ML20245D317

Forwards Proprietary & Nonproprietary Sections of Amend 7 to GE Advanced BWR Ssar.Proprietary Sections 9,11,15,19B & 19C Withheld

ML20245D317
Person / Time
Site:	05000605
Issue date:	06/02/1989
From:	Marriott P GENERAL ELECTRIC CO.
To:	Chris Miller NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
Shared Package
ML19312B278	List: ML20245D317 ML20245D326
References
MFN-036-89, MFN-36-89, NUDOCS 8906270062
Download: ML20245D317 (5)

Text

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'y GE Nuclear Enemy i

General Dectric Company i 175 Curtner Annue. San Jose, CA 95125

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June 2,1989 l

MFN No. 036-89 Docket No. STN 50-605 l

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l Document Control Desk  ;

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 s

i I Attention: Charles L. Miller, Director I i

Standardization and Nca-Power Reactor Project Directorate

Subject:

Submittal of Amendment 7 to GE's ABWR SSAR l

Dear Mr. Miller:

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l Enclosed are thirty-four copies of selected sections of Chapter 1, Introduction and General Description of Plant, Chapter 2, Site Characteristics, Chapter 3, Design of Structures, Components, Equipment, and Systems, Chapter 4, Reactor, Chapter 5, Reactor Coolant System and Connected Systems, Chapter 6, Engineered Safety Features, Chapter 7, Instrumentation and Control Systems, Chapter 9, Auxiliary Systems, Chapter 11, Radioactive 1Vaste Afanagement, Chapter 12, Radiation Protection, Chapter 13, Conduct of Operations, Chapter 15, Accident Analysis, Chapter 17, Quality Assurance, Chapter 19, Response to Severe Accident Policy Steement, Chapter 20, Question and {

Response Guide, of the Standard Safety Analysis Report (SSAR) for the Advanced Boiling Water Reactor (ABWR).

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This submittal amends Chapter 1 to include Turbine Building Arrangement drawings, Chapter 9 j

. to include Turbine Building Cooling Water System, Chapter 10 to include deferred portions of l Sections 10.1 and 10.4, Chapter 19 to include Sections 19B and 19C, and Chapter 20 which j includes responses to Request for Additional Information dated Feb. 3,1989. This amendment l also includes further modifications to complete the scope of expansion.  ;

1 in addition there are other changes to various sections of the SSAR which are identified, along 1 with the above changes, on the page change instruction sheet.

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.- t l Document Control Desk Docket No. STN 50-605 U.S. Nuclear Regulatory Commission MFN No. 036-89 ,

June 2,1989 j Page 2 1 1

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Please note that all or parts of the following sections contain information that is designated as General Electric Company proprietary information: 9,11,15,19B, and 19C. This information is 1 being submitted separately.

l I Sincerely, j I  %

P.W. Marriott, Manager i Licensing and Consulting Services cc: D. R. Wilkins (GE) 1 T. E. Murley (NRC)

D. M. Crutchfield (NRC) l D.J. McGoff (DOE) l F. J. Miraglia, Jr. (NR.C)  :

D. C. Scaletti (NRC)

K. E. Stahlkopf (EPRI)

F. A. Ross (DOE) ,

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General Electric Company i 1

AFFIDAVIT {

I, .lobert C. Mitchell, being duly sworn, depose and state as follows:

1. I am Manager, Products Licensing, General Electric Company, and have been delegated the function of reviewing the information described in paragraph 2 which is sought to be with- i held and have been authorized to apply for its withholding.  !

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2. The information sought to be withheld is the attached selected portions of the ABWR Stan-dard Safety Analysis Report (SSAR) Chapter 9, Auxiliary Systems, Chapter 11, Radioactive j Waste Management, Chapter 15, Accident Analysis, and Chapter 19, Response to Severe f Accident Policy Statement.

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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 757. This definition provides:

1 "A trade secret may consist of any formuit pattern, device or compilation of infor- l mation whi:h is used in one's business and which gives him an opportunity to I obtain an advantage over 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 1 determining whether given information is one's trade secret are: (1) the extent to which the information is known outside of his business; (2) the extent to which it is known by employees and others involved in his business; (3) the extent of mea-sures taken by him to guard the secrecy of the information; (4) the value of the in-formation to him and to his competitors;(5) the amount of effort or money ex-  ;

panded by him in developing the information; (6) the ease or difficulty with the '

which the information could be properly acquired or duplicated by others."

4. Some examples of categories of information which fit into the definition of proprietary infor-mation 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, relative to a process, method or apparatus, the application of which provide a competitive economic advantage, e.g., by optimization or improved marketability;

c. Information which if used by a competitor, would reduce his expenditure of resources or I improve his competitive position in the design, manufacture, shipment, installation, as-surance 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; l

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e. Information which reveals aspects of past, present or future General Electric cus .

tomer-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; I

g. Information which General Electric must treat as proprietary according to agreements ,

with other parties.  !

5. In addition to proprietary treatment given to material meeting the standards enumerated above, General Electric customarily maintains in confidence preliminary and draft material which has not been subject to complete proprietary, technical and editorial review. This prac-tice is based on the fact that draft documents often do not app a problem, may contain tentative conclusions and may errors thatcontam,ropriately can be correc:ed reflect during normal review and approval procedures. Also, until the final document is complete it may not be possible to make any definitive determination as to its proprietary nature.

General Electric is not generally willing to release such a document in such a preliminary form. Such documents are, however, on occasion furnished to the NRC staff on a confiden-tial basis because it is General Electric's belief that it is in the public interest for the staff to be promptly furnished with significant or potentially significant information. Furnishing the document on a confidential basis pending completion of General Electric's internal review permits early acquaintance of the staff with the information while protecting General Electric's potential proprietary position and permitting General Electric to insure the public documents are technically accurate and correct.

6. 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.

7. 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 author-ity, 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. Disclo-sures outside General Electric are generally limited to regulatory bodies, customers and po-tential customers and their agents, suppliers and licensees then only with appropriate protec-tion by applicable regulatory provisions or proprietary agreements.

8. 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 propri-etary and which is customarily held in confidence by General Electric.

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9. The information to the best of my knowledge and belief has consistently been held in confi-dence 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 i regulatory provisions of proprietary agreements which provide for maintenance of the infor-mation in confidence.

Affidavit Page 2

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10. The pages for Chapters 9,11, and 15 are corrections of earlier proprietay submittal. Sections -l 19B and 19C are being submitted as proprietary at this time in order to allow sufficient time to properly identify the proprietary information. We plan to remove selected matenal from the proprietary information category as we complete our review.pr 1

STATE OF CALIFORNIA ) .

l COUNTY OF SANTA CLARA ) ss.

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Robert C. Mitchell, being duly sworn, deposes and says: .)

1 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 San Jose, California, this N day of TO A)6 1989.

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&RobertC.%~1reL C. Mitchell 0oN General Electric Company i 1

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Subscribed and sworn before me thisJ day of 1989.

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Notary Public- California Santa Clara County i OFFICIAL SEAL  !

I MARY L KENDAlt..

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i j ;I SANTA Ct. ARA COUNTY l '. My Comm. Exp. Mar. 26,1993 Affidavit Page 3