ML18296A159: Difference between revisions

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{{Adams
#REDIRECT [[M180200, GE-Hitachi Nuclear Energy Americas, LLC - Response to NRC Request for Additional Information (RAI) Interim Status Report]]
| number = ML18296A159
| issue date = 10/23/2018
| title = GE-Hitachi Nuclear Energy Americas, LLC - Response to NRC Request for Additional Information (RAI) Interim Status Report
| 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 =
| contact person =
| case reference number = M180200
| package number = ML18296A158
| document type = Legal-Affidavit, Letter
| page count = 4
}}
 
=Text=
{{#Wiki_filter:Proprietary Information Notice Attachment 2 to this letter contains 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 Attachment 2, the balance of this letter may be made public
.
GEH to US NRC M180200 October 23, 2018 Page 2 of 5 2) Demonstrate compliance with 10 CFR 20.1406(c) by providing an engineering structural analysis of the shutdown reactor facilities that includes an analysis of their ability to maintain integrity of the building for purposes of ensuring confinement of the residual radioactivity; providing the plan for routine maintenance and surveillance of the shutdown facilities related to structural integrity and any special surveillance requirements that would be necessary sbould a seismic event occur during the current licensing period or during the requested extension to the decommissioning period; and providing a plan and schedule for when access to the lower portions of the VBWR will be safe for GEH employees and NRC staff and inspectors to enter so that they can effectively carryout surveillance and inspections. (Reference 3, pages 4-5). To address RAI 1: GEH has requested services from an environmental engineering consulting firm for a subsurface hydrology and groundwater monitoring program assessment.
To address RA12: In July 2018 GEH established a professional services contract with a decommissioning engineering consulting firm to provide technical assistance in performing the necessary analyses.
o The engineering firm's assigned Project Manager, Structural Engineer, and two environmental subject matter experts performed a site visit and walk down of all three shutdown reactor facilities in September 2018. o The engineering firm has requested facility drawings and previous supporting documentation.
GEH is collecting and providing the information.
The decommissioning engineering firm has provided a project schedule summary to meet the March 2019 target NRC submittal date (See Attachment 2 to this letter) Please contact me if you have any questions or would like to discuss this matter further. Sincerely, Facility Licensing Attachment(s):
: 1) GEH affidavit
: 2) GEH RAI Project Schedule Summary (contains proprietary information)
Cc: B. Watson, USNRC NMSS SPM 18-051 
 
GEH to US NRC M180200 October 23, 2018 Page 4 of 5 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 anive 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 conect. Executed on this 23rd day of October 2018. ScottP.Murray GE Hitachi Nuclear L.L.C. STATE OF NORTH CAROLINA COUNTY OF NEW HANOVER Subscribed aud swom to me, a Notary Public, iu day of Odobec 2018. Notary Public in and for the State of North Carolina My Commission Expires: .June 23, 2023}}

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