ML090770448
| ML090770448 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 02/27/2009 |
| From: | GE-Hitachi Nuclear Energy Americas |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| DRF 0000-0094-9796, PLA-6484 0000-0096-5766-NP-R1 | |
| Download: ML090770448 (64) | |
Text
Enclosure 6 to PLA-6484 Non PROPRIETARY VERSION "Revised Susquehanna Replacement Steam Dryer Limit Curves -
Main Steam Line Mounted Instrumentation."
HITACHI GE Hitachi Nuclear Energy 3901 Castle Hayne Rd Wilmington, NC 28401 Non-Proprietary Version 0000-0096-5766-NP-Ri DRF 0000-0094-9796 Class I February 2009 Engineering Report Revised Susquehanna Replacement Steam Dryer Limit Curves - Main Steam Line Mounted Instrumentation
0000-0096-5766-NP-Ri NON-PROPRIETARY VERSION IMPORTANT NOTICE REGARDING THE CONTENTS OF THIS REPORT Please Read Carefully NON-PROPRIETARY NOTICE This is a non-proprietary version of the document 0000-0096-5766-P-Ri, 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 ((
IMPORTANT NOTICE REGARDING CONTENTS OF THIS REPORT Please Read Carefully The only undertakings of the GE Hitachi Nuclear Energy (GEH) respecting information in this document are contained in the contract between the company receiving this document and GEH.
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 GEH 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, GEH makes no representation or warranty, and assumes no liability as to the completeness, accuracy or usefulness of the information contained in this document, or that its use may not infringe privately owned rights i
0000-0096-5766-NP-Ri NON-PROPRIETARY VERSION REVISION
SUMMARY
Rev..Changes'Ih'corpofated in Curent Reisioni 0
Initial Issue 1
Figures 2 and 3 revised ii
0000-0096-5766-NP-R I NON-PROPRIETARY VERSION TABLE OF CONTENTS Section Page
- 1.
EX ECU TIV E SU M M A R Y.............................................................................................
1
- 2.
BASIS FOR DEFINING THE SUSQUEHANNA MSL LIMIT CURVES................ 2 2.1
((
)) BIAS AND UNCERTAINTY.2
- 3.
REVISED STRESS FREQUENCY FACTORS........................................................
10
- 4.
APPLICABILITY OF LIMIT CURVES TO SSES UNIT 2.....................................
15
- 5.
LIMIT CURVES FOR MSL MOUNTED STRAIN GAGE INSTRUMENTATION... 18
- 6.
C O N C LU SIO N S.......................................................................................................
19
- 7.
R EFERE N C E S.........................................................................................................
20 iii
0000-0096-5766-NP-RI NON-PROPRIETARY VERSION List of Tables Table I
((
)) Data Statistics.....................................................
5 Table 2
((
)) Data Statistics...........................................
6 Table 3
((
))7 Table 4a
((
]J for the Upper Dryer.......................................................
9 Table 4b
((
)) for the Lower Dryer.......................................................
9 Table 5 Limit Curve Factor Calculation- ((
]........ 13 Table 6 Limit Curve Factors ((.....................................
14 iv
0000-0096-5766-NP-RI NON-PROPRIETARY VERSION List of Figures Figure I a
[.........................
21 Figure lb ((...........................
22 Figure Ic
((
11......................... 23 Figure Id
((
............................ 24 Figure le
((
.......................... 25 Figure If
((
))...................
26 Figure Ig
((
27 Figure lIh
[
))........................ 28 Figure Ii
((
]......................
29 Figure lj
((
))....................
30 Figure 2 MSL Strain Gauge Comparison - MSL A-Upper.................................................
31 Figure 3 MSL Strain Gauge Comparison - MSL A-Lower.................................................
32 Figure 4 Limit Curve for Line A-Upper.............................................................................
33 Figure 5 Limit Curve for Line A-Lower.............................................................................
34 Figure 6 Limit Curve for Line B-Upper.............................................................................
35 Figure 7 Limit Curve for Line B-Lower.............................................................................
37 Figure 8 Limit Curve for Line C-Upper.............................................................................
38 Figure 9 Limit Curve for Line C-Lower.............................................................................
39 Figure 10 Limit Curve for Line D-Upper.............................................................................
40 Figure I I Limit Curve for Line D-Lower.............................................................................
41 v
0000-0096-5766-NP-R I NON-PROPRIETARY VERSION ACRONYMS AND ABBREVIATIONS Item Short Form Description I
ACM Acoustic Circuit Model 2
ASME American Society of Mechanical Engineers 3
EPU Extended Power Uprate Power, 3952 MWt 4
FE Finite Element 5
GEH GE Hitachi Nuclear Energy 6
Hz Hertz 7
LCF Limit Curve Factor 8
MSIV Main Steam Isolation Valve 9
MSL Main Steam Line 10 MWt Megawatt Thermal I 1 NRC Nuclear Regulatory Commission 12 OLTP Original Licensed Thermal Power, 3293 MWt 13 PPL PPL Susquehanna, LLC 14 PSD Power Spectral Density 15 Psi Pounds per square inch 16 RMS Root-Mean-Squared 17 S/RV Safety/Relief Valve 18 SG Strain Gage 19 SRSS Square Root Sum of Squares 20 SSES Susquehanna Steam Electric Station 21 Stdev Standard Deviation 22 SUPF Stress Under Prediction Factor 23 TC Test Condition 24 VPF Vane Passing Frequency vi
0000-0096-5766-P-RI NON-PROPRIETARY VERSION
- 1. EXECUTIVE
SUMMARY
As part of the Susquehanna Steam Electric Station (SSES) license for Extended Power Uprate (EPU), PPL is required to provide the Main Steam Line (MSL) limit curves to the Nuclear Regulatory Commision 90 days prior to operating above 3489 MWt. On-dryer instrumentation data measured on the Susquehanna Unit I replacement dryer became available after May 2008.
These on-dryer instrumentation data were used to develop the limit curve factor for Unit 1.
Baseline curves for Unit I were developed from Unit 1 MSL strain gage measurements.
Limit curves for Unit 1 were then developed from scaling the baseline curves by the limit curve factor.
MSL strain gage measurements were compared between Unit I and Unit 2. The
))
The two SSES units are similar in design and operating conditions; therefore it is expected that the pressure loading on the steam dryer will be similar. The Unit 2 MSL strain gauge measurements are very similar to those for Unit 1. Therefore, the Unit I limit curves provided are applicable for use at Unit 2 as well.
Figures 4 through I I provide the updated limit curves. These figures include the Level I and Level 2 limit curves for the eight strain gage MSL monitoring locations on SSES Unit 1. Assuring that the Level I acceptance limits are met will minimize the potential for fatigue damage to the PPL replacement dryer. If a measurement exceeds the Level 1 criteria, a reduction in power to the previously acceptable power level is required. If a measurement exceeds the Level 2 criteria, the plant shall hold at the current power level and re-evaluate the dryer loading and structural response.
PPL will monitor the main steam line (MSL) strain gauges during power ascension testing above 3489 MWt (Unit 2) and 3733 MWt (Unit I) for increasing pressure fluctuations in the steam lines along with reactor pressure vessel water level instrumentation and MSL piping accelerometers. If resonance frequencies are identified as increasing above nominal levels PPL will stop power ascension and re-evaluate the dryer loading and structural response.
0000-0096-5766-NP-R I NON-PROPRIETARY VERSION
- 2. BASIS FOR DEFINING THE SUSQUEHANNA MSL LIMIT CURVES GEH developed revised MSL limit curves in March 2008 [1] based on the as-built dryer stress analysis [2] for the purpose of monitoring the MSL strain gage response during the SSES Unit I EPU power ascension from 3489 MWt (Pre-EPU licensed thermal power) through 3733 MWt (94.4% EPU). For this first EPU power ascension step, dryer monitoring and conformance with the acceptance criteria were based on the measured strain response of on-dryer instrumentation [3]. During the SSES Unit 1 power ascension in 2008, both MSL strain gage data and on-dryer strain and pressure data were gathered, which allow the development of revised MSL limit curves based on MSL strain gage measurements from partial EPU testing and ((
2.1 I
11 BIAS AND UNCERTAINTY Reference 4 provides the results of the SSES Unit I power ascension testing for the replacement steam dryer through the first two power ascension steps to a core power of ((
)) In addition, at each test condition, PPL gathered data from the MSL strain gage instrumentation that was synchronous with the on-dryer data.
GEH performed an evaluation of the instrumented steam dryer data to perform an update of the Reference 2 stress report, the update of which is contained in Reference 5.
2
0000-0096-5766-NP-Ri NON-PROPRIETARY VERSION
]1 In the previous limit curve development [1], ((
1]
The SSES Unit I replacement dryer was ((
3
0000-0096-5766-NP-R I NON-PROPRIETARY VERSION A baseline curve for the MSL limit curves was developed from the raw steam line data from the MSL testing at ((
)) Consistent with the previous MSL limit curve report [1], ((
4
0000-0096-5766-NP-Ri NON-PROPRIETARY VERSION 1]
which is consistent with the previous MSL baseline curve development [1].
Table I provides a summary of ((
11
]1Data Statistics Table 1 1[
1]
Consistent with Reference 1, ((
Cs Consistent with the Reference I assessment, the data in Table 2 ((
5
0000-0096-5766-NP-RI NON-PROPRIETARY VERSION Table 2
((
)) Data Statistics
))
Table 3 summarizes a comparison of ((
)) The lower row in
)) from Table 2.
The Table 3 provides ((
))
In Reference 1, these ((
)) shown in Table 3. Therefore in this assessment, ((
1]
6
0000-0096-5766-NP-RI Table 3 It NON-PROPRIETARY VERSION 11 1]
In order to address the ((
11 Figures la through lj provide ((
7
0000-0096-5766-NP-Ri NON-PROPRIETARY VERSION In Reference 3, ((
1]
8
0000-0096-5766-NP-Ri NON-PROPRIETARY VERSION Table 4a
[I 1] for the Upper Dryer II T]
Table 4b
((
II for the Lower Dryer It 9
0000-0096-5766-NP-Ri NON-PROPRIETARY VERSION
- 3. REVISED STRESS FREQUENCY FACTORS The stress results from the GEH finite element stress analysis of the as-fabricated dryer [2] were used in developing the MSL limit curves. ((
)) to the 13,600 endurance limit after application of the stress under prediction (SUPF) and EPU factors.
In order to address the ((
1]
The peak stress values for the ((
are presented in Table 3-1 of Reference 2.
The Level 1 limit curves were developed by ((
1]
)) The Level 2 limit curves were developed using the same approach ((
10
0000-0096-5766-NP-Ri NON-PROPRIETARY VERSION The time history stress data from the ((
1]
11
0000-0096-5766-NP-R I The LCF I factor, ((
NON-PROPRIETARY VERSION The previous limit curve factor developed in Reference I was ((
12
0000-0096-5766-NP-Ri NON-PROPRIETARY VERSION Table 5 Limit Curve Factor Calculation-ff I!
13
0000-0096-5766-NP-R I NON-PROPRIETARY VERSION Table 6 Limit Curve Factors ((
))
))
14
0000-0096-5766-NP-RI NON-PROPRIETARY VERSION
- 4.
APPLICABILITY OF LIMIT CURVES TO SSES UNIT 2.
The MSL limit curves developed in Section 3 are based on the measurements taken during the power ascension at Susquehanna Unit 1. These limit curves will also be applied to Unit 2 to monitor the power ascension to full EPU operation.
SSES Units I and 2 are both 25 1-inch BWR/4 reactors in Mark II containments.
The reactor and containment geometry and operating conditions are essentially the same for the two units. ((
I]
All four MSLs on each unit were instrumented with strain gauges in order to measure the acoustic pressures within the steamlines.
Each steamline was instrumented near the top and the bottom of the vertical riser. Four strain gauges were used at each measurement location. The MSL strain gage measurements 15
0000-0096-5766-NP-Ri NON-PROPRIETARY VERSION were compared between Unit 1 and Unit 2. ((
)) Figures 2 and 3 The MSL measurements for both Unit I and Unit 2 ((
)) show that the significant pressure loading occurs in the low frequency range. The replacement dryer was designed ((
))
The limit curve factors and limit curves in Sections 2 and 3 were developed
((I
)) As discussed above, the reactor operating conditions and reactor geometry are the same for the two units. A comparison of the Unit t and Unit 2 16
0000-0096-5766-NP-Ri NON-PROPRIETARY VERSION MSL geometry found no significant difference that would lead to a substantially different pressure loading on the Unit 2 steam dryer. The MSL measurements for both Unit I and Unit 2 as well as ((
))
show that the significant pressure loading occurs in the low frequency range. The MSL measurements show that the frequency content in the pressure loading is similar between the two units. Because of the similarity in the expected pressure loading between the two units, the Unit 1 limit curves provided are applicable for use at Unit 2 as well.
17
0000-0096-5766-NP-RI NON-PROPRIETARY VERSION
- 5. LIMIT CURVES FOR MSL MOUNTED STRAIN GAGE INSTRUMENTATION Figures 4 through 11 show the revised Level 1 and Level 2 limit curves based on
((
)) and MSL measurements taken at Unit I through the first power ascension step to a power level of ((
))
These figures also include the baseline curves used in the development of the limit curves. The filtered and unfiltered strain gage test data at ((
))
is included to illustrate the noise filtered from the raw MSL measurements.
The limit curves are based ((
I]
18
0000-0096-5766-NP-Ri NON-PROPRIETARY VERSION
- 6. CONCLUSIONS Revised Level I and Level 2 MSL limit curves have been developed based on an evaluation of the on-dryer and MSL measurements taken at Unit I through the first two power ascension steps to a power level of ((
)) MSL strain gage measurements were compared between Unit I and Unit 2. ((
1))
The two SSES units are similar in design and operating conditions; therefore it is expected that the pressure loading on the steam dryer will be similar. Therefore, the Unit 1 limit curves provided are applicable for use at Unit 2 as well.
Assuring that the Level I acceptance limits are met will minimize the potential for fatigue damage to the PPL replacement dryer. If a measurement exceeds the Level I criteria, a reduction in power to the previously acceptable power level is required. If a measurement exceeds the Level 2 criteria, the plant shall hold at the current power level and re-evaluate the dryer loading and structural response.
PPL will monitor the main steam line (MSL) strain gauges during power ascension testing above 3489 MWt (Unit 2) and 3733 MWt (Unit 1) for increasing pressure fluctuations in the steam lines along with reactor pressure vessel water level instrumentation and MSL piping accelerometers. If resonance frequencies are identified as increasing above nominal levels PPL will stop power ascension and re-evaluate the dryer loading and structural response.
19
0000-0096-5766-NP-RI NON-PROPRIETARY VERSION
- 7. REFERENCES
[1] "Susquehanna Replacement Steam Dryer Limit Curves - Main Steam Line Mounted Instrumentation", GE-NE-0000-0080-8732-P-RO, March 2008.
[2] "Susquehanna Replacement Steam Dryer Stress Analysis at Extended Power Uprate Conditions", GE-NE-0000-0079-2250-P-RO, January 2008
[3] "Susquehanna Replacement Steam Dryer Instrumentation Acceptance Criteria Dryer Mounted Instrumentation," GE-NE-0000-0080-2994-P-R4, April 2008.
[4] "Susquehanna Unit I Replacement Steam Dryer Vibration Instrumentation Program NRC Summary," GE-NE-0000-0085-2413-P-RO, July 2008.
[5] "Susquehanna Replacement Steam Dryer Updated Stress Analysis at Extended Power Uprate Conditions," 0000-0095-2113-P-RO, February 2009.
[6] "Susquehanna-I Steam Dryer Vibration Steady State and Transient Response
- Final Report," MDE #199-0985-P, Revision 1, January 1986.
20
0000-0096-5766-NP-R I NON-PROPRIETARY VERSION Figure la 11 I!
(Green Measured, Blue FE Model) 21
0000-0096-5766-NP-R I NON-PROPRIETARY VERSION 1]
Figure lb 1[
iI (Green Measured, Blue FE Model) 22
0000-0096-5766-NP-RI NON-PROPRIETARY VERSION I1 Figure Ic f[
11 (Green Measured, Blue FE Model) 23
0000-0096-5766-NP-RI NON-PROPRIETARY VERSION It Figure ld 11 1i (Green Measured, Blue FE Model) 24
0000-0096-5766-NP-RI NON-PROPRIETARY VERSION 11 1]
Figure le 1l I!
(Green Measured, Blue FE Model) 25
0000-0096-5766-NP-R I NON-PROPRIETARY VERSION
!i Figure if 1[
11 (Green Measured, Blue FE Model) 26
0000-0096-5766-NP-RI NON-PROPRIETARY VERSION i I Figurelg 1
!1 (Green Measured, Blue FE Model) 27
0000-0096-5766-NP-RI NON-PROPRIETARY VERSION If Figure 1h II I!1 (Green Measured, Blue FE Model) 28
0000-0096-5766-NP-RI NON-PROPRIETARY VERSION It 1]
Figure li II I1 (Green Measured, Blue FE Model) 29
0000-0096-5766-NP-RI NON-PROPRIETARY VERSION 11 Figure lj 11 Ii (Green Measured, Blue FE Model) 30
0000-0096-5766-NP-RI NON-PROPRIETARY VERSION Figure 2 MSL Strain Gauge Comparison - MSL A-Upper 31
0000-0096-5766-NP-RI NON-PROPRIETARY VERSION Figure 3 MSL Strain Gauge Comparison - MSL A-Lower 32
0000-0096-5764-P-RI GEH PROPRIETARY INFORMATION
[r 11 Figure 4 Limit Curve for Line A-Upper 33
0000-0096-5766-NP-RI NON-PROPRIETARY VERSION 1]
Figure 5 Limit Curve for Line A-Lower 34
0000-0096-5766-NP-Ri NON-PROPRIETARY VERSION 1]
Figure 6 Limit Curve for Line B-Upper 35
0000-0096-5766-NP-RI NON-PROPRIETARY VERSION 36
0000-0096-5766-NP-RI NON-PROPRIETARY VERSION
))
Figure 7 Limit Curve for Line B-Lower 37
0000-0096-5766-NP-RI NON-PROPRIETARY VERSION Figure 8 Limit Curve for Line C-Upper 38
0000-0096-5766-NP-RI NON-PROPRIETARY VERSION
))
Figure 9 Limit Curve for Line C-Lower 39
0000-0096-5766-NP-Ri NON-PROPRIETARY VERSION 1]
Figure 10 Limit Curve for Line D-Upper 40
0000-0096-5766-NP-RI NON-PROPRIETARY VERSION Figure 4
Limit Curve for Line D-Lower 41 to PLA-6484 Non PROPRIETARY VERSION "SSES Dryer Component Worst Case Fatigue Margin Under Projected EPU Conditions"
142215-PCR3-20090224-01 Page 1 of 1 Non-proprietary Version of PLA 6484 SSES Dryer Component Worst Case Fatigue Margin under Projected EPU Conditions 1I
_I_
I __
II to PLA-6484 Cross Reference of GEH Documents
GEH References / PPL To NRC Transmittal Cross Reference Matrix Reference # In Updated Dryer Stress Report Reference Description Originally Transmitted To NRC via PPL Letter 0000-0094-2113-P-RU 1 - Section 9 GE-NE-0000-0079-2250-P-RO, PLA-6323, "Susquehanna Steam Electric Station Proposed "Susquehanna Replacement Steam Dryer Amendment No. 285 For Unit 1 Operating License No. NPF-14 And Stress Analysis at Extended Power Uprate proposed License Amendment 252 For Unit 2 Operating License No.
Conditions", January 2008 NPF-22 Constant Pressure Power Uprate Application", B.T. McKinney to USNRC, January 25, 2008 2 - Section 9 GE-NE-0000-0085-2413-P-RO, "Susquehanna PLA-6408, "Susquehanna Steam Electric Station Unit 1 Operating Unit 1 Replacement Steam Dryer Vibration License No. NPF-14 License Condition 2.C.(36)(b)7", B.T. McKinney Instrumentation Program NRC Summary to USNRC, September 26, 2008 Report", July 2008 1 - Appendix "A" GE-NE-0000-0080-2994-P-R4, PLA-6332, "Susquehanna Steam Electric Station Unit 1 Operating "Susquehanna Replacement Steam Dryer License No. NPF-14 License Condition 2.C.(36)(b)1", B.T. McKinney Instrumentation Acceptance Criteria - Dryer to USNRC, February 23, 2008 Mounted Instrumentation", April 2008 As Amended By:
PLA-6349, "Susquehanna Steam Electric Station Unit 1 Operating License No. NPF-14 License Condition 2.C.(36)(b)1", B.T. McKinney to USNRC, April 11, 2008 2 - Appendix"A" GE-NE-0000-0085-2413-P-RO, PLA-6408, "Susquehanna Steam Electric Station Unit 1 Operating "Susquehanna Unit 1 Replacement Steam License No. NPF-14 License Condition 2.C.(36)(b)7", B.T. McKinney Dryer Vibration Instrumentation Program to USNRC, September 26, 2008 NRC Summary Report", July 2008 3 - Appendix "A" GE-NE-0000-0079-2250-P-RO, PLA-6323, "Susquehanna Steam Electric Station Proposed "Susquehanna Replacement Steam Dryer Amendment No. 285 For Unit 1 Operating License No. NPF-14 And Stress Analysis at Extended Power Uprate proposed License Amendment 252 For Unit 2 Operating License No.
Conditions", January 2008 NPF-22 Constant Pressure Power Uprate Application", B.T. McKinney to USNRC, January 25, 2008 4 - Appendix "A" ASME B&PV Code,Section III, 1989 Edition Document was not transmitted by PPL to NRC with no Addenda
GEH References / PPL TO NRC Transmittal Cross Reference Matrix Reference # In Updated Steam Dryer MSL Limit Curve Report Reference Description Originally Transmitted To NRC via PPL Letter 0000-0096-5766-P-RO GE-NE-0000-0080-8732-P-RO, PLA-6346, "Susquehanna Steam Electric Station Unit 1 Main Steam "Susquehanna Replacement Steam Dryer Line Limit Curves", B.T. McKinney to USNRC, April 1, 2008 Limit Curves - Main Steam Line Mounted Note: The entire report was not transmitted; only the limit curves Instrumentation", March 2008 themselves were provided 2
GE-NE-0000-0079-2250-P-RO, PLA-6323, "Susquehanna Steam Electric Station Proposed "Susquehanna Replacement Steam Dryer Amendment No. 285 For Unit 1 Operating License No. NPF-14 And Stress Analysis at Extended Power Uprate proposed License Amendment 252 For Unit 2 Operating License No.
Conditions", January 2008 NPF-22 Constant Pressure Power Uprate Application", B.T. McKinney to USNRC, January 25, 2008 3
GE-NE-0000-0080-2994-P-R4, PLA-6332, "Susquehanna Steam Electric Station Unit 1 Operating "Susquehanna Replacement Steam Dryer License No. NPF-14 License Condition 2.C.(36)(b)1", B.T. McKinney Instrumentation Acceptance Criteria - Dryer to USNRC, February 23, 2008 Mounted Instrumentation", April 2008 As Amended By:
PLA-6349, "Susquehanna Steam Electric Station Unit 1 Operating License No. NPF-14 License Condition 2.C.(36)(b)1", B.T. McKinney to USNRC, April 11, 2008 4
GE-NE-0000-0085-2413-P-RO, PLA-6408, "Susquehanna Steam Electric Station Unit 1 Operating "Susquehanna Unit 1 Replacement Steam License No. NPF-14 License Condition 2.C.(36)(b)7", B.T. McKinney Dryer Vibration Instrumentation Program to USNRC, September 26, 2008 NRC Summary", July 2008 5
0000-0095-2113-P-RO, PLA-6484, Enclosure 1 "Susquehanna Replacement Steam Dryer Updated Stress Analysis at Extended Power Uprate Conditions", February 2009 6
MDE #199-0985-P, Revision 1, PLA-6138, "Susquehanna Steam Electric Station Proposed License "Susquehanna-1 Steam Dryer Vibration Amendment No. 285 For Unit 1 Operating License No. NPF-14 And Steady State and Transient Response - Final Proposed License Amendment No. 253 for Unit 2 Operating License Report", January 1986 No. NPF-22 Constant Pressure Power Uprate - Supplement",
B.T. McKinney to USNRC, December 4, 2006 to PLA-6484 Affidavits
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"), 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 GEH report, GE-NE-0000-0095-2113-P-RO, Susquehanna Replacement Steam Dryer Updated Stress Analysis at Extended Power Uprate Conditions, February 2009. The proprietary information is identified by a dotted underline inside double square brackets. ((Thjs.s.entence is an..exa..m.p.e...!)) In each case, the superscript notation f3) 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, 704F2dl280 (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.
Aff GE-NE-0000-0095-2113-P-RO Affidavit Page I of 3
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 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 BWR Steam Dryers. Development of these methods, techniques, and information and their application to the design, modification, and analyses methodologies and processes for the Steam Dryer Program was achieved at a significant cost to GEH.
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 Aff GE-NE-0000-0095-2113-P-RO 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 23rd day of February 2009.
Tim E. Abney Vice President, Services Licensing GE-Hitachi Nuclear Energy Americas LLC Aff GE-NE-0000-0095-2113-P-RO 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"), 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 GEH Engineering Report, 0000-0096-5766-P-Ri, Revised Susquehanna Replacement Steam Dryer Limit Curves - Main Steam Line Mounted Instrumentation, February 2009.
The proprietary information is identified by a dotted underline inside double square brackets.
((.Tjs...tMn i..is
.an
.e..am..p.l.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 Proiect v. Nuclear Regulatory Commission, 975F2d87l (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.
Aff 0000-0096-5766-P-Ri Affidavit Page I of 3
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 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 BWR Steam Dryers. Development of these methods, techniques, and information and their application to the design, modification, and analyses methodologies and processes for the Steam Dryer Program was achieved at a significant cost to GEH.
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 Aff 0000-0096-5766-P-Ri 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 26th day of February 2009.
Tim E. Abney Vice President, Services Licensing GE-Hitachi Nuclear Energy Americas LLC Aff 0000-0096-5766-P-Ri 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"), 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 GEH letter, 142215-PCR3-20090224-01, Enclosure 4 of PLA Letter 6484 - Dryer Stress Components Table, dated February 24,.
2009. The proprietary information in Enclosure 1 entitled, Enclosure 4 of PLA Letter 6484
- Dryer Stress Components Table, is identified by a dotted underline inside double square brackets. ((This.se.n.tenc.eisa.n.e.x.a.mpe
] 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, 704F2dl280 (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.
Aff 142215-PCR3-20090224-01 Affidavit Page I of 3
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 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 BWR Steam Dryers. Development of these methods, techniques, and information and their application to the design, modification, and analyses methodologies and processes for the Steam Dryer Program was achieved at a significant cost to GEH.
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 Aff 142215-PCR3-20090224-01 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 24th day of February 2009.
Tim E. Abney Vice President, Services Licensing GE-Hitachi Nuclear Energy Americas LLC Aff 142215-PCR3-20090224-01 Affidavit Page 3 of 3