ML18078A191: Difference between revisions
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==References:== | ==References:== | ||
1) NRC License SNM-1 097, Docket 70-1113 2) NRC License SNM-2500, Docket 72-01 3) NRC License SNM-960, Docket 70-754 4) NRC License DPR-1, Docket 50-18 5) NRC License DR-1 0, Docket 50-183 6) NRC License TR-1, Docket 50-70 7) NRC License R-33, Docket 50-73 8) GE Company Parent Guarantee of Decommissioning Funds, 5/1/17 9) Telecom with GEH and NRC Staff to Discuss GE Company Financial Assurance, 3/8/18 | : 1) NRC License SNM-1 097, Docket 70-1113 2) NRC License SNM-2500, Docket 72-01 3) NRC License SNM-960, Docket 70-754 4) NRC License DPR-1, Docket 50-18 5) NRC License DR-1 0, Docket 50-183 6) NRC License TR-1, Docket 50-70 7) NRC License R-33, Docket 50-73 8) GE Company Parent Guarantee of Decommissioning Funds, 5/1/17 9) Telecom with GEH and NRC Staff to Discuss GE Company Financial Assurance, 3/8/18 | ||
==Dear Sir or Madam:== | ==Dear Sir or Madam:== | ||
As requested by NRC Staff on March 8, 2018 (Reference 9), Attachment 2 to this letter provides GE Hitachi Nuclear Energy Americas, L.L.C (GEH) and Global Nuclear Fuel-Americas (GNF-A) supplemental information regarding their use of a parent company guarantee of funds for decommissioning costs. If you have any questions concerning this letter, please call me at (91 0) 819-5950. Sincerely, Facility Licensing | As requested by NRC Staff on March 8, 2018 (Reference 9), Attachment 2 to this letter provides GE Hitachi Nuclear Energy Americas, L.L.C (GEH) and Global Nuclear Fuel-Americas (GNF-A) supplemental information regarding their use of a parent company guarantee of funds for decommissioning costs. If you have any questions concerning this letter, please call me at (91 0) 819-5950. Sincerely, Facility Licensing | ||
US NRC March 19, 2018 M180053 Page 2 of 2 (8) The information identified in paragraph (2) above is classified as proprietary because it contains details of GEH's processes, design and manufacturing facilities. (9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEH's competitive position and foreclose or reduce the availability of profit-making opportunities. The facility design and licensing methodology is part of GEH's comprehensive safety and technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods. The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GER. The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial. GEH's competitive advantage will be lost if its competitors are able to use the results of the GEH experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions. The value of this information to GEH would be lost if the information were disclosed to the public. Making such information available to competitors without there having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GEH of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable analytical tools. I declare under penalty of perjury that the foregoing is true and correct. Executed on this 19th day of March 2018. Scott P. Murray GE Hitachi Nuclear Energy ricas, L.L.C. STATE OF NORTH CAROLINA COUNTY OF NEW HANOVER Subscribed and sworn to me, ' NotMY Public, St.P. No;;= 9th d*y of MMch 2018. My Commission Expires: .June 23, 2018 Notary Public in and for the State of North Carolina | US NRC March 19, 2018 M180053 Page 2 of 2 (8) The information identified in paragraph (2) above is classified as proprietary because it contains details of GEH's processes, design and manufacturing facilities. (9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEH's competitive position and foreclose or reduce the availability of profit-making opportunities. The facility design and licensing methodology is part of GEH's comprehensive safety and technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods. The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GER. The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial. GEH's competitive advantage will be lost if its competitors are able to use the results of the GEH experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions. The value of this information to GEH would be lost if the information were disclosed to the public. Making such information available to competitors without there having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GEH of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable analytical tools. I declare under penalty of perjury that the foregoing is true and correct. Executed on this 19th day of March 2018. Scott P. Murray GE Hitachi Nuclear Energy ricas, L.L.C. STATE OF NORTH CAROLINA COUNTY OF NEW HANOVER Subscribed and sworn to me, ' NotMY Public, St.P. No;;= 9th d*y of MMch 2018. My Commission Expires: .June 23, 2018 Notary Public in and for the State of North Carolina}} | ||
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Revision as of 23:10, 17 May 2018
| ML18078A191 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos Nuclear Center, 07000754, 07001113, 07200001, Vallecitos |
| Issue date: | 03/19/2018 |
| From: | Murray S P GE-Hitachi Nuclear Energy Americas |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML18078A189 | List: |
| References | |
| M180053 | |
| Download: ML18078A191 (4) | |
Text
(. HITACHI Proprietary Information Notice Attachment 2 to this letter contains GE Hitachi Nuclear Energy proprietary information which is to be withheld from public disclosure in accordance with 10 CFR 2.390 and RIS 2005-31. Upon removal of Attachment 2, the balance of this letter may be made public. M180053 March 19, 2018 U.S. Nuclear Regulatory Commission Director, Office of Nuclear Material Safety and Safeguards Director, Office of Nuclear Reactor Regulation Washington, DC 20555-0001 ATTN: Document Control Desk GE Hitachi Nuclear Energy Scott P. Murray Manager, Facility Licensing 3901 Castle Hayne Road P.O. Box 780 Wilmington, NC 28402 USA T (910) 819-5950 scott.murray@ ge.com
Subject:
GEH/GNF-A Financial Assurance of Decommissioning Funds-Supplemental Information
References:
- 1) NRC License SNM-1 097, Docket 70-1113 2) NRC License SNM-2500, Docket 72-01 3) NRC License SNM-960, Docket 70-754 4) NRC License DPR-1, Docket 50-18 5) NRC License DR-1 0, Docket 50-183 6) NRC License TR-1, Docket 50-70 7) NRC License R-33, Docket 50-73 8) GE Company Parent Guarantee of Decommissioning Funds, 5/1/17 9) Telecom with GEH and NRC Staff to Discuss GE Company Financial Assurance, 3/8/18
Dear Sir or Madam:
As requested by NRC Staff on March 8, 2018 (Reference 9), Attachment 2 to this letter provides GE Hitachi Nuclear Energy Americas, L.L.C (GEH) and Global Nuclear Fuel-Americas (GNF-A) supplemental information regarding their use of a parent company guarantee of funds for decommissioning costs. If you have any questions concerning this letter, please call me at (91 0) 819-5950. Sincerely, Facility Licensing
US NRC March 19, 2018 M180053 Page 2 of 2 (8) The information identified in paragraph (2) above is classified as proprietary because it contains details of GEH's processes, design and manufacturing facilities. (9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEH's competitive position and foreclose or reduce the availability of profit-making opportunities. The facility design and licensing methodology is part of GEH's comprehensive safety and technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods. The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GER. The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial. GEH's competitive advantage will be lost if its competitors are able to use the results of the GEH experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions. The value of this information to GEH would be lost if the information were disclosed to the public. Making such information available to competitors without there having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GEH of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable analytical tools. I declare under penalty of perjury that the foregoing is true and correct. Executed on this 19th day of March 2018. Scott P. Murray GE Hitachi Nuclear Energy ricas, L.L.C. STATE OF NORTH CAROLINA COUNTY OF NEW HANOVER Subscribed and sworn to me, ' NotMY Public, St.P. No;;= 9th d*y of MMch 2018. My Commission Expires: .June 23, 2018 Notary Public in and for the State of North Carolina