ML20260H239
| ML20260H239 | |
| Person / Time | |
|---|---|
| Site: | 05200021 |
| Issue date: | 08/25/2020 |
| From: | Mori T Mitsubishi Heavy Industries, Ltd |
| To: | George Wunder Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20260H241 | List: |
| References | |
| UAP-HF-20002 | |
| Download: ML20260H239 (6) | |
Text
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MITSUBISHI HEAVY INDUSTRIES, LTD.
1; 1, WADASAKI-CHO, 1-CHOME, HYOGOKU, KOBE, 652-8585 JAPAN August25,2020 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attention: Mr. George Wunder Docket No.52-021 MHI Ref: UAP-HF-20002
Subject:
Transmittal of the Accepted Version of the Topical Report MUAP-07001, Revision 7, "The Advanced Accumulator"
References:
- 1) "Final Safety Evaluation for United States -Advanced Pressurized Water Reactor Advanced Topical Report Safety Evaluation for Topical Report MUAP-07001-NP, Revision 7, 'THE ADVANCED ACCUMULATOR,"'
dated June 24, 2020 (ML20055F976)
- 2) MHI Letter No. UAP-HF-18004, "Transmittal of the Topical report MUAP-07001, Revision 7, 'The Advanced Accumulator,"' dated May 18, 2017 (ML18178A263).
With this letter, Mitsubishi Heavy Industries, LTD. (MHI) transmits to the U.S. Nuclear Regulatory Commission (NRG) a copy of the official document entitled "Accepted Version of the Topical Report 'The Advanced Accumulator' MUAP-07001 Revision 7."
As indicated in the enclosed materials, this document contains information that MHI considers proprietary, and therefore the report should be withheld from disclosure pursuant to 10 C.F.R. § 2.390 (a)(4) as trade secrets and commercial or financial information which is privileged or confidential. Accordingly, the topical report is being submitted in two versions, on separate compact discs. One version (on CD 1 of Enclosure 2) contains the complete proprietary version of the topical report. A non-proprietary version of the topical report is enclosed on CD 2 (Enclosure 3). In the non-proprietary version, the proprietary information, bracketed in the proprietary version, is replaced by the designation"[ ]". In accordance with the NRG submittal procedures, this letter includes an Affidavit (Enclosure 1) that identifies the reasons why the proprietary version of the Report should 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 NRG has questions concerning any aspect of this submittal. His contact information is provided below.
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Sincerely, Takayuki Mori, Engineering Manager Nuclear Systems Engineering Department Nuclear Energy Systems Mitsubishi Heavy Industries, Ltd.
Enclosure:
- 1. Affidavit of Takayuki Mori
- 2. CD1: "Accepted Version of the Topical Report 'The Advanced Accumulator' MUAP-07001-P-A, Revision 7"
- Version that contains proprietary information
- 3. CO2: "Accepted Version of the Topical Report 'The Advanced Accumulator' MUAP-07001-NP-A, Revision 7"
- Version that does not contain proprietary information The files contained in the CDs are listed in attachment 1 and 2.
CC: G. Wunder J. Tapia Contact Information Joseph Tapia, Principal Consulting Engineer Mitsubishi Nuclear Energy Systems, Inc.
11405 N. Community House Rd., Ste. 300 Charlotte, NC 28277 E-mail: joseph_tapia@mnes-us.com Telephone: (202) 631 - 1002
ENCLOSURE 1 Docket No.52-021 MHI Ref: UAP-HF-20002 MITSUBISHI HEAVY INDUSTRIES, LTD.
AFFIDAVIT I, Takayuki Mori, state as follows:
- 1. I am Engineering Manager of Nuclear Systems Engineering Department, Nuclear Energy Systems, Mitsubishi Heavy Industries, ltd., and have been delegated the function of reviewing Mitsubishi Heavy Industries, LTD's ("MHI") 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 "Accepted Version of the Topical Report 'The Advanced Accumulator,' MUAP-07001 Revision 7" dated August, 2020, 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 s,taff.
- 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 MH_I 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 August, 2020.
7 ~
Takayuki Mori, Engineering Manager Nuclear Systems Engineering Department Nuclear Energy Systems Mitsubishi Heavy Industries, Ltd.
ATTACHMENT 1 FILES CONTAINED ON CD 1 CD 1: "Accepted Version of the Topical Report 'The Advanced Accumulator' MUAP-07001-P-A Revision 7"
- Version that contains proprietary information Contents of CD File Name Size Sensitivity Level ACC ToR-P-A R7 vol 1.pdf 14.2 MB Proprietary ACC ToR-P-A R7 vol 2.pdf 13.4 MB Proprietary ACC ToR-P-A R7 vol 3.pdf 39.5 MB Proprietary ACC ToR-P-A R7 vol 4.pdf 49.7 MB Proprietary ACC ToR-P-A R7 vol 5.pdf 25.6 MB Proprietary ACC ToR-P-A R7 vol 6.pdf 33.6 MB Proprietary ACC ToR-P-A R7 vol 7 .pdf 16.3 MB Proprietary ACC ToR-P-A R7 vol 8.pdf 32.9 MB Proprietary ACC ToR-P-A R7 vol 9.pdf 24.0 MB Proprietary
ATTACHMENT 2 FILES CONTAINED ON CD 2 CD 2: "Accepted Version of the Topical Report 'The Advanced Accumulator' MUAP-07001-NP-A Revision 7"
- Version that does not contain proprietary information Contents of CD File Name Size Sensitivity Level ACC ToR-NP-A R7 vol 1.pdf 7.7MB Non-Proprietary ACC ToR-NP-A R7 vol 2.pdf 49.0 MB Non-Proprietary ACC ToR-NP-A R7 vol 3.pdf 25.4 MB Non-Proprietary ACC ToR-NP-A R7 vol 4.pdf 22.1 MB Non-Proprietary