ML20079R674

Forwards Proprietary Draft Amend to Gessar Ii,Supporting Leak Before Break Approach.Submittal Extends Leak Before Break Approach Only to Recirculation Sys Piping.Affidavit Encl.Rept Withheld (Ref 10CFR2.790)

ML20079R674
Person / Time
Site:	05000447
Issue date:	01/31/1984
From:	Quirk J GENERAL ELECTRIC CO.
To:	Thomas C Office of Nuclear Reactor Regulation
Shared Package
ML19289B816	List: ML20079R674
References
JNF-007-84, JNF-7-84, MFN-011-84, MFN-11-84, NUDOCS 8402020323
Download: ML20079R674 (6)

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iiENER s y~AL $ ELECTRIC NNLkAR PdWER SYSTEMS DMslON dENERAL ELECTRIC COMPANY

• 175 cURTNEk AVENUE

• sA!! JOSE, CAUFORNIA 95125 M/C,682, _(408) 925-2606s ' _ _ _ , ~ MFN-011-84

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January 131,, 1984 , s.

U.S. Nuclear Regulatory Coidhissiolr" '

Office of Nuclear Reactor Regulation s

• Washington, D.C. 20555 "i ,

Attention: Cecitx0'.' Thomas , Chief ~ ~ d Standardization and Special Projects Branch Gentlemen: J' k%

SUBJECT:

IN THE MATTER OF 238-3UCLEAR ISLAND GENERAL ELECTRIC STANDARD SAFETY ANALYSIS REPORT (GESSAR II)

DOCKET NO. STN 50-447 SUBMITTAL OF DRAFT AMENDMENT SUPPORTING LEAK-BEFORE-BREAK APPROACH Attached please find a draft amendment supporting the leak-before-break (LBB) approach on the GESSAR II design. The following summarizes the elements of this submittal:

1. Modification to Section 3.6 - Introduces LBB approach as an alternate to current criteria and provides a road map to supporting Appendices 3J, 3K, 3L and 3M.

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2. Modification to Section 3.9 - Provides a reference to the alternate pipe break criteria of Appendix 3J. -

3. New Appendix 3J - Describes the modifications to criteria related to pipe break postulations.

4. New Appendix 3K ' Characterizes the fracture mechanics properties of piping materials anf analysis methdds, including the leak rate calculation methods.

5. New Appendix 3L - Applies, the metho2s of ' Appendix 3K to specific piping systems to demonstrate the qualification to the LBB approach.

6. New Appendix 3M - provides a probabilistic a essment f boti direct and indirect double-en~ded guillotine' breaks. y

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GENER AL $ ELECTRIC Page 2 The present submittal extends the LBB approach only to the Recirculation System piping. We plan to first update the submittal to include the piping

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of the Feedwater and Main Steam Systems. A second update is planned to cover the balance of Reactor Coolant Pressure Boundary System piping equal to or greater than 6 inches in diameter. This second update is expected to provide relief on suppression pool hydrodynamic loads. We are planning to make both of these LBB submittal updates before mid-1984. However, this schedule will depend to some degree on the schedule assigned by the staff for its review of applying the LBB approach to GESSAR II.

We are requesting that the attached information designated as proprietary be withheld from public disclosure pursuant to Section 2.790 of 10 CFR Part 2.

If you have any questions please contact myself (408) 925-2606 or J.N. Fox (408) 925-5039 of my staff.

Very truly yours,

(

Quirk, Manager WR Systems Licensing Nuclear Safety & Licensing Operation Attachments cc: F.J. Miraglia (NRC) w/o attachment D.C. Scaletti (NRC) w/3 copies attachment K.R. Wickman (NRC) w/3 copies attachment R.W. Klecker (NRC) w/3 copies attachment L.S. Gifford (GE-Bethesda) w/o attach

GENERAL ELECTRIC C0MPANY AFFIDAVIT I, Joseph F. Quirk, being duly sworn, depose and state as follows:

1. I am Manager, BWR Systems Licensing, Nuclear Safety & 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 information sought to be withheld pertains to the proprietary information submitted in Appendices 3L, 3M and 3N supporting the leak-before-break approach for the 238 Nuclear Island General Electric Standard Safety Analysis Report (GESSAR II).

3. In designating material as proprietary, General Electric utilizes the definitico 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 oppurtunity 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 which the information is known outside of his business; (2) the cxtent 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:

I 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; l

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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;

c. "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 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 witn the information while protecting General Electric's potential proprietary position and permitting General Electric to insure the public documeats are technically accurate and correct.

6. Initial approval of proprietary treatment of a document is made by the Subsection Mar.ager of the originating component, the man raost 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 technical content, competitive effect and determination of the accuracy of the proprietary designation in accordance with the 2

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 p'aragraph 2 above has been evaluated in accordance with the above criteria and procedures and has been found

• to contain information which is proprietary a,nd which is customarily held in confidence by General Electric.

9. The information mentioned in paragraph 2 provides fracture mechanics and leak rate calculational methods, qualification of piping for the leak-before-break approach, and the probability of a LOCA in reactor coolant system piping.

10. The information to the best of my knowledge and belief, has consistently 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 agreements which provide for maintenance

. of the information in confidence.

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

a. It was developed with the expenditure of resources exceeding

$100,000.

b. Public availability of this information would deprive General l Electric of the ability to seek reimbursement, would permit 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 l

competitive disadvantage of General Electric.

c. Public availability of the information would allow foreign competitors, including competiting BWR suppliers, to obtain containment information at 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 lowee cost than General Electric.

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STATE OF CALIFORNIA

) ss:

COUNTY OF SANTA CLARA )

Joseph F. Quirk, 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, thisd day of JAA/unR t/ ,198I.

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General Electric Company Subscribed and sworn before me this y day of _7AA/uMR // 198[.

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g OFFICIAL SEAL KAREN S. VOGELHUBER g h j*y[-

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