HNP-11-095, Request for License Amendment Measurement Uncertainty Recapture Power Uprate Response to Request for Additional Information (RAI 9)
| ML11300A183 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 10/21/2011 |
| From: | Jefferson W Progress Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| HNP-11-095, TAC ME6169, CAW-11-3265 | |
| Download: ML11300A183 (22) | |
Text
~j~Progress Energy October 21, 2011 HNP-1 1-095 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400 / RENEWED LICENSE NO. NPF-63
Subject:
REQUEST FOR LICENSE AMENDMENT MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI #9)
References:
- 1. Letter from C. L. Burton (PEC) to the U.S. NRC, "Request for License Amendment, Measurement Uncertainty Recapture Power Uprate," dated April 28, 2011.
- 2. Letter from B. Mozafari (U.S NRC) to W. Jefferson Jr. (PEC), "Shearon Harris Nuclear Plant, Unit 1 - Request for Additional Information Regarding Measurement Uncertainty Recapture Power Uprate (TAC NO. ME6169)"
dated October 14, 2011 (RAI #9).
Ladies and Gentlemen:
By letter dated April 28, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML11124A180, Reference 1), as supplemented on June 23, 2011 (ADAMS Accession No. ML11179A052), Carolina Power &Light Company (CP&L) requested approval from the U.S. Nuclear Regulatory Commission (NRC) to increase the core thermal power level of Shearon Harris Nuclear Power Plant, Unit 1 from 2,900 megawatts thermal (MWt) to 2,948 MWt, an increase of approximately 1.66 percent over the present licensed power level and to change the power plant technical specifications accordingly.
CP&L, doing business as Progress Energy Carolinas, Inc., provided a letter dated September 6, 2011, in response to the NRC staff August 8, 2011 request for additional information (RAI). The staff determined that clarification of the additional information is needed. Additional questions were provided to CP&L in Reference 2, which requested that responses be provided by October 21, 2011. Those responses are provided as enclosures to this letter.
Enclosure 2 contains information proprietary to Westinghouse Electric Company LLC. It is supported by an affidavit signed by Westinghouse, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Progress Energy Carolinas, Inc.
Harris Nuclear Plant P. 0. Box 165 New Hill, NC 27562
U.S. Nuclear Regulatory Commission Page 2 HNP- 11-095 Commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commissions' regulations. includes the Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW- 11-3265, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice.
Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.3 90 of the Commission's regulations.
Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse affidavit should reference CAW-1 1-3265 and should be addressed to J. A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company LLC, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.
CP&L has concluded that the information provided in this response meets the intent of the original submittal (Reference 1) and does not impact the conclusions of the: 1) Technical Analysis, 2) No Significant Hazards Consideration under the standards set forth in 10 CFR 50.92(c), or 3) Environmental Consideration as provided in the original submittal.
In accordance with 10 CFR 50.91 (b), HNP is providing the state of North Carolina with a copy of this response.
This document contains no new Regulatory Commitments.
Please refer any questions regarding this submittal to Mr. David Corlett, Supervisor - HNP Licensing/Regulatory Programs, at (919) 362-3137.
I declare under penalty of perjury that the foregoing is true and correct. Executed on [ / o/I .//
Sincerely, Harris Nuclear Plant
U.S. Nuclear Regulatory Commission Page 3 HNP-1 1-095
Enclosures:
- 1. Harris Nuclear Plant Response to Request for Additional Information, RAI #9, Question # 1, Measurement Uncertainty Recapture Program
- 2. Harris Nuclear Plant, Westinghouse Response to Request for Additional Information, RAI #9, Question #2, Measurement Uncertainty Recapture Program (Proprietary)
- 3. Harris Nuclear Plant, Westinghouse Response to Request for Additional Information, RAI #9, Question #2, Measurement Uncertainty Recapture Program (Non-Proprietary)
- 4. Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-1 1-3265, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice.
cc: Regional Administrator, USNRC/Region II Project Manager, Harris Nuclear Plant, USNRC/NRR Resident Inspector, Harris Nuclear Plant, USNRC Section Chief, NC Division of Environmental Health
HNP-l 1-095 Enclosure 4 SHEARON HARRIS NUCLEAR POWER PLANT / UNIT NO. 1 (HNP)
DOCKET NO. 50-400 / RENEWED LICENSE NO. NPF-63 LICENSE AMENDMENT REQUEST MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE TAC ME6169 WESTINGHOUSE APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE CAW-1 1-3265, ACCOMPANYING AFFIDAVIT, PROPRIETARY INFORMATION NOTICE, AND COPYRIGHT NOTICE (9 PAGES)
Nuclear Services e~ esingh useWestinghouse ElectricDrive 1000 Westinghouse Company Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (724) 720-0754 11555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852 Proj letter: PGN-I 1-88 CAW-1 1-3265 October 19, 2011 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
PGN-I 1-88 P-Attachment, "Harris Nuclear Plant - Westinghouse Response to Request for Additional Information - RAI #9, Question #2 - Measurement Uncertainty Recapture Program" (Proprietary)
The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW- 11-3265 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. 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 2.390 of the Commission's regulations.
Accordingly, this letter authorizes the utilization of the accompanying affidavit by Progress Energy.
Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-1 1-3265, and should be addressed to J. A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company LLC, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.
Very truly YO rs, J. A. Gresham, Manager Regulatory Compliance Enclosures
CAW- 11-3265 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF BUTLER:
Before me, the undersigned authority, personally appeared J. A. Gresham, 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 Company LLC (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:
A . Gresham, Manager Regulatory Compliance Sworn to and subscribed before me this 19th day of October 2011 Notaryj ublic COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Renee Giampole, Notary Public I Penn Township, WeStmoreland County My CommisslonElIreg September 25, 2013J
2 CAW-1 1-3265 (1) 1am Manager, Regulatory Compliance, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), 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 rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.
(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.
(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse 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 2.390 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:
(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of
3 CAW-1 1-3265 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.
(f) It contains patentable ideas, for which patent protection may be desirable.
There are sound policy reasons behind the Westinghouse system which include the following:
(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.
(b) It is information that 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.
(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.
4 CAW-1 1-3265 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If 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.
(f) 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 10 CFR Section 2.390, 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 PGN-1 1-88 P-Attachment, "Harris Nuclear Plant -
Westinghouse Response to Request for Additional Information - RAI #9, Question #2 -
Measurement Uncertainty Recapture Program" (Proprietary) for submittal to the Commission, being transmitted by Progress Energy letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse for use by Harris Nuclear Plant is expected to be applicable for other licensee submittals in response to certain NRC requirements for Measurement Uncertainty Recapture (MUR) submittals and may be used only for that purpose.
5 CAW-1 1-3265 This information is part of that which will enable Westinghouse to:
(a) Provide input to the NRC for review of the Harris Nuclear Plant MUR submittals.
(b) Provide structural qualification of the Harris Nuclear Plant baffle-former bolts.
(c) Provide licensing support for customer submittals.
Further this information has substantial commercial value as follows:
(a) Westinghouse plans to sell the use of the information to its customers for the purpose of meeting NRC requirements for licensing documentation associated with MUR submittals.
(b) Westinghouse can sell support and defense of the technology to its customer in licensing process.
(c) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.
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 information 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.
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.
6 CAW-l 1-3265 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.
Further the deponent sayeth not.
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 2.390 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) 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 2.390(b)(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 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. 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. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.
HNP- 11-095 Enclosure 1 SHEARON HARRIS NUCLEAR POWER PLANT / UNIT NO. 1 (HNP)
DOCKET NO. 50-400 / RENEWED LICENSE NO. NPF-63 LICENSE AMENDMENT REQUEST MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE TAC ME6169 HARRIS NUCLEAR PLANT RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RAI #9, QUESTION #1 MEASUREMENT UNCERTAINTY RECAPTURE PROGRAM (3 PAGES)
HNP- 11-095 Page 2 of 3 Question 1 In response to an NRC staff request for additional information (RAI), regarding the design code of record used in the evaluation of the reactor vessel internals (RVIs) to support the implementation of a measurement uncertainty recapture (MUR) power uprate at Shearon Harris Nuclear Power Plant, Unit 1 (HNP), it was stated in Reference 2 that the HNP RVIs are not American Society of Mechanical Engineers (ASME) Code internals. As such, it was stated that no code of record is applicable to the original design and construction of the RVIs and that the structural integrity of the RVIs were originally using "different design codes." Furthermore, it was stated that the 2004 Edition of the ASME Boiler and Pressure Vessel (B&PV) Code,Section III, Subsection NG, "Core Support Structures," was used to evaluate the RVIs for acceptability at the conditions which will exist after MUR implementation.
Section 3.9.5.4 of the HNP Final Safety Analysis Report (FSAR) states that the intent of Subsection NG of the ASME B&PV Code was utilized in the evaluation of the RVIs, with respect to the allowable stresses used in the design basis analyses of the RVIs. The HNP FSAR also states that the allowable stress limits ". .. during the design basis accident..." are based on the 1973 draft of Subsection NG and the criteria for faulted conditions specified in the Code.
Specifically, the FSAR cites the limits provided in Figure NG-3221-1 of the Code for the Normal and Upset Conditions, and NG-3224-1 of the Code for Emergency Conditions as those used in the evaluation of the RVIs. Faulted loading conditions were stated to have been evaluated in accordance with Appendix F of the Code.
Confirm that the stress limits cited in the HNP FSAR were utilized in the evaluation of the RVIs to support the proposed MUR power uprate at HNP and confirm that these limits will remain satisfied following MUR implementation. Additionally, please provide a technical justification regarding the use of the provisions in the 2004 Edition of the ASME B&PV Code,Section III, Subsection NG, in lieu of the design basis acceptance criteria cited in the HNP FSAR. This justification should include, but not be limited to, a confirmation that the criteria used in the design basis analyses of the RVIs (i.e., FSAR limits) have been reconciled to the criteria of the 2004 Edition of the ASME B&PV Code,Section III, Subsection NG.
Response 1 Table 1 shows the various design parameters and design loads used in the RVI component analysis. They were evaluated to determine which components were affected by the MUR power uprate. They are consistent with the design parameters and design loads used in the HNP analysis of record (AOR). Table 1 also indicates the MUR power uprate impact on these design parameters/loads. The heat generation rates were the only design loads affected. RVI components affected by heat generation rates are the upper and lower core plates and the baffle-former bolts.
Because the heat generation rates affect thermal conditions on these components, component evaluations were limited to Normal and Upset conditions (Service Levels A and B).
HNP- 11-095 Page 3 of 3 Table 1. Reactor Vessel Internals Design Parameters and Loads Parameter / Load MUR Power Uprate ParameterILoad_ Affected Not Affected Geometry X Material X Thermal Design Transients X Heat Generation Rates (Gamma Heating) X Weight X Reactor Internals Hold-down Spring Forces X Flow Lift and Lateral Forces X Reactor Internals Pressure Differences X Vibration Loads X LOCA System Loads X LOCA Acoustic and Hydraulic Loads X Seismic System Loads X Fuel Assembly Interface Loads X Driveline and Control Rod Interface Loads X Per the HNP FSAR: Figure NG-3221-1 (from the 1973 draft of the ASME code for Core Support Structures, Subsection NG) indicates the stress categories and limits for Normal and Upset conditions.
For the HNP MUR power uprate project, the stress limits were taken from the 2004 Edition of the ASME B&PV Code. Table 2 lists the stress intensity (Sm) and moduli of elasticity from the 1971 and 2004 editions of the ASME Code.
Table 2. Sm and Moduli of Elasticity Comparison ASME B&PV Code, 1971 ASME B&PV Code, 2004 Parameter Edition with Addenda Edition with Addenda through 19731 through 2006 Sm @ 650 degrees F 16.1 ksi 16.2 ksi Modulus of Elasticity @ 70 degrees F 28.3 x 106 psi 28.3 x 106 psi Modulus of Elasticity @ 600 degrees F 25.4 x 106 psi 25.4 x 106 psi
- 1. Subsection NG of the ASME B&PV Code was first released in the Winter 1973 Addenda, issued December 31, 1973. The first edition of Subsection NG as a separate document was in the 1974 Edition of the ASME B&PV Code.
As indicated in Table 2, only the Sm value changed slightly - from 16.1 ksi to 16.2 ksi - between the two editions of the Code. The stress limits cited in the HNP FSAR were utilized in the evaluation of the RVIs to support the proposed MUR power uprate at HNP and these limits remain satisfied following MUR implementation.
HNP- 11-095 Enclosure 3 SHEARON HARRIS NUCLEAR POWER PLANT / UNIT NO. 1 (HNP)
DOCKET NO. 50-400 / RENEWED LICENSE NO. NPF-63 LICENSE AMENDMENT REQUEST MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE TAC ME6169 HARRIS NUCLEAR PLANT WESTINGHOUSE RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RAI #9, QUESTION #2 MEASUREMENT UNCERTAINTY RECAPTURE PROGRAM (NON-PROPRIETARY)
(7 PAGES)
Westinghouse Non-Proprietary Class 3 PGN- 11-88 NP-Attachment Page 1 of 6 October 19, 2011 Harris Nuclear Plant - Westinghouse Response to Request for Additional Information -
RAI #9, Question #2 - Measurement Uncertainty Recapture Program (6 Pages)
©2011 Westinghouse Electric Company LLC. All rights reserved.
Westinghouse Non-Proprietary Class 3 PGN-1 1-88 NP-Attachment Page 2 of 6 October 19, 2011 RAI In response to an NRC staff RAI, regarding the structural evaluation of the HNP baffle-former bolts to determine their adequacy at the proposed MUR power level, a qualitative discussion was provided which compared the HNP baffle-former bolts to the baffle-former bolts at Almaraz Unit 2. As indicated in a previous response, the only loads used in the design of the HNP RVIs which are affected by the proposed MUR power uprate are those loads due to heat generation rates. It was stated that the HNP baffle-former bolts (a RVI component) were acceptable for operation at MUR conditions based on the fact that the Almaraz Unit 2 baffle-former bolts were structurally qualified under its current conditions, given the similarities in the geometries, operating parameters, design transients and heat generation rates between each facility.
Provide a quantitative summary of the information described above, which qualitatively compared the HNP and Almaraz Unit 2 baffle-former bolts, to demonstrate the structural qualification of these components at MUR conditions. Include a quantitative summary of the effects of the higher heat generation rates on the analysis of record for the baffle-former bolts, including the effects of the higher heat generation rates on the stresses and fatigue usage factors. Further, compare the expected stresses and fatigue usage factors in the baffle-former bolts to the HNP design basis acceptance criteria for these components such that an explicit determination, that the components will continue to meet their design basis requirements following MUR implementation, can be made.
Response
The structural qualification of the HNP baffle-former bolts was accomplished by comparing the baffle-former bolt data with that from Almaraz Unit 2, which has the same baffle-barrel and baffle-former bolt designs.
To show the similarity between HNP and Almaraz Unit 2, the following design inputs are compared:
- Drawings
- Operating parameters
- Geometric parameters
- Design transients
- Heat generation rates As shown in Table 1, HNP and Almaraz Unit 2 use the same former drawings, as well as the same baffle plate drawings. By doing so, the baffle-former bolt locations and baffle plate pressure relief hole locations are the same for both plants.
Westinghouse Non-Proprietary Class 3 PGN-1 1-88 NP-Attachment Page 3 of 6 October 19, 2011 Table 1 Notes:
I. The different revision numbers for comparison do not affect the results of the baffle-former bolt qualification.
- 2. There are no major changes from Revision 3 to Revision 6.
Table 2 shows the comparison of operating parameters between HNP and Almaraz Unit 2.
Table 2 Comparison of HNP and Almaraz Unit 2 Operatin Z Parameters AImaraz Parameter Unit 2 Comment Vessel/Core inlet temperature (°F) 536.0 [ ]jC These temperatures represent the Vessel outlet temperature (°F) 608.0 [ temperatures used in the thermal analysis for a 1/8th segment model. The temperature difference differs by only 1.2 Vessel inlet outlet AT (°F) 72.0 [ ]'x (IF). This would have an insignificant impact on the baffle plate temperatures differences.
System pressure (psia) 2250 [ ]3.C Same pressure.
Thermal design flow (gpm-n) 277,800 [Less than 0.2% difference. Insignificant impact.
Less than 0.4% difference. Insignificant Core power (MWt) 2958 [ , impact.
This flow represents the flow used in the thermal analysis for a 1/8th segment Flow in the baffle/barrel region (lbim/hr ]a,c ]a.c model. The lower flow for Almaraz Unit flow) 2 is more conservative and will produce higher temperature differences across the baffle plate.
The operating parameters for the two plants are very similar; the small difference would have an insignificant impact on the thermal analysis used to generate the baffle plate delta Ts.
Westinghouse Non-Proprietary Class 3 PGN- 11-88 NP-Attachment Page 4 of 6 October 19, 2011 The data presented in Tables 3 and 4 compare the geometry used in the thermal analysis of the baffle/barrel region. From the comparison, the geometries of the baffle/barrel region in Almaraz Unit 2 and HNP are identical.
Table 3 rison of HNP and Almaraz Unit 2 Geometric Parameters Table 4 Former Hole Locations and Diameters for Notes:
I. Distance from core centerline to former hole center along X-axis.
- 2. Distance from core centerline to former hole center along Y-axis.
- 3. Diameter of former hole.
Westinghouse Non-Proprietary Class 3 PGN-I 1-88 NP-Attachment Page 5 of 6 October 19, 2011 The design transients used for the HNP MUR are the same as those used in the Almaraz Unit 2 analysis.
Both plants use the transients that are in the Standard System Design Criteria (SSDC) 1.3, Revision 2.
The heat generation rates used for the HNP MUR are the same as those used in the Almaraz Unit 2 analysis. Both plants use the same heat generation rates as those in WCAP-9620, Revision 1. These heat generation rates are shown in Table 5. These heat generation rates are applicable to both pre- and post-MUR; therefore, there would be no change in pre- and post-MUR results.
Table 5 Region Average Heat Generation Rates for HNP and Almaraz Unit 2 Region Average Heat Generation Rate IBtu/hr-Ibm]
Long Term Short Term Short Term Component (500 ppm Boron) (No Boron) (1100 ppm Boron)
Baffle Plate 4 [ ]pc [ ]a.c [ ]a.c Baffle Plate 5 [ ]axc ]a,c [ ]a.c Baffle Plate 6 [ ]ac [ ]a.c [ ]jC Baffle Plate 7 [ ]a.c [ ]j [ ]ax Baffle Plate 8 [ ]ac [ ].c [ ]ac Baffle Plate 9 [ ]a.c [ ]pc [ ]3.c Core Barrel [ ]a,c ]a,c [ ]asc The design input comparison in Tables 1 through 5 shows that the Almaraz Unit 2 results are applicable to HNP.
The Almaraz Unit 2 baffle-former bolts were qualified based on baffle-former bolt test results.
The method outlined in Section III, Division 1, Subsection NG (NG-3232.3) was utilized. The following briefly summarizes that method:
" NG-3232.1 and NG-3232.2 Average and Maximum Stress. These requirements are met by demonstrating that the loads meet 0.44Lu, where Lu is defined in NG-3228.4.
" NG-3232.3 Fatigue Analysis of Threaded Structural Fasteners. All baffle-former bolts have tensile strength of less than 100.0 ksi. Therefore the methods applied to other structures, NG-3222.4(e) is applicable to baffle-former bolts.
In lieu of the cyclic stress requirements of Article NG-3222.4(e) of Subsection NG of the ASME Code, a baffle-former bolt test program was performed within the requirements of Article I-1500 of ASME Code,Section III, Division 1, Appendix 11. This is permitted per Article NG-3222.4(a) of Section III, Subsection NG of the ASME Code. The basis for the Almaraz Unit 2 and HNP baffle-former bolt qualification is based on these test results rather than stress qualification.
Due to the difficulty in demonstrating compliance by purely analytical methods, baffle-former bolt testing was performed. This testing was performed in order to demonstrate compliance of the baffle-former bolts to the rules of the ASME Boiler and Pressure Vessel Code,Section III, Subsection NG. This testing satisfied the requirements of both static and fatigue loads from Table NG-3232-1. The testing was performed in such a manner that the primary plus secondary stress check required by Subsection NG of the ASME Code was satisfied.
The total cumulative usage factors for the "long" and "short" baffle-former bolts are shown in Table 6.
The total cumulative fatigue usage factors, which are less than one, are applicable to HNP; therefore, the bolts are structurally acceptable. The results of this analysis confirmed that the baffle-former bolts will remain acceptable after the MUR power uprate.
Westinghouse Non-Proprietary Class 3 PGN-I 1-88 NP-Attachment Page 6 of 6 October 19, 2011 Table 6 Baffle-Former Bolts Bolts Usage Factor Short 0.549 Long 0.525