ML18075A088

Global Nuclear Fuel - Americas, LLC - Submittal of NRC Region Ii Requested Document

ML18075A088
Person / Time
Site:	07001113
Issue date:	03/16/2018
From:	Murray S P Global Nuclear Fuel
To:	Eric Michel Document Control Desk, Office of Nuclear Material Safety and Safeguards, NRC/RGN-II
Shared Package
ML18075A087	List: ML18075A088
References
EA-17-090, M180054
Download: ML18075A088 (3)

Text

Global Nuclear Fuel Proprietary Information Notice This letter forwards proprietary information to be withheld from public disclosure in accordance with 10CFR2.390. Upon removal of Attachment 2 , the balance of this letter may be made public. M180054 Ma r ch 16, 2018 Eric Michel, Branch Chief NRC Region II US Nuclear Regulatory Commission 245 Peachtree Center Avenue, NE Atlanta , GA 30303-1257 Attn: Document Control Desk

Subject:

NRC Region II Requested Document Re f erence: 1) NRC License SNM 1097 , Docket 70-1113 2) NRC GNF-A Confirmatory Order EA-17-090 , 12/14/17 3) Letter A. Hilton to C. Haney, 2/12/2018

4) Phone Request E. Michel to S. Murray, 3/14/2018

Dear Mr. Michel:

Global Nuclear Fuel Scott P. Murray Manager , Facility Licensing 3901 Castle Hayne Road P.O. Bo x 7 80 Wilmington , NC 28402 USA T (91 0) 819-5950 scott.murray@ge

.com Attached is the documentation as listed below, that you have requested. This document contains GE Hitachi Nuclear Energy (GEH) Proprietary Information and should be protected accordingly. It is our understanding that you will protect this document from public disclosure. 1) Nuclear Safety Culture Assessment of GE Hitachi Nuclear (Proprietary)

If you have any questions concerning this information, please call me at (91 0) 819-5950.

Sincerely , /().

Facility Licensing {;/ Commitments:

None Attachment(s):

1. Affidav i t 2. Nuclear Safety Culture Assessment of GE Hitachi Nuclear (Proprietary)

Cc: SPM 18-019

(8) The information identified in paragraph (2) above is classified as proprietary because it contains details of GEH' s processes, design and manufacturing fac.ilities.

(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 GEH. 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 their 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 16th day of March 2018. GE Hitachi Nuclear Energy STATE OF NORTH CAROLINA COUNTY OF NEW HANOVER Subscribed and sworn to me, a Notary Public, in and for the State of North Carolina, this 16th day of March 2018. My Commission Expires: June 23, 2018 Notary Public in and for the State of North Carolina