ML25175A314
| ML25175A314 | |
| Person / Time | |
|---|---|
| Site: | 07007033 |
| Issue date: | 06/24/2025 |
| From: | Knowles T Global Laser Enrichment |
| To: | Office of Nuclear Material Safety and Safeguards, Document Control Desk |
| References | |
| REGS-PLEF-NRC-LTR-1000032 | |
| Download: ML25175A314 (1) | |
Text
REGS-PLEF-NRC-LTR-1000032 Page 1 of 4 Global Laser Enrichment LLC 4110 US Hwy 421, Suite 100 Wilmington, NC 28401 USA Timothy Knowles T: +1 (910) 623-4336 M: +1 (432)-425-5525 email: timothy.knowles@gle-us.com June 24, 2025 Director, Office of Nuclear Material Safety and Safeguards Attn: Document Control Desk U. S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 RE:
Request for Exemption to the Requirement to Submit the SPPP, PCSP and CMTSP with the License Application REF:
- 1) NRC Docket 70-7033
- 2) NRC Regulation 10 CFR 70.17 Specific Exemptions In accordance with 10 CFR 70.17 (Reference 2), Global Laser Enrichment (GLE) hereby submits this request for an exemption from the requirement in 10 CFR 70.22(m) to provide a description of the programs to protect classified matter separate from and after a license application is submitted to the U.S. Nuclear Regulatory Commission (NRC).
GLE also requests that the NRC perform an expedited review of this exemption request and grant an approval no later than July 31, 2025.
10 CFR 70.17 provides for the NRC to grant exemption to the regulations in Part 70.
Exemption Request Pursuant to Title 10, Code of Federal Regulations, Part 70.17 (10 CFR 70.17), Global Laser Enrichment (GLE) hereby submits this request for an exemption from the requirements in 10 CFR 70.22(m) which states:
REGS-PLEF-NRC-LTR-1000032 Page 2 of 4 Each application for a license to possess equipment capable of enriching uranium or operate an enrichment facility, and produce, possess, or use more than one effective kilogram of special nuclear material at any site or contiguous sites subject to control by the applicant, must contain a full description of the applicant's security program to protect against theft, and to protect against unauthorized viewing of classified enrichment equipment, and unauthorized disclosure of classified matter in accordance with the requirements of 10 CFR parts 25 and
- 95.
GLE specifically requests that an exemption be granted from 10 CFR 70.22(m). This exemption is needed because the Standard Practices and Procedure Plan (SPPP), Program Cyber Security Plan (PCSP) and Classified Matter Transportation Security Plan (CMTSP) will not be thoroughly developed at the time the Paducah Laser Enrichment Facility (PLEF) license application is submitted. Detailed design work on the PLEF is not yet complete to prepare these documents with sufficient detail. Granting the exemption will allow the PLEF license application to proceed as scheduled and develop security plans more thoroughly and accurately. GLE commits to submission of the SPPP, PCSP, and CMTSP as part of the request for an NRC facility clearance in accordance with 10 CFR 95.15, Approval for Processing Licensees and Others for Facility Clearance, for the PLEF.
Background
As described in GLEs letter of intent dated February 13, 2023, Global Laser Enrichment, LLC advised the NRC of the intent to prepare a license application for the authority to construct and operate a laser enrichment facility under 10 CFR 70. The license application is associated with GLEs plans to construct and operate a laser enrichment facility adjacent to the Paducah Gaseous Diffusion Plant (PGDP) site. This facility, referred to as the Paducah Laser Enrichment Facility (PLEF), is anticipated to be deployed as part of an agreement between GLE and the U.S.
Department of Energy (DOE) to purchase and re-enrich certain DOE inventories of depleted UF6.
Regulatory Requirements Part 70.22, Filing, states "(m) Each application for a license to possess equipment capable of enriching uranium or operate an enrichment facility, and produce, possess, or use more than one effective kilogram of special nuclear material at any site or contiguous sites subject to control by the applicant, must contain a full description of the applicant's security program to protect against theft, and to protect against unauthorized viewing of classified enrichment equipment, and unauthorized disclosure of classified matter in accordance with the requirements of 10 CFR parts 25 and 95."
Part 70.17, Specific exemptions, states (a) The Commission may, upon application of any interested person or upon its own initiative, grant such exemptions from the requirements of the regulations in this part as it determines are authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest.
REGS-PLEF-NRC-LTR-1000032 Page 3 of 4 Technical Justification Authorized by Law The proposed exemption will allow the NRC to begin the review of the safety portions of the license application while the detailed design is completed. Granting of the proposed exemption which relates to the separation of the submittals will not result in a violation of the Atomic Energy Act of 1954, as amended, or the NRC's regulations. Therefore, the exemption is authorized by law.
Will Not Endanger Life or Property or the Common Defense and Security The exemption will not endanger Life, Property or Common Defense because the separation of the submissions does not change how the public is affected by the PLEF. The exemption enhances Common Security because it allows earlier submission of the PLEF license application and will result in establishment of additional US based uranium enrichment capacity sooner than if the PLEF license application is delayed. Granting of the exemption request does not circumvent the regulatory requirement that these documents be submitted as part of the request for an NRC facility clearance in accordance with 10 CFR 95.15, Approval for Processing Licensees and Others for Facility Clearance, for the PLEF and therefore does not:
a) impact the probabilities of evaluated accidents; b) affect margins of safety; c) affect effectiveness of programs contained in licensing documents; d) increase effluents; e) increase occupational radiological exposures; or f) impact operations or decommissioning activities.
Otherwise In the Public Interest Supports getting enrichment services in place sooner with less burden: Granting the exemption facilitates a more streamlined implementation process for enrichment services and avoids delays. By providing an exemption, with the commitment of compliance by the time of a facility clearance request, the exemption allows critical infrastructure to be deployed sooner and more efficiently. This accelerates the delivery of enriched materials, which are vital to various energy and national security initiatives.
Reinforces the national interest put forward by the President: The administration has emphasized the need to strengthen domestic capabilities in nuclear fuel enrichment, citing both energy independence and national security as key priorities. Supporting enrichment services aligns with these strategic objectives, reinforcing domestic supply chains and reducing reliance on foreign sources. The exemption helps achieve this policy goal in a timelier and resource-effective manner.
Reduces the likelihood of RAIs (Requests for Additional Information): Regulatory processes often involve iterative cycles of review and RAI exchanges, which can be time-consuming and resource-intensive for both licensees and regulators. By providing an exemption, this reduces
REGS-PLEF-NRC-LTR-1000032 Page 4 of 4 potential RAIs related to the afore mentioned license basis documents and therefore leads to a more efficient and predictable review process.
Reduces regulatory burden and allows limited resources for the NRC and GLE to focus on other safety-related reviews: Both the NRC and GLE operate with finite resources during a time of rapid industry demand and growth. Prioritizing higher-risk reviews helps maintain regulatory effectiveness while also supporting operational efficiency. This exemption helps allocate time and effort where it is most impactful with the intent of reviewing thoroughly developed plans that align with the mission of the NRC.
If there are any questions regarding this letter and its content, please do not hesitate to contact me.
Sincerely, Tim Knowles Licensing & Regulatory Affairs Manager cc:
M. Murphy (GLE)
J. Rickman (GLE)
M. Bartlett (NRC, NMSS)