ML23041A235

BWXT Nuclear Fuel Services, Inc. (Nfs), Response to NRC Request for Additional Information - Application for U-Metal License Amendment

ML23041A235
Person / Time
Site:	Erwin
Issue date:	01/31/2023
From:	Knowles T BWXT Nuclear Fuel Services
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
21G-23-0005, GOV-01-55-04, ACF-23-0015
Download: ML23041A235 (1)

Text

eWXT Nuclear Fuel Services, Inc. OFFICIAL USE ONLY 21 G-23-0005 Certified Mail GOV-01-55-04 Retum Receipt Required ACF-23-0015 January 31 , 2023 Director, Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Attn: Document Control Desk

Reference:

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

2) Letter from NFS to NRC, License Amendment Request for U-Metal at the NFS Site, dated November 18, 2021 (21G-21-0092)

3) Letter from NRC to NFS, Acceptance of Application for U-Metal License Amendment, dated March 25, 2022

4) Letter from NRC to NFS, Request for Additional Information -

Application for U-Metal License Amendment, dated August 31, 2022

Subject:

RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION -

APPLICATION FOR U-METAL LICENSE AMENDMENT By our letter dated November 18, 2021, Nuclear Fuel Services, Inc. (NFS) submitted a License Amendment Request (LAR) for U-Metal at the NFS Site (Reference 2). By letter dated March 25, 2022, (Reference 3) NRC accepted the application with no omissions or deficiencies identified . As part of the detailed technical review for the application, NRC staff requested additional information (Reference 4). NFS herein provides the following responses to the NRC Request for Additional Information (Attachment 1). A publicly available version of the updated Supplemental Environmental Report is provided as a separate enclosure to this letter.

If you or your staff have any questions, require additional information, or wish to discuss this matter further, please contact me at (423) 743-1705 , or Tom Holly, Licensing Manager, at (423) 743-2595. Please reference our unique document identification number (21 G-23-0005) in any correspondence concerning this letter.

Sincerely, NUCLEAR FUEL SERVICES, INC.

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Tim Knowles Safety and Safeguards Director Document transmitted herewith contains OUO Markings not applicable when Official Use Only Information QUO enclosure(s) is removed OFFICIAL USE ONLY People Strong 1205 Banner Hill Rd, Erwin, TN 37650 t: +1. 423. 743 .9 141 f:

• 1.423.743.0 140 www.nuclea rfuelservices.com INNOVATION DRIVEN >

21 G-23-0005 GOV-01-55-04 ACF-23-0015 TCH/las Affidavit Trade Secrets or Commercial Information : NFS Response to the Request for Additional Information Enclosure A: Supplemental Environmental Report Copies:

Mr. James Downs Senior Project Manager Division of Fuel Management Office of Nuclear Material Safety and Safeguards US Nuclear Regulatory Commission Two White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 Regional Administrator US Nuclear Regulatory Commission, Region II 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257 Mr. Larry Harris NRC Senior Resident Inspector

21 G-23-0005 GOV-01-55-04 ACF-23-0015 AFFIDAVIT TRADE SECRETS OR COMMERCIAL INFORMATION I, Tim Knowles, Safety & Safeguards Director 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(s) which Nuclear Fuel Services, Inc. (NFS) wishes to have withheld from public disclosure is:

Attachment to letter (21G-23-0005), dated January 31, 2023:

Response to NRC Request for Additional Information for the License Amendment Request for U-Metal at the NFS Site B. The information contained in the document(s) cited in A above has been held in confidence by Nuclear Fuel Services, Inc. (NFS), in that it contains commercial information concerning physical protection of special nuclear material not otherwise designated as Safeguards Information or classified as National Security Information or Restricted Data as specified in Title 10, Code of Federal Regulations, Part 2.390(d)(1 ).

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, as appropriate, in accordance with 10 CFR 2.390(b)(i)(B).

C. The information contained in the document(s) cited in A above is the intellectual property of Nuclear Fuel Services, Inc. (NFS) , 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(s) cited in A above has not been made available to public sources by Nuclear Fuel Services, Inc. (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(s) cited in A above is likely to cause substantial economic harm to the competitive advantage held by Nuclear Fuel Services, Inc. (NFS). The basis for withholding said information is that it contains information, the disclosure of which could provide a competitive advantage for NFS' competitors in the procurement of government and commercial contracts.

F. The public disclosure of the information contained in the document(s) cited in A above is likely to cause substantial economic harm to the parent company of Nuclear Fuel Services, Inc. (NFS) as it is a publicly held company and the information, if disclosed, will lack context or explanation for the shareholders.

21 G-23-0005 GOV-01-55-04 ACF-23-0015 G. The proprietary/security information that Nuclear Fuel Services, Inc. (NFS) requests to be withheld from public disclosure is contained in the entire document(s) as so marked.

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