ML20199B541

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Application for Withholding Proprietary Info from Public Disclosure (Ref 10CFR2.790).Affidavit Encl
ML20199B541
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 01/08/1986
From: Wiesemann R
WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To: Harold Denton
Office of Nuclear Reactor Regulation
Shared Package
ML19292F429 List:
References
CAW-86-004, CAW-86-4, NUDOCS 8606170169
Download: ML20199B541 (20)
v • d • e


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ATTACHMENT G ST-HL AE /68]

PAGE / OF 7 Westinfiouse Water Reactor Ba m Pmsbtrgh Pennsytvania 15230-0355 Electric Corporation Divisions January 8, 1986 CAW-86-004 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20055 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Reference:

Houston Lighting & Power Company Letter to NRC dated January 1986

Dear Mr. Denton:

The proprietary material for which withholding is being requested in the reference letter by Houston Lighting & Power Company is further identified in an af fidavit signed by the owner of the proprietary information, Westinghouse

Electric Corporation. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b) (4) of 10CFR Section 2.790 of the Commission's regulations.

The proprietary material for which withholding is being requested is of the same technical type as that proprietary material previously submitted with application for withholding CAW-84-102.

Accordingly, this letter authorizes the utilization of the accompanying af fidavit by Houston Lighting & Power Company.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-86-004, and should be addressed to the undersigned.

Very truly yours, 8606170169 860610 PDR ADOCK 05000498 PDR M

A p hW p ob rt A. Wiesemann, Manager u ulatory & Legislative Affairs HFC/wh/1212n Enclosure cc: E. C. Shomaker, Esq.

Of fice of the Executive Legal Director, NRC

ATTACHMENT C-ST-H L. AE./ 6g/

PAGE c2_ OFr1 CAW-84-102 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally appeared John D. McAdoo,,

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:

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Joh D. McAdoo, Assistant Manager clear Safety Department Sworn to and subscribed before me this A L_ day

....e.f W h .1984.

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&.hlOp Notary Public E0asAlbt M. PIPLICA. NOTARY PUBLIC N04R0tYlLLt BORD. ALLECH!hY COUNTY NY COMuisst04 [xPitts Dtc 14.1987 Nember. Pennsylvania Association of botaries HFC/0162n/11-20-84 k

. . ATTACHMENT (L ST HL-AE /681

_ PAGE S OF r2 CAW-84-102 (1) I am Assistant Manager, Nuclear Safety Department, in the Nuclear Technology Division, of 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 or rulemaking proceedings, and am authorized to apply for its withholding on behalf of the Westinghouse Water Reactor Divisions.

(2) I am neking this Affidavit in conformance with the provisions of 10CFR Section 2.790 of the Commission's regulations and in conjunction with the Westinghouse application for withholding accompany this Affidavit.

(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse Nuclear Energy Systems in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) 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 should be withheld.

(i) The information sought to be withheld from public disclosure is

. owned and has been held in confidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public.

Westinghouse has a rational basis for determining the types of j

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 policy and provides the rational basis required.

HFC/0162n/11-20-84 7 . _ _ .

1 ATTACHMENT C .

ST-HL AE-/MI I

PAGE # OF 7 CAW-84-102 I

Under that system, information is held in confidence if it falls in i one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows: l l

(a) The information reveals the distinguishing aspects of a 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 process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.

(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.

It reveals cost or price information, production capacities, (d) budget levels, or commercial strategies c' Westinghouse, its

, customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable. -

(g) It is not the property of Westinghouse, but must be treated as proprietary by Westinghouse according to agreements with the owner.

HFC/0162n/11-20-84 l

- ATTACHMENT C, ST.HL AE- 16f/

PAGE $ OF 7 7Aw-s4-loz There are sound policy reasons behind the Westinghouse system which include the following:

(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors.

It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

(b) It is information which is marketable in many ways. The extent to which such inforwation 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 resources at our expense.

(d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable 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 Westinghouse of a competitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition in those countries.

l (f) The Westinghouse capacity to invest corporate assets in l research and development depends upon the success in obtaining and maintaining a competitive advantage.

(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.

HFC/0162n/ll-20-84 1

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ATTACHMENT CS ST HL AE- /6t/ )

PAGE 6 OF '7 j t

o 5- CAW-84-102 (iv) The information sought to be protected is not available in public sources to the best of our knowledge and belief.

l (v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP-10489,

" Technical Bases for Eliminating Pressurizer Surge line Ruptures as the Structural Design Bases for South Texas Project," dated February 1984, and " Additional Information - South Texas Surge Line."

The subject information could only be duplicated by competitors if they were to invest time and effort equivalent to that invested by Westinghouse provided that they have the requisite talent and experience.

Public disclosure of this information is likely to cause substantial harm to the competitive position of Westinghouse because it would simplify design and evaluation tasks without requiring a commensurate investment of time and effort.

Further the deponent sayeth not.

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l HFC/0162n/ll-20-84

1 ATTACHMENT C ST-HL AE-/6 #/#

PAGE ef 0F 7

, PROPRIETARY INFORMATION NOTICE ,

( .

TRANS)CTTED HDEWITH ARE PROPRIETARY AND/0R NON-PROPRIETARY YERSIONS O DOCUMENIS RfRNISHG TO THE NRC IN CONNECTION WITH REQUESTS FOR CE PLAhT SPECIFIC REVIEW AND APPROVAL.

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IN ORDER TO C0hTORM 70 THE REQUIRIMEhTS 710CFR2.790 W THE 0'HMISSION REGULATIONS CONCERNING THE PROTECTION W PROPRIETARY INFORMATION S 70 THE NRC, THE INFORPATION WHICH IS PROPRIETARY IN THE PROPRIETARY VERSIONS IS CONTAING WITHIN BRACKETS AND WHDE THE PROPRIETARY INFORMATION HAS B

. DEI.ETD IN THE NON-PROPRIETARY VDSIONS GC.Y THE BRACKETS RDRIN, THE -

IhTORPATION THAT WAS CONTAINED WITHIN THE BRACKEIS IN THE PROPRIET HAVING BEDI DI2.ETE. THE JUSTIFICATION FOR Q. AIMING THE INFORMATION SO

( DESIGNATED AS PROPRIETARY IS INDICATE IN BOIH VDSIONS BY MEANS W LO LETTDS (a) THROUGH (g) CohTAING WIININ PAREhTi!SES LOCATED AS A SUPERSCRIFT IMMEDIATII.Y FOLLOWING THE BRACKETS EQ.05ING EACH ITIN OF INFORMATION IDENTIFIED AS PROPRIETARY OR IN 1HE MARGIN OPPOSITE SU01 INFORMATIO LOWD CASE LETTERS REFER TO THE TYPES W INFORMATION WDTINGHOUSE CU HOLTS IN CONFIDENCE IDEhTIFIED IN SECTIONS (4)(ii)(a) through (4)(ii)(g) 0F THE AF7IDAVIT ACCOMPAhTING THIS TRANSMITTAL PURSUAhT TO 10CFR2 790(b)(1 Em

Attachment C t ST-HL- AE -1681 PFN: G9.10 SOUTH TEXAS PROJECT LEAK-BEFORE-BREAK SCREENING CRITERIA FOR HIGH ENERGY AUXILIARY PIPING SYSTEMS This attachment presents the screening criteria for the application of leak-before-break to high energy piping systems in South Texas Project.

-The purpose of this effort is to apply the state-of-the-art technology in leak-before-break through a screening process developed to minimize the downstream effort and to obtain an insight in ascertaining the possibility of successful demonstration of leak-before-break. Successfully passing the screening criteria establishes technical justification to eliminate the dynamic effects of postulated breaks. The screening criteria are provided in the following enclosures:

Enclosure 1: WCAP #11043 - South Texas Project Leak-Before-Break Screening Criteria for High Energy Auxiliary Piping Systems (Proprietary Class 2)

Enclosure 2: WCAP #11044 - South Texas Project Leak-Before-Break Screening Criteria for High Energy Auxiliary Piping Systems (Proprietary Class 3) i l

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z Nj i ATTACHMENT (3 i ST-HL-AE- /68f PAGE / OF 7 Water Reactor Nx 355 Westinghouse Pmsburgh Pennsylvania 15230-0355 88CtflC C0fp0fatl0n Divisions January 8, 1986 CAW-86-004 9

Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20055 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Reference:

Houston Lighting & Power Company Letter to NRC dated January 1986

Dear Mr. Denton:

The proprietary material for which withholding is being requested in the reference letter by Houston Lighting & Power Company is further identified in an affidavit signed by the owner of the proprietary information, Westinghouse Electric Corporation. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b) (4) of 10CFR Section 2.790 of the Commission's regulations.

The proprietary material for which withholding is being requested is of the same technical type as that proprietary material previously submitted with application for withholding CAW-84-102.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Houston Lighting & Power Company.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-86-004, and should be addressed to the undersigned.

Very truly yours, M

60 h w ob rt A. Wiesemann, Manager p

u ulatory & Legislative Affairs

~~

HFC/wh/1212n Enclosure cc: E. C. Shomaker, Esq.

Office of the Executive Legal Director, NRC

ATTACHMENT CL ST HL AE /6g/

PAGE d2. OF#7 CAW-84-102 s

AFFIDAVIT CONNONWEALTH OF PENNSYLVANIA:

ss COUNTY OF ALLE6HENY:

8efore me, the undersigned authority, personally appeared John D. McAdoo,,

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 aver 1nents of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:

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Joh D. McAdoo, Assistant Manager clear Safety Department Sworn to and subscribed before me this d day

, ....p..f.... h .1984.

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N. l' h Notary Public LottAtht at PirlicA. NOTARY PUBlic WO440tVILLE BORQ. AlltCH!NY COUMIT NY COMul35104 EXPIRIS Ctc 14. lH7 Gember. Pennsylvania Association of hotaries i

l NFC/0162n/11-20-84 L

I ATTACHMENT C

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. ST-HL AE /681 PAGE S OFr1 CAW-84-102 (1) I am Assistant Manager, Nuclear Safety Department, in the Nuclear Technology Division, of Westinghouse Electric Corporation and as such, I have been specifically delegated the function of reviewing the proprietary inforwation sought to be withheld from public disclosure in connection with nuclear power plant licensing or rulemaking proceedings, and am authorized to apply for its withholding on behalf of the Westinghouse Water Reactor Divisions.

(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 Westinghouse application for withholding accompany this Affidavit.

(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse Nuclear Energy Systems in designating information as a trade secret, privileged or as confidential commercial or financial information.

j (4) 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 should be withheld.

l (i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to 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 policy and provides the rational basis required.

HFC/0162n/ll-20-84

1

- ATTACHMENT C ST-HL AE-/6al PAGE # OF 7

'. CAW-84-102 Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a 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 i other companies.

(b) It consists of supporting data, including test data, relative to process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.

(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.

(e) It reveals aspects of past, present, or future Westinghouse or

, customer funded development plans and programs of potential I commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

(g) It is not the property of Westinghouse, but must be treated as proprietary by Westinghouse according to agreements with the owner.

MFC/0162n/11-20-84 t

ATTACHMENT C, i ST-HL AE- /681 t PAGE 5 OF 7  ;

CAW-84-lD2 s

There are sound policy reasons behind the Westinghouse system which include the following:

(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors.

It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

(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 resources at our expense.

(d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable i

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 Westinghouse of a competitive advantage.

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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 in those countries.

(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in i

obtaining and maintaining a competitive advantage.

l (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.

4 HFC/0162n/11-20-84

1 ATTACHMENT CS ST HL AE- /6t/

PAGE 6 OF /7 CAW-84-102

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(iv) The information sought to be protected is not available in public sources to the best of our knowledge and belief.

(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP-10489,

" Technical Bases for Eliminating Pressurizer Surge line Ruptures l as the Structural Design Bases for South Texas Project," dated February 1984, and " Additional Information - South Texas Surge Line."

The subject information could only be duplicated by competitors if they were to invest time and effort equivalent to that invested by Westinghouse provided that they have the requisite talent and experience.

! Public disclosure of this information is likely to cause substantial harm to the competitive position of Westinghouse -

because it would simplify design and evaluation tasks without requiring a commensurate investment of time and effort.

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[ Further the deponent sayeth not.

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HFC/0162n/11-20-84

ATTACHMENT C,

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ST-HL-AE PAGEef OF /6 8'/

i PROPRIETARY INFORMATION NOTICE .

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TRANSMITTED HDEWITH ARE PROPRIETARY AND/OR NON-PROPRIETARY VDSIONS OF DOCUMENTS FURNISHD 70 THE NRC IN CONNECTION WITH REQUDTS FDR CEERIC AC/OR PLAhT SPECIFIC REVIEW AND APPROVAL.

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IN OF. DER 10 C0hTORM TD THE RDUIREMENTS OF 10CFR2.790 0F THE C0HKISSION'S REGULATIONS CONCERNING THE PROTECTION & PROPRIETARY INFVRMATION SO SUBMITTE

_ TD THE NRC, THE INFORFATION WHICH IS PROPRIETARY IN 1HE PROPRIETARY VERSIONS IS CONTAING WITHIN BRACKETS AND WHERE THE PROPRIETARY INFORMATION HAS BEDi

, DELETD IN THE NON-PROPRIETARY VERSIONS DC.Y THE BRACKETS REMAIN, THE IhTORFATION THAT WAS CONTAINED WITHIN THE BRACKEIS IN 1HE PROPRIETARY VERSIO HAVIN3 BED DII.ETD. THE JUSTIFICATION FDR (1. AIMING THE INFORMATION 30 t

( DESIGNATED AS PROPRIETARY IS INDICATED IN BOTH VERSIONS BY MEANS W LOWS CASE LETTDS (a) THROUGH (g) CohTAINED WITHIN PARDiTHESES LOCATED AS A SJPERSCRIPT IMMEDIATE.Y FDLLOWIN3 THE BRACKETS ECI.05ING EACH ITEM OF INFORMATION BEIN3 IDENTIFIED AS PROPRIETARY OR IN THE MARGIN OPPOSITE SJCH INFORMATION. THESE LQiB CASE LEITERS REFIR 1V THE TYPES OF INFORMATION WESTINGHOUSE QJS1DMAR l HC'.DS IN CONFIDENCE DEh71FIED IN SECTIONS (4)(ii)(a) through (4)(ii)(g) 0F THE

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AFFIDAVIT ACCOMPAhTING THIS TRANSMITTAL PURSUAhT 7010CFR2.790(b)(1).

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Attachment D ST-HL-AE- 1681 PFN: G9.10 Page 1 of'2 PROVISIONS FOR MINIMIZING STRESS CORROSION CRACKING IN HIGH ENERGY LINES Industry experience (NUREG 0691) has shown that there is a strong potential for stress corrosion cracking (SCC) if the following three conditions exist simultaneously: (1) high tensile stresses, (2) susceptible piping material, and (3) a corrosive environment. Althcogh any stainless or carbon steel piping will exhibit some degree of resioci mie:;es and material susceptibil-ity, Houston Lighting 4 P)wer Company minimizes the potential for SCC by choosing piping materia' with low susceptibility to stress corrosion and by preventing the existence of a corrosive environment. The material specifica-tions consider compatib 'ity with the system's operating environment (both internal and external), otner materials present in the system, applicable ASME code requirements, fracture toughness characteristics, welding procedures, and pipe fabrication techniques.

The likelihood of stress corrosion cracking in stainless steel increases with carbon content. Consequently, only the lower carbon content stainless steels (304, 304L, 316, 316L) are used in high energy systems in contact with the reactor coolant.1 The existence of a corrosive environment is prevented by strict criteria for internal and external pipe cleaning, and water chemistry control during preoperation testing and normal plant operation. The mainte-nance of extremely low residual oxygen concentrations (less than 0.005 ppm) within the RCS and systems in direct contact with the RCS during normal operation, precludes the occurrence of pipe cracking which has been identified at some facilities.

For most secondary systems, ferritic type carbon steel 2 is used for piping, fittings, and valve bodies forming the pressure boundaries. Significant portions of the Steam Generator Blowdown System (SGBDS) (steam generator to flash tank) use ferritic alloy steel. This ferritic material has been found satisfactory from the standpoint of non-susceptibility to stress corrosion cracking for the service conditions encountered.

High energy piping systems are cleaned externally and flushed as part of the preoperational test program. The piping is flushed with demineralized water subject to limits on total dissolved solids, conductivity, chlorides, j flourides, and pH. Flush water quality is monitored daily. The flushing is controlled in accordance with procedures. Water chemistry for preoperational testing is controlled by written specifications.

I Stainless Steel Material as listed in Attachment A, Table 1.

2 Carbon Steel Material as listed in Attachment A, Table 1.

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7-Attachment <D ST-HL-AE- 1681 PFN: G9.10 Page 2 of 2 During plant operation, primary and secondary side water chemistry are moni-tored, contaminant concentrations are maintained below the thresholds known to be conducive to stress corrosion cracking. The water chemistry control standards are included in operating procedures for those systems where breaks are being eliminated.

Attachment A identifies the systems where breaks are being eliminated.

Portions -of these systems operate at temperatures below 200 F. Industry experience shows that stress corrosion is not a significant concern at temper-atures this low. The water chemistry requirements for primary systems are presented in FSAR section 5.2.3. Secondary system water chemistry control is discussed in FSAR section 10.3.5.

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Attachment E ST-HL- AE- 1681 PFN: G9.10 Page 1 of 1 PROVISIONS FOR MINIMIZING THE EFFECTS OF THERMAL AND VIBRATION INDUCED PIPING FATIGUE I. GENERAL FATIGUE DESIGN CONSIDERATIONS Fatigue considerations are addressed in STP Class 1 piping by the use of a cumulative usage factor (CUF). In order to ensure that piping does not fail due to fatigue, the ASME Code limits the CUF to a maximum of 1.0.

Each Class 1 p.iping system will be reviewed to minimize the number of high stress-intermediate breaks. In accordance with the December, 1985, draft revision of ANSI /ANS 58.2 standards, the CUF threshold for high stress intermediate break locations will be taken as 0.4 in lieu of the 0.1 value noted in section 3.6.2 of the July 1982 Standard Review Plan.

II. THERMAL DESIGN CONSIDERATIONS The STP steam generators have separate nozzles for auxiliary feedwater-(upper nozzle) and main -feedwater (lower nozzle). Thermal fatigue is minimized in the main feedwater piping by preventing the introduction of ,

cold water. The main feedwater lines ,.inside ,the RCB are used only when feedwaterg temperatures downstream of the containment isolation valves are above 250 F. This is assured by permissives on the feedwater isolation valves which prevent their opening until the dognstream feedwater temper-atures measured at two locations g are above 250 F. Feedwater temperature is maintained above 250 F by heating in the deaerator with , extraction, main, or auxiliary steam. During shutdown; startup,and hot standby water is provided to the upper steam generator nozzle. The upper nozzle to the steam generator uses a thermal sleeve to minimize pipe stress resulting from thermal considerations.

The heat affected zone adjacent to the muih feedwater nozzles is the region which has experienced pipe cracks inlPWRs. The fracture mechanics analysis for this piping will be completed to ensure that Leak-Before-Break criteria will be met.

III. YIHRATION DESIGN CONSIDERATIONS -

i f l Piping is designed and supported to minimize transient and steady state vibration. Piping system vibration testing will be performed as de-scribed in FSAR Section 3.9.2 to ensure that piping system vibration'is within allowable levels.

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I Attachment F

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ST-HL- AE-1681 PFN: G9.10 Page 1 of 2 PROVISIONS FOR MINIMIZING STEAM / WATER HAMMER EFFECTS The reactor coolant, safety injection, chemical and volume control, and residual heat removal systems have been designed to preclude water hammer.

Westinghouse has conducted a number of investigations . into the causes and consequences of water hammer events. The results of these investigations have been reflected in STP design interface requirements to assure that water hammer events initiated in the 80P secondary systems do not compromise the performance of the Westinghouse supplied safety-related systems and compo-nents.

The lines in which postulated pipe ruptures are being eliminated and which have the potential for water / steam hammer effects are being designed to minimize or preclude such effects. Water hammer protection in each of these systems is described below:

1. Safety In.iection System The safety injection lines are all water solid at ambient temperature; thus, no water hammer is expected.
2. Chemical and Volume Control System (CVCS)

Normallyothe CVCS is water solid. In the low temperature lines (less than 125 F), water hammer would not be expected because of the small probability of steam void formation. In the high temperature lines, the piping has been designed to maintain water solid conditions during normal operation, thus minimizing the possibility of water hammer effects.

3. Reactor Coolant System Water hammer is not expected to be a concern in the reactor coolant system because it is designed to preclude steam void formation.

l 4. Residual Heat Removal (RHR) System The RHR system lines are all water solid; thus, no water hammer is expected.

5. Auxiliary Feedwater System A separate auxiliary feedwater line and nozzle has been provided to each steam generator to minimize the potential for water hammer. This is in l addition to the following design measures. The auxiliary feedwater

! discharge pipe inside the steam generator is arranged to prevent water draining from the pipe following a drop in steam generator water level.

! Piping volume connected to the steam generator nozzle which could form a l steam void is minimized by minimizing the length of horizontal inlet j piping. Specific design features to reduce the potential for condensation-induced water hammer were discussed in Attachments 3 and 4 of ST-HL-AE-1202 dated March 8, 1985 (see Note 1).

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l Attachment F ST-HL-AE- 1681 PFN: G9.10 Page 2 of 2

6. Steam Generator Blowdown System Blowdown flow from the steam generators is normally two-phase and of 0-7 percent quality. The normal flow regime between the steam generator and the blowdown control valve is slug flow. This section of pipe is run in horizontal and descending vertical legs to the piping low point drain located at the blowdown control valve. The normal flow regime downstream of the blowdown control valve to the flash tank lies in the dispersed flow regime. Operating procedures calling for gradually increasing flow into the normal operating range minimize the potential for water hammer downstream of the blowdown control valve which establishing flow during startup.
7. Main Steam System The main steam piping from the 5 way restraints just outside containment to the main turbine has a minimum slope of 6 inches per 100 feet of piping. Twenty-four-inch diameter drip legs are installed upstream of the main turbine inlet on the 24-inch and 30-inch main steam lines to collect and dispense drainage to the condenser. The branch lines that tee off the main steam lines are sloped and contain low point drains to eliminate the possibility of water hammer due to condensate water pockets collecting in low points.
8. Main Feedwater System Westinghouse has conducted extensive investigations into potential sources of water hammer in preheat steam generators as used on STP.

Initiation of main feedwater is controlled by procedure and system interlocks to minimize the potential for water hammer in the main feedwater system.

The routing of the main feedwater piping is in compliance with the Westinghouse criteria for layout, temperature monitoring / alarm, and operational procedures to minimize or eliminate water hammer. Although Westinghouse plants with preheat steam generators have never experienced a bubble collapse type water hammer event in the main feedwater system, the steam generators and feedwater piping are designed for these water hammer events. Specific design and operational features to reduce potential for water hammer are discussed in Attachments 1, 2 and 4 of ST-HL-AE-1202 dated March 8, 1985 (see Note 1).

! Note 1 i

The NRC acceptable evaluation of this justification for elimination of arbitrary intermediate breaks is provided in Appendix G to NUREG-0781 which is

, the Safety Evaluation Report related to operation of South Texas Project Units 1 and 2.

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