ML20059E231
| ML20059E231 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 10/28/1993 |
| From: | COMMONWEALTH EDISON CO. |
| To: | |
| Shared Package | |
| ML19311B157 | List: |
| References | |
| NUDOCS 9311030135 | |
| Download: ML20059E231 (13) | |
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ATTACHMENT B TECHNICAL SPECIFICATION CHANGES FOlt LASALLE UNITS 1 AND 2
SUMMARY
OF PROPOSED CHANGES FOR LASALLE UNIT 1 Table 3.3.3-3, Item 1 Response time increased for LPCS Table 3.3.3-3, Item 2 Response time increased for LPCI Table 3.3.3-3, Item 4 Response time increased for HPCS Table 3.3.3-3, Footnote Stroke time increased for LPCS and LPCI Injection Valves i
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PDR ADOCK 05000373 k$)t P
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.TAELE 3.3.3-3 EMERGENCY CORE COOLING SYSTEM RESPONSE TIMES ECCS REa/0NSE TIME (Seconds) 1.
LOW PRESSURE CORE SPRAY SYSTEM 2.
LOW PRESSURE COOLANT INJECTION MODE OF RHR SYSTEM (Pumps A, B, and C) i4 60 3.
AUTOMATIC DEPRESSURIZATION SYSTEM NA 4.
HIGH PRESSURE CORE SPRAY SYSTEM 1(((
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LOSS OF POWER NA O
- Injection valves shall be fully OPE within 2 seconds after receipt of the reactor vessel pressure and ECCS Injection Line Pressure Interlock signal-concurrently with power source availability and receipt of an accident initiation signal.
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LA SALLE - UNIT 1 3/4 3-31 Amendment 10 6
SUMMARY
OF PROPOSED CHANGES FOR LASALLE-UNIT 2 -
i Table 3.3.3-3, Item 1 Response time increased for LPCS Table 3.3.3-3, Item 2 Response time increased for LPCI -
Table 3.3.3-3, Item 4 Response time increased for HPCS t
Table 3.3.3-3, Footnote Stroke time increased for LPCS and LPCI Injection Valves I
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TABLE 3.3.3-3
' EMERGENCY CORE COOLING SYSTEM RESPONSE TIMES ECCS RESPONSE TIME (Seconds) 1.
LOW PRESSURE CORE SPRAY SYSTEM 2.
LOW PRESSURE COOLANT INJECTION MODE OF RHR SYSTEM (Pumps A, B, and C) 4 3.
AUTOMATIC DEPRESSURIZATION SYSTEM NA 4.
HIGH PRESSURE CORE SPRAY SYSTEM
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LOSS OF POWER NA 40
- In.lection valves snall be fully OPEN within 0 seconds after receipt of the reactor vessel pressure and ECCS Injection Line Pressure Interlock signal concurrently with power source availability and receipt of an accident initiation signal.
LA SALLE - UNIT 2 3/4 3-31
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ATTACHMENT C EVALHATION OF SIGNIFICANT HAZARDS CONSluEllATION Commonwealth Edison has evaluated this proposed amendment and determined that it involves no significant hazards considerations. According to 10 CFR 50.92 (c), a proposed amendment to an operating license involves no significant hazards considerations if operation of the facility in accordance with the proposed amendment would not:
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Involve a significant increase in the probability or consequences of an acci-dent previously evaluated; or 2.
Create the possibility of a new or different kind of accident from any accident previously evaluated; or 3.
Involve a significant reduction in a margin of safety.
The nronosed chances do not involve a sienificant increase in the probability or conse-guer:ces of an accident previousiv evaluated becsEg:
The probability of an accident previously evaluated will not increase as a result of this change, because the only modification being performed is to the stroke times fordhe LPCS, j
LPCI, and HPCS injection valves. Changing the opening or closing time of the injection I
valves for these ECCS systems does not cause any accident previously evaluated to occur.
j Therefore, modifying their stroke times will not increase the probability of occurrence for i
any accident previously evaluated.
The consequences of a LOCA are not significantly increased and do not exceed the previously accepted licensing criteria for this accident. GE has calculated the revised licensing basis PCT for LaSalle Station to be 1260F, which is well below the 2200F criterion of 10CFR 50.46 and Section 15.6.5 of NUREG-0800 (Standard Review Plan).
The acceptance criteria for cladding oxidation, metal-water reaction (hydrogen generation), coolable geometry and long-term cooling also continue to be met with the increased valve stroke times.
GE has performed sensitivity analyses justifying the continued applicability of previous analyses for Anticipated Transients Without Scram (ATWS), cor,tainment analyses, off-site dose (Main Steamline Break Outside Containment), and HPCS-related transients (Loss of Feedwater Flow). Other events are not affected because these systems are not assumed to function.
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'l The proposed changes do not create the possibility of a new or different kind of
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accident from any accident previously evaluated because.
The only modification is to increase the stroke time of the injection valves for LPCS, l
LPCI and HPCS. This does not result in any changed component interactions, other l
than to increase the affected ECCS response times. The injection valves will still pro-vide the function fbr which they were designed. Since the systems will continue to function as intended, the proposed changes do not create the possibility of a new or dif-fbrent kind of accident from any previously evaluated.
The proposed changes do not involve a significant reduction in a marcin of safety hecause:
While the calculated licensing basis PCT is larger than that previously calculated with the current valve stroke times, the new PCT remains far below the 2200 F licensing ac-ceptance limit associated with a LOCA. This limit has been previously evaluated as i
providing a sufriciem margin of safety. All other LOCA licensing limits also continue to be met with the increased stroke times. For other accidents and transients, the in-creased stroke times have a negligible effect on the results, so the' margin of safety is.
preserved.
CONCLUSION Guidance has been provided in " Final Procedures and Standards on No Significant Hazards Considerations," Final Rule, 51 FR 7744, for the application of standards to.
license change requests for determination of the existence of significant hazards considerations. This document provides examples of amendments which are and are not considered likely to involve significant hazards considerations. These proposed amendments most closely fit the example of a change which may either result in some increase to the probability or consequences of a previously analyzed accident or may reduce in some way a safety margin. but where the results of the change are clearly; within all acceptable criteria with respect to the system or component specified in the Standard Review Plan, section 15.6.5, Radiological Consequences of a Design Baals Loss-of Coolant Accident Including Containment Leakage Contribution.
This proposed amendment does not involve a significant relaxation of the criteria used to establish safety limits, a significant relaxation of the bases for the limiting safety system settings or a significant relaxation of the bases for the limiting conditions for.
operations. Therefore, based on the guidance provided in the Federal Register and the criteria established in 10 CFR 50.92 (c), the proposed change does not constitute a significant hazards consideration.
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ATTACHMENT D r
ENVIRONMENTAL ASSESSMENT STATEMENT APPLICABILITY REVIEW Commonwealth Edison has evaluated the proposed amendment against the criteria for identification oflicensing and regulatory actions requiring environmental assessment in accordance with 10 CFR 51.21. It has been determined that the proposed changes meet the criteria for a categorical exclusion as provided under 10 CFR 51.22 (c)(9). This con-clusion has been determined because the changes requested do not pose significant haz-ards consideration or do not involve a significant increase in the amounts, and no signifi-cant changes in the types, of any efliuents that may be released offsite. Additionally, this request does not involve a significant increase in individual or cumulative occupational radiation exposure.
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6 ATTACHAENT E i
GE LOCA ANALYSIS FOR LASALLE COUNTY STATION UNITS 1 AND 2 t
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.3 ATTACHMENT F -
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WITHHOLDING AFFIDAVIT t
i FOR GENERAL ELECTRIC LOCA ANALYSIS REPORT 1
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P GENERAL ELECTRIC COMPANY AFFIDAVIT I, ROBERT C. MITCHELL, being duly sworn, depose and state as follows:
(1)
I am Project Manager, Safety Evaluation Programs, General Electric Company ("GE") 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 GE proprietary report NEDC-32258P, "LaSalle County Station Units 1 and 2 SAFER /GESTR-LOCA Loss-of-Coolant Accident Analysis", Class III, dated October 1993.
This information is delineated by single bars marked in the margin adjacent to the specific material.
(3)
In making this application for withholding of proprietary information of which it is the owner, GE relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552 (b) (4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17 (a) (4), 2.790 (a) (4), and 2.790 (d) (1) for " trade secrets and commercial or financial information obtained from a person and privileged or confidential" (Exemption 4).
The material for which exemption from disclosure is here sought is all " confidential commercial information",
and some portions also qualify under the narrower definition of " trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Enerav Proiect v. Nuclear Reculatory Coramission. 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Groun v. FDA, 704F2d1280 (DC Cir.
1983).
(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, including supporting data and analyses, where prevention of its use by General Electric's competitors'without license from General Electric constitutes a competitive economic advantage over other companies; 1
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. b.
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; c.
Information which reveals cost or price information, production capacities, budget levels, or commercial strategies of General Electric, its customers, or its suppliers; d.
Information which reveals aspects of past, present, l
or future General Electric customer-funded development plans and programs, of potential commercial value to General Electric; e.
Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.
The information sought to be withheld is considered to be proprietary for the reasons set forth in both paragraphs (4)a. and (4)b., above.
(5)
The information sought to be withheld is being submitted to NRC in confidence.
The information is of a sort customarily held in confidence by GE, and is in fact so held.
Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as' set forth in (6) and (7) following.
The information sought to be withheld has, to the best of my-knowledge and belief, consistently been held in confidence by GE, no public disclosure has been made, and it is not available in public sources.
All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence.
(6)
Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge.
Access to such documents within GE is limited on a "need to know" basis.
(7)
The procedure for approval of external release of such a i
document typically requires review by the. staff manager,
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project manager, principal scientist or other equivalent j
authority, by the manager of the cognizant marketing _
function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of i
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, c 3-the accuracy of the proprietary designation.
Disclosures outside GE are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.
(8)
The information identified in paragraph (2) is classified as proprietary because it contains detailed results of analytical models, methods and processes, including computer codes, which GE has developed, obtained NRC approval of, and applied to perform evaluations of the loss-of-coolant accident for the BWR.
The development and approval of the loss-of-coolant accident computer codes used in this analysis was ac?icved at a significant cost, on the order of several millit" dollars, to GE.
The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GE asset.
(9)
Public disclosure of the information sought to be withheld is likely to cause substantial harm to GE's competitive position and foreclose or reduce the availability of profit-making opportunities.
The information is part of GE's comprehensive BWR safety and technology base, _and its commercial value extends beyond the original development cost.
The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process.
In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.
The research, development, engineering, analytical, and NRC review costs comprise a substantial investment of time and money by GE.
The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.
GE's competitive advantage will be lost if its competitors are able to use the results of the GE experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.
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-4 The value of this information to GE would be lost if the information were disclosed to the public.
Making such i
information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provida competitors with a windfall, and deprive GE of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing these very valuable i
analytical tools.
STATE OF CALIFORNIA
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COUNTY OF SANTA CLARA
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Robert C. Mitchell, 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.
Executed at San Jose, California, this b day of O c tr yrl, 19D b 9 C "S LA S
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Robert C. Mitchell General Electric Company 1
Subscribed and sworn before me this day of hd2ff, 199_3 I
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f Notary Public, State ef California OFFICIAL SEAL PAULA F. HUSSEY f
fJO70W PUD 4 - CALTORNIA (
MNTA ClAPA COUNW l
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My comtn. ex:: ires APR 5,1994 1
10/14/93RTH
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