ML082830073
| ML082830073 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  (NPF-014) |
| Issue date: | 09/26/2008 |
| From: | Mckinney B Susquehanna |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| PLA-6408 | |
| Download: ML082830073 (13) | |
Text
Britt T. McKinney Sr. Vice President & Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.3149 Fax 570.542.1504 btmckinney@pplweb.com one P
SEP 2 6 2008 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop OP l-17 Washington, DC 20555 SUSQUEHANNA STEAM ELECTRIC STATION UNIT 1 OPERATING LICENSE NO. NPF-14 LICENSE CONDITION 2.C. (36) (b) 7 PLA-6408 Docket Nos. 50-387 and 50-388 References.
"Susquehanna Steam Electric Station, Units 1 and 2 - Issuance ofAmendment Regarding the 13-Percent Extended Power Uprate (TAC Nos. MD3309 and MD3310), "dated January 30, 2008.
"Susquehanna Steam Electric Station Unit 1 Operating License No. NPF-14 License Condition 2. C. (36)(b) 7, "dated February 22, 2008.
The purpose of this letter is to provide a written report following the completion of testing of the Susquehanna Unit 1 power ascension up to 3733 MWth (107% CLTP),
which is the interim plateau in achieving the full Extended Power Uprate (EPU) operating conditions. This testing was completed in May 2008. The information contained herein is provided to satisfy the requirements of license condition 2.C.(36)(b)7, per Reference 1, which states:
"PPL shall submit CPPU steam dryer reports to the NRC. Two written reports will be provided to the NRC. These reports will be issued following completion of testing of Unit 1 power ascension to 107% CLTP and 114% CLTP. Each report will include evaluations or corrective actions that were required to assure steam dryer structural integrity. Additionally, they will include relevant data collected at each power step, comparisons to performance criteria (design predictions), and evaluations performed in conjunction with steam dryer structural integrity monitoring." contains the proprietary version of the GE-Hitachi (GEH) "SSES Replacement Dryer Vibration Instrumentation Program NRC Summary Test Report" and the proprietary version of the PPL Susquehanna, LLC (PPL) prepared "Susquehanna Unit 1 EPU Start-Up Main Steam Line Strain Gage and Piping Vibration Summary Test Report."
0 Document Control Desk PLA-6408 The two reports provided in Enclosure 1 contain information obtained during the recent Unit 1 power ascension to the 3733 MWt EPU operating conditions. The report prepared by GEH outlines the response of instrumentation that was installed directly on the dryer.
The GEH report includes the results of dryer-mounted strain gauge trending, which was used as the formal acceptance criteria to assure dryer structural integrity. The PPL report contains main steam line strain gauge trending results, which were used for general monitoring purposes. The PPL report also summarizes the results of piping and component monitoring and walkdowns.
Data from each of these reports will be used to update the maximum calculated stresses and the stress report, as well as to re-establish new main steam line limit curves that will be used as the formal acceptance criteria for future SSES EPU power ascensions. The revised stress report and new limit curves will be provided in the future, as required by Unit 1 License Conditions 2.C.(36)(b)2 & 2.C.(36)(b)4, and Unit 2 License Condition 2.C.(20)(b)2.
During the conduct of the power ascension, the instrumentation installed on the dryer performed adequately. Sufficient data was collected and analyzed to assess and validate the dryer's structural integrity. In addition, comparisons of the "as-measured" instrument response to pre-determined performance criteria (Reference 2) did not identify the need for any corrective actions or structural re-evaluations.
The information contained in Enclosure 1 is proprietary information as defined by 10 CFR 2.390. GEH and PPL, as the owners of the proprietary information, have executed the enclosed affidavits, which identify that the enclosed proprietary information has been handled and classified as proprietary, is customarily held in confidence, and has been withheld from public disclosure. The proprietary information was provided to PPL in a GEH transmittal that is referenced by the affidavit. The proprietary information has been faithfully reproduced in the enclosed information such that the affidavit remains applicable. GEH and PPL hereby request that the enclosed proprietary information be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390 and 9.17.
The header of each page in Enclosure 1 carries the notation "GEH Proprietary Information" or "PPL Proprietary Information." GEH proprietary information is identified by a dotted underline inside double square brackets. ((Tl-s..sentence.is.an
.x.mp..t1e3..I.)) In each case, the superscript notation131 refers to Paragraph (3) of the GEH affidavit, which provides the basis for the proprietary determination. Specific information that is not so marked is not GEH proprietary. PPL proprietary information is identified inside triple brackets. I I IThis sentence is an example. 2 1) ) In each case, the superscript notation{2) refers to Paragraph (2) of the PPL affidavit, which provides the basis for the proprietary determination. Specific information that is not so marked is not PPL proprietary.
-3 Document Control Desk PLA-6408 contains the non-proprietary versions of the GEH "SSES Replacement Dryer Vibration Instrumentation Program NRC Summary Test Report" and the PPL "Susquehanna Unit 1 EPU Start-Up Main Steam Line Strain Gage and Piping Vibration Summary Test Report." Enclosure 3 contains the signed affidavits.
If you have any questions or require additional information, please contact Mr. Duane L. Filchner at (610) 774-7819.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on:
B. T. McKinney - Proprietary Versions of the GEH "SSES Replacement Dryer Vibration Instrumentation Program NRC Summary Test Report" and the PPL "Susquehanna Unit 1 EPU Start-Up Main Steam Line Strain Gage and Piping Vibration Summary Test Report" - Non-Proprietary Versions of the GEH "SSES Replacement Dryer Vibration Instrumentation Program NRC Summary Test Report" and the PPL "Susquehanna Unit 1 EPU Start-Up Main Steam Line Strain Gage and Piping Vibration Summary Test Report" - Affidavits Copy:
NRC Region I Mr. R. R. Janati, DEP/BRP Mr. F. W. Jaxheimer, NRC Sr. Resident Inspector Mr. B. K. Vaidya, NRC Project Manager to PLA-6408 Affidavits
CONFIDENTIAL INFORMATION SUBMITTED UNDER 10 C.F.R. §2.390 AFFIDAVIT OF RICHARD D. PAGODIN I, Richard D. Pagodin General Manager-Nuclear Engineering PPL Susquehanna, LLC, do hereby affirm and state:
- 1. I am authorized to execute this affidavit on behalf of PPL Susque-hanna, LLC (hereinafter referred to as "PPL").
- 2. PPL requests that the information attached and identified by text inside triple brackets (({This sentence is an example.} be withheld from public disclosure under the provisions of 10 C.F.R. 2.390(a)(4).
- 3. The PPL Documents contain confidential commercial information, the disclosure of which would adversely affect PPL.
- 4. This information has been held in confidence by PPL. To the extent that PPL has shared this information with others, it has done so on a confidential basis.
- 5. PPL customarily keeps such information in confidence and there is a rational basis for holding such information in confidence.
The information is not available from public sources and could not be gathered readily from other publicly available information.
- 6. Public disclosure of this information would cause substantial harm to the competitive position of PPL, because such information has significant commercial value to PPL.
- 7.
The information identified in paragraph (2) above is classified as proprietary because it details the results of test data derived from test instrumentation installed specifically to collect this data. This instrumentation was installed at a significant cost to PPL. The data and the conditions under which it was collected constitute a major PPL asset.
- 8.
Public disclosure of the information sought to be withheld is likely to cause substantial harm to PPL by foreclosing or reducing the availability of profit-making opportunities. The information is of value to other BWR Licensee's and would support evaluations and analyses associated with extended power uprate license amendment submittals. Making this information available to other BWR Licensee's would represent a windfall and deprive PPL the opportunity to recover a portion of its large investment in the test instrumentation from which this data is derived. PPL SUSQUEHANNA, LLC Richard D. Pagodin Subscribed and sworn before me, a Notary Public in and for the Commonwealth of Pennsylvania This 6Aiday of *u ,4 2008 COMMONWEALTH OF PENNSYLVANIA Notarial Seal Pamela M. Vincent, Notary PublIc Sugarloaf Twp., Columbia County My Commission Expires May 31, 2010 Member, Pennsylvania Association of Notaries
GE Hitachi Nuclear Energy Americas LLC AFFIDAVIT I, Tim Abney, state as follows: (1) I am Vice President, Services Licensing, Regulatory Affairs, GE-Hitachi Nuclear Energy-Americas LLC ("GEH"). I 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 GEH proprietary report, GE-NE-0000-0085-2413-P-RO, Susquehanna Unit 1 Replacement Steam Dryer Vibration Instrumentation Program NRC Summary Test Report, Revision 0, Class III (GEH Proprietary Information), July 2008. GEH proprietary information is identified by a dotted underline inside double square brackets ((Tbji.ssentence is an example. 31)). In each case, 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 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 Project v. Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704F2d1280 (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 GEH's competitors without license from GEH 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 GEH customer-funded development plans and programs, resulting in potential products to GEH;
- 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. Af GE-NE-0000-0085-2413-P-RO, Sus Dryer Inst Program Summary Test Report 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 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, 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 information identified in paragraph (2) above is classified as proprietary because it contains results and details of structural analysis methods 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 GEH, on the order of approximately several million dollars. The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GEH asset. (9) Public disclosure of the information sought to be withheld 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 determine and apply Af GE-NE-0000-0085-2413-P-RO, Sus Dryer Inst Program Summary Test Report Affidavit Page 2 of 3
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 GEH. 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 demonstrating that they can arrive at the same or similar conclusions. The value of this information to GEH 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 GEH of the opportunity to exercise its competitive advantage to seek an adequate return on its 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, information, and belief. Executed on this 1 8th day of July 2008. Tim E. Abney Vice President, Services Licensing GE-Hitachi Nuclear Energy Americas LLC Af GE-NE-0000-0085-2413-P-RO, Sus Dryer Inst Program Summary Test Report Affidavit Page 3 of 3
GE Hitachi Nuclear Energy Americas LLC AFFIDAVIT I, Tim E. Abney, state as follows: (1) I am Vice President, Services Licensing, Regulatory Affairs, GE-Hitachi Nuclear Energy-Americas LLC ("GEH"). I 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 PPL report, Susquehanna Unit JEPU Start-Up Main Steam Line Strain Gage And Piping Vibration Summary Test Report, August 2008, Revision 0. GEH proprietary information is identified by a dotted underline inside double square brackets ((TIhia..I*n[. n~9.J. tpJ.9 i)). In each case, 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 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 Project v. Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704F2d1280 (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 GEH's competitors without license from GEH 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 GEH customer-funded development plans and programs, resulting in potential products to GEH;
- 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. Af Susq Dryer FIV Report.doc 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 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, 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 information identified in paragraph (2) above is classified as proprietary because it contains results and details of structural analysis methods 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 GEH, on the order of approximately several million dollars. The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GEH asset. (9) Public disclosure of the information sought to be withheld 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 determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods. Af Susq Dryer FIV Report.doc Affidavit Page 2 of 3
The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GEH. 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 demonstrating that they can arrive at the same or similar conclusions. The value of this information to GEH 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 GEH of the opportunity to exercise its competitive advantage to seek an adequate return on its 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, information, and belief. Executed on this 16th day of September 2008. Tim E. Abney Vice President Services Licensing GE-Hitachi Nuclear Energy Americas LLC Af Susq Dryer FIV Report.doc Affidavit Page 3 of 3 to PLA-6408 NON-PROPRIETARY VERSIONS GEH "SSES Replacement Dryer Vibration Instrumentation Program NRC Summary Test Report" and PPL "Susquehanna Unit 1 EPU Start-Up Main Steam Line Strain Gage and Piping Vibration Summary Test Report"}}