ML20101R793

Proposed Tech Specs Re HPCI Turbine Steam Exhaust Line

ML20101R793
Person / Time
Site:	Quad Cities
Issue date:	07/06/1992
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML19303E902	List: ML20101R787 ML20101R793
References
NUDOCS 9207160208
Download: ML20101R793 (27)

Text

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- AUACHMENI_3 AffECTEQ_PAGES._ LOR PROPOSED._ClyEES TO APEfRIX_A-i-

IECHMICALSEECIEICATIONS l 0060_ CITIES STallot 1 -.

UKIL1 FACILITY OPERATING LICENSLDPA-29 l

i Eage.Jiunttler.1 j 3.2/4,2 i 3.2/4.2-9 3.2/4.2-15

! 3.7/4.7 ' 3,7/4,7-38 l

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QUAD-CITIES DPR-29 settjng of 140% of rated steam flow, in conjunction with the flow limiters and main steamline valve closure,111mits- the mass inventory loss such that fuel:is not uncovered, fuel temperatures remain less than 1500*F,1and _

release of radioactivity to the environs is well below 10 CFR 100 guidelines--

(reference'SAR Sections 14.2.3.9 and 14.2.3.10).: ,

Temperature monitoring instrumentation is provided in the main 'steamline tunnel to detect-leaks in this area. Trips are provided on this _

instrumentation and when exceeded cause closure of Group l'isolatiom valves. Its setting of 200*F is low enough to detect: leaks of the order of 5 to.10 gpm; .tntsdt ii cspable 'of covering'the entire spectrum of breaks. "

For large breaks it is a backup to high-steam flow instrumentation-discussed above, and for small breaks with'_the resulting small release of-radioactivity, gives isolation before the guidelines of 10 CFR _100 are exceeded.

High radiatior.

detect gross fuel-failure. w itors in the main.steamline tunnel have been provided to valves, the only valves required to close for this accident. With theThis: ins.

established setting of--15 times normal background-(without hydrogen addi-tion) and main-steamline isolation valve closure.-fission-product release . . -

is-limited so that 10 CFR~100 guidelines are not exceeded for this accident (reference'SARLSection 14.2.1.7).

Pressure instrumentation is provided which trips when main-steamline-pressure drops below 825 psig. A trip'of this instrumentation results in closure of Group 1-isolation valves.

In the Refuel and-Startup/ Hot Standby modes this trip function is bypassed. -This function is provided primarily to provide protection against a pressure regulator malfunction which would cause the control and/or bypass valve to open. With the trip set at 825 psig, inventory loss is limited so that fuel:is not. uncovered and peak cladding temperatures are much less than 1500*F; thus,-there are no fission products available for rolease other than those in the.-reactor water; (reference SAR Section 11.2.3).

The- RCIC and the HPCI high ; flow and ~ temperature instr-ntation are provided .

to detect- a break in theirL respective piping.fTripping of this -

( finstrumentation results in actuation of tne McIC or of HPCI isolation

{ valves. Tripping logic for this functionLis the same'as that for the main steamline isolation valves, thus all_ sensors are required to be: operable or

\in a trioned condition to meet sinole-failure criteria.fThe trip settings of 170'F and 300% of design flow and . valve closure ttee are such that core uncovery is prevented and fission product release is within limits, c Q 7

/ M S 6 R T~ "A" lN S6 RT* W '

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3.2/4.2 Amendment'No.

L,., _-.

4 QUAD-CITIES OPR-29 The instrumentation which initiates ECCS action is arranged in a

' one-outf of-two taken twice logic circuit.- Unlike thJ reactor' scram cf reuits, however, there is one trip system _ associated with each function i rather than the two trip systems in the reactor protection system. The

' single-failure criteria are met by virtue of the fact that redundant core cooling functions are provided,-e.g.,' sprays and automatic blowdown and -

highpressurecoolantinjection. The specification requires that if_a trip system becomes inoperable, the system which it activates is declared' inoperable. For example, if the 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 effectiveness of the system with respect to the single-failure criteria even during periods when maintenance or testing is being_ performed.

The control rod block functions are provided to prevent excessive control rod withdrawal so that MCPR does not go below the MCPR Fuel Cladding Integrity Safety Limit. The trip logic.for this function.is.one out of n; i

e.g., any trip on one of the six APRM's, eight IRM's, four SRM's will result-i in a rod block. The minimum instrument channel requirements aJsure sufficient instrumentation to assure that the single-failure criteria are met. The minimum instrument cht:nel requirements for the RBM.may be reduced by one for a short period of tin # to allow for maintenance, testing, or calibration. This r.ime period is only & 3% of the operating time in a month and dnes not significantly increase the risk of preventing an in:dvertent control rod withdrawal.

I W t'RM 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 i 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-biased 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 boiling in a local region of the core for a single rod withdrawal' error from a limiting control rod pattern.1The trip point _is flow biased. The worst-case single control rod withdrawal error is analyzed l

for each reload to assure that, with the specific trip settings, rod i

withdrawal is blocked before the'MCPR reaches the fuel cladding integrity safety limit.

3.2/4.2-9 Amendment No.

1

', ... , s QUAD-CITIES j OPR-29

.* TABLE 3.2-li

INSTRUMENTATION THAT' INITIATES PRIMARY. CONTAINMENT ISOLATION FUNCTION I Hinimum Number

of Operable or l Tripped

. Instrument Channels [1], Instruments. Trio Level Settino

--_ Action [21 .

4 .

Reactor low water [5] >144 inches above top of A active-fuel" i 4 Reactor low low water - >84 inches above top of A j

active fuela 4 High drywell pressure [5] 12.5 psig [3] A-j 16 High flow main suaaline[5] $140% of rated steam flow 8- - -

! 16 High temperature main <200*F B j steamline tunnel

! 4 High radiation main <15 x-normal. rated power-- B

steamline tunnel [6] Eackground (without hydrogen addition) 4 Low main steam pressure [4]

{ >825 psig B i 2 High flow RCIC steamline <300%'of rated steam

C Tiow[7]

4 RCIC turbine area high <170*F-

[

temperature - C i 2 High flow HPCI steamline <300% of rated steam i

D

-Tlow[7]

4 HFCI area high temperature $170*F D-

! b- 7 Notes 1

. IMSIE R T "bv

[1] Whenever primary containment integrity is required, there shall be two j

operable or tripped systems for each function, except for low pressure main steamline which only-need be available in the Run position.

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3.2/4.2-15 Amendment No.

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.QUAO-CITIES-OPR-29 1

j TABLE 3.7-1 (Cont'd)

,l PRIMARY CONTAINMENT ISOLATION Valve-Number Number of Mailmum-

{ for Power-Operated Operating Normal Action on i Isolation Valve Units Valves .

Time Operating- Initiating

Group Identification 1 and 2 Inboard -Outboard (sec) Position Signal

{

, Reactor Water Cleanup i

j 3 Pump suction isolatior valve M0-1201-2 1 <30 0 GC l 3 Pump suction isolation i valve M0-1201-5 1 130 0 GC j HPCI l 4 -Steam 5- isolation i valve MO-2301-4 -1 -

<50 0 GC

{ 4 Steam isolation valve MO-2301 1 150 -0 -GC RCIC y

5 Turbine steam

) supply MO-1301-16 1 <25 0 GC i 5 Turbine steam j supply MD-1301-17 1 0 GC 1

125 L

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3.7/4.7-37 Amendment No.

QUAD-C!T!ES OPR-29

.. TABLE 3.7-1 (Cont'd)

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

Group 1:

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

1

1. Reactor low-low-water level

2. Main steamline high radiation

3. Main steamline high flow

4. Main steamline tunnel high temperature

5. Main steamline low pressure Group 2:

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

1. Reac+or low water level

2. High drywell pressure Group 3:

Reactor low water leve' alone initiates the following:

1. Cleanup demineralizer system isolation 4:

Group / closed upon any one of the following si 9 s/solationvalvesintheh 1 tac Ste e 1. HPCI steamline high flow Supply 2. High temperature In the vicinity of the HPCI steamline

3. Low reactor pressure

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3.7/4.7-38 Amendment No.

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INSERT "A" "A trip of this instrumentation results in closure of the RCIC or HPCI steam supply isolation 1 valves. The trip logic for this function is similar to that for the main stocmline isolation valves, thus ail sensors are required to be operable or in a tripped condition to meet single-failure criteria."

4

) Itl3ERT "B" "In addition, the steam supply valves for each system are closed on low steamline pressuro to l

, provide primary containment isolation when the reactor pressure, as sensed in the system I steamlines. is below the required pressure for turbine operation."

INSERT "C"

" Operation of the HPCI ?.urbine will continue as long as reactor pressure is above 150 psig.

j When the reactor pressure falls below 150 psig, the speed of the turb;ne pump unit will decrease and gradually be slowed due to stop friction and windage losses at low reactor pressures. Tt e low reactor pressure isolation setpoint was developed in accordancu with 4

NEDC 31336, " General Electric Instrument Setpoint Methodology," dated October,1986. The

trip setpoint of greater than or equal to 100 psig was calculated such that the isolation will 4

occur on decreasing reacto' pressure 'o provide primary contalinnant isolation when the

reactor pressure, as sensed in the *ystem steamlines,is below the required pressure for turbine operation. The external vacuum heaker line for the HPCI turbine willisolate on low steamlino pressure concurrent with high drywell pressure signals. The instrumentation and controls

ensure the proper HPCI and primary containmerit response to a HPCI steamline break (isolation

of the steamline supply valves only), & Mge break insioe the containment (closure of the stearr.

supply and vacuum relief isolation valvess and a smell or intermediate size break inside containment (steam supply and vacuum breaker isolation valves remain open for HPCl ope' 9 tion)."

l INSERT "D" "4 HPCI Steamline pressure 2:100 psig D" INSERT "E" "4 Vacuum breaker isolation MO-2399-40 1 s 50 0 GC" "4 Vacuum breaker isolation MO 2399 41 1 s 50 0 GC" 1

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! "The turbine exhaust vacuum breaker isolation valves close when both of the i following signals are present (simultaneously):

i 4

1. High drywell pressure j 2. Low reactor pressure l Group 5: Isolation valves in the reactor core isolation ,coling system (RCIC) are closed upon j any one of the following signals:

i i 1. RCIC steamline high flow

2. High to nperature in the vicinity of the RCIC steamline

3. Low reactor pressure" .

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i EVALUAII0tLOLSIGN AIICANLHAZARDS_CONSIDERAIION10R l ER0 POSED 3HAhGESJQ REENDIX.A_1ECHNICALSPICILICATIONS ,

k 00ADl111LS_SIA110N l UNIL1 4

i i !AGiMJLDPIMIINGJ.ICENSE_D&21 i

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<t i The proposed changes outlined in=this amendment request would

3 -

f Reflect a proposed modification to.the HPCI turbine steam exhaust i 1.

i line vacuum breaker configuration scheduled for:the upcoming cycle 12 i refueling outage.. The modification will create a new primary )

3 containment boundary such that the steam exhaust line check valve -

l 2301-45_can be removed from the 10 CFR 50, Appendix J 1eak rate

testing program and incorporated into the Inservice Testing Program 4 according to Section XI of the _ASME Code per 10 CFR-50.55(g),

e f 2. Amend the current Technical Specification to correct an omission of j the HPCI low pressure isolation setpoint to Table'3.2-1._  ;

t t 3. Amend the current Technical Specification to add two new vacuum'line  !

l primary containment isolation valves to Table 3.7-1.

?

i Commonwealth Edison has reviewed the proposed amendment in accordance t.ith the '

e criteria delineated in 10 CFR 50.91,: and has concluded that the proposed j amendment does not present a significant hazards consideration. -The basis _for j the determination is as follows:

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t%51530iLN0_SIGNI EICAN Ul4ZARDS_CONSI DERAU DN Commenwealth Edison has evaluated this proposed amendment and determined that It involves no significant hazards consideration. In accordance with the criteria of 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:

1. Involve a sisinficant increasc in the probabillty or consequences of an accident retvlously evaluated because:

lahle_L2-1 The addition of the HPCI steam line low pressure isolation setpoint to Technical Specification Table 3.2-I is a correction of an omission to the original Technical Specification. The HPCI system primary containment a isolation feature is part of the original design basis for the system; however, the isolation setpoint has not been included in the Technical Specification. The proposed change corrects this omission by adding the low pressure isolation setpoint and limiting conditions for operations to Technical Specification Table 3.2-1. The calculation which supports the proposed setpoint assures that HPCI is not prematurely isolated. The isolation setpoint does 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 isolation setpoint to Technical Specification Table 3.2-1 will ensure that steam and radioactive gases will not escape from the HPCI turbine shaft seals into the reactor building after steam pressure has decreased below turbine operating pressure. CECO has performed a calculation to confirm the value of the proposed low pressure isolation setpoint (100 psig). The criculation ensures that the isolation does not occur prior to the low pressure assumed in the fuel accident analysis of 150 psig. The lower bounding limit for isolation is based on engineering judgment and is conservative when compared to the anticipated stall pressures for the HPCI turbine.

The HPCI Icw pressure isolation setpoint, therefore, does not increase the consequences of the accident but rather provides further assurances that the isolation function is initiated at an appropriate pressure.

Jahle_L1-1 The elimination of the extr. ting 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 the torus, creates a potential flow path from the containment air space through the existing vaceum 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 CFR 50, Appendix J.

sc1:1849 13

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j The proposed modification changes-the primary containment boundary. The j modification does not affect any accident initiators and therefore does

! not affect the probability of an accident. The design-features of the new 3 vacuum breaker assures that the consequences of an accident _are not increased. The new design isolates the torus air space from the HPCI i

} steam exhaust line through the use of motor-operated valves. The new i vacuum breaker valves are designed to accommodate 10 CFR 50, Appendix J j leak rate testing and will be added to the Station's 10 CFR 50, Appendix J  ;

Test Program. As such, the valve leakage will be included in the_ limits i j for containment leakage, as defined in the Technical Specifications, to _

j ensdre that the resulting doses wlII-not exceed 10 CFR, Part 100 limits.

The consequences of.the accident are also unaffected by the closure time i of the new motor-operated valves. The valve closure time is based on the -

~

j ability of the valve to close and does not significantly affect the dose-i rates. The specified closure time is typical of current motor-operated i isolation valves in the HPCI system and is less'than'the_ time where, _ i i significant fuel failure occurs during a design basis loss-of-coolant  :

I accident. '

i .

i Finally, the isolation logic assures that.the HPCI system is isolated during conditions'_in which the HPCI reactor inventory or pressure co_ntrol function cannot be maintained and-there is indication of i large break-in l the drywell. This isolation logic assures that the consequences of the 7 accident are not significantly increased by providing the necessary j isolation of containment during_ accident conditions.

! 2. Create the possibility of a new or different kind of accident from any j previously evaluated because:

i l Intile_12-l I

j As indicated previously, the HPCI=1ow reactor pressure isolation-function

! was included as part of the original system design; however, a lim, ting

{ condition for operation and instrumentation setpoint was:not included in-i Technical Specification Table 3.2-1. As.such,-the-propo'id amendment =does not introduce the use of new equipment which has'a different_ failure  !

mechanism or whose failure'is considerably more probable that the existing equipment. The proposed change to_ Table 3.2-1, therefore, does not create- l the possibility of a new or different kind of accident from any previously

evaluated. y

IRble 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 va M ) and a more L effective isolation boundary _ design (motor-operated gab valve versus- ,

i check valve). The HPCI isolation sensors-and control: logic are optimally ,

! arranged to provide a high' degree of reliability. ' Independence is provide to each isolatten valve so that no single failure will prevent'the isolation function. Periodic testing of instruments and valves ensures I

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i that the isolation function of the valves is maintained within design parameters. Manual operation of the valves (both local and remote) is a i 4 backup in the unlikely event of a failure to automatically isolate. I 1

!' The control logic for the new isolation valves provides reliable operation for HPCI nerformance. The new valves will be normally open during '

operation. Therefore, the valves are not required to stroke from their

! normal position in the case of a HPCI initiation. The valves will l automatically isolate on indications of a large break inside containment (drywell pressure grtater than 2.5 psig) and when HPCI is no longer ,

i capable of providing pressure control and/or reactor water inventory.

i A gross failure of the vacuum breaker function and/or new containment isolation valves in the closed position has been evaluated for the potential hazard of collapsing the turbine exhaust line and containment i' penetration due to a vacuum. Using conservative parameters for the HPC1 exhaust piping (length-to-diameter - 50 and diameter-to-thickness = 40)

J and the methods of ASME Section III NB-3133.3 (cylindrical shells made of l low yield carbon steel), the capability of the exhaust piping exceeds a '

j maximum external pressure of 300 psia. Since the maximum theoretical external pressure is less than 15 psia, the collapse of any HPCI turbine exhaust component is not a concern.

1 Finally, the proposed design for the new vacuum breaker is consistent with

the design of newer BWR plants for external vacuum breaker lines (e.g.,

LaSalle RCIC).

l 3. Involve a significant reduction in the margin of safety because:

i

, Jable A Z-1 3

i As previously indicated, the original. design for the system included the HPCI low reactor presaure isolation function. The existing setpoint for the HPCI isolation is iO psig which is based on previous operability

. requirements for HPCI. The new calculated setpoint (100 psig) does not involve a significant reduction in the margin of safety since the calculation inputs; (1) assure that the HPCI function will remain Operable i during periods when the HPCI system is required to support the assumptions

in the accident analysis; and, (2) assure that the isolation of the HPCI system will occur prior to reaching the stall pressure for the turbine.

The lower bound for the calculation is conservative when compared to the anticipated stall steam pressures typical of turbines similar to the Quad Cities design. The margin of safety remains essentially unchanged in that

, the isolation setpoint has not significantly changed from the current value used to isolate the turbine prior to steam pressure reaching a level i where the turbine can no longer operate.

Iahle_3J-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 require that the containment undergo testing as specified in 10

, CFR 50, Appendix J. Due to the modification of the containment boundary l

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4 8 A 6 i with the new vacuum breakei line, the motor-operated valves will be tested l

! in accordance with 10 CFR 50, Appendix J to ensure TS leakage limits c:e i maintained. The testing kill ensure that any potential leakage will i

! result in dose limits well below 10 CFR, Part 100 limits. In addition, the existing containment boundary for the HPCI steam exhaust system i

! uttilzes the suppres lon pool inventory (as an effective water seal) and two large check valves. One of the check valves is testable and will

continue to be tested according to Section XI'of the ASHE Code per 10 CFR 50.55(g), to ensure that the HPCI turbine exhaust line does not experience water leaks.

The closure time for the HPCI vacuum breaker isolation valves does not significantly decrease the margin of safety. The closure times are based on reasonable closure times for the motor-operated valves. The specified  ;

closure time is typical of current motor-operated isolation valves.In the HPCI system and is less than the time where significant fuel failure

occurs during a design basis loss-of-coolant accident.

Finally, the isolation logic is designed to assure thdt HPCI remains in a ,

" standby" operational mode and isolates during conditions which are.

Indicative of a large break in the drywell concurrent with an insufficient steam pressure to suppoit the HPCI system function. ,

Therefore, since the proposed license amendment satisfies the criteria specified in 10 CFR 50.92. Commonwealth Edison has determined that a no significant hazards consideration exists for these items. We further request their approval in accordance with the provisions of 10 CFR 50.91(a)(4) i i

sc1:1349:16 ,

ATJACHMENL_5 LNVIRONMENI ALASS ESSMfELf 0fLEROPOS ED_CHANGF.LIQEPINDIX_A IECllNICALSP[CIEICAllDNS QUAD _CIIIES_SIAT10M UNIL_1 I

[ACILIILDPIRAIJNGlICENSLDPR-29 j i

The proposed Ganges to the Quad Cities Nuclear Power Station Technical Specifications lavolve:

1. A proposed modification to the HPCI turbine steam exhaust Ilne vacuum breaker configuration scheduled for the upcoming cycle 12 refueling outage. The proposed modification will create a new primary containment boundary such tha* the steam exhaust line chect valve '

2301-45 can be removed from ti- 10 CFR 50, Appendix J 1eak rate testing program and incorporated into the Inservice Testir.g Program according to Section XI of the ASME Code per 10 CFR 50.55(g). The new primary containment will consist of two motor-operated 4-inch gate valves as discussed in Attachment 1 of this amendment request.

2. The addition of the HPCI low pressure isolation setpoint to Table 3.2-1.

3. The addition of two new vacuum line primary containment isolation valves to Tab 1' 2.7-1. The new isolation valves will establish a new boundary for tne HPCI steam exhaust line and are required to be tested in accordance with 10 CFR 50, Appendix J requirements. The testing will ensure that the containment leakage remains within TS Ilmits and as such, will ensure any resulting dose will remain within 10 CFR, Part 100 limits. The isolation logic for the new valves will ensure that the potential leakage path is isolated under conditions indicative of a large break loss-of-coolant accident where HPCI operation is inhibited due to reactor low pressure.

4 scl:1849:17

! Commonwealth Edison has evaluated the proposed amendment in accordance with l the requirements of 10 CFR 50.21, and has determined that the amendment meets l the requirements for categorical exclusion as specified by 10 CFR 51.22 (c)(9).

Commonwealth Edison has evaluated the proposed changes cg inst the criteria ~of 10 CFR 50.92 (c) and determined that the proposed changes do not present a significant hazards consideration. The basis for that determination is l

provided in Attachment 4.

The proposed amendment does not change the types of effluents or increase the amounts of effluents that aiy be released offsite. The proposed changes have no significant affect on individual and cumulative occupational radiation exposure nor are any significant increases likely to occur due to the proposed amendment. Commonwealth Edison is currently testing the HPCI steam exhaust check valve on an accelerated schedule due to poor performance. As a result, occupational radiation exposure associated with this valve is higher than normally expected for the maintenance of a containment isolation valve. The installation and maintenance of the new vacuum breaker isolation valves is not expected to "asult in any significant increase in occupational exposures, in conclusion, the proposed Technical Specification amendment will not result in any increase in environmental consequences and does not involve  ;

trreversible consequences beyond those already accepted-by the NRC in the Final Environmental Statement.  ;

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Figure 1 HPCI TURBINE EXHAUST LINE MDDIFICATION TO CDNTRDL RDDH <-

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LOGIC (2399-40,41 VACUUM BREAKERS)

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se s e DIV. II OL. RESET N/ 2

Enclosure 2 GENERAL ELECTP.!C COMPANY i

AFFIDAVIT I, David J. Robare, being duly sworn, depose snd state as follows:

1. I am Manager, Plant Licensing Services, Gereral Electric Comoany, 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.

4 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 st;pply pressure low channel. The calculation was performed consistent with the GE proprietary document, " General Electric Instrument betpoint Methodology, NEDC-31336," dated October 1986.

"A trade secret may consist of any formula, pattern, device or compilation of inforrr.stion which is used in one's business and which gives him an opportunity to obtain an advantage over competitors who do not knott 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 deter niniig whether given information is one's trade secret are (1) the m. tent to which the information is

' known outside of his business; (2) the extent to which it is known by employees and others involved in his business; (3) the i

extent of measures taken by him to gitard 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 I the informttion could be properly acquired or duplicated by others."

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

t l a. Information that discloses a process, method or apparatus where prevention of its use by General Electric's competitors without license from General Electric constitutas a competitive economic advantage over other cortpanies;

b. Information consisting of supporting data and saalyses, 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; l

I

s... ,,

J Enclosure 2 GENERAL ELECTRIC COMPANY  ;

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 Electr.  ;

f. Information which discloses patentable subject matter for which  !

4 it may be desirable to obtain patent protection;

g. Information which General Electric must treat as proprietary according to agreements with other parties.

i

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

.i 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 oxternal 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 cognizar.t Marketing function (or delegate) and by the Ltgal Operation for technical content, competitively effect and crermination of the accuracy of the proprietary designation in

acurdance with the standards enumerated above. Disclosures outside General Electric are generally limited to regulatory bodies, customer /

and potential customers and their agents, suppliers and licensees then only with appropriate protection by applicable regulatory provisions or proprietary agreements.

6. The documer.t 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 j been held > in confidence by the General Electric Company, ne public-disclosure has been made, and it is not avaihble in public sources.

All disclosures to third parties have been made pursuant to regulatory provisions of proprietary agreements which provide for ,aintenance 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 Genera!

Electric Company and deprive or reduce the availability of profit making opportunities because it would provide other. parties, including competitors, with valuable information.

Enclosure 2 GENERAL ELECTRIC COMPANY STATE OF CALIFORNIA )

) 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.

1 Executed at San Jose, California, this 81 bday of 3ONE 19 9l, Davic J. Robara General Electric Company SubscribedandswornbeforemethisINdayof 5'Lt al 19Cf l .

')

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$A$h.H G1Lk L Y . Y LL2 n we a n evne . caumma Hotary Public, State of Cajifornia -

I 31MTA M N Y W came, easkes W L M I

[*o 4 Enclosurc 3 i

EB RAE E5 information EpWW n letter SERVICES l

x

! October 31, 1973 SIL No. 30 Category 2 i

j HPCI/RCIC TURBINE EXHAUST LINE VACUUM BREAKERS Surveillance testing of the HPCI/RCIC systems at many operating BWRs has

} disclosed an undesirable exhaust line vacuum condition that causes one or more of the following adverse effects:

l l 1. Pressure instability in the exhaust line.

I j 2. Cycling and slaming of the exhaust line . heck valves.

l 3. Pipe and torus vibration.

J

{ 4. Water slug carryover.

t j 5. Post shutdown vibration caused by steam collapse.

Investigations into this phenomenon.during the course of pre-op activities j at Browns Ferry 1 and Peach Bottom 2 have concluded that HPCI/RCIC systems

! can benefit significantly by the installation of vacuum breakers on the  ;

i turbine exhaust lines. Tests conducted at Browns Ferry and Peach Bottom j confirmed that the installation of vacuum breakers improves low load opera-l tiun and provides acceptable turbine shutdown conditions by minimizing pressure fluctuations. Also, the installation of these vacuum breakers will prevent water from rising in the turbine exhaust line during a pos-tulated LOCA when the torus would become pressurized.

I The minimum vacuum breaker size reconsnended is 2 inches for HPCI turbine l exhaust, and 14 inches for RCIC turbine exhaust. The vacuum breaker check l! valves should have a pressure drop of less than 0.5 psi to assure adequate vacuum breaker capability. .

Figures 1 & 2 (attached) provide schematics of thelrecomended installation.

] Note that Figure 1 appines to plants having HPCI systems whereas Figure 2

is applicable to HPCI/RCIC systems, i

i i

b warranty or representat;on expressed or implied is made with respect to the accuracy, completeness or usefulness of this informatiort General Electric Company assumes no responsibility for liability or damage which may result from the use of this information.

4 NUCLEAR ENERGY DIVISION e BWR SERVICES e SAN JOSE, CALIFORNI A GEN ER AL h ELECTRIC

o.* -.

Enclosure 3 SIL No. 30 Page 2 Note also that both vacuum breaker configurations include provisions for positive isolation of the suppression pool air space. This provision is in compliance with AEC criteria that check valves not be used for long term isolation. The positive isolation should be automatically inTtTated by a combination of low reactor pressure and high drywell pressure. The existing low reactor pressure switches may be used, combined with exist-ing "2 psig" tigh drywell pressure switches. Electrical separation should be maintained to the redundant isolation switches.

Remote manual switches in the control room are not requiradt local switches are considered adequate. However, control room indicating lights should be provided, plus an alann annunciating "YACUUM BREAKER ISOLATION VALVES NOT FULLY OPEN."

If additional help in implementing this recomended installation is desired, General Electric would_ be pleased to provide a quotation for supplanental engineering or installation assistance.

Prepared by: V. G. Grayhek Approved by:

0.' G. Bricenbaugh,FManager h[Ab Issued by:

V. G. GrayKek, Manager Performance Evaluation and Perfonnance Analysis and Improvement Service Comunications Product

Reference:

E41 - HPCI System E51 - RCIC System

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