ML20247H431
| ML20247H431 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 09/11/1989 |
| From: | Silady J COMMONWEALTH EDISON CO. |
| To: | Murley T Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19307A357 | List: |
| References | |
| TAC-67046, TAC-67049, NUDOCS 8909190336 | |
| Download: ML20247H431 (6) | |
Text
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.A <2 Address Reply to: Post Office grF76T 72 West Adams Street, Chicago, Illinois e V
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' September 11, 1989 ATTACHMENT CONTAINS -
PROPRIETARY. JNE0RMAT10M Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation
'U.S.1 Nuclear Regulatory Commission Washington DC 20555
Subject:
Quad Cities-Nuclear Power Station Units 1 and 2' Revised Loss of Coolant Analysis Report (TAC Nos. 67046 and 67049)
M C Docket Nos. 50-254 and_E0-265 References (a): October 13, 1988 letter from T.M. Ross to H.E. Bliss.
(b):
February 8,1989 letter from J. A. Silady to T.E. Murley.
Dr.-Murley:
The Reference (a) letter transmitted two SERs concerning the effect of postulated DC power failure on ECCS functionality.
In addition to concurring with the CECO-proposed design modifications to the LPCI swingbus automatic transfer scheme at-the Dresden and Quad Cities Units, Reference (a) required that the Loss of Coolant Accident (LOCA) reports for each station be revised to reflect the impact of a DC power supply failure. These reports were to be revised and submitted prior to the startup from the next scheduled refueling outage of each unit.
The Dresden revisions were provided as part of the Reference (b) transmittal. Attachment A to this letter provides the revised report for the Quad Cities Units.
It should be noted that the ECCS equipment availability for the 125V DC control power case (referred to as " battery failure") reflects:
(a) completion of the LPCI swingbus modifications; and l
(b) no credit for the HPCI system, to facilitate comparison with BWR 3/4 generic analyses.
ATTACHMENT CONTAINS PROPRIETARY iNFORMATION
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8909190336 890911 PDR ADOCK 0500o254 k
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Dr. T.E. Murley September 11, 1989 ATTACHMENT CONTAINS PROPRIETARY INFORMATION The swingbus modification was completed during the Spring, 1988 outage for Quad Cities Unit 2 and is scheduled for completion for Quad Cities Unit 1 prior to restart following the Fall, 1989 refueling outage.
With the swingbus configuration modified, the ECCS availability (and LOCA analysis results) for the battery failure case is the same as for the Diesel Generator /
HPCI failure case in the previous revision of the report.
This revision also reflects some additions to specific fuel bundle information contained in Appendix B of the LOCA report.
These changes are summarized in Attachment B and are consistent with the Quad Cities Unit 1 Core Operating Limits Report for Cycle 11 which is being submitted separately.
Please note that the Attachment A LOCA report is considered proprietary by General Electric Company (GE).
Attachment C contains the GE affidavit and application for withholding per 10 CFR 2.790.
Please contact this office should further information be required.
Very truly yours, acRAay J. A. Silady Nuclear Licensing Administrator 1m Attachments (3) cc:
A.B. Davis - Regional Administrator, Region III T.M. Ross - Project Manager, NRR R.L. Higgins - Senior Resident Inspector, Quad Cities ATTACHMENT CONTAINS PRO?RIETARY INFORM /sTION 0281T:2
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l Arr^cHMENT C
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General Electric Company
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'1, Janice S. Charnley, being duly sworn, depose and state as follows:
1.
I am Manager, Fuel Licensing, General Electric Company, and have been delegated the function of reviewing the information described in paragraph 2 which is sought to be with.
held from public disclosure and have been authorized to apply for its withholding.
2.
The information sought to be withheld is the attached NEDC-31345P, Revision 2, SAFER /GESTR.LOCA Loss-of-coolam Accident Analysis for Quad Cities Nuclear Power Station Units 1 and 2.
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 Resi9tement of Torts, Section 757. This definition provides:
"A tiade secret may consist of any formula, pattern, device or compilation of infor-
- mation 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 ofimproper 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 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 t.o 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-pended by him in developing the information; (6) the ease or difficulty with which the information could be properly acquired or duplicated by others."
4, Som,e 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 ofits 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; Information which, if used by a competitor, would reduce his expenditure of resources c.
or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality or licensing of a similar product; d.
Information which reveals cost or price information, production ca pacities, budget levels or commercial strategies of General Electric, its customers or supp:iers;
o
_ Affidavit s
Information which reveals aspects of past, present or future General Electric cus.
e.
- 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; 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 tysically requires review by the Subsection Manager, Project manager, Principal Scientist or ot ter 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 shove. Disclo-sures outside General Electric are generally limited to regulatory bodies, customers and po-tential customers and their agents, suppliers and licensees, and then only with appropriate protection by applicable regulatory provisions or proprietary agreements.
7.
The document mentioned in paragra 3h 2 above has been evaluated in accordance with the above criteria and procedures and ;ias been found to contain information which is propri-etary and which is customarily held in confidence by General Electric.
i 8.
The document mentioned in paragraph 2 above is classified as proprietary because it contains details concerning current General Electric fuel designs which were developed at considerable expense to General Electric, which are not available to other parties.
9.
The information to the best of my knowledge and belief has consistently been held in confi-dcnce 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 or proprietary agreements which provide for maintenance of the infor-mation in confidence.
10.
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, with valuable mformation regarding current General Electric fuel designs which l
were obtained at considerable cost to the General Electric Company. The manpower, computer and manufacturing resources expended by General Electric to develop the current fuel designs are valued at approximately $8 million. In addition, the development of individual bundle and lattice designs required over 120 man hours and approximate.y $20,000 in computer resources.
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STATE OF CALIFORNIA sm COUNTY.0F SANTA CLARA J enice S. Charnley, being duly sworn, deposes and says:
That he/she has read the foregoing affidavit and the matters stated therein are true and correct to the best of his knowledge,information, an belief.
Executed at San Jose, California, this..... _ day o N 989.
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lee S.CharnIEy eneral Electric Company V
Subscribed and sworn before me this [
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OFFICI LSEAL 14ARY L KENDALL h
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SUMMARY
OF CHANGES
REFERENCE:
Quad Cities Nuclear Power Station Units 1 and 2 SAFER /GESTAR-LOCA Loss of Coolant Accident Analysis, GE Report'NEDC-31345P, Revision 2, July 1989.
The following changes / additions appear in the reference document:
1.
Single failure.of "DG/HPCI" is replaced by " Battery" throughout the document.
No new analyses were performed for this revision since the remaining ECCS equipment is the same with the LPCI
.swingbus modification in place.
2.
Inclusion of MAPLHGR limits for fuel bundle type BP8DRB299; for one assembly reconstituted with 6 fuel rods from a Barrier Lead Test Assembly.(BLTA).
3; Inclusion of Enrichment and Gadolinium Distribution for BP8DRB299 fuel bundle type; reconstituted with 6 fuel rods from BLTA.
4.
Inclusion of Enrichment and Gadolinium Distribution for the BD301H.(EDB Number 1817) fuel bundle type. MAPLHGR limits for this type were previously issued via Erratta and Addendum.
These modifications are indicated by bars in the right margin of the enclosed document.
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