ML20092P177

Forwards Proprietary & Nonproprietary Responses to NRC 840517 Questions Re Analog Transmitter Trip Sys Tech Spec Package Submitted on 840123.Proprietary Responses Withheld. GE Affidavit Dtd 840605 Encl

ML20092P177
Person / Time
Site:	Hatch
Issue date:	06/07/1984
From:	Gucwa L GEORGIA POWER CO.
To:	Stolz J Office of Nuclear Reactor Regulation
Shared Package
ML19269A334	List: ML20092P177
References
NED-84-281, TAC-54169, TAC-54433, TAC-54607, NUDOCS 8407060028
Download: ML20092P177 (21)

Text

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• Georgia Power Company 333 Piedmont Avenue ,

Attarna. Georg a 30308 Telephone 404 52G4526 Ma*ng Addrew Past Office Box 4545 A:lanta, Georg a 30302 Georgia Power L T. Gucwa tre southern etectic system Manager Nuclear Er gineenng and Chief Nuclear Engtneer NED-84-281 aine 7, 1984 1

Director of M1 clear Reactor Regt11ation Attention: Mr. John F. Stolz, Chief Operating Reactors Branch No. 4 Division of Licensing U. S. M1 clear Regulatory Comnission Washington, D. C. 20555 NRC DOCKET 50-366 OPERATING LI NSE NPF-5 EININ I. HA'ICH NLCIEAR PIANf LNIT 2 RESIONSE 'IO NRC STAFF QUESTIONS ON PROPOSED A'ITS TECHNICAL SPBCIFICATION GANGES Gentlemen:

On May 17, 1984, Georgia Power Conpany along with several other ergineering alpport organizations : net with members of the NRC staff by ,

telephone to discuss specific aspects of the proposed Analog Transmitter Trip System (ATTS) Technical Specification package which was albmitted on Janlary 23, 1984 (NED-84-017) . Attachment 1 provides a list of persons involved in that disalssion. The NRC asked fourteen specific glestions concerning A'ITS design and licensing, to which GPC provided partial answers daring the teleconference. Attachment 2 - to this letter provides a sanmary of those cpestions and doalments the final GPC response to each individual item. Attachment 3 provides information prepared by the ATTS vendor (General Electric Conpany) which addresses setpoint cala11ation methodology, and which also addresses the applicability to Plant Hatch of ten open issues 3 between the NRC and GE regardity the setpoint methodology for NIDL plants,  !

which differs from that used for Plant Hatch in several inportant areas.

- Attachment 3 contains information which is considered proprietary by the General Electric Company. 'Iherefore, that portion of this sibnittal should be withheld from public discloalre for the reasons stated in the enclosed affadavit (Attachnent 4) .

Sincerely yours, ,

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M J. P. O'Reilly (NRC- Region II) a Senior Resident Inspector. s >Y

ATTACINENf 1 NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDWIN I. HA'ICH NUCLEAR PLANT UNIT 2 RESPONSE 'IO NRC STAFF QUESTIONS ON PROPOSED ATIS 'IKHNICAL SPECIFICATION CHANGES

'Ite followirg persons were involved in the May 17, 1984 telephone confereme on the Hatch-2 ATIS:

Maclear Regulato'y Coninission:

Prasad Kadambi Marty Virgillo Jerry Mauck Georgia Power Company:

Ray Baker 01ris Shiver Southern C g ny Services:

Tom Milton Charles Pierce Karen handell Bechtel Power Corporation:

Doug Disnukes Damir Udbinack John Yee Randy Snapp Marty Schwartz Charles Feltnan Larry Rowe General Electric Company:

' Jerry Dain Larry Chi Al Warg JUN O 71984

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ATTACifENT 2 NRC DOCKET 50-366 OPERATING LICENSE NPF-5 EDNIN I. HAICH NUCIEAR PLANT (NIT 2 RESPONSE TO NBC SPAFF QUESTIONS ON PROPOSED ATIS TECHNICAL SPECIFICATION CHANGES 1

4 JUN 0 71984

f QUESTION 1-1 Please supply information relating to the power supply arrangment for the ATTS units within the RPS systs on both the primary and backup power systes. Also, please supply information with regard to the RPS and IECS on how GPC ensures that an undervoltage condition could not exist which would incapacitate the trip functions for those syste s.

RESPONSE l-1

%e RPS portion of the ATTS is supplied, as is the reainder of the RPS, frm the RPS MG set which has a class lE undervoltage trip that initiates a scrm on undervoltage. %e systs itself is a fail-safe systen; therefore, with a loss of power, all instrments go to their safety positions. %is arrangenent is consist.ent with the original design bases of the plant. -

The EOCS portion of the ATTS is powered off the plant batteries. n e class lE batteries are divisionalized and supplied by chargers that are powered off the energency buses. % e batteries are sized per FSAR Section 8.3.2.1.1.a for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> continuous duty without the charger. The power supply for the ECCS portion of AITS is consistent with the original design basis of the plant.

%e installation of the A7TS systen has not affected the design of the Plant Hatch ECCS and RPS power supplies. Undervoltage protection for the EOCS portion of the systen is provided by the Class lE batteries which are supplied' by chargers that are powered fran the energency buses. % e RPS portion of the AITS systen is protected by redundant Class lE output breakers which will deenergize the RPS bus on an undervoltage condition.

The minimm voltage that the batteries would ever show based on the FSAR raguirement is 105 vdc. %e ATTS has voltage converters which work frc.n 105 to 140 vdc on the input-output to give a nominal output of 25 vde and a full load voltage of 23.5 vdc. %e ATTS is designed to operate with a minimtzn voltage of 23.5 vdc; therefore the ATTS function is assured.

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QUESTION 1-2 l l

Does the MG set on the RPS systs also supply sme non-class lE loads, and if so, what type of isolation devices separate the class lE and non-class lE 1 systes? Also, what type of surveillance is performed on those isolation devices?

RESIONSE 1-2

%e MG set on the RPS syste supplies only non-class lE loads. % e RPS syste itself is not a class lE systs; however, it does have separate class lE undervoltage protection. @is is consistent with the original design bases of.the plant.

The ECCS DC distribution panels which supply essential DC power to the ECCS ATIS cabinets also supply se e non-class lE loads. % ese distribution panels are supplied frm the plant class lE batteries which are backed up by chargers fed by the mergency buses. Breakers are used to separate the non-class lE and the class lE systes. %is is also consistent with the original design basis of the plant

%e addition of ATIS into the plant design does not modify the original licensing basis of the plant with respect to the application of breakers in the RPS systs. %e breakers used for undervoltage protection are Class lE. Surveillance testing is required for these breakas per Unit 2 Technical Specifications Section 4.8.2.7. 'Ihere is no ccanitsnent to perform surveillance testing on other breakers within the systu:i. n is is consistent with the original design basi' _ of the plant in that Plant Hatch, Unit 2 is not rejuired to meet Regulatory Guide 1.75.

i 1-2 JUN 0 71984 i

CUESTION 1 Please provide the setpoints for the gross failure alarm.

RESPONSE l-3

%e high/ low gross failure setpoints are to be set at values of 3010.5 and 1 1 0.5 ma., respectively. %ese values are different than what was provided earlier to the NRC via telecon. We alarms are provided to indicate a short-circuit and open-circuit. % erefore, the setpoint values can be varied significantly outside the saturation range of the transmitter and still provide adequate protection.

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CUESTION 1-4 i In.the E NEDO docment topical report on ATIS, there is a table that talks about' the maximm lead lengthity. hat can be installed in the plant using the wire length and power supply voltage. What are we doing with regard to that table at Plant Hatch?

s RESPONSE l-4

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ne table in' question is presented in th'e Posmount, Inc., " Operations Manual-Trip / Calibration Sycts - Model 510DU," 1976. %is manual is referenced in NICO-21617-A. %e, Plant Hatch design, presented in NEDE-22154-1, does'not use Rosmount trip units; GE trip units are used.

However, the two trip unit designs are very similar.

The purp>se of the maximm lead length ratuirment is to assure sufficient voltage out of the trip unit to drive the transmitter. Calculations by E indicate that lead lengths os long as 3820 ft. are acceptable using 16 ga.

wire. %e maximm length of cable used in the Plant Hatch ATIS design is 1800 ft., utilig.ing 16 ga. wire. \

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QUESTION 1-5 Please provide the current status of the ATES qualification progrm.

I RESPONSE l-5

'Ihe qualification progra was empleted in December 1983, with GE's issuance of the finel qualification report (NEDC-30039) .

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" "' Ple'aso provide the' applicability of Regulatory Guide 1.75 and IEEE 279-1971 r with reaard to the Plant Hatch ATIS installation.

.$ , ( RESIONSE l-6 l

/We ATrS design and installation meets the standards of IEEE 279-1971.

GPC is not cTmitted to meet. the 'rcq.uircents of Regula' tory Guide 1.75 in the original licensing bases. However, with regard tc ATIS, GPC attempted to meet Regulatory Guide 1. 75 to the maximtsn practical extent.

However, the ATIS installarion does not canpletely meet Regulatory Guide 1.75 cri%41 a.' For exanple, as, discussed .in Response 1-2, there are non-class lE loads being powered fran class lE buses'with a circuit breaker as the separation device. As'atated . earlier,- this is consistent with the original design basis for. Plant Hatch, inasmuch as Plant Hatch is not a Regulatory Guide.1.7S plant.

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l Divisional separation is/riaintained Nithin the cabinet. Class lE/non-class lE separdtion is carried through-up to the trip' relay. The annunciator trip reicys are, the sepaiat: ion point betweent-lE and ncn-lE; that separation is via the contact to coi] -

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Within the cabinets,,tnEminfahzn separation distance, is 6 in. up to the relay. . Within the' relay, one'$s limits-1 to the distance from the contact to the_ coil. m -

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%e ATrS has been installed _crtwistentwith the rajuirsents of Chapter 8 of the FSAR ar# % CMt 50,. A@cN31x R.o j, a _r - s

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QUESTION 1-7 with regard to the setpoint calculations, how are the analytical limits used in the safety analysis?

RESPONSE l-7

'Ihe analytical limits are the values used as inputs to the safety analysis in the FSAR. For Plant Hatch, the analytical limits are selected to prevent violation of the applicable safety limits. For exm ple, the analytical limit for the level 1 reactor water level trip was selected to prevent fuel cladding temperatures in excess of the peak value (22000 F ) used in the Plant Hatch Appendix K IOCA analyses.

In sme cases values were not used directly in the ESAR analysis. In those cases where an analytical limit was not available, engineering judgment or historical data was justified and used.

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'JUll 0 71984

QUESTION 1-8 With regard to the setpoint calculations, how were the analytical limits derived?

RESPONSE l-8 Unless otherwise noted in our sutnittal, the analytical limits used in our setpoint calculations were the original analytical limits used in the HNP Safety Analysis. For those that were changed, we provided a safety evaluation that justified the change to that analytical limit. In no case with these new limits do the ESAR analyzed transients or accidents exceed the safety limits which are specified in the Plant Hatch Technical Specifications.

%e conservatisms in the Plant Hatch design basis cmputer codes were not used in place of the analytical limit for the starting value of the calculations.

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00ESTION 1-9 What parmeters other than drift are included in the setpoint calculations?

RESPONSE 1-9 he allowable value was obtained by either adding or subtracting (whichever was conservative) the loop acx:uracy frm the analytical limit. The loop accuracy was obtained by taking the square root-of-the-sum-of-the squares of the transitter accuracy, the trip unit accuracy, and the calibration accuracy. %e trip setpoint was calculated by adding or subtracting (whichever was used to obtain the allowable value) the loop drift and the leave alone range frcn the allowable value.

Each of these terms is a function of other parmeters; for instance, the transmitter accucacy reflects transmitter performance with regard to the transmitter basic reference accuracy, transmitter temperature specifications, power supply specifications, and static pressure specifications. Trip unit accuracy is basic reference accuracy.

Calibration accuracy consists of the accuracy of applying pressure to the transmitter and measuring its electrical output error band. hus, trip unit calibration accuracy is a function of the RITS calibration units and the readout used to adjust the trip setpoints. What we refer to as loop accuracy is developed by taking the square root-of-the-sm-of-the squares of all the terms. %ese parmeters envelope the Plant Hatch Unit 2 requirements.

%e methodology which was used is detailed in Attachment 3. Drift of the trip units will be monitored on a monthly basis and drift of the transmitters will be monitored on an operating cycle basis using plant procedures. GPC will evaluate the performance of these trip units and transmitters against the manufacturer's published specifications after two operating cycles. At that time, if necessary, GPC will propose modifications to the surveillance frequencies specifid in the Unit 2 Technical Specifications.

J UN o,7 1984 1-9

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QUESTION 1-10 What variables were treated as dependent variables and as independent variables in the setpoint calculations?

RESPONSE l-10

%e transmitter, trip unit, and calibration accuracies are all treated as independent variables between the analytical limit and allowable value. %e

-transitter and trip unit drifts were treated as independent variables between the allowable value and trip setpoint. The total loop accuracies and the total loop drifts were directly added to obtain the trip setpoint, and were therefore treated as dependent variables.

JAn additional variable called the leave-alone band was added (treated as a dependent variable) between the allowable value and trip setpoint. %is band is set at + 0.25 percent of the trip unit range and allows a range of values that the trip unit may vary. A setpoint adjustment is not rejuired -

when the trip unit setting is within this 10.25 percent range. If the trip unit is out of the range fran the setpoint on a monthly calibration functional test, the operator resets the trip unit trip setooint within the 0.25 percent range. Currently, if the trip unit is outside the 10.60% (sun of leave alone range + trip unit drift) a deficiency report will be generated internally at GPC Plant Hatch. %e methodology which was used to generate the setpoints is detailed in Attachment 3.

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QUESTION 1-11 Does your setpoint methodology include consideration for a harsh enviroment?

RESPONSE l-ll We tenperature effects for a harsh enviroment were explicitly used%as one e data of the variables to determine transitter accuracy for each loop.

used were obtained directly fra the transitter performance

. specifications. No extrapolations were raluired. We manufacturer's performance specifications enve' ope the Plant Hatch calculated harsh enviroment profiles.

%e post-accident harsh enviroment radiation and pressure effects on ATTS tranm itter accuracies have been evaluated . The evaluation has shown that these enviromental factors have negligible effect on setpoint drift or instrment error (see response 1-12) . For Rosenount transitter applications, an evaluation was performed which allowed. exclusion of the radiation harsh enviroment effects.

1-11

-JUM o '7 1984

QUESTION 1-12 Explain how the harsh enviroment effects are considered independent with regard to the setpoint analysis.

RESPONSE l-12

%e two areas explicitly considered in the harsh enviroment effects were radiation and temperature c m pensation. %ese were considered as independent effects. 'Ihe reasoning that they are independent effects is that temperature peaks relatively early in a IDCA event while significant radiation integrated doses occur later. As a result of a GE evaluation for Barton transmitters, it was determined that radiation effects were not a significant effect in the setpoint calculations. %erefore, the setpoint calculations did not explicitly consider radiation as a parmeter. SCS performed an evaluation _ which allowed exclusion of the radiation effect also for those trip functions where Rosemount transmitters are to be installed.

Hmidity was not an explicit parameter in the setpoint calculations. %e testing progra for the transmitters included exposure to a stem enviroment during the DBE/ post-DBE testing phases. % erefore, the effects of humidity are accounted for in the temperature empensation factor.

1-12 JUN o 71984 l

CUESTION 1-13 What values, if.any, have been extrapolated to derive the trip setpoints?

RESPONSE l-13

%e only value extrapolated was setpoint drift. In many cases the transmitter manufacturer's specifications only provided drift values for 6 or 12 month intervals. R ese values were extrapolated linearly to provide 18 and 24 month drift values for use in the Hatch setpoint calculations.

Ongoing vendor test prograns denonstrate that linear extrapolation is a conservative approach.

1-13 JUNO 71984

CUESTION 1-14 With regard to the setpoint calculations, was there any cmponent of error for the man-machine interface?

RESNNSE l-14 No, however, there is a requirment that calibration be performed with.

instruments of 1/4-percent or better accuracy. 21s value was assmed in the setpoint calculations.

During monthly channel functional tests, the trip setpoint millimp value is read directly fr a the calibration unit. %e calibration unit locks in the trip setpoint value and presents a digital display. During channel calibration, the readings are taken with a digital voltmeter. At the calibration checkpoints, sufficient stability of the digital readout is achieved to assure that the hwan ability to read the display presents insignificant errors in the overall results of the setpoints calculations.

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1 1-14 JUN o 71984

I ATTACifENP 4 NBC DOCKET 50-366 OPEPATING LICENSE NPF-5 EININ I. HA'IG NUCLEAR PLANP UNIT 2 RESPONSE 'IO NRC SPAFF QUESTIONS ON PROPOSED ATIS 'I1!CHNICAL SPECIFICATION GANGES 5

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GENERAL ELECTRIC C0MPANY AFFIDAVIT I, R. Artigas, being duly sworn, depose and state as follows:

1. I am Manager, BWR Project Licensing, Safety and Licensing Operation, 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. " Trip Setpoint Methodology for the Edwin I. Hatch Nuclear Plant Analog Transmitter Trip System Instrumentation", Enclosures 1 and 2.

3. In designating material as proprietary, General Electric utilizes the definition of proprietary information and trade secrets set forth in the American Law Institute's Restatement Of Torts, Section 757.

This definition provides:

"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 informa-tion.... Some factors to be considered in determining whether given information is one's trade secret are: (1) the extent 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 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 expended by him in developing the information; (6) the ease or difficulty with which the information could be properly acquired or duplicated by others."

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

a. Information that discloses a process, method or apparatus 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 consisting of supporting data and analyses, includ-ing 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; AJW:csc/IO6051 aun 0 7 1964 s/4/84

c. 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;

d. Information whicn reveals cost or price information, productic, 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. InQ rmation 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.

5. In addition to proprietary treatment given to material meeting the standards enumerated above, General Electric customarily maintains in confidence preliminary and draft material which has not been subject to complete proprietary, technical and editorial review.

This practice is based on the fact that draft documents often do not appropriately reflect all aspects of a problem, may contain tentative conclusions and may contain errors that can be corrected during normal review and approval procedures. Also, until the final document is completed it may not be possible to make any definitive determination as to its proprietary nature. General Electric is not generally willing to release such a document to the general public in such a preliminary form. Such documents are, however, on occasion furnished to the NRC staff on a confidential basis because it is General Electric's belief that it is in the public interest for the staff to be promptly furnished with significant or potentially significant information. Furnishing the document on a confidential basis pending completion of General Electric's internal review permits early acquaintance of the staff with the information while protecting General Electric's potential proprietary position and permitting General Electric to insure the public documents are technically accurate and correct.

6. Initial approval of proprietary treatment of a document is made by the Subsection Manager of the originating component, the man 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 at all times are clearly identified as proprie-tary.

7. The procedure for approval of external release of such a document is reviewed by the Section Manager, Project Manager, Principal Scientist or other equivalent authority, by the Section Manager of the cognizant Marketing function (or his delegate) and by the Legal Operation for Mn0y # M cscA06051 6/4/84 ^

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., a technical content, competitive effect and determination of the accuracy of the proprietary designation in accordance with the i standards enumerated above. Disclosures outside General Electric are generally limited to regulatory bodies, customers and potential customers and their agents, suppliers and licensees only in accor-dance with appropriate regulatory provisions or proprietary agreements.

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8. 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.

9. The information contained herein is the result of extensive analyses performed at' considerable cost to the General Electric Company. The

development and verification of these methods, as well as their

application and execution cost in excess of $1 million.

3 STATE OF CALIFORNIA COUNTY OF SANTA CLARA

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R. Artigas, being duly-sworn, deposes and says:

That he has read the foregoing affidavit and the matters stated therein

are true and correct to the best of his knowledge,'information, and

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Executed at San Jose, California, this dayofb(AAAL ,198k.

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General e ectric Company Subscribed and sworn before'me this._3 y of .

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