ML18212A239
| ML18212A239 | |
| Person / Time | |
|---|---|
| Site: | 05200021 |
| Issue date: | 07/25/2018 |
| From: | Mori T Mitsubishi Heavy Industries, Ltd |
| To: | George Wunder NRC/NRO/DLSE/LB2 |
| References | |
| MUAP-07001-P, Rev. 6, UAP-HF-18005 | |
| Download: ML18212A239 (4) | |
Text
J.,.
MITSUBISHI HEAVY INDUSTRIES, LTD.
1-1, WADASAKI-CHO, 1-CHOME, HYOGOKU, KOBE, 652-8585 JAPAN July 25, 2018 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attention: Mr. George Wunder Docket No.52-021 MHI Ref: UAP-HF-18005
Subject:
MHl's Review Results for Topical Report Safety Evaluation for MUAP-07001-P, Revision 6, "The Advanced Accumulator"
References:
[1] "United States -Advanced Pressurized Water Reactor Advanced Topical Report Safety Evaluation for Topical Report MUAP-07001, Revision 6, 'The Advanced Accumulator'"' dated June 21, 2018.
With this letter, Mitsubishi Heavy Industries, LTD. ("MHI") transmits to the U.S. Nuclear Regulatory Commission ("NRC") the document entitled "MHl's Review Results for Topical Report Safety Evaluation for MUAP-07001-P, Revision 6, "The Advanced Accumulator"", which is related to Topical Report, the Advanced Accumulator, MUAP-07001 Revision 6.
As indicated in the enclosed material, this document contains information that MHI considers proprietary, and therefore should be withheld from public disclosure pursuant to 10 C.F.R. § 2.390 (a)(4) as trade secrets and commercial or financial information which is privileged or confidential.
As described in Reference [1], the current safety evaluation is based on MUAP-07001-P, Revision
- 6. However, the latest version of MUAP-07001 is revision 7, which was revised based on the previous request for incorporation of outstanding RAI discussions. Therefore, the safety evaluation should be updated based on the latest revision of MUAP-07001.
This letter includes a copy of the proprietary version (Enclosure 2) and the Affidavit of Takayuki Mori (Enclosure 1) which identifies the reasons MHI respectfully requests that all materials designated as "Proprietary" in Enclosure 2 be withheld from public disclosure pursuant to 10 C.F.R. § 2.390 (a)(4).
Please contact Mr. Joseph Tapia, Principal Consulting Engineer, Mitsubishi Nuclear Energy Systems, Inc. if the NRC has questions concerning any aspect of this submittal. His contact information is below.
Sincerely, 7
Takayuki Mori, Engineering Manager Global Nuclear Project Department Nuclear Energy Systems Division Power Systems Mitsubishi Heavy Industries, Ltd.
Enclosures:
1 - Affidavit of Takayuki Mori 2 - MHl's Review Results for Topical Report Safety Evaluation for MUAP-07001-P, Revision 6, "The Advanced Accumulator" (Proprietary)
CC: G. Wunder J. Tapia Contact Information Joseph Tapia, Principal Consulting Engineer Mitsubishi Nuclear Energy Systems, Inc.
13860 Ballantyne Corporate Place, Ste. 250 Charlotte, NC 28277 E-mail: joseph_tapia@mnes-us.com Telephone: (202) 631 - 1002
ENCLOSURE 1 Docket No.52-021 MHI Ref: UAP-HF-18005 MITSUBISHI HEAVY INDUSTRIES, LTD.
AFFIDAVIT I, Takayuki Mori, state as follows:
- 1. I am Engineering Manager of Global Nuclear Project Department, Nuclear Energy Systems Division, Power Systems, Mitsubishi Heavy Industries, Ltd. ("MHI"), and have been delegated the function of reviewing MHl's US-APWR documentation to determine whether it contains information that should be withheld from public disclosure pursuant to 10 C.F.R. § 2.390 (a)(4) as trade secrets and commercial or financial information which is privileged or confidential.
- 2. In accordance with my responsibilities, I have reviewed the enclosed document entitled "MHl's Review Results for Topical Report Safety Evaluation for MUAP-07001-P, Revision 6, "The Advanced Accumulator"" dated July 25, 2018, and have determined that portions of the document contain proprietary information that should be withheld from public disclosure.
Those pages containing proprietary information are identified with the label "Proprietary" on the top of the page and the proprietary information has been bracketed with an open and closed bracket as shown here"[ ]". The first page of the document indicates that all information identified as "Proprietary" should be withheld from public disclosure pursuant to 10 C.F.R. § 2.390 (a)(4).
- 3. The information identified as proprietary in the enclosed document has in the past been, and will continue to be, held in confidence by MHI and its disclosure outside the company is limited to regulatory bodies, customers and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and is always subject to suitable measures to protect it from unauthorized use or disclosure.
- 4. The basis for holding the referenced information confidential is that it describes the unique design of the Advanced Accumulator developed by MHI and not used in the exact form by any of MHl's competitors. This information was developed at significant cost to MHI, since it required the performance of Research and Development and detailed design for its software and hardware extending over several years.
- 5. The referenced information is being furnished to the Nuclear Regulatory Commission
("NRC") in confidence and solely for the purpose of information to the NRC staff.
- 6. The referenced information is not available in public sources and could not be gathered readily from other publicly available information. Other than through the provisions in paragraph 3 above, MHI knows of no way the information could be lawfully acquired by organizations or individuals outside of MHI.
- 7. Public disclosure of the referenced information would assist competitors of MHI in their design of new nuclear power plants without incurring the costs or risks associated with the design and testing of the subject systems. Therefore, disclosure of the information contained in the referenced document would have the following negative impacts on the competitive position of MHI in the U.S. nuclear plant market:
A. Loss of competitive advantage due to the costs associated with development and testing of the Advanced Accumulator. Providing public access to such information permits competitors to duplicate or mimic the Advanced Accumulator design without incurring the associated costs.
B. Loss of competitive advantage of the US-APWR created by benefits of enhanced plant safety, and reduced operation and maintenance costs associated with the Advanced Accumulator.
I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information and belief.
Executed on this 25th day of July, 2018.
7~,
Takayuki Mori, Engineering Manager Global Nuclear Project Department Nuclear Energy Systems Division Power Systems Mitsubishi Heavy Industries, Ltd.