ML20236B473
| ML20236B473 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/19/1987 |
| From: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Varga S Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19304B621 | List: |
| References | |
| GL-83-28, NUDOCS 8710260203 | |
| Download: ML20236B473 (7) | |
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PHILADELPHIA ELECTRIC COMPANY l
i 2301 MARKET STREET l
l P.O. BOX 8699 PHILADELPHIA A, PA.19101 mei 841 soot
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NUCESAR OPdN ANONS October 19, 1987 Docket Nos. 50-277 50-278 E
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Mr. Steven A.
Varga, Director
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Division of Reactor Projects I/II
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[j U.S. Nuclear Regulatory Commission i.
ATTN:
Document Control Desk 3>
[j Washington, D.C.
20555
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SUBJECT:
Generic Letter 83-28 Peach Bottom Atomic Power Station
REFERENCES:
1)
Letter from S.
L.
Daltroff, PECo, j
to J.
F.
Stolz, NRC, dated May 29, 1985 2)
Letter from J.
F.
Stolz, NRC, to S.
L.
Daltroff, PECo, dated March 14, 1985
Dear Mr. Varga:
In the Reference 2 letter, the NRC stated that if we endorse the "BWR Owners Group Response to Generic Letter 83-28, Item 4.5.3" (NEDC-30844), our plant-specific response to Item 4.5.3 should be provided within 90 days after the NRC completes its. review and issues its safety evaluation on NEDC-30844.
By the Reference 1 letter, we endorsed the BWR Owners Group Response.
The NRC issued its safety evaluation on NEDC-30844 on July 15, 1987.
The attachment to this letter provides our plant-specific response to Item 4.5.3.
General Electric Company report MDE-87-0485-1 dated October 1987 is also submitted herewith to support our response to Item 4.5.3.
This document contains information which General Electric-Company considers confidential and proprietary.
Consequently, it is hereby requested that this report be withheld from public disclosure in accordance with Section 2.790 of the Commission's regulations.
An executed affidavit of Rudolph Villa, Manager, Consulting Services of General Electric Company, in support of this request is attached hereto.
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Mr.' Steven A.
Varga Octobar.19, 1987 Page 2'
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1 If you.have any questions or require additional.information, please do not hesitate to contact us.
Very truly yours,.
Enclosures cc:
Addressee W. T. Russell, Administrator, Region-I, USNRC l
W.
R.
Bulter, Project Directorate I-2, USNRC o
T.
P. Johnson, PB USNRC Resident Site Inspector
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Madan Dev, Reactor Engineer, Region I, USNRC
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PhiladelphiaEiectricCompany Attachment I
Docket Nos. 50-277.
l 50-278 l
l Response to Item 4.5.3 of Generic Letter 83-28' d'
for Peach Bottom Atomic Power. Station Units 2 and 3-
. of a letter from A. C. Thadani (NRC) to T. A. Pickens (BWROG)
)
dated July 15, 1987 is the NRC's Safety Evaluation Report (SER) on General-l Electric Company (GE) Topical Reports NEDC-30844, "BWR Owners Group Response to
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NRC Generic Letter 83-28", and NEOC-30851P, Technical Specification Improvement' s
The SER concluded that the analysis presented in the BWR Owners Group Report, NEDC-30844, is acceptable for resolving item 4.5.3'of Generic Letter 83-28. Table 1 of the SER specifies the.following three requirements for plant specific closeout of item 4.5.3 of Generic Letter 83-28.
The individual licensee must:
I 1.
Confirm the applicability of the generic analyses to its plant.
l 2.
Demonstrate, by use of current drift information provided by the equipment vendor or plant-specific data, that the drift characteristics for instrumentation used in RPS channels in the plant are bounded by the assumption used in NEDC-30851P when the functional test interval is I
extended from monthly to quarterly.
j 3.
Confirm that the differences between the parts of the RPS~that perform i
the trip functions in the plant and those of the base case plant were
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included in the analysis for its plant done using the procedures of f
Appendix K of NE0C-30851P ( and the results presented in Enclosure 1 to letter 0G5-491-12 from L. Rash (GE) to T. Collins (NRC)-dated November-25,1985), or present plant-specific analyses to demonstrate no j
appreciable change in RPS availability or public risk.
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1 These items are addressed below:
l 1.
A plant-specific review of the applicability of NEDC-30844 to Peach l
Bottom Atomic Power Station has been conducted.
The review compared the Peach Bottom RPS configuration and test procedure with the generic RPS evaluated in NE0C-30844.
Differences between the two were identified and the reliability effect of the differences was assessed. The differences and their effect are documented in GE report MDE-87-0485-1, " Technical Specification Improvement Analysis for the Reactor Protection System for Peach Bottom Atomic Power Station, Units 2 and 3", dated October 1987 (enclosed).
The report identifies twelve differences which were dispositioned by-q either an engineering assessment or additional analyses. The report
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Response to Item-4.5.3-Generic Letter 83-28:-
-Docket Nos.-50-277 50-278' Page 2.of 2 concluded that the generic. analysis is applicable to Peach Bottom Units-
.2 and 3.
2.
Since no extension of the functional. test' interval is being sought at this. time, item 2 is not applicable for this submittal.-
3.
PEco has reviewed the enclosed GE plant-specific report forl Peach
'3 Bottom (MDE-87-0485-1).andhasverifiedthatthe.differencesbetween-1 the Peach. Bottom.and generic reactor protection system were. included in j
the plant-specific analysis. Therefore, the generic analysis in NEDC -
q 30844 is applicable to' Peach Bottom.
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H GENERAL ELECTRIC C0MPANY AFFIDAVIT I, Rudolph Villa, being duly sworn, depose and state as follows:
1 1.
I am Manager, Consulting Services, General Electric Company, and I
have been delegated the function of reviewing the information-1 described in paragraph 2 which.is sought to be withheld and have j
been authorized to apply for its withholding.
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2.
The information sought to be withheld is contained in'the report' entitled " Technical Specification Improvement Analysis for the I
Reactor Protection System for. Peach Bottom Atomic Power Station l
Units 2 and 3," MDE-87-0485-1,- October, 1987.
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l 3.
In designating material as proprietary, General Electric utilizes j
the definition of proprietary information and trade secrets set forth in the American Law Institute's Restatement of Torts, Section 757. This definition provides.
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"A trade secret may consist of any formula, pattern, device or l
compilation of information which is used in one's business and i
l which gives him an opportunity to obtain an advantage over l
competitors who (.o not know or use it....
A substantial element of secrecy must exist, so that, except by'the use of
]
improper means, there would be difficulty in acquiring J
information.
Some factors to be considered in determining j
whether given information is one's trade secret are: (1) the j
extent to which the information is.known outside of his l
business; (2) the extent to which it is known by employees and 1
others involved in his business; (3) the extent of measures l
taken by him to guard the secrecy of the information; (4) the value of the information to him and to his competitors; (5) l the amount of effort or money expanded by him in developing i
the information; (6) the ease or difficulty with the which the l
information could be properly acquired or duplicated by others."
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4.
Some examples of categories of information which fit into the definition of proprietary information are:
a.
Information that disclosed a trocess, method or apparatus where prevention of its use by General Electric's competitors without license from General Electric constitutes a j
competitive economic advantage over other companies; b,
Information consisting of supporting data and analyses, including test data, relative to a process, method or apparatus, the application of which provide a competitive-economic advantage, e.g., by optimization or improved marketability;
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c.
Information which if used by a competitor, would reduce his j
expenditure of resources or improve his competitive position j
in the design,' manufacture,-shipment,-installation, assurance of quality or licensing of a similar product; d.
Information which reveals cost or price information, production capacities, budget levels.or commercial strategies-of General Electric, its customers or suppliers;.
e.
Information which reveals aspects of past, present or future General Electric customer-funded development plans'and programs of potential commercial ~value to General Electric:
f.
Information which discloses patentable subject matter for
. l which it may be desirable to obtain patent protection; g.
Information which General Electric must treat as proprietary according to agreements with other parties, i
5.
Initial approval of proprietary treatment of a document is typically made by the Subsection manager of the originating
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component, who is most likely to be acquainted with the value and i
sensitivity of the information in relation to industry knowledge.
Access to such documents within the Gompany is limited on a "need to know" basis and such documents are clearly identified as proprietary.
6.
The procedure for approval of external release of such a. document
-l typically requires review by the Subsection Manager, Project _
~ i manager, Principal Scientist or other equivalent authority, by the Subsection Manager of the cognizant Marketing function (or delegate) and by the Legal Operation for technical content, competitive effect and determination of the accuracy of the proprietary designation in accordance with the standards enumerated above.
Disclosures outside General Electric are-generally limited to regulatory bodies, customers and potential customers and their agents, suppliers and licensees then only with appropriate protection by applicable regulatory provisions o: Proprietary agreements.
7.
The document mentioned in paragraph 2 above has been evaluated in accordance with the above criteria and procedures and has been found to contain information which is proprietary and which is customarily held in confidence by General Electric.
8.
The information to the best of my knowledge and belief has consistently been held in confidence by the General Electric Company, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties have been made pursuant to regulatory provisions of proprietary.
agreements which provide for maintenance of th3 information in confidence.
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l 9.
Public disclosure of the information sought to be withheld is likely to cause substantial harm to the competitive position of the 1
General Electric Company and deprive or reduce the availability of profit making opportunities because it would provide other parties,
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including competitors, with valuable information concerning the
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application of reliability based methodology and the supporting j
data, which were obtained at considerable cost to the General
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Electric Company.
STATE OF CALIFORNIA
) 88 COUNTY OF SANTA CLARA
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Rudolph Villa, being duly sworn, deposes and says:
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That he has read the foregoing affidavit and the matters stated therein i
are true and correct to the best of his knowledge, information, and belief.
j Executed at San Jose, California, this /(/
day of M IX, 198Z.
Rddolph Villa
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General Electric Company Subscribed and sworn before me this /
day of h M /4.198f.
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@ NOTARY PUBLIC = CAlfFO MARY L KENDAtt NOTARY PQBLIC, STATE OF CALIFORNIA L ": w m!GYl(
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