L-MT-14-060, Extended Power Uprate: Replacement Steam Dryer - Response to NRC Requests for Additional Information, Revised Limit Curves and Supporting Information
| ML14204A622 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 07/22/2014 |
| From: | Fili K Northern States Power Co, Xcel Energy |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML14204A618 | List: |
| References | |
| L-MT-14-060, TAC MF3330 | |
| Download: ML14204A622 (11) | |
Text
ENCLOSURE 1 CONTAINS PROPRIETARY INFORMATION -
WITHHOLD FROM PUBLIC DISCLOSURE IN ACCORDANCE WITH 10 CFR 2.390
@ XcelEnergy" Monticello Nuclear Generating Plant 2807 W County Rd 75 Monticello, MN 55362 July 22, 2014 L-MT-1 4-060 10 CFR 50.4 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Monticello Nuclear Generating Plant Docket 50-263 Renewed License No. DPR-22 Monticello Extended Power Uprate: Replacement Steam Dryer - Response to NRC Requests for Additional Information, Revised Limit Curves and Supportinq Information (TAC No. MF3330)
References:
- 1) Letter from T Beltz (NRC) to K Fili (NSPM), "Monticello Nuclear Generating Plant - Issuance of Amendment No. 176 to Renewed Facility Operating License Regarding Extended Power Uprate (TAC No. MD9990)," dated December 9, 2013. (ADAMS Accession No. ML13343A006)
- 2) Letter from M A Schimmel (NSPM) to Document Control Desk (NRC),
"Monticello Extended Power Uprate: Replacement Steam Dryer -
Responses to Clarification Questions and Revised Analysis Documentation (TAC MD9990)," L-MT-1 3-091, dated August 29, 2013. (ADAMS Accession No. ML13248A343)
- 3) Email from T Beltz (NRC) to J Fields (NSPM), "Monticello Nuclear Generating Plant - Draft Request for Additional Information (EMCB) in Support of EPU Power Ascension (TAC No. MF3330)," dated May 15, 2014.
Pursuant to 10 CFR 50.92, the NRC issued Reference 1, license amendment 176 to the Monticello Nuclear Generating Plant (MNGP) Renewed Operating License (OL) and Technical Specifications (TS) to increase the maximum authorized power level from 1775 megawatts thermal (MWt) to 2004 MWt. This change to power level is considered an extended power uprate (EPU).
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Document Control Desk Page 2 In Reference 2, Northern States Power Company, a Minnesota corporation (NSPM),
doing business as Xcel Energy, provided the final analysis documentation for the replacement steam dryer (RSD) under EPU conditions. This documentation was used in support of the NRC's decision to grant license amendment 176 (Reference 1).
In early 2014, during power ascension activities (at 1864 MWt) for the EPU license amendment, the NRC questioned the accuracy of certain steam dryer data. Upon investigation NSPM discovered that data errors existed in the RSD analyses, one of which impacted the accuracy of the analysis documentation provided in Reference 2.
The errors consisted of 1) a strain gauge adjustment factor in the data acquisition system was left in a position that reduced the amplitude of the data acquired by a constant factor (this did not affect the accuracy of the NRC approval in Reference 1) and; 2) an inadvertent reversal of main steam line strain gauge signals used for benchmarking of the direct steam dryer instrumentation, which did affect the accuracy of the RSD analysis documentation. This discovery and the plans to correct these conditions were discussed with the NRC in a conference call held on May 30, 2014.
Upon discovery of the errors, NSPM reduced the MNGP power level to pre-EPU conditions (1775 MWt) in order to determine the effects of the errors on the RSD analysis. The effects of the errors were evaluated against the approved RSD analysis to determine if structural limits (ASME stress limits) for the RSD were exceeded. The evaluation concluded that the error did not result in exceeding any ASME stress limits.
In Reference 3, the NRC provided NSPM draft requests for additional information (RAIs). These draft RAIs were also discussed on the May 30, 2014 conference call with the NRC. The purpose of this letter is to provide the NRC the RAI responses and to provide additional analysis information to support resumption of EPU power ascension activities. contains Westinghouse Electric Company, LLC (WEC) letter LTR-BWR-ENG-14-010-P, "Responses to the US NRC Request for Additional Information Relative to the Monticello Replacement Steam Dryer Acoustic/Structural Analyses Set #7," dated July 18, 2014. Enclosure 1 provides responses to the RAIs from Reference 3. In addition, pages 24 - 26 of Enclosure 1 provide revised limit curves based on the reanalysis work described in this enclosure. The revised limit curves supersede the limit curves provided in LTR-A&SA-09-32, Revision 8, P-Attachment, previously sent to the NRC in Reference 2. Enclosure 1 contains proprietary information. contains a WEC affidavit executed to support withholding Enclosure 1 from public disclosure. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the NRC and addresses with specificity the considerations listed in 10 CFR 2.390(b)(4). NSPM requests that the proprietary information in Enclosure 1 be withheld from public disclosure in accordance with 10 CFR 2.390(a)4, as authorized by 10 CFR 9.17(a)4. Accordingly, it is respectfully
Document Control Desk Page 3 requested that the information which is proprietary to WEC be withheld from public disclosure in accordance with 10 CFR 2.390.
Correspondence with respect to the copyright or proprietary aspects of WEC information or the supporting WEC affidavit in Enclosure 2 should be addressed to J. A.
Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company LLC, 1000 Westinghouse Drive, Building 3 Suite 310, Cranberry Township, Pennsylvania 16066. contains a nonproprietary version of Enclosure 1. The nonproprietary report is being provided based on the NRC's expectation that the submitter of the proprietary information should provide, if possible, a nonproprietary version of the document with brackets showing where the proprietary information has been deleted.
Since NSPM was performing EPU power ascension activities at the time of discovery of the errors, NSPM has determined that the license conditions approved for EPU power ascension apply to the resolution. License Condition 15(d) requires the following:
- 15. In conjunction with the license amendment to revise paragraph2. C. I of Renewed Facility Operating License No. DPR-22 to reflect the new maximum licensed reactorcore power level of 2004 megawatts thermal (MWt), the license is also amended to add the following license conditions. These license conditions provide for monitoring, evaluating, and taking prompt action in response to potential adverse flow effects as a result of power uprate operation on plant structures, systems, and components (including verifying the continued structuralintegrity of the steam dryer). These license conditions are applicable to the initialpower ascension from 1775 MWt to 2004 MWt (EPU)conditions: ...
(d) The following key attributes of the program for verifying the continued structuralintegrity of the steam dryer shall not be made less restrictive without priorNRC approval:
- 1. During initialpower ascension testing above 1775 MWt, each test plateau increment shall be approximately 5 percent of 1775 MWt.
- 2. Level I performance criteria;and
- 3. The methodology for establishing the limit curves used for the Level I and Level 2 performance.
The analyses and the revised Limit Curves provided in Enclosure 1 support restarting EPU power ascension activities. As the original limit curves (Level 1 Performance Criteria) were based on incorrect data, NSPM is requesting NRC approval of the revised limit curves under License Condition 15(d)(2). , including the revised limit curves, provides the basis to resume EPU power ascension activities, but do not provide a complete set of revised analysis
Document Control Desk Page 4 documentation for the RSD. The EPU License Condition 15(e) requires, "a final load definition and stress reportof the steam dryer, including the results of a complete re-analysis... be provided within 90 days of the completion of EPU power ascension testing." In accordance with this license condition, NSPM is obligated to provide a complete set of RSD analysis documentation, including the error resolutions described herein, within 90 days from the conclusion of EPU power ascension testing activities.
Summary of Commitments This letter makes no new commitments and no revisions to existing commitments.
Karen D. Fili Site Vice-President Monticello Nuclear Generating Plant Northern States Power Company-Minnesota Enclosures (3) cc: Administrator, Region Ill, USNRC (w/o enclosures)
Project Manager, Monticello Nuclear Generating Plant, USNRC Resident Inspector, Monticello Nuclear Generating Plant, USNRC (w/o enclosures)
L-MT-14-060 ENCLOSURE 2 AFFIDAVIT FOR WITHHOLDING PROPRIETARY DOCUMENTS 6 pages follow
CAW-14-3995 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
ss COUNTY OF BUTLER:
Before me, the undersigned authority, personally appeared Bradley F. Maurer, 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:
Bradley F. Maurer, Principal Engineer Plant Licensing Sworn to and subscribed before me C MMONWEALT4 OF PENNSYLVANI, 2014 NOTARIAL SEAL this ,tr day of j--Y \, Elalpel. DiGirolamo, Notary. PUblic "H.arlso .TwO;.;-Allegheny County bCommission Expires Feb. 14, 2018 9ENBER, PENNSYLVANIA ASSOCIATION OF NOTARIES Notary Public
2 CAW-14-3995 (1) I am Principal Engineer, Plant Licensing, in Engineering, Equipment and Major Projects, 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 inconfidence 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 constitute Westinghouse policy and provide 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-14-3995 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.
(iii) 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-14-3995 (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.
(iv) 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.
(v) 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.
(vi) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in LTR-BWR-ENG- 14-01 0-P, "Responses to the US NRC Request for Additional Information Relative to the Monticello Replacement Steam Dryer Acoustic/Structural Analyses Set #7" (Proprietary) for submittal to the Commission, being transmitted by Xcel Energy letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with the Monticello Replacement Steam Dryer Acoustic/Structural Analysis, and may be used only for that purpose.
5 CAW-14-3995 (a) This information is part of that which will enable Westinghouse to:
(i) Assist Xcel Energy in obtaining NRC review of the Monticello Steam Dryer Acoustic/Structural Analysis.
(b) Further this information has substantial commercial value as follows:
(i) Westinghouse plans to sell the use of this information to its customers for purposes of plant specific replacement steam dryer analysis for licensing basis applications.
(ii) Its use by a competitor would improve their competitive position in the design and licensing of a similar product for BWR steam dryer analysis methodology.
(iii) 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 technical justifications 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.
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.
I 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 proprietaly 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.