M180115, GEH Response to NRC Request for Additional Information (RAI): Difference between revisions

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{{Adams
#REDIRECT [[ML18151A862]]
| number = ML18151A861
| issue date = 05/31/2018
| title = GEH Response to NRC Request for Additional Information (RAI)
| author name = Murray S P
| author affiliation = GE-Hitachi Nuclear Energy Americas, LLC
| addressee name = Parrott J D
| addressee affiliation = NRC/Document Control Desk, NRC/NMSS
| docket = 05000018, 05000070, 05000183
| license number = DPR-001, DR-010, TR-001
| contact person =
| case reference number = M180115
| package number = ML18151A860
| document type = Legal-Affidavit, Letter type:M
| page count = 4
| project =
| stage = Response to RAI
}}
 
=Text=
{{#Wiki_filter:Proprietary Information Notice Attachments 3 - 6 to this letter contain GE Hitachi Nuclear Energy proprietary information which is to be withheld from public disclosure in accordance with 10 CFR 2.390 and RIS 2005-31. Upon removal of Attachments 3 - 6, the balance of this letter may be made public
.
GEH to US NRC M180115 May 31,2018 Page 2 of 2 Please contact me if you have any questions or would like to discuss this matter further. Sincerely, Scott P. MurraY, Facility Licensing Attachment(s):
: 1) GEH affidavit
: 2) GEH RAI response summary 3) Groundwater monitoring well status evaluation
: 4) GEH radiological surveillance procedures (4) 5) GEH radiological recordkeeping procedure
: 6) Example completed EVESR!VBWR weekly patrol checklists Cc: B. Watson, USNRC NMSS SPM 18-034 
 
GEH to US NRC M180115 May 31, 2018 Page 2 of 2 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 GEH's processes, design and manufacturing facilities.
(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 there 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 31st day of May 2018.
Scott P. Murray GE Hitachi Nuclear Energy ericas, L.L.C. STATE OF NORTH CAROLINA COUNTY OF NEW HANOVER Subsc.ihed and swom to me, a Nototy Public, in tate f""};Z;: I st day of May 2018 Notary Public in and for the ,,,\\UIIIJ/
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