ML18107A238
| ML18107A238 | |
| Person / Time | |
|---|---|
| Site: | PROJ0816 |
| Issue date: | 04/13/2018 |
| From: | Burzynski M J radICS |
| To: | Joseph Holonich Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML18107A173 | List: |
| References | |
| 042018/10, CAC MF841 1, EPID: L-2016-TOP-0010 | |
| Download: ML18107A238 (6) | |
Text
Ref. N2: 042018/10 Dated: April 13, 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk , Mr. Joseph Holonich Senior Project Manager One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 Limited Liability Company <<RESEARCH AND PRODUCTION COMPANY RADICS>> 29 Geroyiv Stalingradu Street, 25009 Kropyvnytskyi, Ukraine Tel:+380 522 395707 Fax: +380 522 555179 E-Mail: radics@radics-ua.com Subjed: Response to Request for Additional Information for RadlCS Topical Report (CAC NO.: MF841 1; EPID: L-2016-TOP-0010)
References:
(1) Research and Production Corporation Rad I CS letter to NRC dated September 20, 2016, "Submittal of RadlCS Digital l&C Platform Topical Report" (ADAMS Accession No. ML 16274A346) (2) NRC letter to Research and Production Corporation RadlCS dated March 12, 2018, "Request for Additional Information for RadlCS Topical Report" (CAC NO.: MF841 1; EPID: L-2016-TOP-0010)" (ADAMS Accession No. ML 180588946) In Reference 1 Research and Production Corporation RadlCS (RPC RadlCS LLC) submitted a topical report for the RadlCS digital instrumentation and control (l&C) platform. The RadlCS platform is a generic digital safety l&C platform designed to implement Class 1 E safety-related applications in United States nuclear power plants. The NRC requested additional information about the RadlCS Digital l&C Platform Topical Report for review in Reference 2. RPC RadlCS LLC requests that the proprietary presentation documents be withheld from public disclosure. In accordance with 1 O CFR 2.390, "Public inspections, exemptions, requests for withholding," an affidavit is enclosed identifying the specific portions of the above documents that are proprietary and the basis for making that determination. Non-proprietary versions of the documents are also provided with the proprietary information redacted. Enclosure 1 provides the proprietary version of the responses to the NRC request for additional information. Attachment 1 to Enclosure 1 contains the proprietary version of the Rad I CS Topical Report pages affected by the responses to the NRC request for additional information. The pages show the planned changes in a line-in/line-out format. Enclosure 2 provides the non-proprietary version of the responses to the NRC request for additional information. Attachment 1 to Enclosure 2 contains the non-proprietary version of the RadlCS Topical Report pages affected by the responses to the NRC request for additional ' information. The pages show the planned changes in a line-in/line-out format. provides an affidavit related to the proprietary material in Enclosure 1. If you have any questions related to this submittal, please contact me at 423-834-4455 or by mail at mjburzynski@newcleardayinc.com. Sincerely, Mark J. Burzynski US Licensing Manager RPC RadlCS Page 2 of 2 Withholding Affidavit Related to the Proprietary Material in Enclosure 1
~-~-~~----~ ------STATE OF TENNESSEE ) ) COUNTY OF HAMIL TON ) Affidavit &ladICS 29 Geroyev Stalingrada Street 25009 Kirovograd, Ukraine 1. I, Mark Burzynski (RadlCS US Licensing Manager), am familiar with the criteria applied by RadlCS to determine whether certain RadlCS information is proprietary. am familiar with the policies established by Rad I CS to ensure the proper application of these criteria. 2. In accordance with 10 CFR 2.390, "Public inspections, exemptions, requests for withholding," Research and Production Corporation RadlCS. (hereafter called RadlCS) requests withholding from public disclosure of the documents listed in attached Table 1, which is attached to this affidavit. The documents contain application, product design details, and qualification process information related to the RadlCS digital instrumentation and controls platform. RadlCS has expended a significant amount of money and effort involving numerous contractors over more than 5 years to develop this product. 3. As required by 1 O CFR 2.390, RadlCS has included in attached Table 1 the following information:
- Identity of the document or part sought to be withheld;
- Declaration of the basis for proposing the information be withheld, encompassing considerations set forth in§ 2.390(a);
- Specific statement of the harm that would result if the information sought to be withheld is disclosed to the public; and
- Locations in the documents of all information sought to be withheld. 4. As required in § 2.390(b)(4), RadlCS wishes to note that the request for withholding from public disclosure applies to pages that contain commercially sensitive information that RadlCS normally discloses only under a Non-Disclosure Agreement (NDA). This commercially sensitive information is not available in public sources and is the type of information customarily held in confidence by RadlCS and our competitors. Some examples of categories of information which fit into the definition of proprietary information are: a) Information which discloses process, method, or apparatus, including supporting data and analyses, where prevention of its use by RadlCS's competitors without license or contract from RadlCS constitutes a competitive, economic advantage over other companies in the industry. b) Information, which if used by competitors, would reduce their expenditure of resources or improve *their competitive position in the design, manufacture, shipment, application, installation, assurance of quality, or licensing of a product. ---------,
~adICS 29 Geroyev Stalingrada Street 25009 Kirovograd, Ukraine c) Information which reveals cost or price information, production capacities, budget levels, or commercial strategies of RadlCS, its customers, its partners, or, its suppliers. d) Information which reveals aspects of past, present, or future RadlCS funded development plans or programs, of potential commercial value to RadlCS. e) Information which discloses patentable subject matter for which it may be desirable to obtain patent protection. f) Information obtained through RadlCS actions which could reveal, additional insights into nuclear equipment qualification processes, customer applications, and regulatory proceedings, and which are not otherwise readily obtainable by a competitor. 5. RadlCS is transmitting this information to NRC in confidence. 6. As noted in attached Table 1, release of this information in a public forum could cause harm to RadlCS by revealing trade secrets and/or commercially sensitive design and operational details and technical processes related to designing, building, and/or operating a RadlCS digital safety instrumentation and control system. 7. As RadlCS US Licensing Manager, I have been specifically delegated responsibility for reviewing the information sought to be withheld, and I am authorized to apply for its withholding on behalf of RadlCS. 8. The foregoing statements are true and correct to the best of my knowledge, information, and belief. Sworn to and subscribed before me this \ '.1-t.._ day of :P(>" \ tx:i-d.2/Ylaw-US Licensing Manager RadlCS 0 , 20 lo ~tary Public My commission expires: /Jct,,e,n, kAc:: dCf t9d t 5 Table 1. Documents requested for withholding from public disclosure .. *, Basis for proposing the .. Part of document .. . . . information be withheld, Specific statement of the harm tt,at would result if the -.sought to be withl'!eld Documen(Title elico,mpassing information sought to b~ withheld is disclosed to the;* .. from public
- considerations s~t forth * * , public * * ., disclosure ._
- in § 2.390(a)* Enclosure 1: Research and Production RPC RadlCS LLC would be harmed by disclosure of Corporation RadlCS Response Portions of requests for commercially sensitive details of how the generic to the U. S. Nuclear additional information Trade secrets and I or hardware and software components of a RadlCS system Regulatory RAI-P1-01, RAI-P1-08, commercial information as work, and how functions such as data communications and communication independence are implemented. This Commission Staff and RAI-P1-09 marked per§ 2.390(a)(4) would be of value to a competitor in understanding Request for by brackets [[ ]]. specific competitive design and operational characteristics Additional Information of the RadlCS Platform. (Proprietary Version) RPC RadlCS LLC would be harmed by disclosure of Attachment 1: commercially sensitive details of how the generic Topical Report Portions of pages as Trade secrets and I or hardware and software components of a RadlCS system Mark Up Showing marked by brackets commercial information as work, and how functions such as data communications Changes [[ ]]. per§ 2.390(a)(4) and communication independence are implemented. This (Proprietary would be of value to a competitor in understanding Version) specific competitive design and operational characteristics of the RadlCS Platform. Page 1 of 1