ML20116A420

Forwards Proprietary Post-Accident Sampling Sys Evaluation Rept, Addressing 11 Criteria of NUREG-0737,TMI Action Item II.B.3,per SER (NUREG-0853) License Condition 6. Affidavit Encl.Rept Withheld (Ref 10CFR2.790)

ML20116A420
Person / Time
Site:	Clinton
Issue date:	04/19/1985
From:	Spangenberg F ILLINOIS POWER CO.
To:	Schwencer A Office of Nuclear Reactor Regulation
Shared Package
ML19269B432	List: ML20116A420
References
RTR-NUREG-0737, RTR-NUREG-0853, RTR-NUREG-737, RTR-NUREG-853, TASK-2.B.3, TASK-TM U-0833, U-833, NUDOCS 8504240470
Download: ML20116A420 (5)

Text

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y U-0833 L30-65(04-19)-L 1A.120 ILLINOIS POWER 00MPANY CLINTON POWER STATION. P.o. BOX 678. CLINToN. tLLINolS 61727 April 19, 1985 Docket No. 50-461 Director of Nuclear Reactor Regulation Attention: Mr. A. Schwencer, Chief Licensing Branch No. 2 Division of Licensing U.S. Nuclear Regulatory Con: mission Washington, DC 20555

Subject:

Clinton Power Station Unit #1 Post Accident Sampling System Evaluation Report NUREG-0737, TMI Action Plan Item II.B.3 SER License Condition #6

Dear Mr. Schwencer:

Attached is the Clinton Power Station (CPS) Unit #1 " Post Accident Sampling System Evaluation Report". The purpose of this report is to address the eleven (11) criteria of NUREG-0737, TMI Action Plan Item II.B.3 entitled " Post Accident Sampling", as they apply to CPS. This report will assist in the NRC Staff's post-implementation review of the CPS Post Accident Sampling System (PASS), as required in License '

Condition #6 of the CPS Safety Evaluation Report (NUREG-0853).

Clinton SER Supplement #2, Section 9.3.5 identifies additional open items related to this issue as follows:

1. Provide person-motion dose study indicating that operator radiation exposure meets GDC 19, of 10CFR50, Appendix A during sampling, transportation and analysis in the plant [See Attachment #1 of PASS Evaluation Report];

2. Implement a PASS testing and operator training program [Such a program will be established at CPS according to the Position 10 response (See page 35 of the report) via CPS Technical Specifications, Section 6.8.4.c. Personnel requalification will occur every two years, as a minimum, with refresher training on the system's operating characteristics performed on a semiannual basis through routine PASS usage];

3. Submit data supporting the applicability of each selected analytical procedure or online instrument [See the Position 10 response (pages 31-35 of the report)];

4. The CPS Core Damage Estimation Procedure was found acceptable on an interim basis. By fuel load, to obtain final approval of this procedure, the Staff required the procedure to be revised to include the following:

8504240470 850419 PDR ADOCK 05000461 0( (i

U-0833 L30- 85 (04-19)-L 1A.120 (a) A third core damage category that is in-between cladding failure and core melt, namely, fuel overheating (metal water reaction); and (b) Other plant indicators (e.g. hydrogen concentration and radiation monitor indications inside drywell or containment) to assist in the interpretation of the extent of core damage.

These changes to the CPS Core Damage Estimation Procedure have been made and are under review at this time. The Pcaition 2 response provides more detail on these calculational methods.

Since the revised procedure has not been approved by Plant Staff for implementation, it is not included in this submittal. This procedure is used for accident assessment in the CPS Emergency Plan and, as such, will become part of the Emergency Plan Implementing Procedures (EPIPs). The EPIPs will be submitted to the Staff in July 1985, as currently scheduled.

The Clinton PASS is a Sentry Equipment Corporation (SEC) Model B system. Parts of the PASS Evaluation Report are based on information obtained from SEC Specification B10-01. This material is proprietary to SEC. Therefore, Illinois Power requests that the attached PASS Evaluation Report be handled as proprietary and be withheld from public disclosure in accordance with the provisions of 10CFR2.790(b)(1). A signed affidavit by Mr. Charles C. Tuff, President of SEC, to this effect is also attached herein.

Illinois Power considers the information contained herein as sufficient to close out the requirements of CPS SER License Condition

1. 6. Should the Staff have any questions related to this material, please contact me.

Sincerely yours,

/

s;g aate F. A. angqbberg I Directo - fuclear Licensing and Configuration Nuclear Station Engineering TLR/ lab Attachment cc: B. L. Siegel, NRC Clinton Licensing Project Manager NRC Resident Office Regional Administrator, Region III, USNRC Illinois Department of Nuclear Safety

SENTRY EQUIPMENT CORP 856 East Armour Road Oconomowoc, WI 53066 AFFIDAVIT I, Charles C. Tuff, being duly sworn, depose and state as follows:

1. I am President, Sentry Equipment Corp., and have reviewed the information described in paragraph 2 which is sought to be withheld and I apply for its withholding. -

2. The information sought to be withheld is contained in document entitled:

" Specification No. B10-01 R6, Specifications for Model B HRSS (High Radiation Sampling System)."

3. In designating material as proprietary, Sentry Equipment 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 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 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 case 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 Sentry Equipment's competitors without license from Sentry Equipment constitutes a competitive economic advantage over other com-panies,

b. Information consisting of supporting data and analyses, including test data, relative to a process, method, or apparatus, the application of which provides a competitive economic advantage; for example, 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 of quality, or licensing of a similar product. l

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Affidavit C.C. Tuff Page 2 of 3

d. Information which reveals cost or price information, production capacities, budget levels or commercial strategies of Sentry Equipment, its customers or suppliers.

e. Information which reveals aspects of past, present, or future Sentry Equipment funded development plans and programs of potential commercial value to Sentry Equipment.

, f. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

g. Information which Sentry Equipment must treat as proprietary according to agreements with other parties.

5. In addition to proprietary treatment given to material meeting the above standards, Sentry Equipment 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 tentative conclusions, and may contain errors that can be corrected during normal review and approval procedures. Also, it may not be possible to make any definitive determination as to its proprietary nature until the final document is completed.

Sentry Equipment does not release such a document to the general public in such a preliminary form.

6. Approval of proprietary treatment of a document is made by the head of research and development. Access to such documents within Sentry Equipment is limited on a "need to know" basis and such documents at all times are clearly identified as proprietary and confidential.

7. The procedure for approval of external release of such a document is reviewed -

in accordance with the above standards by the Nuclear Products Product Manager and the Project Engineering Manager of Research and Development, for technical content, competitive effect and determination of the accuracy of the proprietary designation. Disclosures outside Sentry Equipment are limited to regulatory bodies, customers and potential customers and their agents, suppliers, and licensees only in accordance with appropriate regulatcry provisions or proprietary agreements.

The document mentioned in paragraph 2 above has been evaluated in accordance

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with the above criteria and procedures and has been found to contain information which is proprietary and which is customarily held in confidence by Sentry Equipment.

9. The document: " Specifications for Model B HRSS (High Radiation Sampling System)", presents and discusses test data which is proprietary to Sentry Equipment.

Affidavit C.C. Tuff Page 3 of 3

10. To the best of my knowledge and belief, the information has consistently been held in confidence by the Sentry Equipment Corp., no public disclosures have been made, and it is not available in public sources. All disclosures to third parties have been made pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence.

11. Public disclosure of the information source to be withheld is likely to cause substantial harm to the competitive position of Sentry Equipment Corp. and deprive or reduce the availability of profit-making opportunities because:

a. It contains test data obtained at a test facility designed, fabricated, and operated by Sentry Equipment Corp. This test facility was developed and operated with a substantial expenditure of resources,

b. It contains the results of engineering evaluation of the test data obtained at the test facility. Considerable resources were utilized in this evaluation.

c. Public availability of this information would permit competitors to utilize this information to the financial and competitive disadvantage of Sentry Equipment Corp.

STATE OF WISCONSIN )

COUNTY OF WAUKESHA ) SS Charles C. Tuff, 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, th Executed at Oconomowoc, Wisconsin, this #2(o day of 'TOUE ,1984.

c3ocm Charles C. Tuff, F'res Sentry Equipment Subscribed and sworn to me thisM day of ump ,1984 k "

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