ML20080H160

Forwards Proprietary Version of NEDE-22146, Kuosheng 1 Reactor Internals Vibration Measurements. SER Confirmatory Issue 9 Closed.Rept Withheld (Ref 10CFR2.790)

ML20080H160
Person / Time
Site:	Clinton
Issue date:	09/16/1983
From:	Nelson R ILLINOIS POWER CO.
To:	Schwencer A Office of Nuclear Reactor Regulation
Shared Package
ML19268B700	List: ML20080H160
References
0982-L, 982-L, U-0666, U-666, NUDOCS 8309210166
Download: ML20080H160 (6)

Text

i U-0666 0982 L lllinois Power Company L30-83 ( 09- 16)-L 500 SOUTH 27TH STREET. P. O. BOX 511, DECATUR, ILLINOIS 62525-1805 September 16, 1983 Docket No. 50-461 Director of Nuclear Reactor Regulation Attention: Mr. A. Schwencer, Chief Licensing Branch No. 2 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Subject:

Clinton Power Station Unit 1 SER Confirmatory Issue #9 (NUREG-0853)

Vibration Assessment of RPV Internals

Dear Mr. Schwencer:

The Kuosheng Nuclear Power Plant Unit 1 in Taiwan is the first BWR/6, size 218-inch vessel, to become operational. Kuosheng-1 (Taiwan Power Company) is the designated prototype on vibration assessment for reactor internals for the Clinton Power Station.

In response to SER Confirmatory Issue #9, Illinois Power Co.

hereby submits the General Electric Company document NEDE-22146, entitled, Kuosheng-1 Reactor Internals Vibration Measurements.

This report presents the results of the vibration measurements on reactor internal components for the General Electric prototype Boiling Water Reactor, BWR/6-218, at the Kuosheng Nuclear Power Plant Unit 1 in Taiwan, from September 26, 1980 through November 11, 1981.

The NEDE-22146 document contains proprietary information of Gencral Electric Company as attested to by the attached affidavit.

Illinois Power Company requests the attached NEDE-22146 report be withheld from public disclosure and considered as proprietary pur-suant to Section 2.790 of 10CFR Part 2.

We trust this information will resolve this confirmatory issue for close out in the next SER supplement. Please let us hear soon if you have any questions on our responses.

Since .y,

, /

R. I. Nelson Director-Nuclear Licensing and Configuration Nuclear Station Engineering GEW/em Attachment PGoI 8309210166 030916 3 PDR ADOCK 05000461 E PDR e

l

Page #2 U-0666 0982-L cc: H. Abelson, NRC Clinton Licensing Project Manager D. Terao, NRC MEB S. Hou, NRC MEB H. H. Livermore, NRC Senior Resident Inspector Illinois Department of Nuclear Safety (w/o enc.)

(

s. ,

y e GENERAL ELECTRIC C0MPANY AFFIDAVIT l I, Glenn G. Sherwood, being duly sworn, depose and state as follows:

1. I am Manager, Nuclear 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 information sought to be withheld consists of NEDE 22146 Kuo-Sheng 1, Reactor Internal Vibration Measurements.

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 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 informa-tion 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; BJE: cal /K11087-1 11/8/82

e

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 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.

l l

I l

BJE: cal /K11087-2 11/8/82 1

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 standards enumerated above. Disclosures outside General Electric are generally limited to regulatory bodies, customers and potential l .. 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. Public disclosure of the information 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 for the following reasons:

A. The cost of developing the proprietary information in the document mentioned in paragraph 2 above has been estimated to be $1,000,000. These costs include data acquisition, reduction, and interpretation and sensor manufacturing and installation.

B. This information would greatly reduce expenditure by a competitors attempting to develop a similar program.

C. The competitors likely to gain from disclosure of this information are Babcock-Wilcox, Westinghouse, Asea Atom, Combustion-Engineering, etc.

D. Competitors in the consulting business currently lack the capability and experience which GE has developed in their vibration program. Revealing this information would cause GE to lose its current competitive advantage.

E. The information sought to be withheld is not available in public sources.

BJE: cal /K11087-3 11/8/82

s

• STATE OF CALIFORNIA )

COUNTY OF SANTA CLARA ) ss:

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 9 day of November , 1982.

& . .ff/N GYeiin G'. 'Shefvood General Electric Company Subscribed and sworn before me this 9 day of November 1982.

geceeeenococococococococoeceg y y g pu on b /A1 OW1/'

N07ARYPU3LIC,STATEOyCALIFORNIA

/ &'

8 SANTA CLARA COUNTY 8 My Commission Expires Dec. 21,1984 W ibnanummananacc>cosanacc> acca BJE: cal /K11087-4 11/8/82