ML23032A236

BWXT Nuclear Fuel Services, Inc., (Nfs), Submittal of Revisions to Non-CRD Integrated Safety Analysis Summaries for Calendar Year 2022

ML23032A236
Person / Time
Site:	Erwin
Issue date:	01/26/2023
From:	Knowles T BWXT Nuclear Fuel Services
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
Shared Package
ML23032A232	List: ML23032A236
References
21G-23-0002, GOV-01-55-04, ACF-23-0005
Download: ML23032A236 (1)

Text

Nuclear Fuel Services, Inc.

UNCLASSIFIED CONTROLLED NUCLEAR INFORMATION 21 G-23-0002 GOV-01-55-04 ACF-23-0005 January 26, 2023 Director, Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington , DC 20555-0001

References:

1) Docket No.70-143; SNM-124

2) Letter from Timothy A Knowles to NRC, Revisions to Classified Integrated Safety Analysis Summaries for Calendar Year 2022 (21Y-23-0001), dated January 26 , 2023

Subject:

Revisions to Non-CRD Integrated Safety Analysis Summaries for Calendar Year 2022 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 2022. 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 2022 submittal was performed , and none of the changes implemented in the summaries required amendment of NFS license (SNM-124) .

Documents transmitted herewith contain Unclassified UCNI markings not applicable when UCNI enclosure(s) is Controlled Nuclear Information removed UNCLASSIFIED CONTROLLED NUCLEAR INFORMATION Peo p le St r ong PO Box 337. MS 123. Erwin . TN 37650 I +1 423 743 914 1 www nu clearfuelserv,cescom INNOVATION DRIVEN >

21 G-23-0002 GOV-01-55-04 ACF-23-0005 The ISA Summaries for the following buildings have not changed and are, therefore, not included in this submittal:

• Building 310 Warehouse ISA Summary, Rev 11

• Building 100 NDA Laboratory, Rev 4

• Laboratories 11 OA, 11 OB, and 11 OD, Rev 1O *

• Waste Water Treatment Facility, Rev 17 The documents and drawings enclosed herewith are being submitted to the NRC for docketing in the NFS SNM 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.

If you or your staff have any questions, require additional information, or wish to discuss this further, please contact me, or Danielle Rogers, Nuclear Safety and Licensing Section Manager, at (423) 735-5475. Please reference our unique document identification number (21 G-23-0002) in any correspondence concerning this letter.

Sincerely, NUCLEAR FUEL SERVICES, INC.

j~' / ~

Tim Knowles, Director Safety and Safeguards

21 G-23-0002 GOV-01-55-04 ACF-23-0005 EAS/las

Enclosure:

Affidavit

Attachment:

Blended Low-Enriched Uranium Preparation Facility (BPF) ISA Summary, Rev 20, (21T-23-0005) (UCNI)

NFS Site ISA Summary, Rev 21, (21T-23-0006) (OUO)

21 G-23-0002 GOV-01-55-04 ACF-23-0005 Regional Administrator U.S. Nuclear Regulatory Commission Region II 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257 (LETTER ONLY)

Dr. Robert Williams Chief, Project Branch I U.S. Nuclear Regulatory Commission, Region II 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, GA 30303-1257 Mr. James Downs Senior Project Manager Division of Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Two White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 (LETTER ONLY)

Mr. Larry Harris Senior Resident Inspector U.S. Nuclear Regulatory Commission

21 G-23-0002 GOV-01-55-04 ACF-23-0005 ENCLOSURE AFFIDAVIT TRADE SECRETS OR COMMERICAL INFORMATION (2 pages)

21 G-23-0002 GOV-01-55-04 ACF-23-0005 AFFIDAVIT TRADE SECRETS OR COMMERCIAL INFORMATION I, Tim Knowles, 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 NFS wishes to have withheld from public disclosure is the Attachment to NFS letter (21 G-23-0002), dated January 26, 2023: .

Revisions to Unclassified Integrated Safety Analysis Summaries for Calendar Year 2022:

Blended Low-Enriched Uranium Preparation Facility (BPF) ISA Summary, Rev 20, (21T-23-0005) (UCNI)

NFS Site ISA Summary, Rev 21, (21T-23-0006) (QUO)

B. The information contained in the document cited in A above has been held in confidence by 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 NFS, or its Contractor, and as such is customarily held in confidence by NFS. As such, 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 NFS, nor has NFS authorized that it be made available. In accordance with 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 held by NFS, or its Contractor. The basis for withholding said information is that it contains distinguishing aspects of a process, methodology, or component(s),

21 G-23-0002 GOV-01-55-04 ACF-23-0005 the exclusive use of which provides a competitive advantage for NFS or its Contractor in product optimization or marketability.

F. The proprietary information that NFS requests to be withheld from public disclosure is contained in the entire document as so marked.

t/J6/~.3 Tim Knowles Date Safety and Safeguards Director ertify the above named person appeared before me and executed this document on is the~ day f January, 2023.

UNCLASSIFIED CONTROLLED NUCLEAR INFORMATION 21 G-23-0002 GOV-01-55-04 ACF-23-0005 ATTACHMENT Blended Low-Enriched Uranium Preparation Facility (BPF) ISA Summary, Rev 20, (21 T-23-0005) (UCNI)

NFS Site ISA Summary, Rev 21, (21T-23-0006) (QUO)

Documents transmitted herewith contain Unclassified UCNI markings not applicable when UCNI enclosure(s) is Controlled Nuclear Information removed UNCLASSIFIED CONTROLLED NUCLEAR INFORMATION