ML20154B334

Requests That Encl Info on GE Rept NEDC-32511P Be Reviewed & Revised Proprietary Version of Subj Rept Be Submitted.Some Info in Rept Should Not Be Exempt from Public Disclosure & Should Be Released & Placed in PDR

ML20154B334
Person / Time
Site:	Hope Creek
Issue date:	09/29/1998
From:	Richard Ennis NRC (Affiliation Not Assigned)
To:	Keiser H Public Service Enterprise Group
References
TAC-MA1674, NUDOCS 9810050170
Download: ML20154B334 (6)

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UNITED STATES NUCLEAR REGULATORY COMMISSION W.- -Q

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WASHINGTON, D.C. 20066 4001 September 29, 1998 Mr. Harold W. Keiser Chief Nuclear Officer & President Nuclear Business Unit Public Service Electric & Gas Company Post Office Box 236 Hancocks Bridge, NJ 08038

SUBJECT:

REQUEST FOR WITHHOLDING INFORMATION FROM PUBLIC DISCLOSURE, HOPE CREEK GENERATING STATION - SAFETY / RELIEF VALVE TOLERANCE ANALYSIS (TAC NO. MA1674)

Dear Mr. Keiser:

By Public Service Electric and Gas Company's letter (LR-N97117) dated April 28,1998, and General Electric Company's (GE) affidavit executed by George B. Stramback, dated April 22, 1998, (Attachment 4 to the letter), you submitted GE Report NEDC-32511P, " Safety Review for Hope Creek Generating Station Safety / Relief Valve Tolerance Analyses," dated April 1996, (Attachment 5 to the letter), and requested that it be withheld from public disclosure pursuant to 10 CFR 2.790.

GE stated that the sutandled information should be considered exempt from mandatory public disclosure for the following reasons:

(a)

Information that discloses a process, method, or apparatus, including supporting data and analyses, 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 which, if used by a competitor, would reduce (the) expenditure of resources or improve [the, ompetitive position in the design, manufacture, shipment, installation, assurance of qs JIity, or licensing of a similar product.

(c)

The information identified in [ Attachment 5 to letter LR-N97117] 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 perform evaluations of loss-of-coolant accident for the BWR.

.)

The developmen', and approval of the BWR loss-of-coolant accident analysis computer codes used in this analysis was achieved at significant cost, on the order of several million dollars, to GE.

The development of the evaluation process along with the interpretation and application of f

the analytical results is derived from the extensive experience database that constitutes a major GE asset.

9810050170 980929 PDR ADOCK 05000354 P

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i H. Keiser We have reviewed your submittal and the material in accordance with the requirements of i

10 CFR 2.790 and, on the basis of GE's statements, have determined that some of the information in GE report NEDC-32511P contains proprietary commercial information. However, the staff has concluded that some of the information in repwt NEDC-32511P that is denoted as proprietary (i.e., marked with vertical bars in the right hand margin of affected pages) should not be exempt from public disclosure and should be released and placed in the Public Document Room (PDR). The specific information that we believe should not be exempt from mandatory public disclosure is listed in the enclosure to this letter along with the reasons for our conclusions.

Therefore, we request that you review the enclosed information and submit a revised proprietary version of GE report NEDC-32511P. In addition, a nonproprietary version of the report should also be submitted to allow for proper docketing pursuant 610 CFR 2.790(b)(1)(i). Upon receipt of this information, we will proceed with our determination as to whether the GE report should be withheld from public disclosure.

We request that the information requested above be provided within 30 days of receipt of thic letter. The 30 day response timeframe was discussed with Mr. James Priest of your staff on September 9,1998, if circumstances result in the need to revise your response date, or if you have any questions, please contact m2 at (301) 415-1420.

1 Sincerely, l

original signed by:

Richard B. Ennis, Project Manager Project Directorate 1-2 Division of Reactor Projects - I!il Office of Nuclear Reactor Regulation Docket No. 50-354

Enclosure:

Proprietary Finding on GE Report NEDC-32511P cc: See next page DISTRIBUTION Docket File REnnis GThomas PUBLIC TClark GHammer PDI-2 Reading TCollins JZwolinski MSiemien RCapra JLinville, RGN-l

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OFFICE PDI-2/PM PDI-3/LA SRXB/BC OGCfn U PDI-2/D NAME REnnis:mw TClarkM TCollins MSiemien RCapra "

DATE 9/ lb /98 f / /(,/98 9 / /X /98 i/N/98

'/4 /98 OFFICIAL RECORD COPY DOCUMENT NAME: HCMA1674. GEN

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H. Keiser.

We have reviewed your submittal and the material in accordance with the requirements of 10 CFR 2.790 and, on the basis of GE's statements, have determined that some of the information in GE report NEDC-32511P contains proprietary commercial information. However, the staff has concluded that some of the information in report NEDC-32511P that is denoted as l

proprietary (i.e., marked with vertical bars in the right hand margin of affected pages) should not I

be exempt from public disclosure and should be released and placed in the Public Document Room (PDR). The specific information that we believe should not be exempt from mandatory public disclosure is listed in the enclosure to this letter along with the reasons for our conclusions.

Therefore, we request that you review the enclosed information and submit a revised proprietary version of GE report NEDC-32511P. In addition, a nonproprietary version of the report should also be submitted to allow for proper docketing pursuant to 10 CFR 2.790(b)(1)(i). Upon receipt of this information, we will proceed with our determination as to whether the GE report should be withheld from public disclosure.

We request that the information requested above be provided within 30 days of receipt of this i

l letter. The 30 day response timaframe was discussed with Mr. James Priest of your staff on September 9,1998. If circumstances result in the need to revise your response date, or ;f you have any questions, please contact me at (301) 415-1420.

Sincerely, original signed by:

Richard B. Ennis, Project Manager Project Directorate 1-2 Division of Reactor Projects - t/11 Office of Nuclear Reactor Regulation Docket No. 50-354 i

Enclosure:

Proprietary Finding on GE Report NEDC-32511P cc: See next page DISTRIBUTION Docket File REnnis GThomas PUBLIC TClark GHammer PDl-2 Reading TCollins JZwolinski MSiemien RCapra JLinville, RGN l OFFICE PDI-2/PM PDI-3/LA SRXB/BC OGC D

PDI-2/D NAME REnnis:mw TClark M TCollins MSiemien RCapra "

DATE 9 / IG /98 T / /(-/98 G / /X /98 i/N/98 i4 /98

/

OFFICIAL RECORD COPY l

DOCUMENT NAME: HCMA1674. GEN 1

l

r H. Keiser,

We have reviewed your submittal and the material in accordance with the requirements of 10 CFR 2.790 and, on the basis of GE's statements, have determined that some of the information in GE report NEDC-32511P contains proprietary commercial information. However, the staff has concluded that some of the information in report NEDC-32511P that is denoted as proprietary (i.e., marked with vertical bars in the right hand margin of affected pages) should not be exempt from public disclosure and should be released and placed in the Public Document Room (POR). The specific information that we believe should not be exempt from mandatory public disclosure is listed in the enclosure to this letter along with the reasons for our conclusions.

Therefore, we request that you review the enclosed information and submit a revised proprietary version of GE report NEDC-32511P. In addition, a nonproprietary version of the report should also be submitted to allow for proper docketing pursuant to 10 CFR 2.790(b)(1)(i). Upon receipt of this information, we will proceed with our determination as to whether the GE report should be withheld from public disclosure.

We request that the information requested above be provided within 30 days of receipt of this letter. The 30 day response timeframe was discussed with Mr. James Priest of your staff on September 9,1998. If circumstances result in the need to revise your response date, or if you have any questions, please contact me at (301) 415-1420.

Sincerely, Richard B. Ennis, Project Manager Project Directorate 1-2 Division of Reactor Projects 1/11 Office of Nuclear Reactor Regulation Docket No. 50-354

Enclosure:

Proprietary Finding on GE Report NEDC-32511P cc: See next page

Mr. Harold W. Keiser Hope Creek Generating Station Public Service Electric & Gas Company cc-Jeffrie J. Keenan, Esquire Manager-Joint Generation Nuclear Business Unit-N21 Atlantic Energy P.O. Box 236 6801 Black Horse Pike Hancocks Bridge, NJ 08038 Egg HarborTwp., NJ 08234-4130 Hope Creek Resident inspector Richard Hartung U.S. Nuclear Regulatory Commission Electric Service Evaluation Drawer 050g Board of Regulatory Commissioners Hancocks Bridge, NJ 08038 2 Gateway Center, Tenth Floor Newark, NJ 07102 Mr. Louis Storz Sr. Vice President - Nuclear Operations Lower Alloways Creek Township Nuclear Department clo Mary O. Henderson, Clerk P.O. Box 236 Municipal Building, P.O. Box 157 Hancocks Bridge, NJ 08038 Hancocks Bridge, NJ 08038 General Manager - Hope Creek Operations Mr. Elbert Simpson Hope Creek Generating Station Senior Vice President-P.O. Box 236 Nuclear Engineering Hancocks Bridge, NJ 08038 Nuclear Department P.O. Box 236 Director-Licensing Regulation & Fuels Hancocks Bridge, NJ 08038 Nuclear Business Unit - N21 P.O. Box 236 Hancocks Bridge, NJ 08038 Regional Administrator, Region i U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Dr. Jill Lipoti, Asst. Director Radiation Protection Programs NJ Department of Environmental Protection and Energy CN 415 Trenton, NJ 08625-0415 L

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PROPRIETARY FINDING ON GE REPORT NEDC-32511P 1)

General comment Since vertical lines in the right-hand margins were used by GE to denote proprietary information, and since a nonproprietary version of the report was not submitted, it is sometimes difficult to identify the exact portions of the text affected. It would have been better to use brackets to identify the specific text that is considered to be proprietary.

2)

Page 3-1, Bullets 1 through 5 (assumptions and initial conditions)

It is not clear why some of these assumptions and initial conditions would be considered proprietary. The information in bullets 1,2,4, and 5 can be found on pages 3 2 and 3-3 and these pages do not have any information marked as proprietary. Either remove the

. marking for bullets 1,2,4, and 5 or provide a rationale for the staff to evaluate.

3)

Page 4-1,1st paragraph it is not clear why the first two sentences of this paragraph are proprietary. This information does not appear to contain detailed results of analytical models, methods or processes. Either remove the marking or provide a rationale for the staff to evaluate.

4)

Pages 5-1,5-2, and 5-3, Sections 5.2 and 5.3 it is not clear why all of the text within the marked portions of Sections 5.2 and 5.3 is proprietary. The source of some of the information is from the Hope Creek Updated Final Safety Analysis Report (UFSAR) as referenced within these sections. Either remove the markings for the affected text or provide a rationale for the staff to evaluate.

5)

Pages 6-2,6-3,6-4,6-5,6-8,6-9,6-10,6-11, and 6-13 it is not clear why a large portion of the information in Section 6 is maied as proprietary.

Much of the information does not appear to contain detailed results of analytical models, methods, or processes. For example, pages 6-4,6-9, and 6-10 provide lists of valve numbers which should not be considered as proprietary information, in addition, this section lists design basis information which can found in the Hope Creek UFSAR (e.g.,

HPCI system flow rate and HPCI design basis injection time as shown on pages 6-2 and 6-3). Either remove the markings for the affected text or provide a rationale for the staff to

)

evaluate.

1 6)

Page 8-1, Bullets 1 through 6 (assumptions)

It is not clear why some of these assumptions would be considered proprietary. The information in bullets 1 and 4 can be found on page 6-1 (second paragraph) and page 8-3 which are not marked as proprietary. The information in bullets 2 and 5 can be found in the Hope Creek Technical Specifications. Either remove the marking for bullets 1,2,4, and 5 or provide a rationale for the staff to evaluate.

ENCLOSURE

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