ML23333A100
| ML23333A100 | |
| Person / Time | |
|---|---|
| Site: | Erwin |
| Issue date: | 05/30/2023 |
| From: | Knowles T Nuclear Fuel Services |
| To: | Division of Fuel Management |
| Shared Package | |
| ML23333A029 | List: |
| References | |
| 001029, EPID L-2022-LLL-0017 | |
| Download: ML23333A100 (5) | |
Text
OFFICIAL YSE ONLY PROPRIETARY INFORMATION 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:
10 CFR 71.15 Follow Up:
Additional Questions Sent Via Email from Tom Holly, NFS to Norma Garcia Santos, NRC regarding Fissile Material Exemptions 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.
OFFICIAL YSE ONLY PROPRIETARY INFORMATION
OFFICIAL YSE ONLY PROPRIETARY INFORMATION G. The proprietary/security information that Nuclear Fuel SeNices, Inc. (NFS) requests to be withheld from public disclosure is contained in the entire document(s) as so marked.
S'/Jo/OJ..3 Tim Knowles Date' NFS Safety & Safeguards Director I certify the above named person appeared before me and executed this document on this the
_ D day of May, 2023.
'dVk--c......i+->>--'\3 My commission expires: .,\\D OFFICIAL YSE ONLY PROPRIETARY INFORMATION
OFFICIAL USE ONLY PROPRIETARY INFORMATION Holly, Thomas C From: Holly, Thomas C Sent: Friday, April 28, 2023 8:40 AM To: Norma Garcia Santos Cc: 'James Downs'; Rogers, Danielle M (DMRogers@nuclearfuelservices.com); Gibson, Clifton T (CTGibson@nuclearfuelservices.com); Walker, Jasof'1 J
Subject:
NRC Response to NFS Related to Applicability of 10 CFR 71.1 S
Dear Ms. Norma Garcia Santos,
As offered in the response letter dated March 29, 2023, NFS kindly requests a meeting to discuss the staff's position and potential path to success for applicability of 10 CFR 71.lS(c). I will be in Washington, DC/Bethesda next week for the Fuel Cycle Stakeholder's meeting. Any option for a break out meeting in person would be welcomed; additionally, a conference call may be scheduled any time based on your availability. Provided below are questions/concerns the NFS Waste Management and Transportation staff have provided for discussion:
1 OFFICIAL YSE ONLY PROPRIETARY INFORMATION