ML20077G999

Proposed Tech Specs Modifying HPCI Turbine Steam Exhaust Line

ML20077G999
Person / Time
Site:	Quad Cities
Issue date:	06/28/1991
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML19302E721	List: ML20077G995 ML20077G999
References
NUDOCS 9107030315
Download: ML20077G999 (25)

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ATTACilMENT 3 REVISED PAGES FOR PROPOSED CHANGES TO APPENDIX A, TECHNICAL SPECIFICATK)N TO QUAD CmES STATION UNIT 2 FACILITY OPERATING LICENSE, DPR-30 Page 3.2/4.2 6a 3.2/4.2 7 3.2/4.2 8 3.2/4.2 11 3.2/4.2 11 a 3.7/4,7 21 3.7/4.7 21a 3.7/4.7 22 3a87 P

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/964:17

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QUAD CITIES DPR 30 The RCIC and the HPCI bloh flow and temperature instrumentation aro 3rovided to detect a break in their respective piping. A trip of this nstrumentation results in closure of the RCIC or HPCI steam supply isolation valves. The trip logic for this function is similar to that for the main stoamlino isolation valves, thus all sonsors are required to be operable or in a tripped condition to moot single failuto critoria. The trip sottings of 170'F and 300%

of design flow and valve closure time are such that core uncovery is prevented and fission product release is within limits. In addition, the steam supply valvos for each system are closed on low steamlino pressure to 3rovide primary containment isolation when the reactor pressure, as sensed n the system steamlines,is below the required pressure for turbino operation.

Operation of the HPCI turbino will continuo as long as reactor pressure is above 150 psig. When the reactor pressure falls below 150 psig, the o aeed of the turbine-pump unit will decrease and would gradually be slowed c uo to stop friction and windage losses at low reactor pressures. Tao low reactor pressuro isolation setpoint was developed in accordance with NEDC 3133G, General Electric Instrument Sotpoint Methodology," dated October,1980.

The trip setpoint of greater than or equal to 100 psig was calculated such that the isolation will occur on decreasing reactor pressure to provido primary containment isolation when the reactor pressure, as sensed in the system steamlines,is below the required arossure for turbino operation. The external vacuum breaker line for tio HPCI turbine will isolate on low steamline pressure concurrent with high drywoll pressure signals. The instrumentation and controls onsure the proper HPCI and primary

'steamilne break isolation of the steamline containment response to a Hsupply valves only), a largo bre .;insidu the co steam su 3 ply and vacuum relief isolation valve) and a small or intermodlate size brea s inside of containment (steam supply and vacuum breaker Isolation valves remain open for HPCl operation)."

The instrumentation whluiInitiates ECCS action is arranged in a one-out of two taken twico logic circuit. Unlike the reactor scram circuits, however, there is one trip system associated with each function rather than the two trip systems in the reactor protection system. The singlo failure criteria are met by virtue of the f act that redundant core cooling functions are arovided, e.g., sprays and automatic blowdown and high pressure coolant njection. The speclfication requires that if a trip system becomes Ino3erable, the system which it activatos is declared inoperable. For example, if Lho trip system for core spray A becomes inoperable, core spray A is declared inoperable and the out of service specifications of Specification 3.5 govern.

This specification preserves the offectiveness of the system with respect to the single fallure critoria even during periods when maintenance or testing is being performed.

The control rod block functions are provided to provent excessivo control rod withdrawal so that MCPR does not go Dolow the MCPR Fuel Cladding Integrity Safety Limit. The trip logic for this function is one out of r,; e.g., any trip on one of the six APRM's, eight IRM's, four SRM's will result in a rod block. The minimum instrument channel regulromonts assure sufficient instrumentation to assure that the single failure criteria are mot.

! 0512J 3.2/4.0 6a Amendment No.

l l

1026:1 l

QUAD CITIES DPR 30 l

The minimum instrument channel requirements for the RBM may be reduced by one for a short period of time to allow for maintenance, testing, or calibration. This time '.

seriod is only . 3% of the oaerating time in a month and does not sl0nificantly nerease the risk of preventing an inadvertent control rod withdrawal.

The APRM rod block function is flow biased and prevents a significant reduction in MCPR, especially during operation at reduced flow. The APRM provides gross core protection, i.e., limits the gross withdrawal of control rods in the normal withdrawal sequence, in the refuel and startup/ hot standby modes, the APRM rod block function is set at 12% of rated power. This control rod block provides the same type of protection in the Refuel and Startup/ Hot Standby modes as the APRM flow blased rod block does in the Run mode, i.e., prevents control rod withdrawal before a scram is reached.

The RBM rod block function provides local protection of the core, i.e., the prevention of transition bolling in a local region of the core for a single rod withdrawal error from a limiting control rod pattern. The trip point is flow blased. The worst case sin 0 0 l control rod withdrawal error is analyzed for each reload to assure that, with the s aecific trip settings, rod withdrawalis blocked before the MCPR reaches the fuel c adding integrity safety limit.

Below 30% power, the worst case withdrawal of a single control rod without rod block action will not violate the fuel cladding Integrity safety limit. Thus the RBM rod block function is not required below this power level.

The IRM block function provides local as well as gross core protection. The scaling arrangement is such that the trip setting is less than a factor of 10 above the indicated level. Analysis of the worst case accident results in rod block action before MCPR approaches the MCPR fuel cladding integrity safety limit.

A downscale indication on an APRM is an Indication the Instrument has failed or is not sensitive enou0h. In either case the Instrument will not respond to changes in control rod motion, and the control rod motion is thus prevented. The downscale trips are set at 3/125 of full scale.

The SRM rod block with <; 100 CPS and the detector not fullinserted assures that the SRM's are not withdrawn from the core prior to commencing rod withdrawal for startup. The scram discharge volume high water level block provide annunciation for o> orator action. The alarm setpoint has been selected to provide adequate time to a low determination of the cause of level increase and corrective action prior to automatic scram initiation.

For offective emergency core cooling for small pipe breaks the HPCI system must function since reactor pressure does not decrease rapidly enough to allow either core spray or LPCI to operate in time. The automatic pressure relief function is provided as a backup to the HPCI in the event the HPCI does not operate.

0512J 3.2/4.2-7 Amendment No.

1026:2 -

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f QUAD CITIES DPR 30 The arrangement of the tripping contacts is such as to provido this funct;on when necessary and minimizo spurious operation. The tsp sottings given in the specification are adogaato to assure the abovo critoria are mot (rotorenco SAR Section 6.2.6.3). The specification preservos the effoctivonoss of the system during aorlods of maintenance, testing or calibration and also minimizes the risk for nadvertent operation, l.o., only one instrument channel out of service.

Two radiation monitors are provided on the refueling floor which initiato isolation of the reactor building and operation of the standby gas treatmont systems. The trip lo0 l c is one out of two. Trip sottings of <100 mR/hr for the monitors on the refueling floor are based upon initiating normal ventilat on isolation and standby Das treatment system operation so that none of the activity eeloased durin0 the refus!Ing accidont loavos the reactor building via the normal ventilation stack but that all the activity is processed by the standby gas treatment syntom.

Tho Instrumentation which is provided to monitor the postaccident condition is listed in Table 3.2-4. The instrumontation listed and the limitin0 conditions for oporation on those systems ensure adequato monitoring of the containment following a loss of-coolant accidont. Information from this instrumentation will provide the operator with a detailed knowledge of the conditions resulting from the accident; based on this Information ho can make logical decisions regarding postaccident recovery.

The specifications allow for postaccident instrumentation to be out of survice for a period of 7 days. This period is based on the fact that several diverso Instruments are availablo for guiding the operator should an accident occur, on the low probability of an instrument aoing out of service and an accident occurring in the 7 day period, and on enginooring judgment.

The normal supply of air for the confrol room ventilation system Trains "A" and "B" is outside the service building. In the avent of an accid 3nt, this source of air may be required to be shut down to provon'. hi0h dosos of radiation in the control room.

Rather than provide this isolation functlon on a radiation monitor installed in the intake air duct, signals which indicato an accident, i.e., high drywell pressure, low water level, main streamline high flow, or bl0h radiation in the reactor building ventilation duct, will cause isolation of the intake air to the control room. The above trip signals result in immediate isolation of the control room ventilation system and thus minimize any radiation doso. Manualisolation capability is also provided.

Isolation from high toxic chemical concontration has boon added as a result of the

' Control Room Habitability Study" submitted to the NRC in December 1981 in responso ammonia, to NUREG-0737 ch'orino, Itemdioxide and sulphur lil D.3.4. As explained detection capability in Section 3 of has boon this study, provided. T he

setpoints chosen for the control room ventilation isolation are based on early detection in the outsido air supply at the odor threshold, so that the toxic chemical will not achieve toxicity limit concentrations in the Control Room.

Tho radioactivio liquid and gaseous offluent instrumentation is provided to monitor the release of radioactive materials in liquid and gaseous offluents during roloasos.

The alarm sotpoints for tha instruments are prov!ded to ensure that the alarms will

! occur prior to exceeding the limits of 10 CFR 20.

0512J 3.2/4.2 8 Amendment No.

1026:3 t

, ~.

QUAD-CITIES OPR-30 TABLE 3.2-1 INSTRUMENTA110N THAT IN!i!ATES PRIMARY CONTAINHENT ISOLATION FUNCTIONS Hinimum Number of Operable or Tripped Ins trumen Channel $l_1 Instruments Trip Level Setting Action (21 4 Reactor low water (5) >144 inches above top of A active fuel

• 4 Reactor low low water 184 inches above top of A active fuel

• 4 High drywell pressure [5] 12.5 psig (3) A 16 High flow main steamilne[5] 1140% of rated steam flow B 16 High temperature main 1200* F 6 steamilne tunnel 4 Highradiationm4}n 1 15 x normal rated power B steamilne tunne1Lol background (without hydrogen addition)  ;

4 Low main steam pressure [4] 1825 psig B  !

2 High flow RCIC steamline <300 % of rated steam C 71ow(7) 4 RCIC turbine area high 1170' F C temperature 2 High flow HPCI steamilne <300% of rated steam 0 71ow(7) 4 HPCI area high temperature 1170' F 0 l

4 HPCI 5teamilne pressure 1100 psig D l

0513J 3.2/4.2-11 Amendment No.

. . ~. 1 QUAD-CiflES OPR-30 TABLE 3.2-1 (Cont.) l thSTRUMENTATION THAT INITIATES PRIMARY CONTAINHENT ISOLATION FUNCilONS Notes

1. Whenever primary containment integrity is required, there shall be two operable or tripped systems for each function, except for low pressure main steamline which only need be available in the Run position.

2. Action, if the first column cannot be met for one of the trip systems, that trip system shall be tripped.

if the first column cannot be met for both trip systems, the appropriate actions listed below shall be taken.

A. Initiate an orderly shutdown and have the reactor in Cold Shutdown condition in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. ,

B. Initiate an orderly load reduction and have reactor in Hot Standby within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

C. Close iso'ation valves in RCIC system. l D. Close isolation valves in HPCI subsystem.

3. Need not be operable when primary containment integrity is not required.

4 Thr, isolation trip signal is bypassed when the mode switch is in Refuel or Startup/ Hot Shutdown.

5. The instrumentation also isolates the control room ventilation system.

6. This signal also automatically closes the mechanical vacuum pump discharge l line isolation valves.

7. Includes a time delay of 3 1 t i 9 seconds.

(

• Top of active fuel is defined as 360" above vessel zero for all water levels i

used in the 1.0CA analysis (see Bases 3.2).

(

i l

l 0513] 3.2/4.2-Ila Amendment No.

i

QUAD-CITIES DPR-30 TABLE 3.7-1 (Cent'd)

Valve imber of Maximum Number for ower-Operated Operating Normal Action on Isolation Valve Units ' valves Time Operating Initiating Gtoup Identification l_and_2 Inboar.d_0utboard (sec) Position 51gaal Radwaste 2 Drywell floor drain discharge A0-2001-3 1 120 0 GC 2 Drywell floor drain discharge A0-2001-4 i 120 0 GC 2 Drywell equipment drain discharge A0-2001-15 1 120 0 GC 2 Drywell equipment drain discharge A0-2001-16 1 s20 0 GC Note: Valve can be reopened af ter Isolation for sanpling Oxygen Analyzer 2 0xygen analyzer valve A0-8801-A, 4 110 0 GC B,C,0 2 Oxygen analyzer valve A0-8802-A, 4 110 0 GC 8,C,0 2 0xygen analyzer valve A0-8803A 1 110 0 GC 2 Oxygen analyzer valve A0-8803B 1 110 0 GC l

RA 4 3.7/4.7-21 Amendment No.

QUAD-CITIES OPR-30 TABLE 3.7-1 (Cont'd)

Valve Number of Maximum Number for Power-Operated Operating Normal Action on Isolation valve Units Valves Time Operating Initiating Group identift. cation 1_and_2 Inboard _0utboar.d (secl Position Signal Traversing incore Probe 2 On isolaticn signal, the TIP Tip Ball detector is Valve withdrawn if in 700-733 use: five ball valves and one nitrogen purge are closed.

Tip Purge Valve Assembly 700-743 Reactor Water Cleanup 3 Pump suction isolation valve H0-1201-2 130 0 GC 3 Pump suction isolation valve H0-1201-5 1 530 0 GC HPCI 4 Steam isolation valve HO-2301-4 1 150 0 GC 4 Steam isolation valve H0-2301-5 1 150 0 GC 4 Vacuum breaker isolation H0-2399-40 1 150 0 GC 4 Vacuum breaker Isolation HO-2399-41 1 150 0 GC RCIC 5 Turbine steam supply H0-1301-16 1 125 0 GC 5 Turbine steam supply HO-1301-17 1 125 0 GC RA 4 3.7/4.7-21a Amendment No.

_ _ _ - _ _ _ _ _ . _ . . . ._.._ . _ _ - . . _ _ . _- _m i

QUAD-CITIES

, DPR-30 ,

1 TABLE 3.7-1 (Cont'd)

Key: 0: open C: closed SC: stays closed GC: goes closed Note: Isolation groupings are as follows:

Group 1: The valves in Group I are closed upon any of the following conditions:

1. Reactor low-low water level

2. Main steamline high radiation

3. Main steamitne high flow

4. Main steamilne tunnel high temperature

5. Main steamline low pressure ,

l Group 2: The actions in Group 2 are initiated by any one of the following l conditions.

1. Reactor low water level l

2. High drywell pressure Group 3: Reactor low water level alone initiates the following:

1. Cleanup domineralizer system isolation Group 4: The steam supply isolation valves in the high pressure coolant ,

injection system (HPCI) are closed upon any one of the following signals:

1. HPCI steamline high flow I

2. High temperature in the vicinity of the HPCI steamitne i

3. Low reactor pressure The turbine exhaust vacuum breaker isolation valves close when both of the following signals are present (simultaneously):

P

1. High drywell pressure

2. Low reactor pressure Group 5: Isolation valves in the reactor core isolation cooling system (RCIC) are closed upon any one of the following signals:

1. . RCIC steamline high flow -- '

2. High temperature in the vicinity of the RCIC steamilne

3. Low reactor pressure RA 4 3.7/4.7-22 Amendment No.

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l ATT ACllMENT 4 EVALUATION OF NO SIGNIFICANT HAZAHDS CONSIDEIMTION l

As described in the Description and Safety Evaluation for the Amendment i Request, the proposed change involves a modification to the HPCI steam exhaus' system. The modification replaces the existing vacuum breaker with a new vacuum breaker which has an automatic isolation feature.  !

Commonwealth Edison has reviewed the proposed amendment in accordance with l the criteria delineated in 10 CFR 50.91, and has concluded that the proposed l amendment does not present a Significant Hazords Consideration. The basis for this determination Is as 'ollows:

1. The proposed change does not involve a significant increaso itt the probability or consequences of an accido..t.

Tablo 3.2-1 The addition of the HPCI steam line low pressure isolation setpoint to Table 3.21 '

does not increase the probability of an accident. The Isolation feature of HPCl is part of the original design basis for the system; however, the isolation setpoint has not been included in the Technical Specifications. This proposed amendment corrects the omission by adding the isoletion signal to the Technical Specifications. The calculation which supports the pro 30 sed setpoint assures that HPClis not prematurely isolated.

The isolation setpoint c oes not affect any accident initiators; therefore, does not represent any increase to the probability of the accident.

The addition of the HPCI steam line low pressure isoldlon setpoint to Table 3.21 does not increase the consequences of the acudent. The purpose of the HPCI steam line low pressure isolation is to ensure that stet rn and radioactive gases will not escape from the HPCI turbine shaft seals into the reacter building after steam pressure has decreased below turbine operating pressure. A calculation has been performed to confirm the value of the HPCIlow pressure isolation. The calculation ensures that the isolation does not occur prior to a decreasing reactor pressure of 150 psig which is consistent with the accident analysis. The lower bound for the isolation is based on engineering judgment and is conservative when compared to anticipated stall aressures for the HPCI turbine. The HPCI Isolation setpoint, therefore, does not nerease the consequences of the accident but rather provides further assurances that the isolation function is Inillated at an appropriate pressure.

Table 3.7-1 The elimination of the existing vacuum breaker line and the addition of a new vacuum breaker line does not affect any accident initiator and as such does not affect the probability of the accident. Currently, the vacuum breaker relief line, which is located inside of the torus, creates a potential flow path from the containment air space through the existing vacuum breakers to the HPCI exhaust line. Containment atmosphere leakage is prevented by the existing turbine exhaust check valves which are periodically tested in accordance with 10 Cf-R 50 Appendix J.

/964:18 e --e - -

l '

Att:chment 4 (continued) 1 Table 3.7-1.(continued)

The proposed modification chan0es the primary containment boundary. The )

modif! cation does not affect any accident initiators and therefore does not affect the  !

. probability of the accident. The design features of the new vacuum breaker assures <

1 that the consequences of the accident are not increased. The new design isolates the I torus air space from the HPCI steam exhaust line through the use of motor operated valves. The new vacuum breaker valves are designed to accomodate 10 CFR 50 Appendix J Ioak rate testing and witi be added to tne Station's 10 CFR Appendix J Test Program. As such, the valve leakage will be included in the limits for containment leakage, as defined in the Technical Specifications, to ensure that the resulting doses will not exceed 10 CFR Part 100 limits.

The consequences of the accident are also unaffected by the closure time of the new motor-operated valves. The valve closure time is based on the ability of the valve l to close and does not significantly affect the dose rates. The most severe radiolo0 lcal  ;

release would result from fuel damage due to a loss of water level which is  ;

accompanied by a loss of reactor pressure. Since the HPCI vacuum breaker lines  !

would be isolated at low reactor pressure concurrent with an indication of a break  !

Inside of the drywell, the vacuum breaker isolation valves would be closed prior to fuel 1 damage.

Finally, the isolation logic assures that the HPCI system is isolated during  !

conditions in which the HPol reactor inventory or pressure control function cannot be  !

maintained and there is indication of a large break in the drywell. This isolation logic  !

assures that the consequences of the accident are not significantly increased by ,

providing the necessary isolation of containment during accident conditions. ,

2. The proposed amendment does not create the possibility of a new or different kind t of accident from any previously evaluated. 1 9

, Table 3.2-1 ,

I As indicated pieviously, the HPCI low pressure isolation was included as part of ,

the original system design; however, was not included in Technical Specification Table i 3.2-1. As such, the proposed amendment does not introduce the use of new ,

equipment which has a different failure mechanism or whose failure is considerably more probable than the existing equipment. The proposed change to Table J.2-1, therefore, does not create the possibility of a new or different kind of accident from any previously evaluated. l Table 3,7 .1 The proposed modification to the HPCI system improves the reliability of the .

Isolation system. The proposed design utilizes smaller isolation valves (when  !

compared to the turbine exhaust check valve) ano more effective isolation design ,

(motor operated gate valve versus check valves). The HPCIisolation sensors and .

controllogic are optimally arranged to provide high degree of reliability. Independent control circuits are provided to each isolation valve so that the f ailure of a single control circuit power supply cannot prevent isolation. Periodic testing of the instruments, as .

described in the Technical Specifications, ensures that the instruments are maintained ,

and functiona! within design parameters. Manual operation of the valves (both local and i remote) are backups in the unlikely event of a failure to automatically isolate HPCI.

/964:19 4

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Att:chment 4 (continued)

Table 3,7-1 (continued) j The controllogic for the new isolation valves provides reliable operation for HPCI performance. The new valves will bo normally open during operation and therefore,

! aro not required to stroke from their normal position in the case of a HPCI initiation. ,

The valves' will automatically isolate on indications of a large break inside containment l (drywell pressure greater than 2 psi) and when HPCl is no longer capable of providing l pressure control and/or reactor inventory. l A gross failure of the vacuum breaker function and/or new containment loolation valves in the closed position has been evaluated for the potential hazard of collapsing the turoine exhaust line and containment penetration due to a vacuum. Using conservative parameters for the HPCI exhaust piping (Length to diameter - 50 and Diameter to thickness = 40) and the methods of ASME Section lll NB 3133.3 for cylindrical shells made of low yield carbon steel, the maximum external aressure

, exceeds 300 psia. Since the maximum theoretical external pressure is less than 15 i

psia, the collapse of any HPCI turbine exhaust component is not a concern, Finally, the proposed design for the new vacuum breaker is consistent with the i design of newer BWR plants for external vacuum breaker lines (e.g., LtiSalle RCIC).

i

3. The proposed change does not involve a significant reduction in the rnargin of safety. ,

Table 3.2-1 As previously indicated, the original design for the system included the HPCI low reactor pressure isolation. The existing setpoint for the HPCl isolation is 90 psig which was based on the previous requirements for HPCI operability. The new calculated

, setpoint (100 psig) does not involve a significant reduction in the margin of safety since the calculation inputs; (1) assure that HPCI will remain operable as assumed in the accident analysis; and, (2) assure that the isolation occurs prior to reaching the stall l pressure for the turbine. The lower bound for the calculation is conservative when '

compared to the actual anticipated stall flow. The margin of safety remains essentially unchanged in that the isolation setpoint assures HPCI is isolated prior to steam pressure reaching a level such that the turbino can no longer operate. l Table 3,7-1 The proposed design for the new vacuum breaker does not involve a significant reduction in the margin of safety. Technical Specifications specify the acceptance criteria for containment integrity determination and also requires that containment undergo testing as specified in 10 CFR 50 Appendix J. Due to the modification of the containment boundary with the new vacuum breaker, the motor operated valves will be tested in accordance with 10 CFR 50 Appendix J to ensure Technical Specifications leakage limits are maintained. The testing will ensure that any potentialleakage will result in dose ilmits well below 10 CFR Part 100 limits. In addition, the existing containment boundary for the HPCI steam exhaust system utilizes two large check valves. The new vacuum breaker design utilizes smaller, motor-operated valves which provide additional rollability in maintaining long-term containment integrity.

~

/964:20

Attachment 4 (continued)

Tablo 3.7-1 (continued)

The closure timo for the HPCI vacuum breaker lines does not significantly decrease the mar Jin of safety. The most revero radiological release results from fuel dama00 due to a oss of reactor water level which is accompanied by a loss of reactor pressure. Since the HPCl vacuum breaker lines would be isolated at a low reactor arossure (concurrent with Indications of a break inside of the drywell), the vacuum aroakor isolation valves would be closed prior to fuel damage. The closure timos are therefore based on reasonable closure times for the motor operated valves.

Finally, the isolation logic is designed to assure that HPCI remains in a ' standby" operational modo and isolates during conditions which are indicative of a large break in the drywell( reator than 2 psi pressure in the drywell) and HPCI is no longer capable of performin its intended function (roactor pressure loss than 95 psi).

/964:21

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PRELIMINARY

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l GENERAL ELECTRIC COMPANY AFFIDAVIT I, David J. Robare, being duly sworn, depose and state as follows:

1. I am Manager, Plant Licensing 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 GE proprietary report, ' Quad Cities HPCI Turbine Steam Supply Pressure Low Setpoint Calculation, GE NE 901-013 0491, Rev.1," June 6,1991. This report presents a calculation to determine the setpoint for the Quad Cities HPCI turbine steam supply pressure low channel. The calculation was performed consistent with the GE proprietary document, " General Electric Instrument Setpoint Methodology, NEDC-31336," dated October 1986.

"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 .:cde secret are (1) the extent to which the information is known ou. side 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 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 developing the information; (6) the ease or difficulty with which the information could be properly acquired or duplicated by others."

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3. Some examples of categories of information which fit into the definition of Proprietary Information are:

a. Information that discloses a process, method or appara'.us where prevention of its use by General Electric's competitoN without license from General Electric constitutes a competitive economic advantage over other companies; I b. Information consisting of supporting data and analyses, including test data, relative to a process, method or apparatus, the application of which provide a competitive economic advantage, e.g., by optimization or improved marketability;

c. Information which if used by a competitor, would reduce his expenditures of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality or licensing of a similar product;

GENERAL ELEC1RIC C0MPANY

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.

4. Initial approval of proprietary treatment of a document is typically made by the Subsection Manager of the originating component, the person 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.

5. 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, competitively 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 thea only with appropriate protection by applicable regulatory provisions or proprietary agreements.

6. 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.

7. The information to the best of my knowledge and belief has consistently been held in confidence by the Gencral 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.

8. 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 l, competitors, with valuable information.

e GEHERAL ELfCTRIC COMPANY -

STATE Of CAllf0RNIA )

) ss:

COUNTY OF SANTA CLARA )

David J. Robare, being duly sworn, deposes and says:

That he has read the foregoing affidavit and the matters stated therein are truly and correct to the best of his knowledge, information, and belief.

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Executed at San Jose, California, this l'R day of 3MNE 19 21

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[iav J77tobare General Electric Company SubscribedandswornbeforemethislM'dayof ihnL 19 3](,,

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<<)(lt ( b2li sF . &'0 u n u PA,U,LA F. HUSSEY3,e Not.ary

. cu nwa Public, State of California

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SE y Sv:0cnn:nwes.th Es:lch  : 4-15-91 ; M: 11 ; E; W S. N NmE E:a 6 g1AF E3 Information WWIra lei:ter SERVICES - ---

October 31. 1973 SIL No. q p gg y 3j -

Category I RFCl/RCIC TURBINI EXRAU$T LINE VACUyH BAEAKERS Survalliance testing of the HPC!/RCIC systems at mary operating BW han disclosed an undesirable exhaust line vacuum condition that causes oro cr trere of the following adverse effectsi

1. Pressure instability in the exhaust line.

2. Cycling and s1p.11rg of the exhaust line check valves.

3. Pipe and torus vibration.

4. Water slug carryovar.

5. Post shutdoe vibration caused by steam collapse.

Investigations into this phenomenon during the course of pre cp activities at Browns Fere 1 and teach Bottom 2 have concluded that HPCI/RCIC sylte75 can benefit si nificantly by the installation of vacuum breakers on t*e turbine p haus lines. Tests conducted at Browns ferry and Peach Bottom confirmed that the installation of vacuurr, treakers improves low load > pert-tion and providea acc6ptable turbine shutdown conditions by minim 121n!

pressure fluctuations. Also, the installation of these vacuum breakt*3 will prevent water frosi rising in the turbine exhaust line during a pis-tulated LOCA whtn the torus sould becoine pressurtzed.

The minteum vacwre breaker size recomended is 2 inches for HPCI turbine exhaust, and its inches for RCIC turbine nhaust. The vacuum breaker check valves should have a pressure drop of less than 0.6 psi to assure ade- ao vacuum breaker capability, .

Figures 1 4 2 hote that Figur(e 1 app 1'es to plants having HPCI tysterss whereas figu is applicable to HPC1/PCIC systerns.

w *. ,...y ., ....... ..si ,i ..p.....a ., impii.e is m.o. uin reir.ot to :re u,.c r. eempist a.is or s,sef wie . of e h Iitc em tion c a... si....i. come.r:f ,n..

,io r,ispiiscity to,i..nmty or o.,nie. .,hich may eeiuit erom the use of t'iii inf aemi li i.

NUp(t AR ENEHGY DIVillON e th"H st AVICEs e S AN Jose.CALIFORNI A 0ENERAL$ Ell!CiRIC

4-t M 1 t 15: 17 : enc OCNFS* ESC 00nNEN! 3ko/E;8 7 SEN{Sv:ConnonvesithEHlon ,

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t Note also that both vacuum bretLNr configurations include provisions far positive isolation of the suppression pool air space. This provision is in compilance with Atc criteria that check valves not be used for long tem isolation. The pocitive tsolation should be autornatically initiated  ;

by a contiinitTon of low reactor pressure and high dr existing low reactor pressure switches may"Te used, ywell pressurt. Ta combined with exist.

ing "t high drywell essure switches.

be mainged to the redugnt 1 solation switches. Electrical separation should *,

Reects inanval switches in the control roosi tre not requiredi local swl"chus are considered adequate. However, control room indicating Iights shou'd be  !

provided, plus an alam annunciating 'YACVUM BREAKER ISOLATION VALVES 107 ryLt.Y OPEM.*

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If additional help in implementing this recomended installktion is delirt<.

General Electric engineering would be plassed or installetion to provide a quotation for supplementa1 nssistance.

• Prepared byl V. G. Greyhek I Approved by 3 Ak1 Di 5. Uruenbaugh, manager Issued by: _ m, V. G. Graynek', Manager *.

t Performance Evaluation and Perfomance Analysis and 1mprovmant Service Communications  ;

} i Product Reference' '

t41 HPCI System '

, t51 - RCIC System .

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SENT BY:CcMenwesith Edison i 4-16-91 i 15:15 i ENC QCNPS* ENC 00WNERi 3RC-T;# 8

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