ML20072F359
| ML20072F359 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 01/11/1994 |
| From: | Liparulo N WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML19304C524 | List: |
| References | |
| CAW-94-565, NUDOCS 9408230306 | |
| Download: ML20072F359 (16) | |
Text
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Westinghouse Energy Systems Ba 355
"'ttsburgri Pennsylvania 15230-0355 Electric Corporation January 11,1994 CAW-94-565 l
Document Control Desk US Nuclear Regulatory Commission Washington, DC 20555 Attention: Dr. Thomas Murley, Director APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
"Elirnination of Pressure Sensor Response Time Testing Requirements" (WCAP-13632, Revision 1, Proprietary)
Dear Dr. Murley:
The proprietary information for which withholding is being requested in the above-referenced letter is further identified in Affidavit CAW-94-565 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 10 CFR Section 2.790 of the Commission's regulations.
Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Southern Nuclear Operating Company.
Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter CAW-94-565, and should be addressed to the
. undersigned.
Very truly yours, Nicholas J. L' a o,
anager Nuclear Safety and Regulatory Activities
/cid E.tclosures
[
cc:
Kevin Bohrer/NRC (12H5)
CIN0liitJM4Jil194 9408230306 940817 PDR ADOCK 05000348.
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1 CAW-94-565 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF ALLEGHENY:
Before me, the undersigned authority, personally appeared Henry A. Sepp, 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:
l
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1]
Henry A. Sepp, Manag/ M /
er Strategic Licensing Issues Sworn to and subscribed before me this
//
day of 46 _..
,1994
/
0 n i n >n. k Notary Public Paanalseal Lerrabo M. P(Act, Pubac Monrooda Boro.
County My Commimon Expires
.14.1995 MmT. bur, PersisyNarna Aw rimrn or tem unic RlM i:oitin CAW-94-565
+
(1)
I am Manager, Strategic Licensing Issues, in the Nuclear Technology Division, of the 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 and rulemaking proceedings, and am j
authorized to apply for its withholding on behalf of the Westinghouse Energy Systems Business Unit.
1 (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 accompanying this Affidavit.
(3)
I have personal knowledge of the criteria and procedures utilized by the Westinghouse Energy Systems Business Unit 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 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.
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:
1 4
tooic-RM101iim.
)
l CAW-94-565 (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 a 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 commercial value to Westinghouse.
l I
(f)
It contains patentable ideas, for which patent protection may be desirable.
There are sound policy reasons behind the Westinghouse system which include the j
following:
l l
1 (a)
The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors, it is, therefore, withheld from j
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.
'141tC-RM3:011104
_. CAW-94-565 (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. !f 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 of those countries.
(t)
The Westinghouse capacity to invest corporate assets in 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.
(iv)
The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method 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 " Elimination of Pressure Sensor Response Time Testing Requirements", WCAP-13632 Revision I (Proprietary), December,1993 for Joseph M. Farley Units I and 2, being transmitted by the Southern Nuclear Operating Company (SNC) letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk, Attention Dr. Thomas Murley. The proprietary information as submitted for use by SNC for the J. M Farley Units 1 and 2 is expected to be applicable in other licensee I
IOHC-kM4 011194
~
_ CAW-94-565 submittals in response to certain NRC requirements for justification of the elimination of response time testing (RTT) requirements.
This information is part of that which will enable Westinghouse to:
(a)
Provide documentation in support of methods for the elimination of pressure sensor response time testing requirements.
(b)
Provide the applicable similarity analysis for sensors not identified in the EPRI report which establishes justification for RTT elimination for those sensors.
(c)
Provide data supporting elimination of RTT for certain sensors excluded by the EPRI report.
(d)
Provide a methodology for substituting response times in lieu of values obtained from RTT for each sensor.
Further this information has substantial commercial value as follows:
(a)
Westinghouse plans to sell the use of similar information to its customers for purposes of the elimination of response time testing (RTT) requirements.
(b)
Westinghouse can sell support and defense of the methodology in the licensing process.
Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar methodologies and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.
mmc-RM 5:Oll1%
. CAW-94-565 The development of the technology described in part by the information is the result.
of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.
In order for competitors of Westinghouse to duplicate this information, similar.
technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended for developing the methodology.
Further the deponent sayeth not.
IINIC RJM43.011tw
Proprietary Information Notice Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.
In order to conform to the requirements of 10 CFR 2.790 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) contained within parentheses located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.790(b)(1).
CLD640 R1MV!2il91 1
Copyright Notice The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.790 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection not withstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. The NRC is not authorized to make copics for the personal use of members of the public who make use of the NRC public document rooms. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.
CLDMo RJM972893
ATTACIIMENT III SNC Response to NRC Staff Questions Listed in Section 4 of Safety Evaluation Report (SER)" Evaluation of GE Topical Report on the Elimination of Selected Response of Selected Time Testing Requirements"
Reference:
BWR Owners' Group March 27,1992 Licensing Submittal and General Electric Report NEDC-32013P," System Analyses for Elimination Response Time Testing Requirements."
NRC Ouestion 1:
What are the purpose and goals of response time testing?
SNC Response:
The purpose of response time testing is explained in paragraph one on page 2-1 of WCAP-13632, Revision 1.
NRC Ouestion 2:
What information is gained from response time tests?
SNC Response:
The information gained from response time tests is described by the Technical Specifications defmitions shown on page 3-1 and illustrated by Figure 1 in Section 7.0 of WCAP-13632, Revision 1 (i.e., the specific response time for each primary trip and actuation ftmetion credited in the accident analyses). In addition, for those Reactor Trip System (RTS) and Engineered Safety Features Actuation System (ESFAS) functions where pressure sensor response time measurements are obtained with noise analysis techniques, the specific response time includes sensing line delays which are beyond the Technical Specifications testing requirements.
NRC Ouestion 3:
How is the response time information used?
SNC Response:
Presently, the typical method for using response time test data requires the longest measured sensor time for a given RTS/ESFAS function to be added to the associated instrumentation channel with the longest measured time. In the final step, the total composite time derived from testing (including measured sensor, instrument channel and logic circuits, reactor trip breaker and/or ESF component actuation times)is compared to the response time limit.
As such, response time information is used to verify the total response time for each primary trip and actuation function is less than the specified RTS/ESFAS limit, inherent in this process, for those functions where pressure sensor response time is obtained j
.l
I 11 Page 2 through noise analysis techniques, is confirmation that a sensing line degradation has not resulted in excessive time delay.
NRC Ouestion 4:
If response time tests are eliminated, what tests would replace them and still provide the above information?
SNC Response:
Existing calibratian and other surveillance monitoring methods other than response time testing (e.g., channel checks) have been shown to detect significant degradation of pressure sensor performance that could impact response times. While outside the scope of Technical Specifications requirements, extensive pressure sensor sensing line degradation can be detected by channel checks.
I In addition, for systems with a history of sensing line degradation i
(e.g., blockage), a sensing line flushing program will be included in Farley outage activities. This preventative maintenance practice is consistent with the NUREG/CR-5851 recommendation to flush sensing lines.
i NRC Ouestion 5:
How would the information from question 4 be used?
SNC Response:
The existing surveillance procedures in addition to the baseline response time test show that the performance of the instrumentation
'l loop is well within allowable limits Therefore, established baseline response times in accordance with the methodology provided in I
Section 9.0 of WCAP-13632, Revision I can be used to compare with the specific Reactor Trip System and Engineered Safety Feature Actuation System response time limits.
NRC Ouestion 6:
What would be the frequency of the replacement tests?
SNC Response:
In accordance with the Technical Specifications, the periodic smveillance/ calibration tests mentioned in the response to Question 4 above are performed more frequently than current response time tests. Baseline response time testing would be performed as described in Sections 4.5 and 9.0 of WCAP-13632, Revision 1.
Flushing ofcertain sensing lines will be performed on a refueling basis.
\\
< 1I Page 3 NRC Onestion 7:
Ilow will application of the Maintenance Rule (10 CFR 50.65) affect safety-related instrumentation maintenance and calibration methodology?
SNC Response:
The Maintenance Rule is performance based and permits specific instrumentation monitoring or calibration methodology to be established by the licensee based on: 1) the safety significance of the system; and 2) whether performance or condition of the system is effectively controlled by appropriate preventive maintenance programs. Since acceptable system response time is assured by other testing methods and preventative maintenance activities, the elimination of certain sensor response time testing requirements is consistent with the intent of the Maintenance Rule.
NRC Onestion 8:
Is the Failure Mode and Effects Analysis (FMEA) all inclusive, including not only individual part failures but also interactions between parts, such as friction or binding between moving and static parts?
SNC Response:
Revision 1 of EPRI Report NP-7243, " Investigation of Response Time Testing Requirements," addresses all of these items. In addition, EPRI has continued to develop and interpret FMEA analyses as part ofits Instrument Calibration Monitoring Program (ICMP). These analyses assess the credibility and detectability of different failure modes using techniques other than response time testing. Sensitivity of fill oil viscosity due to temperature and radiation and credible failure modes involving mechanical interaction of piece parts have also been considered in the ICMP as documented in EPRI report TR-103436, " Instrument Calibration and Monitoring Program: Failure Mode and Effects Analysis."
rttsensl.mge July 15,1994 l
l
3 ATTACilMENT IV SIGNIFICANT HAZARDS EVALUATION Joseph M. Farley Nuclear Plant Elimination of Periodic Pressure Sensor Response Time Testing As required by 10 CFR 50.91 (a)(1), an analysis is provided to demonstrate that the proposed license amendment to delete the requirement for periodic response time testing -
certain pressure and difTerential pressure sensors involves no significant hazards consideration.
Proposed Change The proposed amendment modifies the Reactor Trip System Instrumentation Surveillance Requirement 4.3.1.3 and the Engineered Safety Feature Actuation System Instrumentation Surveillance Requirement 4.3.2.3, including the associated Bases Section of the FNP -
Technical Specifications to indicate that the total channel response time for each function will be verified based on the technicaljustifications and methodology presented in WCAP-13787, Revision 1, " Elimination of Pressure Sensor Response Time Testing Requirements."
Background
In 1975 response time testing (RTT) requirements were included in the Westinghouse Standard Technical Specifications and were required for all plants licensed afler that date.
The Standard Technical Specifications contain definitions for both Reactor Trip System (RTS) and Engineered Safety Features Actuation System (ESFAS) response times. The response time definitions are:
"The REACTOR TRIP SYSTEM RESPONSE TIME shall be the time interval from when the monitored parameter exceeds its trip setpoint at the channel sensor until loss of stationary gripper coil voltage."
"The ENGINEERED SAFETY FEATURES RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays where applicable."
I l
Significant llazards Evaluation l
Page 2 The Technical Specifications Bases Section 3/4.3 states that the response time may be measured by any series of sequential, overlapping, or total steps such that the entire response time is measured. This approach is also consistent with IS A Standard 67.06,
" Response Time Testing of Nuclear Safety-Related Instrument Channels in Nuclear Power Plants" Given this guidance and the complexity of testing an entire instrument channel from the sensor to the final device, plant surveillance procedures normally test a channel in two or more overlapping steps. One individual step in most plant test methodologies is the instrument sensar response time test. Separate procedures using specialized test equipmem end/or outside vendors are typically used solely for testing the sensors.
The first RTT guidelines were established by the Institute of Electrical and Electronic Engineers in ANSI /IEEE Standard 338-1975," Criteria for the Periodic Testing of Class l
IE Power and Protection Systems." in 1977 this standard was revised and accepted by the NRC with the issuance of NRC Regulatory Guide 1.118, " Periodic Testing of Electric Power and Protection Systems," Revision 1. Following Revision 2 of Regulatory Guide 1.118, the Instrument Society of America approved ISA S67.06 in Augtst 1986.
This significant hazards consideration analysis applies to the proposed deletion of periodic response time testing requirements for certain pressure and differential pressure transmitters and switches from the Technical Specifications.
Analysis The primary purpose of this evaluation is to determine if the deletion of periodic response time testing could bejustified for specific RPS and ESFAS pressure, level, and flow functions that utilize pressure and differential pressure sensors. IEEE Standard 338-1977 defines a basis for eliminating RTT. Section 6.3.4 states:
" Response time testing of all safety related equipment, per se, is not required if, in lieu of response time testing, the response time of the safety system equipment is verified by functional testing, calibration checks or other tests, or both."
WCAP-13632, Revision 1 provides the technicaljustification for deletion of periodic response time testing of selected pressure sensing instruments. The program described in the WCAP utilizes the recommendations contained in EPRI Report NP-7243, Revision 1,
" Investigation of Response Time Testing Requirements," for justifying elimination of response time testing surveillance requirements on cenain pressure and differential pressure sensors. To address other sensors installed in Westinghouse designed plants, the WCAP contains a similarity analysis to sensors in the EPRI report or a Failure Mode and EfTects Analysis (FMEA) to provide justification for elimination of response time testing
T 1
i Significant Hazards Evaluation j
Page 3 requirements. The specific sensors installed at J. M. Farley Units 1 & 2 are listed below.
Steam Generator Water Level
- Barton 764 Pressurizer Pressure
- Foxboro El1GM (Unit 1)
- Barton 763A (Unit 2)
Steamline Pressure
- Foxboro EllGM Containment Pressure
- Barton 764/351 Reactor Coolant Flow
- Foxboro E13DH The basis for eliminating periodic response time testing for each sensor is discussed in the WCAP and/or the EPRI report. These reports providejustification that any sensor failure that significantly degrades pressure or differential pressure transmitter response time will be detectable during surveillance testing such as calibration and channel checks.
Based on these results, J. M. Farley Units 1 & 2 Technical Specifications are being revised to indicate that the system response time shall be verified utilizing a sensor response time justified by the methodology described in WCAP-13632, Revision 1. Allocations for pressure sensor response times may be obtained from: (1) historical records based on acceptable response time tests (hydraulic, noise, or power interrupt tests); (2) in place, onsite, or offsite (e.g., vendor) test measurements; or (3) utilizing vendor engineering specifications.
Conformance of the proposed amendment to the standards for a determination of no significant hazard as defined in 10 CFR 50.92 is shown in the following analysis.
- 1) The proposed license amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
This change to the Technical Specifications does not result in a condition where the design, material, and construction standards that were applicable prior to the change are altered. The same RTS and ESFAS instrumentation is being used; the time response allocations /modeling assumptions in the FSAR Chapter 15 analyses are still the same; only the method of verifying time response is changed. Periodic calibration of these pressure and difTerential pressure instruments will detect significant degradation in the sensor response characteristic and assure equipment operability. Flushing of selected sensing lines during each refueling outage as recommended by NUREG/CR-5851,"Long Term Performance and Aging Characteristics of Nuclear Plant Pressure Transmitters," will mitigate sensing line response time degradation due to blockage that noise analysis testing techniques would have previously detected. The proposed change will not modify any system interface and could not increase the likelihood of an accident since these events are independent of this change. The proposed activity will not change, degrade or prevent actions or alter any assumptions previously made in evaluating the radiological
Significant Ilazards Evaluation i
Page 4 consequences of an accident described in the FSAR. Therefore, the proposed amendment does not result in any increase in the probability or consequences of an accident previously evaluated.
- 2) The proposed hanse amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
This change does not alter the performance of the pressure and differential pressure transmitters and switches used in the plant protection systems. All sensors will still have response time verified by test before placing the sensors in operational service and afler any maintenance that could affect response time. Changing the method of periodically verifying instrument response for certain sensors from time response testing to calibration will not create any new accident initiators or scenarios. Implementation of the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3) The proposed license amendment does not involve a significant reduction in margin of safety.
This change does not afTect the total system response time assumed in the safety analysis.
The periodic system response time verification method for selected pressure and differential pressure sensors is modified to allow use of actual test data or engineering data. The method of verification combined with sensing line preventative maintenance provides assurance that the total system response is within the time limit defined in the safety analysis, since calibration tests will detect any degradation which might significantly afTect pressure sensor response time and periodic sensing line flushing will minimize the potential for long-temt buildup of contaminants which may impact sensing line response.
Based on the above, it is concluded that the proposed license amendment request does not result in a reduction in margin with respect to plant safety.
Conclusion Based on the preceding analysis, it is concluded that elimination of periodic pressure sensor response time testing is acceptable and the proposed license amendment does not involve a significant hazards consideration finding as defined in 10 CFR 50.92 rttsens3.mge July 15,1994