ML20085K128

Forwards Suppl 2 to Rev 1 of NEDC-31624P, LOCA Analysis Rept for Brunswick Steam Electric Plant Unit 2 Reload 9 Cycle 10. Rept Withheld (Ref 10CFR2.790)

ML20085K128
Person / Time
Site:	Brunswick
Issue date:	10/23/1991
From:	Floyd S CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19312B442	List: ML20085K128
References
NLS-91-272, NUDOCS 9110300159
Download: ML20085K128 (6)

Text

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. Carolina Power & Ught Company 4

OCT 2 31991 i SERIAL: NLS 91272 1

United States Nuclear Regulatory Commission ATTENTION: Document Controf Desk )

Washington, DC 20555 DRUNSWICK STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-324/LICENSF NO. DPR-02 TRANSMITTAL OF I.OCA REPORT l

Gentlemen:

The purpose of this lettar is to submit a copy of the updated loss of caolant accident (LOCA)

!icensing basis for the Drunswick Steam Electric Plant, Unit 2. This information is contained in the document entitled ' Loss of Coolant Accident Analysis Report for Brunswick Steam Electric P! ant Unit 2 - Reload 9, Cycle 10

• NEDC-31624P, Supplement 2, Revision 1, A copy of this document is enclosed herein. The report is classified as proprietary by General Electric: therefore, an affidavit for withhoL%g the report from public disclosure in accordance with 10 CFR 2.790 is also enciased.

The updated LOCA licensing basis, which applies to Brunswick Unit 2 Cycle 10 operation, provides information in accordance with the NRC Safety Evaluation for Amendment 19 to GESTAR il and makes use of the SAFER /GESTR LOCA methodology. On November 17,1988, the Nuclear Regulatory Commission (NRC) approved Amendment 19 to General Electric Company document NEDE 24011 P A (GESTAR II). On June 1,1989, the NRC approved the use of the SAFER /GESTR LOCA methodology for future revisions of the Brunswick Plard LOCA licensing basis. The latest revision of the SAFER /GESTR LOCA methodo'.ogy for the Brunswick Plant has been accerted by the NRC and is documented in an NRC letter dated Jsnuary 10,1991.

Please refer any questions regarding this submittal to Mr. W. R. Murray at (919) 540 4601.

Yours very truly, S. D. Floyd ,

l Manager Nuclear Licensing Section WRM/wrm (b2r9Ioca.wpf)

Enclosures cc: Mr. S, D. Ebneter l Mr. N. D. Le l Mr. R. L. Prevatte p2TsymwascramucErfascMfmrzgre"ast::a / (

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s ENCLOSURE 2

. e BRUNSWICK STEAM ELECTRIC PLANT, UNIT 2 NRC DOCKET NO. 50 324 OPERATING LICENSE NO. DPR 02 GENERAL ELECTRIC COMPANY AFFIDAVIT LOSS CP COO. ANT ACCIDENT ANALYSIS REPORT

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GE Nuclear Energy Aindavit

1. Janice S. Charnley, being duly sworn, depose and state as follows:

1. I am Manager, Fuel Licensing, General Electric Company, and have been delegated the func.

tion 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 Loss-of-Coolant Accident Ana& sis Report For Brunswick Steam Electric Plant Unit 2 Reload 9 Qrle 10 NEDC 31624P Supplement 2, Revision 1 September '991.

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 llestatement of Torts, Section 757. This definition provides:

"A trade secret may consist of any formula, pattern, device or compilation of in-formation which is used in one's business and which gives him an opporiunity to obtain an advantage over competitors who do not know or use it, . . A substan-tial element of secrecy must exist, so that, except by the use of improper means, there would be difficulty in acquiring information. , , Some factors to be consid-cred in determining whether given information is one's trade secret are: (1) the exant 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 ex-tent 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 ia developing the information; (6) the ease or diffi-culty 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 infor-mation are:

a. Information that disclosed 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, including test data, relative to a process, method or apparatus, the application of which provide a competitive eco-nomic advantage, e.g., by optimization or improved marketability;

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c. Jhformation 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 i or commercial strategies of General Electric, its customers or suppliers;  !

e. Information which reveals aspects of past, present or future General Electric cus-tomer funded development plans and programs of potential commercia value to

' General Electric;

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

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

5. Initial approval of proprietary treatment of a document is typically made by the Subsection l' manager of the originating component, who is 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 are clearly identified as proprietary.  :

6. The procedure for approval of external release of such a document typically requires review by the Subsection Manager, Project manager, Principal Scientist or other equivalent authority, by the Subsection Manager of the cognizant Marketing function (or 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 customers and their agenta, suppliers and licensees and then only with appropriate protection i by applicable regulatory prosisions c,r 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 document mentioned in paragraph 2 above is classified as proprietary because it contains

' details concerning current General Electric fuel designs which were developed at considerable expense to Or ieral Electric which are not available to other parties. -

9. The information tc. the best of my knowledge and belief has consistently been held in confi-dence by the.Oenen! 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 regula-tory provisions or. proprietary agreements which provide for maintenance of the information "

in confidence.

l 10. Public disclosure of the information sought to be withheld is likely to cause substantial harm i- to the competitive position of the General Electric Company and deprive or reduce the availability of profit making opportunities because it would provide other parties, including Affidavit Page 2 l'

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competit' ors, with valuable information regarding current General Electric fuel designs which were obtained at considerable cost to the General Electric Company.

STATE OF CALIFORNIA )

COUN'lY OF SANTA CLARA )" 1 Janice S. Charnley, being duly sworn, deposes and says:

That she has read the foregoing affidavit and the matters stated therein are true and correct to the best of her knowledge, information. and belief.

Executed at San Jose, California, this //T day of ,/78ix t_.1991.

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, 11 nice $. Charnlef General Electric Company Subscribed and sworn before me this N b ay d of Er ohn bry'1991.

OFFICIAL SEAL (

PAULA F. HUSSEY a i ii e4ou w rueuc cAurenNm < P ritd NT,54(4hi_

SANTA cUW, COUNTY Notary l'ublic - California v

, _ N _ _ [ ' * ? _ " f " N ' f- J Santa Clara County Affidavit Page 3

A ENCLOSURE 1 BRUNSWICK STEAM ELECTRIC PLANT, UNIT 2 NRC DOCKET NO. 50 324 OPERATING LICENSE NO. DPR 62 LOSS OF COOLANT ACCIDENT ANALYSIS REPORT FOR BRUNSWICK STEAM ELECTRIC PLANT UNIT 2 RELOAD 9, CYCLE 10 (NEDC 31024P, SUPPLEMENT 2, REVISION 1, SEPTEMBER 1991) se

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