ML20127H493

Forwards GE Rept GE-NE-770-14-0592, CR & Offsite Doses from 300 Gpm Reactor Water Cleanup Sys Leak, in Support of 920914 License Amend Application Re Steam Leak Detection Instrumentation Numac Upgrade.Rept Withheld

ML20127H493
Person / Time
Site:	Brunswick
Issue date:	01/13/1993
From:	Mccarthy D CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19303F200	List: ML20127H493
References
NLS-93-002, NLS-93-2, TAC-M84686, TAC-M84687, NUDOCS 9301220345
Download: ML20127H493 (5)

Text

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CaroIIna Power & Light Company (JM413 B93 SERIAL: NLS 93-002 TSC 92TSD01 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 DRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50 325 & 50 324/ LICENSE NOS. DPR 71 & DPR 62 STEAM LEAK DETEC110N INSTRUMENTATION NUMAC UPGRADE (NRC TAC NOS. M84680 AND M84687)

Gentlemen:

The purpose of this letter is to submit a copy of a General Electric Company calculation in rupport of Carolina Power & Light Company's (CP&L) September 14,1992 license amendment application for the Brunswick Steam Electric Plant, Unit Nos.1 ano 2. The proposed amendment revises the Technical Specifications to reflect the replacement of ox! stir'g Riley, GEMAC, and Fenwat steam leak detection equipment with General Electric NUMAC leak detection equipment.

During a December 23,1992 telephona discussion, the NRC staff requested that CP&L provide a copy of the General Electric calculation for evaluating control room and offsite doses based on an assumed 300 opm reactor water cleanup system leak. Enclosure 1 provides a copy of General Electric Comppny Report GE-NE 770-14 0592, DRF E31-0029 2 Class 111, " Control Room and Offsite Doses from 300 GPM Reactor Water Clean Up System Leak," dated May 1992. Gencial Electric has informed CP&L that the document is considered proprietary. Therefore, an affidavit is provided in Enclosure 2 that supports withholding the document from public disclosure.

The Company recognizes that techniques used in the General Electric analysis for the partitioning factor and whole body dose determinations are not as conservati.'o as some other methods.

Application of more conservative techniques in the verification process concluded that the effects are nrat significant and tiie rcssults are still well below the acceptance criteria.

Please refer any questions regarding this submittal to Mr. D. B. Waters at (919) 546-3678.

Yours very truly, D. C. McCarthh

-* 0% Nuclear Licensing Section WRM/wrm (nis93002.wpf)  ;

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9 Document Control Desk NLS 93 002 / Page 2 cc: Mr. S. D. Ebneter Mr. P. D. Milano Mr. R. L. Prevatte I

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GENERAL ELECTRIC COMPANY AFFIDAVIT I, David J. Robare, being duly sworn, depose and state as followst

1. I am Manager, Plant Licensing Services, General Electric Compar.y, 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 containod in General Electric Report, GE-NE-770 14-0592. DRF-E31-0029 2 Class III, " Control Room and Offsite Doses from 300 GPM Reactor Water Clean Up System Leak", dated May 1992.

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 I

which gives him an op)ortunity to obtain an advantago over competitors who do not (now 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 expanded by him developing the information; (G) the ease or difficulty with which I

the information could be properly acquired or duplicated by others."

4. Some examples of categories of information which fit into the I

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 application of which provide a competitive economic advantage, e.g., by optimization or improved marketability;

. A s -w.inea-e.s., .m . - ~ . ..-w.--%---.<--s..---.-.se-+---+ne---.--.-4e.-~= , ----w-----e.was...- -*---w =--s%=.u=ww GENERAL ELECTRIC C0MPANY

c. Information which if used by a competitor, would reduce his expenditures 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 destrable to obtain patent protection;

g. Inf ormation which General Electric must treat as proprietary according to agreements with other parties.

5. Initial approval of proprietary treatment of a document is typically made by the Subsection Manager of the originating component, the person 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 "noed 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, competitively 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, suppliers and lic.ensees then only with appropriate protection by applicable regulatory provisions or proprietary agreements.

I 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.

B. The infora.ation to the best of my knowledge and belief has 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 of proprietary agreements which provide for maintenance of l

the information in confidence.

, A

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i GENERAL E-L E C T R I C CONPANY-l 9. Public disclosure of the information sought to be withheld is likely to

cause substantial harm to the competitive position of .the General i Electric Company and deprive or reduce the availability of profit 4

making opportunities because it would. provide other parties, including i competitors, with valuable information.

1 -

l STATE OF CALIFORNIA )

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e COUNTY OF SANTA CLARA -)

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! David J. Robare, being duly sworn, _ deposes and says:

! That he has read the foregoing affidavit _and the matters stated therein are truly

. and correct to:the best of his-knowledge, information, and belir

! Executed at San Jose, California, this 31 day of _ .- 4 19 M .

i i.dT ONL, David E Robare

! General Electric Company-i Suoscribed and sworn before me this 3/dday of MM 19 f,t.

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h,h A. u-y /  !!A?.

hotary Publfc, State of CalTrornia 1

OFFICIAL SEAL

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• MARY L KENDALL

- Notary Public Ca5fomia Q

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SANTA CLARA COUNTY c- My Comm. E4. Wr. 26.1950 i

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