ML19338E996

Authorizes Use of Encl Affidavit in Support of Duke Power Co Application for Withholding CAW-80-60 Re Qualification of safety-related Instruments.Util Nonproprietary Response to NRC Questions Re Barton Transmitters Encl

ML19338E996
Person / Time
Site:	McGuire, Mcguire
Issue date:	09/25/1980
From:	Wiesemann R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	Harold Denton, Youngblood B Office of Nuclear Reactor Regulation
Shared Package
ML19260G338	List: ML19338E995 ML19338E996
References
NS-RAW-271, NUDOCS 8010070270
Download: ML19338E996 (151)

Text

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ueanemiegy civis:en Westinghouse Water Reactor Electric Corporation Divisions Box 355 _

Pittsturgf1 Pennsytvania 15230 September 25, 1980 NS-RAW-271 Mr. Harold Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: B. J. Youngblood

SUBJECT:

Docket Nos. 50-369 and 50-370 McGuire Nuclear Power Station Units 1 and 2 REF: Duke Power Company Application for Withholding, CAW-80-60, Duke Power Company to Denton, September 1980

Dear Mr. Denton:

The proprietary material for which withholding is being requested by Duke Power Comoany is of the same technical type as that proprietary material previous j submitted concerning the qualification of safety-related instruments.

The previous application for withholding, AW-76-39, dated August 27, 1986, was accompanied by a non-proprietary affidavit signed by the owner of the proprietary information, Westinghouse Electric Corporation. Further, the material previously submitted, AW-76-39, was approved by the Comission on April 15, 1977 and is equally applicable to this material.

Accordingly, this letter authorizes the use of the previously furnished affidavit in support of Duke Power Company's application for withholding CAW 80-60.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavits should reference CAW-80-60 and should be addressed to the undersigned.

Very truly yours,

'N JLukLW Robert A. Wiesemann, Manager Regulatory & Legislative Affairs

/mb cc: E. C. Shomaker, Esq. (NRC) 8010 070 ~ .

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4 PWRSys:rmscivis;on Wecinghmsa Pr)wer $yStemg Electric Carporation Company sans-Pittsautg1Pennsyvan:a15220 August 27,1976

! . AW-76-39 l

Mr. John F. Stolz, Chief Lir;ht Water Reactors Project Division of Project Management Office of Nuclear Raactor Regulation i l

U. S. Nuclear Regulatory Commission -  !

7920 Norfolk Avenue Bethesda, Maryland 20014 l

. I APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

SUBJECT:

Westinghouse Equipment Qualification Programs and Thermal Environmental Qualification Curve REF: Westinghouse L'etter No. NS-CE-ll83, Eicheidinger to Stolz, dated August 27, 1976 This application for withholding is submitted by Westinghouse Electric Corporation (" Westinghouse") pursuant to the provisions of paragraph (b)(1) of Section 2.790 of the Commission's regulations. Withholding from public disclosure is requested with respect to the subject infor- .

mation which is further identified in the affidavit accomp'anying this application. ,

The undersigned has reviewed the information sought to be withheld and is authorized to apply for its withholding on. behalf of Westinghouse, WRD, notification of wh'ich was sent to the Secretary of the Commission on April 19, 1976.

The affidavit accompanying this application sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.790 of the Commission's regulations.

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August 27, 1976 Mr. John F.. Sto,1z AW-76-39 l

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Accordingly, it is respectfully requested that the subject information which is proprietary to Wes;inghouse and which is further identified in the affidavit be withheld from public disclosure in accordance with 10 CFR Section 2.790 of the Commission's regulations.

Correspondence with respect to this application for withholding or the accompanying affidavit should be addressed to the undersigned.

Very truly yours, 1.jj2M W Robert A. Wiesemann, Manager Licensing Programs

/kek Enclosure cc: J. W. Maynard, Esq.

Office of the Executive Legal Director, NRC f

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AW-76-39 l

AFFIDAVIT 1 I

C0f'RONWEALTH OF PENUSYLVANIA:

ss COUNTY OF ALLEGHENY:

l Before me, the undersigned authority, personally appeared Robert A. Wiesemann, who, being by me duly sworn according to law, de-poses and says that he is authorized to execute this Affidavit on behalf l

of Westinghouse Electric Corporation (" Westinghouse") and that the aver-ments of fact set forth in this Affidavit are true and correct to the b@st of his knowledge, information, and belief:

40Lf2A M tu Robert A. Wiesemann, Manager Licensing Programs j

Sworn to and subscribed before'ethis-idday -

o (dM6 1976.

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AW-76-39 1

(1) I am Manager, Licensing Programs, in the Pressurized Water Reactor Systems Division, of Westinghouse Electric Corporation and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public dis-closure in connection with nuclear power plant licensing or rule-making proceedings, and am authorized to . apply for its withholding on behalf of the Westinghouse Water Reactor Divisions. .

(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.790 of the Commission's regulations and in con-junction with the Westinghouse application for withholding ac-companying this Affidavit.

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(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse Nuclear Energy Systems in designating information 4

as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.790 t of the Commission's regulations, the following is furnished for l

consideration by the Ccmmission in determining whether the in-  !

4 fonnation sought to be withheld from public disclosure should be withheld. -

(i) The information sought to be withheld from public disclosure l

is owned and has been held in confidence by Westinghouse.

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(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public.

Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in I

that connection, utilizes a system to determine when and whether to hold certain types of information in confidence.

i The applicatica of that system and the substance of that '

i system constitutes Westinghouse policy and provides the rational basis required. '

Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential com-j petitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.)

where prevention of its use by any of Westinghouse's competitors without license from Westinghouse consti-tutes a competitive economic advantage over other J

j companies.

(b) It consists of supporting data, including test data, l relative to a process (or ccmponent. structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.

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AW-76-39

. (c) Its use by a competitor would reduce his expenditure 4

of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similcr product.

i (d) It reveals cost or price information, production cap-i acities, budget levels, or commercial strategies of

Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future West-

! inghouse or customer funded development plans and pro-grams of potential commercial value to Westinghouse.

4 (f) It contains patentable ideas, for which patent pro-tection may be desirable.

j (g) It is not tne property of Westinghouse, but must be l treated as proprietary by Westinghouse according to j agreements with the owner.

i There are sound policy reasons behind the Westinghouse

! system which include the following:

i (a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its ccm-

t l petitors. It is, therefore, withheld from disclosure 1

to protect the Westinghouse competitive position.

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..y AW-76-39 (b) It is information which is marketable in many ways.

The extent to which such information is available to _

competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.

(c) Use by our competitor would put Wdstinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

(d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary infor-mation, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition in those countries.

(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintainir.g a competitive advantage.

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AW-76-39 (iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.790, it is to 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 submittal is that which is appropriately marked in the attachment to Westinghouse letter number NS-CE-ll83, Eiche1dinger to Stolz, dated August 27, 1976, concerning Westinghouse equipment quali-fication programs and thermal environmental qualification curve.

The letter and attachment are being submitted in response to the NRC's request for information dated July 28, 1976.

This information enables Westinghouse to:

(a) Develop test inputs and procedures to satisfactorily verify the design of Westinghouse supplied equipment.

(b) Assist its customers to obtain licenses.

Further, the information has substantial commercial value as follows:  !

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(a) Westinghouse can sell the use of this information to customers.

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• AW-76-39 (b) Westinghouse uses the information to verify the design of equipment which is sold to customers. .

(c) Westinghouse can sell testing services based upon the experience gained and the test equipment and methods developed.

Public disclosure of this information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to de-sign, manufacture, verify, and sell electrical equipment for commercial power reactors without commensurate expenses.

Also, public disclosure of the information would enable ,

others having the same or similar equipment to use the infor- -

mation to meet NRC requirements for licensing documentation without purchasing the right to use the infonnation.

The development of the equipment desce: bed in part by the information is the result of many years of devel:opment by Westinghouse and the expenditure of a considerable sum of money.

This could only be duplicated by a competitor if he were to invest similar sums of money and provided he had the appropriate talent available and could'somehew obtain the requisite experience.

Further the deponent sayeth not. l l

i

s Attachment 1 McGuire Nuclear Station Class lE Equipment Qualification I. Barton Transmitters (Lot 2)

In a letter dated January 24,1980 fromJ F Stoltz to T M Anderson, the staff requested additional information from Westinghouse regarding the qualification test report entitled " Qualification Test of ITT/Barton Transmitters, Prcduction Lot No. 2" (NS-TMA-2184 dated January 16, 1980).

L Westinghouse responded generically to Questions 1, 2 and 4 of the staff's January 24 letter (NS-TMA-2248 dated May 21,1980). The following response to Question 3 specifically applies to the Barton Lot 2 units employed in McGuire IJnit 1 Question 3:

Westinghouse notes that the [ ]b,c.e of tist unit BE-2 exceeds the acceptance criteria and is under further investigation.

Westinghouse noted that it suspects that a [ ]b,c,e problem exists within this unit. Should this be the cause, it would appear that this 'is a potential source for common mode failures of these transmitters when subjected to harsh environmental conditions, Why will transmitters tsed

, in plant applications not be subject to the same problems if [

]b c,e is the cause of the [ ]?b,c.e Further, what acticn I

will be taken to qualify this instrument if the failure of this instrument to meet the acceptance requirements is not attributed to,[

]?b,c,e What is the rationale.for permitting plants to operate with this instrument during the time required to demonstrate acceptable qualification?

Response: (Applicable only to McGuire Unit 1 Lot No. 2 transmitters)

[ ]b,c.e exhibited an unusually [ ]b,c.e early in the temperature transient, The magnitude of this [ ]b,c.e far exceeded the [ ]b,c.e of the other three differential pressure units tested. Singe this appeared to be a [ -]b , c .e caused by [

], ,c.e Westinghouse performed additional tests on an instrumented unit to determine the [ ].b,c,e As shown in Figure 1, the maximum temperature difference between the [

]b,c.e is approximately [ ]b,c.e at five minutes into the event which corresponds to the time of the observed [ ].b,c,e Based on this information, Westinghouse has developed a model to determine the acceptability of the remaining units in 'ot No. 2 This model uses the values of the [ ]b,c e to calculate the expected [ ].b,c,e Also included is the [ ]b,c,e determined from the final temperature calibration.

In addition to the original four test units, three more differential pressure units have been tested and compared to the model. Based on this data from seven units the model is somewhat conservative as shown below:

S/N Predicted Actual b,c,e 503 504 466 505 602 501 500 J

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Westinghouse is performing additional testing to reduce the conservatism before passing judgement on all of the units in lot No. 2 The transmitters used for pressurizer water level and steam generator water level for McGuire Unit 1 have been reviewed using the conservative model and all negative errors are less than [ ]%, This is within the trip and monitoring accuracy requirement for this project. An additional requirement for McGuire Unit 1 is to limit the positive error for the

- trip function of narrow range stearn generator level transmitters to

+5%. The original Lot 2 report noted an error of [ ]%b ,c.e early in the steam test transient, Additional tests were performed on the same unit using [ ]b,c,e ,

This caused the temperature of the [.

]b,c,e more closely during the first minute and limited the positive error to less than [ ]%b,c.e . In other words, the temperature difference between the [ ] ,c,e shown in Figure 1 has been reduced to a level compatible to McGuire Unit I functional requirements.

II. Containment Air Return and Hydrogen Skimmer Fan Motors NRC letter dated March 7,1980 requested Duke to provide justification for the acceptability of separate effects testing for the containment air return and hydrogen slimmer fan motors. Specifically, the NRC Staff's concern was that although the motor insulation system and other motor components are qualified for a radiation environment in excess of the calculated normal plus accident radiation environment, the motorette testing did not include

< exposure to a steam environment following exposure to radiation.

Duke Power Company has reviewed the design and testing of tnese fan motors.

We have determined that the combined effects of a radiation environment and a steam environment were previously included in the qualification testing on a complete motor assembly. The motor assembly tested was a valve motor

. operator composed of the materials identified in Reliance Electric Company Report NUC-9 which are similar to the materials composing the McGuire

containment air return and hydrogen skimmer fan motors. This valve motor operator (ID No. 2Y267074AlEZ) was irradiated and examined as reported by Reliance in NUC-9 and then shipped to the Limitorque Corporation where it was successfully tested in a steam environment in accordance with IEEE 382-1972 as reported in Limitorque Test Report 600456 The radiation and steam environmental parameters used in the Reliance and Limitorque tests envelope the accident conditions for the McGuire fan motors, Cuke Power Co.upany therefore concludes that in addition to the environmental testing described in Joy Manufacturing Company Test Report X-604, the er.vironmental testing described above further assures the capability of the McGuire containment air return and hydrogen skimmer fan motors to function in the postulated McGuire accident environrcent.

III. Barton 351 Pressure Sensing Bellows Device The design of the McGuire containment pressure sensing system has been modified thereby deleting the use of the Barton 351 pressure sensing bellows device.

The pressure transmitters have been relocated to the penetration rooms on elevations 750' and 733' adjacent to the containment in the Auxiliary Building. Instrument lines will be run from the transmitters to the containment. Relocation of the transmitters has the following advantages:

1. Area environment is much less severe which effectively eliminates inaccuracies induced by high radiation.

2. Transmitters are closely accessible for calibration and maintenance.

3. Response time of'the pressure sensing system is improved.

To assure that containment isolation provisions are met, a motor-operated, fail-as-is valve will be installed on each impulse line. These valves will have open and closed position indicators and control switches in the control room.

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