ML20083B593
| ML20083B593 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 05/05/1995 |
| From: | Schrage J COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19344C870 | List: |
| References | |
| NUDOCS 9505120130 | |
| Download: ML20083B593 (7) | |
Text
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Osmnu,nwealth lavin G,rnpany i NYJ Opm Plxe n,wnen on c.11.msis May 5,1995 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Document Control Desk
Subject:
Quad Cities Nuclear Station Units 1 and 2, AdditionalInformation Core Shroud Modification NRC Docket Nos. 50-254 and 50-265
Reference:
(1)
R.M. Pulsifer to D.L. Farrar letter dated March 3,1995.
(2)
J.L. Schrage to USNRC letters dated March 3,1995, March 22,1995, March 27,1995, and April 6,1995.
(3)
Teleconference between USNRC (R. Pulsifer, et al) and Comed O. Schrage, et al) on April 27,1995.
In Reference (1), the NRC staff transmitted a Request for Additional Information (RAI) to Commonwealth Edison (Comed) related to the proposed repair and inspection plan for the Quad Cities Station, Units 1 and 2 core shrouds. Comed provided a response to the RAI (including additional NRC staff-requested clarifications) in the Reference (2) letters. During the Reference (3) teleconference, the NRC Staff requested additional information pertaining to Enclosure 3 of the March 22,1995 letter from J.L. Schrage to the USNRC (GENE 771-68-1094, Revision 4, " Shroud and Shroud Repair Hardware Stress Analysis - Shroud Repair for H1 Through H7 Welds for Commonwealth Edison Quad Cities Nuclear Power Station Units 1 and 2").
Attachments 1 and 2 to this letter transmit the additional information requested by the NRC staff during the Reference (3) teleconference (GENE 771-681094, Supplement A to Revision 4,
" Supplement A to Shroud and Shroud Repair Haniware Stress Analysis," and " Quad Cities Tie Rod Loads Summary").
During the installation of the shroud repair hardware on Quad Cities Unit 2, pockets were cut in the shroud flange to accomodate the long upper supports. During this cutting operation, one of the pockets was cut too deep, and the cut transversed through the back of the shroud flange. This cut I
produced a steam bypass flow area. Attachment 3 to this letter transmits an evaluation of the deviation for the shroud repair hardware installation at Quad Cities Unit 2 resulting from this steam hypass flow area.
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U.S. NRC May 5,1995 This submittal contains information which is proprietary in nature to the General Electric Nuclear Company. This proprietary information is contained in Attachments 1,2, and 3, and is marked by venical lines in the right hand margin. Comed has included, as Attachment 4, a General Electric Nuclear Company affidavits (dated May 4,1995), per the requirements of 10CFR 2.790(b),
explaining the reasons and circumstances for withholding the applicable information from public disclosure.
To the best of my knowledge and belief, the analyses and evaluations contained in these documents are true and correct. In some respects these documents are not based on my personal knowledge, but on information furnished by other Commonwealth Edison employees, contractor employees, and/or consultants. Such information has been reviewed in accordance with company practice, and I believe it to be reliable.
If there are any questions concerning this matter, or need for further clarification, please contact this office.
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Sincerely,
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GENE 771-68-1094, Supplement A to Revision 4, " Supplement A to Shroud and Shroud Repair Hardware Stress Analysis," dated April 1995.
" Quad Cities Tie Rod Loads Summary," dated May 5,1995.
GENE-771-110-0595, Revision 0, " Evaluation of the Acceptability of FDDR No.
1E6AR-FDDR-001 for the Shroud Repair Program at Quad Cities Unit 2," dated May 4,1995 Quad Cities Station Unit 2 Core shroud repair documents - General Electric Nuclear Company Affidavit, dated May 4,1995.
ec: J. Martin, Regional Administrator - Rlll R. Pulsifer, Project Manager - NRR C. Miller, Senior Resident Inspector - Quad Cities Office of Nuclear Facility Safety IDNS I
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ATTACHMENT 4 Quad Cities Station Unit 2 Selected Core Shroud Repair Design Documents GENERAL ELECTRIC COMPANY AFFIDAVITS I
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General Electric Company AFFIDAVIT I, George H. Stramback, being duly sworn, depose and state as follows:
(1) I am Project Manager, Licensing 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 the GE proprietary reports GENE-771-68-1094, Shroud Mechanical Repair Program Quad Cities Nuclear Power Station Supplement A to Shroud and Shroud Repair Hardware Stress Analysis, Supplement A to Revision 4, (GE Proprietary Information), dated April 1995, and GENE-771-110-0595, Evaluation of the Acceptability of FDDR No.
1E6AR-FDDR-001for the Shroud Repair Program at Quad Cities Unit 2, Revision 0, (GE Proprietary Information), dated May 4,1995, and GE letter, M. D. Potter to Kenneth Hutko, Transmittal of GENE Documentation Related to the Quad Cities Units 1 and 2 Shroud Repair Project, dated May 4,1995 with proprietary attachment response to NRC RAI, Quad Cities Tie Rod Loads Summary, (GE Proprietary Information). The proprietary information is delineated by bars marked in the margin adjacent to the specific material.
(3) In making this application for withholding of proprietary information of which it is the owner, GE relics 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), 2.790(a)(4), and 2.790(d)(1) for " trade secrets and commercial or financial information obtained from a person and privileged or confidential" (Exemption 4). The material for which exemption from disclosure is here sought is all " confidential commercial information", and some portions also qualify under the narrower definition of " trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Proiect v. Nuclear Regulatory Commissio2 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 GIIS-95-6-afQCRAl2. doe Affidavit Page 1 l
a 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 cost or price information, production capacities, budget levels, or commercial strategies of General Electric, its customers, or its suppliers; d.
Information which reveals aspects of past, present, or future Gcneral Electric customer-funded development plans and programs, of potential commercial value to General Electric; e.
Information which discloser 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 both paragraphs (4)a. and (4)b., above.
(5) 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 j
review by the staff manager, project manager, principal scientist or other equivalent j
authority, by the manager of the cognizant marketing function (or his delegate), and l
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.
i GBS-95-6-afQCRAl2. doc Affidavit Page 2
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4 (8) The information identified in paragraph (2), above, is classified as proprietary because it contains responses to NRC questions and report information which provide detailed results of analytical models, methods and processes, including computer codes, used to evaluate a hardware design modification (stabilizer for the shroud horizontal welds) intended to be installed in a reactor to resolve the reactor pressure vessel core shroud weld cracking concern. The development and approval of this design modification utilized systems, components, and models and computer codes that were developed at a significant cost to GE, on the order of several hundred thousand dollars.
The development of the supponing processes, as shown in this detailed information, was at a significant additional cost to GE, in excess of a million dollars, over and above the large cost of developing the underlying individual proprietary report information.
(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 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 undenake 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.
GilS.95 6-afQCRAl2. doc Affidavit Page 3
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STATE OF CALIFORNIA
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COUNTY OF SANTA CLARA
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George B. Stramback, 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 N'N-day of
@m 1995.
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General Electric Company Subscribed and sworn before me this day of Y m 1995.
-O by g Notary Public, State of California I PAUtA F. HUSSEY C Oh M #1046120
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1ANTA CLARA COUMY My Comm. Empires IXC 1.1996 j
GBS-95-4afQCRAl2. doc Affidavit Page 4
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