ML19219A142
| ML19219A142 | |
| Person / Time | |
|---|---|
| Site: | 05200021 |
| Issue date: | 07/29/2019 |
| From: | Mori T Mitsubishi Heavy Industries, Ltd |
| To: | George Wunder Document Control Desk, Office of New Reactors |
| Shared Package | |
| ML19219A187 | List: |
| References | |
| UAP-HF-19002 | |
| Download: ML19219A142 (4) | |
Text
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MITSUBISHI HEAVY INDUSTRIES, LTD.
1-1, WADASAKI-CHO, 1-CHOME, HYOGO-KU, KOBE, 652-8585 JAPAN July 29, 2019 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attention: Mr. George Wunder Docket No.52-021 MHI Ref: UAP-HF-19002
Subject:
Supplemental Response to US-APWR DCD RAI No. 1097-8499 (SRP 07.01)
Reference:
- 1) "US-APWR RAI - US-APWR Design Certification Application RAI 1097-8499 (7.1 Instrumentation and Controls - Introduction)," dated March 15, 2016, ML16075A445.
UAP-HF-16003, dated August 18, 2018, ML16236A066.
With this letter, Mitsubishi Heavy Industries, Ltd. (MHI) submits to the U.S. Nuclear Regulatory Commission (NRC) a document entitled "Supplemental Response to US-APWR DCD RAI No.1097-8499 (SRP 07.01)."
Enclosed are the supplemental responses to clarify the responses submitted in Reference 2.
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. A non-proprietary version of the document is also being submitted with the information identified as proprietary redacted and replaced by the designation "[ ]."
This letter includes a copy of the proprietary version of the Supplemental RAI response (Enclosure 2), a copy of the non-proprietary version of the Supplemental RAI response (Enclosure 3), and the Affidavit of Takayuki Mori (Enclosure 1) which identifies the reasons MHI respectfully requests that all material designated as proprietary in Enclosure 2 be withheld from 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 letter. His contact information is provided below.
Sincerely, Takayuki Mori Engineering Manager Global Nuclear Project Group Nuclear Systems Engineering Department Nuclear Energy Systems Division Power Systems Mitsubishi Heavy Industries, Ltd.
Enclosures:
- 1. Affidavit of Takayuki Mori
(Proprietary)
(Non-Proprietary)
CC: G. Wunder J. Tapia Contact Information Joseph Tapia, Principal Consulting Engineer Mitsubishi Nuclear Energy Systems, Inc.
6210 Ardrey Kell Road, Suite 350 Charlotte, NC 28277 E-mail: joseph _ tapia@mnes-us.com Telephone: (202) 631-1002
ENCLOSURE 1 Docket No.52-021 MHI Ref: UAP-HF-19002 MITSUBISHI HEAVY INDUSTRIES, LTD.
AFFIDAVIT I, Takayuki Mori, being duly sworn according to law, depose and state as follows:
- 1. I am Engineering Manager, Global Nuclear Project Group, Nuclear Systems Engineering Department, Nuclear Energy Systems Division, Power Systems, Mitsubishi Heavy Industries, Ltd.(MHI) and have been delegated the function of reviewing MHI '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 "Supplemental Response to US-APWR DCD RAI No. 1097-8499 (SRP 07.01)," dated July, 2019 and have determined that the document contains 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 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 desi~n and methodology developed by MHI for the l&C design of the US-APWR.
- 5. The referenced information is being furnished to the Nuclear Reguiatory 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 of the safety l&C system. Providing public access to such information permits competitors to duplicate or mimic the safety l&C system 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 safety l&C system.
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 29th day of July, 2019.
7~,
Takayuki Mori Engineering Manager Global Nuclear Project Group Nuclear Systems Engineering Department Nuclear Energy Systems Division Power Systems Mitsubishi Heavy Industries, Ltd.