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 Office of Inspection and Enforcement Region 1 631 Park Avenue King of Prussia, PA 19406

Dear Mr •. Grier:

NRC IE BULLETIN NO. 79-0lB ENVIRONMENTAL QUALIFICATION OF CLASS IE EQUIPMENT SALEM GENERATING STATION UNIT NO. 1 DOCKET ~O. 50-272

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The Environmental Qualification Review Rep'orts for Salem Unit 1 are enclosed and supersede ·all previous information submitted for Bulletin 79_-0_lB on Marph 7, March ·21, A]'ril 14, and June 4, 19 80. 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 th;at the 'information proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2. 790. co·rrespondence about the proprietary aspects of this request to wi_thhold information or the supporting Westinghouse affida.vit should reference CAW-80-15,- and should be addressed to R. A. Wies·emann, 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 tha:t will be taken to· complete ·qualification documentation. ·

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 Septeiriber 19, 1980, signed by Darrell G. Eisenhut, Director, Division of Licensing. We recognize that this sub­mittal as it relates to Unit 2 has undergone extensive discus­sions 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 required.

If you have any questions concerning this matter, please do not hesitate to contact us.

Sincerely,

cc u.s. Nuclear Regulatory Commission Off ice of Inspection and Enforcement Division of Reactor Operations :i:nspection Washington,. DC · .20555 Cw/o attachment}

Mr. D. G·. Eisenhut, D:i.rector Division of Licensing u. s. Nucle·ar Regulatory Commiss"ion Washington, _DC 2 O 5 5 5

Mr. s. A. Varga, _Chief Operating Reactors Branch 1 Division of Licensing U.S. Nuclear Regulatory Commission Washington, oc· 20555 Cw/o attachment)

Mr. W. J. Ross·, l?roj edt Ma.nager Operating Reactors Branch ·1 Division of Licensing u. s ._ Nuclear Regulatory Commission Washington, DC 20555 Cw/o atta;chtrierit}

Mr .. A. E. Finkel, _Reactor !nswection u. s .. Nuclear Regulatory Cornmiss·ion Office of Inspection and Enforcement Region l 631 l?ark Avenue King of Prussia, RA 19406

STATE OF NEW 'JER,SEYl l SS:

COUNTY OF ESSEX }

- FREDERICK W. SCHNE:CDER,, }:)eing du'.l,:y 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 tru~ to

the best of my knowledge, information, and belief.

~JCLJ._ FREDERICK ~NEIDER

Subscribed and sworn to before me

__ this.d I day of(f t/;~!u_jy, :J.980~

My cornrnis sion expires on (Cc.I-. I · / Y A3

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WeS1in~housc Electric Corporation

Water Reactor Divisions

. Mr. H. R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commis~ion Washington, D. c~ 205~5

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APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATIOH FROM PUBLIC DISCLOSURE

N1J:lcarTcchnolocy Division

Box355 Piltsb11r2h rcnnsylvan!a i">:?:?O

May 22, 1980 CAW-80-15

. SUBJECT: Salem Unit 2 (Docket Number 50-311) tniormation Related to Electrical Equipment Qualification

·.. ; REF: Letter from Mittl to Denton dated May 22, 1980

Gentlemen:

The proprietary ma"':erial transmitted by the reference letter supplements the proprietary ma-t~eria 1 previously submitted concerning the environmenta 1 qualification of safety-related equipment. Further, the affidavit submitted to justify the ma t~ri a 1 previously submi tte:d, AW·-76-39, was approved by the Commission on April l!), 1977,_ and is equa11¥ applicable to this materia).

Accordingly, withholding the subject material from public disclosure is requested fn accordance with the previously submitted affidavit and appli­cation for, v~ithholding, ·AH-76-39, dated August 27, 1976, a copy of which is attached. ·The app:'oved application was further ~upported by a proprietary affidavit, not att.1ched, which was sent to the C1 1mmission on September 29, 1978 and approved l>y ·the Commission on May 9, 19~9.

Correspondence with respect to this application ···or withholding or the .. accompanying affidavit should refe~ence CAW-80-lf,, and should be addressed to the undersigned.

/bek Attachment

cc: J. /\. Cooke, :::sq.

Veri tr-u'\y yours,

/2J}).l1Ae,~.t[U/,t,(J,O Robert A. Wies emzrnn, Manager Regulatory & Legislative Affairs

Office of the Executive Legal Director, NRC

.. : \·J~r..tinahn11c:P.

Elccrric corpora 1 ion

e Pnwt"r Sv~l;·m~ . . . . . . ~ . . . . Company

•

Mr. John F. Stolz,.Chicf · Light Water ?.eactors Project

Division of Project i·:anagerr.ent . Office of i:uc1ear Reactor Regulation U. S. Nuclear Regul~'.ory Cor..:nission -7920 Norfolk Avenue· Bethesda, f·!aryl an.d ~'.0014

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• APPL! CAT Im: FOP. WITHHOLDH:G PROPRJ ~TARY

HffOR:·lATIO:-! FRO;·~ PUBLIC DISCLQSURE '·

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. PWR Systems 01visiCXl

6ox35~ PillS!J.Jri:,h Pt.ms111~113 15230

Augu!;t 27 9 1976. A~l-76-39

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SUBJECT:: Westinghouse Equip~ent Qualification Programs and Thermal Environ:nenta 1 Qua l i f!_ca ti on Curve

REF: Westinghou~~ Letter Ne. NS-CE-118·3, Eicheld.inger to Stolz, d.ated A;;gus t 27, 1976

This application for withholding is sub~itted by Westinghouse Electric Corporation ( 11 ~·!estin1;house 11 ) pu1Asuant to the previsions of paragraph (b)(l) of Section 2. 190 of the C0i~;;iission 1 s regL lations._ ~·lithholdir.g from public disclosu·e is requested with respect to the subject infor­mation which is furt·1er identified in the affidavit accompanying this application. ·

The und~rsigncd has reviewed the information so~ght to be withheld and is authorized to apply for its withholding on behalf of Westinghouse, WRD, notification of which \·tas sent to the Secretary of the Con:r.1ission on April 19, 1976 .

. The affidavit accompanying this application sets forth the basis on _which the informJtion mu.y be \'Ii thhcld fror.l public disclosur.c by the Commission end uddrcsscs with specificity the considerations listed in

_ pal'agraph (b)(4) of Section 2.790 of the Coiiimission's regulations.·

. ·

· Mr. Jqhh F. s to lz· ·9

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August 27, 1 !J7G AH .. -3~·

·Accordingly, it is respectfully requested that the subject informJtion which is proprietary to \-!estinghousc and \·Jhich is further identified iri the affidavit be withheld from p~blic disclosure.i~ accordance with 10 CFR Section 2.790 of the- Co~1ission 1 s regulations.

Corresponde~ce with resp~ct to this application for withholding or the accompanying affidavit should be addressed to the undersigned.

.,

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Enclosure '

cc: J. W. Maynard, Esq.

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Very truly yours, · ·

. :/) ·0,, fi,,~"'~·'l'~ ~i.,'i:L.-Llu ~~--"~'-" .;J Robert A. w~ese~ann, Manager Licensing Programs

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Office of the Executive Leg~l Director, HRC

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. . . /\W-76..:39 ·

. /\FFJ DJ\ V IT -CO!·~~OtlHE/\LTlf QF PEWlSYLVJ\tlIA: •

.· COUNTY OF ALLEGHENY: .

Before me, the undersigned authority, personally appeared Robert A. Wiesemarn, who, being by me duly sworn according to law, de­poses and says that he is authorized to executa this Affidavit on behalf of Westinghouse Electric Corporation (~Westinghouse") and that ·the aver­ments of fact set forth in this Affidavit are true and correct to the ,. . . . . best of his kno~·11edge, informatio.n, and belief: '·

-Sworn to and subscribed

,.. /} beforepe .thi s:_(cv day o~1.etL:.i~1976.

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0, , 1(/ u.f.(4' ~ 4t/£a> . Notary Public

. ··c.: r·c1·1 .. , r.;:.:-::c ~t£ CCA A. lC'f.I. ·: ' '·;· ..

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Robert A. Wiesem~nn, Manager Licensing Programs

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·(1) I am Manager, Licensing P~ograms, in the Pressu~fzed Water Reactor . . Syst~ms Division, of l·!cstinghouse Electric .co.rporation and as such,

I have been specif~~ally delegated the functior of reviewing the proprietary informa .. :ion sought to be withheld from public dis-.

closure in connecti)n \·1ith nuclear power plant lic~msing or. rule­

making proceedings, and am authorized to apply for its withholding

on behalf of the Westinghouse Water Reactor_Di,isions. . ,

(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.7~0 of the Com."llission's regu1rltions and in con­

junction with the Westinghouse application for withholding·ac~ . companying this Affidavit.-

(3} .I ~ave personal knowledge~f the criteria· and procedures utilized· by Westinghouse Nuclear Energy Systeras in de$i.gnating inforr.1ation as a trade secret, privileged or as confidential co::-wrnercial or

financial information.

(4) Pursuant to the provisio~s of paragraph (b)(4J of Section 2.790 _of the Co~mission's regulations, the fo11owin~ is furnished for consideration by ·.:he Corr.;nission in determining \::hether the in­

formation ·sought ·:o be \·lithheld from public disclosure should b.e

with~cld. ~ •\

··i··

(i) The information sought to be withheld fro:n public disclosure

is O\·mc::J and has been held in confidence by Westinghouse.

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-J;.. e /M-75-39

. · (i.i} The information is of a type customarily held in confidence . .

by Westinghouse and not custcimarily disclosed to the public. . . Westinghouse has a rational basis for determining the types of information cu5tor.i~rily held in confidence by it and,· in that connection, utilizes a system to dttermine when and whether to hol~ certain ty~pes of information in confidence.

The application of that system and the substance of that

system constitute"s Westinghouse policy and provides the· rational basis required.

Under that system, information is held in confidence if it . . falls in ore or more of several types; the release of which

might result in the loss of an existing or potential com­petitive advantage, as follows:

{a) The information reveals the distinguishi~g aspects of a process (or componeni, structure, tool, method, etc.) where p1·eventi on of its use by any of ~.'es ti nghous·e 1 s

. . ·compc~itors without license fro~ Westinghouse consti­tutes a competitive economic advantage over other •

compa:iies.

{b) It consists of supporting data, in:luding test data, rel~tive to a process (or co~ponent, structure, tool, method, etc.), the application of which d~ta ~ecures a competitive economic advantage, e.g., by optimization or improved m.:i.rkctability.

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. . . . (c) Its us·c by a competitor would reduce his expenditure

of r~sources or i~provc his comp~titivc positi-0n in ~he design, manufacture, shipment, installation, assurance of quality, or licensing a similar product •

(d} ..

It reveals cost or price information, production cap-acities, budg~t levels, or commercial strateg~es of

Weitinghouse, its customers or sµp~liers.

~·(e) It reveals aspects of past, present, or future"West­inghouse or customer funde~ development plans ana pro-. . grams of potential com.ercial value to ~·!esting~ouse •

. .

(f) It contains patentable ideas," for which patent pro-

tection may be desirable. . . . .

(g) It is not the property of Westinghouse, but must be t:catzd as proprietary by Westinghouse according to

. . agreenents with the owner.

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There are sound policy reasons behind the Westinghouse ~ system which include the following:

·(a) The use of such information by Wcsti~ghouse gives Westinghouse a cor.:petitive advantage over its com-

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pctitors. It is~ therefore,\:lithheld from disclosure·

to protect the Westinghous~ competitive positi-0n.

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eAH~7G-39

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(b) It is information Nhich is marketable in ~any ways ..

(c)

"The extent to which such.' information is available to

· competitors diminishes the Westinghouse abi.1 i ty to

-~ell products and services involving ~he use of th~

information. . ..

Use by our competitor would put Westingho~se at a . .

competitive disadv~ntage by reducing his expenditure

of resources at our expense •

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:Cdl Each component of proprietary inforrna ti CQ pertinent

(e}

to a particu.lar tor.1petitivt! advan~age is_ potentially

as valuable as t_he total cor.ipetitive. advantage. If

competi~ors acquire_components of proprietary infor­

mation, any one co~ponent may be the key to the entire puzzle, thereby ~epriving Westin;house of acor.ipctitive · advantage.

Unrestricted disclosure would jeopardize the positio~ of prominence· of .Westingho11se. in the \'/Orld. market, . . and ~hereby give a ma~ket. advantage t~ the.competition in those. countriEs.

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(f) The \!estihghouse capacity to invest corporate assets in research and development depends upon the success . _/,.. in obtaining and maintaining a competitive adv~ntage~

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... -G;.. · AH..;7G-39.

·(iii) The information is being transmi~tcd ·do the. Gair.mission in

conr'idcnce and, under the provisiqns dr 10 ~FR Section 2.790, .. it is ".o be received in .confidc~c~ by I the Corr.mission. . ·

(iv) The information is not available in p 61 ic sources to the

best of our knowledge and belief.

(v) . .

The pro;)riet:ry information sought to 1be \·tithheld in this

submitt~1 is that which is appropriate\1Y ~arked in _the attachm:it

to Westinghouse letter number ~S-CE-11.S3, Eicheldinger to Stolz. dated A~~ust 27,· 1976, concernjng .West~nghoui~ equip~ent quali­

ficptio!1 pr-ograms and thermal environ:iH~ntal qualification curve. \ .

The letter and a ttacr.iiient are be.i ~~ suqmi tted in respo~se to the

NRC's request for infor~ation dated Ju~y 28, 1976 . l '

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This information enables Wes ti'nghcuse 1to: I . ~1 '

(a) De,·elop test inputs and proced1Jre!~ to satisfactorily

·vei·ify the design of Westinghouse! suppl:ied equipllient.

I (b) As~ist its customers to obtai~ lic~enses.

Further, the information has

as fo 11 ows:

\ substa~tic:\1 corr:rnercial value

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(a) Westinghouse can sell the use of t1'.his information to

customers. \ I I

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(b) Wcstin•;hous<;? uses the information to verify the design

: of equipment \'thich is sq1d to customers~ •. I'

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(c) Westinghouse ~an se11 testing servit~s tascd upon the f

the test equipment and methods· experiance gained an~

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developed. · I . Public disclosure of this info~ation is ~itely-to caus•

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subst~ntia~ harm to the cor.lpetitive positi·on·of Westinghouse

because it \·1ould. enhance the ability of c mpetitors to de­

_sig~, manuf~cture, ·verify, and sell_ elec1:1~ic•1 equipment for cor.1merci a 1 power -re~ctors without co;.:\;1e:nsura te expenses.

Also, public disc'losUre of the infcrmottOh 1·1oul.d enable

others having the s a;:e or s im.il a r equ i p:;;e~t !o use the in for­

mation to meet HRC requir~ents fpr licenbing documentation

without purchasing the right to use the tlnfomat.ion.

The devel'•pment of the equipment descriliid tr. part by the information is the result of ~any years 1pf d~v::iopr.ient by

Westingho~sc and the expenditure of a cahsid2rable sum of

money.

This could only be duplicated by a compeltitcr if. he were . I

to "invest similar sums of money and provtidcd r2· had the . I

~:~~t:~~~::~ailable and could rme~~ ~ain the

Further the deponent sayeth not. \

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