ML20210H321
| ML20210H321 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 07/14/1999 |
| From: | Hughey W ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20137Y855 | List: |
| References | |
| RTR-NUREG-1465 GNRO-99-00057, TAC-M98744, NUDOCS 9908030333 | |
| Download: ML20210H321 (6) | |
Text
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Ents gy rstions, Inc.
Port Gbson, MS 39150 Tel 601437-6470
-July 14,1999 W;K.iughey j
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U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Attention:
Document Control Desk
Subject:
Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-29 Submittal of information Supporting Review of Generic Alternate Source Term Request
Reference:
GGNS Letter GNRO 97/00034, dated May 6,1997,
" Submittal of BWROG Report - Prediction of Onset of Fission Gas Release from Fuel in Generic BWR" (NRC TAC # M98744)
GNRO-99/00057 Gentlemen:
The referenced correspondence transmitted a BWROG report for your review in support of attemate source term implementation. Specifically, the report provided the results of an j
snalysis to determine minimum time to fuel perforation, on a generic basis, for all BWRs.
NUREG 1465 had quantified this parameter for the PWRs and noted that fuel failures for BWRs would occur significantly later. The attached information is being transmitted to support the NRC review of that submittal.
The attached information had been submitted earlier to the NRC contractor (INEEL) performing the technical review of the 1997 submittal. This transmittal is to support the NRC review of the technical evaluation and the preparation of a safety evaluation approving the use of the BWROG report. The BWROG report has also been referenced in our November 3,1998 pilot plant submittal (GNRO-98/00085) requesting approval of a partial scope application of the attemate source term insights of NUREG 1465.
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l 14 o ac7 9909030333 990714 i
w GNRO-99/00057 Page 2 of 2 The attachment contains proprietary information. Per the attached General Electric letter and affidavit, it is requested that it be handled in accordance with 10CFR2.790.
Yours truly,
/FGB attachment:
cc:
Ms. J. L. Dixon-Herrity, GGNS Senior Resident (w/a)
Mr. L. J. Smith (Wise Carter) (w/a)
Mr. N. S. Reynolds (w/a)
Mr. H. L. Thomas (w/o)
Mr. E. W. Merschoff (w/a)
Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Mr. S. P. Sekerak, NRR/DLPM/PD IV-1 (w/2)
U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 13D18 11555 Rockville Pike Rockville, MD 20852-2378 L _
GENuclear Energy Richard E. Kingston Nuclear Fud Product Management fuelhqinct Manager GeneralElectnc Company Castle Hayneiki. P 0, Box 780. M/C A33 Wilnuneran. NC:84010/80 th0 675 6192 DC' 8'292 6192 Iax 910 615 5684 Pager 9103118I84, id kkgrun@yene ge com July 8,1999 cc: R. W. Byrd REK;99-114 M. D. Withrow J. B. Lee W. G. Fiock all w/o attachment Mr. Greg Broadbent Grand Gulf Nuclear Station Bald Hill Road P. O. Box 756 Port Gibson, MS 39150
Subject:
Transmittal ofInformation to Support the Prediction of the Onset of Fission Gas Release from Fuel in Generic BWR
Dear Greg:
l This information is submitted in support of the Staff review of the BWROG gap release timing report submitted under GGNS docket in May 1997. This GE report, entitled " Prediction of the Onset of Fission Gas Release from Fuel in Generic BWR", dated July 1996, applies GE's SAFER and CHASTE computer codes to calculate the minimum time to BWR fuel failure in the event of an unmitigated large-break Loss of Coolant Accident. This transmittal contains the fuel data requested by the NRC's contractor, INEEL, in support of their review of this report Very truly yours, b
t.
wp R. E. Kingston Fuel Proje.t Manager M/C A33, (910)675-6192 rk attachment I
GE Nuclear Energy I
GeneralBactic Corrpeny P. o. Box 700, Hemington, NC 28402 Affidavit j
i 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 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 attachment to the letter, R. E. Kingston (GE) to G. Broadbent (EOl), Transmitta! ofInformation to Support the Prediction of the Onset ofFission Gas Releasefrom Fuelin Generic BWR, July 8, I998.
(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 the Freedom of Infonction 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) 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 discicsure is here sought is all " confidential commercial information," and some portions also qualify under the narrower defmition of" trade secret," within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Qritigal Mass Enerav Project v.
Nuclear Renulatory Commission. 975F2d871 (DC Cir.1992), and Public Citizen Health Research Groun v. FDA,704F2dl280 (DC Cir.1983).
(4) Some examples of cat:gories of information which fit into the definition of proptictary l
information are:
a.
Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by General Electrk'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 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 or price information, production capacities, budget levels, or commercir.1 strategies of General Electric, its customers, or its suppliers;
- d. Information which reveals aspects of past, present, or future General Electric customer-funded development pl:as and programs, of potential commercial value to General Electric; c.
Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.
Page1
he information sought to be withheld is considered to be proprietary for the reasons set
!forth in both paragraphs (4)a. and (4)b., above.
(5) The information sought to be withheld i,s 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 information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in (6) and (7) following. He information 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 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 the informatica in confidence.
(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..nd sensitivity of the information in relation to industry knowledge. Access to such documents within GE is limited on a "need to know" basis.
(7) The procedure for approvai of externa' release of such a document typically requires review by the stafT 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 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, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary j
agreements.
j l
(8) The information identified in paragraph (2) is classified as proprietary because it contains details of GE's fuel designs and methodology assumptions and the corresponding results which GE has applied to actual core designs with GE's fuel.
The development of the methods used in these analyses, along with the testing, development and approval of the supporting methodotogy was achieved at a significant cost, on the order of several million dollars, to GE.
(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GE's competitive position and foreclose or reduce the availability of profit-making opponunities.
He fuel design and methodology information is part of GE's comprehensive BWR safety and uchnology 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 apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.
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 correct analytical methodology is difficult to quantify, but it clearly is substantial.
GE's competitive advantage will be lost if its competitors are able to use the results of the Gij experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.
CMUCWEdavventava &c Page 2
Affl davit 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 i
a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GE of the opportunity to exercise its conhpetitive advantage to seek an adequate return on its large investment in developing these very valuable analytical tools.
State of North Carolina
)
SS-County of New llanover
)
Glen A. Watford, 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.
Executed at Wilmingtor %rth Carolina, this day of [Ultf
,1999 i/
len A. W rd General Electric Company Subscribed and sworn before me this F11 day of dh[w
.19 N 0
6T Notary Public, State of North Carolina My Commission Expires J-8M~EdO/
CNUCMfhdaviref%ve ens Page 3