ML070040383

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GE-NE-OOOO-0061-0595-NP-RO, Engineering Report: Susquehanna Replacement Steam Dryer Fatigue Analysis.
ML070040383
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 12/31/2006
From:
General Electric Co
To:
Office of Nuclear Reactor Regulation
References
PLA-6146 GE-NE-OOOO-0061-0595-NP-RO
Download: ML070040383 (97)
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Enclosure 2 to PILA-6146 General Electric Company Nuclear Energy Report

  1. GE-NE-OOOO-0061-0595-NP-RO Susquehanna Replacement Steam Dryer Fatigue Analysis December 2006 (Non Proprietary)

GE Energy Nuclear General Electric Company 1 6705 Valleeftos Road Sunol CA 94586 Non-proprietaiy Version GE-NE-0000-006 1-0595-NP-RO.

DRF 0000-0061-0582 Class I December 2006 Engineering Report Susquehanna Replacement Steam Dryer Fatigue Analysis

GE-NE-O0O0-0061 -05 95-NP-RO NON-PROPRIETARY VERSION IMPORTANT NOTICE REGARDING THE CONTENTS OF THIS REPORT Please Read Carefully NON-PROPRIETARY INFORMATION NOTICE This is a non-proprietary version of the document GE-NE-OOOO-0061-0595.-P-RO, which has the proprietary information removed. Portions of the document that have been removed are indicated by an open and closed double brackets as shown here ff B.

IMPORTANT NOTICE REGARDING CONTENTS OF THIS REPORT Please Read Carefully The only undertakings of the General Electric Company (GE) respecting information in this document are contained in the contract between the company receiving this document and GE.

Nothing contained in this document shall be construed as changing the applicable contract. The use of this information by anyone other than a customer authorized by GE to have this document, or for any purpose other than that for which it is intended, is not authorized. With respect to any unauthorized use, GE makes no representation or warranty, and assumes no liability as to the completeness, accuracy or usefuldness of the information contained in this document, or that its use may not infringe privately owned rights ii

GE-NE-OOOO-0061 -0595-NP.RO NON-PROPRIETARY VERSION TABLE OF CONTENTS Section Page ACRONYMS AND ABBREVIATIONS ............. ................................................ vii ACRONYMS AND ABBREVIATIONS ................................. ..... I...................... 1vii

1. EXECUTIVE

SUMMARY

........................................................................1..

2. INTRODUCTION ANT) BACKGROUND .............................................. .......... 2 3.MATERIAL PROPERTIES ...................................................... .................. 3
4. DESIGN CRITERIA ......... ....................................................................... 4 4.1 Fatigue Criteria....................I....................................................... 4 4.2 ASMIE Code Criteria for Load Combination ......................................... 5
5. DRYER FEA MODEL AND APPLIED LOADS ................................................. 6 5.1 Full Dryer Shell Finite Element Model................................................ 6 5.2 Dynamic Pressure Loads.............................. .................................. 7 5.3 Spatial Distribution, Time H9story and Frequency Contents of the Loads ...... 7 5.4 1]and Extrapolation to EPU.................... 7
6. VIBRATION ANALYSIS AND PREDICTED COMPONENT STRESSES .................. 9 6.1 Vibration Analysis Appro ach........................................................... 9 6.2 Maximum Stresses, Structural Uncertainty and Design Criteria............ 9 63Initial Fatigue Assessment and (( ].............

..... 12 6.3.1 [))Stress Prediction .......................... 12 6.3.2, (( Stress Investigation ............ I........14

7. FATIGUE PREDICTION AT EPU CONDITIONS............................................. 16
8. ASME LOAD COMBINATIONS................................................................. 19 8,1 ASME Code Load Combinations ........................................... .......... 19 8.2 AS.ME Code Load Case Stress Results .............................................. 21
9. CONCLUSIONS .................................................................................... 24
10. REFERENCES................................................................ 25 iii

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION LIST OF TABLES Table 3-1 Properties of SS304 [Reference 2]..........-.................................... ............ 3 Table 4-1 ASME Code Stress Limits [Reference 3] ................................................... 5 Table 6-1 Maximum Stress Intensity from Vibration Solution under 113%OLTP Loads ...... 11..

Table 7-1 Updated Component Stress Summary..................................................... 17 Table 7-2 Predicted Fatigue Margin under EPU Condition ......................................... 18 Table 8-1 Susquehanna Units I & 2 Steam Dryer Load Combinations ............................ 19 Table 8-2 EPU ASME Results for Normal and Upset Conditions: Maximum Stresses........... 22 Table 8-3 EPU ASME Results for Emergency and. Faulted Conditions: Maximum Stresses.....23 iv

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION LIST OF FIGURES Figure 5-1 Thickness Increase of Susquehanna Replacement Dryer .............................. 26 Figure 5-2 Susquehanna Dryer Finite Element Model.............................................. 27 Figure 5-3 Section of Water Element................................................................. 28 Figure 5-4 Dryer Top Plate Details ................................................................... 29 Figure 5-5 Trough Thin and Thick Section Details ................................................. 30 Figure 5-6 Bank Top Plate and Top Side Plate Details............................................. 31 Figure 5-7 Outer Vane Bank End Plate and Inner Vane Bank Plate Details...................... 32 Figure 5-8 Thin and Thick End Plate Details........................................................ 33 Figure 5-9 Inner Hood and Outer Hood Details..................................................... 34 Figure 5-10 Hood Support Details.................................................................... 35 Figure 5-1 1 Inlet End Plates (Thin and Thick) Details.. ........................................... 36 Figure 5-12 Drain Pipes, Drain Channels, Skirt and Lower Skirt Ring ........................... 37 Figure 5-13 Vane Banks with Perforated Plates..................................................... 38 Figure 5-14 Susquehanna Dryer FE Model's Boundary Conditions .............................. 39 Figure 5-15 Vane Bundle-Trough Interface Boundary Conditions................................ 40 Figure 5-16 Pressure Distribution on 90' Hood at LS547. 113% OLTP Nominal............... 41 Figure 5-17 Pressure Distribution on 2700 Hood at LS666. 113% OLTP Nominal............. 42 Figure 5-18 Peak Pressure Time History, 90' Hood................................................ 43 Figure 5-19 Peak Pressure Time History, 270' Hood .............................................. 44 Figure 5-20 Peak Pressure PSD, 90' Hood........................................................... 45 Figure 5-21 Peak Pressure PSD, 270' Hood......................................................... 46 Figure 6-1 Rayleigh Damping Curve ............................ 47 Figure 6-2 Dryer Base Plate Max. Stress Intensity, 113% OLTP Nominal........................48 Figure 6-3 Trough Thin Section Max. Stress Intensity, 113% OLIP Nominal .................. 49 Figure 6-4 Trough Thick Section Max. Stress Intensity, 113% OLTP Nominal .......... -...... 50 Figure 6-5 Bank Top Plate Max. Stress Intensity, 113% OLTP Nominal......................... 51 Figure 6-6 Bank Top Side Plates Max. Stress Intensity, 113% OLTP Nominal ................. 52 Figure 6-7 Outer Vane Bank End Plate Max. Stress Intensity, I 13%OLTP Nominal ........... 53 Figure 6-8 Inner Vane Bank End Plate Max. Stress Intensity, 113% OLTP Nominal........... 54 v

GE-NE-0OOO-0061-0595-NP-RO NON-PROPRIETARY VERSION Figure 6-9 Thin End Plates Max. Stress Intensity, 113% OLTP Nominal........................ 55 Figure 6-10 Thick End Plates Max. Stress Intensity, 113% OLTP Nominal ..................... 56 Figure 6-11 inner Hood Max. Stress Intensity, 113% OLTP Nominal............................ 57 Figure 6-12 Outer Hood Max. Stress Intensity, 113 % OLTP Nominal........................... 58 Figure 6-13 Hood Support Max. Stress Intensity, 113 % OLTP Nominal ..................59 Figure 6-14 Inlet End Plate (Thin) Max. Stress Intensity, 113% OLTP Nominal ............... 60 Figure 6-15 Inlet End Plate (Thick) Max. Stress Intensity, 113% OLTP Nominal............... 61 Figure 6-16 Skirt Max. Stress Intensity, 113% OLTP Nominal ................................... 62 Figure 6-17 Support Ring Max. Stress Intensity, 113% OLTP Nominal ......................... 63 Figure 6-18 Drain Pipe Max. Stress Intensity, 113% OLTP Nominal ............................ 64 Figure 6-19 Drain Channel Max. Stress Intensity, 113% OLTP Nominal........................ 65 Figure 6-20 Lower Skirt Ring Max. Stress Intensity, 113% OLTP Nominal .................... 66 Figure 6-21 Cover Plate Max. Stress Intensity, 113% OLTP Nominal ........................... 67 Figure 6-22 Skirt Max. Stress Intensity, 113% OLTP Minus75................................... 68 Figure 6-23 ......................6 9 Figure 6-24 .......... ......... .......70 Figure 6-25 .... .......71 Figure 6-26 ] .......... 72 Figure 6-27 Inner Vane Bank End Plate Max. Stress Intensity, 113% OLTP, PluslO........... 73 Figure 6-28 Sketch of the Tie rod and Inner Vane.Bank End Plate Joint .......................... 74 Figure 6-29 Inner Vane Bank End Plate without Tie rod Joint Regions .......................... 75 Figure 6-30 Updated Inner Vane Bank End Plate Max. Stress, 113% OLTP, MinuslO......... 76 vi

GE-NE-0OOO-0061 -0595-NP-RO ACRONYMS AND ABBREVIATIONS Item Short Form <b'Description I ACM Acoustic Circuit Model 2 ASME American Society of Mechanical Engineers 3 BWR Boiling Water Reactor 4 CLTP Currently Licensed Thermnal Power 5 EPU Extended Power Uprate 6 FEA Finite Element Analysis 7 FEM Finite Element Model 8 FFT Fast Fourier Transform 9 FIy Flow Induced Vibration 10 GE General Electric I11 GENE General Electric Nuclear Energy 12 Hz Hertz 13 LGSCC Intergranular Stress Corrosion Cracking 14 Mlbmlhr Millions pounds mass per hour 15 MS Main Steam 16 MSL Main Steam Line 17 MW Megawatt Thermal 18 NA Not Applicable 19 NRC Nuclear Regulatory Commission 20 OBE Operational Basis Earthquake 21 OLTP Original Licensed Thermal Power 22 Pb Primary Bending Stress 23 Pm Primary Membrane Stress 24 PPL Pennsylvania Power & Light 25 psi Pounds per square inch 26 Ref. Reference 27 RMS Root-Mean-Squared 28 RPV Reactor Pressure Vessel 29 SCF Stress Concentration Factor 30 SRSS Square Root Sum of Squares 31 SR Safety Relief Valve 32 SSES Susquehanna Steam Electric Station vii

GE-NE-O000-0061 -0595-NP-RD NON-PROPRIETARY VERSION

1. EXECUTIVE

SUMMARY

This report documents the finite element stress analyses of the proposed replacement steam dryer for the Susquehanna Steam Electric Station (SSES). The focus of these analyses is to predict the replacement dryer's susceptibility to fatigue under the Flow Induced Vibration (FIV) and mechanically induced vibration loads during normal operation at Extended Power Uprate (EPU) power levels. A detailed finite element model (1FEM) is used to perform the structural dynamic analyses. The results of these analyses are used to assess dryer versus fatigue and ASME design criteria under the operating conditions.

The fatigue evaluations are performed at steam flow closely matching 113% of the Original Licensed Thermal Power (OLTP) flow conditions. The applied pressure loads were developed by Continuum Dynamics, Inc. (CDI) based on in-plant steam line pressure measurements taken during the spring of 2006. The 113% OLTP analysis is used as the basis for extrapolating the dryer stress to full EPU conditions by using the benchmark study and scaling law previously developed for Susquehanna dryer.

The fatigue evaluation indicates that at full EPU conditions, all dryer components meet the fatigue acceptance criteria with adequate or high margins, and the replacement dryer is structurally adequate to accommodate the FIV and mechanically induced vibration loads at EPU condition.

The ASMIE load combination analysis results indicate that the stresses for all structural components are under the allowable ASME Code limits at EPU operating conditions.

Therefore, the fatigue evaluation and ASME load combination analysis proves the acceptability of the Susquehanna replacement steam dryer design.

I

GE-NE-0000-0061 -05 95-NP-RO NON-PROPRIETARY VERSION

2. INTRODUC11ON AND BACKGROUND The original Susquehanna steam dryer's structural responses were analyzed for component fatigue evaluation at Extended Power Uprate (EPU) conditions [Reference 1]. The analyses used the steam dryer's finite element model to calculate its transient dynamic responses. The pressure loads used in the analyses were developed by Continuum Dynamics, Inc. (CDD) based on in-plant steam line pressure measurements taken at various power levels during the spring of 2006, which included the Original Licensed Thermal Power (OLTP), the Current Licensed Thermal Power (CLTP), and the 113% OLTP. In addition to these provided nominal loads, the time scale of the loads was stretched by plus and minus 10% respectively to create frequency shift in loads, in order to capture structural uncertainty. In all these transient response analyses, Rayleigh damping equivalent to 1% damping ratio was applied. The maximum stresses of dryer components were searched from all the solutions over the calculated response time histories. Based on a benchmarking analysis of 1985 strain gauge data, a scaling factor was applied to these stresses to include both flow and mechanically induced vibration. Subsequently, a scale factor is then used to extrapolate the stress results of 113% OLTP to EPU conditions, and the resulting stress values were used for component fatigue evaluation.

The results of the analyses on the original Susquehanna dryer identified that several dryer components were susceptible to fatigue failure under EPU operating condition.

After a comprehensive review of alternative dryer modifications and a review of the operational history of previous dryer modifications, a replacement dryer configuration was proposed to sustain the vibration environment at EPU condition. This replacement dryer uses ((

13thus to reduce component stresses and increase fatigue margin. The corresponding structural analyses are performed to predict the dryer's structural responses to the vibration loads and ASME load combination, and to assure the dryer meets the design criteria.

This report documents the fatigue analysis and ASME load combinations of this Susquehanna replacement dryer, and summarizes the predicted component stresses and fatigue margins.

2

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION

3. MATERIAL PROPERTIES The dryer assembly is manufactured from Type 304 conforming to the requirements of the material and fabrication specifications. ASMIE material properties are used

[Reference 21, The applicable properties are shown in Table 3-1.

Table 3-1 Properties of SS304 [Reference 2]

Room temperature Operating temperature Material / property 70OF 545OF SS304 Sy, Yield strength, psi 30,000 17,000 Su, Ultimate strength, psi 75,000 63,500 E, Elastic modulus, psi 28,300,000 26,430,000 3

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION

4. DESIGN CRITERIA 4.1 Fatigue Criteria The steam dryer fatigue evaluation consists of calculating the alternating stress intensity from Fly and mechanical induced vibration loading at all locations in the steam dryer structure and comparing it with the allowable design fatigue threshold stress intensity. The recommended fatigue threshold stress intensity considered is the ASME Code Curve C value of 13,600 psi.

Stresses below the ASME Code Curve C value are assumed to be below the level required to initiate a fatigue crack The fatigue design criteria for the steam dryer is based on Figure 1-9.2.2 of ASME Section III [Reference 3], which provides the fatigue threshold values for use in the evaluation of stainless steels. [

4

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION 4.2 ASME Code Criteria for Load Combination The ASME Code stress limits used in the evaluation of the Susquehanna dryer are listed in Table 4-1.

Table 4-1 ASME Code Stress Limits [Reference 3]

Stress Core Support Structures Stress limits Service level category IC(NG)

Stress Limit (ksi)

Service levels A & B Pm Sm 16.9 Pm+Pb 1.5 Sm 25.35 Service levels C Pm 1.5 Sm 25.35 Pm. + Pb 2.25 Sm 38.03 Service level D Pm Min (IS, or 2.4 Sm) 40.56

____________Pm + Pb 11.5 (Pm Allowable) 60.84 Legend.

General primary membrane stress intensity Pb: Primary bending stress intensity ASME Code stress intensity limit S,.

Ultimate strength Table 4-1 Note: Service Level Limits for Service Levels A, B and C are according to NG-3221 and Appendix F Paragraph F-133 1 for Level D. Upset condition stress limits are increased by 10% above the limits shown in this table per NG-3223 (a).

5

GE-NE-OOOO-0061I-0595-NP-RO NON-.PROPRIETARY VERSION

5. DRYER FEA MODEL AND APPLIED LOADS 5.1 Full Dryer Shell Finite Element Model The replacement dryer configuration only ((

1]

6

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION 5.2 Dynamic Pressure Loads The replacement steam dryer FIV response analysis uses loads developed by CDI, which are based upon steam flow conditions representative of 113% OURP The loads were derived from in-plant pressure measurements taken on the reactor main steam lines in 2006. [

The loading time history developed with the CDI acoustic circuit model is used as the nominal load case for the replacement steam dryer FIV analysis. In order to capture structural uncertainties, the time scale of this nominal load is stretched or compressed to create load cases with frequency shifts. In this replacement dryer fatigue analysis, a total of 9 load cases are created and analyzed. These 9 load cases include the nominal, minuslO (-10%), minus7.5 (-7.5%), minus5 (-5%). minus2.5 (-2.5%), plus2.5

(+2.5%), plus5 (+5%), plus7.5 (+7.5%), and pluslO (+10%) load cases.

5.3 Spatial Distribution, Time History and Frequency Contents of the Loads

))The spatial distributions of pressure on the dryer at these two instances are shown in Figures 5-16 and 5-17, respectively. The spatial distribution shows that the high pressure occurs near the MSL locations.

The pressure time histories, measured at the two maximum pressure locations on the outer hoods, are shown in Figures 5-18 and 5-19. [

))Therefore, a pressure power spectral density (PSD) evaluation is used to describe the frequency contents of the pressure time history. The results of the PSD evaluation for the time histories of Figures 5-18 and 5-19 are shown in Figures 5-20 and 5-21, respectively.['

5.4 []Jand Extrapolation to EPU In Reference 1, benchmark comparisons were made between the Susquehanna FEA predictions and in-plant measurements taken during testing in 1985. The benchmark 7

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION study included comparisons between predicted and measured pressures at the pressure drum and outer hood locations. A more detailed comparison was also made of the predicted strains versus measured strains at specific strain gauge locations. It was concluded that Susquehanna FEA results were under predicted such that a stress under-prediction factor of 2.17 should be applied to the FEA stress results to bring them inline with the testing measurements. This approach (i.e., use of an adjustment factor) will be used in the replacement Susquehanna dryer fatigue evaluation.

The FIY analysis for the replacement steam dryer is performed with the loading developed from the Susquehanna in-plant main steam line pressure measurements for power level of 113% OLTP (3721 MWt). The results of the finite element analyses must then be extrapolated to determine the stresses on the dryer at EPU conditions.

Dynamic operating measurements are available from three sources for determining the extrapolation to EPU. Reference I documented the process of extrapolating the results of 113% OLT? to EPU conditions, which included the use of three data sources: The 1985 in-plant instrumented dryer measurements [Reference 5], the MSL pressure measurements [Reference 7], and SSES-specific scale model testing

[Reference 8]. [

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GE-NE-0OOO-006 1-0595-NP-RO NON-PROPRIETARY VERSION

6. VIBRAl1ON ANALYSIS AND PREDICTED COMPONENT STRESSES 6.1 Vibration Analysis Approach The structural responses of the replacement steam dryer [

))Rayleigh damping is used in all of the analyses. Rayleigh damping coefficients[I 6.2 Maximum Stresses, Structural Uncertainty and Design Criteria Following each of the transient solutions, an ANSYS macro is used to search through all time steps on every component to extract the maximum stress intensity and the corresponding time and location. The element stress values from the shell element top, bottom, and middle surfaces are surveyed. The maximum values of stress intensity on the shell top or bottom are used for fatigue evaluation, and the maximum values of stress intensity on the middle surface are used in the ASME load combination.

Of the 9 load cases, the maximum stress intensity of nominal load is to be used for fatigue margin calculation using the following formula:

Margin = 13600 1 Stress - SF The difference between the nominal case and the maximum stress of all 9 cases is used to evaluate structural uncertainty using the following formula:

9

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION Structural Uncertainty = Maximum Stress-Nominal Stress The design criteria based on these fatigue margin and structural uncIertainty values is to require each component to have fatigue margin greater than its structural uncertainty.

Table 6-1 summarizes the component stresses and the associated structural uncertainty. Corresponding to the stress values of the nominal load case, the component stress plots are shown in Figures 6-2 through 6-21.

10

GE-NE-OOOO-006 1-0595-NP-RO NON-PROPRIETARY VERSION Table 6-1 Maximum Stress Intensity from Vibration Solution under 11 3%OLTP Loads

[I

+ + 4 4 + 4 + +

1]

II

GE-NE-0OOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION 6.3 Initial Fatigue Assessment and [

The scale factors applying to the stresses for fatigue evaluation for EPU conditions include a weld factor of 1.0, 1.4, or 1.8 depending on the weld configuration [Reference 1], a stress under-prediction factor of 2.17 and an EPU scale factor of 1.15 (Section 5.4). With these factors included, an initial fatigue assessment was made. The results indicated that the skirt and the inner vane bank end plate might be susceptible to fatigue.

6.3.1 [C )) Stress Prediction At this region, the dryer FE model has introduced simplifications in order to capture the dynamic behavior without complicating the FE model. ((

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GE-NE-OOOO-006 1-0595-NP-RO NON-PROPRIETARY VERSION 13

GE-NE-OOOO-0061-0595-NP-RO NON-PROPREETARY VERSION 6.3.2 [ ]Stress Investigation 14

GE-NE-OOOO-0061-0595-NP-RO NON-PROPRIETARY VERSION 15

GE-NE-OOOC-0061-0595-NP-RO NON-PROPRfIETARY VERSION

7. FATIGUE PREDICTION AT EPU COND1IlONS Based on the vibration response in Section 6.2 and ((

)) in Section 6.3, the Susquehanna replacement dryer's component stresses are summarized in Table 7-I, ((

]JStructural uncertainty is also calculated for every component in Table 7-I. Correspondingly, the component fatigue margins are calculated in Table 7-2.

The results in Table 7-2 indicate that all dryer components' fatigue margins are greater than their structural uncertainty. Therefore, all components of this Susquehanna replacement dryer meet the design criteria, and, this replacement dryer concept is structurally adequate to accommodate the vibration environment at EPU condition. This proves the replacement dryer concept's feasibility of sustaining the vibration loads.

16

GE-NE-OQOO-006 1-0595-NP-RO NON-PROPRIETARY VERSION Table 7-1 Updated Component Stress Summary

___________ I ___ t __ I __ I __ I __ I ___ I __ I ___ I ___ I____ I ____

4 4- 4 4 4 .4- 4- 4 4 -I-4 4- 4- 4 4 4 4- 4- 1 4 4-4 4- 4 1 4 4 + 4- 4 4 4-11 17

GE-NE-0OOO-006 1-0595-NP-RO NON-PROPRIETARY VERSION Table 7-2 Predicted Fatigue Margin under EPU Condition 11 18

GE-NE-0OOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION

8. ASME LOAD COMBINATIONS The Susquehanna steam dryer was analyzed for the ASMIE Code load combinations (primary stresses) shown in Table 8-1. The acceptance criteria used for these evaluations are specified in Section 4.2 and are the same as those used for safety related components. The FIV stresses, where applicable, were added from the existing results obtained for the EPU condition.

8.1 ASME Code Load Combinations Susquehanna is a "New Loads" plant. The resulting load combinations for each of the service conditions are discussed in Reference 9 and summarized in Table 8-1.

Tabl e 8-1 Susquehanna Units I & 2 Steam Dryer Load Combinations A-i ý Normal DW + 6PN + FIVN 1" 9 B-i Upset DW + liPN + TSV 1 + FIVN B-2 Upset DW +,LPN + TSV 2 B-3 Upset DW + OPu + SRV +FIVu B-4 Upset DW + LPN +OBE + FVN B-5 Upset DW + 6Pu + [SRV 2 + OBE2] 0.5 + FlVu C-i1 Emergency DW + £6PE + SRVADS + FIVN D-1 Faulted DW + PFl + [SRVADS 2 +SSE 2105s D-2 Faulted iDW + £6PN + [AC12+ SSE 2 + FIVN 2]05' D-3 Faulted DW +iPF2 D-4 Futd DW~NAC2 + FVN D-5 Faulted DW + 6Pu + [SRV2 + SSE 2]05ý + FIVu Definition of Load Acronyms:

ACI = Acoustic load due to Main Steam Line Break (MSLB) outside containment, at the Rated Power and Core Flow (Hi-Power) Condition.

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GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION AC2 = Acoustic load due to Main Steam Line Break (MSLB) outside containment, at the Low Power/High Core Flow (Interlock) Condition.

AP = Annulus Pressurization Loads CHUG Chugging -(LOCA) Loads, Greater of symmetric or asymmetric chugging loads.

DW = Metal Weight + Water Weight.

APn = Differential 4static' Pressure Load during Normal Operation.

Apu = Differential 'static' Pressure Load during Upset Operation (including the effects of stuck-open relief Valve (SORV) condition).

APE = Differential 'static' Pressure Load during Emergency Operation (inadvertent actuation of ADS).

APFI Differential Pressure Load in the Faulted condition, due to Main Steam Line Break outside containment at the Rated Power and Core Flow (Hi-Power) condition.

APF7 = Differential Pressure Load in the Faulted condition, due to Main Steam Line Break outside containment at the Low. Power/High Core Flow (Interlock) Condition.

FIVN = Flow Induced Vibration Load during Normal Operation.

FIVu = Flow Induced Vibration Load during Upset Operation.

JR = Jet Reaction Loads OBE = Operating Basis Earthquake.

SSE Safe Shutdown Earthquake.

SRV = Safety Relief Valve Loads (Greater of all SRV or SR V-Asymmetric)

SRVADs= SRV Loads caused by the "automatic depressurization system" TSVI = The Initial Acoustic Component of the Turbine Stop Valve (TSV)

Closure Load (Inward load on the outermost hood closest to the nozzle).

TSV2 = The Flow Impingement Component (following the Acoustic phase) of the TSV Closure Load (Inward load on the outermost hood closest to the nozzle).

20

GE-NE-OOOO-0061 -0595-NP-RO NON-.PROPRIETARY VERSION 8.2 ASME Code Load Case Stress Results The stresses reported from the ANSYS analysis runs are maximum stresses and not general primary membrane or membrane plus bending stresses. Comparing the maximum stresses (rather than primary stresses as it is required by the Code) against the ASME limits (Table 4-1) is a very conservative way of structural components evaluation. However, as it is shown in Table 8-2 and Table 8-3, this conservative qualification has been successful for all the components and load combinations. Table 8-2 and Table 8-3 list the components maximum stresses obtained from the ANSYS analysis.

For ASME load combination analysis, (

Table 8-2 and Table 8-3 summarize the ASME load combination analysis results and indicate that the stresses for all structural components are under the allowable ASME Code limits at EPU operating conditi ons.

21

GE-NE-00OO-006 1-0595-NP-RO NON-PROPRIETARY VERSION Table 8-2 EPU ASME Results for Normal and Upset Conditions: Maximum Stresses 22

GE-NE-OOOO-006 1-0595-NP-RO NON-PROPRIETARY VERSION Table 8-3 EPU ASME Results for Emergency and Faulted Conditions: Maximum Stresses 11 23

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION

9. CONCLUSIONS Finite element stress analyses are performed for the replacement Susquehanna steam dryers to predict dryer's structural responses to the Flow Induced Vibration (Fly) and mechanically induced vibration loads under the Extended Power Uprate (EPU) condition and ASMIE load combination, A detailed finite element model (FEM) is used to perform the structural dynamic analyses. The applied pressure loads were developed by Continuum Dynamics, Inc.

(CDI) based on in-plant steam line pressure measurements taken at 113% OLT?

power levels during the spring of 2006. The results are used as basis for extrapolating the dryer stresses to full EPU conditions.

The fatigue evaluation indicates that at full EPU conditions, all dryer components meet the fatigue acceptance criteria with adequate or high margins, and the replacement Susquehanna design is structurally adequate to accommodate the vibration environment at EPU condition.

The ASME load combination analysis results indicate that the stresses for all structural components are under the allowable ASME Code limits at EPU operating conditions.

Therefore, the fatigue evaluation and ASME load combination analysis proves the acceptability of the Susquehanna replacement steam dryer design.

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GE-NE-OOOO-0061I-0595-NP-RO NON-PROPRIETARY VERSION

10. REFERENCES

[1] Susquehanna Steam Dryer Fatigue Analysis, GENE 0000-0057-4166-Ri, September 2006

[2] ASMIE B&PV Code, Section 11, Part D-Properties, 1995,

[3] ASME B&PV Code, Section 111, 1998 Edition with 2000 Addenda.

[4] C.DI. Report No. 06-22 Rev. 0, "Hydrodynamic Loads at OLTP, CLT`P, and 113% OLTP on Susquehanna Unit I Steam -Dryer to 250 Hz," September 2006

[5] MIDE #199-0985, "Susquehanna - 1 Steam Dryer Vibration Steady State and Transient Response," October 1985.

[6] Susquehanna Steam Electric Station Units 1&2 Extended Power Uprate, GENE 0038-356 1 RO, June 2005

[7] Horvath, R., and Trubeija, M.; SIA Calculation Package; Susquehanna Unit 1 Main Steam Line Strain Gage Data Reduction; File No. SSES-23Q-302, Project No. SSES-23Q.

[8] Neiheisel, M., Test Report # I Susquehanna Steam Electric Station, Unit I Scale Model Test. GENE-0000-0054-2552. May 2006.

[9] "Susquehanna Units 1 and 2 Steam Dryer Load Combinations", GENE 0000-0051-3345, April 2006 25

GE-NE-OOOO-0061-0595-NP-RO NON-PROPRIETARY VERSION Figure 5-1 Thickness Increase of Susquehanna Replacement Dryer

.26

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION 11 Figure 5-2 Susquehanna Dryer Finite Element Model 27

GE-NE-0OOO-.0061 -0595-NP-RO NON-PROPRIETARY VERSION Figure 5-3 Section of Water Element 28

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION 1]

Figure 5-4 Dryer Top Plate Details 29

GE-NE-OOOO-0061 -059 5-NP-RO NON-PROPRIETARY VERSION tt 11 Figure 6-5 Trough Thin and Thick Section Details 30

GE-NE-OOOO-.0061 -0595-NP-RO NON-PROPRIETARY VERSION 1]

Figure 5-6 Bank Top Plate and Top Side Plate Details 31

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION

[II Figure 5-7 Outer Vane Bank End Plate and Inner Vane Bank Plate Details 32

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION 11 Figure 5-8 Thin and Thick End Plate Details 33

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION It 1]

Figure 5-9 Inner Hood and Outer Hood Details 34

GE-NE -0OOO-0061-0595-NP-RO NON-PROPRIETARY VERSION UI Figure 5-10 Hood Support Details 35

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION 11 Figure 5-11 Inlet End Plates (Thin and Thick) Details 36

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION 11 11 Figure 5-12 Drain Pipes, Drain Channels, Skirt and Lower Skirt Ring 37

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION Figure 5-13 Vane Banks with Perforated Plates 38

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION 11 Figure 5-14 Susquehanna Dryer FE Model's Boundary Conditions 39

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION Figure 5-15 Vane Bundle-Trough Interface Boundary Conditions 40

GE-NE-OOOO-0061 -05 95-NP-RO NON-PROPRIETARY VERSION Figure 5-16 Pressure Distribution on 900 Hood at LS547. 113% OLTP Nominal 41

GE-NE-0OOO-0061-0595-NP-RO N4ON-PROPRIETARY VERSION Figure 5-17 Pressure Distribution on 270' Hood at LS666. 113% OLTP Nominal 42

GE-NE-OOOO-0061-0595-NP-RO NON-PROPRIETARY VERSION

[t Figure 5-18 Peak Pressure Time History, 900' Hood 43

GE-NE-OOOO-0061 -05 95-NP-RO NON-PROPRIETARY VERSION 11 11 Figure 5-19 Peak Pressure Time History, 2700 Hood 44

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION 1]

Figure 5-20 Peak Pressure PSD, 900 Hood 45

GE-NE-0OOO-0061-0595-NP-RO NON-PROPRIETARY VERSION Figure 5-21 Peak Pressure PSD, 270* Hood 46

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION tt Figure 6-1 Rayleigh Damping Curve 47

GE-NE-0OOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION 1]

Figure 6-2 Dryer Base Plate Max. Stress Intensity, 113% OLTP Nominal 48

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION Figure 6-3 Trough Thin Section Max. Stress Intensity, 113% OLTP Nominal 49

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION Figure 6-4 Trough Thick Section Max. Stress Intensity, 113% QLTP Nominal 50

GE-NE-OOOO-0061-0595-NP-RO NON-PROPRIETARY VERSION Figure 6-5 Bank Top Plate Max. Stress Intensity, 113% OLTP Nominal 51

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION

[II 1]

Figure 6-6 Bank Top Side Plates Max. Stress Intensity, 113% OLTP Nominal 52

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION Figure 6-7 Outer Vane Bank End Plate Max. Stress Intensity, 113%OLTP Nominal 53

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION Figure 6-8. Inner Vane Bank End Plate Max. Stress Intensity, 113% OLTP Nominal 54

GE-NE-OOOO-0061-0595-NP-RO NON-PROPRIETARY VERSION 11 Figure 6-9 Thin End Plates Max. Stress Intensity, 113% OLTP Nominal 55

GE-NE-OOOO-0061 -0S95-NP-RO NON-PROPRIETARY VERSION Figure 6-10 Thick End Plates Max. Stress Intensity, 113% OLTP Nominal 56

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION 1]

Figure 6-11 Inner Hood Max. Stress Intensity, 113% OLTP Nominal 57

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION 1]

Figure 6-12 Outer Hood Max. Stress Intensity, 113% OLTP Nominal 58

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION Figure 6-13 Hood Support Max. Stress Intensity, 113% OLTP Nominal 59

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION Figure 6-14 Inlet End Plate (Thin) Max. Stress Intensity, 113% OLTP Nominal 60

GE-NE-0OOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION Figure 6-15 Inlet End Plate (Thick) Max. Stress Intensity, 113% OLTP Nominal 61

GE-NE-OOOO-0061I-0595-NP-RO NON-PROPRIETARY VERSION 11 1]

Figure 6-16 Skirt Max. Stress Intensity, 113% OLTP Nominal 62

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION Figure 6-17 Support Ring Max. Stress Intensity, 113% OLTP Nominal 63

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION Figure 6-18 Drain Pipe Max. Stress Intensity, 113% OLTP Nominal 64

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION 1]

Figure 6-19 Drain Channel Max. Stress Intensity, 113% OLTP Nominal 65

GE-NE-0OOO-0061 -05 95-NP-RO NON-PROPRIETARY VERSION

[II Figure 6-20 Lower Skirt Ring Max. Stress Intensity, 113% OLTP Nominal 66

GE-NE-0OOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION 11 Figure 6-21 Cover Plate Max. Stress Intensity, 113% OLTP Nominal 67

GE-NE-OOOO-0061-0595-NP-RO NON-PROPRIETARY VERSION Figure 6-22 Skirt Max. Stress Intensity, 113% OLTP Minus75 68

GE-NE-OOOO-0061 -OS95-NP-RO NON-PROPRIETARY VERSION Er 11 Figure 6-23 (( i11 69

GE-NE-0OOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION 11 1]

Figure 6-24 11 70

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION 1]

Figure 6-25 11 71

GE-NE-OOOO-0061-0595-NP-RO NON-PROPRIETARY VERSION Figure 6-26 ff 11 72

GE-NE-0OOO-0061 -05 95-NP-RO NON-PROPRIETARY VERSION Figure 6-27 Inner Vane Bank End Plate Max. Stress Intensity, 1,13% OLTP, PluslO 73

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION 1]

Figure 6-28 Sketch of the lie rod and Inner Vane Bank End Plate Joint 74

GE-NE-OOOO-.0061 -0595-NP-RO NON-PROPRIETARY VERSION 1]

Figure 6-29 Inner Vane Bank End Plate without Tie rod Joint Regions 175

GE-NE-OOOO-0061 -0595-NP-RO NON-PROPRIETARY VERSION Figure 6-30 Updated Inner Vane Bank En .d Plate Max. Stress, 113% OLTP, MinuslO0 76

Enclosure 5 to PLA-6146 Description of PPL Commitment Closure (Non Proprietary Version)

Non- Proprietary Version of the PPL Responses Enclosure 5 to PLA-6146 Page 1 of 6 Introduction In the Attachment to PLA-6 128 (Reference 4), PPL commnitted to provide the following:

1) A summary of proposed steam dryer structural modifications;
2) The results of the final finite element analyses at 120% original licensed thermal power (OLTP), based on the final dryer structural configuration;
3) ASME load combination tables, based on the 120% OLTP condition; and,
4) A description of the steam dryer power ascension test plan.

The following provides a summary description of how each of these commitments have been satisfied.

Reg~ulatory Commitment (1)

Provide a Summary of Proposed Steam Dryer Structural Modifications In Attachment 10 of PPL's CPPU submittal (Reference 1), several dryer sub-components were identified has having little, or no fatigue margin. Thus, the fatigue analysis indicated that modifications to the dryer will be required for CPPU operation.

In Attachment I of PPL letter (Reference 3), PPL stated that a review had been completed of modifications required to resolve the over stress conditions identified with the current Susquehanna steam dryer design. The review concluded that structural modifications to the existing steam dryer are not justifiable when economic and ALARA factors are considered. As a result, PPL directed General Electric (GE) to design and fabricate two new steam dryers for the Susquehanna units. The new Unit 1 steam dryer will be installed during the 2008 refueling outage and the new Unit 2 steam dryer will be installed during the 2009 refueling outage.

The new Susquehanna steam dryer design has resolved the over stress conditions. The new Susquehanna steam dryer design maintains the current curved hood configuration and the current geometry and dimensional envelope. Critical structural components have had their thickness increased to improve the overall stiffness of the steam dryer. The critical component changes are:

11l

Non-Proprietary Version of the PPL Responses Enclosure 5 to PLA-6 146 Page 2 of 6 These changes are graphically depicted in Figure 5-1 of the "Susquehanna Replacement Steam Dryer Fatigue Analysis," which is provided in Enclosure 1.

Re~yulatory Commitment (2)

Provide the Results Of The Final Finite Element Analyses At 120 % Original Licensed Thermal Power (OLTP), Based On The Final Dryer Structural Configuration GE has constructed a finite element model for the new steam dryer and has completed the required fatigue analysis. The 113% OLTP Acoustic Circuit Model (ACM) loads calculated for the existing steam dryer were input to the new Finite Element Analysis (FEA) model. These 113% OLTP loads are based on a composite load definition from main steam line strain gauge data obtained during MSIV slow closure testing, where each of the four MSIVs were closed one at a time. In the FEA, small time steps were used which correspond to frequency shifts of [

))to determine the maximum stress intensities. Weld factors were then applied, and the maximum stress intensities ((I )). The 113% stress intensities were then scaled to the full CPPU steam flow conditions. The FEA model used to generate the stress intensities is discussed in detail in Sections 5 and 6 of the "Susquehanna Replacement Steam Dryer Fatigue Analysis," which is provided in The final results of the GE FEAs indicate that the maximum stress intensities for all components, including structural uncertainties, are below the ASME 13,600 PSI fatigue design limit for 304 stainless steel with adequate margins. In addition, Table 1 below identifies the margins for the critical dryer structural components, with consideration given to Susquehanna's "end-to-end" uncertainty evaluation, which was provided in 0 of PPL' s CPPU submittal (Reference 1).

Non-Proprietary Version of the PPL Responses Ecoue5t PLA-6 146 Page 3 of 6

Non-Proprietary Version of the PPL Responses Enclosure 5 to PLA-6146 Page 4 of 6 TABLE 1 - Worst Case Margin Analysis With "End-To-End" Uncertainties

[II

Non- Proprietary Version of the PPL Responses Enclosure 5 to PLA-6 146 Page 5 of 6 Remulatory Commitment (3)

Provide the ASME Load Combination Tables, Based On The 120% OLTP Condition The complete ASME load combination analysis is presented in Section 8 of the "Susquehanna Replacement Steam Dryer Fatigue Analysis", which is provided in .

Re~ulatorv Commitment (4)

Provide a Description Of The Steam Dryer Power Ascension Test Plan PPL will instrument the new Susquehanna Unit 1 steam dryer with various instrumentation at selected high stress locations. As a result, during power ascension, dryer stress intensities will be determined via the direct measurement of subcomponent strains, accelerations, etc. Concurrent data will be obtained from the main steam line strain gauges for comparison to future Unit 2 measurements, which will be obtained during that unit's power ascension testing.

Power will be increased at 2.5% increments and instrument output will be recorded and compared to ASME Code fatigue limits. If any stress intensity

Non- Proprietary Version of the PPL Responses Enclosure 5 to PLA-6 146 Page 6 of 6 above the Code allowable is recorded, power will be decreased to the point where acceptable stresses are maintained, and an engineering evaluation will be performed prior to ascending to the next power level.

In addition, MSIV slow closure testing will be performed at a selected power level to simulate the full 120% OLTP steam flow conditions, and dryer strain gauge data will be collected. This data will be used to confirm the absence of branch line acoustic resonances at the full CPPU steam flows. In addition, this data will provide the bases to allow Unit 2 to proceed to the full CPPU operating conditions.

Finally, PPL will continue to inspect the new steam dryers following each cycle of operation in accordance with the BWRVIP and GE recommendations.

General Electric Company AFFIDAVIT 1, George B. Stramback, state as follows:

(1) I am Manager, Regulatory Services, General Electric Company ("GE") and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.

(2) The information sought to be withheld is contained in Enclosure 1 to GE letter GE-SSE-EP-3 15, Larry King to Mike Gorski (PPL), GE Review of draft PPL letter, PLA-6 146, dated December 21, 2006. The* Enclosure 1 (GE Review of PPL Letter PLA-6146) proprietary information is delineated by a double underline inside double square brackets. Figures and large equation objects are identified with double square brackets before and after the object. In each case, the sidebars and the superscript notation. 3 ) refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.

(3) In making this application for withholding of proprietary information of which it is the owner, GE relies upon the exemption from, disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905,. and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) for "trade secrets" (Exemption 4). The material for which exemption from disclosure is here sought also qualify under, the narrower definition of "trade secret", within the meanings assigned to those terms for purposes of FOJA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission.

975F72d87 1 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704F72d1280 (DC Cir. 1983).

(4) Some examples of categories of information which fit into the definition of proprietary information are:

a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by General Electric's competitors without license from General Electric constitutes a competitive economic 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 reveals aspects of past, present, or future General Electric customer-funded development plans and programs, resulting* in potential products to General Electric; GBS-06-06-af GE-SSES-SEP-315 Suppl Dryer Acceptance Letter PLA-6146 Review 12-21-06.doc AfdvtPg Affidavit Page I
d. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

The inform-ation, sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a., and (4)b, above.

(5) To address 10 CFR 2.390 (b) (4), the information sought, to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GE, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GE, no public disclosure has been. made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.

(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to such documents within GE is limited on a "need to know" basis.

(7) The procedure for a pproval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GE are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

(8) The information identified in paragraph (2), above, is classified as proprietary because it contains details of steam dryer testing and analyses of the design of the Susquehanna BWR Steam Dryer. Development of this information and. its application for the design, procurement and analyses methodologies and processes for the Steam Dryer Program was achieved at a significant cost to GE, on the order of approximately two million dollars.

The development of the dryer performance evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GE asset.

(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GE's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GE's GBS-06-06-af GE-SSES-SEP-315 Suppi Dryer Acceptance Letter PLA-6146 Review 12-21-06.doc AfdvtPg Affidavit Page 2

comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GE.

The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is, difficult to quantify, but it clearly is substantial.

GE's competitive advantage will be lost if its competitors are able to use the results of the GE experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

The value of this information to GE would be lost if the information were disclosed to the public. Making such information available to competitors without their.

having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GE of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing these very valuable analytical tools.

I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.

Executed on this ý dyof I)VC~~~I 06 oeo~g4. Sanback General Electric. Comp~any GBS-06-06-af GE-SSES-SEP-315 Suppl Dryer Acceptance Letter PLA-6146 Review 12-21-06.doc AfdvtPg Affidavit Page 3

General Electric Company AFFIDAVIT 1, George B. Stramback, state as follows:

(1) I am Manager, Regulatory Services, General Electric Company ("GE") and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.

(2) The information sought to be withheld is contained in GE proprietary report GE-NE-O000-0061-0595-P-RO, Susquehanna Replacement Steam Dryer Fatigue Analysis, Class III (GE Proprietary Information), dated December 2006. The proprietary information is delineated by a double underline inside double square brackets.

Figures and large equation objects are identified with double square brackets before and after the object. In each case, the sidebars and the superscript notation {3) refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.

(3) In making this application for withholding of proprietary information of which it is the owner, GE relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) for "trade secrets" (Exemption 4). The material for which exemption from disclosure is here sought also qualifyi under the narrower definition of "trade secret", within the meanings assigned to those terms for purposes of FOJA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission.

975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704172d1280 (DC Cir. 1983).

(4) Some examples of categories of informnation which fit into the definition of proprietary information are:

a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by General Electric's competitors without license from General Electric constitutes a competitive economic 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 reveals aspects of past, present, or future General Electric customer-funded development plans and programs, resulting in potential products to General Electric; GBS-06-06-af Susq Replacement Dryer Fatigue Analysis GE-NE 61-0595-P-RO.doc AfdvtPg Affidavit Page I
d. 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 (4)a., and (4)b, above.

(5) To address 10 CFR 2.390 (b) (4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GE, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GE, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.

(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to such documents within GE is limited on a "need to know" basis.

(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GE are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

(8) The information identified in paragraph (2), above, is classified as proprietary because it contains details of steam dryer fatigue analyses of the design of the replacement Susquehanna BWR Steam Dryer. Development of this information and its application for the design, procurement and analyses methodologies and processes for the Steam Dryer Program was achieved at a significant cost to GE, on the order of approximately two million dollars.

The development of the dryer performance evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GE asset.

(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GE's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GE's GBS-06-06-af Susq Replacement Dryer Fatigue Analysis GE-NE 61-0595-P-RO.doc fiaitPg Page 2 Affidavit

comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GE.

The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.

GE's competitive advantage will be lost if its competitors are able to use the results of the GE experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

The value of this information to GE would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GE of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing these very valuable analytical tools.

I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.

Executed on this ; ýdyof 2006.

GeriRS trmback General Electric Company GBS-06-06-af Susq Replacement Dryer Fatigue Analysis GE-NE 61-0595-P-RO.doc AfdvtPg Affidavit Page 3

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