ML20097J276
| ML20097J276 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 09/19/1984 |
| From: | Beckham J GEORGIA POWER CO. |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19269A544 | List: |
| References | |
| RTR-NUREG-0619, RTR-NUREG-619 GL-81-11, NED-84-496, TAC-55966, TAC-55967, NUDOCS 8409210185 | |
| Download: ML20097J276 (9) | |
Text
m u,
Georg*a Power Conipany
= 333 Pedmont Avenuo !
8
= Acanta. Georgia 30308 z Telephone 404 526-7020
'Mamng Address-
~ Post Offes Box 4545
. Atlan:a, Georgta 30302 Georgia Power ttv septnern e e:ctne system v
J. T. Beckham, Jr.
NED-84-496 vce President and cenerai uanage, Nuclear Generation September 19, 1984
. Director of Nuclear Reactor Regulation
~-
. Attention: Mr. John F. Stolz, Chief Operating Reactors Branch No. 4.
- Division of-Licensing U. S. Nuclear Regulatory Ocamission Washington, D. C.
- 20555.
NRC DOCITIS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. IWIG NUCLEAR PUNI' UNITS '1, 2
FEEDWA'IER N0ZZLE FRAC'ItJRE MECHANIG ANALYSES Gentlemen:
By leter dated June 30, 1983, Georgia Power Ccapany (GPC) advised you-of the preliminary results.of the fracture mechanics analyses performed for the feedwater nozzles for Hatch Units 1 and 2.
'1he subject analyses were
'x performed for the Hatch - units pursuanti to _ NUREG-0619 as mended by NRC Generic Intter 81-11 in order ' to determine the acceptability of continued -
use of the existing feedwater low flow controllers.
Continued use of the
.~ existing low flow controllers was acceptable provided that crack growth as idetermined by the fracture mechanics analysis was one-inch or less for a
-forty-year plant life. The purpose of this letter _ is to transnit the final
~results of the fracture mechanics analyses for Hatch Units 1 and 2.
1
Ibe results of the - fracture mechanics analysis performed by General I Electric (GE) - for Hatch Unit 1 indicate that the feedwater nozzle crack growth would be less than one-inch during the forty-year life of the unit.
- the best-fit crack growth relationship (using a best-fit curve developed from actual. fatigue crack growth) resulted in an end-of-life crack depth of
- 0.47 inch, whereas the A!ME Section-XI crack growth relationship (developed -
ur:ing the 1980 AEME Section XI fatigue crack growth curves) resulted in a "d.82 ; inch depth..'therefore, the existing Hatch Unit 1 feedwater low flow controller is in compliance with NUREG-0619 as mended by NRC Generic Intter 81-11 and:is acceptable for continued use. Enclosed for your review are six (6) ; copies of proprietary GE topical report NEDE-30238 for Hatch Unit 1 which ' discusses the fracture mechanics analysis in detail and the results thereof.
gho
[ ooh P
i l%
r-
- 7, Georgia Power A Director of Nuclear-Reactor Regulation Attention: Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 Septenber 19, 1984 Page 'Iwo
%e results of the fracture mechanics analysis performed by GE for Hatch Unit 2 were unacceptable in that crack growth of the feedwater nozzle would exceed one-inch during ' the forty-year life. of the unit.- Re-analysis by GE indicated similar results. %e best-fit crack growth relationship resulted in a one-inch crack-after 33 years of operation, while the ASME Section XI crack growth relationship resulted in a one-inch crack depth after 13 years of operation.- herefore,' the existing feedwater low flow controller at LHatch. Unit. 2 is not in cmpliance with NUREG-0619 as anended by Generic Intter 81-11 and requires corrective action by GPC.
Enclosed for your review are six (6) copies of proprietary GE topical report NEDC-30256 for Hatch Unit 2 which discusses the fracture mechanics analysis in detail and the results thereof.
hith regard to corrective action for the Hatch Unit 2 feedwater low flow controller, please be advised that we are in the process of reviewing the
. various recmsnendations made by GE.
At this time, no course of action has been deteanined with regard to modification or replacenent of the subject equipnent. Upon determination of what course of action to pursue, we will advise you accordingly and provide a schedule for implenentation.
Please be advised that the topical reports of the Hatch Unit 1 and 2 fracture mechanics analyses were not issued by GE to GPC in non-proprietary form. Consequently, the topical reports enclosed herein contain information which the General Electric Company custmarily maintains in confidence and withholds fra public disclosure.
%e information has been handled and classified as proprietary to General Electric, as indicated in the attached affadavits, and it is hereby requested that GE topical reports NEDE-30238 and NEDC-30256. for Hatch Units 1 and 2,
respectively, be withheld from public disclosure in accordance with the provisions of 10 CFR 2.790.
Should you have any questions in this regard, please contact this office.
Georgia Power A Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 September 19, 1984 Page Three J. T. Beckhm, Jr. states that he is _ Vice President of Georgia Power Cmpany and is authorized to execute this oath on behalf of ' Georgia Power Cmpany, and that to the best of his knowledge and belief the facts set forth in this letter are true.
GEORGIA POhTR O@lPAhY b
h By:
y J. T. Beckh m, Jr.
Sworn to and subsc i before me this 19th day of r, 1984.
Notary Finbhc. Georgia. Sta t W Commession Expires Sept.18,1987 g
Notary Public JAE/trb
Enclosures:
Affadavit for NEDE-30238 NEDE-30238 (6 copies)
Affadavit for NEDC-30256 NEDC-30256 (6 copies) xc:
H. C. Nix, Jr.
Senior Resident Inspector J. P. O'Reilly, (NRC-Region II)
Director, Office of Inspection and Enforement (Washington)
e a'
o s
o N,
GENERAL ELECTRIC COMPANY AFFIDAVIT 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.
9EciwinE. THatc6, Nudlearlower'Sfation', Unit 2,~ Fe'edwAter' Nozzle Fracture I
~
2.
'MechanicsLAnalysis",(NEDC-30256, August,1983f~
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 defini-tion 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 information....
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 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 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 applica-tion of which provide a competitive economic advantage, e.g., by optimization or improved marketability;.
t
-.n.
s a:aw
.~
-~ a. ~...a
.+
.~x.,
g.,
l c.
Information which if used by a competitor, would reduce his expendi-ture of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality or licensing of a similar product; i
d.
Information which reveals cost or price information, production l
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.
Infcrmation 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 acquain-tance 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 treatme.nt 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.
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 customers and their agents, w L.h
..a
. nw
C a
.t 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.
The information contained herein is the result of extensive analyses performed at considerable cost to the General Electric Company.
The development and verification of these methods, as well as their applica-tion and execution cost in excess of $1 million.
STATE OF CALIFORNIA
) ss:
COUNTY OF SANTA CLARA
)
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 f_ day of R us,f M, 198 M
b n/kAt Glenn G.' 'Sherw~oor ~ ~ ~ ~ '
General Electric Company Subscribed and sworn before me this 2 day of Piu.Giud198h y
IC A
---=-
csc/108024 OFFICIAL SF.AU KAREN S. VOGELHUBER NOTARY PUBUC.CAutotNIA q SANTA CLARA COUNTY My Commission Expires Dw 21 1984 g
. :;;ttO40aosooooooooooo,oosocosy.
- -w Al. w..
.. a A a. : -w.n.
mj
/,
b E
GENERAL ELECTRIC C0MPANY AFFIDAVIT 4
I, Ricardo Artigas, being duly sworn, depose and state as follows:
1.
I am Manager of BWR Projects Licensing, 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 _is contained.in.the repor.t_,
entitled.T"Edwin I. Hatch. Nuclear Power Station / Unit 1, Feedwater- -.s NozzleFracture_' Mechan.i._csAnalysis'toShowlCompliancewithNUREG-0619,"]
j_
m w ~<- -
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 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:
Information that discloses a process, method or apparatus where a.
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 competiti'ze economic advantage, e.g., by optimization or improved marketa Wlity; HTW: rm:csc/A08257 9/1/83 l
~-
0-Information which if used by a competitor, would reduce his c.
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; Information which reveals aspects of past, present or future e.
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.
In addition to proprietary treatment given to material meeting the 5.
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 accurata and correct.
6.
Initial appre al
>f proprietary treatment of a document is made by the Subse% - + ager of the originating component, the man most likely t)
-P cinted with the value and sensitivity of the informato. b :.e ation 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 l
HTW:rm:csc/A08257 9/1/83
.?
- - - - - - - - - - ' ' - - ' ' ' ^ - ~
=
standards enumerated above.
Disclosures outside General Electric j
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.
3 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 s
held in confidence by General Electric.
=
9.
The detailed design data, test data, test instrumentation drawings, and test process data are considered proprietary.
g 10.
e
~~
iformation, to the best of my knowledge and belief, has consistently been held in confidence by the General Electric Company, no public j
disclosure has been made, and it is not available in public sources.
Also, disclosures to third parties have been made pursuant to Regulatory provisions for proprietary 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 harm to the competitive position of the General Electric Company and deprive or reduce the availability of profit making opportunities because approximately 6 manmonths and $100,000 g
in test facilities were required to obtain the information.
g STATE OF CALIFORNIA
)
COUNTY OF SANTA CLARA
) ss:
j 4
Ricardo Artigas, 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.
f I
i Executed at San Jose, California, this day of dU OW/,,1981 I
1 1
I em
+
a Ricardo Artig%
General Electric Company
-j Subscribed and sworn before me this /
day of5DIrmam1983 j
cocececocccccccccocccecocccccet j
OFFICIAL SEAL
,/
7 g> ar.KAREN 5. VOGELHUBER 8 NOTARY PUBUC CAUFORNIA 8 p y(
1 i
=
2
$ My Commission Expires DecSANTA CLARA COUNTY NOTARY PUBLIC. STA 0F CALIFORNIA j
i 3
kmmmmmmcumcec. 21,1984ucumcuc3 5
HTW: rm:csc/A08257 -
-4 9/1/83
- - - - - - " - - ' i...........
- ' -