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MONTHYEARML22277A5392022-10-0404 October 2022 Updated GNF-A Fuel Fabrication Facility Decommissioning Funding Plan Project stage: Request ML23089A2392023-04-10010 April 2023 Global Nuclear Fuel Americas, LLC, Triennial - 2022 Update to Decommissioning Funding Plan - Supplemental Information Needed - Enterprise Project Identification Number L-2022-DDP-0002 Project stage: Other ML23089A2402023-04-10010 April 2023 Encl: GNF-A 2022 DFP Request for Supplemental Information Project stage: Other ML23116A1842023-04-26026 April 2023 GNF-A Response to NRC Request for Supplemental Information - Decommissioning Funding Plan (DFP) Project stage: Request ML23178A0992023-06-27027 June 2023 GNF-A Additional Response to Nrg Request for Supplemental Information - Decommissioning Funding Plan (DFP) Project stage: Request ML23202A0872023-08-0101 August 2023 Acceptance of GNF-A 2022 Triennial Update to Decommissioning Funding Plan Project stage: Acceptance Review ML24129A1832024-05-21021 May 2024 Global Nuclear Fuel - Americas LLC RAI to Support Review of Global Nuclear Fuel-Americas Updated Fuel Fabrication Facility Decommissioning Funding Plan Project stage: RAI ML24268A0382024-09-25025 September 2024 Approval Letter of Global Nuclear Fuel - Americas, LLC 2022 Triennial Update to Decommissioning Funding Plan Project stage: Other 2023-06-27
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Category:Legal-Affidavit
MONTHYEARML24275A0342024-10-0101 October 2024 GNF-A Emergency Response Telephone Listing Dated 9/27/2024 ML24240A0702024-08-26026 August 2024 GNF-A Submittal of FOCI Information Update ML24184A1262024-07-0202 July 2024 Global Nuclear Fuel - Americas, LLC, Submittal of Response to NRC Request for Additional Information ML24172A0612024-06-20020 June 2024 GNF-A Comments on Buildings as IROFS - Meeting Slides ML24156A2032024-06-0404 June 2024 GNF-A Natrium Fuel Fabrication Facility Pre-Application - Meeting Slides ML24101A2372024-04-10010 April 2024 GNF-A Submittal of Emergency Response Telephone Listing Dated 4/2/2024 ML23229A5122023-08-17017 August 2023 GE-Hitachi Nuclear Energy Americas, LLC, Response to NRC Staff Observations Enclosed with NRC Acceptance Letter (Reference 2) Related to GE, Geha and GNF-A Application (Reference 1) ML23178A0992023-06-27027 June 2023 GNF-A Additional Response to Nrg Request for Supplemental Information - Decommissioning Funding Plan (DFP) ML23104A4172023-03-31031 March 2023 GNF-AGEH Financial Assurance of Decommissioning Funds - Surety Bond Riders Cover Letter and Affidavit ML23033A5422023-02-0202 February 2023 Global Nuclear Fuel - Americas, LLC - Submittal of FOCI Information Update ML23030A8022023-01-30030 January 2023 Submittal of GNF-A Natrium Fuel Fabrication Facility Pre-Application - Meeting Slides ML22355A1622022-12-20020 December 2022 GNF-A Submittal of FOCI Information Update ML22264A1772022-09-21021 September 2022 GNF-A - Submittal of FOCI Information Update ML22084A5782022-03-23023 March 2022 GNF-A/GEH Financial Assurance of Decommissioning Funds - Surety Bond Riders Cover Letter and Affidavit ML22020A1292022-01-20020 January 2022 Global Nuclear Fuel - Americas, LLC, Request to Approve Safety Analytic Methods ML21166A3582021-06-15015 June 2021 GE-Hitachi Nuclear Energy Americas, LLC, a Submittal of Oodep Updates ML20316A0242020-11-11011 November 2020 Global Nuclear Fuel-Americas - NRC Request for Documents ML18096A4682018-04-0606 April 2018 Global Nuclear Fuel - Americas, LLC - Submittal of NRC Region Ii Requested Document M180053, GEH/GNF-A Financial Assurance of Decommissioning Funds - Supplemental Information2018-03-19019 March 2018 GEH/GNF-A Financial Assurance of Decommissioning Funds - Supplemental Information ML18075A0882018-03-16016 March 2018 Global Nuclear Fuel - Americas, LLC - Submittal of NRC Region Ii Requested Document 2024-08-26
[Table view] Category:Letter
MONTHYEARML24275A0342024-10-0101 October 2024 GNF-A Emergency Response Telephone Listing Dated 9/27/2024 ML24268A0382024-09-25025 September 2024 Approval Letter of Global Nuclear Fuel - Americas, LLC 2022 Triennial Update to Decommissioning Funding Plan ML24255A8022024-09-11011 September 2024 GNF-A DFP Supplemental Information ML24250A0482024-09-0606 September 2024 Global Nuclear Fuel Americas, LLC (GNF-A) NRC Licensee Contacts ML24240A0702024-08-26026 August 2024 GNF-A Submittal of FOCI Information Update ML24236A0222024-08-22022 August 2024 GNF-A Written Follow-up Report - Fire System Impairment ML24219A2632024-08-0606 August 2024 GNF-A Semi-Annual Effluent Monitoring Report ML24205A1392024-07-25025 July 2024 Global Nuclear Fuels-America - Core Inspection Report 07001113/2024002 ML24184A1262024-07-0202 July 2024 Global Nuclear Fuel - Americas, LLC, Submittal of Response to NRC Request for Additional Information ML24180A0132024-06-28028 June 2024 GNF-A Fundamental Nuclear Material Control Plan ML24176A2742024-06-25025 June 2024 Global Nuclear Fuel – Americas, L.L.C. – Inspection Schedule for Calendar Year 2025 ML24172A0612024-06-20020 June 2024 GNF-A Comments on Buildings as IROFS - Meeting Slides ML24156A2032024-06-0404 June 2024 GNF-A Natrium Fuel Fabrication Facility Pre-Application - Meeting Slides ML24129A1832024-05-21021 May 2024 Global Nuclear Fuel - Americas LLC RAI to Support Review of Global Nuclear Fuel-Americas Updated Fuel Fabrication Facility Decommissioning Funding Plan ML24128A1602024-05-0707 May 2024 Submittal of Revision to GNF-A Radiological Contingency & Emergency Plan (Rc&Ep) ML24121A1652024-04-30030 April 2024 Global Nuclear Fuel - Americas, LLC - Annual Reporting ML24110A0432024-04-23023 April 2024 Global Nuclear Fuel - Americas - Core Inspection Report 07001113/2024001 ML24103A1992024-04-12012 April 2024 Submittal of Revision to GNF-A Radiological Contingency & Emergency Plan (Rc&Ep) ML24101A2372024-04-10010 April 2024 GNF-A Submittal of Emergency Response Telephone Listing Dated 4/2/2024 ML24074A3632024-03-15015 March 2024 Global Nuclear Fuels - Americas - NRC Inspection Report 07001113-2024006 ML24068A1302024-03-0808 March 2024 Global Nuclear Fuel - Request to Withdraw GNF-A Supplemental Environmental Report ML24017A1602024-01-31031 January 2024 Global Nuclear Fuel - Americas - Core Inspection Report 07001113-2023004 ML24030A5182024-01-30030 January 2024 Global Nuclear Fuel - Americas, LLC (GNF-A), Submittal of Revised ISA Summary Per 10CFR70.72(d) ML24008A2892024-01-10010 January 2024 Global Nuclear Fuel-Americas - NRC Inspection Report 07001113/2023006 ML24003A6832024-01-0404 January 2024 Global Nuclear Fuel - Americas, L.L.C. – Material Control and Accounting Program Inspection Report 07001113-2023401 - Public ML23311A3802023-12-11011 December 2023 Cover Letter - Safety Evaluation Report for GNF-A Request for 8 Weight Percent Uranium 235 ML23283A3292023-11-30030 November 2023 NRC Issuance of Order Consenting to Indirect Transfer of Control of Ge/Geha/Gnfa Licenses ML23334A2222023-11-30030 November 2023 GE Hitachi Nuclear Energy - NRC Notice Before Actions Necessary to Accomplish the Indirect Transfers of Control Are Completed ML23276B3952023-10-13013 October 2023 the U.S. Nuclear Regulatory Commission Staff Assessment of Ge/Geha/Gnfa Reponses to Acceptance Observations Application for the U.S. Nuclear Regulatory Commission Consent to Indirect Transfer of Licenses ML24005A2842023-09-18018 September 2023 23-004 M230129 GNF-A 2023 Biennial Exercise Supplement NRC Cover Letter 9-18-2023 ML23255A2902023-09-13013 September 2023 Global Nuclear Fuel Americas, L.L.C. Inspection Schedule for Calendar Year 2024 ML23230A3942023-08-18018 August 2023 GNF-A Semi-Annual Effluent Monitoring Report ML23229A5122023-08-17017 August 2023 GE-Hitachi Nuclear Energy Americas, LLC, Response to NRC Staff Observations Enclosed with NRC Acceptance Letter (Reference 2) Related to GE, Geha and GNF-A Application (Reference 1) ML23213A1452023-08-0202 August 2023 Global Nuclear Fuel Americas, LLC Core Inspection Report 07001113/2023002 ML23209A6762023-07-28028 July 2023 GNF-A Response to NRC Request for Additional Information ML24005A2782023-07-27027 July 2023 23-030 M230100 GNF-A 2023 Biennial Exercise NRC Cover Letter 7-27-23 ML23191A8592023-07-27027 July 2023 Acceptance Letter GE GNFA and Geha Application for NRC Consent to Indirect Transfer of Licenses ML23195A0942023-07-14014 July 2023 GNF-A Written Follow-up Report Fire System Impairment ML23192A5162023-07-11011 July 2023 GNF-A Natrium Fuel Fabrication Facility Schedule Update ML23156A1832023-07-0303 July 2023 Request for Additional Information Regarding GNF-A License Amendment Request for 8 Weight Percent Uranium 235 ML23178A0992023-06-27027 June 2023 GNF-A Additional Response to Nrg Request for Supplemental Information - Decommissioning Funding Plan (DFP) ML23177A0892023-06-26026 June 2023 Geha and GNF-A Application for Indirect Transfer of Control - Revision 2 ML23171A9762023-06-20020 June 2023 Geha and GNF-A Application for Indirect Transfer of Control - Revision 1 ML23159A1342023-06-0808 June 2023 Global Nuclear Fuel - Americas, LLC, Physical Inventory Summary Reports ML23152A1162023-05-30030 May 2023 Application for Order Consenting to Indirect Transfer of Control with Respect to Reactor Licenses, Materials Licenses, and Export Licenses, and Notification Regarding Other Approvals ML23116A3212023-04-27027 April 2023 Public Meeting Summary Licensee Performance Review of Global Nuclear Fuel Americas, LLC, Docket Number 07001113 ML23116A1842023-04-26026 April 2023 GNF-A Response to NRC Request for Supplemental Information - Decommissioning Funding Plan (DFP) ML23089A2392023-04-10010 April 2023 Global Nuclear Fuel Americas, LLC, Triennial - 2022 Update to Decommissioning Funding Plan - Supplemental Information Needed - Enterprise Project Identification Number L-2022-DDP-0002 ML23104A4172023-03-31031 March 2023 GNF-AGEH Financial Assurance of Decommissioning Funds - Surety Bond Riders Cover Letter and Affidavit ML23065A0722023-03-0606 March 2023 Global Nuclear Fuel Americas (GNF-A), Supplemental Environmental Report Information and Request to Begin Construction 2024-09-06
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GNr Global Nuclear Fuel Global Nuclear fuel Scott P. Murray Manager, Facility Licensing 390-1 Castle Mayne Road -
P.O. Box 780 Wilmington, NC 28402 Proprietary Information Notice Attachment 2 to this Jetter contains proprietary information to be USA
- - - _~ -T (910) 819-5950 -
withhe/d from pubfic *disclosure in accordance with 10CFR2.390.
s~tt-~_urr~ @ge.com Upon the removal of Attacl1_1!1_ent 2, the balance of this~letter can be made public.
M230086 June 27, 2023 Samantha Lav., Chief Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Material Safety & Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Attn: Document Control Desk
Subject:
GNF-A Additional Response to NRG Request for Supplemental Information - Decommissioning Funding Plan (DFP} . ,
References:
1} NRG License SNM-1097, Docket 70-1113
- 2) GNF-A Decommissioning Funding Plan, Rev. 8, 10/4/22
- 3) Letter, from Jonathan Rowley (NRG} to S. P. Murray (GNF-A} Request for Supplemental Information Regarding Update to DFP, 4/10/23
- 4) Letter, from S. P. Murray (GNF-A} to J. Rowley (NRG}, GNF-A Re~ponse to NRG Request, 4/26/23 .
- 5) Telecom betwe-en NRG Staff, including Ms. Samantha Lav and GNF-A, including Scott Murray held 6/14/23- - -
Dear Ms. Lav:
As we discussed on June 14, 2023 (Reference 5), the Global Nuclear Fuel-Americas, LL.C.
(GNF-A} facility in Wilmington, North Carolina hereby provides additional information regarding the GNF-A Decommissioning Funding Plan, Rev. 8 dated October 4, 2022.
Attachment 2 to this letter contains GNF-A proprietary information to be withhelo from public disclosure.
If you have any questions regarding this information, please contact me at (91 O} 819-5950.
Sincerely, s~l!J~
Facility Licensing /
M230086 USNRC June 27, 2023 Page? of2 Attachments: 1) GNF-A Affidavit
- 2) GNF-A Additional Information Regarding the GNF-A Decommissioning Funding Plan, Revision 8 - - - -- -
cc: J. Rowley, USNRC/DFM/FFLB SPM 23-024 .
M230086 USNRC June 27, 2023 Page l- of2 _
Attachment 1 AFFIDAVIT I, Scott P. Murray, state as follows:
(1) am f the Manager, Facility Licensing of Global Nuclear Fuel - Americas (GNF-A) and have been delegated the function by GNF-A of reviewing the information described in paragraph (2) which is sought to be-withheld and have been authorized to.apply for its withholding. _ __
(2) The information sought to be withheld is contained in Attachment 2 to GNF-A's letter, M2-30086, S, Murray *- **-
to Samantha Lav, entitled GNF-A Additional Response to NRC Request for Suppl~mental lnformation.-GNF--
A proprietary information is contained in Attachment 2 and is identified by the statement "GNF-A Proprietary Information".
(3) In making this application for withholding of proprietary information of which it is the owner or licensee, GNF-A relies upon the exemption from disclosure set forth in the Freedom of Information Act (FOIA), 5 USC Sec.
552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations IO CFR_9.17(a)(4), and 2.390(a)(4) for trade secrets {Exemption 4). The material for which exemption from disclosure is here sought also qualifies under the narrower definition of trade secret, witnin the meanings assignea to those terms for purposes of FOIA Exemption *4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission. 975 F2d 871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F2d 1280 (DC Cir. 1983).
(4) The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4 )a. and (4 )b. Some examples of cate¥ories of i~formation that fit into the definition of proprietary information are:
- a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GNF-A's competitors without license from GNF-A constitutes a competitive economic advantage over GNF-A and/or other companies.
- b. Information that, if used by a*cornpetitor, would reduce their expenditure of resources or improve their competitive position in the design, manufacture, shipment, installation, assurance of quality, or lice*nsing of a similar product. * *
(5) To address IO CFR 2.390(b)(4), the information sought to be withheld is being submitted to the NRC in confidence. The information is of a sort customarily held in confidence by GNF-A, and is in.fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GNF-A, not been disclosed publicly, and not been made available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary and/or confidentiality agreements that provide for maintaining the information in confidence. The initial designation of this information as proprietary information, and the subsequent steps taken to prevent its unautliorized disclosure are as set forth in the following paragraphs (6) and (7).
(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, who is the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or who is the person most likely to be subject to the terms under which it was licensed to GEH. Access to such documents within GNF-A is limited to a "need to know" basis.
(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist, or other equivalent authority for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GNF-A are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary and/or confidentiality agreements.
(8) The information identified in paragraph (2) above is classified as proprietary because it contains details of GNF-A's processes, design and manufacturing facilities.
M230086 USNRC June 27, 2023 Page 2 of2 (9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GNP-A's competitive position and foreclose or reduce the availability of profit-making opportunities. The facility design and licensing methodology is part of GNP-A'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. -lo 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 GNP-A. 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. GNP-A's competitive advantage will be lost if its competitors are able to use the results of the GNP-A 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 GNP-A would be lost if the information were disclosed to the public. Making such information available to competito_rs without their having been required to undertake a similar expend!ture of resources would unfairly provide competitors with a windfall, and deprive GNP-A 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 ~e foregoing is true and correct.
Executed on this 27th day of June 2023.
/(~P/Y2~
Scott~~;y Global Nuclear Fuel - Americas STATE OF NORTH CAROLINA )
) ...
COUNTY OF NEW HANOVER )
Subscribed and sworn to me, a Notary Pub~ic, in and for the State of North Carolina, this 27th day of June 2023.
qQ ~a.n Da.luwv NtaryPic in and for the -
State of North Carolina My Commission Expires: $$0 'J.l MORGAN DATEMA Notary Public, North Carolina New Hanover County My Commission Expires April 30, 2027