ML20202C430

Forwards Proprietary Info Re Plant Unique Scram Speed Adjustment Factors for Application to VYNPS When Reload Licensing Analyses Are Performed W/Ges Gemini/Odyn Set of Models.Proprietary Info Withheld,Per 10CFR2.790

ML20202C430
Person / Time
Site:	Vermont Yankee
Issue date:	02/05/1998
From:	Watford G GENERAL ELECTRIC CO.
To:	Joshua Wilson NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20070L470	List: ML20202C430
References
GAW-98-006, GAW-98-6, MFN-009-98, MFN-9-98, NUDOCS 9802120240
Download: ML20202C430 (5)

Text

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e GENuclear Encrgy Nuclear feelEnginernng oeneralElectne Cemopany P. o. Bat 184 minsngsms NC 28402 February 5,199 GAW-98-006 MFN-009-98 Document Control Desk US Nuclear Regulatory Conunission Washington, DC 20$$$ -

ATTN: J.11. Wilson

Subject:

Plant Unique Scram Speed Adjustment Factors for Vermont Yankee Nuclear Power Strtion

References:

1) J. S. Charnley (GE) to 11. N. Berkow (NRC), Supplementarylqformation Regarding Amendment i1 to GE Licensing Topical 'teport NEDE-24011-P.

A, January 16,1986.

2) G. C. Lainas (NRC) to J. S. Charnley (GE), Acceptanccfor refcrcncing of 1.icensing Topical Report NEDE 24011-P-A, "GE Generic 1.tcensing Report", Suppicment to Amendment 1), March 22,1986.

This letter trr.nsmits, for your information, plant unique scram speed adjustment factors (SSAF) for application to the Vermont Yankee Nuclear Power Station (VYNPS) when the reload licensing analyses are performed with GE's GEMIN1/0DYN set of models. Rese data are shown in Attaclunent I to this letter.

Reference I describes the procedure for application of the GEMIN!/ODYN set of models to transient analyses. NRC approval of this procedare is given in Reference 2.

Reference 1 included the derivation of SSAFs to be applie6 to GEMINI /0DYN results to d:termine plar(operating limits. Fac: ors for other types of plants (either generic plant groups or plant specific cvaluations) would be derived using the same methodologies as described in Reference 1, and these factors would be sent to the NRC for information. %c NRC agreed with this approach in Reference 2.

The SSAF is used to determine the Cption .' MCPR Operating Limit. VYNPS wili use two Option A type limits: the SS AFs given in the first column are applicable for both the 678 scram speeds (see VYNPS Technical Specification 3.3.C.I.2) and the generic BWR/4 Improved Technical Specification (NUREG 1433) scram speeds; the values given in the second column are applicable to the VYNPS Technical Specification Measured Scram Time (see VYNPS Technical Specification

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3.3.C,1,1). %c Measured Scram Time option is discussed in Section S.S.I.5.1 of Rc'.ision 13 of t.w

, ' US Supplement to GESTAR 11.

If you have further goestions, please phone me at (910) 675-5446 or Jim Rash of my staff at (910) 675-5612.

Please note that some of the infornation contained in the attachment is of the type which GE rr.aintains in confidence and withholds from public disclosure. This information has been handled and classified as proprietary to GE as indicated in the attached affidasit. We hereby request that this information be withheld from public disclosure in accordance with the prosisions of 10CFR2.790.

Sincerely, l

Glen A. ord, Manager Nuclear uelEngineering cc: T. E. Collins (NRC)

L. E. Phillips (NRC) h cMt.KS1tc samsunhw4m s== wee es j

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Q' GE Nuclear Energy GeneralDoctrsc Cwyeny P. o. aos 100. H1tndngton. NC 2040%

Affidavit I, Glen A Watford, being duly sworn, depose and state as follows:

(1) I am Manager, Nuclear Fuel Engineering, General Electric Company ("GE") and have been delegatej the function of reviewing the information described in paragraph (2) which is sought to be withhcid, and have been authorized to apply for its withholding.

(2) ne information sought to be withheld is contained in the Attachment the letter from G. A.

Watford (GE) to United States Nuclear Regulatory Commission, A r Unique Scram Spccd Adjustment Factorsfor l'ermont Yankee Nucicar Power Station, dated rebruary 5,1998.

(3) In making this application for withholding of proprietary information of which it is the owner, GE relics upon the exemption from disclosure set forth in tin Freedom ofInfonnation Act ("FOIA"),

5 USC Sec. 552(b)(4), and the Trade Secrets Act,18 USC Sec.1905, and NRC regu'ations 10 l CFR 9.17(a)(4) and 2.790(a)(4) for " trade secrets and commercial or fmancial 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 infonnation," and some portions also qualify under the rnrrower dermition of" trade secret," within the meanings assigned to those terms for purposes of FGIA Exemption 4 in, respectively, Qiti. cal Mass Energyfmitgl1 Nuclear Reculatorv CommissioL 975F2d871 (DC Cir.1992), and htblic Citizen IJcahh .

Ecitarch Groun v. FDA,704F2dl280 (DC Cir,1983).

(4) Some examples of categories of infonnation which fit into the defmition of proprietary information are:

a. Infonnation that discloses a process, method, or apparatus, including supporting data and analyses, where pievention of its use by General Electric's competitors without liccase from General Electric constitutes a competitive economic advantage over other companies;

b. Infonnation 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;

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

d. Information v Nich reveals aspects of past, present, or future General Electric customer-funded devciopment plans and programs, of potential commer. ~d value to General Electric;

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

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Affid v:! .

. , The information sought to be withheld is considered to be proprietary for the reasons set j forth in both paragraphs (4)a. and (4)b., above. i (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. Its initial designation as proprietary infonnation, and the subsequent steps taken to prevent its unauthoriral disclosure, are as set forth in (6) and (7) following. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GB, no pubFc disclosure has been made, and it is not available in public sources. All disclosures to third parties lacluding any required transmittals to NRC, have been made, er must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence.

(6) Initial approval of proprietary treatment of a document is made by the manager of th; originating component the person most likely to t>c acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to such documents within GE is limited c,n a "nced to know" basis.

(7) The procedure for approval of extemal release of such a document typically requires resiew 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 efTect, 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 licensecs, 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) is classified as proprietary because it contains details of GE's safety analysis methods and the corresponding teruits which GE has applied to Vennert Yankec's actual core design with GE's fuel.

The development of the methods used in these analysis, along with the te: ting, development and approval of the supporting correlation was achieved at a significant cost, on the order of several million dollars, to GC.

(9) Putlic disclosure of the information sought to bc withheld is likely to cause substantial harm to GE's competitive position and foreclose or reduce the availability of profit-making opportunities.

The fuel design 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 app) the appropriate evaluation process. In addition, the technology base includes :he value derived from providing analyses done with NRC-approved methods.

The research, development, mgineering, analytical, and NRC resiew costs comprise a substantial investment of time end money by GE.

The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to qu: ntify, but it clearly is substantial.

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 equivalcut understanding by demonstrating that they can arrive at the same or similar conclusions.

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- ' Affidavit .

, , 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 scck an adequate return on its hrge investment in developing these very valuable analytical tools.

State of North Carolina )

88 County of New llanover )

Glen A. Watford, being duly sworn, deposes and says:

nat he has read the foregoing affidavit and the matters stated therein are true and correct to the best of his knowledge, information, and belief.

N Executed at Wilmington, North Carolina, this f day or Fehvart4 ,i9 %

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pena.We rd General tric Company

iubscribed and sworn before me this -I # ayof d -/elraar.4 .19 Y

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w k. 0,6w Notary ublic, State of North Carolina My Commissinn Expires // f Z##/

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