ML20117H617
| ML20117H617 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 05/22/1996 |
| From: | Dawn Powell Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19355D284 | List: |
| References | |
| LR-N96139, NUDOCS 9605280289 | |
| Download: ML20117H617 (8) | |
Text
O PSIEG Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038-0236 Nuclear Business Unit MAY 2 21996 LR-N96139 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemer4:
SHUTDOWN COOLING BYPASS EVENT SUPPLEMENTAL INFORMATION HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 Public Service Electric and Gas Company (PSE&G) is submitting the enclosed analyses that were performed as a result of the Hope Creek Generating Station's shutdown cooling bypass event.
This event occurred July 7-8, 1995, and was documented in Hope Creek Licensee Event Report (LER) 95-016-00 dated August 9, 1995 and updated by supplemental LERS 95-016-01 and 95-016-02 dated October 3, 1995 and March 6, 1996, respectively.
Following the event, PSE&G performed simplified calculations that determined the status of the reactor coolant, and confirmed that an operational condition change from Cold shutdown to Hot Shutdown had occurred.
General Electric Company (GE) has performed more detailed computer analyses of the event.
These analyses, entitled Hope Creek Generating Station Shutdown Cooling Analyses, have been reviewed by PSE&G and are being submitted as Enclosure 1 to this letter.
This document is GE Proprietary Information and in accordance with 10CFR2.790 (a) (4) and 10CFR2.790 (d) (1), we request that this information be withheld from public disclosure. to this letter contains the GE affidavit supporting this request.
l Should there be any questions regarding this submittal, please do not hesitate to contact us.
l Sincerely, DA.Ad D. R. Powell I
- ] 2 Manager -
[d Licensing and Regulation i
9605200289 960522 s
i PDR ADOCK 05000354 l
S PDR TheputrisinSourbank 95 2166 FIEV 694
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~ Document' Control Desk. MAY 2 21996 LR-N96139 C:
Mr. T.
T. Martin, Administrator - Region'I i
U.
S. Nuclear Regulatory Commission i
475 Allendale Road' King of' Prussia, PA 19406.
Mr.
D. H Jaffe,' Licensing Project-Manager - Hope Creek-U.
S. Nuclear Regulatory Commission l
l One White Flint North 11555 Rockville Pike l
Mail Stop 14E21 L
Rockville, MD 20852 Mr.
R. Summers (X24) l USNRC Senior Resident Inspector Mr.
K.
Tosch, Manager IV Bureau of Nuclear Engineering 33 Arctic Parkway CN 415 Trenton, NJ 08625 I'
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LR-N96139 ENCLOSURE 1 HOPE CREEK GENERATING STATION SHUTDOWN COOLING ANALYSES 1
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LR-N96139 ENCLOSURE 2 AFFIDAVIT
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1 General Electric Company l
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I, George B. Stramback, being duly sworn, depose and state as follows:
(1) I am Project Manager, Regulatory Services, General Electric Company ("GE") and i
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 report GE-Nii-El100075-01, Hope Creek Generating Station Shutdown Cooling Analyses,,
Class Ill (GE Proprietary Information), dated February 1996. 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 relies 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). Tr.e 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 Fnergy Proiect v. Nuclear Remilatory Commission. 975F2d871 (DC Cir.1992), and Public Citi7en Health Research Groun
- v. FDA,704F2d1280 (DC Cir.1983).
(4) Some examples of categories of information which fit into the definition of proprietary information are:
Information that discloses a process, method, or apparatus, including supporting a.
data and analyses, where prevention ofits use by General Electric's competitors without license from General Electric constitutes a competitive economic advantage over other companies; l
b.
Information which, if t.
4 by a competitor, would reduce his expenditure of r
l resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product; i
i GBS-96 3-afHCTRAC. doc Affidavit Page i
i Information which reveals cost or price information, production capac c.
budget levels, or commercial strategies of General Electric, its customers, suppliers; d.
Information which reveals aspects of past, present, or future General Electric cus'tomer-funded development plans and programs, of potential commerc value to General Electric:
Information which discloses patentable subject matter for which it may bc e.
desirable to obtain patent protection.
j 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 review by the staff manager, project manager, principal scientist or other equivalent authority, by the 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. 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.
(8) The infonnation identified in paragraph (2), above, is classified as proprietary because it contains detailed results of a TRACG code analysis of the Hope Creek Shutdown Cooling Event including sensitivity analysis of the important parameters using analytical models, methods and processes, including computer codes, which GE has developed and applied to perform evaluations of reactor loss-of-coolant accidents and transients for the BWR.
GBS-96 3-afHCTRAC. doc Affidavit Page 2
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He development and approval of the TRACG code for application to the BWR as used in this analysis was achieved at a significant cost, on the order of several million dollars, to GE.
j' The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience i
database that constitutes a major GE asset.
(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 l
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.
i 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 conclusicas.
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 undertake 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 retum on its large investment in developing these very valuable analytical tools.
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1 STATE DF CALIFORNIA-
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COUNTY OF SANTA CLARA
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l 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.
day of [M 1996.
Executed at San Jose, Califomia, this //oO Lo B Gedrge B.dtramback General Electric Company l
l Subscribed and swom before me this 4W day of 4m,m/ 1996.
6
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l u
ary Public, State of C@
is JULIE A CURIS COMM. # 974651 g
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Noto*y PubEc - Cohfomic 3
l SANTA CLARA COUN1Y My Comm. Empires SEP 30.1996 l
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