosure is the Attachment to NFS letter (21G-19-0005),
dated January 24, 2019:
Revisions to Unclassified Integrated Safety Analysis Summaries for Calendar Year 2018:
BPF ISA Summary, Rev 16, (21T-19-0013)
NFS Site ISA Summary, Rev 16, (21T-19-0014)
Building 310 Warehouse ISA Summary, Revision 10, (21T-19-0012)
B. The information contained in the document cited in A above has been held in confidence by Nuclear Fuel Services, Inc. (NFS), or its Contractor,.in that it contains trade secrets or commercial information as specified in Title 10, Code of Federal Regulations, Part 2.390(a). The basis for requesting that this document(s) be withheld from public disclosure is explicitly marked on the cover page to each of the aforementioned documents and/or the top of each affected page in accordance with 10 CFR 2.390(b)(i)(B).
C. The information contained in the document cited in A above is the intellectual property of Nuclear Fuel Services, Inc. (NFS), or its Contractor, and as such is customarily held in confidence by Nuclear Fuel Services, Inc. (NFS). As such, Nuclear Fuel Services, Inc. (NFS) has customarily submitted privileged and confidential information of this type to the Nuclear Regulatory Commission (NRC) and to its predecessor, the Atomic Energy Commission (AEC), in confidence.
D. The information contained in the document cited in A above has not been made available to public sources by Nuclear Fuel Services, Inc. (NFS), nor has Nuclear Fuel Services, Inc. (NFS) authorized that it be made available. In accordance with Nuclear Fuel Services, Inc. (NFS) policies governing the protection and control of information, proprietary information contained herein has been made available, on a limited basis, to _others outside NFS only as required and under suitable agreement providing for nondisclosure and limited use of the information.
E. The public disclosure of the information contained in the document cited in A above is likely to cause substantial economic harm to the competitive advantage OFFICIAL USE ONL V WHEN DETACHED, HANDLE THIS PAGE AS DECONTROLLED
OFFICIAL USE ONLY 21G-19-0005 GOV-01-55-04 ACF-19-0004 held by Nuclear Fuel Services, Inc. (NFS), or its Contractor. The basis for withholding said information is that it contains distinguishing aspects of a process, methodology, or component(s), the exclusive use of which provides a competitive advantage for NFS or its Contractor in product optimization or marketability.
F. The proprietary information that Nuclear Fuel Services, Inc. (NFS) requests to be withheld from public disclosure-is contained in the entire document as so marked.
RichardJ.Frfu enberger Safety and Safeguards Director I certify the qbove named person appeared before me and executed this document on this the _?!t._ day of January, 2019.
My commission expires:
1-3lJ-22 OFFICIAL USE ONLY WHEN DETACHED, HANDLE THIS PAGE AS DECONTROLLED
OFFICIAL USE ONLY ATTACHMENT 21 G-19-0005 GOV-01-55-04 ACF-19-0004 Revisions to Unclassified Integrated Safety Analysis Summaries For Calendar Year 2018:
BPF ISA Summary, Rev 16 (21 T-19-0013)
NFS Site ISA Summary, Rev 16 (21 T-19-0014)
Building 310 Warehouse ISA Summary, Revision 10 (211-19-0012)
OFFICIAL USE ONLY May be exempt from public release under the Freedom of Information Act (S U.S.C. 552)
Exemption number _"1-___ _
Nuclear Regulatory Commission review required before
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OFFICIAL USE ONL V WHEN DETACHED, HANDLE THIS PAGE AS DECONTROLLED