ML20116E596

Forwards Proprietary Updated Draft Gessar II Amend Supporting Leak-Before-Break. Submittal for Carbon Steel Piping Scheduled for 850618.Rept Withheld (Ref 10CFR2.790)

ML20116E596
Person / Time
Site:	05000447
Issue date:	04/26/1985
From:	Sherwood G GENERAL ELECTRIC CO.
To:	Thompson H Office of Nuclear Reactor Regulation
Shared Package
ML19269B455	List: ML20116E596
References
MFN-054-85, MFN-54-85, NUDOCS 8504300340
Download: ML20116E596 (6)

Text

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GENERAL $ ELECTRIC NUCLEAR ENERGY BUSINESS OPERATIONS GENERAL ELECTRIC COMPANY

• 175 CURTNER AVENUE e SAN JOSE, CAUFORNIA 95125 MC 682, (408) 925-5040 April 26, 1985 MFN# 054-85 U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, D.C. 20555 Attention: H. L. Thompson, Jr., Director Division of Licensing Gentlemen:

SUBJECT:

IN THE MATTER OF 238 NUCLEAR ISLAND GENERAL ELECTRIC STANDARD SAFETY ANALYSIS REPORT (GESSAR II)

DOCKET NO. STN 50-447 SUBMITTAL OF DRAFT AMENDMENT SUPPORTING LEAK-BEFORE-BREAK APPROACH

References:

1) Glenn G. Sherwood to H. L. Thompson, Jr. , " Review of .

Leak-Before-Break Approach on GESSAR II Docket," April 4, 1985, MFN-049-85

2) J. F. Quirk to Cecil 0. Thomas, " Submittal of Draft Amend-ment Supporting Leak-Before-Break Approach," January 31, 1984, MFN-011-84 Attached please find the updated draft amendment to GESSAR II supporting the leak-before-break (LBB) approach. This update, as noted in Reference 1, was necessary to make the submittal consistent with the recommendations of the recently issued NUREG-1061, Volume 3. As in the case of the original submittal (Reference 2), the update is limited to stainless steel piping. The following summarizes the elements of this submittal:

1. Modification to Section 3.6 - Introduces LBB approach as an alternate to current criteria and provides a road map to supporting Appendices 3J, 3K, 3L and 3M.

2. Modification to Section 3.9 - Provides a reference to the alternate pipe break criteria of Appendix 3J.

3. New Appendix 3J - Describes the modifications to criteria related to pipe break postulations.

4. New Appendix 3K - Characterizes the fracture mechanics properties of piping materials and analysis methods, including the leak rate calculation 3 methods.

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5. New Appendix 3L - Establishes the probabilistic fracture mechanics methodology for direct double-ended guillotine breaks (DEGBs).

6. New Appendix 3M - Applies the method of Appendix 3K to specific piping systems to demonstrate the qualification to the LBB approach. The method of Appendix 3L is also applied for additional justification to eliminate DEGB postulation and decouple SSE and LOCA, with a discussion on DEGB probability from indirect causes.

Also included in items 1 and 2 above is a proposed revision to the current pipe break criteria when the LBB approach is not selected. This revision related to the justifiable elimination of arbitrary intermediate breaks (following the recommendation of NUREG-1061, Volume 3) and to application of pipe break criteria for nuclear piping to non-nuclear safety-related piping analyzed for seismic loads.

We are preparing a separate submittal for carbon steel piping. This second submittal, scheduled for 6/18/85, should allow ample time for the NRC staff to complete its Safety Evaluation Report by 9/1/85.

We are requesting that the attached information designated as proprietary be withheld from public disclosure pursuant to Section 2.790 of 10CFR Part 2.

If you have any questions, please contact me on (408) 925-5040 or R. Villa (408) 925-5722 of my staff.

Very truly yours, Glenn G. Sherwood, Manager Nuclear Technologies and Fuel Division GGS: rm:pc/A04235*

Attachment cc: L. S. Gifford B. D. Liaw D. L. Murray J. A. O'Brien D. C. Scaler.ti C. O. Thomas

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i GENERAL ELECTRIC C0MPANY j l

AFFIDAVIT I, Rudolph Villa, being duly sworn, depose and state as follows:

1. I am Manager of Product 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 pertains to the proprietary information submitted in Appendices 3K, 3L and 3M supporting the leak-before-break approach for the 238 Nuclear Island General Electric Standard Safety Analysis Report (GESSAR II).

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 econom-ic advantage over other companies; JF: rm/A04236* _ . _ __ - . . _ _ _ _

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;

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 tenta-tive 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 occa-sion 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 l

permitting General Electric to insure the public documents are l 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 sansitivity of the g

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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 Scien-tist 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 determina-tion 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, 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 Hth 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 mentioned in paragraph 2 provides fracture mechanics and leak. rate calculational methods, qualification of piping for the leak-before-break approach, and the probability of a LOCA in reactor coolant system piping.

10. The information to the best of my knowledge and belief, has consis-

-tently been held in confidence by the General Electric Company, no public disclosure has been made, and it is not available in public q sources. All disclosures to third parties have been made pursuant to regulatory provisions of 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:

a. It was developed with the expenditure of resources exceeding

$200,000,

b. Public availability of this information would deprive General Electric of the ability to seek reimbursement, would permit competitors to utilize this information to General Electric's detriment, and would impair General Electric's ability to maintain licensing agreer.ents to the substantial financial and competitive disadvantage of General Electric.

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STATE OF CALIFORNIA )

COUNTY OF SANTA CLARA ) ss:

Rudolph Villa, 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, thish day of pp/!,19d MY Rudolph Vilra General Electric Company Subscribed and sworn before me thi d day of Aop[/19[

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_________ _ AdF OFFICIAL SEAL KAREN S VOGELHUBER NOMWPUBLIC, STATE OFfLIFORNIA

@ NOTARY PUBLfC - CAUFOR SANTA CLAPA COUNTY My comm. expires DEC 30, 1988 JF: rm/A04236* .- _, .