View source for AECM-84-0090, Forwards Results of Analysis Performed Showing Relationship Between ECCS Reliability & Agastat Relay Test Intervals. Analysis Withheld (Ref 10CFR2.790)

{{Adams
| number = ML20081B542
| issue date = 03/07/1984
| title = Forwards Results of Analysis Performed Showing Relationship Between ECCS Reliability & Agastat Relay Test Intervals. Analysis Withheld (Ref 10CFR2.790)
| author name = Dale L
| author affiliation = MISSISSIPPI POWER &amp; LIGHT CO.
| addressee name = Denton H
| addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| docket = 05000416
| license number = 
| contact person = 
| document report number = AECM-84-0090, AECM-84-90, NUDOCS 8403090215
| package number = ML19292D005
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 6
}}

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P MISSISSIPPI POWER & LIGHT COMPANY Helping Build Mississippi
        .                                  P. O. B O X 1640, J AC K S O N, MIS SIS SIP PI 3 9 2 0 5 March 7, 1984 NUCLE AR PRODUCT 40N DEPARTMENT U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation                                                                            ,
Washington, D. C. 20555                                                                                         l l
Attention:        Mr. Harold R. Denton, Director

==Dear Mr. Denton:==

==SUBJECT:==
Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-13 File: 0272/L-334.0 Ref: AECM-84/0024 AECM-84/0034 ECCS Reliability Analysis for Agastat Relay Test Intervals AECM-84/0090 Please find attached the results of the analysis performed for GCNS showing the relationship between emerg(ncy core cooling system (ECCS) relis-bility and Agastat relay test intervals. The common mode failure assumptions are also discussed in this attachment for both the previous reactor protection system (RPS) analysis transmitted in AECM-84/0024 dated January 6, 1984, and for this ECCS analysis. This information is being provided per the request of Mr. Martin Virgilio (ICSB) as referenced in AECM-84/0034 dated January 20, 1984.
The analysis varied the ECCS test intervals to determine the affect of the testing frequency on ECCS unavailability, core damage frequency and public risk. As is discussed in the attached results, a reduction in relay surveil-lance test intervals provides only slight changes in the subject ECCS unavail-ability, core damage frequency, and public risk. MP&L, therefore, concludes that the existing CGNS surveillance test intervals are suf ficient for detection of Agastat relay failures and the maintenance of plant reliability goals.
The attached information is considered proprietary pursuant to the enclosed af fidavit by General Electric Company and should be withheld from public disclosure in accordance with 10 CFR 2.790.
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L 8403090215 840307                                                                                  (
gDRADOCK 05000416 PDR                                                              g f}@s\         C
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Ti: $"I Member Middle South Utilities System

AECM-84/0090 MISSISSIPPI POWER O LICHT COMPANY            Pags 2 Please advise, if you require further information.
Yours truly, W
L. Dale nager of Nuclear Services SAB/JGC:rg Attachment cc:   Mr. J. B. Richard (w/o)
Mr. R. B. McGehee (w/o)
Mr. T.-B. Conner (w/o)
Mr. G. B. Taylor (w/o)
Mr. Richard C. DeYoung. . Director (w/o)
Office of Inspection & Enforcement U. S.' Nuclear Regulatory Commission Washington, D. C. 20555 Mr. J. P. O'Reilly, Regional Administrator (w/o)
U.S. Nuclear Regulatory Commission Region II-101 Marietta St., N.W.,               Suite 2900 Atlanta, Georgia 30303 1
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o     .                  GENERAL ELECTRIC C0MPANY AFFIDAVIT I, Ricardo Artigas, being duly sworn, depose and state as follows:
: 1. I'am Manager, BWR 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 to be withheld consists of text, tables and charts which delineate failure rates, ECCS system reliabilities, core damage and public risk as a function of relay surveillance test interval.
: 3. In designating material as proprietary, General Electric utilizes the definition of proprietary information and trade secrets set forth in the American Law .'nstitute's Restatement Of Torts, Section 757. This definit.on 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 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 informa-ti o: . . . . _ 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 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 expended by him in developing the information; (6) the ease or difficulty with 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 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, includ-ing 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; SB:rm/A01208                                     1/20/84

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: c.          Information which if used by a competitor, would reduce his 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 revealsEcost or price information, production capacities, budget levels or commercial strategies of General
.                                                Electric, its customers or suppliers;
                          .          e.          Information which reveals hspects 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 proprietasy 1
according to agreements with other parties.                                                                                                                                !
1
: 5.        In addition to proprietary treatment given to material meeting the standards enumerated above, General Electric customarily maintains in confidence preliminary and draft material whicn has not been subject to complete proprietary, technical and editorial review.
This practice is based on the fact that draft documents often do not appropriately reflect all aspects of a problem, may contain= tentative conclusions and may contain errors that can be corrected during h                                    normal : review and approval procedures. Also, until the final
: document is completed it may not be possible to make any definitive determin'ation as.to its proprietary nature.                                                            General Electric is not generally willing to release such a document to the general public in such a preliminary form.                                           Such documents are, however, on occasion                                                                        ,
furnished to the NRC staff on a confidential 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.
i
: 6.        Initial approval of proprietary treatment of a document is made by.
the Subsection Manager of the originating component, the man most likely to be acquainted with the value and sensitivity of the information in relationJto industry knowledge.                                                                  Access to such documents within the Company is limited on a "need to know" basis and such documents at all times are clearly identified as proprietary.
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SB: rm/A01208                                                      - .
1/20/84
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    -i          . 7.'        The procedure for approval of external release of such a document is                                                                          >
reviewed by the Section Manager, _ Project Manager, Principal Scientist or other equivalent authority, by the Section Manager of the cognizant Marketing function (or.his 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. Disclosures outside General Electric
                              - are generally limited to regulatory bodies, customers and potential customers and their agents, suppliers and licensees only in accordance
                  ._            with appropriate regulatory provisions or proprietary agreements.
                     - 8.        The materials 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.
                     - 9. ~ Public disclosure of the information is likely to be very harmful to                                                                               i the. competitive position of the General Electric Company and reduce the availability of profit-making opportunities for the following reasons:
I-A .-            Tne indirect cost for developing the capacity to produce the
                                              - information is well in excess of $1,000,000.
B.             The 'information provided in the curves would greatly reduce the
                                               -expenditures by competitors in the attempt to generate a similar program.
C.             The competitors likely to gain from disclosure of this information are Westinghouse, Pickard, Lowe & Garrick (PLC), SAI, NUS, Quadrex, etc.
D.             Competitors in the consulting business lack the capability and experience which GE has developed.                  Revealing this information would cause GE to lose some of its current competitive advantage.
E.             The information sought to be withheld is-not available in public sources.
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STATE OF CALIFORNIA                    )
     .         COUNTY OF SANTA CLARA                  ) ss:
Ricardo Artigas, 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           _ day of                                , 198   .
h-          1;0 Ricard M gas General Electric Company Subscribed and sworn before me this d[ day of MNt1AP(/198 J
OF'          LS A              /                                       M8        M NOTARY PUBLIC, STATE OFgALIFORNIA KAREN S. VOGELHUSER l
i          NOTARY PutuC.CAUTORNIA g 1            SANTA CLARA COUNTY My Commission Empires Dec. 21,1984 bogosoooooooocuosoooooooo SB:rm/A01208                                                1/20/84
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