ML20116H495

Forwards Nonproprietary & Proprietary GE Rept Clinton Plant-Unique Encroachments Final Test Rept, Resolving Confirmatory Issue 71.Proprietary Rept Withheld (Ref 10CFR2.790)

ML20116H495
Person / Time
Site:	Clinton
Issue date:	04/29/1985
From:	Spangenberg F ILLINOIS POWER CO.
To:	Schwencer A Office of Nuclear Reactor Regulation
Shared Package
ML19269B467	List: ML20116H526 U-600006, Forwards Nonproprietary & Proprietary GE Rept Clinton Plant-Unique Encroachments Final Test Rept, Resolving Confirmatory Issue 71.Proprietary Rept Withheld (Ref 10CFR2.790)
References
U-600006, NUDOCS 8505020237
Download: ML20116H495 (3)

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L30- 85 (04-29 )-L 1A.120 ILLIN018 POWER COMPANY )

IP CLINTON POWER STATION. P.o. BOX 678. CLINTON. ILLINOIS 61727 April 29, 1985 Docket No. 50-461 i

Director of Nuclear Reactor Regulation

-Attention: Mr. A. Schwencer, Chief Licensing Branch No. 2 Division of Licensing U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Clinton Power Station Unit 1

. Plant - Specific 1/10-Scale Encroachments Tests Confirmatory Issue #71

Dear Mr. Schwencer:

In Illinois Power Company's Letter U-0772 dated December 21, 1984, a program was submitted to address the effects of local encroachments on pool swell impact loads for Clinton Power Station. The purpose of this letter is to transmit the final test report for the plant-specific tests conducted and to endorse the resolution path outlined in Containment Issues Owners Group (CIOG) Letter GWS-0G-142 dated April 9, 1985, to Mr.

H. R. Denton (NRC) as a result of a meeting with members of the NRC staff on March 28, 1985.

The conclusion which can be drawn from the final test report is that the encroachment pool swell loads are less than the loads produced from the Mark III Containment Confirmatory Test Program. During the meeting of_ March 28, 1985, additional confirmatory data was requested concerning a flow momentum comparison betweet encroached and unencroached pool areas.' This information will be provided by April 30, 1985. It is anticipated that this will close the local encroachment issue for Clinton Power Station.

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- L30- 85(04-29)-L ' I 1A.120 Portions of the attached "Clinton Plant Unique Encroachments Final Test Report" contain General Electric proprietary information which is exempt from public disclosure in accordance with 10CFR2.790(b)(1).

Attached is General Electric's affidavit which attests to the proprietary nature of the information.

Please do not hesitate to contact us shouln you have any questions regarding this matter.

Sincerely yours, Q. lo. LOW fAS F. A. Spangenberg Director - Nuclear Licensing and Configuration Nuclear Station Engineering Attachment JLP/ lab cc: B. L. Siegel, NRC Clinton Licensing Project Manager NRC Resident Office Regional Administrator, Region III USNRC Illinois Department of Nuclear Safety

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A GENERAL ELECTRIC C0MPANY AFFIDAVIT I, Ricardo A.tigas, being duly sworn, depose and state as follows:

1. I am Manager, BWR Projects 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 the response to NRC questions related to Humphrey concerns.

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:

"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 fl1 element of secrecy must exist, so that, except by the use of improper means, there would be difficulty in acquiring informa-tion.... 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 informa-tion to him and to his competitors; (5) the amount of effort or s .. money expended by him in developing the information; (6) the ease or difficulty with which the information could be properly acquired cr 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 econom-ic advantage over otner companies;

b. Information consisting of supporting data and analyses, includ-ing test data, relative to a procees, method or apparatus, the application of which provide a r:ompetitive economic advantage, e.g., by optimization or improved marketability; g .

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q O c. Information which if used by a competitor, would reduce his Q 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 information, production 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;

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 practice is based on the fact that draft documents often do not appropriately reflect all aspects of a problem, may contain tenta-tive conclusions and may contain errors that can be corrected during O

D normal review and approval procedures. Also, until the final document is completed 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 to the general public in such a preliminary form. Such documents are, however, on occa-sion 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

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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 Gemral Electric to insure the public documents are technically accurate and correct.

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 relation to 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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S' 7. The procedure for approval of external release of such a document is reviewed by the Section Manager, Project Manager, Principal Scien-tist 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, custom-ers and potential customers and their agents, suppliers and licensees only in accordance with appropriate regulatory provisions or propri-etary 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 proprietary and which is customarily held in confidence by General Electric.

9. 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. The material consists of inforntion which is part of the General Electric technology base which has a value that is clearly substantial and would be lost if the information were disclosed to the public.

i STATE OF CALIFORNIA ) ss:

COUNTY OF SANTA CLARA )

Ricardo Artigas, being duly sworn, deposes and says:

That he har the foregoing affidavit and the matters stated therein are true at rect to the best of his knowledge, information, and belief.

Executed at San Jose, California, this 22nd day of February,1985.

j Ric r M %rty gas General Electric Company Subscribed and sworn before me this 22nd day of February, 1985.

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