ML25353A299
| ML25353A299 | |
| Person / Time | |
|---|---|
| Site: | 07007033 |
| Issue date: | 12/19/2025 |
| From: | Knowles T Global Laser Enrichment |
| To: | Office of Nuclear Material Safety and Safeguards, Document Control Desk |
| Shared Package | |
| ML25353A298 | List: |
| References | |
| GLE-NRC-25-42, EPID L-2024-NEW-0004 | |
| Download: ML25353A299 (0) | |
Text
DECONTROLLED NOTICE Page 1 of 4 Global Laser Enrichment LLC 4110 US Hwy 421, Suite 100 Wilmington, NC 28401 USA Timothy Knowles Licensing and Regulatory Affairs Manager T: +1 (901) 623-4336 M: +1 (910) 200-9562 timothy.knowles@gle-us.com GLE-NRC-25-42 Docket: 70-7033 December 19, 2025 Director, Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 RE:
GLE LLC. Request for Additional Information Responses Set 1 REF: REQUEST FOR ADDITIONAL INFORMATION - SET 1 - GEOTECHNICAL AND EMERGENCY MANAGEMENT - LICENSE APPLICATION FOR THE PADUCAH LASER ENRICHMENT FACILITY (ENTERPRISE PROJECT IDENTIFICATION NUMBER L-2024-NEW-0004)
In accordance with Title 10 Code of Federal Regulations (CFR) Sections 70.5(a)
Communications, and 70.21(h) Filing, Global Laser Enrichment LLC (GLE) submitted an application to possess and use special nuclear material in the Paducah Laser Enrichment Facility (PLEF). On November 7, 2025, the Nuclear Regulatory Commission issued Set 1 Request for Additional Information regarding Geotechnical and Emergency Management.
Summary of this Submittal GLE hereby submits its responses to Set 1 Request for Additional Information regarding Geotechnical and Emergency Management to the NRC. The enclosed materials provide the updated application content, supporting documentation, and clarifications prepared to address each RAI. These materials include the following:
DECONTROLLED NOTICE Page 2 of 4 Affidavit, as required by 10 CFR 2.390 to support GLEs request to withhold the below-mentioned enclosures.
For the purposes of electronic submittal through the NRC Electronic Information Exchange (EIE)
System, the names of the Enclosures are listed below.
Request for Additional Information (RAI) U.S. Nuclear Regulatory Commission (NRC) Staff Review of Global Laser Enrichment, LLC (GLE) - Paducah Laser Enrichment Facility (PLEF) License Application - Geotechnical GLE Response Request for Additional Information (RAI) U.S. Nuclear Regulatory Commission (NRC) Staff Review of Global Laser Enrichment, LLC (GLE) - Paducah Laser Enrichment Facility (PLEF) License Application - Emergency Management GLE
Response
License Application Chapter 1: General Information License Application Chapter 4: Radiation Protection License Application Chapter 7: Fire Safety License Basis Document: Emergency Plan The cover letter and affidavit, absent from its enclosures, can be treated as an uncontrolled document.
If there are any questions regarding this letter and its contents, please do not hesitate to contact me.
Sincerely, Tim Knowles Licensing & Regulatory Affairs Manager Cc:
M. Murphy (GLE)
J. Rickman (GLE)
DECONTROLLED NOTICE Page 3 of 4 AFFIDAVIT OF TIMOTHY KNOWLES, ON BEHALF OF GLOBAL LASER ENRICHMENT (GLE), IN SUPPORT OF REQUEST FOR WITHHOLDING PROPRIETARY INFORMATION UNDER 10 CFR 2.390 I, Tim Knowles, Licensing and Regulatory Affairs Manager of Global Laser Enrichment (GLE),
make the following representations that to the best of my knowledge and belief:
- 1. I am authorized to execute this affidavit on behalf of Global Laser Enrichment LLC (GLE), and I have personal knowledge of the facts and circumstances set forth herein.
- 2. GLE seeks to have withheld from public disclosure, pursuant to 10 CFR 2.390(a)(4),
and 10 CFR 2.390(b)(4)(v) the following documents submitted to the Nuclear Regulatory Commission (NRC) in connection with GLEs uranium enrichment facility licensing application:
Request for Additional Information (RAI) U.S. Nuclear Regulatory Commission (NRC) Staff Review of Global Laser Enrichment, LLC (GLE)
- Paducah Laser Enrichment Facility (PLEF) License Application -
Geotechnical GLE Response Request for Additional Information (RAI) U.S. Nuclear Regulatory Commission (NRC) Staff Review of Global Laser Enrichment, LLC (GLE)
- Paducah Laser Enrichment Facility (PLEF) License Application -
Emergency Management GLE Response License Application Chapter 4: Radiation Protection License Application Chapter 7: Fire Safety License Basis Document: Emergency Plan
- 3. These documents contain sensitive commercial and financial information that is considered confidential and proprietary to GLE. The withheld information includes technical processes, facility design features, safety analyses, control strategies, financial methodologies, and operational strategies, the disclosure of which would likely cause substantial harm to GLEs competitive standing.
- 4. The information sought to be withheld is not available in public sources and has been held in confidence by GLE. GLE has taken appropriate measures to maintain the confidentiality of this information, including limiting access to employees and contractors with a specific need to know.
- 5. Disclosure of this information would enable current and prospective competitors particularly those in the process of preparing similar NRC uranium enrichment applicationsto gain an unfair commercial advantage. The withheld materials reflect the results of substantial investments in terms of time, cost, and specialized technical know-how. Competitors could use this information to avoid similar development costs and shortcut complex analytical and regulatory workstreams, thereby reducing GLEs competitive edge and return on investment.
DECONTROLLED NOTICE Page 4 of 4
- 6. Of particular note, uranium enrichment is a highly competitive sector of the nuclear fuel cycle, and the NRC is currently reviewing or anticipating the submission of several enrichment facility applications. Public disclosure of GLEs proprietary information at this juncture would provide other market participants with an opportunity to extract regulatory, financial, and technical strategies from GLEs submittals, thereby distorting the level playing field intended by the NRC's licensing process and undermining the commercial integrity of GLEs position.
- 7. The cumulative detail and strategic integration of the application materials render even those components commercially sensitive. Taken together, they could serve as a roadmap for other applicants, effectively allowing competitors to reverse-engineer or mirror GLEs submission strategy without incurring the same investment or technical rigor.
- 8. Due to the dynamic and highly competitive nature of current enrichment licensing activity, the requested withholding is also time sensitive. GLE respectfully requests that the NRC grant this exemption on an expedited basis and GLE agrees to revisit the scope of the requested withholdings at a mutually appropriate future date, once the risk of competitive harm has materially subsided or market conditions warrant reconsideration.
- 9. Redaction of the proprietary information would render the public versions of these documents devoid of substantive content and would be of no practical utility to the public or stakeholders.
- 10. The information that GLE requests to be withheld from public disclosure is contained in the entire document(s) as so marked.
- 11. The information stated in this affidavit has been submitted in accordance with the applicable parts of 10 CFR 2.390 and the guidance contained in NUREG-1556, Vol.
20, Appendix F.
I declare under penalty of perjury that the foregoing is true and correct.
Tim Knowles Date Licensing & Regulatory Affairs Manager