ML20135E695

Rev 2,Addendum 1 to Safety Review for LaSalle County Station Unit 1 & 2 Safety/Relief Valves Reduction & Setpoint Tolerance Relaxation Analyses

ML20135E695
Person / Time
Site:	LaSalle
Issue date:	09/30/1996
From:	Hoang H GENERAL ELECTRIC CO.
To:
Shared Package
ML19310D739	List: ML20135E655 ML20135E684 ML20135E688 ML20135E695
References
GE-NE-B13-01760, GE-NE-B13-01760-R02, GE-NE-B13-1760, GE-NE-B13-1760-R2, NUDOCS 9612110432
Download: ML20135E695 (16)

Text

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I e GENERAL ELRCTRI GE-NE-B13-01760 Revision 2 Addendum 1 I l Class I September 1996 l

i SAFETY REVIEW FOR LASALLE COUNTY STATION UNIT I AND 2 SAFETY / RELIEF VALVES REDUCTION AND SETPOINT TOLERANCE RELAXATION ANALYSES i

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9612110432 961202 DR ADOCK0500g3

GE-NE-B13-01760, Rev. 2, Addendum I i.

This addendum is issued to incorporate Figures 3-1-1 through 3-1-4 and 6-1-1 through 6-1-4 in GE report GE-NE-B13-01760, Revision 2. Reduced versions of these figures are on pages 3-5 and 6-9 respectively, of the above noted report as " Figure 3-1 MSIV Closure Event,102P/105F, Nominal +3%,8 SRVs OOS" and " Figure 6-1 MSIV Closure Event,100P/87F,6 SRVs OOS".

The figures in this addendum are full scale versions of the same four figures on pages 3-3 and 6-

9. In addition , a fifth figure is also provided in this addendum, ( Figure 6-1-5), pertaining to the l

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1 ATTACHMENT F WITHHOLDING AFFIDAVIT FOR GENERAL ELECTRIC REPORT i

J 1

l l General Electric Company .

AFFIDAVIT I, David J. Robare, being duly sworn, depose and state as follows:

(1) I am Project Manager, Technical Services, General Electric Company ("GE") 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 GE proprietary report GE-NE-B 13-01760, Revision 2, Safety Reviewfor LaSalle County Station Units 1 and 2, '

Safety / Relief Valves Reduction and Setpoint Tolerance Relaxation Analyses, Class III (GE Company Proprietary Information), dated February 1996. The proprietary l

information is delineated by bars marked in the margin adjacent to the specific l 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 l

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). The 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 l

the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Enerav Project v. Nuclear Remdatory Commission.

975F2d871 (DC Cir.1992), and Public Citizen Health R*=aarch Group v. FDA.

704F2d1280 (DC Cir.1983).

l (4) Some examples of categories of information which fit into the definition of proprietaryinformation are:

l a. Information that discloses a process, method, or apparatus, including supporting l 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;

b. Information which, if used by a competitor, would reduce his expenditure of f resources or improve his competitive position in the design, manufacture, l shipment, installation, assurance of quality, or licensing of a similar product; e

Affidsvit Page 1

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c. Information which reveals cost or price information, production capacities, budget levels, or commercial strategies of General Electric, its customers, or its suppliers;

d. Information which reveals aspects of past, present, or future General Electric customer-funded development plans and programs, of potential commercial value to General Electric; e.

Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

The information sought to be withheld is considered to be proprietary for the reasons j 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 I information is of a sort customarily held in confidence by GE, and is in fact so held.

The infonnation 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 l 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 l 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 I sensitivity of the information in relation to industry knowledge. Access to such documents within GE is limited on a "need to know" basis.

I (7) The procedure for approval of external release of such a document typically requires l review by the staff manager, project manager, principal scientist or other equivalent L

' 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, l

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 information identified in paragraph (2), above, is classified as proprietary because it contains detailed results of analytical models, methods and processes, including computer codes, which GE has developed, obtained NRC approval of, and applied to I perform evaluations of the loss-of-coolant accident for the BWR.

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The development and approval of the BWR loss-of-coolant accident analysis computer codes used in this analysis was achieve:1 at a significant cost, on the order of several million dollars, to GE.

The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GE asset.

. (9) Public disclosure of the information sought to be withheld is likely to cause l substantial harm to GE's competitive position and foreclose or reduce t,he availability i of profit-making opponunities. The information is part of GE's comprehensive BWR j safety and technology base, and its commercial value extends beyond the original l

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 , i technology base includes the value derived from providing analyses done with i NRC-approved methods. [1 l

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 I correct analytical methodology is difficult to quantify, but it clearly is substantial.

i ,l1 l GE's competitive advantage will be lost ifits competitors are able to use the results of i l the GE experience to normalize or verify their own process or if they are able to-claim an equivalent understauding by demonstrating that they can arrive at the same ,

or similar conclusions. I 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 opponunity to exercise its competitive advantage to seek an adequate retum on its large investment in l developing these very valuable analytical tools.

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l STATE OF CALIFORNIA )

) ss:

COUNTY OF SANTA CLARA )

David J. Robare, 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.

l Executed at San Jose, California, this N

• day of ATR.)L 1996.

l l

David J. Robare General Electric Company l

l Subscribed and sworn before me this 22 ay of Ml' 1996.

1

. . , 1 l " MARY L KENDALL 5 COMM. # 987864 3 'fg 3 Notory Public - Collfornio >

• j SANTA CLARA COUNTY My Comm. Expres MAR 26.1997 Notary Pu/blic, State of California 1 l I

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