ML20153F860

Nonproprietary Package Consisting of Proposed Rev to Ssar Subsection 7.7.1.11,w/respect to Manual Actuation Function List & Indication List

ML20153F860
Person / Time
Site:	05200003
Issue date:	09/22/1998
From:	WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:
Shared Package
ML20153F843	List: ML20153F839 ML20153F860
References
NUDOCS 9809290275
Download: ML20153F860 (1)

Text

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Attachment to NTD-NRC-94-4041 Revise the Manual Actuation Function list in Subsection 7.7.1.11 as follows:

Manual Actuation Function i

The manual actuation function of the diverse actuation system is implemented by wiring the control board mounted switches directly to the final loads in a way that completely bypasses the normal path through the control board multiplexers, the engireered safety features actuation cabinets. the integrated logic cabinets and the diverse actuation system automatic logic.

The diverse manual functions are:

Reactor and turbine tnp Passive residual heat removal actuation Core makeup tank actuation Automatic depressurization system valve actuation Passive containment cooling actuation Critical contamment penetration isolation Containment hydrogen igrutor actuation S:  ; gnc== c;;'1" ;'.ncnden Revise the Indication list in Subsection 7.7.1.11 as follows:

Indication To support the diverse manual actuations, sensor outputs are displayed in the main control room in a manner that is diverse from the protection system display functions. The indications that are provided trom at least two sensors per function are:

Wide range steam generator water level - for reactor trip and passive residual beat removal acuiations Hot leg temperature - for passive residual beat removal and automatic depressurization system actuat;ons Hot leg level for in-containment refueling water storage tank injection initiation Pressurizer level - for con: makeup tank actuation and reactor coolant pump trip a

Containment temperature - for containment isolation and passive containment cooling system actuation Containment bydrogen - for containment hydrogen ignitor actuation Steam generator water level - for overfill prevention by manual actuation of the automatic depressurization system valves.

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m Westinghouse Energy Systems scx 355 Electric Corporation Pmsburgn Pennsylvania 15230 0355 DCP/NRCl413 NSD NRC-98-5757 Docket No.: 52-003 August 14,1998 l Document Control Desk ,

U. S. Nuclear Regulatory Commission Washington, DC 20555 l l

ATTENT10N: T. R. Quay

SUBJECT:

RESPON3E TO NRC LETTERS CONCERNING REQUEST FOR WITHHOLDING INFORMATION 1

Reference:

1. Letter, Sebrosky to McIntyre, " Request for withholding information from public disclosure for Westinghouse AP600 design !ctter of October 20,1993," dated June 18, 1998.

2. Letter, Sebrosky to McIntyre, " Request for wititholding information from public disclosure for Westinghouse AP600 design letter of January 17,1994," dated June 18,1998.

3. Letter, Sebrosky to McIntyre, " Request for withholding information from public disclosure for Westinghouse AP600 letters of September 20,1993, January 21, 1994, and February 3,1994," dated July 10,1998.

4. Letter, Sebrosky to McIntyre, " Request for withholding proprietary information for Westinghouse letters dated April 18,1995," dated July 15,1998.

5. Letter, Huffman to McIntyre, " Request for withholding information from public disclosure of Westinghouse report on AP600 function based task analysis," dated July 17,1998.

Dear Mr. Quay:

Reference 1 provided the NRC assessment of the Westinghouse claim that proprietary information was provided in a letter dated October 20,1993, that contained the response to a staff request for additional information regarding the AP600 probabilistic risk assessment. The NRC assessment was that the material was similar to material that exists in the current (1998) nonproprietary version of the AP600 probabilistic risk assessment (PRA) report. In addition, the staff indicated the material was used by the staffin the development of the AP600 draft safety evaluation report and therefore should remain on the docket. At the time this request for additional information response was provided to the _

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NRC technical staff, the information was considered to be proprietary by Westinghouse since it contained information that had commercial value to Westinghouse. If this request for additional information response was indeed used by the staffin development of the AP600 draft final safety evaluation report in November 30,1994, then at this time, almost five years later, this information is no longer considered to be proprietary by Westinghouse.

Reference 2 provided the NRC assessment of the Westinghouse claim that proprietary infonnation was provided in a letter dated January 17,1994, that contained the response to a staff request for additional information regarding the AP600 instrumentation and control system The NRC assessment was that t!ie material was similar to material that exists in the current (1998) nonproprietary version of the AP600 standard safety analysis report. In addition, the staff indicated the material was used by the staff in the development of the AP600 draft safety evaluation report and therefore should remain on the docket. At the time this request for additional information response was provided to the NRC technical staff, the information was considered to be proprietary by Westinghouse since it contained information that had commercial value to Westinghouse. If this request for additional information response was indeed used by the staffin development of the AP600 draft f' mal safety evaluation report in November 30,1994, then at this time, over four years later, this information is no longer considered to be proprietary by Westingbouse.

i Reference 3 provided the NRC assessment of the Westinghouse claim that proprietary information was provided in a letter dated September 20,1993, that contained information related to the AP600 PRA and WCAP-13795, which provided the PRA uncertainty analysis. The NRC assessment was that the material was similar to material that exists in the current (1998) nonproprietary version of the AP600 probabilistic risk assessment (PRA) report. In addition, the staff indicated the material was used by the staffin the development of the AP600 draft safety evaluation report and therefore should remain on the docket. At the time this information was provided to the NRC technical staff, it was considered to be proprietary by Westinghouse since it contained information that had commercial value to Westinghouse. If the information transmitted by the Westinghouse September 20,1993, letter was indeed used by the staffin development of the AP600 draft final safety evaluation report in November 30,1994, then at this time, almost five years later, this information is no longer considered to be proprietary by Westinghouse.

Reference 3 also provided the NRC assessment of the Westinghouse claim that proprietary information was provided in a letter dated January 21,1994, that contained WCAP-13913. " Framework for AP600 Severe Accident Management Guidance"(SAMG). The NRC assessment was that the material was similar to material that exists in current (1998) nonproprietary AP600 documents (e.g., WCAP 13914,

" Framework for AP600 Severe Accident Management Guidance"). In addition, the staffindicated the material was used by the staff in the development of the AP600 draft safety evaluation report and therefore should remain on the docket. At the time this Framework for SAMG was provided to the NRC technical staff, the information was considered to be proprietary by Westinghouse since it contained information that had commercial value to Westinghouse. At this time, over four years later, this information is no longer considered to be proprietary by Westinghouse.

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DC'P/NRCl413 NSD NRC-98 5757 August 14, 1998 Reference 3 also provided the NRC assessment of the Westinghouse claim that proprietary information was provided in a letter dated February 3,1994, that contained additional copies of WCAP-13913,

" Framework for AP600 Secte Accident Management Guidance"(SAMG). He NRC assessment was that the material was similar to material that exists in current (1998) nonproprietary AP600 documents (e.g , WCAP-l'2914, " Framework for AP600 Severe Accident Management Guidance"). In addition, the staff indicated the material was used by the staffin the development of the AP600 draft safety evaluation report and therefore should remain on the docket. At the time this Framework for SAMG was provided to the NRC technical staff, the information was considered to be proprietary by Westinghouse since it contained information that had commercial value to Westinghouse. At this time, over four years later, this information is no longer considered to be proprietary by Westinghouse.

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Reference 4 provided the NRC assessment of the Westinghouse claim that proprietary information was l provided in a letter dated April 18,1995, that contained information for a MAAP4/RELAP comparison for the AP600 in response to a staff request for additional information. The NRC assessment was that  !

the Westinghouse cover letter indicated that Enclosure 2 is a non proprietary version of Enclosure 3, l

however, the staff could not find any portion of the enclosures marked as proprietary. The staff l

assessment further states the conventional bracketed-superscript notation also appears to be missing.

Finally, the NRC assessment states the staff could not determine which pan of the material enclosed l

with the Westinghouse letter was Enclosure 1,2, or 3. It should be noted that the Westinghouse April l 18,1995, cover letter states " Enclosures 2 (nonproprietary) and 3 (proprietary) provide the requested infortnation." He letter does not indicate that enclosure 2 was a duplicate of enclosure 3 minus the proprietary information. A cover sheet was provided just prior to each of the enclosures to the Westinghouse letter. De enclosures contained the following: Enclosure 1 provided a copy of the NRC's two-page request for information for the MAAP RELAP comparison. Enclosure 2 provided the requested information, and was titled " Requested Information for AP600 MAAP4/RELAP Comparison." Under section 4, Initial Conditions, of Enclosure 2 it states the initial conditions information (which was proprietary) is provided in Enclosure 3 of the subject Westinghouse letter.

Finally, Enclosure 3 contained the list of initial conditions. The information provided in Enclosure 3 was labeled as Westinghouse Proprietary Class 2 at the top of the page, however, the specific proprietary information was not indicated by the bracketed-superscripted notation. In addition to the initial conditions, a mark up of AP600 PRA Figure K-1 was provided in Enclosure 3. Again, the information was labeled as Westinghouse Proprietary Class 2 at the top of the page, however, the specific proprietary information was not indicated by the bracketed superscripted notation. At the time the information provided in Enclosure 3 of the subject Westinghouse letter was provided to the NRC technical staff, the information was considered to be proprietary by Westinghouse since it contained information that 1.ad commercial value to Westinghouse. At this time, over three years later, this information is no longer considered to be proprietary by Westinghouse.

Reference 5 provided the NRC assessment of the Westinghouse claim that proprietary information was provided in a letter dated February 8,1994, provided a copy of WCAP-13957, "AP600 Reactor Coolant System Mass inventory: Function Based Risk Analysis." ne NRC assessment was that the material was not "information that the staff customarily accepts as proprietary." In addition, the staff indicated the material was used by the staff in the development of the AP600 final safety evaluation report and therefore should remain on the docket. At the time this report was prepared, the m .g m.

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.- NSD-NRC-98 5757 August 14,1998 infonnation was considered to be proprietary by Westinghouse since it contained information that had commercial value to Westinghouse and was of the type ofinformation that was customarily held in confidence by Westinghouse. That the material was not information that the staff customarily accepts as proprietary is not relevant to making the proprietary determination. However, in an effort to expedite the issuance of the AP600 Final Safety Evaluation Report and Final Design Approval, Westinghouse agrees to no longer consider this infonnation to be proprietary.

In a telephone call on July 8,1998, the stalTinformed Westinghouse of a concern related to WCAP-13288 and WCAP-13289, which were associated with the AP600 check valve testing specification.

The concern was that the proprietary report had no proprietary information identified and the nonproprietary report had been placed in the public document room. Westinghouse has reviewed these reports and, at this time, considers none of the information to be proprietary.

This response addresses the proprietary issues delineated in the references.

I A N Brian A. McInt3re, Mana i i

Advanced Plant Safety and Licensing jml cc: J. W. Roe - NRC/NRR/DRPM '

J. M. Sebrosky - NRC/NRR/DRPM W. C. Huffman - NRC/NRR/DPPM

. H. A. Sepp - Westinghouse I

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