ML20236L531
| ML20236L531 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 11/05/1987 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Varga S NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19302D079 | List: |
| References | |
| GL-83-28, NUDOCS 8711100393 | |
| Download: ML20236L531 (7) | |
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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.0, BOX 8699 PHIL ADELPHI A, PA.19101 -
(215)841 4500 JOHN S. KEMPER November 5, 1987
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Docket Nos. 50-352 l
50-353 Mr. Steven A. Varga, Director Division of' Reactor ~ Projects-I/II U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 3
SUBJECT:
Generic Letter 83-28 Limerick Generating Station Units 1 and 2 i
REFERENCES:
1)
Letter from S. L. Daltroffr.PECo, j
'to W. R.: Butler, NRC, dated June 7, 1985 i
2)
Letter from A.-Schwencer, NRC, to S. L. Daltroff, PECo, dated' March 19, 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 l
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.
l General Electric Company report MDE-93-0485-1 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.
Consequentif, 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-Joseph Quick,. Program Manager Domestic ABWR, Consulting Services of General Electric Company, in support of this request is attached hereto.
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The submittal of.this plant specific lresponsefis: delayed due:
j to an. error in tracking ther' commitment.
C.'A. Mengers of'PECo-W discussed'the-need for.the delay withiR. Clark,~USNRC Project.-
Manager. 'The delay:was-found acceptable.
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'l If you have,any questions'or require additional information,
,j please" do not hesitate' to'. contact us.
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- Very: truly.yours c
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Enclosures
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Addressee i
W. T. Russell, Administrator, Region I, USNRC W. R. Butler, Project Directorate.I-2, USNRC.
E. M. Kelly, LGS'USNRC Senior. Resident Site Inspector f
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GENERAL ELECTRIC C0MPANY AFFIDAVIT i
I, Joseph Quirk, being duly sworn, depose and state as follows:
I 1.
I am Senior Program hanager, Domestic ABWR, General Electric Company, 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 itt, withholding.
2.
The information sought to be withheld is ccutained in the report entitled " Technical Specification Improvement Analysis for the Reactor Protection System for Limerick Generating Station Units 1 and 2," MDE-93-0485-1, October, 1987.
q 3.
In designating material as proprietary, General Electric utilizes the definition of proprietary information and trade secrets set forth in the American Law Institute's Restatement of Torts, Section j
757.
This definition provides:
"A trade secret may consist of any formula, pattern, device or compilation of information which is used in one's business and which gives him an opportunity to obtain an advantage over i
competitors who do 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 information...
Some factors to be considered in determining whether given information is one's trade secret are: (1) the extent to which the information is known outside of his j
business; (2) the extent to which it is known by employees and others involved in his business; (3) the extent of measures taken by him to guard the secrecy of the information; (4) the value of the information to him and to his competitors; (5) the amount of effort or money expanded by him in developing the information; (6) the ease or difficulty with the which the 1
information could be properly acquired or duplicated by others."
4.
Some examples of categories of information which fit into the definition of proprietary information are:
a.
Information that disclosed a process, method or apparatus 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 consisting of supporting data and analyses, including test data, relativeEco 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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Information which if.used by a competitor, would reduce his
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expenditure of resources or improve his competitive position
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in the design, manufacture,. shipment, installation, assurance j
of quality or licensing-of a similar product; i
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 which it may be desirable to obtain patent protection; g.
Information which General Electric must treat as. proprietary according to agreements with other parties.
5.
Initial approval of proprietary treatment of a document is typically made by the Subsection manager of the originating component, who is most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge.
Access to such documents within the Company 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 typically requires review by the Subsection Manager, Project 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 effet.t 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 j
protection by applicable regulatory provisions or 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 j
customarily held in confidence by General Electric.
j 8.
The information to the best of my knowledge and belief has consistently been held in confidenco by the General Electric Company, no public disclosure has been made, and it is not l
available in public sources. All disclosures to third parties have been made pursuant to regulatory provisions of proprietary I
agreements which provide for maintenance of the information in confidence.
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Public: disclosure) of the.information sought to be withheld is
.likely to cause substantial harm to the competitive position.of-the General' Electric' Company and-deprive or reduce the availability of profit making opportunities because it would provide other parties,,
including competitors,lwith valuable information.concerning-the application of reliability based methodology.and;the supporting data, which were'obtained at considerable cost.to the General-l Electric Company.
- I STATE OF CALIFORNIA-
) 88 i
COUNTY OF SANTA CLARA
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Joseph Quirk, being duly sworn, deposes and says:
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That he has read the foregoing l affidavit.and the matters stated therein are true' and correct to the best of his knowledge, information, and belief.
ExecutedatSanJose, California,'thisY day of di'/oR F 198k.
li Josep) ' Quirk " '
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Gener4J Electric Company Subscribed and sworn before me this /4 day of d I.
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My comm.' expires JAll 20, 1988
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@. NOTARY PU KAREN A DUNBAR SANTA CLARA COUNTY My comm. expires JAN 29, 1988
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I Philadelphia Electric Company Docket Nos. 50-352 50-353 Response to Item 4.5.3 of Generic Letter 83-28 For Limerick Generating St ition Units 1 and 2 1
l of a letter from A. C. Thadant (NRC) to T. A. Pickens (BWROG) dated July 15, 1987, is the NRC's Safety Evaluation Report (SER) on General Electric Company (GE) Topical Reports NEDC-30844 "BWR Owners Group Response to NRC Generic Letter 83-28", and NEDC-30851P, Technical Specification Improvement Analysis for BWR RPS".
The SER concluded that the analysis presented in tN MR Owners Group Report
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NEDC-30844 is acceptable for resolving Its t.5.3 of Generic Letter l
83-28. Table 1 of the subject SER specifies the following three
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conditions for plant' specific closecut of Item 4.5.3 of Generic Letter j
83-28, i
i The Individual Itcensee must:
1 1.
Confirm the applicability of the generic analyses to its plant.
2.
Demonstrate, by use of current drift infonnation 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 assunption used in NEDC-30851P l
when the functional test interval is extended from monthly to quarterly, i
3.
Confirm that the differences between the parts of the RPS I
that perform the trip functions in the plant and those of the I
1 base case plant were included in the analysis for its plant done using the procedures of Appendix K of NEDC-30851P (and the results presented in Enclosure 1 to letter OG5-491-12 from L. Rash (GE) to T. Collins (NRC) dated Noverrber 25, 1985),
or present plant-specific analyses to demonstrate no appreciable change in RPS availability or pubile risk.
1 These conditions are addressed below:
l l
1.
A plant-specific review of the applicab!11ty of Topical Report NEDC-30844 to Limerick Generating Station has been conducted.
The review, which is docunented in GE Report " Technical Specification Improvement Analysis for the Reactor Protection System for Limerick Generating Station Units 1 and 2", dated l
October 1987 (enclosed), corrpared the Limerick RPS I
configuration and test procedure with the generic RPS I
evaluated in the Topical Report.
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Differences be' tween 'the two were"I'dentit led and thei Tj n
reliability offect of the. differences'was ' assessed.'
i The~ report. Identified eight= differences whleh were
' dispositioned by either an engineering' assessment brc:
additiona11 analyses. 1 The report c concluded that. the, generic analysis Is appilcable t6 Limerick ~ Units 1 and 2.
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Since t o extension of the-functional? test interval;is being.
sought'at'this time,icondIt1onL2;IsLnot applicable'for.th!sL
'I submittal...
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3.
PECo has reviewed the.GE plant-specific report for Limerick" ll and has.verifled that -the differences between the' Limerick' and j
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generic reactor protection ' systems were' included.-In.the' plant-specific analysis. ;Therefore the generic analysts.In NEDC-30844 is appilcable to Limerick ~.
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