ML19269C446
| ML19269C446 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 01/23/1979 |
| From: | David Williams ARKANSAS POWER & LIGHT CO. |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19269C447 | List: |
| References | |
| 2-019-15, 2-19-15, NUDOCS 7902020251 | |
| Download: ML19269C446 (5) | |
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ARKANSAS POWER & LIGHT COMPANY POST OFFICE BOX 551 LITTLE ROCK. ARKANSAS 72203 (501)371-4000 January 23, 1979 2-019-15 Director of Nuclear Reactor Regulation ATTN:
Mr. J. F. Stolz, Chief Light Water Reactors Branch #1 U. S. Nuclear Regulatory Commission Washington, D. C.
20555-
Subject:
Arkansas Nuclear One - Unit 2 Docket No. 50-368 License No. NPF-6 Environmental Qualification Test Report (File:
2-1510)
Gentlemen:
As committed in our letter of August 15, 1978, the following in-formation in regard to environmental qualificati~on of pressure transmitters is provided.
Attached are eight copies of "Nyle Laboratories Test Report No.
26304", Proprietary, 20 copies of "Nyle Laboratories Test Report No. 26304", Non-Proprietary, eight copies of " Supplement to Wyle Test Report No. 26304", Proprietary, and twenty copies of " Supplement to Wyle Test Report No. 26304", Non-Proprietary.
Certain information contained in the attachments is proprietary to Arkansas Power and Light Company.
Pursuant to 10 CFR 2.790, it is requested that this information be withheld from public disclosure.
Also in accordance with 10 CFR 2.790(b) it is recognized that with-holding this information from public inspection shall not affect the right, if any, of persons properly and directly concerned to inspect the information. The non-proprietary versions of all attached pro-prietary documents are attached.
In addition, tha affidavit specified by 10 CFR 2.790(b) is attached.
This information has been characterized as proprietary for one or more of the following reasons:
1.
The use of the information by the instrument manufacturers would substantially decrease their expenditures, in time and resources and could create an unfair and unwarranted competitive advantage.
2.
This information consists of test data and process methods, the application of which could result in an unfair and un-warranted competitive advantage to the transmitter manu-facturers.
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MEMOEF4 MiOOLE SOUTH UTILITIES SYSTEM
2-019-15 January 23, 1979 Mr. J. F. Stolz 3.
This information reveals special aspects of a process, method,
. component or the like, the use of which could result in an unfair and unwarranted competitive advantage to the trans-mitter manufacturers.
The pages containing proprietary information have been so indicated.
Please contact us if you have any questions regarding the proprietary nature of this material.
Very truly yours,
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Daniel H. Williams Manager, Licensing DHW:JTE:vb Attachment
AFFIDAVIT PURSUANT TO 10 CFR 2.790 Arkansas Power and Light Company
)
State of Arkansas
)
County of Pulaski
)
SS.:
I, D. A. Rueter, depose and say that I am the Director, Technical and Environmental Services, of Arkansas Power and Light Company, duly authorized to make this affidavit, and have reviewed or caused to have reviewed the infor-mation which is identified as proprietary and referenced in the paragraph immedi-ately.below.
I am submitting this affidavit in conformance with provisions of 10 CFR 2.790 of the Commission's regulations for withholding this information.
The information for which proprietary trehtment is sought is contained in the following documents:
"Wyle Laboratories Test Report No. 26304"
" Supplement to Wyle Test Report No. 26304" I have personal knowledge of the criteria and procedures utilized by Arkansas Power and Light Company in designating information as a trade secret, privileged or as confidential commercial or financial information.
Pursuant to the provisions of paragraph (b) (4) of Section 2.790 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure, included in the above referenced documents, should be withheld.
1.
The information sought to be withheld from public disclosure is the results and supporting data of the Environmental Testing performed on Rosemount and Foxboro Pressure Transmitters.
2.
The information consists of test data and evaluations of test results, the use of which could result in unfair and unwarranted
competitive adva'ntages of the suppliers and commercial position as related to their buyers.
3.
The information is of a type customarily held 'in confidence by Arkansas Power and Light Company and not customarily disclosed to the public. Arkansas Power and Light has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a procedure to determine when and whether to hold certain types of information in confidence. This procedure was applied in determining that the subject documents herein are proprietary.
4.
The information is being transmitted to the Nuclear Regulatory Commission in confidence under the provisions of 10 CFR z.790 with the understanding that it is to be received in confidence by the Commission.
5.
The information, to the best of my knowledge and belief, is not available in public sources, and any disclosure to third parties has been made pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence.
6.
Public disclosure of the information is likely to cause substantial harm to the commercial position of buyers of the tested equipment because:
a.
Similar products are manufactured and sold by major competitors to the manufacturers of these transmitters.
b.
Development of this information by AP6L required hundreds of man-hours of effort and thousands of dollars. To the best of my knowledge and belief, the transmitter manufacturers would have to undergo similar expense in generating equivalent information.
In o'rder to acquire such information, the manufacturer c.
would also require considerable time and inconvenience in accumulating equivalent data to support the degree of Environmental Qualification presented in this report.
d.
This information required significant effort and expense to obtain the licensing approvals necessary for appli-cation of the information. Avoidance of this expense could result in unfair and unwarrcnted competitive ad-vantages by selected manufacturers.
The information consists of data supporting qualification e.
testing of these instruments to NRC requirements. Availability of this information to the manufacturers could enable manufacturers to charge substantial amounts for this quali-fication information to buyers of the transmitters.
f.
Significant expenditures due to research, development, engineering, analytiedl, licensing, quality assurance and other costs and expenses are included. The ability of manu-facturers to utilize such information without similar ex-penditure of resources may result in an unfair and un-warranted competitive advantage.
Further th'e deponent saith not, ea D. A. Rueter Director, Technical and Environmental Services Sworn to before me this at\\-tg day of WM tC Notary Public My commission expires D N7.,
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i Supplement To Wyle Test Re po r t #26304 Environmental Qualification Test Repor t on Foxboro Model EllAH, P&P Model 50EP1041 and 13D2496 and Rosemount Model ll53GA9 Transmitters 4
TABLE OF CONTENTS DESCRIPTION PAGE Scope 3
Acceptance Criteria 3
Performance Calculations 4
Post LOCA Inspection and Recommendations 7
Summary 7
Fig. 1 Foxboro Model EllAH Performance Curves Fig. 2 Foxboro Model EllAH Radiation Errors Fig. 3 Foxboro Model EllAH LOCA Errors Fig. 4 Foxboro Model EllAH LOCA-Er ror s (continued)
Fig. 6 P&P 50EP1041 Performance Curves Fig. 11 P&P 13D2496 Performance Curves Fig. 16 Rosemount ll53GA9 Per formance Curves Fig. 17 Rosemount ll53GA9 Radiation Errors Fig. 18 Rosemount ll53GA9 LOCA Errors Fig. 19 Rosemount ll53GA9 LOCA Errors (continued) 2 A
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Scope:
e Discuss the basis for specified acceptance criteria. Analyze test data supplied by Wyle and compare with specified acceptance criteria to determine whether or not the subject transmitters performed within the acceptance limits.
Acceptance Criteria:
The acceptance criteria are included in the Bechtel test procedure 6600-M-2308, Rev. I and are restated on page six of this supplement.
This procedure is included in the Nyle test report as Appendix I.
The performance limits were established separately for the trip functions and the long term post-accident monitoring (PAM) function. The selection of the allowable errors in providing the trip functions is based on the set point adalyses for the ANO-2 design basis accident (Large Break LOCA) as defined in the ANO # 2 FSAR.
A.
Foxboro Transmitters:
Foxboro EllAH transmitters are used to provide both the high and high-high containment pressure trip signals and the long term post-accident monitor-ing (PAM) signals.
The high-high containment pressure trip signal is generated within 5 seconds after a loss of coolan t accident (LOCA). A test period of 30 days reflecting current industrial practice was arbitrarily chosen for the post-acciden t monitor ing se':vice.
4 B.
F&P Transmitters:
The Fischer and Porter (F&P) Model 50EP1041 transmitter is used to provide pressurizer and steam generator (S.G.) pressure trip signals and longterm post accident monitoring functions. The Model 13D2496 is used to provide steam generator level tr ip signal and post accident monitoring f unctions.
3 0
t
C.
Rosemount Transmitter:
To qualify the Rosemount Model ll53GA9 transmitter as a replacement for the Foxboro and/or P&P transmitters, it must meet the more stringent of the above criteria established for Foxboro and F&P Transmitters.
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Performance Calculations The following performance calculations are based on the attached per-formance curves, Figures 1 thru 4 (Foxboro EllAH), Fig. 6 (f & P 50EP1041),
Fig. 11 (F&P 13D2496) and Fig. 16 thru 19 (Rosemount ll53GA9). As an added conservatism higher than required radiation exposure, greater number of OBE's (five instead of one required by the acceptance criteria) and longer periods of LOCA simulation (35 to 70 seconds instead of the 5 and 60 ser nds respectively required by the acceptance criteria) are used in these actual performance calculations.
It should be noted that the F&P Model 13D2496 was not tested under simulated post LOCA conditions for reasons listed in the Wyle report.
The P&P Model 50EP1041 produced erratic output after 10 minutes of simulated LOCA testing. See Wyle report for additional details. Due to other operating limitations it was decided to replace the P&P units, therefore the F&P test data was not analyzed.
Seismic / Vibration Effects enum 4
In the following error analysis, all errors are calculated from devia-tions compared to the immediately preceding performance curve, i.e.,
LOCA error is the deviation observed from the expected output for identical input as represented by the pre-LOCA performance curve.
For Foxboro, this will be curve #6 on Fig.
1.
Foxboro EllAH Trtasmitter See Figures 2 and 3 for radiation and LOCA errors.
1 A.
Containment Trip Function:
See Figures 16 thru 19.
5
1 C.
Post Accident Monitoring:
Error Summ _arv m
Function Accegance Criterid Actual Performance 4
6
As seen above, the Foxboro transmitter meets the containment trip function criterion and PAM criteria up to 12 days of operation following a LOCA. In addition, the transmitter is capable of surviving the 30 days LOCA test as discussed in the Wyle report, Section 6.5.4.3.
Rosemount transmitters can be used in lieu of Foxboro instruments to provide the containment pressure trip signal, if desired. As seen above, the Rosemount transmitter meets the acceptance criterion for this func-tion. In addition, Rosemount transmitter performance is within the accept-ance criteria for providing S.G.
and pressurizer pressure and S.G.
level trips. It also meets the post acciden t monitoring acceptance criterion.
Post LOCA Inspection and Recommendations:
Please refer to Section 6.5.4 of Wyle Test Report for details of inspection findings.
To insure that any significant insulation damage caused by mechanical handling is discovered it'is recommended that a megger test from trans-mitter to control room terminals be conducted on Foxboro installations to establish that no insulation bceakdown has occurred.
The Rosemount transmitter performed within the tolerances established by the acceptance criteria despite a small amount of leakage.
The leakage may have been the result of (1) the mismatch between the cylindrical threads on the transmitter conduit entry and NPT threads on the short nipple between the transmitter and the coupling and/or (2) dissimilar metals (transmitter housing is stainless steel and the nipple was carbon steel) and the resultant dif ferential thermal expansion. It is recommended that all the interfacing parts be of similar metal, i.e.,
stainless steel.
(On ANO-2 actual installation includes a stainless steel nipple). A pro-perly tightened mismatched thread connection would probably not result in leakage.
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Summary In summary, the Foxboro Model No. EllAH and Rosemount Model #1153GA9 meet the performance specifications for the ANO-2 PAM and trip functions.
No data analysis has been done regarding the F&P Model 50EP1041 and 1302496 transmitters.
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