ML20129F358
| ML20129F358 | |
| Person / Time | |
|---|---|
| Site: | 05000447 |
| Issue date: | 05/17/1984 |
| From: | Quirk J GENERAL ELECTRIC CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20127A304 | List: |
| References | |
| FOIA-84-175, FOIA-84-A-66 JFQ-18-84, MFN-058-84, MFN-58-84, NUDOCS 8506060749 | |
| Download: ML20129F358 (8) | |
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GENERAL 4 ELECTRIC NUCLEAR POWER SYSTEMS DMslON GENERAL ELECTRIC COMPANY
- 175 CURTNER AVENUE e SAN JOSE, CAUFORNIA 95195 May 17, 1984 MFN-058-84 JFQ-18-84 U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, D. C.
20555 Attention:
Mr. D. G. Eisenhut, 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 GENERAL ELECTRIC SOURCE TERM SENSITIVITY STUDY Attached, please find the subject source term sensitivity study. This evaluation was performed to provide the Staff with information on the impact of variations of source term parameters from the base case values used by GE in the GESSAR II Probabilistic Risk Assessment. This infor-mation will allow the Staff to conclude the evaluation of severe acci-dent issues ior GESSAR II prior to the completion of the ongoing -
Accident Source Term Program.
It is General Electric's intent to addend this report with an additional section that responds to conrnents on the GE pool scrubbing program made by the NRC subcontractor who reviewed GE's pool scrubbing submittals on GESSAR II. The additional section will be provided by the end of May.
We are requesting that the attached information be witheid from public disclosure and considered as proprietary pursuant to Section 2.790 of l
If there are any questions on the information provided herein, please l
contact me or Mr. Kevin Holtzclaw (408) 925-2506.
Very truly yours,
)
virk, Manager BitR Systems Licensing Safety & Licensing Operation JFQ:lw Attachment 8506060749 841203 RA
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F.J. Miraglia (NRC)
D.C. Scaletti~
J. Rosenthal C.O. Thomas
-B. Hardin NRC J.B. Read NRC)
L.S. Gifford GE)
R. Villa (GE) d
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z GENERAL ELECTRIC C0MPANY l
AFFIDAVIT I, Joseph F. Quirk, being duly sworn, depose and state as follows,:
j 1.
I am Manager, BWR Systems Licensing, Nuclear Safety & 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.
2.
The information sought to be withheld is contained in the proprietary i
submittal on the GESSAR II Source Term Sensitivity Study in support i
of the Severe Accident portion of the 238 Nuclear Island General l
Electric Standard Safety Analysis Report (GESSAR II).
i i
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 usa 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 i
properly acquired or duplicated by others."
l 4.
Some examples of categories of information which fit into the e
definition of proprietary information are:
e 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 competi-tive 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 competitive economic advantage, e.g., by optimization or improved marketability; JFQ:re/A05171.
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y
s 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, produc-tion 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 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 s
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 signifi-cant or potentially significant information.
Furnishing the docu-ment on a confidential basis pending completion of General E1'ectric's internal review permits early acquaintance of the staff with the information while protecting General Electric's potential proprie-tary 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 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 JFQ:rm/A05171 b
Operation for technical content, competitive effect and deter-mination of the accuracy of the proprietary designation in accord-ance 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 evaluat'ed 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 mentioned in paragraph 2 provides additional infor-mation in support of the severe accident portion of GESSAR II contained in Section 150.3 of the GESSAR II submittal.
10.
The information 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 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:
It was developed with the expenditure of resources exceeding a.
$500,000.
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 agreements to the substantial financial and competitive disadvantage of General Electric.
c.
Public availability of the information would allow foreign competitors, including competiting BWR suppliers, to obtain information at no cost which General Electric developed at substantial cost.
Use of this information by foreign competitors would have given them a competitive advantage over General Electric by allowing foreign competitors to produce their containments at lower cost than General Electric.
i JFQ: rs/A05171. - -.,.... _.
i STATE OF CALIFORNIA
)
COUNTY OF SANTA CLARA
) ss' 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, Wnd belief.
Executed at San Jose, California, this /
ay of 1
, 198 d
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J 5ptf F. Quirl(
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G eral Electric Company Subscribed and sworn before me this 8 y of N74 198f.
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-r NOTARY PUBLIC, STATE OF CALIFORNIA
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OFFICIAL SEAL RUTHE M KINNAMON NOTARY PUSUC + CAUroRNiA SANTA CLAftt Co!!NTY e
s-a -Hy carm. agires AFR 26.193 175 Certner Avenue San Jose, CA 95125 JFQ:rm/A05171.
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GENERAL ELECTRIC COMPANY PROPRIETARY I.
INTRODUCTION In the course of the NRC review of the General Electric Standard Plant de sign (GESSAR II) relative to postulated severe accidents, the poten-tial for changes of severe accident radionuclide source terms was reco gniz ed.
This potential was especially evident by the significant resources being expended by the NRC, its contractore and the nuclear industry in programs aimed at quantifying source terms and reducing the uncertainties inherent in that quantification.
In order to allow the GESSAR II severe accident review to be completed on a schedule prior to the expected conclusion of the NRC Accident Source Term Program, the staf f requested General Electric to perf orm a number of sensitivity studies.
Those studies were to be perf ormed on various parameters which could have an effect on radionuclide re-leases as a result of a core damage event.
The intent of the study was to consider a range of the parameters which could be expected to include the final values resulting f rom the NRC Source Term Programs.
This would define potential changes in the perception of the GESSAR II plant risk profile given a change in source terms.
The sensitivity studies would also preclude re-analysis of the GESSAR II plant risk profile for small parameter changes (within the parameter study envelopes).
The staff also requested GE to consider the study results in the evaluation of proposed design modifications to assess the effects of higher source terms than those resulting from GE's best estimates in the GESSAR II Probabilistic Risk Assessment.
The parameters to be evaluated by GE were mutually agreed upon in a series of meetings involving personnel from GE, the NRC staf f and their subcontractor, Brookhaven National Laboratory.
It should be noted that the NRC and BNL personnel were especially helpf ul in the problem scoping, particularly in sharing insights f rom their evalu-ations of parameter variations.
The parameters which GE varied in the source term sensitivity study -
included the f ollowing:
core heatup and slump f raction, oxidation modeling, in-vessel vaporization release, primary system retention, lower head melt-through, ex-vessel vaporization release, pool scrubbing decontamination f actors and site demography.
Suppression pool bypass and high presure corium ejection were also considered.
The initial results of GE's evaluations were presented to the staff and their subcontractors on March 20, 1984.
This report documents the evaluations perf ormed and their summary.
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GENERAL ELECTRIC COMPANY PROPRIETARY t'
II.
SOURCE 3125 SENSITIVITY STUDIES In this section of the report, the parameter sensitivity studies are presented.
The issues are defined as follows:
1.
Core Beatup 2.
Oxidation Model Following Node Melt 3.
In-Vessel Fission Product Vaporization l
4.
Primary System Retention 5.
Core Slump Fraction 6.
Melt-Through of Vessel Lower Head i
7.
Ex-Vessel Fission Product Vaporization i
i 8.
Suppression Pool Scrubbing l
9.
Suppression Pool Bypass 10.
Site Effects l
11.
High Pressure Corium Ejection
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C) 0 Iegal Environmental Assistance Foundation (LEAF) 1802 Healey Building 57 Forsyth St.. Atlantac GA 30303 (404/688 3299) l September 11, 1984 I
Director EREEDOM OF INFORMATION Office of Administration ACI REQUEST U.S. Nuclear Regulatory Commission Washington, D.C. 20555
[OZA -# V-MJ FREED 0i.7 0F INFORMATION ACT REQUEST
- c/ Q / 7 To Whom it may concern Pursuant to the Freedom of Information Act, 5 U.S.C. 522, j
as amended, the Legal Environmental Assistance Foundation (LEAF) requests the following documents regarding a 1967 accident at the Radiation Effects Laboratory or " hot cell" at the Georgia Nuclear Laboratory, Dawsonville, Georgia.
Please consider"docu-ments" to include reports, studies, test results, arrespondence, memoranda, meeting notes, meeting min tes, working papers, graphs, charts, diagrams, notes and any other forms of written communication, including internal NRC staff memoranda.
In your response, please identify which documentscorrespond to which requests below.
Pursuant to this request, please provide all documents pre-pared or utilized by, in the possession of, or routed through the NRC related to:
1.
the 1967 accident at the Radiation Effects Laboratory that contaminated the building with cobolt 60 and forced evacuation of the personnel and closure of the facility.
2.
All measures taken to decontaminate the area subsequent to this accident including disposal of contaminated equipment, materials, soil etc.
3 All tests and surveys performed to verify effective decontamination.
Because the Legal Environmental Ass.istance Foundation is a non-profit public interest organization, we believe it is ap-charges, pursuant to 5 U.S.C. 552(a)(4)( A)pying and search propiate in this case for you to waive co "because furnishing the information can be considered as primarily bnnefiting the general public."
sincerely.
m -,
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Vicki A. Breman Attorney, Legal Environmenatal Centrrl Appalachian Office aNOffice 602 Gay St Suite 507 2330 Highland Ave. S.
Knoxville, TN 37902 Birmingham, AL 35205 A Public letevest Law Firus
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