ML19311C709

Global Nuclear Fuel - Americas (GNF-A), Request for Withholding Information from Public Disclosure

ML19311C709
Person / Time
Site:	99901376
Issue date:	12/05/2019
From:	Ngola Otto Licensing Processes Branch
To:	Michelle Catts GE Hitachi Nuclear Energy
Otto N, 415-6695
References
EPID L-2018-TOP-0006
Download: ML19311C709 (4)

Text

December 5, 2019 Ms. Michelle P. Catts Senior Vice President, Regulatory Affairs GE-Hitachi Nuclear Energy Americas, LLC P.O. Box 780 M/C A-10 Wilmington, NC 28401

SUBJECT:

GLOBAL NUCLEAR FUEL - AMERICAS (GNF-A), REQUEST FOR WITHHOLDING INFORMATION FROM PUBLIC DISCLOSURE (EPID L-2018-TOP-0006)

Dear Ms. Catts:

By letter dated October 29, 2019 (Letter No. M190192, Agencywide Documents Access and Management System (ADAMS) Accession No. ML19302F246), Global Nuclear Fuel (GNF) provided a response to the U.S. Nuclear Regulatory Commission (NRC) staffs request to identify any information that it considers proprietary and provide comments on factual errors or clarity concerns in the Draft Safety Evaluation (SE) for Licensing Topical Report (LTR)

NEDE-33885P, Revision 0, GNF Control Rod Drop Accident (CRDA) Application Methodology.

In the October 29, 2019, letter, GNF submitted proprietary and non-proprietary versions of the Draft SE and Comment Summary Table and an affidavit dated October 29, 2019 (ADAMS Accession No. ML19302F249), that was submitted and executed by Dr. Brian R. Moore, General Manager Core and Fuels Engineering, GNF, requesting that the information contained in Draft SE for LTR NEDE-33885P, Revision 0, be withheld from public disclosure pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 2.390.

The nonproprietary copy of the Draft SE and Comment Summary Table has been placed in the NRCs Public Document Room and are available in ADAMS Accession No. ML19302F248.

The affidavit stated that the submitted information should be considered exempt from mandatory public disclosure because it is:

a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GNF-As competitors without license from GNF-A constitutes a competitive economic advantage over other companies;

b. Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product.

We have reviewed your submittal and the material in accordance with the requirements of 10 CFR 2.390 and, on the basis of your statements, have determined that the submitted information sought to be withheld contains proprietary commercial information and should be withheld from public disclosure.

M. Catts Therefore, the version of the submitted information marked as proprietary will be withheld from public disclosure pursuant to 10 CFR 2.390(b)(5) and Section 103(b) of the Atomic Energy Act of 1954, as amended.

Withholding from public inspection shall not affect the right, if any, of persons properly and directly concerned to inspect the documents. If the need arises, we may send copies of this information to our consultants working in this area. We will, of course, ensure that the consultants have signed the appropriate agreements for handling proprietary information.

If the basis for withholding this information from public inspection should change in the future such that the information could then be made available for public inspection, you should promptly notify the NRC. You also should understand that the NRC may have cause to review this determination in the future, for example, if the scope of a Freedom of Information Act request includes your information. In all review situations, if the NRC makes a determination adverse to the above, you will be notified in advance of any public disclosure.

If you have any questions regarding this matter, I may be reached at 301-415-6695.

Sincerely,

/RA/

Ngola Otto, Project Manager Licensing Processes Branch Division of Licensing Projects Office of Nuclear Reactor Regulation Docket No. 99901376 cc: See next page

M. Catts GE-Hitachi Nuclear Energy Americas Project 712 Docket No. 99901376 cc:

Ms. Michelle P. Catts Senior Vice President, Regulatory Affairs GE-Hitachi Nuclear Energy Americas, LLC P.O. Box 780 M/C A-10 Wilmington, NC 28401 Michelle.Catts@ge.com Mr. Kent E. Halac Senior Project Manager, Regulatory Affairs GE-Hitachi Nuclear Energy Americas, LLC P.O. Box 780, M/C A-70 Wilmington, NC 28401-0780 Kent.Halac@ge.com Dr. Brian R. Moore General Manager, Core & Fuel Engineering Global Nuclear Fuel-Americas, LLC P.O. Box 780, M/C A-75 Wilmington, NC 28401-0780 Brian.Moore@ge.com

ML19311C709 OFFICE NRR/DORL/LLPB/PM NRR/DORL/LLPB/LA NRR/DSS/SNPB NRR/DORL/LLPB/BC NRR/DORL/LLPB/PM NAME NOtto DHarrison* RLukes DMorey NOtto DATE 12/2/19 12/2/19 12/4/19 12/5/19 12/5/19