ML20217P935

Proposed Tech Specs Section 3/4.4.2,implementing More Appropriate SRV Setpoint Tolerances

ML20217P935
Person / Time
Site:	Hope Creek
Issue date:	04/28/1998
From:	Public Service Enterprise Group
To:
Shared Package
ML20013H969	List: ML20217P922 ML20217P935
References
NUDOCS 9805070143
Download: ML20217P935 (8)

Text

I Document Control Desk LR-N97117 LCR H97-10 HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NPF-57 DOCKET NO. 50-354 SAFETY RELIEF VALVE SETPOIN'I TOLERANCES TECHNICAL SPECIFICATICd PAGES WITH PROPOSED CHANGES The following Technical Specifications for Facility Operating License No. NPF-57 are affected by this change request, j

Technical Specification Page I

3.4.2.1 3/4 4-7 4.4.2.2 3/4 4-8 9005070143 990428 PDR ADOCK 05000354 P

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,ygg REACTOR C0OLANT $YSTEM 3/4.4.2 SAFETY / RELIEF VALVES

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SAFETY / RELIEF VALVES LINITING C00SITION FOR OPERATION 3.4.2.1 The safety valve function of at least 13 of the following reactor coolant system safety / relief valves shall be OPERA 8tE*# with the specified code safety valve function lift settings:**

4 safety-relief valves 91108 psig M */o 5

safety-relief valves 9 1120 psig d 3%

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safety-relief valves 91130 psig i p4 APPLICA8ILITY: OPERATIONAL C00EITIONS 1, 2 and 3.

ACTION:

a.

With the safety valve function of two or more of the above listed fourteen safety / relief valves inoperable, be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

b.

With one or more safety / relief valves stuck open, provided that suppression pool average water temperature is less than 110*F, close the stuck open safety relief valve (s); if unable to close the stuck open valve (s) within 2 minutes or if suppression pool average water temperature is 110*F or greater, place the reactor mode switch in the Shutdown position.

c.

With one or more of the above required safety / relief valve acoustic moni-tors inoperable, restore the inoperable monitors to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in COLD SHUTDOWN within the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

• SRVs which perform as ADS function must also satisfy the OPERABILITY requirements of Specification 3.5.1, ECCS-Operating.

• • The lift setting pressure shall correspond to amb' ent conditions of the valves at nominal operating temperatures and pressures.

1. SRVs which perform a low-low set function must also satisfy the OPERA 8ILITY requirements of Specification 3.4.2.2, Safety / Relief Valves Low-Low Set Function.

HOPE CREEK 3/4 4-7 Amendment No. 64

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' SURVEILLANCE REQUIREMENTS 4.4.2.1 The acoustic monitor for each safety / relief valve shall be demonstrated OPERABLE with the setpoint verified to be s 30% of full open noise level ** by performance of a:

a.

CHANNEL FUNCTIONAL TEST at least once per 31 days, and a t.

CHANNEL CALIBRATION at least once per 18 months *.

4.4.2.2 At least 1/2 of the safety relief valve pilot stage assemblies shall be remcVed, set pressure tested and reinstalled or replaced with spares that have been previously set pressure tested and stored in accordance with manufacturer's recommendations at least once per 18 months, and they shall be rotated such that all 14 safety relief valyc pilot stage assemblies are removed, set pressure tested and reinstalled or replaced with spares that have been previously set pressure tested and stored in accordance w manufacturer's recomendations at least once per 40 months. (ith 4.4.2.3 The safety relief valve cuin (mechanical) stage assemblies shall be set pressure tested, reinstalled or replaced with spares that have been previously set pressure tested and stored in accordance with manufacturer's recomendations at least once every 5 years.

• The provisions of Specification 4.0.4 are not applicable provided the Surveillance is performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure is adequate to perform the test.

• • Initial setting shall be in accordance with the manufacturer's recomendations. Adjustment to the valve full open noise level shall be accomplished after the initial noise traces have been analyzed.

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HOPE CREEK 3/4 4-8 Amendment No. 64

Documsnt Control Desk LR-N97117 LCR H97-10 l

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ATTACHMENT 4 l

GENERAL ELECTRIC AFFIDAVIT l

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1 General Electric Company i

AFFIDAVIT I, George 11. Stramback, being duly sworn, depose and state as follows:

(1) I am Project Manager, Regulatory Services, General Electric Company ("GE") and have been delegated the function of reviewing the infonnation 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-32511P, Safety Review for Hope Creek Generating Station Safety / Relief l'alve Tolerance <fnalyses. Class 111 (GE Proprietary Information), dated April 1996.

The proprietary infomtation is delineated by 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 Infonnation 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 Eneruv Proiect v. Nuclear Reculatory Commission _,975F2d871 (DC Cir.1992), and Public Citizen llealth Research Groun

v. FDA,704F2d1280 (DC Cir.1983).

(4) Some examples of categories of information which fit into the definition of proprietary information are:

Information that discloses a process, method, or apparatus, including supporting a.

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; 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:

GBS-98 2-athopeereek_srv_to!erance. doc Affidavit Page 1

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Infonnation which reveals cost or price information, production capacities, c.

budget levels, or commercial strategies of General Electric its customers, or its suppliers; d.

Information which reveals aspects of past, present, or future General Electric customer-funded development plans and programs, of potential commercial value to General Electric; Information which discloses patentable subject matter for which it may be e.

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 infonnation 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. The infbrmation sought to be withheld has, to the best of my knowledge and belief, corHstently been held in confidence by GE, no public disclosure has been made, an( it is not available in public sources. All disclosures to third parties including ary required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the infonnation in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set fbrth in paragraphs (6) and (7) following.

(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 document typically requires review by the staff manager, project manager, principal scientist or other equivalent 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 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), above, is classified as proprietary because it contains detailed results of analytical models, methods and processes, including computer codes, which GE has byeloped, obtained NRC approval of, and applied to perform evaluations of the loss-of-coolant accident for the BWR, l

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1 The development and approval of the BWR loss-of-coolant accident analysis computer codes used in this analysis was achieved at a significant cost, on the order i

of several million dollars, to GE.

I The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience l

database that constitutes a major GE asset.

l (9) Public disclosure of the infonnation sought to be withheld is likely to cause l

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 I

extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In j

addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

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The research, development, engineering, analytical and NRC review costs comprise a sabstantial investment of time and money by GE.

4 The precise value of the expertise to devise an evaluation process and appiv the i

correct analytical methodology is difficult to quantify, but it clearly is substantial.

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l GE's competitive advantage will be lost ifits 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 unive at the same or similar conclusions.

i The value of this information to GE would be lost if the infonnation were disclosed to the public. Making such information available to competitors without their 1

having been required to undertake a similar expenditure of resources would unfairly provide 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 analytical tools.

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STATE OF CALIFORNIA

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ss:

COUNTY OF SANTA CLARA

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George B. Stramback, being duly sworn, deposes and says:

That he has read the foregoing affidavit and the matters stated therein are true and correct I

to the best of his knowledge, information, and belief.

Executed at San Jose, California, this2M day of dd 1998.

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PAUM F. HUSSEY cow. #1cei20 g

Gedrge B. Stramback

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Pt c General Electric Company e,

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.j My comm. F. wee osc 1.190s (

Subscribed and sworn before me this bday of hpril

1998,

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No'tary Public, State of Qifornia t

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