ML20097D109
| ML20097D109 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 09/11/1984 |
| From: | Harrington W BOSTON EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19269A528 | List: |
| References | |
| 84-146, IEB-82-03, IEB-82-3, IEB-83-02, IEB-83-2, NUDOCS 8409170382 | |
| Download: ML20097D109 (28) | |
Text
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t BOSTON EDISON COMPANY 500 BovLETON STREET J3 7 3057 No MA55ACHUBETT5 02199 WILLIAM D. MARRINGTON -
BEco Ltr.84-146 50............
4 September 11, 1984
- =-
Harold R. Denton, Director Office of Nuclear Reactor. Regulation U. S.-_ Nuclear Regulatory Commission Washington, D. C.
20555 License No. DPR-35 Docket No. 50-293 Resoonse to 16 SCC Insoection Order Confirmina Shutdown
References:
(a) USNRC Letter (Vassallo to Harrington) dated 8/26/83 with Enclosure "IGSCC Inspectian Order Confirming Shutdown" (b)
BEco Letter (W. D. Harrington to H. R. Denton dated 12/8/83, File Reference #63-292
Enclosures:
(A) Matrix of IGSCC Inspection Order Examinations
-(8)
ISI Isometrics (C) Welds not Sch~eduled for Examination (D)
Hydrogen / Water Chemistry Program (E) Recirculation Nozzle Repair Program and Hydrogen Water Chemistry Materials Qualification y
Dear. Sir:
This letter submits information in response to Section III.C.5 of the IGSCC In3pection Order Confirming Shutdown (Order) dated August 26, 1983. The Order required that a report be submitted to NRC of the results of mandated 9
inspections and corrective actions taken. The format of this letter is to
. address each.of the parts of Section III.C of the Order. The Order parts are
~
reproduced below followed by our response.
Order Part III.C.1
.To the extent practicable, the licensee shall conduct an ultrasonic examination of 1005, but in no case less than the number specified in Attachment & to the July 21, 1983 50.54(f) letters, of the welds involving 304 stainless steel piping of greater than or equal to 4' in the following systems or portions thereof:
a.
Rerirculation System b.
ASME Code Class 1 Portion of the Residual Heat Removal System c.
ASME Code Class 1 Portion of the Core Spray System external to the Reactor Vessel
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d.
ASME Code Class 1 Portion of the Reactor Cleanup System N
D o
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- BO'., TON CCON COMPANY -
Harold R. Denton, Director September 11, 1984 Page 2 ResD0nse Enclosure (A). identifies those welds which were examined in accordance with the Order. Based on the results of ultrasonic examination of selected welds, Boston-Edison Company (BECo) elected as corrective action to replace 304
- stainless steel piping within the drywell.
Consequently, the inspection
. requirements of.the Order for welds in removed piping became moot. Enclosure (A) also contains, where available, stress rule index and carbon content information, as requested in Order Part III.C.5 and describes corrective action taken based on results of inspections regarding the Order.
Enclosure (B) contains isometrics which show weld locations for the welds listed in Enclosure (A) and also to show those portions of the piping which were replaced with 316NG piping.
Order Part III.C.2 Within 10 days of the date of this Order or prior to the commencement of the
, inspections required by this Order, whichever is later, the licensee shall
-provide to the Director, Office of Nuclear Reactor Regulation, a list of the welds specified above that it does not intend to inspect during this current
. outage together with a suitable technical justification for not conducting 1such-inspections at this tism. This list should identify each weld not being inspected by system, location and size.
Response
~
Reference (b) contained a list of specific welds which BECo requested an exemption from the Order. Subsequent to that submittal, BECo has revised its inspection plans and now requests an exemption-only for the welds listed in Enclosure C.
Order Part III.C.3 All UT personnel conducting these inspections shall have received appropriate training in IG5CC inspection using cracked thick-wall pipe specimens. All Level.II and III UT operators shall have sucessfully completed the performance demonstration tests described in '.EB 83-02. The footnote on page 4 of IEB 83-02, which allowed qualification under IEB 82-03, Revision 1, is no longer
-applicable.
Response
-BECo selected Magnaflux Quality fervices (MQS) to conduct the required examinations and all MQS personnel were qualified in accordance with the requirements of the Order at the EPRI validation course given at the J. A.
Jones ~ Applied Research Center. Documentation of this training is available for review.
r 3:
1.
502 TON EICON COMPANY Harold R. Denton, Director i
September.11, 1984 Page 3 i
Or' er Part -III.C.4 d
~ Based on the results of the inspections, the licensee shall take appropriate corrective actions.
^
Response
a)
Based onLthe results of ultrasonic inspection of selected welds as
'~
' described in a meeting with the members of the NRC Staf f on November 17, 1983, BEco elected to replace all Recirculation System piping with 316NG
- material, b) :In order to eliminate interference problems associated with replacing the Recirculation System and also to keep the boundaries of the piping system consistent with the design specification, BEco elected to replace the stainless steel portion of the Residual Heat Removal (RHR) System piping from the Recirculation System piping connections out to the drywell penetrations with 316NG material.
The~results of an ultrasonic (UT) examination of all the welds in the Class 1 portion of the'RHR System outside the drywell identified four indications in weld number 10-IB-14A.
(See Enclosure B.)
That portion of the RHR System in which this weld is included will also be replaced during the current outage with 316MG piping.
In addition,-the existing weld within the penetration and the penetration to new piping sub-assembly material will be corrosion resistant clad on the inside surface using 308L weld material..
c)- The portion of.the Core Spray System piping from the manual isolation valves to the penetration will be replaced with 316NG material during the current outage..Results of the UT examination of all of the Class 1 portion of the Core Spray System, outside the drywell, identified four indications in weld number 14-B-21.- Replacement material is not available at this tism; therefore, an evaluation will be performed using NRC acceptance criteria for flaws less than 25% of the wall thickness to allow operation during the next operating cycle without repair, d)
Boston Edison elected to replace the suction piping in the ASME Class 1 portion of the Reactor Water Cleanup (RWCU) System from the RHR piping connection to'the drywell penetration for the same reason as the RHR System within the drywell.
The UT examination of the Class 1 welds of the RWCU System outside contair. ment was completed (with the exception of welds 12-I-20 and 12-I-22 which have pipe whip restraints covering the welds) and no indications were observed.
)
5=
Go!, TON E2 CON COMPANY.
s.
Harold R. Denton, Director
' September-11,-1984 Page 4
. Discussion
-Replacement activities were conducted in accordance with NRC supplied procedural guidance for pipe replacement at BWR's. This guidance contained in
' Generic Letter 84-07, addresses the major considerations that should be
. included in a pipe replacement program. Our replacement program addresses each of the major considerations; that is, the program contains sections for Design Specifications, Codes, Materials, Design Changes, Stress Analysis, Fabrication, Installation,- Examination, Testing, System Characteristics, Inspection'and Quality Assurance.
-The Codes'and Standards published in 10 CFR 55.55a were used, specifically the 1980 Edition of Section III with W81 Addenda to the extent practical for replacement activities.
The original design basis was used for material changes only.
For situations involving major configuration changes to small bore (2" and less) piping, later Codes and Standards were used (ASME III,1980 Edition with W81 Addenda).
The original design basis was also used for material t.hanges to small bore
. piping involving only material substitution.
An independent review of our replacement program concluded that our replacement program is consistent with the procedural guidance given in
Additionally, our independent review has shown'tnat the Design Specifications used for pipe replacement and vessel safe ends replacement contain the same load combinations as those identified in our FSAR.
As the result of corrective action to replace Class 1 304 stainless steel piping within the drywell, the following other actions have been taken or are planned:
(1)
Liquid penetrant examinations were conducted on the as-found heat affected zone of cast stainless steel components, such as valves and pumps to determine whether IGSCC existed. The results of these examinations show no IGSCC existed on the heat affected zone on the inside surfaces of those components prior to preparing the ends for welding.
(2)~ Last pass heat sink welding is being planned for use on the Core Spray and RHR Systems where new 316NG-stainless steel piping connects with existing 304 stainless steel within the drywell at the reactor containment penetrations.
BECo's objectives for-a Hydrogen Water Chemistry Program at Pilgrim Station are described in Enclosure D.
Details of our interim objectives for the next fuel cycle as well as our long term objectives are discussed.
i
-i eneroN EDISON COMPANY
' Harold R. Denton, Director
- September 11, 1984 Page 5 This letter also transmits information regarding our program for recirculation nozzle repairs (see_ Enclosure E).
This particular information is submitted in response to your. request at a meeting which was held on June 15, 1984 to 4
discuss.the indications found in the Pilgrim Station recirculation nozzles.
Enclosure E also contains information which qualifies the concept of Hydrogen Water Chemistry control for the reactor coolant as a means of mitigating IGSCC in BWR's.
BEco intends to follow the guidelines of the Boiling Water Reactor Owners Group (BWROG) on Pipe Cracking for augmented inspections of safe-end to nozzle welds. _The initial input for this augmented inspection program was
~ transmitted to the NRC by a letter from the BWROG on Pipe Cracking (G.H.
Neils) to the NRC (H. R. Denton) dated June 27, 1984.
An evaluation of the piping replacement program has been conducted. This evaluation concluded _(1) there is no increase in the probability of occurrence or the consequences of an' accident or malfunction of equipment important to safety previously evaluated in the FSAR; (2) the possibility for an accident or malfunction of a different type than any evaluated previously in the FSAR is'not created;-and (3) that in complying with Section XI, the BECo Owner's
~
Specification (M-544) defines the codes of the original construction as well as the codes to be used for the replacement. The use of Section III of the ASME Boiler & Pressure Vessel Code does not compromise original quality nor does it decrease the overall margins used during the original construction.
Structural integrity evaluations and repairs related to the safe-end to nozzle welds and thermal sleeves cracking have been. conducted in accordance with requirements of~our Technical Specifications which embraces the codes and standards adopted by the NRC.
- A Safety Evaluation for operation with cracked thermal sleeves has been conducted and the results indicate that-no safety concerns associated with full-power operation exists. Full structural margin of the principal safety barrier, the reactor coolant pressure boundary, would be maintained because the thermal sleeves are not part of the pressure boundary.
Failure of a jet pump, low flow, can be detected with in-plant instrumentation and the plant can be shut down in a controlled manner as required by the Technical Specifications.
~ Adequate surveillance inspections are required by our Technical Specifications to determine jet pump flow mis-match which is the condition that would result from a' failed thermal sleeve / jet pump' riser pipe.
.a i
BO3TOH ;$DCON COMPANY
+
Harold R. Denton, Director September 11, 1984 Page 6
.td It should be noted that this report is submitted at this time to facilitate your review. It is our intent to satisfy the requireinents of the Order well in advance of our scheduled startup from the current outage.
Should you have
- ' N.
any questions as a result of your review, do not hesitate to contact me.
Very trulp yours,
)
'i v
Attachments h
ComrInwealth of Massachusetts) e' Coui'ty of,Suffolk) 90 Then pirsonally appeared before me W. D. Harrington, who, being duly sworn, did state that he is Senior Vice President-Nuclear of Boston Edison Company, the applicant herein, and that he is. duly authorized to 9xecute and file the submittal contained herein in the name and on behalf of Boston Edison Company i*
and that the statements in said submittal are true to the best of his O
knowledgeand belief.
My Comission expires: Ma/gN LL2 Notary Public cc:
Dr. T. E. Marley, Regional Administrator U. S. Nuclear Regulatory Comission 631 Park-Avenue King of Prussia, PA 19406 3
Mr. R. C. DeYoung, Director
, Office of Inspection and Enforcement U. S. Nuclear Regulatory Comission m
Washington, D. C. 20555 A
')*
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' ENCLOSURE (A).
I' l
MATRIX OF IGSCC INSPECTION ORDER EXAMINATIONS P ge I cf 7 ORDER STRESS RULE CARBON' CONTENT RESULTS ACTION-REMARKS EXAMINATION CORRECTIVE f
SYSTEM REQUIREMENTS BECO'S ACTION
.RECIRC 100% UT exam-Examined.
Ination of 2-N2A 1.963
.046 Indications Replace the l
all welds.
Reported.
' entire Recirc-(approx. 125) 2-N2C-3 1.188
.079 No Indications.
ulation System with 316 NG 2-N20-5 1.808
.065 Indications material.
Reported.
2-N2E-4 1.215
.053 No Indications.
2-N2K-5 1.907
.046 No Indications-2-NIA-3 1.163
.070 Indications Reported.
2-NIA-9
'l.153-
.070 Ir.dicatloas Reported.
RHR-100% UT of Examined (Suction the ASME Code 10-0-1 1.849
.050 No Indications.
Replace the and Dis-Class 1 RHR System charge)
Portion of the 10-0-2 1.213
.050 No Indications. within contain-system.
ment along with 10-0-3 1.228
.050 No Indications Recirculation System with 10-IA-2 2.178
.050 No Indications.
316 NG material.
l 10-IA-14 Not Available.
Not Available.
No Indications.
Outside Containment.
10-IA-15 Not Available.
Not Available.
No Indications.
Outside Containment.
10-IB-14 Not Available.
Not Available.
No Indications.
Outside Containment.
10-IB-14A Not Available.
Not Available.
Indications Hill be Outside Reported.
replaced Containment.
with 316 NG material.
n:--
ENCLOSURE'(A)
I MATRIX OF IGSCC INSPECTION ORDER EXAMINATIONS' Page 2 of 7 ORDER EXAMINATION CORRECTIVE SYSTEM REQUIREMENTS BECO'S ACTION STRESS RULE CARBON CONTENT RESULTS ACTION REMARKS j
10-IB-15 Not Available.
Not Available.
Indications Evaluated Reported.
as counter-bore and con-firmed by construction x-ray, 10-IB-16 Not Available.
Not.Available.
No Indications.
RHR (Head 1001 Ultra-Ultrasonically No Indications.
Inside and Spray sonic Exam-examined twenty--
outside con-ination of two of the tainment.
the ASME Code twenty-three Class 1 Portion welds.
of the system.
I Held 10-HS-23*
Exemption is scheduled from Order for radiography.
requested.
(tri-metallic Scheduled Weld),
for RT.
Core Spray 1001 Ultra-
- 1) The following Exemption sonic Exam-welds will be from Order ination of the radiographed:
requested.
ASME Code 14-A-1,14-A-3, Scheduled Class 1 14-A-10A, 14-8-1, for RT.
Portion of the 14-B-3,14-B-10A system.
- 2) 14-A-2 and Excluded 14-B-2 not from Order examined as it because is 316L material.
welds are not 304SS.
l ENCLOSURE'(A)
MATRIX OF: IGSCC INSPECTION ORDER EXAMINATIONS-Page 3 of 7 ORDER EXAMINATION CORRECTIVE 15YSTEM REQUIREMENTS BECO'S ACTION STRESS RULE CARBON CONTENT RESULTS ACTION REMARKS
- 3) All 304SS Excluded from 14-A-3 and from Order 14-B-3 to the~
because manual isolation welds are.
valves.was replaced not 304SS.
with carbon steel
'during the 1977 refueling outage'.
- 4) 304 pipe material from the manual isolation val-ves to the dry-well penetration'is being' replaced with 316 NG.
This eliminates the following welds:
A-Loop B-Loop 14-A-11 14-B 14-A-11A 14-B-12 14-A-12 14-B-13 14-A-13 14-B-14
'14-A-14 14-B-15 14-A-15 15-B-16 14-A-16
fk
, ENCLOSURE A).
MATRIX OF IGSCC INSPECIION ORDER EXAMINATIONS Page.4 of'7-.
ORDER EXAMINATION CORRECTIVE l SYSTEM
-REQUIREMENTS
-BECO'S ACTION-STRESS RULE' CARBON CONTENT RESULTS
' ACTION REMARKS
- 5) The following welds outside:
containment to the' Class 1-boundary were
- examined:
A-Loop-
'14-A-17 Not Available.
Not Available.
No-Indications. A-18 Not Available.
Not Available.
Indications.
Evaluated as Reported.
counterbore and 14-A-19 Not Available.
~Not Available'.
No Indications.
confirmed by construction X-ray.
B-Loop:
14-B-17 Not Available.
Not Available.'
No Indications.
.14-B-18 Not.Available.
NotlAvailable.
No Indications.
14-B-19 Not Available.
Not Available.
No Indications.
14-B-20 Not Available.
Not Available..No Indications.
14-B-21 Not Available.
Not Available.
Indications Within 25% of
- Reported, wall thickness, therefore, evaluation in accordance with NRC criteria shall be performed.
RHCU 1001 Ultra-
- 1) RWCU Suction sonic. Exam-pipe from the ination of the RHR supply line ASME Code to the drywel1 Class 1 System.
penetration will be replaced with 316NG material.
. l.
ENCLOSURE (A)'
~
MATRIX-OF-IGSCC INSPECTION ORDER EXAMINATIONS-Page 5.of'7..
~0RDER EXAMINATION CORRECTIVE SYSTEM REQUIREMENTS BECO'S ACTION STRESS RULE.
CARBON CONTENT ~
RESULTS ACTION REMARKS i
- Helds 12-0-24 Not Available.
Not Available.
No Indications.
through 12-0-31 (Outside'contain-
. ment.)
.RHCU Discharge. Not Available.
Not Available.
No Indications.
pipe from the-transition weld 12-I-17 through weld 12-I-36 were examined with the following excep-tions:
a) 12-I-20,12-I-22 pipe whip restraints.
Penetrations 100% Ultra-
.BECo requested RHR sonic exam-exemption ation.
X-51A Not Available.
Not.Available.
No examination conducted; penetration welds are inaccessible for ultra-sonic exam-ination.
ENCLOSURE (A) i MATRIX OF IGSCC INSPECTION ORDER EXAMINATIONS Page 6 of 7 ORDER-EXAMINATION' CORRECTIVE -
SYSTEM REQUIREMENTS BECO'S' ACTION STRESS RULE CARBON CONTENT RESULTS ACTION REMARKS
.X-518 Not Available.
Not Available.
ID of dye was To be dye penetrant-corrosion.
Inspected, resistant; NO IGSCC.
clad when piping subsequently associated with welds Nos.
10-IB-14A and 10Ib-15 is replaced.
Core.
X-16A Not Available.
Not Available.
No Spray examination-conducted; penetration welds are.
inaccessible for ultra-sonic exam-ination.
X-16B Not Available.
Not Available.
No examination conducted; penetration welds are inaccessible for ultra-sonic exam-ination.
-q
' ENCLOSURE'(A)'
' J-
-1 MATRIX OF IGSCC INSPECTION ORDER EXAMINATIONS Page'7 of 7.
ORDER.
EXAMINATION.
CORRECTIVE' SYSTEM-REQUIREMENTS
-BECO'S ACTION
-STRESS RULE CARBON CONTENT ^
RESULTS ACTION-REMARKS RHCU X-14 Not Available.
Not Available.
.No examination.
o conducted;.
welds are inaccessible
-for~ ultra-
' sonic exam-ination.
SYMBOLS ENCLOSURE (B)
-o-NRC REQUIRES UT EXAMINATION REPLACE WITH 316NG MATERIAL g
NOT EXAMINED DUE TO OBSTROCfl0N, MAT *L ETC.
X ULTRASONIC TEST COMPLETED c
g WELD SCHEDULED FOR RADIOGRAPHY (TRI-METALLIC)
)
INDICATIONS REPORTED 4
i r-l NOTES l
l 1.
Section will be removed rather than replaced.
l l
2.
ID of weld was dye penetrant inspected. No IGSCC. To be corrosion resistant clad when piping i
subsequently associated with welds Nos.10-IB-14A and 10lb-15 is replaced.
l t
3.
Indications reported.
J 4.
Evaluated as counterbore and confirmed by construction x-ray.
5.
Within 25% of wall thickness, therefore, evaluation in accordance with NRC criteria shall be l
l performed.
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'O'5StMIL AR METAL t* 27 s EL 3d__ Q3y/.,,r'b X aw> -7 e 8 ~ LL 42' -2 ',$ \\8~ -26 PtPE DATA v 10 [4 -6 DA - f 2 ~.g3 d ll,l +G ' -5 f4 i f 24 .n uwi owe o.337 i3.i.i G i> i '.,' ^ ' uc Pi id scr^ 6.; X -zi ,g.g. i q -".s / \\ N X snE. mu ~ -20 '4 ' am 1O 7f p FEEDWATER.. A 'IT. T.-~p) [RditL3 a* f*'~ s a yh@argpfyf a paa-g' F1 '27 A
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l ENCLOSURE (C) WELDS NOT SCHEDULED FOR EXAMINATION-SYSTEM WELD IDENTIFICATION
- DIAMETER DRAWING NO.
EXEMPT CODE' Head Spray 10-HS-23 4" ISI-I-10-5A 4 Core Spray 14-A-1* 10" ISI-I-14-1 2 (Loop A)- 14-A-3* 10" ISI-I-14-1 2 14-A-10A* 10" ISI-I-14-1 2 Penetration Held (X-16A) 10" ISI-I-14-1 1,3 Core Spray 14-B-1* 10" ISI-I-14-1 2 (Loop B) 14-B-3* 10" ISI-I-14-1 2 14-B-10A* 10" ISI-I-14-1 2 . Penetration Held (X-168) 10" ISI-I-14-1 1,3 RWCU 12-I-20 4" ISI-I-12-2 3 12-I-22 4" ISI-I-12-2 3 12-I-16 6" ISI-I-12-2 4 NOTES: A. Carbon steel welds shown on drawings are not listed. B. Exemption Codes are: 1. Normal system operating temperature less than 200*F. 2. Weld is in 316 stainless steel piping material having low carbon content (below 0.02%) or is a dissimilar metal weld consisting of low carbon 316 stainless steel and carbon steel base materials, clad with Inconel and welded out with Inconel weld metal. 3. Weld is not accessible for ultrasonic examination because of component configuration. 4 Tri-metallic weld. Weld 10-HS-23 will require radiography due to its configuration. Welds 14-A-1*, 14-B-1*, 14-A-3*, 14-B-3*, 14-A-10A*, and 14-B-10A* in the ASME Code Class I portion of the Core Spray System external to the Reactor Vessel will be radiographed in lieu of UT examination because these welds are trl-metallic. Welds 14-A-2 and 14-B-2 were fabricated with 316L base metal and 308L weld metal and consequently were excluded from the Order.
ENCLOSURE (D) HYDROGEN / WATER CHEMISTRY PROGRAM FOR PILGRIM NUCLEAR POWER STATION The Hydrogen / Hater Chemistry Program for Pilgrim Nuclear Power Station will contain three major objectives. The.first objective will be to develop and ' permanently implement Hydrogen chemistry control for the reactor coolant system. The purpose of this objective is to suppress IGSCC in the reactor coolant system piping by reducing the electrochemical driving force for IGSCC. A commercially feasible hydrogen chemistry control program / system does not exist at this time. As such, commencing with startup from the current refueling outage, feasibility studies will be conducted at Pilgrim Station to develop the necessary design criteria to develop such a system. Injection and instrument taps will be installed and other modifications made to the reactor coolant system to facilitate testing. Various methodologies will be evaluated and a final conceptual design is targeted for implementation during RF0 #7. The implementation of Hydrogen chemistry control at Pilgrim Station will significan$.8y impact station operations. Radiation levels are expected to rise which in turn will create shielding problems in several areas of the plant. Extensive analyses and evaluations will have to be conducted to address this impact. From a licensing perspective relief from the Technical Specifications will be needed for the Main Steam Line Radiation Limits. The second objective of the Hydrogen / Hater Chemistry Program provides interim measures, during the upcoming fuel cycle, to minimize the potential for IGSCC propagation. This objective creates a general water chemistry control program for the reactor coolant. It is our intention to make every effort to comply with the Electric Power Research Institute guidelines for BHR water chemistry. Achieving this second objective will also require several major changes to system operations. Lessons learned during this interim period will be incorporated in the ongoing program to modify the reactor coolant environment to mitigate IGSCC. The final objective is to effect a reorganization such that water chemistry control at Pilgrim Station is given sufficient attention and importance to make it an integral part of station operations. Dedicated manpower and resources will be allocated to facilitate a permanent and comprehensive Hydrogen / Water Chemistry Program. I
...-.s., 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 l 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. 11e in' formation sought to be withheld pertains to the proprietary information submitted in NEDC-30730-P, " Pilgrim Nuclear Power Station-Recirculation Nozzle Repair Program and Hydrogen Water Chemistry Materials Qualification", Class III, August 1984. 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: j. "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 information... Some factors to be considered in determining js 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 t'o 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 compet-itive economic advantage over other companies; b. Information consisting of. supporting data and analyses, including test data, relative to a process, method or appara-tus, the application of which provide a competitive economic advantage, e.g., by optimization or improved marketability; 4 ( f.
y 4-c e: s
- (
I c. Information which if'used by a competitor, would reduce his-expenditure of resources or improve his competitive position iin 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 conclustons 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 ~
- w general public in such a preliminary 1 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 od 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 all1 times are clearly identified as g proprietary. t 4 4
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. ;.a 9 - a 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 Genera 1' 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. L8.; ~ 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. 19.= The-information mentioned in paragraph 2 provides details of the ~ recirculation inlet and outlet safe-end to nozzle weld inspection and repair prior to the. installation of.new safe-ends at Pilgrim. In' addition, justification is provided for continued. operation with -intermittently cracked recirculation inlet nozzle thermal sleeves. 'Also, the results of the hydrogen water chemistry materials qualification program are discussed.
- 10. 1The information to.the best of my knowledge and belief, has 3
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'or to proprietary information agreements which provide for maintenance of the 'information in confidence. 11._ Public disclosure of the information sought to be withheld is _ likely to cause substantial h' arm to the competitive position of the General Electric Company and deprive or reduce the availability of- . profit-making opportunities because: It was developed with the expenditure of resources exceeding a. l $500,000.00. b.- Public availability of this information would deprive General Electric of the' ability _to seek reimbursement and would permit competitors to utilize this information to General Electric's detriment, to the substantial financial and competitive disadvantage of General Electric. n t u
\\ .. i s. 1 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, this day of ,198[. U / J rph'F. Quirld G ral Electric Company ik Subscribed and suorn before me chis 3 day of b uf ,198j. V W 19 setJw NOTARY PUBLIC, STATE OF CALIFORNIA _____-u.-_y OFFICIAL SEAL @9 RUTHE M KINNAMON 0TARY PUtuC
- CAUFORNfA 3ANTA CLARA mmTY My comm. oghes APR 26, 1985 75A
[h n hee, CA 3515 ..}}