LR-N08-0199, Hope Creek - Response to Request for Information for License Amendment Extended Power Uprate, License Condition 2.C.(22)2.b

Hope Creek - Response to Request for Information for License Amendment Extended Power Uprate, License Condition 2.C.(22)2.b

ML082540328
Person / Time
Site:	Hope Creek
Issue date:	09/02/2008
From:	Keenan J Public Service Enterprise Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LR-N08-0199
Download: ML082540328 (5)

Text

PSEG Nuclear LLC PO. Box 236,, Hancocks Bridge, NJ 08038-0236 0 PSEG Nuclear L.L. C.FOL 2.C.(22)2.b LR-N08-0199 September 2, 2008 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Hope Creek Generating Station Facility Operating License No. NPF-57 NRC Docket No. 50-354

Subject:

License Condition 2.C.(22)2.b

Reference:

1) Hope Creek Generating Station -Issuance of Amendment Re: Extended Power Uprate (TAC No. MD3002)This letter provides information in accordance with the subject requirement in connection with the license amendment (Reference

1) which increased the authorized maximum power level for the Hope Creek Generating Station to 3,840 megawatts thermal (MWt).License Conditions 2.C.(22)2.b requires: After reaching 111.5 percent of 3339 MWt, PSEG Nuclear LLC shall obtain measurements from the MSL strain gages and establish the steam dryer flow-induced vibration load fatigue margin for the facility, update the dryer stress report, and re-establish the limit curves with the updated ACM load definition, which will be submitted to the NRC staff.The required information is provided in the following attachments which have been updated to reflect operation at 111.5 percent of 3,339 MWt. Attachment 1 provides the limit curves based on in-plant strain gage data obtained at 111.5 percent of 3,339 MWt and the minimum stress ratio calculated from the strain gage data. Attachment 2 provides the updated dryer stress report.1 gooi LR-N08-0199 September 2, 2008 Page 2 Attachments 1 and 2 contain information proprietary to Continuum Dynamics, Inc.(C.D.l.).

C.D.I. requests that the proprietary information in Attachments I and 2 be withheld from public disclosure in accordance with 10 CFR 2.390(a)(4).

An affidavit supporting this request is provided in Attachment

3. Non-proprietary versions of the C.D.I. documents are provided in Attachments 4 and 5.The information contained in this letter and attachments is provided to comply with the subject requirement.

There are no new regulatory commitments contained in this submittal.

Should you have any questions regarding this submittal, please contact Mr. Paul Duke at 856-339-1466.

Sincerely, Manager -Licensing Attachments (5)1. C.D.I. Technical Note No.08-20P, Revision 1 (Proprietary Information)

.2. C.D.I. Report No.08-29P, Revision 0 (Proprietary Information)

3. Affidavit for Withholding C.D.I. Technical Note No.08-20P and C.D.I. Report No.08-29P from public disclosure

• 4. C.D.I.Technical Note No. 08-20NP, Revision 1 (Non-Proprietary version)5. C.D.I. Report No. 08-29NP, Revision 0 (Non-Proprietary version)cc: S. Collins, Regional Administrator

-NRC Region I J, Lamb, Project Manager -USNRC NRC Senior Resident Inspector

-Hope Creek P. Mulligan, Manager IV, NJBNE LR-N08-0199 ATTACHMENT 3 Hope Creek Generating Station Facility Operating License NPF-57 Docket No. 50-354 Affidavit for Withholding C.D.I. Technical Note No.08-20P and C.D.I. Report No.08-29P from public disclosure 4Continuum Dynamics, Inc.(609) 538-0444 (609) 538-0464 fax 34 Lexington Avenue Ewing, NJ 08618-2302 AFFIDAVIT Re: "Limit Curves with ACM Rev. 4 for 111.5% Power Level Basis at Hope Creek Unit 1," C.D.I. Technical Note No.08-20P, Revision 1, prepared by Continuum Dynamics, Inc. dated August 2008 and "Final Stress Assessment of Hope Creek Unit I Steam Dryer at 111.5% CLTP Conditions," C.D.I. Report No.08-29P, Revision 0, prepared by Continuum Dynamics, Inc. dated August 2008 I, Alan J. Bilanin, being duly sworn, depose and state as follows: I1. I hold the position of President and Senior Associate of Continuum Dynamics, Inc. (hereinafter referred to as C.D.I.), and I am authorized to make the request for withholding from Public Record the Information contained in the documents described in Paragraph

2. This Affidavit

is submitted to the Nuclear Regulatory Commission (NRC) pursuant to 10 CFR 2.390(a)(4) based on the fact that the attached information consists of trade secret(s) of C.D.I. and that the NRC will receive the information from C'D.I. under privilege and in confidence.

2. The Information sought to be withheld, as transmitted to -PSEG Nuclear LLC as ,attachments to C.D.I. Letter No. 08144 dated 2 September 2008 "Limit Curves with ACM Rev. 4 for 111.5% Power Level Basis at Hope Creek Unit 1," C.D.I.Technical Note No.08-20P, Revision 1, prepared by Continuum Dynamics, Inc.dated August 2008 and "Final Stress Assessment of Hope Creek Unit 1 Steam Dryer at 111.5% CLTP Conditions," C.D.I. Report No.08-29P, Revision 0, prepared by Continuum Dynamics, Inc. dated August 2008 3. The Information summarizes: (a) a process or method, including supporting data and analysis, where prevention of its use by C.D.I.'s competitors without license from C.D.I. constitutes a competitive advantage over other companies;(b) Information which, if used by a competitor, would-reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;(c) Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

The information sought to be withheld is considered to be proprietary for the reasons set forth in-paragraphs 3(a), 3(b) and 3(c) above.

4. The Information has been held in confidence by C.D.I., its owner. The Information has consistently been held in confidence by C.D.I. and no public disclosure has'been made and it is not available to the public. All disclosures to third parties, which have been limited, have been made pursuant to the terms and conditions contained in C.D.I.'s Nondisclosure Secrecy Agreement which must be fully executed prior to disclosure.

5. The Information is a-type customarily held in confidence by C.D.I. and there is a rational basis therefore.

The Information is a type, which C.D.I. considers trade secret and is held in confidence by C.D.I. because it constitutes a source of competitive advantage in the competition and performance of -such work in the industry.

Public disclosure of the Information is likely to cause substantial harm to C.D.I.'s competitive position and foreclose or reduce the availability of profit-making opportunities.

I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to be the best of my-knowledge, information and belief.Executed on this day of -r-,' -2008.Pan J. u lai Sbscribed and sworn before me this day: _ /&4n 4 eite"r, Notary Public EILEEN P. BURMEISTER NOTARY PUBLICOF NEW JERSEY MY COMM. EXPIRES MAY-6, 2012