ML20247G039
| ML20247G039 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/29/1989 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19302D792 | List: |
| References | |
| NUDOCS 8904040107 | |
| Download: ML20247G039 (4) | |
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e PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHIA A. PA.19101 (215)841 450o
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MAR 291989 U. S. Nuclear Regulatory Conmission Docket No. 50-353 Attn: Doctsnent Control Desk Washington, DC 20555
SUBJECT:
Limerick Generating Station, Unit 2 Single Loop Operation Analysis Gentlemen:
Enclosed for your review is an analysis of the operation of Philadelphia Electric Company's Limerick Generating Station, Unit 2 (LGS-2) with a single operable recirculation loop. This report (NEDC-31629P) is based on the LGS Unit 1 report (NEDC-31300P) submitted on November 4, 1988 and concludes that single loop operation as previously analyzed for Unit 1 is equally appilcable to Unit 2.
As stated in the report, Information pro-prletary to General Electric Company is contained therein and it is re-quested,-In accordance with 10CFR2.790(b)(1), that the doctment be with-held from pubile disclosure.
Since the. LGS-2 Operating License has not yet been issued, PEco will continue to work with the Nuclear Regulatory Cenmission Staff to develop appropriate Technical Specifications to reflect the results of this analysis.
PECo will also amend the Final Safety Analysis Report following the approval of this analysis.
If there are any questions, please let me know.
Sincerelv,
/SY/df Attachment
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I HDH/dk/03228903 Copy to:
R. A. Granm, LGS Unit 2 Senior Resident Inspector W. T. Russell, Region I Administrator R. J. Clark, LGS Project Manager j
8904040107 890329 l
PDR ADOCK 05000353 A
,v G E N E.R A U E L E C T R I C C0MPANY p '
I, David J. Robare, being duly sworn, depose and state as follows:
1.
I am Manager, Licensing Services, General Electric Company, and have been delegated the rection 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 GE prop-rietary report NEDC-31629-P, " Single Loop Operation Analysis for Limerick Generating Station Unit 2", September 1988. This report justifies operation of Limerick Unit 2 at reduced power with only a single recirculation pump in operation. It reviews accidents and abnormal operational transients presented in the Limerick FSAR, Sections 6.2, 6.3 and the main text of Chapter 15, with only a single recirculation pump in operation.
"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 competitors who do not know or use it... A substantial element of secrecy must exist, so that, except by the use of improper q
means, there would be difficulty in acquiring information...
.V Some factors to be considered in determining whether given information is one's trade secret are (I) 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 l
in his business; (3) the extep 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 developing the information; (6) the case or difficulty with which the information could be properly acquired or duplicated by others."
I 3.
Some examples of categories of information which fit into the definition of Proprietary Information are:
a.
Information that discloses 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 l
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, marketability; I
c.
.nformation which if used by a competitor, would reduce his expenditures of resources or improve his competitive position
4'
.a
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G E N E R A L 'E L E C T R I C C0MPANY i]
in the design, manufacture, shipment, installation, assurance V
-of quality or licensing of a similar product; d.
Information which reveals cost or price information, produc-tion 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; i
g.
Information which General Electric must treat as proprietary according to agreements with other parties.
4.
Initial approval of proprietary treatment of a document is typi-cally made by the Subsection Manager of the originating component, the person 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.
5.
The procedure for approval of external release of such a document Os 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 dele-gate) and by the Legal Operation for technical content, competi-tively 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 protec-tion by applicable regulatory provisions or proprietary agreements.
6.
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.
7.
The information to the best of my knowledge and belief has consis-tently 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 the information in confidence.
8.
Public disclosure of the information sought to be withheld is likely to cause substantial harm to the competitive position vf the O
General Electric Company and depr ve or reduce the availability of i
profit making opportunities because it would provide other parties, including competitors, with valuable information.
I
G E N E.R.A'L' ELECTRIC COMPANY (Q
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STATE OF CALIFORNIA
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COUNTY OF SANTA CLARA
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David J. Robare, 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 San Jose, California, this 8% day of NOVEM@819 E6 IRb h
DTvid J. P.obars General Electric Company Subscribed and sworn before me this /
day of 19 [.
& d'~$bAA Notary Public, State of California OFFiri A' SEAL
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@ NOTARY PUBLIC
/AARY L KENDALL f
SANTA CLARA COUNTY Y
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