PLA-6255, Proposed License Amendments 285 and 253, Constant Pressure Power Uprate Application Regarding Steam Dryer Flow Effects Verbal and Confirmatory Requests for Additional Information Responses

Proposed License Amendments 285 and 253, Constant Pressure Power Uprate Application Regarding Steam Dryer Flow Effects Verbal and Confirmatory Requests for Additional Information Responses

ML072340597
Person / Time
Site:	Susquehanna
Issue date:	08/13/2007
From:	Mckinney B Susquehanna
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PLA-6255
Download: ML072340597 (22)

Text

Butft T. McKinney PPL Susquehanna, LLC Sr. Vice President & Chief Nuclear Officer 769 Salem Boulevard Berwick, PA 18603 AUG 1 3 2007 Tel. 570.542.3149 Fax 570.542.1504 btmckinney@pplweb.com PI 3 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop OP1I- 17 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION PROPOSED LICENSE AMENDMENT NO. 285 FOR UNIT 1 OPERATING LICENSE NO. NPF-14 AND PROPOSED LICENSE AMENDMENT NO. 253 FOR UNIT 2 OPERATING LICENSE NO. NPF-22 CONSTANT PRESSURE POWER UPRATE APPLICATION REGARDING STEAM DRYER FLOW EFFECTS VERBAL AND CONFIRMATORY REQUESTS FOR ADDITIONAL INFORMATION RESPONSES Docket Nos. 50-387 PLA-6255 and 50-388 References.- 1) PPL Letter PLA -6076, B. T' McKinney (PPL) to USNRC, 'ProposedLicense Amendment Numbers 285 for Unit I OperatingLicense No. NPF-14 and 253 for Unit 2 Operating License No. NPF-22 Constant PressurePower Uprate, - dated October 1], 2006.

2) PPL Letter PLA-61 76, B. T' McKinney (PPL) to USNRC, "Proposed License Amendment No. 285 for Unit I OperatingLicense No. NPF-14 and ProposedLicense Amnendmnent No. 253 for Unit 2 Operating License No. NPF-22 Extended Power Update Application Regarding Steamn Dryer and Flow Effects Request for Additional Information Responses, "dated April 2 7, 2'007.

3,) PPL Letter PLA-623 7, B. Ti McKinne~v (PPL,) to USNRC, "ProposedLicense Amendmnent No. 285 for Un it I Operating L icense No. NPF-14 and ProposedL icense Amnendmnent No. 253 for Unit 2 Operating License No. NPF-22 Constant Pressure Power Uprate -

Supplemzent, "dated July 6, 2007.

4,) PPL Letter PLA-6242, B. Ti McKinney (PPL) to USNRC, "ProposedLicense Amendment No. 285.for Unit I Operating License No. NPF-14 and ProposedLicense Amendment No. 253 for Unit 2 Operating License No. NPF-22 Extended Power Uprate Application Regarding Steam Dryer and Flow Effects Request ForAdditional Informnation Responses, "dated July 31, 2007.

Pursuant to 10 CFR 50.90, PPL Susquehanna LLC (PPL) requested in Reference 1 approval of amendments to the Susquehanna Steam Electric Station (SSES) Unit 1 and Unit 2 Operating Licenses (OLs) and Technical Specifications (TS) to increase the maximum power level authorized from 3489 megawatts thermal (MWt) to 3952 MWt, an approximate 13% increase in thermal power. The proposed Constant Pressure Power Uprate (CPPU) represents an increase of approximately 20% above the Original Licensed Thermal Power (OLTP).

p-01

Document Control Desk PLA-6255 The purpose of this letter is to provide responses to the NRC Staffs verbal and confirmatory Requests for Additional Information (RAls). The responses contained herein are intended to provide supplemental information to References 2 through 4.

Attachment I contains the PPL responses.

The PPL responses in Attachment 1 contain information that GE - Hitachi Nuclear Energy Americas, LLC considers proprietary. GE - Hitachi Nuclear Energy Americas, LLC requests that the proprietary information be withheld from public disclosure in accordance with 10 CFR 2.390 (a) 4 and 9.17 (a) 4. An affidavit supporting this request is provided in Attachment 3. A non-proprietary version of Attachment 1 is provided in .

There are no new regulatory commitments associated with this submittal.

PPL has reviewed the "No Significant Hazards Consideration" and the "Environmental Consideration" submitted with Reference 1 relative to the Enclosure. We have determined that there are no changes required to either of these documents.

If you have any questions or require additional information, please contact Mr. Michael H. Crowthers at (610) 774-7766.

1 declare under perjury that the foregoing is true and correct.

Executed on: ~~

B. T. McKinney : Proprietary Version of the Request for Additional Information Responses : Non-Proprietary Version of the Request for Additional Information Responses Attachnment 3: GE-Hitachi Nuclear Energy Americas, LLC Affidavit Copy: NRC Region I Mr. R. V. Guzman, NRC Sr. Project Manager Mr. R. R. Janati, DEP/BRP Mr. F. W. Jaxheimer, NRC Sr. Resident Inspector

Attachment 2 to PLA-6255 Non-Proprietary Version of the Request for Additional Information Responses

Non-Proprietary Version of the PPL Responses Attachment 2 to PLA-6255 Page 1 of 15 NRC Verbal Question 1:

In Table 6-1 in the GE report (GE-NE-OOOO-0061-0595-P-R1), [

))This justification is not clear.

(a) Figure 6-24 in the report shows [

(b) What is the miaximnum stress intensity for the tie-rod and at which location it is acting?

(c) In Section 6.4 of the report, it is stated, It is not clear-why [

)) Please explain.

Non-Proprietary Version of the PPL Responses Attachment 2 to PLA-6255 Page 2 of 15 PPL Response 1:

1(a) The Staff asked that justification be provided forEl Figure 1.a.1 below[I More important, as stated in GE-NE-0000-006 1-0595-P-Ri (Reference 3):

))See RAI Response 6(a) of PLA-6242 dated July 31, 2007 (Reference 4). ((

Non-Proprietary Version of the PPL Responses Attachment 2 to PLA-6255 Page 3 of 15 1]

1(b) ((

I(C) ((

Non-Proprietary Version of the PPL Responses Attachment 2 to PLA-6255 Page 4 of 15

))

Figure 1.a.1

Non-Proprietary Version of the PPL Responses Attachm-ent 2 to PLA-6255 Page 5 of 15 Figure 1.b.1I 11 Figure 1.b.2 11

Non-Proprietary Version of the PPL Responses Attachment 2 to PLA-6255 Page 6 of 15 11l Figure 1.b.3

Non-Propriet~ary Version of the PPL Responses Attachment 2 to PLA-6255 Page 7 of 15 11l Figure 1.b.4

Non-Proprietary Version of the PPL Responses Attachment 2 to PLA-6255 Page 8 of 15 NRC Verbal Ouestion 2:

During the public meeting on June 29, 2007, I (a) In Figure 6-28, as-built geometry of skirt wall and lower skirt ring is shown. In addition, corresponding finite element model is shown. Please explain l (b) Figure 6-29 shows the submodel geometry and mesh for the split-end region of the skirt. Provide a corresponding as-built sketch of that region of the skirt. Please explain the differences between the as-built geometry sketch and the finite element model.

PPL Response 2:

Geometric and material property differences between the steam dryer model used in GE-NE-0000-0061-0595-P-Rl (Reference 3) and the as built/design configuration of the replacement steam dryer are contained in the response to RAI 6(a) of PLA-6242 dated July 31, 2007 (Reference 4). GEH considers that the analysis presented in GE-NE-OO00-0061-0595-P-Rl (Reference 3) adequately bounds the as-built/designed configuration of the Susquehanna steam dryer and that the additional improvements identified in the response to RAI 6(a) of PLA-6242 will lead to a final dryer design with additional fatigue margin to that reported in GE-NE-0000-0061-0595-P-R I (Reference 3).

Additional design improvements are being incorporated into the replacement dryer that increase the margin to structural Ilimnits and reduce the susceptibility to stress corrosion cracking. Ini a complex welded structure, such as the dryer, any component or geometric change will change the dryer's dynamnic characteristics. As explained in the response to RAI 6(a) of PLA-6242, all fabrication improvements have been and will continue to be evaluated with detailed finite element modeling and full dryer analyses to ensure they

Non-Proprietary Version of the PPL Responses Attachment 2 to PLA-6255 Page 9 of 15 increase the fatigue design margin. The dryer will be dynamically tested and the finite element model and associated modeling assumptions benchmarked against the measured response. Finally the replacement dryer will be instrumented with pressure transmitters, accelerometers and strain gages to allow benchmarking of dynamic load definitions and the structural analysis modeling.

The following components in the replacement steam dryer are solution annealed to minimize residual stresses from fabrication:

Non-Proprietary Version of the PPL Responses Attachment 2 to PLA-6255 Page 10 of 15 PPL Response 2(a):

This issue has been addressed in RAI response 6(a) of PLA-6242 (Reference 4), which is reiterated below:

Er

Non-Proprietary Version of the PPL Responses Attachment 2 to PLA-6255 Page I1I of 15 PPL Response 2(b):

Figure 2.b. 1 below is a sketch of the original steam dryer split-end region of the skirt.

Figure 2.b.1I Er

Non-Proprietary Version of the PPL Responses Attachment 2 to PLA-6255 Page 12 of 15 11l Figure 2.b.2

Non-Proprietary Version of the PPL Responses Attachment 2 to PLA-6255 Page 13 of 15 NRC Confirmatory Question 1 In RAI 26 PPL was asked to provide natural frequencies of the dryer components and the pumnp vane passing frequency at 120% OLTP. If any component experiences a resonance with the pump vane passing frequency, PPL was asked to explain how the resulting stresses are accounted for in the fatigue evaluation of that component. PPL responds to RAI 26 in Attachment 1 to a letter (PLA-6 167) from B. T. McKinney (PPL) to NRC dated 4/27/2007. In its response, PPL shows images of several dryer modes that might be excited by the recirculation pump vane passing frequency. Since any of these modes mig ht be excited., PPL proposes to[I (a) Please explain how and when the proposed forcing function would be developed.

(b) When would the corresponding fatigue evaluation be performed and the results be submitted for the staff review?

PPL Response I (a) The response to RAI 5 contained in PLA-6 176 (Reference 2) provides a description of the instrumentation which will be installed on the new Unit 1 steam dryer for the first two CPPU steps. RAI 5 states:

11 .

Non-Proprietary Version of the PPL Responses Attachment 2 to PLA-6255 Page 14 of 15 The increased core flow (ICF.) mode of operation was not approved for Susquehanna SES until 1993. Therefore, the 1985 in-plant steam dryer test data does not contain dryer acceleration data in the 100 Mlbm,/hr to 108 Mlb,,,/hr core flow range. As noted in the PATP also contained in Reference 2, steam dryer vibration measurements will be taken at ICF conditions up to 108 Mlb ... /hr at the 107% CLTP power level. Additional dryer acceleration data from vane passing frequencies at these core flows must be obtained to provide a complete analysis.

(b) The fatigue evaluation will be performed as part of the steam dryer reanalysis following the first two CPPU steps on Unit 1. That data will be forwarded to the staff for review in accordance with the Unit 1 proposed license condition 2.d contained in PLA-6242 (Reference 4).

Non-Proprietary Version of the PPL Responses Attachment 2 to PLA-6255 Page 15 of 15 NRC Confirmatory Question 2 Please confirm whether the correct boundary conditions were used in the steam dryer fatigue analysis presented in GENE-0000-0057-4166-RI-P, Rev. 1, "Susquehanna Steam Dryer Fatigue Analysis," September 2006. If not, please explain how the use of correct boundary conditions would affect the determination of the stress under-prediction factor.

PPL Response 2 The steam dryer fatigue analysis presented in GENE-0000-0057-4166-R1-P, Rev. 1 did not use the correct boundary conditions for the steam dryer support brackets. As part of the GEH actions to correct the dryer boundary conditions, the Original Licensgd Thermal Power (OLTP) benchmark analysis for the original dryer presented in GENE-0000-0057-4166-R1I-P,.Rev. 1 was reanalyzed with the corrected boundary conditions and the stress under-prediction factor was recalculated. The finite element model used in GENE-0000-0057-4166-RlI-P, Rev. 1.was based on the current Susquehanna dryer configuration with reinforcing straps on each of the four middle bank corners. As part of the reanalysis to correct the boundary conditions, the strap was removed on the end of the bank where strain gauge S6 was located in 1985. This configuration matched the bank as it was for the 1985 measurements and allowed the comparison of the S6 predicted/measured response to be included along with S4 and S5 in the reanalysis of the stress under-prediction factor. The change in the boundary conditions did change the predicted strain response for S4 and S5. However, when using the same methodology as w .as used in GENE-0000-0057-4166-RI-P, Rev. 1 and including the comparison for S6, the corrected stress under-prediction factor remained unchanged at (( )). Therefore, the original stress under-prediction factor of (( )) remains applicable to the revised Susquehanna dryer analyses which was provided to the NRC in Reference 3.

Attachment 3 to PLA-6255 GE-Hitachi Nuclear Energy Americas, LLC Affidavit

GE-Hitachi Nuclear Energy Americas LLC AFFIDAVIT 1, Tim E. Abney, state as follows:

(1) 1 am Project Manager, Services Licensing, Regulatory Affairs GE-Hitachi Nuclear Energy Americas LLC ("GEH"), 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 Attachment I to PPL Susquehanna letter PLA-6255 to the U. S. Nuclear Regulatory Commission.

The proprietary information is delineated by a ((do-t-ted --u-nderl--ine ins-i-de ..d-ouble sýquareý br-acket-s.__'-)) Figures and large equation objects are identified with double square brackets before and after the object. In each case, the superscript notation 13 refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.

(3) In making this application for withhAolding of proprietary information of which it is the owner or licensee, GEH 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 FOIA Exemption 4 in., respectively, Critical Mass Energy Proiect v. Nuclear Regulatory Commission, 975F2d87l (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704F2d 1280 (DC Cir. 1983).

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

a. Informnation that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GEH's competitors without license from GEl- 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. Inform-ation which reveals aspects of past, present, or future GEH customer-funded

• development plans and programs, resulting in potential products to GEH;

d. Inform-a tion 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 thle reasons set forth in paragraphs (4)a. and (4)b. above.

Affidavit Page I of 3

(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 GEH, 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 GEH, 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 informnation 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, or subject to the terms under which it was licensed to GEH. Access to such documents within GEH 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 for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GEH 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 infonination identified in paragraph (2) above is classified as proprietary because it contains results and details of analysis inethods and techniques developed by GEH for evaluations of a BWR Steam Dryer and of other reactor internals, including separators.

Development of these methods, techniques, and information and their application for the design, modification, and analyses methodologies and processes for the Steam. Dryer Program and to the design and manufacturing of other BWR internal hardware was achieved at a significant cost to GHNEA, on the order of approximately several million dollars.

(9) Public disclosure of the information sought to be withhield is likely to cause substantial harm to GEH's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GEH's 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 determnine and apply the appropriate evaluation process. In addition, the technology base includes the value derived fromn 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 GEH.

Affidavit Page 2 of 3

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.

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

The value of this inforination to GEH would be lost if the infonri-ation 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 GEH of the opportunity to exercise its competitive advantage to seek an adequate return on i ts large investment in developing and obtaining 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, informnation, and belief.

Executed on this 8t day of August, 2007.

Tim E. Abney GE-Hitachi*Nuclear EnergyN Americas LLC Affidavit Page 3 of 3