ML20203M940
| ML20203M940 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 08/26/1986 |
| From: | Corbin McNeil Public Service Enterprise Group |
| To: | Adensam E Office of Nuclear Reactor Regulation |
| References | |
| NLR-N86111, NUDOCS 8609050193 | |
| Download: ML20203M940 (2) | |
Text
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e Public Service l
Electric and Gas Company Corbin A. McNeill, Jr.
Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609339-4800 Vice Prendent -
3 Nuclear August 26, 1986 3
NLR-N86111 Director of Nuclear Reactor Regulation U.S.
Nuclear Regulatory Commission 7920 Norf olk Avenue Bethesda, MD 20814 Attention:
Ms. Elinor Adensam, Director Project Directorate 3 Division of BWR Licensing
Dear Ms. Adensam:
PROPRIETARY INFORMATION (GENERAL ELECTRIC REPORT)
HOPE CREEK GENERATING STATION j
DOCKET NO. 50-354 Public. Service Electric and Gas Company (PSE&G) has learned and hereby advises that an af fidavit of the type requested by your letter dated August 11, 1986 (E. Adensam, NRC to C.
A.
- McNeill, PSE&G) regarding the General Electric report, " Probability of Missile Generation in General Electric Nuclear Turbines" and it's being withheld from public disclosure pursuant to 10 CFR 2.790, was previously submitted by letter dated February 6,
- 1984, D.
P.
Timo, GE, to T. A.
Ippolito, Chief of Operatir.g Reactors Branch 2.
A copy of that letter and the affidavit is attached for your information.
i In view of the fact that an application ~ (and affidavit) for l
withholding the subject report from public disclosure has already been made under the provisions of 10 CFR 2.790, PSE&G requests that the subject report be withheld from public disclosure based on the information contained in the earlier-filed application.
Sincerely, OYlN 0 Ell I-8609050193 860826 PDR -ADOCK.05000354 P
PDR Attachment t
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.i Director of Nuclear
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Reactor Regulation k
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.C Mr.
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USNRC. Licensing Project Manager Mr.
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Borchardt USNRC Senior Resident Inspector Ij-l' i
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J TUR BINE-G EN ER ATOR CENERAL ELECTRIC COMPANY.ONE RIVER ROAD. SCHENECTADY.NEWYORX 12345 DIVISION Building 41-301 (518) 385-4258 ATTACH M t2.N I rebruary 6, igs4 Mr. T. A.
Ippolito, Chie f Operating Reactors Branch 2 Division of Operating Reactors U.
S. Nuclear Regulatory Commission Washington, D. C. 20555
Subject:
Volume Entitled " PROBABILITY OF MISSILE GENERATION IN GENERAL ELECTRIC NUCLEAR TURBINE 2
Dear Mr. Ippol ito:
By letter dated April 28, 1983, I forwarded to you certain material relating to a meeting between representatives of NRC and GE relating to General Electric's probabilistic analysis of turbine missiles.
In that letter I indicated that a detailed writeup describing General Electric's analysis of the probability of missile generation in General Electric nuclear turbines was currently being prepared and that a copy of that writeup would be sent to the l
NRC for its review upon it completion.
l The work has now been completed and is contained in l
the attached subject volume.
The material contained in the subject volume is of the type that General Electric's Large Steam Turbine-Generator Department maintains in confidence and withholds from public disclosure and the volume is so marked.
It is properly handled and classified as proprietary by General Electric as indicated by the attached affidavit.
We hereby request that this document and the information contained therein be withheld from public disclosure in accordance with the provisions of 10 CFR 2.790.
Very truly yours, Dominic P. Timo l
M an ag er, Structural Development Eng ine e ring, LST-G Department i
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ATTACHMENT 1 GENERAL ELECTRIC COMPANY Af fidavit of DOMINIC P. TIMO in Support of Request to Have Certain Technical Data Withheld f rom Public in Accordance with 10 CFR 2.790 Disclosure DOMINIC P. TIMO, being duly sworn, deposes and states as follows:
I am Manager, Structural Development 1.
Engineering, Large Steam Turbine-Generator Department (LST-G), General Electric Company, and have been delegated the function of reviewir.g the information described in to be withheld and paragraph 2 which is sought have been authorized to apply for its withholding.
2.
The following document is sought to be Attached volume entitled withheld:
" Probability of Missile Generation in General l
Electric Nuclear Turbines".
General Electric's Large Steam 3.
considers as Turbine-Generator Department proprietary any technical, financial or operating data generated by General Electric, f
whether patentable or not, which is used in its own its business, which was developed at expense, which is not available to others, gives to Garer=1 Electric s cc petitive o"
t ich see cc: ;n ad /af.t age c /er cor.pe-itors wr.:
50 0 I4 c ; ; ;P. ; f 2';On i T, f 0 7.T 3; i;T., % 3 ; ;r. ;! T.33 s.< J. J J. 'I f T.a lT.0 3 10, as 0.".4
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Some examples of types of data which General Electric's LST-G Department considers to fall within the category of trade secrets or proprietary information, and which it endeavors to maintain exclusivity to, are:
Turbine design drawings and data a.
unique to General Electric.
b.
Turbine manuf acturing process instructions ceilized in manufacturing, General Electric's turbines and known to be unique to General Electric which are of competitive value to General Electric.
Materials specifications and c.
materials acceptance data prepared by General Electric's LST-G Department specifically for use in its products and which have characteristics which are of competitive value to General Electric, the loss of ' exclusivity of which would adversely af fect General Electric's LST-G Department's competitive position.
d.
Product data relating to measured and calculate-d e ;:neering and materials parare:ers :f parts and :::,5cncn s c f
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W permissible operating conditions.
These data are highly proprietary in that, from them a competitor could calculate LST-G Department's key design criteria and tolerances which are related to the reliability of the Department's products, one of its most important compe titive advantages, the loss of which would be highly detrimental to General Electric.
Information that discloses a process, e.
method or apparatus where prevention of its use by General Electric's competitors without license from i
General Electric constitutes a competitve economic advantage over other companies.
f.
Information consisting of supporting data and analyses, including test 1
data, relative to a process, method or apparatus, the. application of which provides a competitive economic advantage, e.g., by optimization or improved marketability.
g.
Information which reveals cost or price information, production capa:itie, letels er er.Tmer:12; stra:e,ies of General Ele::ric, ::s e fat:T.ers er s.pp' ;*r2.
- .. f : r.. A. ; c.:..'e r. d i s :1::i; n.
I pa;t.:s;.1 s r, :.; 'atts:.
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W it may be desirable to obtain patent protection.
- i. Information which General Electric must treat as proprietary according to agreements with other parties.
In addition to the foregoing material tre'ated 5.
as proprietary by General Electric's LST-G are internal engineering reports Department, (Data Folders) assigned a classification of 2, 3 or 4 in the General Electric data classification system and which contain any of the foregoing types of data in addition to Such other data which are not proprietary.
documents are generated for internal usage by LST-G Department's engineering components, are in a form to be released to third parties, not and require a mixture of proprietary and nonproprietary information in ceder to convey the entire picture of an engineering test procedure or a report on the situation, examination of a customer's apparatus which describes reasons for obsarved and measured performance.
Initially all drawings and internally 6.
generated engineering data within LST-G Cepartment's engineering components are tr::: d as proprietary due to the high i
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- .e r e :f protaci'. :y of some :f : e contents ca:e;; ries of Leir.; witnin one er ::r+ Of the paragrapr.3 4 and 5 a::;+,
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sophisticated enough to take a determination as tr, whether or not proprietary data is contained therein; it is deemed the only way to protect LST-G Department's competitive position is to treat all such documents and data as proprietary until such time as its release to third parties is contemplated.
This is a conservative but effective approach.
In ad'dition to being restricted fecm third parties, access to such internally generated documents and data within LST-G Department is on a need-to-know basis.
7.
Before any document or data relating to the products of General Electric's LST-G Department, e.g., a technical paper for presentation to a professional society, or a trade journal or a product brochure is to be made available to the general public, it is re=riewed by subiection. management in the component in which the action for release is initiated to determine that no data which is proprietary to General Electric is contained therein. It is then subject to review by section level management in the engineering, manufacturing and marketing funct ions, or a person designated by sues section management, f:r the p.rpose Of verif;'ng it s nonpr:prietary s:stus and the appropriateness O f it s re'.e as e.
- .s f.as reviewei y legal ecansel to deter:ir.e :n r. its release will note create legal liari..:y for Geners; E'e :r.:,;. r. a r.;.
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8.
When a document containing proprietary information is considered for a limited release outside General Electric on a restricted or limited distribution basis which normally should not adversely affect the competitive position of General Electric, e.g., to a governmental agency, or to a customer, or his agent, the appropriate functional nanager at unit or subsection level reviews the appropriateness and business risks of such release with his section manager, and if a positive decision for a limited release of the document is made, the limited release is cleared with section level management having responsibility in engineering and marketing to f urther evaluate the business risks involved.
If it.e ousiness benefit to be gained by limited release of the dociament outweighs the business risk of such release by a consensus of concerned management, the requested limited release of such document is authorized under the appropriate restrictive circumstances.
Subsequent similar docur.ents for which release is desired under similar circumstances may there l' e: te released -ith the apprcval of a !
i tj subsecti:n level manager, based upon the j
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init:2'. d2etaion and n: significint change in ta:ts.
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decaments required by venders fo r Fropr:e:2r-,
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conduct of the business are routinely released by the buyers in LST-G Department Purchasing Section, but the Purchasing Section routinely reqaires that all such documents be stamped with restrictive markings.
Documents containing proprietary information which General Electric is obligated to provide to licensees vho have accepted an obligation to maintain the same in confidence are routinely released by the Turbine Licensee Engineer (one individual) with restrictive markinga.
9.
The document referenced in paragraph 2, above, has been evaluated in the light of the criteria and practices set forth above and has been determined as proprietary to LST-G Department of General Electric as containing information, the unrestricted release of which would be detrimental to the competitive position of General Electric.
10.
The document referenced in paragraph 2 provides detailed material regarding the probabilistic analysis of the occurrence of a turbine nissile and of th2 vacious f actors considered in such analysis. This information is proprietary to General Electric.
f DCMI!;:C P. TIMO, being duly sworn, deposes and i
j arts tna: he has read t..e foregoing affidavit, and the matters 2:sted enerein are true and correct to the tes cf I
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his knowledge, information, and belief.
SIGNED at Schenectady, New York, this
[jdI day of c [%u 1984.
/
i hw,,4 ). N. eM Dominic P. Timo General Electric Company STATE OF NEW YORK a
ss.
COUNTY OF SCHENECTADY :
Cworn to and subscribed before me this [
1984.
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