NRC-89-0237, Forwards Proprietary GE Rept KH1-0619-001, Feedwater Nozzle Fracture Mechanics Analysis to Show Compliance W/NUREG-0619 for Fermi Unit 2. Affidavit to Withhold Rept Encl.Rept Withheld (Ref 10CFR2.790)
| ML19332D529 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 11/22/1989 |
| From: | Sylvia B DETROIT EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19293A044 | List: |
| References | |
| CON-NRC-89-0237, CON-NRC-89-237, RTR-NUREG-0619, RTR-NUREG-619 GL-81-11, NUDOCS 8912040089 | |
| Download: ML19332D529 (5) | |
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Novenber 22,.1989 NIC-89-0237 w
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U. S., Nuclear Regulatory Comission Attn:L' Document Control Desk' Washington, D. C.
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References:
- 1) _ Fermi l 2 NIC Docket No. 50-341 NIC License No.' NPF-43 4
- 2) Detroit Edison Letter, IF2-53449 dated June 4,1981,
" Degree of Conformance with NURDG-0619" Subjects..
Ege3 water Nozzlg Crack Growth Analysis Detroit Edison has conpleted a plant unique fracture mechanics
- analysis of the:feedwater nozzle assuming an initial 0.25 inch corner crack.__ This analysis is required by Generic Letter 81-11 as an
- acceptable alternative to making certain modifications reccmended in NUREG-0619, "BWR Feedwater Nozzle and Control Rod Drive Return Line Nozzle' Cracking." Specifically, Detroit Fdison elected to perform l:(
this analysis to allow continued.use of an existing high quality, low flow controller that does not possess all six characteristics of NEDE-21821-A, -(BWR Feedwater Nozzle /Sparger Final Report, February
~1980).-
' As stated in Reference 2, Detroit Fdison had intended to use actual tenperature-fluctuations during the first fuel cycle as input to the analysis. Rowever, ~ the analysis was actually perforned utilizing thermal cycle history data conservatively estimated from the current Fermi 2 low flow feedwater controller system design as well as other plant specific paraneters, since sufficient input data was not obtained.- ~ Additionally, the conditions of low feedwater flow during startup, shutdown and scram cycles during the first fuel cycle are not expected to be representative of future plant operation.
The results show that stress cycling from conservative temperature and
= flow profiles, when added to cycling resulting from startups, shutdowns, scrams, and other transients, results in the growth of an assumed initial 0.25-inch crack to a one inch depth in 8.9 years based on the 1989 ASME Section XI Fatigue Crack Growth curve. Additionally, a best-fit curve developed from actual fatigue growth data from other m
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NBC-89-0237.
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V, nuclear power plants shows that the one inch limit is reached in 13.5 L.b years. Ihis analysis assumes 260 startup and shutdown cycles and 468 i
scram cycles over a 40 year plant life and that the Fermi 2 low flow controller is not operating ten percent of the time. -Both crack i
- growth assunptions confirm that crack growth in the short term is well L y;
. within the allowable value of one. inch.
- Fermi ~ 2 will acquire plant operating data so that actual-low flow controller operating characteristics can be obtained.. This data will
- be used to reevaluate the crack growth analysis described.above. The 4
reanalysis will-be conpleted prior to returning to power operation i
after the third ' refueling outage. Since this analysis assunal conservative ~ interpretation of. flow controller characteristics, it is-expected that with actual tenperature data, the predicted tine to reach one inch depth will be well in excess of the current value.
A copy of General Electric report KH1-0619-001, "Feedwater Nozzle Fracture Mechanics Analysis" to show conpliance with NUBGEG-0619 for Fermi 2, is enclosed for-your use. This information is considered by GE to be proprietary information and an affidavit from GE to that e
effect is also enclosed. Pursuant to 10CFR2.790 it is requested that the information contained in the report be withheld from public disclosure.
Sincerely, (g
Enclosure cc:
A. B. Davis R. W. DeFayette W. G. Rogers J. F. Stang l
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G E N'E R A L ELECTRIC COMPANY AFFIDAVIT
.I Robert Mitchell, being duly sworn, depose and state as follows; s
s 1.
I am Manager, Nuclear Products Licensing, 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_~ its withholding.
2.
- The information sought to be withheld is contained in Report #
KH1-0619-001, Fermi NUREG 0619 Analysis.
'3.
'In designating material as. proprietary, General Electric utilizes the definition of propriethry information and trade secrets set forth in the
-American Law' Institute's information and trade secrets set forth in the American Law Institute's Restatement of Torts, Section 757. This i
definition provides:
i "A trade-secret may consist of any formula, pattern, device or compilation of information which is used in one's business and which 1
gives him an opportunity to obtain an advantage over competitors who i
do not know or use it.... A substantial element of secrecy must exist, i
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 i
business; (2) the extent to which-it is known by employees and others L
involved in his business; (3) the extent of measures taken by him to l
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 expendedbyhimindeveloping-theinformation;(6)theeaseof l
-difficulty with which the information could be properly acquired or p
duplicated by others."
1 L.
4.
Some examples of categories of information which fit into the definition of proprietary information are:
l 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 L.
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 L
which provide a competitive economic advantage, e.g. by optimization or improved marketability; n
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o, c.
Infomation which if used by a competitor, would reduce his
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expenditure of resources 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 infomation, production capacities, budget levels or comercial strategies of General Electric, its customers or suppliers; e.
Information v:hich reveals aspects of past, present or future General Electric customer-funded development plans and programs of potential commercial value to General Electric:
t f.
Infomation which discloses patentable subject matter for which it may l'
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 s
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.
6.
The procedure for approval of external release of such a document typically requires review by the Subsection Manager, Project N nager, Principal' Scientist or other equivalent authority, by the Subsection Manager of the copMzant Marketing function (or delegate) and by the Legal Operation for technical content, competitive effect and determination of the accuracy of the proprietery 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 applica>1e regulatory previsions 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 i
contain information which is proprietary and which is customarily held in confidence by General Electric.
8.
The document mentioned in Paragraph 2 above is classified as proprietary because it contains details concerning current Generai Electric methodology for fracture mechanics assessment of reactor vessel nozzle y
crack growth which were developed at considerable expense to General l
Electric which are not available to other parties.
1 9.
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 the information in confidence.
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- 10. Public disclosure of the infomation sought to be withheld is likely to cause substantial nam to the competitive ?.osition of the General l
Electric Company and deprive or reduce tht availability of profit making opportunities because it would provide other parties, including
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co% etitors, with valuable information regarding current General Electric j
methodology which were obtained at considerable cost to the General Electric Company.
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STATE OF CALIFORNIA
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COUNTY OF SANTA CLARA
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l Robert Mitchell, being duly sworn, deposes and says:
That he has read the foregoing affidavit and the matters stated therein are i
L true and correct to the best of his knowledge, information, and belief.
Executed at San Jose, California, this lo day of A/* V.,19g M%kQ,0 0 Robert Mitchell General' Electric Company Subscribed and sworn before me this /8 day of h M 19 M han.t. d at NOTARY PUBLIC, STATE OF CAllf0RNIA l
OFFN.$LSEAL i
i MARY LKENDALL
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kary Putdio.Wirrnis SANTA oLARA oOONTY My Comm. bp, Mar,36,1993 [
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