ML20071C688
| ML20071C688 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 02/23/1983 |
| From: | Causey J GEORGIA POWER CO. |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19262H594 | List: |
| References | |
| NED-83-108, TAC-49989, NUDOCS 8303070001 | |
| Download: ML20071C688 (10) | |
Text
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[$sI[2[$ o NED-83-108 February 23, 1983 Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C.
20555 NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT UNIT 2 PROPOSAL FOR TECHNICAL SPECIFICATION CHANGES WHICH SUPPORT CYCLE 4 STARTUP Gentlemen:
In accordance with the provisions of 10 CFR 50.90 as required by 10 CFR 50.59(c)(1), Georgia Power Company (GPC) hereby proposes an amendment to the Edwin I. Hatch Unit 2 Technical Specifications (Appendix A to the Operating License).
These changes are associated with and support plant modifications planned for the scheduled refueling outage preceding cycle 4 on Plant Hatch Unit 2.
GPC is currently planning to install a Low Low Set (LLS) Safety Relief Valve (SRV) logic system on Plant Hatch Unit 2 during the upcoming outage.
Associated with this is a change in the reactor water level isolation signal setpoint for the Main Steam Isolation Valves (MSIVs), and a change in the allowable setpoint margin for the SRV tailpipe pressure switches.
The purpose of the LLS logic is the mitigation of containment system loads during SRV operation as identified in NUREG-0661.
The enclosed document entitled "Edwin I.
Hatch Nuclear Plant Unit 2, Docket No. 50-366, Proposed Plant Modification 3 - Low Low Set Logic and Lowered MSIV Water Level", contains a detailed description of these plant modifications, as well as a complete safety evaluation.
This document also
- contains, in the section entitled
" Proposed Technical Specification Revisions," the proposed amended Technical Specification oaoes. alona with instructions for incorporation of these changes.
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Georgia Power A Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief
. Operating Reactors Branch No. 4 February 23, 1983 Page Two These proposed changes to the Plant Hatch Unit 2
Technical Specifications have been evaluated by both the Plant Review Board and -the Safety Review Board and both groups have determined that these changes would in no way constitute an unreviewed safety question.
The probability of occurrence and the consequences of an accident or malfunction of safety-related equipment would not be increased above those analyzed in the FSAR because no increase in accident probabilities or consequences would be introduced by these changes.
The probability of an accident or' malfunction of a different type than previously evaluated _in the FSAR does not result from these changes because the potential accident scenarior following implenentation of these modifications are bounded by the present FSAR analyses.
The margin of safety as defined in the Technical Specifications is not reduced by these changes because the proposed new operability limit and surveillance requirements for plant systems are consistent with the present safety margins.
In addition-to the above referenced document another enclosure entitled "Edwin I. Hatch Nuclear Plant Unit 2, Docket 50-366, Analog Transmitter Trip Systen Installation" accompanies this submittal.
This document describes the plant modifications associated with the. Installation of a GE Analog Transmitter Trip System (ATTS) on Unit 2, which is scheduled.for completion during the outage immediately preceding cycle 5 startup.
This document contains draft revised Technical Specification pages associated with the ATTS installation; however, those particular pages are not being submitted for amendment action by the EC as part of this proposal.
The final proposed changed Technical Specification pages necessary for ATTS opeation will be submitted for approval at some later date which would still allow an adequate time period for a complete NRC review. - The ATTS document is enclosed to allow for NRC review of the specific Plant Hatch Unit 2 aspects of this system, which was described on a generic basis in a topical report (EDO-21617-A) previously submitted to the EC by GE.
. Included with this proposal as attatchment 1 is a determination. of amendment class. GPC has determined this to be one Class III amendnent, and the appropriate payment is enclosed.
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Georgia Power d Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 February 23, 1983 Page Three J. C. Causey states that he is Vice President of Georgia Power Company and is authorized to execute this oath on behalf of Georgia Power Company, and that to the best of his knowledge and belief the facts set forth in this letter are true.
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GEORGIA POWER COMPANY By: [J.
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pJ.C.3usey Swor and subscribed before me is 23rd day of February,198'.
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J. T. Beckham, Jr.
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Senior Resident Inspector J. P. O'Reilly, (NRC-Region II) mns
1 GeorgiaPower b ATTACHMENT 1 NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HATCH NUCLEAR PLANT 'JNIT 2 PROPOSAL FOR TECHNICAL SPECIFICATION CHANGES.
WHICH SUPPORT CYCLE 4 STARTUP Pursuant to 10 CFR 170.22, Georgia Power Company has evaluated the attached proposed amendment to Operating License MF-5 and has determined that:
The proposed amendment does not require evaluation of a new Safety a.
Analysis Report and rewrite of the facility license;.
b.
The proposed amendnent does not require evaluation.of several complex issues, involve ACRS review, or require an environmental impact statement; c.
The proposed amendment does not involve a complex issue or more than one environmental or safety issue; d.
The proposed amendment does involve a single safety issue, namely that the Technical Specifications be changed to allow operation of Unit 2 with Low Low Set SRV Logic and the associated lowered MSIV reactor water level closure setpoint.
The proposed amendment is therefore a Class III amendment.
e.
700775
GENERAL ELECTRIC C0MPANY l
AFFIDAVIT I, Glenn G. Sherwood, being duly sworn, depose and state as follows:
1.
I am Manager, Safety and Licensing Operation, General Electric.
Company, 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 material designated as proprietary is " Low-Low Set Logic and Lower MSIV Water Level Trip for BWRs With Mark I Containment,"
September 1982 (NEDE-22223).
3.
In designating material as proprietary, General Electric utilizes the definition of proprietary information and trade secrets set forth in the American Law Institute's Restatement Of Torts, Section 757.
This definition provides:
"A trade secret may consist of any formula, pattern, device or compilation of information 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 secrecy must exist, so that, except by the use of-improper means, there would be difficulty in acquiring informa-tion....
Some factors to be considered in determining whether given information is one's trade secret are:
(1) the extent to 4
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 developing the information; (6) the ease or difficulty with which the information could be properly acquired or duplicated by others."
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 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 consisting of supporting data and analyses, includ-ing test data, relative to a process, method or apparatus, the application of which provide a competitive economic advantage, e.g., by optimization or improved marketability;.
~
c.
Information which if used by a competitor, would reduce his d
expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality or licensing of a similar product; d.
Information which reveals cost or price information, production capacities, budget levels or commercial strategies of General' Electric, its customers or suppliers;
.e.
Information which reveals aspects of past, present or future General Electric customer-funded development plans and programs of potential commercial 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.
In addition to proprietary treatment given to material meeting the standards ~ enumerated above, General Electric customarily maintains in confidence preliminary and draft material which has not been subject to complete proprietary, technical and editorial review.
This practice is based on the fact that draft documents often do not appropriately reflect all aspects of a problem, may contain tentative conclusions and may contain errors that can be corrected during
- g normal review and approval procedures.
Also, until the final
\\
document is completed it may not be possible to make any definitive determination as to its proprietary nature.
General Electric is not generally willing'to release such a document to the general public in such a preliminary form. Such documents are, however, on occasion furnished to the NRC staff on a confidential basis because it is General Electric's belief that it is in the public interest for the staff to be promptly furnished with significant or potentially significant information.
Furnishing the document on a confidential basis pending completion of General Electric's internal review permits early acquaintance of the staff with the information while protecting General Electric's potential proprietary position and permitting General Electric to insure the public documents are technically accurate and correct.
6.
Initial approval of proprietary treatment of a document 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 documents within the Company is limited on a "need to know" basis and such documents at all times are clearly identified as proprietary.
7.
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 I
technical content, competitive effect and determination of the accuracy of the proprietary designation in accordance with the I e
standards enumerated above.
Disclosures outside General Electric
(
are generally limited to regulatory bodies, customers and potential customers and their agents, suppliers and licensees only in accordance with appropriate regulatory provisions or proprietary agreements.
8.
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.
9.
The information contained herein is the result of extensive analyses performed at considerable cost to the General Electric Company.
The development and verification of these methods, as well as their application and execution cost in excess of $12 million.
Public disclosure of the information sought to be withheld is likely to cause substantial harm to the competitive position of General Electric Company and deprive or reduce the availability of profit making opportunities by allowing competitors to take full advantage of the extensive development, testing, and reduction to practice that has been performed by General Electric without any cost to competitors.
This information is unavailable to others and could only be obtained through a comparable development and testing program.
STATE OF CALIFORNIA
) ss:
l COUNTY OF SANTA CLARA
)
Glenn G. Sherwood, being duly sworn, deposes 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 m day of September,198_2.
. b'
,Glenn G. Sherwood
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General Electric Company Subscribed and sworn before me this 3 day of Seotember 1982.
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R PUBL C NA SANTA CLARA COUNTY 16TARY PUBLIC, STAT [/ OF CALIFORNIA E My Commission Expires Dec
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booooooooooooooooooo. 21,1984 oososos GGS:sem/B09106 9/10/82.
GENERAL ELECTRIC C0MPANY AFFIDAVIT I, Glenn G. Sherwood, being duly sworn, depose and state as follows:
1.
I am Manager, Safety and Licensing Operation, General Electric Company, 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 material designated as proprietary is " Low-Low Set Relief Logic System.and Lower MSIV Water Level Trip for Edwin I. Hatch Nuclear Plant Units 1 and 2",
December 1982 (NEDE-22224).
3.
In designating material as proprietary, General Electric' utilizes the definition of proprietary information and trade secrets set forth in the American Law Institute's Restatement Of Torts, Section 757.
This definition provides:
"A trade secret may consist of any formula, pattern, device or compilation of information which is used in one's business and which gives him an opportunity to obtain an advantage over competitors who do not knw or use it....
A substantial element of secrecy must exist, so that, except by the use of improper means, there would be difficulty in acquiring informa-tion....
Some factors to be considered in determining whether given information is one's trac'e 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 developing the information; (6) the ease or difficulty with which the information could be properly acquired or duplicated by others."
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 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 consisting of supporting data and analyses, includ-ing test data, relative to a process, method or apparatus, the application of which 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 product; d.
Information which reveals cost or price information, production capacities, budget levels or commercial strategies of General Electric, its customers or suppliers; e.
Information which reveals aspects of past, present or future General Electric customer-funded development plans and programs of potential commercial 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.
In addition to proprietary treatment given to material meeting the standards enumerated above, General Electric customarily maintains in confidence preliminary and draft material which has not been subject to complete proprietary, technical and editorial review.
This practice is based on the fact that draft documents often do not appropriately reflect all aspects of a problem, may contain tentative conclusions and may contain errors that can be corrected during normal review and approval procedures.
Also, until the final document is completed it may not be possible to make any definitive i
determination as to its proprietary nature.
General Electric is not generally willing to release such a document to the general public in such a preliminary form.
Such documents are, however, on occasion furnished to the NRC staff on a confidential basis because it is General Electric's belief that it is in the public interest for the staff to be promptly furnished with significant or potentially significant information.
Furnishing the document on a confidential basis pending completion of General Electric's internal review permits early acquaintance of the staff with the information while protecting General Electric's potential proprietary position and permitting General Electric to insure the public documents are technically accurate and correct.
6.
Initial approval of proprietary treatment of a document 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 documents within the Company is limited on a "need to know" basis and such documents at all times are clearly identified as proprietary.
7.
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 t I technical content, competitive effect and determination of the accuracy of the proprietary designation in accordance with the
-g.
standards enumerated above.
Disclosures outside General Electric l
l are generally limited to regulatory bodies, customers and potential customers and their agents, suppliers and licensees only in accordance with appropriate regulatory provisions or proprietary agreements.
8.
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.
9.
The information contained herein is the result of extensive analyses performed at considerable cost to the General Electric Company.
The development and verification of these methods, as well as their application and execution cost in excess of $12 million.
Public disclosure of the information sought to be withheld is likely to cause substantial harm to the competitive position of General Electric Company and deprive or reduce the availability of profit making opportunities by allowing competitors to take full advantage of the extensive development, testing, and reduction to practice that has been performed by General Electric without any cost to competitors. This information is unavailable to others and could only be obtained through a comparable development and testing program.
STATE OF CALIFORNIA
) ss:
'(
COUNTY OF SANTA CLARA
)
Glenn G. Sherwood, being duly sworn, deposes 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 ly_ day of December
,1981 umMb GfTenn GJ ShRwood General Electric Company Subscribed and sworn before me this 1_7 day of December 1982.
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KAREN 5. VOGELHUBER g
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NOTARY PUBUC-CAUFORNIA NOTMY PUBLIC, STATE OF pALIFORNIA SANTA CLARA COUNTY k My Commission Eirpires Dec coooooooooosoco cnoco. 21.1934ccnoacur.M GGS:sem: ggt /H121608 12/16/82.-
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