ML19291E637

Forwards Proprietary Portions of Application for Amend 3 to Gessar II Re Technical Basis for Improved BWR LOCA Decay Heat Correlation.Proprietary Portion Withheld (Ref 10CFR2.790).Affidavit Encl

ML19291E637
Person / Time
Site:	05000447
Issue date:	12/30/1981
From:	Sherwood G GENERAL ELECTRIC CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML19268D058	List: ML19291E637
References
MFN-217-81, NUDOCS 8201060395
Download: ML19291E637 (4)

Text

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GENERAL h ELECTRIC nuCesta powen SYSTEMS DIVISION MFN-217 -51 GENEPAL ELECTRIC CCMPANY.175 CURTNER AVE., SAN JCSE, CALIFCRNIA 95125 MC 682, (408) 925-5040 ,.

December 30, 1981

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Office of Nuclear Reactor Regulation

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Washington, D.C. 20555 ,

- [=b7'Jgirneszrg\p Attention: H. R. Denton, Director g pH U .p j ,,

Office of Nuclear Reactor Regulation v ',fp O'p/

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SUBJECT:

SUEMITTAL OF PROPRIETARY INFORMATION FOR REVIEW ? '* "'

NUCLEAR ISLAND GENERAL ELECTRIC STANDARD SAFETY ANALYIS REPORT (GESSAR II); DOCKET NO. STN 50-447: AMENCMENT NO. 3 '

General Electric is submitting 5 copies of the proprietary portion of Amendment No. 3 pertaining to GE's technical basis for an improved B'aR loss-of-coolant accident (LOCA) decay heat correlation which we are requesting be withheld from puolic disclosure and considered as preprietary pursuant to Section 2.790 of 10CFR Part 2.

The information contained herein provides details of the calculational method GE proposes to use for determining decay heat in a SWR LOCA evaluation model analysis. It is, therefore, requested that this document be included in the review of GESSAR II and that it be held ir confidence and not be released for publication or otherwise disclosec.

The nonproprietary version of this information is contained in Amendment No. 3 and is proviced under separate cover.

Very truly yours, 6CO3 s

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fTennG.5'herwood, Manager i

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Nuclear Safety and Licensing Operation y uP l

GGS:rm/182 12/1 -I i gp Attachments cc: L. S. Rubenstein (w/o att.)

R. L. Tedesco (w/o att.)

J. R. Miller (w/o att. )

H. J. Faulkner R. M. Minogue (w/o att.')

R. J. Mattson (w/o att.)

B. Sheron L. 5. Gifford (GE, Eetnesca)

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, , . G E.N E R A L ELECTRIC C 0 A P A'N Y AFFIDAVIT I, Glenn G. Sherwood, being duly sworn, depose F.nd state as follows:

1. I am Mar:ager of Safety and Licensing Operation, General Electric Company, and have teen delegated the function of reviewing the information described in parag.'aph 2 which is sougnt to be withheld and have been authorized to apply for its withholding.

2. The information sought to be withheld is contained in Proprietary Supplement to Appendix 5A of 238 Nuclear Island General Electric Standard Safety Analysis Report (GESSAR II).

3. In designating material as proprietary, General il:ctric utilizes the definition of proprietary information and tr..de secrets set forth in the American Law Institute's Restatement Ci Torts, r Section 757. This cefinition provides:

"A trade secret may consist of any formula, pattern, device or compilation of infctmation which is.used in one's business and which gives him an opportunity to obtain an advantage over competitors who do not know or use it.... A substantial element of secret, must exist, so that, except by the use of improper means, there would be difficulty in accuiring information.... Scme factors to be considered in determining whether given information is one's trade secret are: (1) the extent to which the information is known outside of his business; (2) the extent to which it is known by employees and others involved in his business; (3) the extent of measures taken by him to guard the secrecy of the information; (4) the value of the information to him and to his competitors; (5) the amount of effort or money expended by him in ceveloping the information; (6) the ease or difficulty with which the information could be prcperly acquired or duplicated by others."

4 Some examples of categories of information wnich fit into the definition of proprietary information are:

a. Information that discloses a process, method or apparatus wb re prevention of its use by General Electric's competitors without license from General Electric constitutes a competi-tive economic advantage over other companies;

b. Information consisting of supporting data and analyses, including test data, relative to a process, method or apparatus. the application of wnich provide a competitive economic advantage, e.g., by optimization or improved marketability;

c. 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 procuct;

d. Information which reveals cost or price information, procuc-tion capacities, budget levels or commercial scrategies of General Electric, its customers or supplim's;

e. Information which reveals aspects of past, present or future General Electric customer-funced development plans and programs of potential ccmmercial value to General Electric;

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

g. Information which General Electric must treat as proprietary according to agreements with other parties.

5. Initial approvc1 of proprietary treatment of a decument is made by the Subsection Manager of the originating component, the man most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to such documerts within the Company is limited on a "need to know" basis and suca documents at all times are clearly identified as proprietary.

6. The procedure for approval of external release of such a document is reviewed by the Section Manager, Project Manager, Principal Scientist or other equivalent authority, by the Section Manager of the cognizant Marketing function (or his delegate) and by the Legal Operation for technical content, competitive effect and deter-mination of the accuracy of the proprietary designation in accord-ance with the standards enumerated above. Disclosures outside General Electric are generally limited to regulatory bcdies, customers and potential customers and their agents, suppliers and licensees only in accordance with appropriate regulatory provisiens or proprietary agreements.

7. The document mentioned in paragraph 2 above has been evaluated in accordance with the above criteria and procedures and has been found to contain information which is proprietary and which is customarily held in confidence by General Electric.

8. The information presented in the proprietary supplement of 22A7000, Revision 3, provides analytical method ciscussions whicn have been identified as proprietary in previously submitted documents.

9. The information to the best of my knowledge and belief, has c.onsistently been held in confidence by the General Electric Company, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties have been made pursuant to regulatory provisions of proprietary agree-ments which provide for maintenance of the information in confidence.

10. Public disclosure of the informstion sought to be withheld is likely to cause substantial harm to ths competitive position of the General Electric Ccmpany and deprive or reduce the availability of profit-making opportunities because:

a) It was ceveloped with the expenditure of sucstantial resources exceecing 5500,000.

b) Public availability of this information would deprive General Electric of the acility to seek reimbursement, would perm't competitors to utilize this information to General Electric's detriment, and would impair General Electric's ability to maintain licensing agreements to the substantial financial and competitive disadvantage of General Electric.

c) Public availability of the information would allcw foreign competitors, including competing BWR supplierc, to obtain containment information ct no cost which General Electric developed at substantial cost. Use of this information by foreign competitors would give them a competitive advantage over General Electric by allowing foreign competitors to produce their containments at lower cost than General Electric.

Glenn G. Sherwood, being duly sworn, ceposes and says that he has read the foregoing affidavit and the matters stated therein are true and correct to the best of his knowledge, information, and belief.

Executed at San Jose, California, this $ dayfof T E.N7 ,1991 k 144 - M.d h

'Gienn G. Sn'erwoca General Electric Comoany STATE OF CALIFORNIA )

COUNTY OF SANTA CLARA , ss:

Subscribed and sworn before me this M day of T Ec , 1981 W m L 5 V S- w 1 A A U

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KAREN 5. VOCELMUn2 **fg WIARY PUBLIC IN AND# 0R SAID g

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scTAty pusuc.cAurcasiA x COUNTY AND STATE h SANTA C:. ARA COUNTY 2,

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NUCLEAR REGULA'OR v C0Mw I5s10N

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General Electric Company ) Docket No. STN 50-Ja7

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Standard Plant )

SUOMITTAL OF PROPRIETARY INFORMATION FOR REV!EV 0F 238 NUCLEAR ISLAND GENERAL ELECTRIC STAACARD SAFETY ANALYSIS REPORT (GESSAR II)

General Electric Comp ey, applicant in the aoove captioned proceeding, herstry suturits proprietary information to be included in the review of the 238 MucNr Island General Electric Standard Safety Analysis Report (GESSAR II).

This proprietary meterial is part of Ampmement No. 3 which amends GE55AR II try adding Appendix 64 to Chapter 6. Appendix GA provides the detailed technical basis for an improved BWR loss-of-coolant accident (LOCA) h decay heat correlation based on the AN51/ANS 51-1979 decay heat standard.

Respectfully sucaitted, General Electric Company j / I ky:

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G. G. 5hifw50c.~ Manager Safety and Licensing Operation Suttscribed and sworn to before me this M day of TEC, 1981.

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GESSAR II 22A7000 238 NUCLEAR ISIAND Rev. 3 121481 6A.6.7 A_pplication Considerations GE PROPRIETARY - provided under separate cover

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6A.6-11

3ESSAR II 22A7000 238 NUCLEAR ISLAND Rev. 3 121481 6A.6.7 Acplicati en Consideratiens_ (Contir.7eus PROPRIETARY - provided nnder sepu ate cover s .

6A.6-13

GESSAR II 22A7000 238 NUCLEAR ISLAND Rev. 3 121481 6A.6.7 Application Considerations (Centinued)

GE PROPRIETARY - provided under separate cover 6A.6.8 Evaluation ef Uncertainties GE PROPRI7:TARY - provided under separate cover s

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GESSAR II 22A7000 238 NUCLEAR ISLAND Rev. 3 121481 6A.6.B Evaluation of Uncertainties (Continued)

GE PROPRIETARY - provided under separate cover 1

6A.6-17

GESSAR II 22A7000 236 NUCLEAR ISLAND Rev. 3 121481 Table 5A-8 DECAY POWER RATIO AT VARICUC EXPOSURES RELATIVE TO DECAY POWER RATIO FOLLCWING SCRAM FRCM 10 GWd/STU J

GE PROPRIETARY - provided under separate cover 4

6A.9-9

GESSAR II 22A7000 238 NUCLEAR ISI.AND Rev. 3 121481 Table 6A-10 DECAY PCMER RATIO - ENRICHMENT DEPENDENCE GE PROPRIETARY - provided under separate cover a

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GESSAR II 22A7000 238 NUCLEAR ISLAND Rev. 3 121481 GE PROPRIETARY - provided under separate cover -

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Figure 6A-2. Decay Pcwer Ratio versus Exposure Level at

( Shutdown for Various Tir.es T (seconds)

N. aftez Scra.t 6A.10-3/6A.10-4