ML18085A206

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Forwards Environ Qualification Review Repts for Facility Which Supersede All Previous Info Submitted in Response to IE Bulletin 79-01B, Environ Qualification of Class IE Equipment. Proprietary Info Withheld (Ref 10CFR2.790)
ML18085A206
Person / Time
Site: Salem  PSEG icon.png
Issue date: 10/31/1980
From: Schneider F
Public Service Enterprise Group
To: Grier B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
IEB-79-01B, IEB-79-1B, NUDOCS 8011120316
Download: ML18085A206 (12)
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{{#Wiki_filter:Frederick W. Schneider Vice President Public Service Electric and Gas Company 80 Park Place Newark, N.J. 07101 201/430-7373 Production October 31, 1980 Mr. Boyce H. Grier, Director U.S. Nuclear Regulatory Commission Off ice of Inspection and Enforcement Region 1 1:::i ~._,..,

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Dear Mr. Grier:

NRC IE BULLETIN NO. 79-0lB ENVIRONMENTAL QUALIFICATION OF CLASS IE EQUIPMENT SALEM GENERATING STATION UNIT NO. 1 DOCKET NO. 50-272 n,.,, (J) --t 0 (>I z The Environmental Qualification Review Reports for Salem Unit 1 are enclosed and supersede all previous information submitted for, Bulletin 79-0lB on March 7, March 21, April 14, and June 4, 1980. Please note that proprietary and non-proprietary versions have been prepared because information proprietary to Westinghouse Electric Corporation is included in the reports. Similar reports were submitted on May 5, 1980 for Unit 2 as part of the full power license requirements and contained proprietary information supported by an affidavit signed by Westinghouse. A copy of the Westinghouse affidavit is attached. We respectfully request that the information proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.790. Correspondence about the proprietary aspects of this request to withhold information or the supporting Westinghouse affidavit should reference CAW-80-15, and should be addressed to R. A. Wiesemann, Manager, Regulatory and Legislative Affairs, Westinghouse Electric Corporation, P.O. Box 355, Pittsburgh, Pennsylvania 15230. The enclosed reports include justifications for the continued operation of equipment with insufficient qualification data and specify actions that will be taken to complete qualification documentation.

r Boyce H. Grier, Dir. 2 - 10-31-80 This submittal is being made to fulfill the requirement of the Revised Order for Modification of License, Docket No. 50-272, effective date September 19, 1980, signed by Darrell G. Eisenhut, Director, Division of Licensing. We recognize that this sub-mittal as it relates to Unit 2 has undergone extensive discus-sions for the Salem Unit No. 2 (Docket No. 50-311) full power license requirements. It should be noted that as a result of the meeting held on October 30, 1980 between Messrs R. L. Tedesco, V. s. Noonan and other NRC staff and PSE&G representatives con-cerning Unit 2 equipment qualification, revision to this Unit 1 submittal may be requirede If you have any questions concerning this matter, please do not hesitate to contact. us. Sincerely, CC U.S. Nuclear Regulatory Commission Of £ice of Inspection and Enforcement Division of Reactor Operations Inspection Washington, DC 20555 tw/o attachment) Mr. D. G. Eisenhut, Director Division of Licensing U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. s. A. Varga, Chief Operating Reactors Branch 1 Division of Licensing U.S. Nuclear Regulatory Commission Washington, DC 20555 Cw/o attachment) Mr. w. J. Ross, Project Manager Operating Reactors Branch 1 Division of Licensing U.S. Nuclear Regulatory Commission Washington, DC 20555 tw/o attachment) Mr. A. E. Finkel, Reactor Inspection U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region 1 631 Park Avenue King of Prussia, PA 19406

r-I STATE OF NEW JERSEY) ) SS: COUNTY OF ESSEX ) FREDERICK w. SCHNEIDE~, being duly sworn according to law deposes and says: I am a Vice President of Public Service Electric and Gas Company, and as such, I signed the letter dated October 31, 1980, to Mr. Boyce H. Grier, Director, NRC Office of In-spection and Enforcement, Region 1, in response to NRC Bulletin No. 79-0lB "Environmental Qualification.of Class IE Equipment." The matters set forth in said response letter are true to the best of my knowledge, information, and belief. Subscribed and sworn to before me this.31 day offf(/-t,__,A..tJv, 1980 .~? Notary Public of New Jersey (/ My commission expires on ({c_f. I /{jE3

\\'Jr.!-. tin crhn11<: P. £1cc1ric corporJ ti on Pn\\'Jrr Svo:::li*m<: ~.... CompJny Mr. John F. Stolz,.Chief Light Water Reactors Project Division tif Project Management. Office of i:ucl~ar Reactor Regulation U. S. r~uclear Regult!'.ory Car.mission - 7920 Norfolk Avenue* Bethesda, l*:a ryl an_d ~'.0014 "APPLTCATIO~ FOR WITHHOLDl~G PROPRI~TARY PWR Systems 011*i5icn Dox35~ Pill$!.\\Jfi:hPL"n'lSj'll:?.113 15230 Augu5t 27, 1976 AH-76-39

SUBJECT:

Westinghouse Equip~ent Qualification Programs and Thermal Environmental Qualifi~ation C~rve REF: Westinghouse Letter N6. NS-CE-llBJ. Eicheldinger to Stolz, dated A~gust 27, 1976 This application for withholding is sub~itted b) Westinghouse Electric Corpoi~ation ( 11 \\-!2stir.qhouse") pui~suant to the previsions of paragrt!ph (b)(l) of Section 2.790 of the Co~~ission 1 s regLlations._ Withholdir.g from public di sclosu 'e is requested with respect to the subject info1'- mation which is furt1er identified in the affid2vit accompanying this application. The undersigned has reviewed the information soLght to be withheld and is authorized to apply for its withholding on behalf of Westinghouse, WRD, notification of v:hich \\*1as sent to the Secretary of the Con*J11ission on April 19, 1976. . The affidavit acco~panying this application sets forth the basis on .which the infonnJtion muy be \\'lithheld fror.i public disclosLff.c by the Co1m1ission ~nd addresses with specificity the considerations listed in ~ paragraph (b)(4) of Section 2.790 of the Cor.;mission 1 s regulations.

  • Mr. 'John F. Stal z e Au9~1s~27, 197G AU-7f9..
  • /\\ccordingly, it is respectfully requested that the subject informJtion which is proprietary to !*!estinghousc and \\*1hich is further identified iri the affidavit be withheld from public disclosure.i~ accordance with 10 CFR Section 2.790 of the Co~1ission 1

s regulations. Corresponde,cc with resplct to this application for withholding or the accompanying affidavit should be addressed to the undersigned. /kek Enclosure cc: J. W. Maynard, Esq. Very truly yours, .../) 0 'I Ji,,,,,,,~..,,~ 1t{.J-{).,,~-{l V -<-u7t.r~*1.-Ut. i-v."LJ Robert A. w~ese~ann, Manager Licensing Programs -Office of the Executive Leg~l Director, NRC I

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    • '*SS COUNTY OF ALLEG!IEl"lY:

Before me, the undersigned authority, personally appeared Robert A. ~liesemarn, \\*tho, being by me duly sworn a*ccording to law, de-poses and says that he is authorized to execute this Affidavit on behalf of Hestinghouse Electric Corporation (~'~!estinohouse 11 ) and that the aver-ments of fact set forth in this Affidavit are true and correct to the best of his kno~*iledge, informatio.n, and belief: Sworn to and subscribed ,.. /} before;ffie ~his~(cv day of~1.e~t;r;.dt, 1976. I .:(7,. /j(/ i/.t/(!~ V '/f;_t/ue Notary Public

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J (1) I am ManJgcr, Licensing P~ograms, in the Pressu~fzed Water Reactor Syst~ms DiviSion, of Westinghouse Electric.co_rporation and as such, I have been spccifi~ally delegated the functior of reviewing the proprietary informa.. :ion sought to be withheld frciil public dis-. closure in connectirn \\*lith nuclear power plunt licen*sing or rule-making proceedings, and am authorized to apply for its withholding on behalf of the Westinghouse Water Reactor_Di\\isiqns. (2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.7£:0 of the Commission's regulations and in con-junction with the ~estinghouse application for withholding*ac~ companying this Affidavit.* (3) *.I have personal knowledge 'of the criteria* and procedures utilized

  • by Hestinghouse Nuclear Energy Syster.1s in de~ignc~ing infon:1ation as a trade secret, privileged or as confidential co::-Jnercial or financial information.

(4) Pursuant to the provisio~s of paragraph {b){4J of Section 2.790

  • _of the Co~mission's regul~tions, the following is furnished for consideration by *.:he Conmission iri determining \\::hether the in-formation sought *.:o be \\*lithheld from public disclosure should be withheld.

(i) Ttic information sought to be withheld fro:n public disclosure is owned and has been held in confidence by Hestinghouse. ~ *,

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  • H-76-39 (ii} The information is of a type customarily held in confidence by Hestinghousc and not customarily disclosed to the public.

Westinghouse has a rational b.isis for determining the types of information custoQarily held in confidence by it and, in that connection, utilizes a system to dEtermine when and whetl1cr to hold certain t~pes of information in cbnfidence. The application of that system and the sub~ftance of that system constitutes \\*:estinghouse policy and provides the* rational basis required. Under that system, information is held in confidence if it fa1ls in ore or more of several types; the release of which might result in the loss of an existing or potential com-petitive advantage, as follows: {a) The information reveals the distinguishing aspects of .a process (or componeni, structure, tool, method, etc.) where prevention of its use by any of ~:estinghous*e's

  • competitors without license fro~ Westinghouse consti-tutes a competitive economic advantage 6ver other
  • compa:iies.

(b) It consists of su~p6rting data, in:luding test data, relative to a process (or component, structure, tool, method, etc.), the application of which data ~ecures a competitive economic advantage, e.g., by optimization or improved m.:irkctability.

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  • (c)

I ts use by a compcti tor would reduce his expenditure of r~sources or improve his comp~titivc position in ihe design, manufacture, shipment, installation, assurance of quality, or licensing a similar product. (d) It reveals cost or price information, production cap-acities, budget. levels, or commercial strateg~es of We~tinghouse, its customers or supFliers.

  • . ~(e) It reveals aspects of past, present, or future.West-inghouse or customer funded development ~lans ana pro-

~r;ams of potential cor.i.";1ercial value to ~*!esting_house. (f) It contains patentable ideas,' for which patent pro-tectiory may be desirable. (g) It is not the property of Westinghouse, but must be t.rca t.;d as proprietary by Westinghouse according to agrecnents with the owner. There are sound policy reasons behind the Westirighouse ~ system which include the following:

  • ca)

The use of such information by Westin_ghouse gives Westinghouse a co~petitive advantage over its com-petitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

I i_ 9-:7G-39 (b} It is information which is marketable in cany ways. 'The extent to which such~ informatidn is available to competitors diminishes the West~nghouse ability to

  • sell products and services involving the use of the (c) informotion.

Use b_y our competitor \\'1Uuld put Hestingh::n;se at a competitive disadv~ntage by reducing his expenditure of resources at our expense.

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Each component of proprietary informaticQ pertinent to a particu.lar *co;-:1petitive advan:age is_potentia11y as valuable as t~e total corapetitive advantage. If competi~ors acquire compone~ts of proprietary infor-mation, any one co~ponent rr.aY. be the key to the entire puzzle, thereby ~epriving Westinshouse of a co~petitive ** advantage. (c) Unrestricted disclosure would jeopardize the position of pro~inence*of.Westinghouse in the wor_ld market, and ~hereby give a market advantage t~ the competition in those countri£s. ~ -* \\' (f} The \\Jestinghouse capacity. to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

~ L~-*--- AH~7G-39 (iii) The in1*ormation is being transmitted *to the Comnission in confidence and, under the provisiqns of 10 CFR Section 2.790, it is ~.o be received in confidence by the Commission. (iv) The information is not available in public sources to the best of our knowledge and belief. (v) The proprietary information sought to be withheld in this submitt3l is that which is appropriately marked in the attachm21t to Westi~ghouse letter number ~S-CE-1163, Eicheldinger to Stolz. dated A~]ust 27,* 1976, concernjng _Westinghoµie equip~ent quali-ficptio!1 pr-ograms and thermal envirorni1ntal. qual if~caticn curve. The letter and attachment are being sucmitted in response to the NRC's request for infor~ation dated July 28, 1976. This i.nforma tion en ab 1 es Wes tfnghouse to: (a) De,*elop test inputs and procedures to satisfactorily vei*ify the design of Westinghouse supplied equipn:ent. (b) As~ist its customers to obtai~ licenses. Further, the information has substaitial coii".111ercial value as f o 11 O\\*Js: (a) Westinghouse can sell the use of this information to

  • customers.

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  • -76-39 (b) Wcstin11housc uses the informution to verify the design
of equipment \\*1hich is sold to customers.

(c) Westinghouse can sell testing servitcs tascd upon the experience gained ar.9 the test equipment and methods* developed. Public disclosure of this information is likely-to caus~ substantia~ harm to the co~petitive position-of Westinghouse becau.se it \\*1.ould enhance the ability of ~or:.petitors to de-sign, manufacture, verify, and sell electrica1 equipment for cor.u11erc1a1 power -re~ctors without co;..--:ien:.ura te expenses. Also, public disilos~re of the informtti~n w~ul~ enable others having the saGe or similar equipraent to use the i~for: mation to meet NRC requirements for licensing docu~entation without purchasing the right to use the inforsation. The devel'1pment of the equipment described ir. pert by the information is the result of many years of d2v~loplilent by ~ Westingho~se and the expenditure of a consid~rable sum of money. This could_ only be duplicated by a competitor if" he were to invest similar sums of money and provided rz* had the appropriate talent available and could someh:~ obtain the requisite experience. further the deponent sayeth not.}}

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