ML24185A252

Louisiana Energy Services, LLC, Dba Urenco USA, Affidavit for Urenco Presentation on Buildings as IROFS

ML24185A252
Person / Time
Site:	07003103
Issue date:	06/25/2024
From:	Dorathy B, Lorskulsint P Louisiana Energy Services, URENCO USA
To:	Office of Nuclear Material Safety and Safeguards, Document Control Desk
Shared Package
ML24185A251	List: ML24185A252
References
LES-24-080-NRC
Download: ML24185A252 (2)

Text

{{#Wiki_filter:LES-24-080-NRC Withhold under 10 CFR 2.390 USA

June 25, 2024 The National Enrichment Facility

ATTN: Document Control Desk Samantha Lav, Chief, Fuel Facility Licensing Branch U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Louisiana Energy Services, LLC NRC Docket No. 70-3103

Subject:

Affidavit for Urenco Presentation on Buildings as IROFS

Louisiana Energy Services (LES), dba Urenco USA (UUSA) is providing the attached affidavit (Enclosure 1) along with the presentation regarding Buildings as IROFS (Enclosure 2) in support of the NRC meeting regarding "Fuel Facility Structures as Items Relied on for Safety" scheduled for June 27, 2024.

UUSA requests that the material presented as Enclosure 2 "Building Requirements (Closed Portion)" be withheld from public disclosure as provided by 10 CFR 2.390(a)(4) and ( d) because it contains proprietary and/or commercial sensitive information or security related information that is privileged and confidential. The enclosed Affidavit supports this withholding request.

If you have any questions concerning this submittal, please contact Chris Schwarz, Licensing and ECP Manager, at 575.394.5783. ~ ul:0-Mk

Brian Dorathy for Paul Lorskulsint Head of Compliance UUSA and Chief Nuclear Officer

CC:

Jonathan Rowley, Senior Project Manager - UUSA U.S. Nuclear Regulatory Commission Jonathan.Rowley@nrc.gov

James Downs, Senior Project Manager U.S. Nuclear Regulatory Commission James.Downs@nrc.gov

Enclosure : 1. Affidavit

2. UUSA Presentation titled "Building Requirements (Closed Portion)"

Enclosure 2 transmitted by this letter contains Proprietary and/or Security-Related information. Lo u isiana Ener !fic S.erwc e51 LtG When detached, this letter is decontrolled. UUSA I P.O. Box :.1789 J Eunice,.! New Mexico I 88231 I USA T : +1 (575) 394 4646 I W www.uusa.urenco.com © 2024 Louisiana.Energy 'Services, LL c' LES-24-080-NRC

ENCLOSURE 1 Affidavit USA The National Enrichment Facility

I, Brian Dorathy, being duly sworn, state that I am the Head of Engineering and Site Projects for Louisiana Energy Services, LLC (LES) at the Urenco USA Facility; that I am authorized on the part of said company to sign and file with the Nuclear Regulatory Commission this document; and that all statements made and matters set forth herein are true and correct to the best of my knowledge, information, and belief:

LES wishes to have withheld from public disclosure the following document:

• UUSA Presentation on Buildings as IROFS Titled: "Building Requirements (Closed Portion)".

The information contained in the document cited above for which exemption from public disclosure is requested is owned by LES. The information contained in the documents cited above for which exemption from public disclosure is requested includes confidential business proprietary, trade secret, and/or commercially sensitive information related to commercial aspects of the Urenco USA Facility operated by LES, its operation and/or commercially sensitive LES business plans and security related information. LES is likely to suffer competitive disadvantages from disclosure of the referenced information. Accordingly, LES requests that the confidential, proprietary, and Sensitive Unclassified Non-Safeguards Information (SUNSI) be exempt from disclosure pursuant to the provisions in 10 CFR 2.390(a)(4) and 10 CFR 2.390(d).

Public disclosure of the information in the attached enclosure to this submittal has the potential to result in substantial harm to the competitive position of LES, unfairly provide valuable company proprietary business information to competitors of LES which the competitors could utilize to their benefit without having to expend their own resources to develop and to interfere with LES business strategies, and such disclosure could reduce or foreclose the availability of profit opportunities. The information sought to be withheld is not available in public sources, to the best of LES' knowledge and belief.

The information stated in this affidavit has been submitted in accordance with the applicable parts of 10 CFR 2.390 and the guidance from NRC RIS-2004-11 and NRC RIS-2005-31 Revision 1, Enclosure 2, Appendix 1 (Fuel Cycle Facility Reviews). I declare under penalty of perjury that the foregoing is true and correct. ~ -JLJ:s4- ~/is / &f-{ Brian Dorathy Date 1 Head of Engineering and Site Projects Louisiana Energy Services, LLC

ov amed person appeared before me and executed this document on 4.

My commission expires: 4 -2 i - 202']-

JESSICA ESMERALDA RASCON Louisiana Energy Services, LLC Notary Public

• State of New Mexico UUSA I P.O. Box 1789 1 Eunice I New Mexico I 88231 I USA Commission II 1125 723 T : +1 (575) 394 4646 I W : www.uusa.urenco.com

© 2024 Louisiana Energy Services, LLC My Comm. Expires Apr 28, 2027}}