ML23025A317
| ML23025A317 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 01/25/2023 |
| From: | Travis Tate Framatome |
| To: | Office of Nuclear Material Safety and Safeguards, Document Control Desk |
| Shared Package | |
| ML23025A316 | List: |
| References | |
| TJT:23:002 | |
| Download: ML23025A317 (1) | |
Text
framatome January 25, 2023 TJT:23:002 U.S. Nuclear Regulatory Commission Attn: Document Control Desk (03-H8)
One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2738 Gentlemen:
Subject:
Submittal of Integrated Safety Analysis (ISA) Summary Annual Update for Framatome Inc.s (Framatomes) Richland, Washington Fuel Fabrication Facility; License No. SNM-1227; Docket No. 70-1257.
Enclosed with this letter, in digital format, is the annual update of the ISA Summary for Framatomes Richland, Washington nuclear fuel fabrication facility. Attachment A provides a listing of the files contained on this digital file. Framatome requests that this Digital file in its entirety be withheld from public disclosure in accordance with 10 CFR 2.390 or 10 CFR 2.790 in that portions of all files are either commercially proprietary in nature or contain security-related information, respectively. Attachment B provides an affidavit attesting that these files are either proprietary in nature or contain security related information. The annual update is being submitted in accordance with 10 CFR 70.72 (d)(3) and documents the changes to the Richland sites ISA summary. The changes are highlighted in yellow. PDF files with an expanded sized copy of the revised figures are provided on a separate digital file. A list of the files contained on the ISA digital file, including the file name, size, and sensitivity level (commercially proprietary or security-related) for each file, is included as Attachment C to this letter.
Technical contact information relative to the Richland Site ISA is as follows:
Framatome Inc.
Attn: William L. Doane, Manager Nuclear Safety 2101 Horn Rapids Road Richland, WA 99354 Phone: 509-375-8717 Email; william.doane@framatome.com Additionally, I can be reached at 509-375-8550 or via email at timothv.tate@framatome.com.
Very truly yours, T. J. Tate, Manager Environmental, Health, Safety & Licensing Framatome Inc.
2101 Horn Rapids Road Richland, WA 99354 Tel: (509) 375-8100 www.frainatome.com
US NRC TJT:23:002 January 25, 2023 Page 2 c: Richard Jervey, NRC
US NRC TJT:23:002 January 25, 2023 Page 3 Attachment A: List of Electronic Files Attachment B: Affidavit requesting that the Framatome ISA summary be handled as proprietary information.
Attachment C: Table of Contents and File Designations
Enclosure:
Two Digital Letter book files submitted into NRC portal; TJT:23:002 Submittal of Integrated Safety Analysis (ISA) Summary Annual Update for Framatomes Inc.s (Framatomes) Richland, Washington Fuel Fabrication Facility; License No.
SNM-1227; Docket No. 70-1257. Second letter book TJT:23:003 Framatome Inc.
(Richland) Summary of Facility Changes Made during Calendar Year 2022
US NRC TJT;23:002 January 25, 2023 Page 4 be: w/o enclosures WL Doane L Stephens CD Manning
ATTACHMENT A FOLDER: Chapters Part 1 - Chapters 1 through 8 (One File)
File Name: 001 E15-01-1 Chapters 1-8 Version 28.pdf Chapter 1 - Introduction Chapter 2 - Horn Rapids Road Site Information Chapter 3 - Overview of AREVA Facilities, Operations and Hazards Chapter 4 - ISA Team Credentials and Standard Methodologies Chapter 5 - Quantitative Standards for Acute Chemical Exposures Chapter 6 - Definition of Terms Chapter 7 - General External and Facility Hazards Chapter 8 - Horn Rapids Plant Administrative and Management Measures Part 2 - Chapter 9 through 19 (Various Files)
Chapter 9 - UO2 Building File Name: 002 E15-01-2.9A Version 20.0 - U02 Building.pdf Chapter 9 - UO2 Building File Name: 003 E15-01-2.9B Version 21.0 - U02 Building.pdf Chapter 9 - UO2 Building File Name: 004 E15-01-2.9C Version 21.0- U02 Building.pdf Chapter 9 - UO2 Building File Name: 005 E15-01-2.9D Version 20.0 - U02 Building.pdf Chapter 9 - UO2 Building File Name: 006 E15-01-2.9E Version 20.0 - U02 Building.pdf Chapter 10 - Dry Conversion Facility File Name: 007 E15-01-2.10 Ver 20.0 - Dry Conv Facility.pdf Chapter 11 - SF Building File Name: 008 E15-01-2.11 Version21.0-SFBuilding.pdf Chapter 12 - ELO Building File Name: 009 E15-01-2.12 Version 20.0 - ELO Building.pdf Chapter 13 - UF6 Cylinder Recertification Facility File Name: 010 E15-01-2.13 Version 15.0 - UF6 Cyl Recert.pdf Chapter 14 - Ammonia Recovery Facility and Industrial Waste Water Treatment System File Name; 011 E15-01-2.14Ver20.0-ARFandlndWaste.pdf Chapter 15 - Blended Dysprosium and Uranium Processing Facility (BDU)
File Name: 012 E15-01-2.15 Version 13.0 - BDU Proc Fac.pdf Chapter 16 - Detached Storage and Waste Handling Systems File Name: 013 E15-01-2.16 Version 21 - Detached Storage.pdf Chapter 17 - Fuel Services Building File Name: 014 E15-01-2.17 Ver 13.0 - Fuel Services Bldg.pdf
Chapter 18 - Ventilation Systems (Plantwide)
File Name; 015 E15-01-2.18 Ver 20 - Vent Syst Plantwide.pdf Chapter 19 - Product Development Test Facility File Name: 016 E15-01-2.19 Version 13.0 PDTF.pdf Chapter 20 - Ancillary Systems File Name: 017 E15-01-2.20 Ver 13.0 Ancillary Systems.pdf Chapter 21 - Uranyl Nitrate Storage Tank Building File Name: 018 E15-01-2.21 Ver 11.0 UN Storage Tank Bldg.pdf Chapter 22 - Scrap Uranium Recovery Facility (SURF)
File Name: 019 E15-01-2.22 Ver 4.0 Scrap Uranium Rec. Fac.pdf Chapter 23 - Generic Comingled Chemical Exposure File Name: 020 E15-01-2.23 Ver 3.0 Gen. Comingled Chem Expsr.pdf Revised Figures Chapters E15-01-1 File Name: 021 E15-01-1 Version 28 Figure 3-1.pdf Chapter E15-01-1 File Name: 022 E15-01-1 Version 28 Figure 3-2.pdf Chapter E15-01-2.9C File Name: 023 E15-01-2.9C Version 21 Figure 9-9.pdf Chapter E15-01-2.9C File Name: 024 E15-01-2.9C Version 21 Figure 9-11.pdf Chapter E15-01-2.10 File Name: 025 E15-01-2.10 Version 20 Figure 10-1.pdf Chapter E15-01-2.10 File Name: 026 E15-01-2.10 Version 20 Figure 10-2.pdf Chapter E15-01-2.10 File Name: 027 E15-01-2.10 Version 20 Figure 10-3.pdf
STATE OF WASHINGTON )
- ss COUNTY OF BENTON )
Timothy J. Tate, being duly sworn on oath, states as follows;
- 1. I am employed by Framatome Inc. (Framatome) as Manager, Environmental, Health, Safety and Licensing in Richland, Washington. I am responsible for the overall administration of the safety programs at Framatomes Richland, Washington nuclear fuel fabrication facility, including regulatory licensing and permitting. This affidavit is based on my first hand, personal knowledge and is submitted in my capacity as Manager, Environmental, Health, Safety and Licensing.
- 2. I am familiar with the contents of the Submittal of Integrated Safety Analysis (ISA) Summary Annual Update for Framatome Inc., Richland, Washington Fuel Fabrication Facility (Annual ISA Summary Update), which provides the annual update to the Richland Site ISA as required by 10CFR70.72(d)(3). This Annual ISA Summary Update has been classified and designated as Proprietary by Framatome in accordance with the document control system and policies established by Framatome for the control and protection of proprietary and confidential information.
- 3. Framatome is engaged in the business of designing and manufacturing nuclear fuel assemblies for commercial nuclear reactors. Within the United States, there are two additional firms that design and manufacture nuclear fuel for commercial nuclear reactors and there are several other companies outside of the United States that engage in the same business as Framatome.
Competition among these companies including Framatome is fierce and manufacturing costs of the nuclear fuel are critical to the maintenance of market share and to the growth of market share among utility customers.
Affidavit of Timothy J. Tate ISA Submittal (2023)
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- 4. The Annual ISA Summary Update contains commercial information of a confidential nature that is not available in public sources or available to the public. Sections also contain information that is considered security sensitive in accordance with USNRC RIS 2005-31. This information contained in the Annual ISA Summary Update is commercial and confidential because it:
A. Reveals distinguishing aspects of Framatomes manufacturing processes by relating sequences of operations and/or sub-operations to optimize the efficiency and performance of manufacturing operations which a competitor within the field of nuclear fuel manufacturing may adapt for their own processes, reducing the competitors expenditure of resources to achieve the same efficiencies, thereby gaining a competitive advantage to the disadvantage of Framatome.
B. Reveals the use of process chemical additives for the enhancement of chemical processes which are believed to be unique in the industry both in terms of type and application, which if revealed to a competitor would provide for an unfair competitive advantage by reducing any expenditure by the competitor to develop and test the same concepts.
C. Reveals aspects of privately funded development of process controls and parameters derived by Framatome over the course of optimizing the performance of waste treatment and other processes.
D. Reveals technical rationale developed by Framatome relating to plant layout, structure, process flow and other technical information which a competitor could readily use without expenditure of funds and replicate in its facilities thereby gaining a competitive advantage to the disadvantage of Framatome.
Affidavit of Timothy J. Tate ISA Submittal (2023)
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- 5. Framatome Inc. will suffer considerable competitive harm if the contents of the license amendment package are made available to Framatome domestic and international competitors. Finally, this material cannot be reasonably segregated from other material which may not meet the criteria set forth in 10 CFR§ 2.390.
Dated this day of January, 2023.
Timothy J. Tate Manager, Environmental, Flealth, Safety and Licensing STATE OF WASHINGTON )
ss COUNTY OF BENTON )
On this 25 _ day of January, 2023, before me, the undersigned, a Notary Public in and for the State of Washington, duly commissioned and sworn, personally appeared Timothy J. Tate to me known to be the Manager, Environmental, Health, Safety, and Licensing of Framatome Inc., the corporation that executed the foregoing instrument, and acknowledged the said instrument to be the free and voluntary act and deed of said corporation, for the uses and purposes therein mentioned, and on oath stated that he is authorized to execute the said instrument.
Witness my hand and official seal hereto affixed the day and year first above written.
Katherine Lynn Kerr Notary Public in and for the State of Washington, residing at Benton, Washington.
My commission expires: September 12th, 2026 Affidavit of Timothy J. Tate ISA Submittal (2023)
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