BECO-88-026, Forwards GE Proprietary Rept, Tech Spec Improvement Analysis for Reactor Protection Sys for Pilgrim Nuclear Power Station, Supporting Proposed Changes to Tech Spec Tables 3.1.1 & 3.2.A.Rept Withheld (Ref 10CFR2.790(b)(1))

Forwards GE Proprietary Rept, Tech Spec Improvement Analysis for Reactor Protection Sys for Pilgrim Nuclear Power Station, Supporting Proposed Changes to Tech Spec Tables 3.1.1 & 3.2.A.Rept Withheld (Ref 10CFR2.790(b)(1))

ML20196E394
Person / Time
Site:	Pilgrim
Issue date:	02/22/1988
From:	Bird R BOSTON EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML19341D992	List: BECO-88-026, Forwards GE Proprietary Rept, Tech Spec Improvement Analysis for Reactor Protection Sys for Pilgrim Nuclear Power Station, Supporting Proposed Changes to Tech Spec Tables 3.1.1 & 3.2.A.Rept Withheld (Ref 10CFR2.790(b)(1))
References
BECO-88-026, BECO-88-26, TAC-60465, NUDOCS 8803010067
Download: ML20196E394 (6)

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- Executive Offices 800 Boylston Street Boston, Massachusetts 02199 1

Ralph G. Bird Senior Vice President - Nuclear BECo 88-02 6 U. S. Nuclear Regulatory Commission February 22, 1988 Document Control Desk Hashington, DC 20555 License DPR-35 Docket 50-293 SUPPORTING INFORMATION FOR PROPOSED TECHNICAL SPECIFICATION CHANGES TO HQIES FOR TABLES 3.1.1 and 3.2.A (TAC #60465)

References:

1. Technical Specification Improvement Analysis for BWR Reactor Protection System, NEDC-30851-P

2. NRC Safety Evaluation for General Electric Company Topical Report; NEDC-30844, "BHR Owners Group Response to Generic Letter 83-28", and NEDC-30851-P, "Technical Spe:ification Improvement for BWR RPS", dated July 15, 1987.

This letter supplies additional information to our December 23, 1985 proposed Technical Specification change concerning the out-of-service time for testing and calibrating the Reactor Protection System and the Primary Containment Isolation System.

Attachment I addresses the PNPS plant-specific applicability of General Electric analysis NE0C-30851-P (Reference 1), as stipulated in the July 15, 1987 NRC letter to Mr. Terry A. Pickans, Chairman, BWR Owners Group (Reference 2).

Attachment 2 is a proprietary General Electric Company (GE) plant specific analysis performed to support BECo use of the GE analysis (Reference 1), and we request it be withheld from public disclosure in accordance with 10CFR2.790(b)(1).

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BOSTON EDISON COMPANY 1[.k[Nu'clearhegulakoryCommission Page 2 cc: Mr. D. G. Mcdonald, Project Manager Division of Reactor Projects I/II Office of Nuclear Reactor Regulation Mail Stop: 14D1 U. S.-Nuclear Regulatory Commission-1 Mhite Flint North 11555 Rockville Pike Rockville, MD 20852 U. S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 NRC Senior Resident Inspector Pilgrim Nuclear Power Station i

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Attachment 1 to BECo Letter 88- 026 Supporting Information for Proposed Technical Soecification Chanaes to Note i for Tables 3.1.1 and 3.2. A In Reference A, Boston Edison Company (BECo) proposed an amendment to Appendix A of Operating License No. DPR-35. The amendment establishes a six hour time limit for allowing Reactor Protection System (RPS) and Primary Containment Isolation System (PCIS) equipment to be out of service during testing and calibration. Section 5.7.1 of General Electric Company analysis NEDC-30851-P supports our proposed 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> out-of-service time for on-line RPS testing and calibration. He applied the same rationale in support of a 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> out-of-service time for on-line PCIS testing and calibration. On July 15, 1987 the NRC issued a Safety Evaluation Report (SER) (Reference B) for the GE analysis, and placed several conditions on the use of the generic analysis for individual plants. The following information supports Pilgrim Nuclear Power Station's (PNPS) use of the GE analysis, and addresses the NRC's conditions:

1. Cp_nfirm the aoolicabilitv of the aeneric analysis Proprietary GE report, "HDE-31-0286 Technical Specification Improvement Analysis for the Reactor Protection System for Pilgrim Nuclear Power Station," documents the generic analysis applies to PNPS and is provided as Attachment 2.

2. Demonstrate that drift characteristics of RPS instrumentation are bounded by the aeneric analysis assumptions HDE-31-0286 compared the PNPS RPS instrumentation configuration, including the recently installed BECo Analog Trip System (ATS), against the BHR generic model.

GE advised us that instrumentation drift was included for ATS equipment only, and is based on equipment vendor information. The drift data in the generiu analysis is applicable to PNPS.

HDE-31-0286 found either no plant specific difference between the instrumentation used at PNPS and the generic model, or, in cases where dfferences do exist, the differences do not affect the appplicability of the generic analysis to Pilgrim Station.

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3. Confi rm that the differences between those comoonents that oerform tr_ip functions in the base case olant and PNPS were included in the plant-soecific analysis i

! HDE-31-0286 shows the RPS configuration for PNPS has several differences l compared to the RPS configuration of the generic analysis, but the I

differences do not affect the applicability NEDC-30851-P to Pilgrim.

Therefore, our proposed change to technical specifications is supported by l

1 Section 5.7.1 of NEDC-30851-P.

References:

A. Boston Edison Company Letter 85-277, dated December 23, 1985

8. NRC Safety Evaluation for General Electric Company Topical Report; NEDC-30844, "BHR Owners Group Response to Generic Letter 83-28," and NEDC-30851-P, "Technical Specification Improvement for BHR RPS," dated July 15, 1987.

C. Technical Specification Improvement Analysis for BHR Reactor Protection System, NEDC-30851-P

6ENERAL ELECTRIC C0MPANY 8FFIDAVIT I, Ricardo Artigas, being duly sworn, depose and state as follows:

1. I am Manager,~ Licensing and Consulting Services, General Electric Company, and have been delegated the function of reviewing the information described in paragraph 2 which is sought to be withheld and have been authorized to apply for its withholding.

2. The information sought to be withheld is contained in the report entitled "Technical Specification Improvement Analyses for 'he Reactor Protection System for Pilgrim Nuclear Power Station," MDE-31-0286, September 1987, Revision 4.

3. In designating material as proprietary, General Electric 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 e secrecy of the information; (4) the value of the information to him and to his competitors; (5) the amount of effort or money expanded by him in developing the information; (6) the ease or difficulty with the 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 General Electric's competitors without license from General Electric 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 i application of which provide a competitive economic advantage, e.g., by optimization or improved marketability; I

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;

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

e. Information which reveals aspects of past, present or future General Electric customer-funded development plans and programs of potential commercial value to General Electric:

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

g. Information which General Electric must treat as proprietary according to agreements with other parties.

5. Initial approval of proprietary treatment of a document is typically made by the Subsection manager of the originating component, who is most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to such documents within the Company is limited on a "need to know" basis and such documents are clearly identified as proprietary.

6. The procedure for approval of external release of such a document typically requires review by the Subsection Manager, Project manager, Principal Scientist or other equivalent authority, by the Subsection Manager of the cognizant Marketing function (or delegate) and by the Legal Operation for technical content, competitive effect and determination of the accuracy of the proprietary designation in accordance with the standards enumerated above. Disclosures outside General Electric are generally limited to regulatory bodies, customers

, and potential customers and their agents, suppliers and licensees then only with appropriate protection by applicable regulatory provisions or proprietary agreements.

7. The document mentioned in paragraph 2 above has been evaluated in accordance with the above criteria and procedures and has been found to contain information which is proprietary and which is customarily held in confidence by General Electric.

8. The inform 1 tion to the best of my knowledge and belief has consistently been held in confidence by the General Electric Company, -

no public disclosure has been made, and it is not available in public sources. All disclosures to third parties have been made pursuant to regulatory provisions of proprietary agreements which provide for maintenance of the information in confidence.

9. Public disclosure of the information sought to be withheld is likely to cause substantial harm to the competitive position of the General Electric Company and deprive or reduce the availability of profit

making opportunities because it would provide other parties, including competitors, with valuable information concerning the application of previously developed reliability based methodology, which was developed at considerable cost to the General Electric Company.

STATE OF CALIFORNIA )

COUNTY OF SANTA CLARA ) ss:

Ricardo Artigas, being duly sworn, deposes and says:

That he has read the foregoing affidavit and the matters stated therein are trueandcorrecttothebestofhisknowgge,information,andbelief.

Executed at San Jose, California, thi b d of M ,198k.

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I RicardgArTjgas General Electric Company Subscribed and sworn before me this,2M day of / 198f. .

W NOTARY PUBLIC, STATE OF ( ALIFORNIA l .,_

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