ML20094D356

Forwards Nonproprietary Use of Code Case N-192... & Proprietary Repts,Including Documentation of Compliance of Mbc P/N 73989... & Hose Assembly... Qualification Test Procedures,Per Reg Guide 1.84.Proprietary Repts Withheld

ML20094D356
Person / Time
Site:	Hope Creek
Issue date:	07/30/1984
From:	Mittl R Public Service Enterprise Group
To:	Schwencer A Office of Nuclear Reactor Regulation
Shared Package
ML19273A433	List: ML20094D356 ML20094D365
References
RTR-REGGD-01.084, RTR-REGGD-1.084 NUDOCS 8408080344
Download: ML20094D356 (10)

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O PS G Come,any Electnc and Gas 80 Park Plaza, Newark, NJ 07101/ 201430-8217 mat LING ADDRESS / P.O. Box 570, Newark, NJ 07101 Robert L. Mitti General Manager Nuclear Assurance and Regulation July 30, 1984 Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, MD 20814 Attention: Mr. Albert Schwencer, Chief Licensing Branch 2 Division of Licensing Gentlemen:

HOPE CREEK GENERATING STATION DOCKET NO. 50-354 COMPLI ANCE WITH REGULATORY GUIDE 1.84

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Public Service Electric and Gas Company (PSE&G) submits the attached detailed design data on the use of Code Case N-192, as required by Regulatory Guide 1.84. This design data demonstrates compliance with Paragraph NC/ND-3649 of ASME Section III.

This information is considered to be proprietary and is to be withheld f rom public disclosure r as indicated in the attached af fic.avit.

Should you have any questions in this regard, please contact us.

Very truly yours,

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g R.C R PR.69 KI 12 01 rt o f 8 L O. f 0pCf 8408080344 84o73o

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The Energy People 9um uvi 7 a3

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~, Director of' Nuclear = 2 7/30/84

,'  : Reactor Regulation l.

C .D. H. Wagner .(w/ attach)

USNRC Licensing Project Manager W. H . Bateman.(w/o attach)

USNRC Senior. Resident Inspettor KI 12 01/02 4

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mise 40260194 a:3'840267225 d

l (ljBER E5555 METAL BELLOWS CORPORATION (MBC)

AFFIDAVIT I, Paul B. Campbell, being duly sworn, depose and state as follows:

1. I am Corporate Vice President, Engineering, and have been delegated the function of reviewing the information described in paragraph 2 which is sought to be withheld and has been authorized to apply for its withholding.

2. The material. sought to be withheld is:

CR 364 Report, Hose Assembly, Flexible Metal Instrumentation, including Addendum I CR 429 Allowable Installation Configuration for MBC P/N 73989 CR 431 Stress Report for MBC P/N 73989 CR 434 Documentation of Compliance for MBC P/N 73989

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CR 709 Design Report CR 710 Documentation of Compliance CR 719 Design Report CR 720 Documentation of Compliance CR 725 Report, Hose Assembly, Flexible Metal, Instrumentation CPS 3043 Weld Specification for Nuclear Components CPS 3098 General Cleaning Procedure for Cleaning and Packaging Nuclear Components CPS 3118 Procedure and Control for Penetrant Inspection CPS 3187 General Acceptance Test Procedure for Nuclear Items, including Attachment I CPS 3197 Cleaning, Packaging, and Shipping Procedure for Nuclear Components CPS 3208 Minimum Wall Thickness Verification Procedure for

{ Formed Bellows CPS 3210 Identification Marking of Parts and Assemblies

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i JUL 3 '84 0 2 6 7 2 2 5 m s840260194

! i AFFIDAVIT

. MBC,3/2/84 i

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( gg 78012 Hose Assembly - 1" IPS Drawing h 78013 Hose Assembly - 1 1/2" IPS Drawing 78014 Hose Assembly - 2" IPS Drawing 78040 Hose Assembly - 8" Diameter Drawing  !

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, 78528 Hose Assembly - Flexible Metal per ASME Section III, Class 2 & 3 A006 QW-482, Welding Procedure Specification including s

Supplements I and II A006 QW-483, Procedure Qualification Record l A012 QW-482, Welding Procedure Specification 1 -

A012 QW-483, Procedure Qualification Record A012 Supplement A029 QW-482, Welding Procedure Specification

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A029 QW-483, Procedure Qualification Record A029 Supplement A030 QW-482, Welding Procedure Specification A030 QW-483, Procedure Qualification Record A030 Supplement A034 QW-482, Welding Procedure Specification A034 QW-483, Procedure Qualification Record

, A034 Supplement IM 77598 Instruction Manual - Installation, inspection and handling for hose assembly, flexible metal per ASME Section III, Class 2 IM 77600 Instruction Manual, Installation, Inspection. Storage and Handling for Hose Assembly - Floating Flange Connection.

Q.A.

s Manual Quality Assurance Nuclear Manual DT-068-18 Ultrasonic Examination

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. MBC,3/2/84

[ gg DT-068-19 Radiographic Examination EEBEB DT-osa-zo Magnetic Particle Examination

3. In designating material as proprietary, MBC 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 infonnation 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 information.... Some factors to be considered in one's trade secretdetermining are: (whether givento

1) the extent infonnation which theis information is known cutside 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 2 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 nuclear metallic hose competitors without license from MBC 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;

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 or quality or licensing of a similar product;

d. Information which reveals cost or price information, production capacities, budget levels or comercial strategies of MBC, its customers or suppliers;

e. Information which reveals aspects of past, present, or future MBC customer-funded development plans and programs or potential comercial value to MBC;

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/ MBC,3/2/84 l

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g g' f. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection; 35 '

g. Information which MBC must treat as proprietary according i to agreements with other parties. j

5. In addition to proprietary treatment given to material meeting '

the standards enumerated above, MBC customarily maintains in confidence preliminary and draft material which has not been 7' * '

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 normal revi#and approval procedures. Also,

g until the final docu0ent is completed it may not be possible to make any det,'nitive determination as to its 7roprietary nature. '

j MBC is not generally wpling to release such a document to the

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general public in such-a preliminary form. Such documents are however, on occasion furnished to the NRC staff on a confidential' ~

basis be:ause it is )4BC's belief that, it J is in the public interest for the staff to be promptly furnished witn significant or potentially significant infomation. Furnishing the document on a confidential basis pending completion of MBC internal review permits early acquaintance of the staff with the information i while protecting MBC's potential proprietary position and permitting MBC tn insure the documents are technically accurate

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and correct. '

6. Initial approval 'of proprietary treatment of a document is made ,

, bLthe Subsection Manager of the originating component, the man most likely to bd acquainted with the value' and sensitivity of <

tWinformation in' relation to industry knowledge. Access to such documents within.the Company is limited on a "need to know" basis and such dccuments at all times are clearly identified as-proprietary. ,

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7. The procedure for approval of external release of such a document is reviewed. by the SectioT Manager, Project Manager, Principal Scientist;or other equivalent authority, by the Section Manager of the cagaizant Marketing function (or his delegate) and by the Legal Operaticn for technical content, l t' competitive effect and determination of the accuracy of the l proprietary designation in accordance with .the standards

( t, enumerated above. Disclosures outside MP.C are generally limited to regulatory bodies, customers and potential customer and their l agents, supplier, and licensees only in' accordance with l appropriate regulatory provisions or proprietary agreements.

8. The documents mentioned in paragraph:2'above ha e been evaluated in accordance with the above criteria and procedures and have

, been found to contain information which is propriet.ary and which is customarily held in confidence by MBC.

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m :s 84026019 4 AFFIDAVIT

- MBC,3/2/84 JJ!. -3 '84 0 P. 6 7 2 2 5

( g g 9. The materials mentioned in Paragraph 2 above provide a detailed discussion of both the philosophy and methodology used by MBC in B5 nuclear metallic hose for safety related equipment and as such are considered to contain commercially sensitive information.

This infonnation is handled as proprietary by Metal Bellows Corporation Chatsworth, California Paul S. Campbell, 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, infonnation, and belief.

Executed at Chatsworth, California, this 2nd day of March 1984, k

Paul B. Campbell Subscribed and sworn before me this 2nd day of March 1984.

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' NOTARY PUBLIC IN A,NP FOR SAID COUNTY AND STATE SUSAN COOPER y NOTARY F UBUC - CAUFORNIA LoS AlGELES COUNTY My Comm Empires Sept. 24,1986 l

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