ML20058E347
| ML20058E347 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 08/22/1990 |
| From: | Wiesemann R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19310C816 | List: |
| References | |
| CAW-90-067, CAW-90-67, NUDOCS 9011070140 | |
| Download: ML20058E347 (18) | |
Text
{{#Wiki_filter:,- 4 e i\\ Westinghouse Energy Systems na ass l Electric Corporation h"5be rm*a man cass t I August 22, 1990 CAW 90 067 Document Control Desk US Nuclear Regulatory Commission Washington, DC 20555 Attention: Dr. Thomas Hurley, Dirnetor APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBl1C DISCLOSURE
Subject:
" Median Signal Selector for Westinghouse 7300 Series Process _ Instrumentation - Application to Westinghouse Three Loop Plants Employing the RTD Bypass Elimination Alabama Power Company - Joseph M. Farley Unit 1"
Dear Dr. Murley:
The proprietary information for which withholding is being requested in the above referenced letter is further identified in Affidavit CAW 90 067 signed by the owner of the proprietary information, Westinghouse Electric Corporation. The affidavit, which accompanies this letter, sets forth the basis on which the i i information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.790 of the Commission's regulations. 1 Accordingly,. this letter authorizes the utilization of the accompanying Affidavit by Alabama Power Company. Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-90 067, and should be addressed to the undersigned. Very truly yours, 1 l / / R r1 . Wiese nn, Manager i Enclosures RhytAa ory & Legislative Affairs cc: C. M. Holzle, Esq. Office of the General Counsel, NRC V. Wilson, NRR 9011070140 901026 ADOCK O$00g 8 DR
L '. \\; CAW 90-067 j U. AFFIDAVIT ) COMMONWEALTH OF PENNSYLVANIA: ss i COUNTY OF ALLEGHENY: Before me, the undersigned authority, personally appeared 'R'obert'A. Wiesemann, who, being by me duly sworn according to law, deposes and says that he is' authorized to execute 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 knowledge. information, and belief: g %W NYOAMfAtu Robert A. Wiesemann, Manager Regulatory and Legislative Affairs 7 Sworn to and subscribed o-before me this 73 day L of d o e u d',' 1990. 3 1% v ( l l l S- -C &ld ( 8 $ .u f_ e Notary Public .c 1 i NOT ARJ.L $E AL LORRM4E M PiPUCA, NOTARY PUBLIC MONROEVILLE 00RO. ALLEGHENf COUNTY MY COMM:$$ ION EXPIRES DEO 14. iM1 Member, P6msy'vaw /muMn el N;'att
q ! CAW 90 067 l I (1) I am Manager, Regulatory and Legislative Affairs, in the Nuclear and Advanced Technology Division, of the Westinghouse Electric Corporation and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rulemaking proceedings, and am authorized to apply for its withholding on behalf of the ' Westinghouse Energy Systems Business _Vnit. (2) I am making this Affidavit in conformance with the provisions of 10CFR Section 2.790 of the Commission's regulations and in conjunction with the 1 Westinghouse application for withholding accompanying this Affidavit. i (3) l-have personal knowledge of the criteria and procedures utilized by the 3 Westinghouse Energy Systems Business Unit in designating information as a l trade secret, privileged or as confidential commercial or financial information, .t 1 L '(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.790 of the + l 3 Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld. l; (1) The information sought to be withheld from public disclosure is owned L and has been held in confidence by Westinghouse, m l 6 - ~ _ -.
e b CAW 90 067 i i (ii) The information is of a type customarily held in confidence by 1 Westinghouse and not customarily disclosed in the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouse pol cy 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 j result in the loss of an existing or potential competitive advantage, as follows: (a) The.information reveals the distinguishing aspects of a L process (or component, structure, tool, method, etc.) where prevention of.its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over'other companies. (b) It consists of_ supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimintion or improved. marketability. L k i
! '.a j o. n. 4-CAW 90 067 t 1 (c) Its use 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 a similar product. (d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of ] Westinghouse, its customers or suppliers. 9 i (e) It reveals aspects of past, present, or future Westinghouse or customer funoed development plans and programs of .m .n potential commercial value to Westinghouse. 1 (f) It contains patentable ideas, for which patent protection may be desirable. l (g) It is not the property of Westinghouse, but must be treated as proprietary by Westinghouse according to agreements with the owner. p There are sound policy reasons behind the Westinghouse system which include the following: t u ~y i 7 (a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors, g' It is, therefore, withheld from disclosure to protect the Westinghouse competitive position. 1 i k g e . - ~ ,I
i -5 CAW-90 067 1 i J (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 Westinghouse at a competitive disadvantage by reducing his expenditure of i' resources at our expense. (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable f as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving l Westinghouse of a competitive advantage. i l (e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those i countries, t (f) The Westinghouse capacity to invest corporate assets in l, research and development depends upon the success in R obtaining and maintaining a competitive advantage.
j F r / 1 6-CAW 90 067 r (iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10CFR Section 2.790, it is to be received in confidence by the Commission. (iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief. y (v) The proprietary information sought to be withheld in this submittal is that which is. appropriately marked in " Median Signal Selector for. Westinghouse 7300 Series Process Instrumentation - Application to Westinghouse Three Loop Plants Employing the RTD Bypass Elimination for - Alabama Power Company -'J. M. Farley Unit 1", WCAP 12675, (Proprietary) for J. M. Farley Unit 1, being transmitted by l. the Alabama Power Company (APCo); letter and Application for Withholding-Proprietary Information from Public Disclosure, Mr. W. G. Hairston 111, APCo, to Document Control Desk, to the Attention Dr. Thomas Murley, August, 1990. The proprietary information as submitted for use by Alabama L Power Company for the J. M. Farley Unit 1 is expected to be applicable.in other licensee submittals in response to certain NRC requirements for-justification of use of the median signal selector in RTD Bypass Elimination applications. I
( y h c- ' CAW 90 067 4 This information is part or that which will enable Westinghouse to: (a) Provide documentation of the licensing basis for use the median signal selector in RTD Bypass Elimination application. (b) Provide documentation of the plant operability improvements achieved through the addition of the median signal selector function to the process control system. (c) Provide documentation of utility advantages achieved [ through the addition of the median signal selector function to the process' control system. (d). Provide documentation of the elimination of the system L interaction mechanism and fault tolerant features available when implementing the' median signal selector as part of RTD Bypass elimination. (e)~AssistthecustomertoobtainNRCapproval. h ' Further this information has substantial commercial value as follows: Yu (a). Westinghouse plans to sell the use of similar 1 information to its customers for purposes of - satisfying NRC requirements for licensing documentation, k
l o . CAW 90 067 1 (b) Westinghouse can sell sup) ort and defense of the this licensing basis and technology to its customers to support the licensing process. Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar instrumentation and control and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information. t i The development of the technology described in part by the information is the result of applying the results of many lL years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money, in order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended c L for developing the licensing basis and suitable equipment to perform the median signal selector function, further the deponent sayeth not. l: l l
Proprietary Information Notice Transmitted herewith are propriotary and/or non proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval. In order to conform to the requirements of 10 CFR 2 90 of the Commission's regulations concerning the protection of proprietar information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets and where the proprietary information has been deleted in the non proprietary versions on the brackets remain, the information that was contained within brackets and where the proprietary information has been deleted in the non proprietary versions only the brackets remain, the information that was contained within the brackets in the proprietary versions having been deleted. The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case ' letters (a) through (g) contained within parentheses located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds:in confidence identified in Sections (4)(ii)(a) through (4)(ii)(g) of the affidavit accompanying this transmittal. pursuant to 10 CFR 2.790(b)(1). i F i .\\ t m 9 1 i ~ i
o i Copyright Notice p The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.790 regarding restrictions on public disclosure to the l extent'such information has been identified as proprietary by Westinghouse, -copyright protection not withstanding. With respect to the non proprietary versions of these reports, the NRC is permitted to make the number of copies l i beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. The NRC is not authorized to make copies for the personal use of members of the public who make use of the NRC public document rooms. Copies made by the NRC must include the copyright notice in all. instances and the proprietary notice if the original was identified as proprietary. )
,3 s I ,,..u.,t 'j ATTAC5NENT 4 g s.i. o. N2 r, t- ? _ W
- VCAP-12694
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{ l i ATTACilNDrr 5 i i EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION l j h -1 .I f.. v-s i .1
r q EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION Pursuant to the requirements in 10 CPR 50.92, each application for amendment to operating license must be reviewed to determine if the modification involves a significant hazard. The proposed amendment involves an increase in equivalent steam generator tube plugging, a decrease in reactor coolant flov, and removal and replacement of the existing Resistance Temperature Detector (RTD) bypass manifold temperature measurement system with fast response RTDs located in the reactor coolant piping. The proposed amendment involves the following technical specification changes. The DNB parameters for Reactor Coolant System (RCS) flow and RCS have been modified. The revised RCS flovrate includes an approximate T' M reduction and also a 2.2% calculated flow uncertainty. l The RCS T has been raised to include the additional calculated uncertainty (4.3* P versus 4.0*F) using the statistical setpoint methodology. Core limits have been revised to include the effects of the 1.5% flow reduction. Allovable values for overpower 6T (OP6T), overtemperature AT (OT6T), loss of flov, low-lov [for P-12 (increasing and decreasing), as well as and T, ling safeguards actuation on coincident high steam flov and low-lov enginee j have been modifled to include additional margins gained by the T,Sointmethodologycalculations. se Modifications to the OPAT/0 TAT equations resulted from the proposed RTD bypass elimination and tube plugging efforts. These include a reduction in the K1 term (constant in the OTAT equation) to afford protection for the revised core limits. Additional dynamic compensations were added to the equation to more fully describe the as-installed hatdvare. Although.these dynamic functions are set to have no dynamic effects, they are included to provide complete compatibility with the accident analyses. The OTAT reactor trip response t2me was increased to account for the new hardware configuration (i.e., RTD element and well versus RTD element only). Several-bases were modified to account for the RTD bypass elimination. The bases for the amendment as described in VCAP-12694, " Alabama Power Company Joseph M. Farley Unit 1 Increased Steam Generator Tube Plugging and Reduced Thermal Design Flov Licensing Report," and VCAP-12614, Revision 1, "RTD Bypass Elimination Licensing Report for J.-M. Farley Nuclear Plant Units 1 and 2," has been reviewed and deemed not to involve a significant hazard based on the following evaluation. The proposed amendment involves an increase in equivalent plugging limits from the current licensed value of 10% uniform plugging to a nev licensed value of 15% average with a 20% peak in any one steam generator. Also included is a decrease of approximately 1.5% in Reactor Coolant System total flovrate from the current licensed value of 265,500 gpm to a nev ' analysis value of 261,600 gpm. In addition, calculations for flow uncertainty have reduced the current flow uncertainty value of 3.5% to a j new value of 2.2%. The new technical specification _value is therefore 267,400 gpm, which includes an approximate 1.5% reduction and a 2.2% increase to account for the new flow uncertainty. As discussed in VCAP-12694 and VCAP-12614, Revision 1, a comprehensive evaluation of the effects of the increased tube plugging, reduced RCS flovrate, and RTD . Bypass Elimination (RTDBE) has been completed, and no adverse safety implications have been identified, t i l
t i k The proposed amendment-also involves removing and replat.ing the existing-RTD bypass manifolti system with f ast response RTDs located in the reactor 3 -coo ant hot leg and cold leg piping. The original RTD bypass system l utilized an arrangement which directs a sample of the RCS flow from the main coolant piping to.an independent temperature measurement manifold. Vith the proposed system, the hot leg temperature measurement on each loop vill be. accomplished with three fast response, narrow range, dual element RTDs mounted in thermovells. To accomplish the sampling function of the RTD bypass manifold system and minimize the need for additional hot leg ydoing penetrations, the thermovells vill be located within the three existing RTD bypass manifold scoops wherever possible. If plant inter-ferences preclude the placement of a thermovell in a scoop, then the scoop vill be capped and a nev penetration made to accommodate the thermovell. These three RTDs accomplish a sampling function to measure the average hot leg temperature which is used to calculate the reactor coolant loop . differential temperature (6T) and average temperature (T,,,). Cold leg temperature is taken by means of one fast response, narrow range, dual-element RTD located in each cold leg at the discharge of the Reactor - Coolant Pump (RCP). This RTD vill replace the cold leg RTDs located in the bypass manifold. Temperature streaming in the cold leg is not a concern due to the mixing action of the RCP. For this reason, only one RTD is required.- This RTD vill measure the cold leg temperature which is used to calculate reactor coolant loop 6T and T,y. To assure that the functional capability and inherent reliability provided in the original Reactor Protection System design are not compromised, a Median Signal Selector (HSS) is' implemented in the Reactor Control System for receiving reactor coolant temperature information. The function of the signal selettor is to eliminate the' potential for a control and protection system interaction mechanism involving the Reactor Control System and the thermal overpower and overtemperature protective functions in accordance U with-the' requirements of the Institute of Electrical and Electronics Engineers Standard, IEEE Standard 279-1971, " Criteria for Protection l[ Systems for Nuclear-Power Generating Stations," Section 4.7. Installation.of a fast response; system which measures loop temperature via thermovell-mounted RTDs protruding into the' main reactor coolant flow will eliminate the bypass piping network and operating obstacles associated with ,U the bypass system (such as leakage:through valves,-flanges, etc., and radiation exposure during maintenance). Conformance of the proposed amendments'to the standards for a determination of no significant hazard as defined in.10 CFR "S. M is shown in the followingr 1) Operation of Parley Unit 1 in accordance with the proposed license amendment does not involve a significant increase in the probability or consequences =of an accident previously evaluated..
The use of fast response RTDs, increased tube plugging, and decreased RCS thermal design flow do not involve a significant increase in the probability or consequences of any accident previously evaluated. The non-LOCA and LOCA accidents were reviewed in VCAP-12694 and VCAP-12614, Revision 1, verifying that the increased tube plugging and decreased flovrate and the variations in uncertainty associated with certain reactor trip functions were acceptable. 't was concluded that I an increase in RCS temperature uncertainty, increased tube plugging, and decreased RCS flovrate can be accommodated by margins in the safety analyses to acceptance criteria limits and allocation of generic DNB margin. Certain non-LOCA accidents (Main Feedvater Pipe Rupture, Uncontrolled Bank Vithdraval From Suberitical, Partial Loss of Flov, Single Reactor Coolant Pump Locked Rotor, Steam Cencrator Tube Rupture) were reanalyzed using the revised conditions associated with increased tube plugging and reduced RCS flovrate and RTDBE, and acceptable results were obtained. For those remaining non-LOCA accidents for which evaluations i vere performed, acceptable results were obtained by use of existing margins, or allocation of generic DNB margin. In addition, effects of asymmetrical flow distributions have been evaluated and found acceptable. The most limiting Large Break LOCA analysis (C -0.4) was reanalyzed for thenewconfiguration,andtheanalysisdemonsIratedacalculatedPCT .l cless than the Appendix K limit of 2200'F. Evaluations of Small Break LOCA, LOCA hydraulic forcing functions, post-LOCA long-term core i ' cooling, and hot leg switchover to prevent boron precipitation were performed, and all current conclusions for Farley Unit I remain valid. ! valuations of Hain Steam Line Break (MSLB) and LOCA mass and energy Ereleases concluded the present mass and energy releases are applicable and the containment responses remain valid and all licensing . conclusions remain valid.
- Evaluation of the modification to the Reactor Coolant System pressure boundary has been performed. and no degradation in integrity is involved.
In addition, a' detailed assessment of the effects of ,o increased steam generator tube plugging and reduced RCS thermal design j . flow on major nuclear steam supply-equipment has shown that all acceptance criteria are still met. 1 The above evaluations and analyses support the conclusion that the increased steam generator tube plugging, reduced RCS flovrate, and RTD Bypass Elimination do not involve a significant increase in the probability'or consequences of an accident previously evaluated. l 2) The proposed license amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated. 1 Neither the increased tube plugging nor the reduction in RCS thermal design flov-creates the possibility of a new or different kind of accident from any accident previously evaluated. These effects were i
t reviewed in detail in VCAP-12694 for any adverse effects on RCS components. Major Nuclear Steam Supply System components [i.e., the reactor vessel, internals, loop piping, reactor coolant pump, pressurizer, and the Control Rod Drive Mechanisms (CRDHs)] were reviewed, and no adverse safety effects were found. No new single failures or accident initiators were found. Since increased tube plugging can physically alter the steam generator, the possible effects on the steam generator were evaluated in detail. The results of thermal and hydraulic evaluation, U-bend tube vibration assessment, and the structural evaluation have concluded that the current components of j the Farley Unit 1 steam generators satisfy the requirements of the ASME ] Boller and Pressure Vessel, Section III for the increased tube plugging and reduced RCS flovrate. In addition, the use of fast response RTDs 'does not create the possibility of a.new or different kind of accident from any accident previously evaluated..The three dual element hot leg RTDs and one dual element cold leg RTD vill utilize the existing penetrations, whenever possible, into the RCS piping from the bypass r system with only slight modifications. Caps and velds sealing the croFsover leg bypass return noEEle and piping, as well as the modification and velding for the existing penetrations, vill be qualified in accordance with the ASHE code, thus precluding the possibility for a new or different kind of accident. The function of the 6T/T protection channels is not changed because n of the bypass elimination., The newly installed fast response RTDs perform the same function in both T n'and T applications. The I three T signalsareelectronicalIyaverag,8g Dual element RTDs are j e. installe8g in the hot and cold legs..Should one RTD element fail, the spare e.lement can be connected. In addition, the average T dgnal 3 canbeelectronicallybiasedtoatwoRTDaverageshouldone,hualRTD fail..The measured temperature values vill still serve as input to 'two-out-of-three voting logic for protection functions. The Median Signal Selector (HSS) vill eliminate the potential for control and 1 protection interactions for all 6T/T applications. The basis for j the instrumentation and control desigE/ meets the criteria of applicable j LIEEE standards, regulatory guides, and general design criteria in that J such principals as-electrical. separation, seismic and environmental' I qualification, and single failure criteria.are satisfied. Therefore, there is no possibility of a new or different kind of accident as a result of the instrumentation aspects of RTD Bypass Elimination.- l l 1 3) The proposed license amendment does not involve a significant reduction l in a margin of safety. l l l The effeet of increased tube plugging, decreased RCS flovrate, the j response time, setpoint uncertainty, and temperature and flov measurement uncertainty does not involve a significant reduction in a margin:of. safety. These changes have been evaluated and compared to the acceptance-limits vith respect to the fuel, RCS pressure boundary, and. containment. All acceptance limits continue to be met. 4 I ! y ? ( - .j \\; j
[ v The evaluation of the effect of these variables on non-LOCA and LOCA transients has verified that plant operation vill be maintained within the bounds of safe, analyzed conditions as defined in the FSAR with the revised technical specifications, and the conclusions presented in the b, FSAR remain valid. Safe operation with revised core limits, a revised OToT K1 constant of 1.18, an approximate 1.5% reduction in thermal design flov, a 2.2% flow uncertainty, and an 0.3'F increase in temperature uncertainty has been demonstrated. In addition, component evaluations have been performed to demonstrate compliance to current acceptance critetla. As such, there is no significant reduction in the p margin of safety for operation of J. M. Farley Nuclear Plant Unit 1 4 with increased steam generator tube plugging, reduced RCS flovrate, and l: RTD Bypass Elimination. V '1 9 i U 1 F l -}}