ML071510178

Attachment 2 to PLA-6211, Steam Dryer Replacement, NRC Meeting

ML071510178
Person / Time
Site:	Susquehanna
Issue date:	05/30/2007
From:	General Electric Co, Susquehanna
To:	Office of Nuclear Reactor Regulation
References
PLA-6211
Download: ML071510178 (36)

Text

Attachment 2 to PLA-6211 Non-Proprietary Version of the Meeting Information

Susquehannai Steam Dryer Replacement NRC Meeting May 30, 2007 Rockville, MD jIg .J PI

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Unverified Draft

Non-Proprietary Notice This is a non-proprietary version, which has the proprietary information removed.

Portions of the document that have been removed are indicated by an open and closed bracket as shown here H I].

2 Unverified Draft

Steam Dryer Replacement ppl I*:-

Agenda

- Replacement Dryer Overview

-Steam Dryer Instrumentation Plan

- Power Ascension Test Plan RAI Responses 3

Unverified Draft

Replacement Dryer Overview

• Overall Design Approach Maintain basic geometry Load definition development remains applicable

- 1985 instrumented dryer measurements

- 2006 main steam line measurements

-Supplemental scale model testing Improve fabrication design details to reduce or eliminate stress intensification 4

Unverified Draft

Original Susquehanna Dryer 5

Unverified Draft

New Design Susquehanna Steam Dryer Er 7

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Original Dryer - Inner Hood and Hood Support Detail

• Hood panelsjoined to support with 1/8" weld

• Weld located. at high stress region in hood assembly

• Several welds used to join hood support to vane bank assembly end panels 11 Unverified Draft

Original Dryer - Outer Hood and Hood Support Detail

• Several welds used to join hood panels to support

• Welds located at high stress region in hood assembly

• Several welds used to join hood support to vane bank assembly end panels JI 12 Unverified Draft

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Steam Dryer Instrumentation Plan Vibration Measurement Program Goals

" Verify the adequacy of the replacement steam dryer design under EPU conditions

• Measure pressure loading and structural response for benchmarking load definition and structural analysis models of the dryer 20 Unverified Draft

Steam Dryer Instrumentation Plan

" Strain Gauges

- Primary instrument for monitoring structural response

" Accelerometers

- Monitor dryer rocking, mechanical vibration from recirculation pump vane passing frequency

- Provide backup to strain gauges for structural response

• Pressure Sensors

- Benchmark pressure load definition 21 Unverified Draft

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[I 31 Unverified Draft to PLA-6211 General Electric Affidavit

General Electric Company AFFIDAVIT I, George B. Stramback, state as follows:

(1) I am Manager, Regulatory Services, General Electric Company ("GE") and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.

(2) The information sought to be withheld is contained in Enclosure 1 of GE's letter, JXHJA-02, Mike Bridges (GE) to Thomas Oldenhage (PPL), entitled GE Draft Dryer Presentationfor PPL/NRC Meeting, dated May 8, 2007. The proprietary information in Enclosure 1, which is entitled GE Draft Dryer Presentationfor PPL/NRC Meeting, is delineated by information inside double square brackets.

Figures and large equation objects are identified with double square brackets before and after the object. In each case, the superscript notation(31 refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.

(3) In making this application for withholding of proprietary information of which it is the owner, GE relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) for "trade secrets" (Exemption 4). The material for which exemption from disclosure is here sought also qualify under the narrower definition of "trade secret", within the meanings assigned to those terms for purposes of FOLA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704F2dl280 (DC Cir. 1983).

(4) Some examples of categories of information which fit into the definition of proprietary information are:

a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by General Electric's competitors without license from General Electric constitutes a competitive economic advantage over other companies;

b. Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;

c. Information which reveals aspects of past, present, or future General Electric customer-funded development plans and programs, resulting in potential products to General Electric; GBS-07 Af Susq Draft Dryer Presentation JXHJA-02 5-8-07.doc Affidavit Page I

d. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a., and (4)b, above.

(5) To address 10 CFR 2.390 (b) (4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GE, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GE, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.

(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to such documents within GE is limited on a "need to know" basis.

(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GE are limited 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 agreements.

(8) The information identified in paragraph (2), above, is classified as proprietary because it contains detailed Dryer design and analysis stress effects and instrumentation information related to the BWR Steam Dryer. Development of this information and its application for the design, procurement and analysis methodologies and processes for the Steam Dryer Program was achieved at a significant cost to GE, on the order of approximately two million dollars.

The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GE asset.

(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GE's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GE's GBS-07 Af Susq Draft Dryer Presentation JXHJA-02 5-8-07.doc AfdvtPg Affidavit Page 2

comprehensive BWR 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 GE.

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.

GE's competitive advantage will be lost if its competitors are able to use the results of the GE 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 GE would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GE of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing these very valuable analytical tools.

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 8th day of May 2007.

George B. Stramback General Electric Company GBS-07 Af Susq Draft Dryer Presentation JXHJA-02 5-8-07.doc Affidavit Page 3