L-MT-10-046, Extended Power Uprate: Replacement Steam Dryer Supplement

Extended Power Uprate: Replacement Steam Dryer Supplement

ML102010462
Person / Time
Site:	Monticello
Issue date:	06/30/2010
From:	O'Connor T Northern States Power Co, Xcel Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-MT-10-046, TAC MD9990
Download: ML102010462 (155)

Text

ENCLOSURE 1, APPENDIX 4, AND ENCLOSURES 2, 3, 4, 5, 6, 7, 8 AND 9 CONTAIN PROPRIETARY INFORMATION -WITHHOLD FROM PUBLIC DISCLOSURE IN ACCORDANCE WITH 10CFR 2.390 XcelEnergy Monticello Nuclear Generating Plant 2807 W County Road 75 Monticello, MN 55362 June 30, 2010 L-MT-1 0-046 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Monticello Nuclear Generating Plant Docket 50-263 Renewed License No. DPR-22

Subject:

Monticello Extended Power Uprate: Replacement Steam Dryer Supplement (TAC MD9990)

References:

1) Letter from Northern States Power Company, a Minnesota corporation (NSPM), d/b/a Xcel Energy to Document Control Desk (NRC), "License Amendment Request: Extended Power Uprate," L-MT-08-052, dated November 5, 2008. (ADAMS Accession No. ML083230111)

2) Letter from NSPM, d/b/a Xcel Energy to Document Control Desk (NRC), "

Subject:

Monticello Replacement Steam Dryer," L-MT-10-007, dated February 18, 2010. (ADAMS Accession No. ML100550127)

3) Regulatory Guide 1.20, Revision 3, "Comprehensive Vibration Assessment Program for Reactor Internals During Preoperational and Initial Startup Testing," dated March 2007. (ADAMS Accession No. ML070260376)

Pursuant to 10 CFR 50.90, the Northern States Power Company, a Minnesota corporation (NSPM), doing business as Xcel Energy, requested in Reference 1 an amendment to the Monticello Nuclear Generating Plant (MNGP) Renewed Operating License (OL) and Technical Specifications to increase the maximum authorized power level from 1775 megawatts thermal (MWt) to 2004 MWt.

In Reference 2, NSPM informed the NRC of its plan to replace the existing MNGP steam dryer. NSPM is replacing the steam dryer because the replacement steam dryer (RSD) is a cost effective measure to reduce moisture carryover to< 0.1%. This reduction in moisture carryover helps minimize corrosion products in the steam loop.

The reduced corrosion products minimize high pressure turbine wear, reduce the production and transportation of activated corrosion products, and reduce the volume of bot Page 1

Document Control Desk Page 2 radioactive wastes (from Condensate Demineralizer & Reactor Water Cleanup (RWCU) filtering material replacements). These reductions help minimize worker doses.

NSPM has contracted Westinghouse Electric Company, LLC (WEC) to provide a new steam dryer to replace the currently installed steam dryer (CISD). In this supplement to the EPU application NSPM is submitting to the NRC the analyses and evaluations required to support use of the RSD under EPU conditions. The analyses are provided in accordance with Regulatory Guide (RG) 1.20, Revision 3 (Reference 3). The provided analyses support the planned extended power uprate (EPU),at MNGP. These analyses have been performed to determine the functional and performance requirements of the RSD as well as to qualify the RSD for acoustic pressure loads. The process used to perform the analyses involves advanced thermal/hydraulic computer codes to assess dryer performance and scale model testing, multiple acoustic and structural analyses and several computer codes, both commercially available and special-purpose codes developed in conjunction with the evaluation of acoustic loads. to this letter contains an overview of the design and analyses performed for the RSD. This includes the RSD design, instrumentation provided with the RSD and a description of the scale model testing of the RSD design. In addition, this enclosure discusses the stress analysis results and justifications for acoustic monitoring methodology used.

Appendix 1 to Enclosure 1 is the RG 1.20, Revision 3 compliance table (matrix). This matrix demonstrates RG 1.20 compliance in the RSD development. Appendix 2 to provides an analysis of previously unanswered NRC requests for additional information (RAI's) for the currently installed steam dryer. This appendix provides information on whether the RAI is applicable to the RSD and where the response to the RAI is contained. Appendix 3 to Enclosure 1 contains an evaluation of the changes to EPU documentation based on use of the RSD. Appendix 4 to Enclosure 1 contains revised final pages to other analyses and documents within the body of documentation that is used to support the MNGP EPU licensing basis. Portions of appendix 4 contain proprietary information. Finally, Appendix 5 to Enclosure 1 is the Power Ascension Test Plan for the RSD. is Westinghouse Electric Company, LLC (WEC) WCAP-17085-P, Revision 1, "Monticello Replacement Steam Dryer Structural Evaluation for High-Cycle Acoustic Loads." This document provides a high cycle fatigue evaluation of the WEC RSD for MNGP. Acoustic loads and stresses for both current licensed thermal power (CLTP) and extended power uprate (EPU) conditions have been evaluated for high cycle fatigue. The conclusion of the report indicates that the acoustic loads and stresses meet the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code Section III, Subsection NG criteria. is WEC Report, SES 09-127-P, Revision 2, "Monticello Steam Dryer Replacement - Structural Verification of Steam Dryer." This report presents a stress

Document Control Desk Page 3 analysis of the MNGP RSD for service level A, B, C and D conditions. The purpose of the analysis is to verify that the RSD fulfills the requirements of Section III, Subsection NG of the American Society of Mechanical Engineers (ASME) code. is WEC Report, SES 09-129-P, Revision 2, "Monticello - Steam Dryer Replacement Moisture Carryover Analysis." This report documents the analyses of the performance of the steam dryer in terms of moisture carryover (MCO) and pressure drop. The analysis concludes that the replacement steam dryer for MNGP is expected to have acceptable performance at a reactor thermal power of 2004 MWt: is WEC Report, WCAP-17251-P, Revision 0 "Monticello Replacement Steam Dryer Four Line Acoustic Subscale Testing Report." The purpose of the subscale testing presented in this report is two-fold. First, the subscale main steam line acoustic signature at a range of operating conditions was examined to evaluate the effect of the replacement dryer geometry. Second, a new set of CLTP to EPU scaling spectra were derived to scale the plant acoustic signature from the CLTP signature with the current steam dryer to the predicted EPU signature with the RSD. is WEC Report WCAP-17252-P, Revision 0, "Acoustic Loads Definition for the Monticello Steam Dryer Replacement Project." The report develops two key factors which are be used as input to the structural analysis of the RSD. First, the report develops the three-dimensional acoustic pressure field. Second, the report applies the acoustic circuit model (ACM) Rev. 4.0 methodology to the RSD design to develop the boundary sources at CLTP and EPU conditions. The conditioned pressure signals measured on the main steam lines (MSLs) (provided in Enclosure 5) are applied to the ACM and the scaling factors at CLTP and EPU conditions are calculated. is letter LTR-A&SA-09-32, Revision 2 from WEC dated June 21, 2010.

This letter provides the power ascension test plan (PATP) limit curves that are planned to be utilized following installation of the RSD. Due to the timing of the installation of the RSD and the timing of approval by the NRC to proceed to a higher power level, the RSD - PATP may be accomplished in two phases as outlined in Enclosure 1, Appendix

5. is letter LTR-EP-10-059, Revision 1 from WEC dated June 24, 2010. This letter provides details of the differential pressure methodology utilized by WEC in design of the MNGP RSD. is letter LTR-EP-10-062, Revision 1 from WEC dated June 29, 2010. This letter provides a detailed comparison of the RSD design and testing with RG 1.20, Revision 3. This Enclosure along with Enclosure 1, Appendix 1, provide assurance that the RSD complies with the requirements of RG 1.20, revision 3. The letter contains both proprietary and nonproprietary attachments..

Document Control Desk Page 4 0 contains affidavits. executed to support withholding Enclosure 1, Appendix 4 and Enclosures 2, 3, 4, 5, 6, 7, 8 and 9 from public disclosure. Enclosure 1, Appendix 4 contains information proprietary to General Electric - Hitachi (GEH), the owner of the information. Enclosures 2 - 9 contain information proprietary to WEC; the owner of the information. The affidavits provided set forth the basis for which the information may be withheld from public disclosure by the NRC and addresses with specificity the considerations listed in 10 CFR 2.390(b)(4). Accordingly, it is respectfully requested that the information which is proprietary to GEH and WEC be withheld from public disclosure in accordance with 10 CFR 2.390.

Correspondence with respect to the copyright or proprietary aspects of GEH information or the supporting GEH affidavit in Enclosure 10 should be addressed to Edward Schrull, Vice President, Services Licensing, Regulatory Affairs, GE Hitachi Nuclear Energy Americas LLC, 3901 Castle Hayne Road, Wilmington, North Carolina 28401.

Correspondence with respect to the copyright or proprietary aspects of WEC information or the supporting WEC affidavits in Enclosure 10 should be addressed to J.

A. Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355. 1 is a summary of EPU commitments including commitments associated with .the RSD. The commitment summary includes whether the commitment is new, revised, or completed.

Enclosures 12, 13, 14, 15 and 16 contain nonproprietary versions of Enclosures 2, 3, 4, 5 and 6 respectively. Enclosures 7 and 8 are entirely proprietary and thus no nonproprietary documents have been provided. The nonproprietary reports are being provided based on the NRC's expectation that the submitter of the proprietary information should provide, if possible, a nonproprietary version of the document with brackets showing where the proprietary information has been deleted.

During a conference call held with the NRC on April 23, 2010, the NRC requested information pertaining to the European operating history and operating conditions of designs similar to the RSD that is to be installed in the MNGP reactor. WEC has determined that certain documentation (including the above requested information) related to the MNGP RSD is non-releasable as trade secrets. In order for the NRC to perform a thorough review of the RSD, NSPM understands that the NRC staff may require access to some of these documents. Therefore, arrangements have been made with WEC to provide copies of these documents and make them available for NRC audit and inspection at the WEC offices near NRC headquarters. Please contact Mike Sivack of WEC at 412-374-2372 to arrange for an appointment to audit these documents.

In accordance with 10 CFR 50.91(b), a copy of this application supplement, without enclosures is being provided to the designated Minnesota Official.

Document Control Desk Page 5 Summary of Commitments This letter makes changes to existing commitments and implements one new commitment. See Enclosure 11 for details.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on: June 30)201 Project Manager, cc: Monticello Administrator, Region Nuclear Ill, USNRC (w/oGenerating enclosures)

Resident Inspector, Plant, USNRC Monticello Nuclear Generating Plant, enclosures) USNRC (w/o c:AminnesotratrDepartmnt ofI Comec (w/o enclosures)

ENCLOSURE I DESIGN AND ANALYSIS OF THE REPLACEMENT STEAM DRYER FOR THE PROPOSED EPU AMENDMENT Page 1 of 21

L-MT-10-046 Page 2 of 21 ENCLOSURE 1 TABLE OF CONTENTS 1.0 OVERVIEW

2.0 BACKGROUND

2.1 Design of the Replacement Steam Dryer 2.2 Instrumentation Provided with the Replacement Steam Dryer 2.3 Instrumentation on the Main Steam Lines 2.4 Scale Model Testing of the Replacement Steam Dryer 3.0 ANALYSIS OF THE REPLACEMENT STEAM DRYER 3.1 Stress Analysis of the Replacement Steam Dryer 3.2 Acoustic Circuit Model 3.3 Regulatory Guide 1.20 Revision 3 Compliance 4.0 CHANGES TO CURRENT EPU LICENSING BASES 4.1 Changes to EPU analyses 4.2 Changes to the EPU start up plans 4.3 Evaluation of the No Significant Hazards Consideration

5.0 REFERENCES

Appendix I - Regulatory Guide 1.20, Revision 3 Compliance Matrix Appendix 2 - Applicability of Previously Unanswered NRC Requests for Information for the Monticello Nuclear Generating Plant Replacement Steam Dryer Appendix 3 - Evaluation of Changes to EPU Documentation based on use of the Replacement Steam Dryer Appendix 4 - Revised Final Pages of Docketed Correspondence Related to the Monticello Nuclear Generating Plant Extended Power Uprate Affected by the Replacement Steam Dryer Appendix 5 - Replacement Steam Dryer Power Ascension Test Plan

L-MT-10-046 Page 3 of 21 1.0 OVERVIEW In 2008 Northern States Power, a Minnesota corporation (NSPM) requested from the United States Nuclear Regulatory Commission (NRC) an amendment to the Monticello Nuclear Generating Plant (MNGP) Renewed Operating License (OL) and Technical Specifications (TS). The purpose of the amendment request was to increase the maximum authorized power level from 1775 megawatts thermal (MWt) to 2004 MWt.

(Reference 1)

NSPM also notified the NRC in 2010 that a replacement steam dryer (RSD) is planned to be installed in MNGP in 2011. The RSD is a cost effective measure to reduce moisture carryover to < 0.1%. This reduction in moisture carryover helps minimize corrosion products in the steam loop. The reduced corrosion products minimize high pressure turbine wear, reduce the production and transportation of activated corrosion products, and reduce the volume of radioactive wastes (from Condensate Demineralizer

& Reactor Water Cleanup (RWCU) filtering material replacements). These reductions help minimize worker doses. (Reference 2)

NSPM has contracted Westinghouse Electric Company, LLC (WEC) to provide the RSD to replace the currently installed steam dryer (CISD). The MNGP RSD is based on a design that is in use and has proven to be reliable in a number of European Boiling Water Reactor (BWR) plants. Its main feature is the concentric layout of the dryer panels. This provides symmetry of fluid flow paths through the dryer and supports the overall robustness and integrity with regard to structural loads. Steam dryers of this basic configuration have been in use in European BWRs since 1978 and have accumulated over 200 reactor years of successful operation. The RSD is designed and built by Westinghouse Electric Company, LLC (WEC) (Enclosure 3).

The general layout of the RSD is shown in Figure 1.0-1 below. The upper part consists of a framework built-up of vertical beams and radial girders. This cage-like structure provides support to the dryer panels and to the lifting lugs. The panels are placed in three concentric rings and provide additional stiffness to the upper part of the dryer.

The outside shell is made of semi-curved plates to allow a smooth pathway for the steam flowing to the reactor vessel nozzles. Additional views and cutaways of the RSD are provided in Enclosure 2, Figures 2 2-8.

The NRC requires that plants evaluate steam dryers before any planned increase in power level against the requirements of RPegulatory Guide (RG) 1.20, Revision 3, "Comprehensive Vibration Assessment Program For Reactor Internals During Preoperational And Initial Startup Testing," (reference 3). In this case, because the steam dryer is being replaced (versus verifying the CISD is acceptable at uprated conditions), RG 1.20 requires NSPM establish a comprehensive vibration assessment program for the RSD. This includes collecting data from instrumentation mounted directly on the steam dryer.

L-MT-10-046 Page 4 of 21 Figure 1.0 Monticello Replacement Steam Dryer In accordance with RG 1.20, and the planned extended power uprate (EPU); analyses have been performed to determine the functional and performance requirements of the RSD as well as to qualify the RSD for acoustic pressure loads. The process used to perform the analysis involves multiple acoustic and structural analyses, scale model testing, and several computer codes, both commercially available and special-purpose codes developed in conjunction with the evaluation of acoustic loads. The balance of this enclosure provides an overview of the analyses that have been performed in support of RSD qualification for the EPU conditions of MNGP.

L-MT-1 0-046 Page 5 of 21

2.0 BACKGROUND

As described in section 1.0 and Reference 2, it is NSPMs intention to replace the CISD with the RSD. As stated in reference 2, a preliminary review under 10 CFR 50.59 concluded that installation of the RSD could be completed without NRC approval. This includes operation of the RSD up to 1775 MWt (current licensed thermal power (CLTP)). The purpose of the analyses and evaluations in this letter is to justify use of the RSD up to 2004 MWt (EPU conditions).

2.1 Design of the Replacement Steam Dryer A steam dryer is a passive component that has no safety-related function. It does have a passive function considered important to safety, to maintain its structural integrity during abnormal events.

The RSD structure is modeled using a finite element model (FEM) analysis. The FEM consists of a mixture of elements used to simulate various features and components within the RSD structure. Additional details on the FEM description can be found in , Section 3. Figures 3-2 through 3-20 provide visual details concerning the FEM simulations.

The RSD is fabricated of stainless steel plates, bars and forgings from material SA-240 type 316L. Enclosure 3 (SES 09-127-P, section 4) provides a detailed description of the geometry and features of the RSD. Loading of the RSD is described in section 8 of .

Structural damping is defined as 1% of critical damping for all frequencies. This damping is consistent with the guidance provided in Regulatory Guide 1.20. WEC has used the harmonic analysis approach which uses a consistent damping level across the frequency domain.

Two design evaluations, 1) ASME Code Section III stress evaluation and 2) Fatigue analysis including consideration of acoustic resonance pressure loading have been performed as indicated in section 3.1 of this enclosure to validate the design.

2.2 Instrumentation Provided with the Replacement Steam Dryer Prior to use of the RSD, the RSD will be modified to attach instrumentation. Design of the RSD is influenced by structural, moisture carryover (MCO), and acoustics analysis.

In order to collect real time data used for benchmarking and analytical comparison, accelerometers (2), pressure transducers (22), and strain gages (12) are being installed at pre-designed locations on the RSD.

Westinghouse has prepared an acoustic and structural analysis for the replacement steam dryer being installed at MNGP in 2011. Instrumentation will be installed on the

L-MT-1 0-046 Page 6 of 21 surface of steam dryer components consistent with the requirements of NRC RG 1.20 Rev. 3. The instrumentation will be used to perform a comparison to verify that the analytical models used for acoustic and structural analysis are adequate to confirm that the dryer design meets all ASME code and U.S. regulatory requirements.

Data will be gathered from the RSD instrumentation at several discrete steps during ascension to EPU power. The RSD data will be provided by 12 strain gauges, 2 accelerometers, and 22 pressure transducers. MSL data will be provided by strain gauges installed on the four MSLs. During the power ascension process, data from the MSL strain gauges will be compared to limit curves in order to verify that stresses are within allowable limits.

Accelerometers are being used to verify that there is no RSD movement during operation. The placement of the two accelerometers at 90 degree separation and away from any lifting lugs is adequate to ensure detection of dryer motion.

Pressure transducers and strain gauges are intended to provide comparison data. As such, no single instrument location is considered critical and redundancy is built in due to the number of sensors and their locations. The pressure transducers will measure the pressures experienced by the RSD hood panels. Pressure data will then be compared to values developed from the ACM. This comparison will provide additional information on the ACM results used as inputs to the structural analysis. Strain gauges will take mechanical data from the steam dryer hood panels which will then be compared to results from the structural analysis.

The combination of pressure transducers, strain gauges, and modal testing represents a check of the analytical models and will provide supplemental information to ensure that the structural integrity of the steam dryer will be maintained.

A hammer test prior to RSD installation will provide comparisons to the modal analysis performed using the finite element model created for the RSD.

No further detail on the specific locations of strain gages, accelerometers and pressure transducers can be supplied to the NRC by NSPM as this information is WEC proprietary information that is not releasable. The specific locations of the instrumentation on the RSD are owned exclusively by WEC. However, this information is available for audit and inspection by the NRC at WEC offices.

2.3 Instrumentation on the Main Steam Lines The main steam line (MSL) instrumentation has not changed from the initial discussion of this instrumentation in Reference 1, Enclosure 11. To facilitate the NRC's review of this supplement, a summary of the MSL instrumentation is provided below. Further details concerning the MSL instrumentation can be found in Reference 1, Enclosure 11, Section 3.

L-MT-10-046 Page 7 of 21 Generation of Load Definition Measured strain gage time-history data in the four main steam lines at the MNGP were processed by a dynamic model of the steam delivery system to predict loads on the full-scale steam dryer. These measured data were first converted to pressures, then positioned on the four main steam lines and used to extract acoustic sources in the system. A validated acoustic circuit methodology was used to predict the fluctuating pressures anticipated across components of the steam dryer in the reactor vessel. The acoustic circuit methodology included a low frequency hydrodynamic contribution, in addition to an acoustic contribution .at all frequencies. This pressure loading was then provided for structural analysis to assess the structural adequacy of the CISD in MNGP.

Strain Gage Locations and Configuration Strain gage (SG) locations were determined by Continuum Dynamics Incorporated (CDI). The locations were selected to optimize the signal for the frequency of interest (162 Hz) and to minimize uncertainties associated with comparisons to the Quad Cities benchmark data (see Reference 1, Enclosure 11, Appendix II). The locations were selected so that no acoustic sources would be present between upper and lower strain gages. Figure 2.3-1 displays the general locations of the strain gages as installed at MNGP. The upper strain gages were located on the vertical pipe runs at the same location on each pipe; approximately 12 feet from the vessel steam outlets. The lower strain gages were located exactly 32 feet downstream of the upper gages on the diagonal runs of each line (not shown in the figure).

Strain gages were installed during the 2007 refueling outage. Each of the four main steam lines was instrumented in two locations for a total of eight strain gage locations.

Each location received eight strain gages installed circumferentially and equally spaced for a total of 64 strain gages. In order to minimize the bending error, the strain gages that are diametrically opposite to each other are connected in a half-bridge "Wheatstone Bridge" configuration. Consequently, signals from the individual SGs are additive, resulting in the partial cancellation of the bending strain and enhancement of the hoop strain sensitivity. For every such location, the four signals are averaged to minimize the bending errors and improve the signal to noise ratio. Failure of individual strain gages can cause spurious signals as cancellation of bending strains is reduced. The effect of this is addressed in Reference 1, Enclosure 11, Section 3.3 and shown graphically in Figure 2.3-2 and Figure 2.3-3.

L-MT-10-046 Page 8 of 21 07 A0 MI 073B8 DI 0CO 0 1 'O101 202 C02 D02 A04 'A0 3 04 :13 q-C04 :C)3 0R01 W 003 upper Upper Upper Upper Lower Lower Lowe Loer 5A 1 .016. 5 109 C5 C16 09D 5 D 09 A14 4 AIO 14 810 C14 CIO D14 13A12 All 3 12EC12 B1 ýCiI1 D12 DII MSL MSL 2MSL MSL LD Figure 2.3-1 MSL Acoustic Pressure Vibration Monitoring Strain Gage Installation (typical)

Channels 01 and 02 are two of the 4 channels measuring hoop strain at the upper location on main steam line A. The strain gages that make up these two channels are mounted adjacent to each other as demonstrated in Figure 2.3-1 as strain gage pairs A01-A05 (channel 01) and A02-A06 (channel 02).

Figure 2.3-2 and Figure 2.3-3 demonstrate the effect of the loss of one strain gage from channel 01. Without an opposed strain gage to cancel the bending strain caused by a pipe vibration mode at approximately 22 Hz, an artificial peak is generated in the channel 01 data. This effect is repeated in the data each time a single strain gage is lost from a channel. How these artificial peaks are treated in the load definition is addressed in Reference 1, Enclosure 11, Section 3.4.

L-MT-10-046 Page 9 of 21 IVbnt-IIQ SG, Filtered, Reactor Pwr Level 100%, STR-MSA-01/05, Ch I CI) 0 50 100 150 200 250 Frequency,[iz]:

Figure 2.3-2: Channel 01 with a single operational strain gage. Note the peak at approximately 22 Hz.

fMnt-11QSG, Filtered, Reactor Pwr Level 100%, STR-MSA-02/06, Ch 2 Ai-M.,

0 50 100 150 200 250 Frequency[Hz]

Figure 2.3-3: Channel 02 with a pair of operational strain gages. Note the absence of the peak at approximately 22 Hz.

L-MT-1 0-046 Enclosure 1 Page 10 of 21 A typical strain gage system is comprised of a Wheatstone Bridge (WB) as shown in Figure 2.3-4. In Figure 2.3-4, Vin is the DC voltage supplied to the WB circuit, Vout is the output voltage measured. R1 to R4 are the four resistances on the four arms of the WB circuit. In order to minimize the bending strain error, at each SG location the WB circuit was wired in a half bridge configuration. This means that one of the two diametrically attached SGs occupied the position of R1 and the other SG, that is 1800 apart,. occupied the R3 position.

The WB circuit analysis will show that the active resistances R1 and R3 in this case will, be additive. Before the start of the measurements and with no applied strain on the active gages, the compensating resistors R2 and R4 will be adjusted such that the output voltage Vout is zero, which means that the WB circuit is balanced. In the presence of applied strain the resistances R1 and R3 will vary and the output voltage consequently will change and be proportional to the applied strain.

B A

Vin

-Ri,R3 - Active Gage Resistors (Half-Bridge)t

ýR2,,R4 - Compensating Gage Resistors Figure 2.3-4: Wheatstone Bridge and Strain Gage Electrical Schematic Raw Data Reduction The relationship between SG and pressure is governed by the geometry of the piping; therefore, thickness and OD measurements of the piping are performed at all the instrumented locations. Average SG to dynamic pressure conversion factors (PCFs) are computed for each location and are provided in Reference 1, Enclosure 11, Table 3-

L-MT-1 0-046 Page 11 of 21

1. The uncertainties of the various quantities in the SG to pressure relationship were considered when computing the uncertainty in the indirect pressure measurement.

The raw data is independently processed twice. The raw data for the analyses was first transmitted to Structural Integrity Associates (SIA). SIA processed the data as described below to generate frequency versus amplitude (microstrain) plots for each channel. The raw data was also transmitted to CDI. CDI performs a similar processing of the data as described in Reference 1, Enclosure 11, Section 3.4.

The strain gage time histories were first filtered using a Chebychev type bandpass filter (data from 2- 250 Hertz was allowed to pass). Since the data had electrical noise, digital notch filters were applied to the time histories at 60, 120, 180, and 240 Hz. Also, digital notch filters were used to exclude the electrical excitation from a recirculation pump drive. Once the signal was bandpass and notch filtered, each time history was converted from the time domain to the frequency domain (frequency spectra) using a Fast Fourier Transform (FFT) algorithm. Each time signal was averaged over the recording length in groups of 2500/.25 samples (the block size); that is, the time history was grouped into 50 percent overlapping groups of 2500/.25 samples.

Due to the digital filter imperfections, the first few seconds of processed strain data were artificially amplified causing erroneously high readings. To overcome this phenomenon, the first 2 to 5 seconds of processed data were removed before the frequency spectrum was calculated. An FFT was generated for each group and then all FFT groups were summed together, and divided by the number of groups to provide linearly averaged frequency spectra. Plots for each averaged frequency spectrum (amplitude, pE versus frequency, Hz) were generated for each channel. Figure 2.3-2 and Figure 2.3-3 are representative of the post-processed data.

Further details concerning the MSL instrumentation can be found in Referencel, 1.

2.4 Scale Model Testing of the Replacement Steam Dryer In Reference 1, Enclosure 11, Attachment II, NSPM provided CDI report 07-25P to the NRC. This report is entitled, "Acoustic and Low Frequency Hydrodynamic Loads at CLTP Power Level on Monticello Steam Dryer to 200 HZ."

This report provided measured strain gage time-history data of the four MSLs at MNGP as processed by a dynamic model of the steam delivery system to predict loads on the full-scale CISD. These measured data were first converted to pressures, then positioned on the four MSLs and used to extract acoustic sources in the system. A validated acoustic circuit methodology was used to predict the fluctuating pressures anticipated across components of the steam dryer in the reactor vessel. The acoustic circuit methodology included a low frequency hydrodynamic contribution, in addition to

L-MT-1 0-046 Page 12 of 21 an acoustic contribution at all frequencies. This pressure loading was then provided for structural analysis to assess the structural adequacy of the CISD for MNGP.

When the decision was made to remove the CISD and install the RSD, NSPM reanalyzed the acoustic loads for the RSD. Enclosure 5 contains WEC Report, WCAP-17251-P, "Monticello Replacement Steam Dryer Four Line Acoustic Subscale Testing Report." The purpose of the subscale testing presented in this report is two-fold. First, the subscale main steam line (MSL) acoustic signature at a range of operating conditions was examined to evaluate the effect of the RSD geometry. Second, a new set of CLTP to EPU scaling spectra were derived to scale the plant acoustic signature from the CLTP signature with the current steam dryer to the predicted EPU signature with the RSD.

In order to evaluate the structural integrity of the RSD at EPU conditions, the four MSL subscale test described in CDI report 07-25P was reconstructed. For comparison purposes the testing included both the CISD design and the RSD design. This was necessary in order to validate earlier work that had been done to quantify the acoustic signature scaling from CLTP to EPU operating conditions and to evaluate the effect of dryer geometry on the acoustic signature measured on the MSLs.

The results of the testing indicated that the steam Mach number at EPU operating conditions lies in such a range that the safety relief valve (SRV) acoustics contributed to the MSL signature. Using the 4-line subscale test, CLTP to EPU scaling spectra were derived for each MSL transducer location, and these spectra were applied to the plant CLTP signal to predict the MSL acoustic signature at EPU. The testing also indicated that dryer geometry had minimal signal difference at a given steam velocity.

Details concerning how the subscale model testing was setup, performed and data filtering are provided in section 4 of Enclosure 5.

The variation between the original (as found in CDI report 07-25P) and replacement designs dryer geometry did not have a significant impact on the signal. Therefore, it is acceptable to use the plant MSL CLTP signal measured with the CISD as a basis for the acoustic analysis and scaling to the plant MSL EPU signal with the RSD.

Based on the processed plant MSL signals, as well as the results from the subscale testing program, a set of CLTP to EPU scaling spectra have been derived for each MSL measurement location. The energy contribution due to the SRV resonance is inherent in the scaling spectra. The acceptance of using this signal as a basis for the signal at EPU with the RSD was demonstrated with the subscale testing program.

Further details concerning the scale model testing of the RSD can be found in .

L-MT-1 0-046 Page 13 of 21 3.0 ANALYSIS OF THE REPLACEMENT STEAM DRYER 3.1 Stress Analysis of the Replacement Steam Dryer Acoustic Stress Evaluation provides a high cycle fatigue evaluation of the Westinghouse RSD for MNGP. Acoustic stresses for the MNGP replacement dryer at both current licensed thermal power (CLTP) and extended power uprate (EPU) conditions have been evaluated.

The frequency-dependent acoustic loads were developed using a three-dimensional (3-D) acoustic model representation of the dryer assembly. The acoustic pressure loads on the steam dryer structure were calculated by solving the 3-D wave diffusion equation in the frequency domain, i.e., the Helmholtz equation.

The resulting pressure loads are generated using a 1.5-inch uniform mesh grid. Plots showing the geometry of the acoustic model are provided in Enclosure 2, Figures 6-1 and 6-2. Loads are developed for both monopole and dipole load sources, and include both the real and imaginary portions of the load in order to maintain phasing information.

The acoustic load files use a small frequency increment between solutions. Using special-purpose computer codes, the frequency interval is reduced to limit the peak response error below 5%.. This methodology results in variable frequency spacing across the frequency domain, with finer frequency spacing at the lower frequencies.

The acoustic load files generated in the acoustic analysis are input to a special-purpose computer program and the data is reorganized into a 3-D table array format required for reading into ANSYS 1 . The data from the acoustic analysis is limited to the grid positions of the acoustic model and only data adjacent to the steam dryer surfaces is present in the files. In preparing the ANSYS load tables, interpolation of the data on the model surface and simple diffusion schemes off the surface are used to fully populate the load tables.

To be consistent with the acoustic model, only surfaces of the structural FEM that are represented in the acoustic model are prepared to accept the pressure values from the table array files. The FEM is prepared by selecting surfaces common to the acoustic model and superimposing ANSYS pressure elements that are capable of applying both real and imaginary components of the pressure loads.

'ANSYS is registered trademarks of ANSYS, Inc. or its subsidiaries located in the United States or other countries.

L-MT-10-046 Page 14 of 21 Strain gages are mounted on the four main steam lines of MNGP as described in section 2.4. Two data sets are examined in the stress analysis. The first data set corresponds to the CLTP power level, and the second set corresponds to the CLTP signals modified with the scaling factors obtained from a 1/8th scale model test performed for MNGP with the RSD to approximate EPU conditions. The resulting scale factors were supplied to the dynamic analysis code in the form of text files, two files for CLTP conditions, corresponding to the monopole and dipole loads, and similarly, two files for EPU conditions.

The scale factors that are obtained from the ACM analysis are related to the frequency sampling rate for the strain gage data collection. To account for uncertainties in the modal frequency predictions of the FEM, the stresses were also computed for loads that are shifted in the frequency domain.

Acoustic stresses for the MNGP replacement dryer at both CLTP and EPU conditions have been evaluated and found to be acceptable. The acoustic stresses are evaluated for high-cycle fatigue. The requirement is to maintain the alternating stress below the endurance limit. The lowest stress ratio occurs on the middle hood stiffener at both CLTP and EPU. The lowest stress ratios satisfy NRC criteria (above 2.0) at both EPU and CLTP conditions.

See Enclosure 2 for further details on the stress analysis for the RSD.

Structural Stress Evaluation provides a structural analysis of the RSD for MNGP. This report presents the analysis to verify that the RSD fulfills the requirements of ASME Section III, Subsection NG, 2004 Edition, No Addenda. The analysis is performed using Finite Element Modeling (FEM). The finite element model covers the complete RSD including:

" Primary stresses are evaluated for Service Levels A through D.

" Secondary stresses and fatigue are evaluated for Service Level A and B.

• The acoustic part originating from Flow Induced Vibrations (FIV) is considered for Level A and B service conditions.

" Seismic blocks are verified for applicable loads.

The report presents an evaluation of primary stresses, primary plus secondary stresses and cyclic operation. The results show that the overall stress levels are low in the steam dryer. The verification of cyclic operation shows that the requirements are fulfilled with good margins. The results provide the conclusion that the steam dryer fulfils the requirements of ASME Section III, Subsection NG, 2004 Edition, No Addenda.

In addition the seismic blocks and lifting rods were analyzed and shown to meet the requirements.

See Enclosure 3 for further details on the structural verification performed on the RSD.

L-MT-1 0-046 Page 15 of 21 3.2 Acoustic Circuit Model An accurate 3-D model of the steam dryer and the surrounding fluid, i.e., steam, was developed to predict the distribution of the pressure loads on the entire structure. This model is based on the solution of the 3-D wave diffusion equation in the frequency domain, i.e., Helmholtz equation. Solutions of the acoustic pressure field have been obtained using both monopole and dipole acoustic sources. The solutions were developed in a range from 0 to 250 Hz for the monopole source case and from 0 to 60 Hz for the dipole source case. The solutions obtained with this methodology were post-processed to obtain the pressure field impinging on the inside and outside surfaces of the steam dryer structure.

In order to develop a prediction of the pressure loads for plant specific conditions, i.e.,

EPU, a set of conditioned pressure signals measured with strain gauges on the MSLs was processed through the acoustic circuit model (ACM) Rev. 4.0. The ACM produces the boundary sources which are then combined with the unit pressure loads to obtain a prediction of the acoustic pressure field surrounding the steam dryer. The application of these boundary sources to the 3-D pressure loads generates a prediction of the pressure field for the specific plant conditions, i.e., power level, steam flow rate, and steam line geometry.

Further details concerning use and development of ACM can be found in Enclosure 6 and in Reference 1, Enclosure 11.

3.3 Moisture Carryover Performance In a BWR, the moisture separation is performed in two stages. The two-phase mixture that leaves the core has a quality of around 10-20 % when it enters the first separation stage made of the steam separators also called primary separators. The steam separators separate most of the water. Depending on the performance of the separators, the quality of the flow after the separators is around 90-99 % (corresponding to a moisture content of 1-10 % by weight). The remaining water drops are separated in the second stage of separation. The second stage of separation is the steam dryer.

Almost dry steam then leaves the reactor vessel through the steam lines. The moisture content in the steam leaving the reactor vessel is called the moisture carryover (MCO).

The inlet moisture content at EPU conditions has been estimated based on core power and flow data as specified by NSPM. The data consist of a general heat balance sheet and core distributions of the active flow for each fuel assembly as well as relative power fraction -for each fuel assembly. The data was given at three different points in the burnup cycle: Beginning Of Cycle (BOC), Middle Of Cycle (MOC) and End Of Hot Full Power (EOHFP).

L-MT-1 0-046 Page 16 of 21 With the RSD installed, NSPM specified that MCO be less than 0.030% at 2004 MWt.

This value has been met. To account for 10 CFR 50 Appendix K uncertainties, MCO was also calculated at 2044 MWt. The results of this calculation provided satisfactory MCO values, less than 0.5%.

See Enclosure 4 for further details on the MCO evaluation performed for the RSD.

3.4 Regulatory Guide 1.20 Revision 3 Compliance Regulatory Guide 1.20, Revision 3, (reference 3) describes a methodology for vibration assessment program for reactor internals that the NRC staff considers acceptable. The methodology satisfies General Design Criterion 1, "Quality Standards and Records," as set forth in Appendix A, "General Design Criteria for Nuclear Power Plants," to Title 10, Part 50, of the Code of FederalRegulations (10 CFR Part 50), "Domestic Licensing of Production and Utilization Facilities" and 10 CFR 50.34, "Contents of applications; technical information,"

Reactor internals are designed to accommodate steady-state and transient vibratory loads throughout the service life of the reactor. RG 1.20 presents a comprehensive vibration assessment program that the NRC staff considers acceptable for use in verifying the structural integrity of reactor internals for flow-induced vibrations prior to commercial operation. The overall program includes individual analytical, measurement, and inspection programs. The overall program emphasizes that the individual analytical, measurement, and inspection programs should be used cooperatively to verify structural integrity and to establish the margin of safety.

Although this regulatory guide is directed to new nuclear power plants, current licensees proposing a power uprate also use this guidance in establishing a power ascension testing program.

In accordance with RG 1.20, section C1.1, NSPM has determined that the RSD is to be evaluated as a 'prototype' component, because its arrangement and design represents a first-of-a-kind design for which no 'valid prototype' exists within the United States.

RG 1.20 states that licensees with a prototype component should perform a detailed analysis of potential adverse flow effects (both flow-excited acoustic resonances and flow-induced vibrations) that can severely impact RPV internal components (including the steam dryer in BWRs) and other main steam system components, as applicable.

Further details on how the RSD complies with RG 1.20, revision 3 is provided in Enclosures 2, 3, 4, 5, 6, 7, 8 and 9. In addition, a matrix demonstrating compliance with RG 1.20, revision 3, is provided in Appendix 1.

L-MT-10-046 Page 17 of 21 4.0 CHANGES TO CURRENT EPU LICENSING BASES 4.1 Changes to EPU Analyses The purpose of this section is to identify those changes to the original EPU analyses and subsequent re-analyses and RAI responses that require modification due to the RSD.

The table included in Appendix 3 provides a summary of all the changes to the EPU analyses. Changed pages to EPU analyses are provided in Appendix 4 to this enclosure.

Major changes to the EPU Analyses are presented below:

4.1.1 Reactor Internal Pressure Differentials (RIPDs)

In Reference 1, Enclosure 5, page 2-48, the calculated value for RIPD for the CISD is a differential pressure (dP) of 0.49 psid irreversible, at 1880 MWt. This value was derived by application of the more conservative BWR4-6 correlation based on the air test data for BWR6steam dryers. An analysis was performed for the EPU project using a different and more realistic correlation for a BWR3 steam dryer and resulted in a CISD dP of 0.30 psid irreversible at EPU conditions. In addition to the irreversible term, the elevation loss of 0.08 psid was calculated for EPU per the revised methodology.

In Reference 1, Enclosure 1, section 2.0, NSPM requested approval for use of a revised methodology (BWR3) for calculating RIPD. This request is no longer required as the BWR3 correlation will no longer be used for calculating the RIPD for the RSD. Rather NSPM requests approval of the WEC methodology for determining RSD faulted differential pressure provided in Enclosure 8.

4.1.2 Moisture Carryover (MCO)

In Reference 1, Enclosure 5, section 2.2.3, NSPM discussed an increase in Moisture Carryover (MCO) for EPU conditions. As shown in Reference 1, Enclosure 5, Figure 1-2, MCO used in the heat balance for EPU conditions (100% power and core flow) is 0.49%. In Reference 1, Enclosure 5, section 2.10, NSPM described that the MCO increase could lead to increased radiation levels in local areas of the balance of plant (BOP) piping due to deposition and build up of contaminants over time.

Reference 4, Enclosure 1, pg 8, provides further information on the MCO analyses that NSPM performed. The RAI response indicated that the evaluation for radiation levels assumed an increase in MCO for the CISD from 0.05% (CLTP) to 0.5% (EPU). This then led to an increase in the generation of deposition sources in the reactor coolant.

The increase in deposition sources led to a large increase in post shutdown dose rates.

L-MT-10-046 Page 18 of 21 The MCO value calculated for the RSD under nominal EPU conditions was determined by the methodology described in section 3.3 above. This returns the MCO value used in the analyses back to a value that meets the original MCO assumptions for CISD (0.05%) under CLTP conditions. Therefore, changes associated with an increase in MCO are no longer required. This means that radiation levels for post shutdown dose rates would be similar to the current environment with no appreciable increase.

As demonstrated in the references cited above, use of a MCO value of 0.5%, while conservative, still results in acceptable values for the EPU analyses. Therefore, these analyses will remain unchanged and are still considered bounding for the RSD. Based on this determination, no changes are required to the previous dose evaluations for MCO for EPU conditions.

4.2 Changes to CPPU testing plans Start up testing described in Enclosure 1, Appendix 5 is intended to enhance the current CPPU startup testing program previously provided in Enclosures 9 and 10 of Reference

1. Specifically, this will identify the testing planned and the results expected during startup from the 2011 plant refueling outage. This start up plan is in sufficient detail to ensure the RSD design is validated.

4.2.1 Power Ascension Testing The RSD Power Ascension Test Plan (RSD - PATP) is provided in Enclosure 1, Appendix 5. The plan is divided into three parts to facilitate testing at startup to 80% of CLTP conditions, 80% - 100% of CLTP conditions and from 100% CLTP to EPU conditions, As described in Reference 1, Enclosure 10 the Structural Integrity Associates Versatile Data Acquisition Systems (SI-VersaDASTM), which was utilized for the flow induced vibration testing, will be utilized for acquiring data during the RSD - PATP. The data stream will include MSL strain gauges, RSD strain gauges, RSD accelerometers and RSD pressure transducers. Data collection will be'simultaneous to ensure data validity and remove any questions concerning timing of data collected. Data collection will occur after steady state operation (as defined by operations) has been achieved at each power level. After the data collection has been confirmed as successful, power ascension testing will continue.

Data will be collated and compared to the design data for the RSD to validate the model and design outputs. This will also confirm that the acceptance criteria of a stress ratio greater than 1 is achieved.

Standard moisture carry over (MCO) testing (in accordance with existing plant procedures) will also be performed to establish a baseline for trending purposes during

L-MT-10-046 Page 19 of 21 normal plant operations as described in Reference 1, Enclosure 9, section 4.2 and table 2.

Data collected will be compared to the limit curves provided in Enclosure 7. If a level 1 acceptance criterion is exceeded, operations will place the unit in a previously acceptable plant condition. Ifthis requires the plant to return to a lower power level then the plant will be placed in that lower power level condition until the level 1 criteria is re-evaluated and new limit curves are generated.

NSPM is making a new commitment to complete the RSD - PATP. The commitment is as follows:

As partof MNGP restart following installationof the replacement steam dryer, NSPM will implement the PowerAscension Test Plan found in Enclosure 1, Appendix 5 of this letter.

The commitment is required to satisfy the requirements of Regulatory Guide 1.20. The RSD - PATP contains requirements from RG 1.20 concerning testing and reporting requirements for the RSD. See Enclosure 11 of this letter for details concerning this commitment. See Appendix 1 to this enclosure for further details on compliance with RG 1.20.

4.2.2 Data reduction Data reduction and comparisons to design data will be transmitted to the NRC after appropriate plant management review. If new limit curves are generated, they will be included in the data package transmitted to the MNGP NRC PM. Power ascension will continue when operations is satisfied that all test conditions have been successfully met. This is documented in the RSD - PATP which is provided in Appendix 5 to this enclosure.

4.3 Evaluation of the No Significant Hazards Consideration With this letter NSPM is essentially describing three changes to the EPU analyses provided in the original amendment request (Reference 1). These changes are:

Reactor Internal Pressure Differential (RIPD) methodology Moisture Carryover (MCO) analysis results Replacement Steam Dryer Power Ascension Testing Plan (RSD-PATP)

RIPD The No Significant Hazards Consideration (NSHC) provided in Reference 1, Enclosure 1, section 5.1 discussed changes to the Reactor Internal Pressure Differentials (RIPDs) which occurred in the EPU evaluations. The RIPD changes were due to the evaluations using the CISD under EPU conditions.

L-MT-10-046 Enclosure 1 Page 20 of 21 As described in section 4.1 above, the methodology for determining the RIPD was changed in Reference 1, Enclosure 1, section 2.0. In Reference 1, Enclosure 1, NSPM requested approval for use of a revised methodology (BWR3) for calculating RIPD.

This request is no longer required as the BWR3 correlation will no longer be used for calculating the RIPD for the RSD. Rather NSPM requests approval of the WEC methodology for determining RSD faulted differential pressure described above.

As this letter requests approval of an RIPD methodology and Reference 1, Enclosure 1, also requested approval of an RIPD methodology, no change to the No Significant Hazards Consideration (NSHC) is required. In addition, the proposed changes do not affect the outcome of the NSHC evaluation.

MCO The MCO analysis value provided in section 4.1.2 of this enclosure is less than the MCO value previously provided value found in the analysis in Reference 1. Therefore, the bounding MCO value provided will still be used. In addition, the MCO changes in reference 1 did not require evaluation under the NSHC. Therefore, no changes to the NSHC are required.

RSD-PATP Finally, the RSD-PATP documented in section 4.2 of this enclosure provides documentation of the revised testing required to support the RSD installation. The RSD-PATP provides assurance that the installed component has the analyzed margin of safety and confirms the results of the vibration analysis. The RSD-PATP does not require evaluation under the NSHC and therefore, no changes to the NSHC are required.

L-MT-1 0-046 Page 21 of 21

5.0 REFERENCES

1. Letter from Northern States Power Company, a Minnesota corporation (NSPM), to Document Control Desk (NRC), "License Amendment Request: Extended Power Uprate," L-MT-08-052, dated November 5, 2008. (ADAMS Accession No. ML083230111)

2. Letter from NSPM, to Document Control Desk (NRC), "

Subject:

Monticello Replacement Steam Dryer," L-MT-10-007, dated February 18, 2010. (ADAMS Accession No. ML100550127)

3. Regulatory Guide (RG) 1.20, Revision 3, "Comprehensive Vibration Assessment Program For Reactor Internals During Preoperational And Initial Startup Testing."

Dated March 2007. (ADAMS Accession No. ML070260376)

4. Letter from NSPM to Document Control Desk (NRC), "Monticello Extended Power Uprate: Response to NRC Reactor Inspection Branch Request for Additional Information (RAI) dated March 20, 2009 (TAC No. MD9990)," L-MT-09-042, dated June 16, 2009.

L-MT-10-046 , Appendix 1 Page 1 of 19 APPENDIX 1 REGULATORY GUIDE 1.20, REVISION 3 COMPLIANCE MATRIX

L-MT-10-046 , Appendix 1 Page 2 of 19 Regulatory Guide 1.20, Revision 3, Compliance Matrix The MNGP RSD has been evaluated against the criteria provided in Regulatory Guide (RG) 1.20, Revision 3, "Comprehensive Vibration Assessment Programfor Reactor Internals during Preoperationaland Initial Startup Testing."

The purpose of the table (matrix) provided below is to demonstrate that the MNGP RSD has been fully evaluated and confirm that the analyses meet the requirements of RG 1.20, Revision 3.

NSPM has determined that the MNGP RSD meets the definition of a "prototype" classification as found in RG 1.20, Rev. 3 section 1.1. Based on this classification, section 2, of RG 1.20 defines the assessment program applicable to the MNGP RSD. The table below demonstrates how NSPM is complying with RG 1.20, Rev. 3 with the analysis and testing program applicable to the RSD.

The matrix is divided into four columns. The first column contains an item number. Since some of the responses to the RG 1.20 requirements are proprietary to Westinghouse Electric Company, LLC (WEC), the item number can be used to find the proprietary response in Enclosure 9. The second and third columns provide the RG 1.20 reference and recite the RG 1.20 requirement. The final column in this table describes how the associated RG 1.20 requirement is met by NSPM.

As noted above some of the methods for meeting the RG 1.20 requirements are proprietary, in this case the response in column four will say see Enclosure 9. Reference documents are also provided in the final column. Reference numbers in this column correspond to the list provided below:

Table

References:

1. Enclosure 3 - Westinghouse Electric Sweden AB Report SES 09-127-P, Revision 2, Monticello Steam Dryer Replacement - Structural Verification of Steam Dryer," June 3, 2010. (WESTINGHOUSE PROPRIETARY)

2. Enclosure 2 - Westinghouse WCAP-1 7085-P, Revision 1, "Monticello Replacement Steam Dryer Structural Evaluation for High-Cycle Acoustic Loads," June, 2010. (WESTINGHOUSE PROPRIETARY)

3. Enclosure 6 - Westinghouse WCAP-1 7252-P, Revision 0, "Acoustic Loads Definition for the Monticello Steam Dryer Replacement Project," June, 2010. (WESTINGHOUSE PROPRIETARY)

4. Enclosure 5 - Westinghouse WCAP-17251-P, Revision 0, "Monticello Plant Data Processing and Subscale Testing Report," June, 2010. (WESTINGHOUSE PROPRIETARY)

L-MT-10-046 , Appendix 1 Page 3 of 19 Item RG 1.20 RG. 1.20, Rev. 3 Requirement NSPM Compliance including

1. section Reference Document 1 C.2.1 "...should perform a vibration and stress analysis for those Analysis of steady-state and anticipated transients conditions steady-state and anticipated transient conditions that that correspond to pre-operational (tests conducted prior to correspond to preoperational, initial startup test, and fuel loading) and initial startup (tests conducted after fuel normal operating conditions." loading during initial plant startup) tests are applicable only to new plants, and are therefore not applicable to the MNGP RSD. The RSD has been evaluated for steady-state loads and anticipated transient conditions applicable to normal operating conditions as part of the design qualification. The analysis of non-acoustic loads is documented in Reference (1) and the analysis of acoustic loads is documented in Reference 2.

2 C.2.1(1) "Describe the theoretical structural and hydraulic models This compliance matrix is limited to matters related to the and analytical formulations or scaling laws and scale structural qualification of the RSD. The theoretical structural models used in the analysis, including all bias errors and and hydraulic models and analytical formulations or scaling uncertainties for reactor internals that, based on past laws and scale models used in the qualification of the RSD, experience, are not adversely affected by the flow-excited including loads that may potentially be adversely affected by acoustic resonances and flow-induced vibrations." the flow-excited acoustic resonances and flow-induced vibrations, are documented in References 1 through 4.

Further information regarding compliance with this requirement is proprietary to WEC, see Enclosure 9.

3 C.2.1(1)(a) "Determine the pressure fluctuations and vibration in the Information regarding compliance with this requirement is applicable plant systems under flow conditions up to and proprietary to WEC, see Enclosure 9.

including the full operating power level."

4 C.2.1(1)(b) "Justify the method for determining pressure fluctuations, Information regarding compliance with this requirement is vibration, and resultant cyclic stress in plant systems." proprietary to WEC, see Enclosure 9.

5 C.2.1(1)(c) "Address significant acoustic resonances that have the Modification to the RSD is not necessary as all ASME Code potential to damage ... steam dryers, and perform requirements are met with satisfactory margins, as modifications to reduce those acoustic resonances, as documented in References 1 and 2.

necessary, based on the analysis."

L-MT-10-046 , Appendix 1 Page 4 of 19 Item RG 1.20 RG. 1.20, Rev. 3 Requirement NSPM Compliance including

1. section Reference Document 6 C.2.1 (1) "... obtain plant-specific data to confirm the scale testing Information regarding compliance-with this requirement is and analysis results for pressure fluctuations and proprietary to WEC, see Enclosure 9.

vibration..."

7 C.2.1 (1) "Ifscale model testing is used to support the applicant's Information regarding compliance with these requirements submission, the following areas should be considered: are proprietary to WEC, see Enclosure 9.

(a) the effects of sound attenuation in the model (or effects of pressure, size, and medium) on the generation of any self-excitation mechanism (flow-excited acoustic or structural resonances)

(b) the effects of sound attenuation on the acoustic pressures ...

(c) the conservatism of the simulation of boundary conditions in the scale model (d) whether the size of the scale model is sufficiently large to allow investigation of small relevant geometrical details (such as branch line openings)"

8 C.2.1(2) "Describe the structural and hydraulic system natural Qualification of the reactor internals was performed in the frequencies and associated mode shapes that may be original EPU analysis and is unchanged by the RSD. See L-excited during steady-state and anticipated transient MT-08-052, Enclosure 5, Section 2.2.3 for further details.

operation, for reactor internals that,, based on past experience, are not adversely affected by the flow-excited acoustic resonances and flow-induced vibrations."

9 C.2.1(2) "... analyses should be performed on ... steam dryers Information regarding compliance with this requirement is

....that may potentially be adversely affected by flow- proprietary to WEC, see Enclosure 9.

excited acoustic resonances and flow-induced vibrations."

10 C.2.1(2) "Determine the damping of the excited mode shapes, and Information regarding compliance with this requirement is the frequency response functions (FRFs, i.e., vibration proprietary to WEC, see Enclosure 9.

induced by unit loads or pressures, and stresses induced by unit loads or pressures), including all bias errors and uncertainties."

L-MT-10-046 , Appendix 1 Page 5 of 19 Item RG 1.20 RG. 1.20, Rev. 3 Requirement NSPM Compliance including

1. section Reference Document 11 C.2.1(2) "Ifa numerical model is used to compute mode shapes Information regarding compliance with this requirement is and FRFs, the modeling approach should be documented proprietary to WEC, see Enclosure 9.

along with the model itself. Uncertainties and bias errors associated with both the approach and the specific model should be provided, along with their bases."

12 C.2.1 (2) "Upper bounds on the uncertainties associated with all Information regarding compliance with this requirement is significant natural frequencies of the mode shapes, which proprietary to WEC, see Enclosure 9.

may be excited during steady-state and transient operation, should be provided, along with the uncertainties and bias errors associated with the amplitudes of the FRFs. The uncertainties associated with modeling the fluid loading (by water and/or steam) on reactor internal structures should also be reported (specifically, how they relate to uncertainties in the natural frequencies and FRFs)."

13 C.2.1 (2) "... any attempt to specify structural damping coefficients Information regarding compliance with this requirement is greater than 1 percent for frequencies greater than proprietary to WEC, see Enclosure 9.

seismic frequencies should be strongly substantiated with measurements."

14 C.2.1(3) "Describe the estimated random and deterministic forcing Qualification of the reactor internals was performed in the functions, including any very-low-frequency components, original EPU analysis and is unchanged by the RSD. See L-for steady-state and anticipated transient operation for MT-08-052, Enclosure 5, Section 2.2.3 for further details.

reactor internals that, based on past experience, are not adversely affected by the flow-excited acoustic resonances and flow-induced vibrations." (NOTE: This requirement is concluded to apply to reactor internals components apart from the dryer which is specifically called out in the following sentence in the RG 1.20.)

15 C.2.1(3) "Evaluate any forcing functions that may be amplified by Information regarding compliance with this requirement is lock-in with an acoustic and/or structural resonance proprietary to WEC, see Enclosure 9.

(sometimes called self-excitation mechanisms).

All potential flow-excited acoustic or structural resonances that lead to feedback and loading amplification (commonly termed lock-in) should be addressed."

L-MT-10-046 , Appendix 1 Page 6 of 19 Item RG 1.20 RG. 1.20, Rev. 3 Requirement NSPM Compliance including

1. section Reference Document 16 C.2.1(3) "Tables of expected flow rates and resonance This data was documented in L-MT-08-052, Enclosure 11, frequencies, along with the possible ranges of lock-in and sections 2 and 3. No changes are required based on the potential load amplifications should be provided. RSD.

Uncertainties in any of the lock-in parameters (such as the characteristic Strouhal numbers of the flow-excitation sources) should be clearly defined."

17 C.2.1(3) "Ifany potential self-excitation or lock-in is identified, the The structural qualification of the Monticello steam dryer, applicant should provide specific mitigation procedures documented in Reference 2, shows that all ASME Code that would be employed if the lock-in leads to vibration requirements are met with satisfactory margins. Therefore, and/or stresses that exceed allowable limits." no specific mitigation procedures are required for the replacement dryer.

L-MT-1 0-046 , Appendix 1 Page 7 of 19 Item RG 1.20 RG. 1.20, Rev. 3 Requirement NSPM Compliance including

1. section Reference Document 18 C.2.1(3) "...some of the forcing functions that should be Information regarding compliance with these requirements considered: are proprietary to WEC, see Enclosure 9.

(a) flow instabilities over openings in the MSLs, like control and safety valve stand pipes, blind flanges, and others that lead to strong narrow-band excitation, which can lock-in to acoustic and/or structural resonances, considering the following parameters:

(i) Strouhal number analysis to check critical flow rates (including any uncertainties in Strouhal number)

(ii) effects of diameter ratio (iii) effects of upstream elbows (iv) distance between stand pipes (v) relative length of stand pipes Flow instability frequencies should be compared to those of acoustic modes in the reactor dome and structural modes in the MSLs, any connected valves, and reactor internal structures. Finite element (FE) simulations or measurements may be used to determine the resonance frequencies.

Any identified self-excitation or lock-in should not be analyzed by simply using linear extrapolation techniques.

(b) separated, impinging and reattached flows in the reactor dome, including low-frequency hydrodynamic loading on the steam dryer in BWRs (c) flow turbulence and narrowband excitation in the steam ring of MSLs in BWRs" 19 C.2.1(3) "...determine the design load definition for ... the steam Information regarding compliance with this requirement is dryer in BWRs up to the full licensed power level, and proprietary to WEC, see Enclosure 9.

should validate the method used to determine the load definitions based on scale model or plant data."

L-MT-10-046 , Appendix 1 Page 8 of 19 Item RG 1.20 RG. 1.20, Rev. 3 Requirement NSPM Compliance including

1. section Reference Document 20 C.2.1(3) "... include instrumentation on the steam dryer to measure Information regarding compliance with this requirement is pressure loading, strain, and acceleration to confirm the proprietary to WEC, see Enclosure 9.

scale model testing and analysis results."

21 C.2.1(3) ""...obtain plant data at current licensed power conditions Information regarding compliance with this requirement is for use in confirming the results of the scale model testing proprietary to WEC, see Enclosure 9.

and analysis for the steam dryer load definition prior to submitting a power uprate request."

22 C.2.1(3) "...clearly define all uncertainties and bias errors Information regarding compliance with this requirement is associated with the MSL pressure measurements and proprietary to WEC, see Enclosure 9.

modeling parameters. The bases for the uncertainties and bias errors, such as any experimental evaluation of modeling software, should be clearly presented."

L-MT-10-046 , Appendix 1 Page 9 of 19 Item RG 1.20 RG. 1.20, Rev. 3 Requirement NSPM Compliance including

1. 1 section Reference Document 23 C.2.1(3) Although stated as guidance, NSPM has evaluated the In regard to measurement of MSL pressures and computing RSD againstthe following statements in RG 1.20. fluctuating pressures within the reactor pressure vessel and

"...approaches that minimize uncertainty and bias error: main steam lines (MSLs):

(a) At least two measurement locations should be (a) NSPM has installed strain gages (SGs) at two elevations employed on each MSL in a BWR ... on each MSL. The placement of the elevations is based (b) Strain gages (at least four gages, circumferentially on calculations that ensure the installed SG locations do spaced and oriented) may be used to relate the not occur at acoustic nodes. Eight strain gages are used hoop strain in the MSL to the internal pressure. around the circumference of the MSL.

(c) The speed of sound used in any acoustic models (b) Eight (8) SGs are installed at each MSL elevation to should not be changed from plant to plant, but rather ensure an acceptable number of working SGs at each should be a function of temperature and steam elevation. During installation of the SGs, the diameter quality. and thickness of the pipe is measured and used in the (d) Reflection coefficients at any boundary between determination the measurement uncertainty.

steam and water should be based on rigorous modeling or direct measurement. The uncertainty of (c) Through (f): Information regarding compliance with these the reflection coefficients should be clearly defined. requirements is proprietary to WEC, see Enclosure 9.

... assuming 100-percent reflection coefficient is not necessarily conservative.

(e) Any sound attenuation coefficients should be a function of steam quality (variable between the steam dryer and reactor dome), rather than constant throughout a steam volume (such as the volume within the RPV).

(f) Once validated, the same speed of sound, attenuation coefficient, and reflection coefficient should be used in other plants. However, different flow conditions (temperature, pressure, quality factor) may dictate adjustments of these parameters."

L-MT-10-046 , Appendix 1 Page 10 of 19 Item RG 1.20 RG. 1.20, Rev. 3 Requirement NSPM Compliance including

1. section Reference Document 24 C.2.1(4) "Additional analyses should be performed on those Information regarding compliance with this requirement is systems and components, such as steam dryers ... , that proprietary to WEC, see Enclosure 9.

may potentially be adversely affected by the flow-excited acoustic resonances and flow-induced vibrations. ....The calculated responses should include vibrations for components that have maximum vibration limits, as well as stresses for components that have maximum stress criteria ... The margins against violating the criteria should be reported."

25 C.2.1(4) "Based on the uncertainties and bias errors identified in Information regarding compliance with this requirement is items 1-3 [2.1(1) - (3)] above, an end-to-end uncertainty proprietary to WEC, see Enclosure 9.

and bias error should be reported, along with a clear explanation of how the individual uncertainties and bias errors have been combined."

26 C.2.1(4) "Since the transfer functions (or FRFs) described in item 2 Information regarding compliance with this requirement is

[2.1(2)], and forcing functions described in item 3 [2.1(3)], proprietary to WEC, see Enclosure 9.

have an uncertainty associated with the frequencies of the response peaks attributable to resonant modes, the vibration and stress calculations should address those uncertainties by shifting either the FRFs or forcing functions in frequency to span the uncertainty in the response peak frequencies. ... the worst case vibration or stress should be reported..."

27 C.2.1(5) "Summarize the calculated structural and hydraulic Information regarding compliance with this requirement is responses for preoperational and initial startup testing proprietary to WEC, see Enclosure 9.

conditions, compared to those for normal operation. This summary should address the adequacy of the test simulation to normal operating conditions."

L-MT-10-046 , Appendix 1 Page 11 of 19 Item RG 1.20 RG. 1.20, Rev. 3 Requirement NSPM Compliance including

1. section Reference Document 28 C.2.1(6) "Identify the anticipated structural or hydraulic vibratory The anticipated structural or hydraulic vibratory responses response [defined in terms of frequency, amplitude that correspond to pre-operational (tests conducted prior to (displacement, acceleration, and/or strain), and modal fuel loading) and initial startup (tests conducted after fuel contributions] that is appropriate to each of the sensor loading during initial plant startup) tests are applicable only to locations for steady-state and anticipated transient new plants, and are therefore not applicable to the MNGP preoperational and startup test conditions." RSD.

Further information regarding compliance with this requirement is proprietary to WEC, see Enclosure 9.

29 C.2.1 (7) "Specify the test acceptance criteria with permissible Qualification of the reactor internals was performed in the deviations and the bases for the criteria. The criteria original EPU analysis and is unchanged by the RSD. See L-should be established in terms of maximum allowable MT-08-052, Enclosure 5, Section 2.2.3 for further details.

response levels in the structure, and presented in terms of maximum allowable response levels at sensor locations."

30 C.2.1(7) "After developing a steam dryer load definition.., should Information regarding compliance with this requirement is apply the load definitions to vibration and stress models to proprietary to WEC, see Enclosure 9.

determine the vibrations ... and stresses within the steam dryer, with justified damping assumptions and applicable weld factors and stress intensities. After including applicable bias errors and random uncertainties, the applicant/licensee should compare ... peak stresses at critical steam dryer locations to the fatigue limits in the ASME Boiler & Pressure Vessel Code..."

31 C.2.1 (7) "...compare stresses, at any locations that might have The above requirement is not applicable to the MNGP RSD experienced fatigue cracking, with the ASME Code fatigue since it has not experienced any fatigue cracking.

limits to validate the stress model ... should also compare the primary and secondary stresses that the steam dryer may experience as a result of plant transients to the applicable ASME Code service level limits."

32 C.2.1(7) "...implement modifications to the BWR steam dryer The above requirement is not applicable to the MNGP RSD based on the design stress margin or to any components as all ASME Code requirements are met with satisfactory responsible for high excitation to reduce that excitation, so margins as documented in Reference 2.

that none of the resulting stresses exceed the Code allowable limits."

L-MT-1 0-046 , Appendix 1 Page 12 of 19 Item RG 1.20 RG. 1.20, Rev. 3 Requirement NSPM Compliance including

1. section Reference Document 33 C.2.1(7) "...develop a ... stress limit curve for the steam dryer for Information regarding compliance with this requirement is power ascension to provide assurance that the ... stress proprietary to WEC, see Enclosure 9.

in the individual steam dryer components will not exceed the ASME Code fatigue limits."

34 C2.1(7) "The limit curves, while including the bias errors and Information regarding compliance with this requirement is uncertainties from the end-to-end vibration and stress proprietary to WEC, see Enclosure 9.

analyses, should also include those associated with the vibration and stress measurement program (in particular, those associated with the data acquisition systems and instrumentation)."

35 C.2.1(7) "...develop a method for collecting plant data during power Information regarding compliance with this requirement is ascension and full licensed power conditions that can be proprietary to WEC, see Enclosure 9.

used to calculate the valve vibrations steam dryer stress, including appropriate bias errors and random The RSD Power Ascension Test Plan (RSD - PATP) contains uncertainties." requirements for collecting plant data during power ascension (see Enclosure 1, Appendix 5).

36 C.2.2 "... develop and implement a vibration measurement The RSD will not affect the steam flow, pressure, and program to verify the structural integrity of reactor temperature for the rest of the reactor internals. Thus, the internals, determine the margin of safety associated with Task Reports that evaluated the RPV and internals are still steady-state and anticipated transient conditions for valid and are appropriate for confirming the structural normal operation, and confirm the results of the vibration adequacy at EPU operating conditions.

analysis."

37 C.2.2 "... collect plant data from instrumentation mounted Enclosure 1, section 2.2 describes the instrumentation directly on the steam dryer at significant locations mounted directly on the RSD. Further Information regarding (including the outer hood and skirt, and other potential compliance with this requirement is proprietary to WEC, see high-stress locations) to verify that the stress on individual Enclosure 9.

steam dryer components is within allowable limits during plant operation. ... BWR licensees planning a power uprate may use plant instrumentation to evaluate steam dryer pressure loading and stress, rather than installing steam dryer instrumentation where justified."

L-MT-1 0-046 , Appendix 1 Page 13 of 19 Item RG 1.20 RG. 1.20, Rev. 3 Requirement NSPM Compliance including

1. section Reference Document 38 C.2.2 "The instrumentation directly mounted on the steam dryer See response to Item 37.

should provide sufficient information for a stress analysis of the entire steam dryer, and should include pressure sensors, strain gauges, and accelerometers."

39 C.2.2 "The MSLs should also be instrumented to collect data to See L-MT-08-052, Enclosure 11, section 3, for the full determine steam pressure fluctuations in order to identify description of the MSL strain gage installation.

the presence of flow-excited acoustic resonances and allow analysis of those pressure fluctuations to calculate Further information regarding compliance with this

... steam dryer loading and stress." requirement is proprietary to WEC, see Enclosure 9.

40 C.2.2 "The direct steam dryer data should be used to calibrate Correlation of the MSL strain gage data with the steam dryer the MSL instrumentation and data analysis prior to direct instrumentation will be performed during power removal or failure of the steam dryer instrumentation." ascension testing. It is anticipated that the biases and uncertainties included in the dryer qualification will result in conservative loads and resultant stresses, such that the applied pressure loads and calculated stresses will be conservative relative to the values measured during power ascension.

Enclosure 1, section 2.2 of this letter describes the instrumentation mounted directly on the RSD. The RSD instrumentation will be used to confirm that results obtained using the MSL strain gages are conservative. Plotting of results during power ascension will allow a confirmation of expected trends for ACM predicted loads and FEA results. In the event that RSD instrumentation is lost, the use of this trend will provide a method for confirming that the ACM and FEA results are conservative and support the requirements for further analysis at higher power levels.

41 C.2.2 "As part of the startup and power ascension program ... Information regarding compliance with this requirement is the steam [dryer],... should be instrumented to measure proprietary to WEC, see Enclosure 9.

vibration during plant operation to verify that qualification limits will not be exceeded..."

42 C.2.2(1) "The vibration measurement program submittal should The vibration measurement program for the RSD includes include a description of the following ... : the following:

the data acquisition and reduction system, including the (a) The transducer types (e.g., pressure transducers,

L-MT-10-046 , Appendix 1 Page 14 of 19 Item RG 1.20 RG. 1.20, Rev. 3 Requirement NSPM Compliance including

1. section Reference Document*

following details: accelerometers, and strain gauges) are selected to (a) transducer types and their specifications, including ensure they will remain functional during the vibration useful frequency and amplitude ranges measurement program. Data specifications will be included to show compliance with the expected operating (b) transducer positions, which should be sufficient to conditions, including frequency and amplitude ranges.

monitor significant lateral, vertical, and torsional structural motions of major reactor internal (b) The number and type of transducers and their positions components in shell, beam, and rigid body modes of are based on the acoustic and structural analyses of the vibration, as well as significant hydraulic responses steam dryer and will be able to confirm the input forcing and those parameters that can be used to confirm the function.

input forcing function (c) Precautions being taken as follows:

(c) precautions being taken to ensure acquisition of quality data (e.g., optimization of signal-to-noise ratio, " All sensors will use shielded cable grounded at one relationship of recording times to data reduction point to minimize electrical noise interference requirements, choice of instrumentation system)

" Signal-to-noise will be maximized by the following:

(d) online data evaluation system to provide immediate " transducer dynamic range selected to coincide verification of general data quality with expected values (e) procedures for determining frequency, modal content, " use low noise electronics from signal conditioning and maximum values of response to DAS (f) all bias errors (such as model underprediction) and " high digitization (number of bits) random uncertainties (such as instrumentation error) " use anti-aliasing filter associated with the instrumentation and data " Data recording times will be sufficient length to provide acquisition systems" at least 1,000 cycles of data at the lowest frequency of interest

" Instrumentation system will be designed to provide:

• Simultaneous acquisition of steam dryer and MSL channels

• Anti-alias filtering for all channels

• High order low and high pass filtering

• Amplification

• High accuracy electronics (d) Data acquisition system will be able to provide a table of maximum, minimum, root mean square values, and allow data to be easily and quickly trended as a function of

L-MT-10-046 , Appendix 1 Page 15 of 19 Item RG 1.20 RG. 1.20, Rev. 3 Requirement NSPM Compliance including

1. section Reference Document power/flow immediately after acquiring the data. In addition, the acquired data may be analyzed using time history and spectrum analysis prior to ascending to the next data point.

(e) Procedures will be provided to perform modal testing on the steam dryer prior to installation into the reactor. The modal testing will provide resonant characteristics (mode shapes, resonant frequency, and damping). This information can then be compared to the operational data to distinguish modal response from the forced response and isolate the acoustic response as observed by the main steam line strain gauges.

(f) An uncertainty analysis will be performed for the instrumentation system from the transducer through data recording. The uncertainty analysis will include:

. uncertainty related to each component

. uncertainty related to the transducer installation and placement 43 C.2.2(2) "The vibration measurement program submittal should The RSD Power Ascension Test Plan (RSD - PATP) contains include a description of the following ... : requirements for vibration monitoring (see Enclosure 1, test operating conditions, including the following details: Appendix 5). The RSD - PATP contains the following (a) ... establish a power ascension program, which parameters:

includes, as applicable, (i) specific hold points and (i) Above CLTP power will be increased in 2.5% increments.

their durations during power ascension; (ii) activities After each 2.5% increment, data will be collected for the to be accomplished during the specified hold points; transducers installed on the RSD and the MSL SGs.

(iii) plant parameters to be monitored in comparison with applicable limit curves; (iv) inspections and (ii) Preliminary data reduction will be performed on the MSL walkdowns to be ... during the specified hold points; (v) SGs and compared to limit curves. In addition, a comparison methods to be used to trend plant parameters; (vi) of the pressure transducers will be compared to the results of acceptance criteria for monitoring and trending plant the ACM analysis.

parameters, and for conducting walkdowns and . (iii) Plant parameters such as moisture carryover, main steam inspections; (vii) actions to be taken if acceptance flow, and recirculation pump speed will be monitored.

criteria are not satisfied; and (viii) provisions for providing information to the NRC staff on plant data, (iv) Walkdowns will be performed for accessible components

L-MT-1 0-046 , Appendix 1 Page 16 of 19 Item RG 1.20 RG. 1.20, Rev. 3 Requirement NSPM Compliance including

1. section Reference Document evaluations, walkdowns, inspections, and procedures of the main steam system. Accelerometers have been prior to and during power ascension, including installed at various locations of the main steam piping to interactions during hold points and any instance in monitor steady state vibration during EPU power ascension.

which acceptance resolution of safetycriteria concernsare identified not satisfied, andthe during (v) Moisture carryover will be monitored via plant parameters staff's review of that information prior to further power (e.g., main steam flow, recirculation pump speeds, etc.)

ascension or continued full-power operation." which will be tabulated corresponding to the time that the data is collected.

(vi) Acceptance criteria have been developed, in the form of limit curves, for the RSD. Additionally, acceptance criteria have been developed for the main steam piping accelerometers.

(vii) If the limit curves are exceeded, then the power will be reduced to the previous level that showed acceptable steady state vibration. For the potential frequencies that exceed the limits curves, specific analyses will be performed for the replacement steam dryer to confirm structurally acceptability and revised limit curves will be provided.

(viii) At each 5% increment in power above 100% CLTP (e.g.,

105%, and 110%), preliminary summary reports will be provided to the NRC, prior to proceeding with the power ascension.

44 C.2.2(2)(a) "... with an instrumented steam dryer, ....determine the Information regarding compliance with this requirement is steam dryer stress from the direct instrumentation, and proprietary to WEC, see Enclosure 9.

compare that stress to the applicable limit curves considering bias errors and random uncertainties, as applicable. ... without an instrumented steam dryer, calculate the steam dryer stress using data from steam system instrumentation, and considering appropriate bias errors and random uncertainties."

L-MT-1 0-046 , Appendix 1 Page 17 of 19 Item RG 1.20 RG. 1.20, Rev. 3 Requirement NSPM Compliance including

1. section Reference Document 45 C.2.2(2)(a) "... provide a summary of its evaluation of plant startup The Power Ascension Test Plan contains requirements for and power ascension to the NRC staff within 90 days of this reporting (see Enclosure 1, Appendix 5). See reactor criticality. If full licensed power is not achieved in Commitment #11 for this requirement.

that time period, ... provide a supplemental report within 30 days of achieving full licensed power."

46 C.2.2(2)(b) "... specify the planned duration of all testing in normal Qualification of the reactor internals was'performed in the operating modes to ensure that the testing will subject original EPU analysis and is unchanged by the RSD. See L-each critical component to at least 106 cycles of vibration MT-08-052, Enclosure 5, Section 2.2.3 for further details.

(i.e., computed has at component a the lowest structural significant frequency response) for which the prior to As regarding the RSD, based on MSL SG baseline data the final inspection of the reactor internals." previously collected for MNGP and the expectation that EPU will not result in the onset of any acoustic phenomenon, the duration of the power ascension plus the hold point will ensure that at least 106 cycles of vibration will occur. The typical frequency range of interest is 0 - 250 Hz. If 200 Hz is conservatively used, the number of vibration cycles that corresponds to 200 Hz is 17.28x10 6 cycles in one day. Thus, the duration of the power ascension is adequate to ensure 106 cycles.

47 C.2.2(2)(c) ... address the disposition of fuel assemblies." Qualification of the reactor internals was performed in the original EPU analysis and is unchanged by the RSD. See L-MT-08-052, Enclosure 5, Section 2.2.3 for further details.

NSPM has determined that the RSD will not affect the steam flow through the fuel. Based on the previous EPU submittal described above, the fuel was shown to be adequate for EPU operating conditions. Since the RSD does not change any of the operating conditions for the fuel, no further evaluation is required for.the fuel assemblies.

L-MT-10-046 , Appendix 1 Page 18 of 19 Item RG 1.20 RG. 1.20, Rev. 3 Requirement NSPM Compliance including

1. section Reference Document 48 C.2.3 "The inspection program submittal should include the The Power Ascension Test Plan contains requirements for following information: inspection of the steam dryer. See Enclosure 1, Appendix 5 (1) ... local areas to be inspected, including the following for details.

details:...

(e) those critical locations on the reactor internal components as identified by the vibration analysis, such as the steam dryers in BWRs (f) the interior of the reactor vessel for evidence of loose parts or foreign material (2) tabulation of specific inspection areas that can be used to verify segments of the vibration analysis and measurement program.

(3) description of the inspection procedure, including the method of examination (e.g., visual and nondestructive surface examinations), method of documentation, provisions for access to the reactor internals, and specialized equipment to be employed during the inspections to detect and quantify evidence of the effects of vibration" 49 C.2.4(1) "The preliminary report should summarize an evaluation of The Power Ascension Test Plan contains requirements for the raw and, as necessary, limited processed data and the this reporting (see Enclosure 1, Appendix 5). See results of the inspection program with respect to the test Commitment #11 for this requirement.

acceptance criteria. Anomalous data that could bear on the structural integrity of the reactor internals should be identified, as should the method to be used for evaluating such data."

L-MT-10-046 , Appendix 1 Page 19 of 19 Item RG 1.20 RG. 1.20, Rev. 3 Requirement NSPM Compliance including

1. section Reference Document 50 C.2.4(2) ... final report should include the following information: The Power Ascension Test Plan contains requirements for (a) description of any deviations from the specified -this reporting (see Enclosure 1, Appendix 5). See measurement and inspection programs, including Commitment #11 for this requirement.

instrumentation reading and inspection anomalies, instrumentation malfunctions, and deviations from the specified operating conditions (b) comparison between measured and analytically determined modes of structural response (including damping factors) and hydraulic response (including those parameters from which the input forcing function is determined) for the purpose of establishing the validity of the analytical technique (c) determination of the margins of safety associated with operation under normal steady-state and anticipated transient conditions, including themargins ofsafety associated with any flow-excited acoustic or structural resonances (d) evaluation of unanticipated observations or measurements that exceeded acceptable limits not specified as test acceptance criteria, as well as the disposition of such deviations" 51 C.2.4(3) "If(a) inspection of the reactor internals reveals defects, This Item is applicable to reactor internals and not applicable evidence of unacceptable motion, and/or excessive or to the steam dryer qualification. Qualification of the reactor undue wear; (b) the results from the measurement internals was performed in the original EPU analysis and is program fail to satisfy the specified test acceptance unchanged by the RSD. See L-MT-08-052, Enclosure 5, criteria; or (c) the results from the analysis, measurement, Section 2.2.3 for further details. Reporting of the structural and inspection programs are inconsistent, the final report adequacy of the steam dryeris adequately covered in items -

should also include an evaluation and description of the 49 and 50.

modifications or actions planned in order to justify the structural adequacy of the reactor internals."

L-MT-1 0-046 , Appendix 2 Page 1 of 11 APPENDIX 2 APPLICABILITY OF PREVIOUSLY UNANSWERED NRC REQUESTS FOR INFORMATION FOR THE MONTICELLO NUCLEAR GENERATING PLANT REPLACEMENT STEAM DRYER

L-MT-1 0-046 , Appendix 2 Page 2 of 11 Appendix 2 The purpose of this appendix is to provide answers to NRC requests for additional information (RAIs) related to the MNGP steam dryer that have not been previously answered. Previously, answered EPU RAIs have been reviewed for impact by the RSD. This review is documented in Appendix 3 to Enclosure 1 of this letter.

NSPM received two sets of RAIs from the NRC related to the MNGP currently installed steam dryer (CISD) that have not been previously answered. One set was dated November 27, 2009 and the other set was dated March 4, 2010. Responses to each set of RAIs are provided below.

Steam Dryer RAIs dated November 27, 2009 On November 27, 2009, Northern States Power Minnesota (NSPM) received an email from the NRC project manager for MNGP (reference 1)'. The email contained the questions below. These questions were based on the CISD and thus some of the questions or portions of questions are no longer applicable. NSPM is providing a response based on the replacement steam dryer (RSD) as described in this supplement to the Extended Power Uprate (EPU) license amendment request (LAR).

Below are the NRC questions and the NSPM responses:

RAI - EMCB-SD-RAI 2 S01 (a)

In its response to EMCB-SD-RAI-2, NPSM discussed three techniques that were applied to justify the removal of signals from the main steam line (MSL) data at frequencies between 14 and 34 Hz, attributingthem to pipe vibration modes. The explanation under Technique 3 is not clear. The licensee is requested to clarify the explanation for Technique 3 with examples and figures, and a more detailed explanation, to justify the removal of signals from the MSL data between frequencies between 14 and 34 Hz.

NSPM Response:

The methods for removal of signals for the RSD are discussed in Enclosure 2. The RSD design complies with Regulatory Guide (RG) 1.20 as demonstrated in Appendix 1 of Enclosure 1 to this letter, which ensures that the RSD meets NRC requirements.

RAI - EMCB -SD-RAI 2 S01 (b)

NSPM acknowledges that 38 of the 64 MSL strain gages have failed. NSPM has not yet positively identified a reason for the failures, but has replaced 18 of the failed gages.

The NRC staff requests that NPSM identify the locations and the correspondingnumber of strain gages that failed during CL TP data acquisition. In addition, NSPM should also provide a strongerjustification, substantiatedby in-plant demonstrations,that sufficient

L-MT-10-046 , Appendix 2 Page 3 of 11 strain gages will be operationalduring EPU power ascension to ensure that the limit curves are not violated.

NSPM Response:

MSL strain gauges provided an input to the design of the RSD. However, the MSL strain gauges also play an important part in the validation of the design of the RSD. As such, NSPM intends to begin start up from the 2011 refueling outage with 64 operating strain gauges. However, is not very likely that all 64 strain gauges will be operational after startup. Industry OE indicates that most plants have had significant numbers of strain gauge failures during startup activities.

The RSD Power Ascension Test Plan (RSD - PATP) contains the requirement that if during startup activities above CLTP conditions (section C testing) the number of active MSL strain gauges is less than one strain gauge at each location, then NSPM will stop start up activities. In this condition, repair activities will commence and RSD - PATP activities above CLTP will resume when strain gauges function has been returned.

RAI - EMCB-SD-RAI 8 S01 In Enclosure 3 of L-MT-09-043, NSPM responded to EMCB-SD-RAI-8 stating, that optimal MSL strain gage arrayspacing is used to minimize errorsnear the peak standpipe frequency, and therefore, the bias errorand uncertaintynear the standpipe resonance frequency (158 to 162 Hz) can be changed from those based on the QC2 benchmarking tests. The NRC staff notes that changing the distance (L) between the strain gage measurement locations would not only affect (e.g., reduce) the bias errorat the frequency ranges for which the distance L is optimized, but would also influence the errors (e.g., increase)for many other frequency ranges for which the distance L is not optimal. These changes in the bias errorand uncertainty must be assessedfor the whole frequency range (not only for a selected range) and must be validated by in-plant measurements. Therefore, the NRC staff cannot approve the use of a negative bias errorof 59.7% for some frequency ranges in the Monticello EPU stress analysis without an in-plant validation of the bias errors and uncertainties at the other frequency ranges.

The licensee is requested to provide the following:

(a) updated dryer stress margins based on a positive bias errorof 65% and an uncertainty of 10% for frequencies between 158 and 162 Hz, and (b) updated limit curves reflecting this bias errorand uncertainty.

NSPM Response:

(a) Dryer stress margins are provided in Enclosures 2 and 3 to this letter.

(b) Limit curves are provided in Enclosure 7 to this letter.

L-MT-10-046 , Appendix 2 Page 4 of 11 RAI - EMCB-SD-RAI 10 S01 In Enclosure 3 of L-MT-09-043, NSPM responded to EMCB-SD-RAI 10, stating that it is notjustifiable to introduce a change in the frequency intervals for bias and uncertainty computation. NSPM provided the following arguments in declining to perform the requested stress computations:

(a) The high alternatingstress ratio of 2.0 accounts for any non-conservatisms that may be associatedwith the choice of frequency intervals used to benchmark the ACM model.

(b) Changing the frequency intervals would require recalibrationof the ACM model.

The NRC staff does not find the above two arguments to be acceptable. The above mentioned stress ratio of 2 is required to account for othersources of errors and uncertainties. Additionally, the NRC staff does not see any reason to recalibratethe ACM model if the frequency intervals are changed.

Finally,in the response to the RAI, NSPM speculates that the end results of the requested additionalcomputations would not affect the qualification of the dryer, and the predicted stress ratios would not differ significantlyfrom the ones obtained from the present computations. The NRC staff requests that NSPM confirm that the end results are not affected, by the means of stress computations based on dividing the frequency interval of 60 to 100 Hz into the two intervals: 60 to 70 Hz and'70 to 100 Hz, with the appropriatebias errorsand uncertainties. The licensee is also requested to updated the stress results in the CDI report 07-26P, to reflect the changed bias errors and uncertainties.

NSPM Response:

The RSD is designed to meet RG 1.20 requirements which provides a stress ratio of 1.0. Calibration of the ACM model is provided in Enclosure 2. In Reference 3, 1, Attachment Ill, NSPM provided a stress assessment report of the CISD.

The stress assessment report prepared by Continuum Dynamics, Inc. (CDI) report 07-26P, Revision 1, "Stress Assessment of Monticello Steam Dryer." is not applicable to the MNGP RSD. This report is superseded by Enclosure 2 to this LAR supplement. In addition, Enclosure 1, Appendix 1 discusses use of steam dryer instrumentation to confirm ACM loads and to ensure that FEA results remain conservative.

RAI - EMCB-SD-RAI 11 Sa1 In Enclosure 3 of L-MT-09-043, NSPM responded to EMCB-SD-RAI 11 and submitted the tabulated results of the stress computations with and without low flow noise. While this response complies with the NRC staff's request to include the low flow noise from the stress computation (EMCB-SD-RAI- 5), it does not account for two of the three main concerns expressed in the RAI, namely:

L-MT- 10-046 , Appendix 2 Page 5 of 11 (a) The dryer loads at frequencies between 158 and 162 Hz are unjustifiably reduced (RAI 8 SO1), and (b) The uncertainties and bias errorin the frequency range of 60 to 100 Hz are not subdivided into two frequency intervals (RAI 10 SO 1).

However, the NRC staff finds that the reduced FE model uncertainty (see EMCB-SD-RAI-9) is now acceptable because the licensee provided adequatejustification for using mean overall bias plus uncertainty that is based on optimized damping in shaker tests.

Please provide the stress ratios at EPU conditions for calculations that account for the two concerns mentioned above that are based on dryer loads with the inclusion of low flow noise.

NSPM Response:

This RAI describes questions associated with the CISD. NSPM, as described in reference 2, intends to remove the CISD and install the RSD. Data included in enclosures 2, 3, 4, 5, 6, 7, 8 and 9 provide information on the evaluations performed for qualification of the RSD at CPPU conditions. In addition, Enclosure 1, Appendix 1 discusses use of steam dryer instrumentation to confirm ACM loads and to ensure that FEA results remain conservative.

RAI - EMCB-SD-RAI 11 S02 As mentioned in the response to RAI 11, NPSM has followed ASME Code Section///,

Subsection NG, Table NG-3352-1, for calculating the alternatingstresses at the fillet weld. According to this table, the alternatingstress at fillet welds is equal to the estimated nominal stresses at the fillet weld multiplied by the fatigue strength reduction factor of 4.0. The licensee is requested to explain how the nominal stresses at the fillet weld were estimated. Specifically, explain whether the nominal stresses from the surroundingelements are extrapolatedto the weld line to determine the maximum nominal stress at the weld. Please also explain whether there are any undersized welds in the Monticello steam dryer. If so, provide dimensions and locations of those welds and explain how the presence of the undersized welds is accounted for in calculatingthe fatigue stresses.

NSPM Response:

This RAI describes a question associated with the CISD. NSPM, as described in reference 2, intends to remove the CISD and install the RSD. Data included in enclosures 2, 3, 4, 5, 6, 7, 8 and 9 provide information on the evaluations performed for qualification of the RSD at CPPU conditions.

L-MT-1 0-046 , Appendix 2 Page 6 of 11 RAI - EMCB-SD-RAI 15 SOI The NRC staff requests that NPSM revise its power ascension procedure if Limit I curve is violated and the evaluation requires a revised stress analysis and correspondingnew limit curves to resolve the violation. The revision may allow 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> for the NRC staff to review and approve the evaluation before the licensee can further increase the reactorpower above CL TP.

NSPM Response:

NSPM will revise the power ascension procedure to return to an acceptable power level (e.g., one that had acceptable limit curve evaluations) if a level 1 limit curve is exceeded. Appropriate calculations / evaluations will be completed and transmitted to the NRC. Upon transmission NSPM will continue power ascension.

RAI - EMCB-SD-RAI 17 S01 (a) The licensee states that all three indicationsin the steam dryer end plates are non-branched and fully contained within the weld, suggesting a fatigue type crack. The licensee further states that the fabrication records indicate that these cracks are facilitatedby residualstresses developed during the welding sequence. The high residual stresses, which act as a high mean stress, would tend to promote fatigue crack initiation under cyclic loading conditions. The NRC staff accepts the licensee's explanation about the role of high mean stress in the initiation of fatigue cracks, but such initiationstill requires alternatingstresses with a minimum amplitude of 13,600 psi. Note that this value of the alternatingstress amplitude is from the Design Fatigue Curve C in Fig. 1-9.2.2, ASME Section III, Division 1, Appendix I. This curve includes the effect of maximum possible mean stress (i.e.,

yield stress of the material). Therefore, the stress analysis results presentedin CDI Report 07-26P are inconsistent with the cracking experience discussed here, and are possibly non-conservative and inaccurate. The NRC staff requests that NSPM revise the stress analysis so that its results are consistent with the cracking of the steam dryer end plate.

(b) The licensee states that all existing cracks on the steam dryer end plate have been re-inspected at least once and no significantcrack growth has been identified.

Therefore, NSPM concludes that these cracks will not grow at EPU conditions.

The NRC staff does not accept this conclusion at this time because all the RAIs related to stress analysis of the dryer under CL TP conditions have not yet been resolved. The NRC staff requests the licensee to re-perform and re-submit the crack growth analysis under EPU conditions after all the RAIs related to the stress analysis of the Monticello dryer are satisfactorilyresolved.

L-MT-10-046 , Appendix 2 Page 7 of 11 NSPM Response:

This RAI describes questions associated with the CISD. NSPM as described in reference 2 intends to remove the CISD and install the RSD. Data included in enclosures 2, 3, 4, 5, 6, 7, 8 and 9 provide information on the evaluations performed for qualification of the RSD at CPPU conditions.

RAI - EMCB-SD-RAI 17 S02 (a) The licensee describes the cracking observed in the steam dryerguide channel as atypical because it is orientedperpendicularto the weld and proceeds from what appears to be an arc strike to the weld materialjoining the guide channel to the skirt. The postulated initiationmechanism for this flaw is a local stress concentration. However, the explanation of the postulatedcrack initiation mechanism is not clearand it contradictsthe information in the StructuralIntegrity Report (No. 0800760.401, Oct. 2008) submitted as partof the Monticello EPU application. That report mentions that this crack has the characteristicsof a fatigue crack. The licensee is requested to describe the characteristicsof the crack and then explain the mechanism that may have initiatedit.

(b) The licensee states that the three successive inspections of crack in the steam dryerguide channel revealed that this indication has been arrested. Then, the licensee concludes that since the postulated initiation mechanism is unrelated to the operatingpower level, this indication does not warrantany special attention or concern for operation at EPU conditions. It is not clearhow the absence of any crack growth under CLTP conditions implies that this crack does not warrantany attention during the EPU conditions. The licensee is requested to provide a crack growth evaluation of this indicationunder EPU conditions after all the RAIs related to the stress analysis of the dryer are satisfactorilyresolved.

NSPM Response:

This RAI describes a question associated with the CISD. NSPM as described in reference 2 intends to remove the CISD and install the-RSD. Data included in enclosures 2, 3, 4, 5, 6, 7, 8 and 9 provide information on the evaluations performed for qualification of the RSD at CPPU conditions.

RAI - EMCB-SD-RAI 17 S03 The licensee states that inter-granularstress corrosioncracking (IGSCC), in lieu of the high cycle fatigue, is the initiation mechanism for the drain channel cover plate cracking.

The licensee further states that the inspection of these indicationsduring the 2009 Refueling Outage did not identify any observable crack growth. However, an IGSCC crack can grow by cyclic loads if the loads are large enough. The licensee is requested to demonstrate that this crack will not grow by high-cycle fatigue mechanisms under

L-MT-1 0-046 , Appendix 2 Page 8 of 11 EPU conditions. The NRC staff recommends that the licensee respond to this request after all the RAIs related to the stress analysis of the dryer are satisfactorilyresolved.

NSPM Response:

This RAI describes a question associated with the CISD. NSPM as described in reference 2 intends to remove the CISD and install the RSD. Data included in enclosures 2, 3, 4, 5, 6, 7, 8 and 9 provide information on the evaluations performed for qualification of the RSD at CPPU conditions.

L-MT-10-046 , Appendix 2 Page 9 of 11 Steam Dryer RAIs dated March 4, 2010 On March 4, 2010 NSPM received an email from the NRC project manager for MNGP (reference 2). The email contained the questions below. These questions were based on the CISD and thus some of the questions or portions of questions are no longer applicable. NSPM is providing a response based on the RSD as described in this supplement to the EPU LAR.

Below are the NRC questions and the NSPM responses:

EMCB-SD RAI No. 21 The licensee is requested to provide a detailed description (i.e., a step-by-step procedure) of how the QC2 main steam line (MSL) strain gage signals at CL TP were modified (both during and after data acquisition),-beforethey were applied to the ACM Rev. 4 Code (whose results were used for benchmarking), to estimate acoustic loads on the instrumented QC2 dryer. Please also provide a step-by-step comparison of this benchmarking procedure with the procedures used in revising the MSL strain gage signals at CL TP for MNGP.

Additionally, the licensee is requested to provide the following information about any exclusion frequencies:

a) Provide the amplitudes of the QC2 MSL strain gage signals for the exclusion frequencies (60, 120 and 180 Hz) at CLTP conditions before these frequencies were removed or filtered. Discuss which of these frequencies were treatedas exclusion frequencies in modifying the QC2 signals.

b) Provide the information on the QC2 recirculationpump frequency, and provide the amplitudes of the MSL strain gage signals at this frequency. Explain whether this frequency was treated as an exclusion frequency in modifying the QC2 signals.

c) Explain whether any exclusion frequency filtering was also applied to the instrumented QC2 dryer pressure signals.

d) Provide a comparisonof frequencies that were treated as exclusion frequencies in the ACM Rev. 4 benchmarking and MNGP stress analysis. Please also provide an explanation of the differences.

NSPM Response:

This RAI describes a question associated with the CISD. NSPM as described in reference 2 intends to remove the CISD and install the RSD. Data included in enclosures 2, 3, 4, 5, 6, 7, 8 and 9 provide information on the evaluations performed for qualification of the RSD at CPPU conditions. The RSD meets all NRC requirements from Regulatory Guide 1.20. See Enclosure 1, Appendix 1 of this letter for details on compliance with RG 1.20. In addition, Enclosure 1, Appendix 1 discusses use of steam

L-MT-10-046 , Appendix 2 Page 10 of 11 dryer instrumentation to confirm ACM loads and to ensure that FEA results remain conservative.

EMCB-SD RAI No. 22 This RAI pertains to the ((

)) signals from the MSL strain gage signals at CL TP, [f )) the hydrodynamic and acoustic loads on the steam dryer. In a recent conference call with anotherlicensee, on using Revision 4 of the Continuum Dynamics Incorporated(CDI)

Acoustic Circuit Model (ACM), regardingthe extended power uprate (EPU)application, the NRC staff was informed that during the benchmarking of the ACM parameters,by means of the Quad Cities Unit 2 (QC2) data, ((

)) the data used to estimate the steam dryer loads. Therefore, it is non-conservative to apply coherence filtering to the MNGP strain gauge data, priorto computing dryer loads using Rev. 4 of the ACM Code.

The licensee is requested to provide revised steam dryer stress analysis results for EPU conditions based on steam dryer loads ((

)). In addition, the licensee is requested to ensure that the minimum alternatingstress ratio (SR-a) is not less than 2.0 for any dryer component, for the projected EPU conditions.

NSPM Response:

This RAI describes a question associated with the CISD. NSPM as described in reference 2 intends to remove the CISD and install the RSD. Data included in enclosures 2, 3, 4, 5, 6, 7, 8 and 9 provide information on the evaluations performed for qualification of the RSD at CPPU conditions. The RSD meets all NRC requirements from Regulatory Guide 1.20. See Enclosure 1, Appendix 1 of this letter for details on compliance with RG 1.20. In addition, Enclosure 1, Appendix 1 discusses use of steam dryer instrumentation to confirm ACM loads and to ensure that FEA results remain conservative.

EMCB-SD RAI No. 23 Contrary to the staff's understandingof the methodology employed in ACM Rev. 4 benchmarking, based on the QC2 data, various BWR plants are using an approach that would result in under-predictionof dryerloads by considerationof the following items:

(1) filtering of low flow noise (plantbackgroundnoise), (2) filtering of EIC signals, and (3) coherence filtering. The licensee is requested to identify any other inconsistenci6s, as appropriate,with the QC2 benchmarking procedure that the staff is unaware of. In addition, please describe the impact of those inconsistencieson the minimum alternatingstress ratio for the projected EPU conditions.

L-MT-1 0-046 , Appendix 2 Page 11 of 11 NSPM Response:

This RAI describes a question associated with the CISD. NSPM as described in reference 2 intends to remove the CISD and install the RSD. Data included in enclosures 2, 3, 4, 5, 6, 7, 8 and 9 provide information on the evaluations performed for qualification of the RSD at EPU conditions. The RSD meets all NRC requirements from Regulatory Guide 1.20. See Enclosure 1, Appendix 1 of this letter for details on compliance with RG 1.20. In addition, Enclosure 1, Appendix 1 discusses use of steam dryer instrumentation to confirm ACM loads and to ensure that FEA results remain conservative.

References 1 Email from Peter, Tam (NRC) to Lynne Gunderson, Gabor Salamon, Kurt T.

Schaefer, (NSPM),

Subject:

"Monticello - Second round RAI on steam dryer for the proposed EPU amendment (TAC MD9990)," dated November 27, 1999.

2 Emailfrom Peter, Tam (NRC) to Lynne Gunderson, Kurt T. Schaefer, (NSPM),

Subject:

"Monticello- Additional draft RAI re. steam dryer structural integrity for EPU (TAC MD9990)," dated March 4, 2010.

3 Letter from Northern States Power Company, a Minnesota corporation (NSPM),

to Document Control Desk (NRC), "License Amendment Request: Extended Power Uprate," L-MT-08-052, dated November 5, 2008. (ADAMS Accession No. ML083230111)

L-MT-1 0-046 , Appendix 3 Page 1 of 25 APPENDIX 3 EVALUATION OF CHANGES TO EPU DOCUMENTATION BASED ON USE OF THE REPLACEMENT STEAM DRYER

L-MT-1 0-046 , Appendix 3 Page 2 of 25 The purpose of this table is to provide an overview of changes that are made to the MNGP EPU application and associated RAI responses and supplements based on the changes in analysis for the RSD. The first two columns in the table below lists the location of text that describes the steam dryer (CISD) and analyses that use CISD parameters. The third column describes the contents that are under review. The final column dispositions the text under review and describes any actions or resolutions that were identified.

Letter No. Locations Applicable Contents/issues Required Actions or Resolution ADAMS No. Evaluated L-MT-08-052, Cover letter, pg 3 The cover letter states: This text is hereby superseded by the text EPU LAR "Enclosure 11 provides the Steam Dryer Dynamic Stress of this supplement cover letter. As ML083230111 Evaluation. This enclosure summarizes the analyses described below, portions of Enclosures 11 performed to demonstrate the structuraladequacy of the to L-MT-08-052, are superseded by the MNGP steam dryer at EPU conditions. Enclosure 11 contains analyses provided in Enclosures 2- 9 of information which is proprietaryto Continuum Dynamics this letter. An equivalent introductory Incorporated(CDI). CDI requests that this proprietary paragraph is provided in this supplement information be withheld from public disclosure in accordance cover letter to address the RSD. Enclosure with 10 CFR 2.390(a)4 and 9.17(a)4. An affidavit supporting 12 (affidavit) is still applicable to proprietary this request is provided in Enclosure 12. Enclosure 13 portions of Enclosure 11 that remain in contains the non-proprietaryversion of the Steam Dryer effect. Enclosure 13 is nonproprietary and Dynamic Stress Evaluation." is essentially superseded by Enclosures 2 -

9 of this letter.

This cover letter section does not provide any technical discussion and therefore, does not need to be modified. This text will be retained for historical purposes.

L-MT-08-052, Cover letter, pg 4 The commitment states: The commitment is applicable to the CISD, EPU LAR commitment "NSPM will inspect the steam dryer during the next refueling and was completed during the 2009 ML083230111 outage to confirm no unexpected changes in crack length on refueling outage. Therefore, this the steam dryer." commitment is no longer required. See Enclosure 11 of this letter for details on this commitment.

L-MT-1 0-046 , Appendix 3 Page 3 of 25 Letter No. Locations Applicable Contents/issues Required Actions or Resolution ADAMS No. Evaluated L-MT-08-052, Enclosure 1, pg 1 Page 1 states: The portion of this statement that is EPU LAR "As part of the MNGP EPU request, NSPM is also proposing evaluated for the RSD is reactor internal ML083230111 changes to the licensing basis for methodology used for pressure differentials (RIPD). The RIPD containment analysis,credit for use of containment methodology for the CISD is based on the overpressure for net positive suction head (NPSH) for low air test data for BWR6 steam dryer pressure Emergency Core Cooling System (ECCS)pumps, methodology, whereas the RIPD for the and reactorinternalpressure differentials for the steam dryer." RSD is based on the WEC methodology described in Enclosure 1, section 4.1 of this letter.

This statement is valid for both the CISD and the RSD, and thus, no change is required. NSPM is still requesting a change in methodology from the BWR6 methodology to the WEC methodology.

L-MT-08-052, Enclosure 1, pg 4 Page 4 states "ReactorInternal Pressure Differentials (RIPDs) The text is revised to eliminate discussion EPU LAR for the Steam Dryer The effects on reactorinternalloads as a of the BWR3 methodology as applicable to ML083230111 result of EPU were evaluated. The increase in core power the EPU. This is no longer correct based generally results in increasedRIPDs for reactorinternals due on the RI PD for the RSD having been to the higher core exit steam quality. The RIPDs for the steam evaluated to a WEC methodology found in dryer in the EPU analysis are reduced from those used in the Enclosure 1, section 4.1 of this letter.

current analyses. NRC approval is requested for this change Therefore, the following statement will be since it is a change to the current licensing basis for analytical deleted: The EPU methodology is based methods used for evaluation of the loads for the reactor on a more realisticcorrelation for a BWR3 internals. The EPU methodology is based on a more realistic steam dryer insteadof air test data for correlationfor a BWR3 steam dryer instead of air test data for BWR6 steam dryers. The subsequent BWR6 steam dryers. The change methodology for statement is still applicable as text in determining steam dryer RIPDs is described in Enclosure 5, Enclosure 5, section 2.2.3 will be modified Section 2.2.3." as described below. (see L-MT-08-052, Enclosure 5, section 2.2.3)

L-MT-10-046 , Appendix 3 Page 4 of 25 Letter No. Locations Applicable Contentsllssues Required Actions or Resolution ADAMS No. Evaluated L-MT-08-052, Enclosure 1, pg Page 26 is part of the Evaluation of Proposed Changes, which The text is revised to eliminate discussion EPU LAR 26 states: of GE Hitachi proprietary information as ML083230111 "ReactorInternal Pressure Differentials for the Steam Dryer applicable to the steam dryer. This is The technicalbases for the change in steam dryer RIPDs incorrect based on the RIPD for the RSD used in the reactorvessel internalload evaluation includes having been evaluated to a WEC information proprietaryto GE Hitachi and are discussed in methodology found in Enclosure 1, section Enclosure 5, Section 2.2.3." 4.1 of this letter.

Therefore, this statement will be revised to read as follows: "The technical bases for the change in steam dryer RIPDs used in the reactorvessel internal load evaluation includes information from Westinghouse Electric Corporation(WEC) and are discussed in Enclosure 5, Section 2.2.3."

L-MT-08-052, Enclosure 1, pg Page 28 is part of the No Significant Hazards Consideration The statements in question 1 of the NSHC EPU LAR 28 (NSHC) evaluation for question 1, where it addresses regarding the evaluation of change in RIPD ML083230111 "ReactorInternal PressureDifferentials (RIPDs) for the Steam methodology are still correct and Dryer." applicable. No change to this text is required.

L-MT-08-052, Enclosure 1, pg Page 29 is part of the NSHC evaluation for question 2, where The statements in question 2 of the NSHC EPU LAR 29 it addresses "ReactorInternal Pressure Differentials (RIPDs) regarding the evaluation of change in RIPD ML083230111 for the Steam Dryer." methodology are still correct and applicable. No change to this text is required.

L-MT-08-052, Enclosure 1, pg Page 31 is part of the NSHC evaluation for question 3, where The statements in question 3 of the NSHC EPU LAR 31 it addresses "ReactorInternal PressureDifferentials (RIPDs) regarding the evaluation of change in RIPD ML083230111 f6r the Steam Dryer." methodology are still correct and applicable. No change to this text is

__ required.

L-MT-10-046 , Appendix 3 Page 5 of 25 Letter No. Locations Applicable Contents/issues Required Actions or Resolution ADAMS No. Evaluated L-MT-08-052, Enclosure 1, pg Page 33 is part of the Applicable Regulatory Requirements The first two paragraphs of this section are EPU LAR 33 evaluation where it addresses "ReactorInternal Pressure factually accurate as they describe the ML083230111 Differentials (RIPDs) for the Steam Dryer" which states: current USAR design criteria applicable to "Section 1.2 of the Monticello USAR contains principaldesign the CISD. The final paragraph contains the criteriaspecific to Monticello. Section 1.2.1 .a of the USAR proposed change for EPU conditions and states, "The plant is designed, fabricated,erected, and no longer correct information. As operated to produce electricalpower in a safe, reliable, and described above, the BWR3 correlation will efficient mannerand in accordance with applicable codes and not be proposed, rather the WEC regulations." methodology described in Enclosure 1, section 4.1 is proposed.

Section 1.2.2.i of the USAR states, "The reactorcore and Therefore, the following sentence is associated systems are designed to accommodate plant deleted: "The EPU methodology is based operationaltransientsor maneuvers which might be expected on a more realistic correlationfor a BWR3 without compromising safety and without fuel damage." steam dryer instead of air test data for BWR6 steam dryers."

The EPU methodology is based on a more realisticcorrelation The subsequent statement is still for a BWR3 steam dryer instead of air test data for BWR6 applicable as text in Enclosure 5, section steam dryers. The change methodology for determining steam 2.2.3 will be modified as described below.

dryer RIPDS is describedin Enclosure 5, Section 2.2. 3. The The conclusion of the Applicable evaluation indicates that the reactorinternals and core supports will continue to meet the requirements of 10 CFR Regulatory Requirements section is 50.55a and MNGP's currentlicensing basis following implementation of the proposed EPU."

L-MT-08-052, Enclosure 1, pg Page 34 is part of the Environment Consideration,which has a The statement is still valid for the RSD as a EPU LAR 34 part labeled "ContainmentAnalysis Methods Change, methodology change is still proposed, and ML083230111 ContainmentOverpressure for NPSH for Low Pressure ECCS thus, no change is required.

Pumps, and Steam Dryer RIPDs" L-MT-08-052, Enclosure 2, all TS markup for EPU conditions L-MT-08-052, Enclosure 2 is not affected EPU LAR by the RSD. Therefore, no further actions ML083230111 are required.

L-MT-08-052, Enclosure 3, all TS Bases markup for EPU conditions L-MT-08-052, Enclosure 3 is not affected EPU LAR by the RSD. Therefore, no further actions ML083230111 are required.

L-MT-1 0-046 , Appendix 3 Page 6 of 25 Letter No. Locations Applicable Contents/Issues Required Actions or Resolution ADAMS No. Evaluated L-MT-08-052, Enclosure 4, pg 6 The last sentence of Section 2.0 states: This statement should be viewed as a EPU LAR "Additionally,the operatingconditions and performance of the historical statement. L-MT-08-052, ML083230111 steam dryer will be closely monitored to determine if a Enclosure 4 is the "MNGP Extended Power modification or replacement will be necessary to support the Uprate Environmental Assessment." The extended power uprate." statement does not contain any technical information that is subject to change with the RSD.

As described in Enclosure 1, Reference 2 to this letter the change to the RSD improves the radiological conditions (environment) for workers in the plant.

Therefore, this statement has been determined to be correct and no change is required.

L-MT-08-052, Enclosure 5, Figure 1-2 is the nominal 100% power heat balance, which The value used in the heat balance for EPU LAR NEDC-33322P, shows "Carryunder= 0.35%"and "0.49 M" (Moisture %). Moisture is equivalent to Moisture ML083230111 Figure 1-2 Carryover (MCO). This is a bounding value and is verified to be bounding by the analysis described in section 4.1 of Enclosure 1 of this letter.

Carryunder is calculated as part of the separator (not steam dryer) evaluation evaluations. It has a negligible effect on the reactor heat balance, because the calculated steam flow is not dependent on the carryunder fraction. Therefore, the RSD does not affect the heat balance.

Based on the above no change is required to the figure.

L-MT-10-046 , Appendix 3 Page 7 of 25 Letter No. Locations Applicable Contents/issues Required Actions or Resolution ADAMS No. Evaluated L-MT-08-052, Enclosure 5, Figure 1-3 is the 102% power heat balance, which shows The value used in the heat balance for EPU LAR NEDC-33322P, "Carryunder=0.35%" and "0.52 M" (Moisture %). Moisture is equivalent to Moisture ML083230111 Figure 1-3 Carryover (MCO). This is a bounding value and is verified to be bounding by the analysis described in section 4.1 of Enclosure 1 of this letter.

Carryunder is calculated as part of the separator (not steam dryer) evaluation /

evaluations. It has a negligible effect on the reactor heat balance, because the calculated steam flow is not dependent on the carryunder fraction. Therefore, the RSD does not affect the heat balance.

Based on the above no change is required to the figure.

L-MT-08-052, Enclosure 5, The section addresses a technical evaluation of Reactor The steam dryer is made of 316L stainless EPU LAR NEDC-33322P, Internal and Core Support Materials. steel, and thus, is compatible with the ML083230111 S2.1.3 environment and materials within the reactor pressure vessel.

L-MT-08-052, Enclosure 5, The section addresses Reactor Coolant Pressure Boundary The statement is generic to all steam EPU LAR NEDC-33322P, Materials. Page 2-8 refers to inspecting the steam dryer. dryers, and thus, remains valid for the ML083230111 S2.1.4 RSD.

L-MT-08-052, Enclosure 5, The section addresses "Flow-AcceleratedCorrosion." Page 2- The MCO assumed for EPU is 0.5%, while EPU LAR NEDC-33322P, 11 states that moisture content is a variable that influences the predicted MCO for the RSD is < 0.1%.

ML083230111 S2.1.6 & T2.1-3 FAC. Table 2.1-3 "FACParameterComparisonfor EPU" Thus, the PUSAR evaluation results bound includes "Steam Quality (%)." EPU operation with the RSD. Therefore, no change is required.

L-MT-08-052, Enclosure 5, The section addresses "ReactorWater Cleanup System." The values shown in Table 2.1-5 are based EPU LAR NEDC-33322P, Table 2.1-5 "EstimatedEPU Effect on Reactor Water on a 15% increase from CLTP nominal ML083230111 S2.1.7& T2.1-5 Parameters"addresses "Conductivity"and "Iron" content. values without regard to steam dryer performance. Therefore, the PUSAR evaluation results are not affected by the RSD.

L-MT-10-046 , Appendix 3 Page 8 of 25 Letter No. Locations Applicable Contentsllssues Required Actions or Resolution ADAMS No. Evaluated L-MT-08-052, Enclosure 5, Section 2.2.3 addresses "ReactorPressure Vessel Internals 1. The statement is generic to all steam EPU LAR NEDC-33322P, and Core Supports." It states dryers, and thus, remains valid for the ML083230111 S2.2.3, T2.2-5, 1. Page 2-41: "The steam dryer and steam separatorsare RSD.

T2.2-6, T2.2-7, non safety-related components. Failure of a dryer 2. Enclosures 11 - 13 of L-MT-08-052 T2.2-8 component does not represent a safety concern, but can were applicable to the CISD and are result in a large economic effect." and superseded by RSD information found

2. Page 2-41: "A proprietaryevaluation has been in Enclosures 2 - 9 of this letter with performed to characterizedryer stress at EPU conditions the exceptions taken under the considering dynamic loading conditions. This evaluation evaluation of Enclosure 11.

is provided as enclosures 11 (proprietary)and 12 (non- This statement is deleted and proprietary). It concludes that the Monticello steam dryer replaced with the following:

is structurallyadequate for operationat EPU conditions." "Evaluationof the steam dryer is

3. Page 2-45 addresses "Steam Dryer Hold Down Brackets" provided in NSPM letter L-MT and "Steam Dryer Support Brackets." 046."

4. Page 2-48 addresses "Steam Dryer RIPD Methodology." 3. The Steam Dryer Hold Down Brackets and Steam Dryer Support Brackets

5. Page 2-52, Item i) addresses the effects of changes in are evaluated in Enclosure 3, sections loads due to EPU for the steam dryer.

15 and 16 to this letter and found to

6. Page 2-55 addresses "Steam Dryer/Separator be acceptable. Therefore the Performance." acceptability conclusion on Page 2-45

7. Tables 2.2-5, 2.2-6, 2.2-7 and 2.2-8 (pages 2 2-71) remains valid.

provide steam dryer RIPDs. 4. A revised RIPD methodology is included in section 4.1 of Enclosure 1 of this letter. Therefore, this entire section on pg 2-48 of the PUSAR is superseded by the evaluation presented in Enclosure 1, section 4.1 of this letter. The text is revised as follows: "See NSPM letter L-MT 046, Enclosure 1 for information on the replacement steam dryer RIPD methodology."

5. Enclosure 3 of this letter presents an evaluation of primary stresses, primary plus secondary stresses and

L-MT-1 0-046 , Appendix 3 Page 9 of 25 Letter No. Locations Applicable Contentsllssues Required Actions or Resolution ADAMS No. Evaluated cyclic operation, and thus, supersedes the discussions presented on this page of the PUSAR. The text is revised as follows: "See NSPM letter L-MT-10-046, Enclosure I for information on the replacementsteam dryer RIPD methodology."

6. The MCO assumed for EPU is 0.5%,

while the predicted MCO for the RSD is < 0.1%. Thus, the PUSAR evaluation results bound EPU operation with the RSD. For clarity the first two sentences in the second paragraph are replaced with the following: "The evaluation of steam separatorperformance at EPU conditions indicates an increase in moisture carryover will occur. The evaluation of steam dryer performance at EPU conditions is provided in NSPM letter L-MT-10-046, Enclosure 4."

7. The dPs for the RSD are shown. in section 8.3.2 of Enclosure 3 to this letter, and are less than those for the CISD. Therefore, the Tables 2.2-5, 2:2-6, 2.2-7 and 2.2-8 steam dryer results bound EPU operation with the replacement dryer. Each table is revised to remove the incorrect information and add the following note in its place: "4 - See L-MT-10-046, Enclosure 3, section 8.3.2 for value."

L-MT-10-046 , Appendix 3 Page 10 of 25 Letter No. Locations Applicable Contents/Issues Required Actions or Resolution ADAMS No. Evaluated L-MT-08-052, Enclosure 5, Page 2-103 addresses "ReactorWater Level - Low (SCRAM)," The dP across the RSD at EPU conditions EPU LAR NEDC-33322P, and states is less than that for the CISD at CLTP ML083230111 S2.4.1.3, T2.4-1 "Increasedsteam flow through the steam dryer creates an conditions. Therefore, the section 2.4.1.3 increaseddifferential pressure across the steam dryer. If statement is no longer needed, and the reactorwater level drops below the level of the steam dryer Table 2.4-1 Reactor Water Level - Low skirt, resulting steam bypassing the dryer flows past the (SCRAM) analytical limit change is not variable leg reactorwater level instrumenttap and creates a needed. However, the net effect of the Bernoulli effect pressure reduction indicated as a non- lower dryer dP is the reactor low water conservative increase in reactor water level. The analytical level scram will occur at a slightly higher limit for this setpoint has been revised applying this effect as a level. This makes the safety analyses that bias." use that scram slightly more conservative, Table 2.4-1 has a change in the Reactor Water Level - Low and thus, no change is needed.

(SCRAM) analytical limit.

L-MT-08-052, Enclosure 5, The section (pg 2-117, 2-118) addresses the Fire Protection The steam dryer support brackets are EPU LAR NEDC-33322P, safe shutdown analysis, which potentially could be affected by analyzed and can support the weight of the ML083230111 S2.5.1.4 dryer weight and pressure drop. replacement steam dryer (Enclosure 3).

During a blow down, the increased mass of the RSD will liberate more sensed heat to the suppression pool. However, this additional heat load results in a < 0.2 0 F pool temperature increase, and thus, is judged to be insignificant.

The dP across the RSD at EPU conditions is less than the dP across the current dryer at CLTP conditions. The net effect of the lower dryer dP is the reactor low water level scram will occur at a slightly higher level. This makes the safety analyses that use that scram slightly more conservative.

The systems required for safe shutdown are not affected by the dryer change.

Therefore, the Fire Protection safe shutdown analysis is not adversely affected. No change required.

L-MT-1 0-046 , Appendix 3 Page 11 of 25 Letter No. Locations Applicable Contents/issues Required Actions or Resolution ADAMS No. Evaluated L-MT-08-052, Enclosure 5, This section (pg 2-152, 2-153) addresses "Liquid Waste The MCO assumed for EPU is 0.5%, while EPU LAR NEDC-33322P, Management Systems," and provides specific values that the predicted MCO for the RSD is < 0.1%.

ML083230111 S2.5.5.2 could change due to the RSD. Thus, the PUSAR evaluation results bound EPU operation with the RSD. Therefore, no change is required.

L-MT-08-052, Enclosure 5, The Section 2.6.3 (pgs 2-177, 2-178) addresses "Mass and During the blow down, the increased mass EPU LAR NEDC-33322P, Energy Release," and Section 2.6.5 (2-181 186) of the RSD will liberate more sensed heat ML083230111 S2.6.3, S2.6.5 addresses "ContainmentHeat Removal" performance. to the suppression pool. However, this and associated additional heat load results in a < 0.2 0 F tables and figures pool temperature increase, and thus, is judged to be insignificant. No change required.

L-MT-08-052, Enclosure 5, The section 2.8.2 (pg 2-239) addresses "NuclearDesign, "i.e., Fuel performance is not expected to be EPU LAR NEDC-33322P, fuel performance." affected by the RSD, however, fuel ML083230111 S2.8.2 performance issues are evaluated and resolved as part of the core reload analyses. No change required.

L-MT-08-052, Enclosure 5, The section 2.8.3 (pg 2-244 247) addresses "Thermal- Thermal-hydraulic instability detection, EPU LAR NEDC-33322P, Hydraulic Design," i.e., stability, mitigation and effects are not expected to ML083230111 S2.8.3, S2.8.3.3 be affected by the RSD, however, stability issues are evaluated and resolved as part of the core reload analyses. No change required.

L-MT-1 0-046 , Appendix 3 Page 12 of 25 Letter No. Locations Applicable Contentsllssues Required Actions or Resolution ADAMS No. Evaluated L-MT-08-052, Enclosure 5, These sections (pgs 2-254, 2-255, 2-266 269, 2-271, 2-273 The steam dryer support brackets are EPU LAR NEDC-33322P, 278, 2-280, 2-282, 2-284, 2-285, 2-287 and 2-289) analyzed and can support the weight of the ML083230111 S2.8.4.2, S2.8.5, address the transient analyses, which potentially could be replacement steam dryer.

S2.8.5.1, affected by dryer weight and pressure drop. During a blow down, the increased mass of S2.8.5.2, the replacement steam dryer will liberate S2.8.5.3, more sensed heat to the suppression pool.

S2.8.5.4, However, this additional heat load results S2.8.5.5, in a < 0.2 0 F pool temperature increase, S2.8.5.6.1 and thus, is judged to be insignificant.

The dP across the replacement steam dryer at EPU conditions is less than the dP across the current dryer at CLTP conditions, and about the same as that for the current dryer at OLTP. The net effect of the lower dryer dP is the reactor low water level scram will occur at a slightly higher level. This makes the safety analyses that use that scram slightly more conservative.

The systems required for transient mitigation are not affected by the dryer change. Therefore, the transient analyses are not adversely affected.

L-MT-08-052, Enclosure 5, The section addresses Recirculation System performance, Carryunder is calculated as part of the EPU LAR NEDC-33322P, which can be affected by carryunder and dryer drain flow. separator (not steam dryer) evaluation ML083230111 S2.8.4.6 evaluations. The basis for carryunder, as shown in the EPU heat balance, is not changed. Drain down flow may slightly increase due to the -0.4% decrease in MCO, however, this will have a negligible affect on Recirculation System available NPSH.

L-MT-1 0-046 , Appendix 3 Page 13 of 25 Letter No. Locations Applicable Contents/issues Required Actions or Resolution ADAMS No. Evaluated L-MT-08-052, Enclosure 5, The section (pgs 2-291 295) addresses ECCS-LOCA For the limiting LOCA event the reactor EPU LAR NEDC-33322P, performance. The steam dryer affects SAFER input in water level drops immediately following the ML083230111 S2.8.5.6.2 three areas: 1) Vessel internal metal stored energy, 2) break and the dryer heat slab does not Initial vessel water inventory, and 3) Vessel steam dome transfer its stored energy to the fluid inside volume. the vessel, therefore there is no impact on the ECCS-LOCA Licensing Basis PCT.

Reduction in the dryer dP will increase the initial water level inside the dryer skirt (and consequently the overall initial vessel water inventory) which would slightly reduce the calculated PCT and the current ECCS-LOCA analysis results would still be applicable. Small changes in the dryer dP are not expected to affect the core flow coastdown result and consequently will have no impact on the ECCS-LOCA Licensing Basis PCT. SAFER and LAMB results are not impacted by free volume and dP changes associated with the RSD.

Therefore, no change is required.

L-MT-08-052, Enclosure 5, This section (pgs 2-297 299) addresses the ATWS There is no change to reactor volumes EPU LAR NEDC-33322P, analyses. The ATWS analyses were evaluated for a change used to calculate boron requirements and ML083230111 S2.8.5.7 in dryer weight and a change in pressure drop. therefore no change to these requirements.

Since ATWS events do not assume reactor cooldown, changes to mass and volume for the RSD do not impact containment response. There is no impact to system capability or operator actions used to mitigate an ATWS event. Therefore there no change to the existing analysis is required.

L-MT-10-046 , Appendix 3 Page 14 of 25 Letter No. Locations Applicable Contents/issues Required Actions or Resolution ADAMS No. Evaluated L-MT-08-052, Enclosure 5, The section addresses "Source Terms for Radwaste Systems The MCO assumed for EPU is 0.5%, while EPU LAR NEDC-33322P, Analyses." the predicted MCO for the RSD is < 0.1%.

ML083230111 S2.9.1 Page 2-334 addresses "Activated Corrosion Products and Thus, the PUSAR evaluation results bound Fission Products,"and states: EPU operation with the RSD. Therefore, "Fissionproducts in the reactorcoolant are separable into the no change is required.

products in the steam and the products in the reactorwater.

The activity in the steam consists of noble gases released from the core plus carryoveractivity h m the reactor water.

This activity is the noble gas offgas that is included in the plant design. The calculated offgas rates for EPU after thirty minutes decay are well below the originaldesign basis of 0.26 Curie/sec. Therefore, no change is requiredin the design basis for offgas activity for the EPU."

Also pages 2-335 and 2-336.

L-MT-08-052, Enclosure 5, The section addresses "Occupationaland Public Radiation The MCO assumed for EPU is 0.5%, while EPU LAR NEDC-33322P, Doses." the predicted MCO for the RSD is < 0.1%.

ML083230111 S2.10.1 Page 2-343 addresses "Post-operationradiationlevels," and Thus, the PUSAR evaluation results bound states EPU operation with the RSD. Therefore, "Post-operationradiation levels in most areas of the plant no change is required.

increase by no more than 13 percent. Post-Operation Radiation levels are generally much lower than present during operation. Evaluationswere conservatively performed assuming a large increase in moisture carryover with increasedcarryoverof radioactivityand deposition in BOP systems. This could result in increasedradiationlevels in local areas of BOP piping equipment by as much as 1130' percent (assumes a 13 percent increase in production of contaminantsand a ten-fold increase in carryoverand deposition). This buildup would occur over time. Plant radiationsurveys should provide prompt detection of these conditions."

L-MT-10-046 , Appendix 3 Page 15 of 25 Letter No. Locations Applicable Contentsllssues Required Actions or Resolution ADAMS No. Evaluated L-MT-08-052, Enclosure 5, Table 2.10-1 addresses "Monticello Area Radiation Levels The MCO assumed for EPU is 0.5%, while EPU LAR NEDC-33322P, During Normal Operation," and states "Some very low dose the predicted MCO for the RSD is < 0.1%.

ML083230111 T2.10-1, T2.10-2 areasmay see increaseddeposition due to moisture Thus, the PUSAR evaluation results bound carryover." EPU operation with the RSD. Therefore, Table 2.10-2 addresses "Monticello Post Operation Area no change is required.

Radiation Levels," and states "Dueto increasedmoisture carryoversome areas may see increaseddeposition of radioactivitythat could create focalized increasesup to 1130 percent."

L-MT-08-052, Enclosure 5, The section addresses "Approachto EPU Power Level and These statements are still valid for the EPU LAR NEDC-33322P, Test Plan." Page 2-353 states: RSD. Therefore, no change is required.

ML083230111 S2.12.1 * "Steam separator-dryerperformance will be confirmed to However, compliance with RG 1.20 be within limits by determinationof steam moisture requires more testing for the RSD. The content as required during power ascension testing." additional testing of the RSD for EPU conditions is provided in the RSD - 5PATP

• "Steam dryer-separatorperformance will be confirmed provided in Enclosure 1, Appendix of this content as letter.

within limits by determinationof steam moisture requiredduring power ascension testing."

L-MT-08-052, Enclosure 6, all No technical content - Affidavit for proprietary information in L-MT-08-052, Enclosure 6 is not affected EPU LAR Enclosure 5. by the RSD. Since none of the changes to ML083230111 L-MT-08-052, Enclosure 5 are of a proprietary nature, this document does require reissue based on re-issuance of selected pages of L-MT-08-052, Enclosure 5.

L-MT-08-052, Enclosure 7, NEDO-33322, is a nonproprietary version of Enclosure 5. This document does not require reissue as EPU LAR no proprietary changes have been made.

ML083230111 All changes have been made in Enclosure 5.

L-MT-1 0-046 , Appendix 3 Page 16 of 25 Letter No. Locations Applicable Contents/issues Required Actions or Resolution ADAMS No. Evaluated L-MT-08-052, Enclosure 8, Table 8-3 addresses "EPUPhase II Modifications Plannedfor As stated in L-MT-08-052, Enclosure 8, EPU LAR Table 8-3 2011 (primarilyRF025)." "These tables are provided for information ML083230111 only and are not commitments. The timing and scope of the modifications may change..." Therefore, NSPM does not consider it necessary to update this table to reflect replacement of the MNGP steam dryer.

L-MT-08-052, Enclosure 9; pg 8 Enclosure 9 addresses the EPU Startup Test Plan. Section The statement is valid for the RSD.

EPU LAR 4.2, page 8, states: Therefore, no change is required.

ML083230111 "Steam dryer/separatorperformance will be confirmed within However, compliance with RG 1.20 limits by determination of steam moisture content as required requires more testing for the RSD. The during power ascension testing." additional testing of the RSD for EPU conditions is provided in the RSD - PATP provided in Enclosure 1, Appendix 5 of this letter.

L-MT-08-052, Enclosure 9, Table 1 addresses "Comparisonof MNGP Initial Startup The item is valid for the RSD. Therefore, EPU LAR Table 1, pg 21 Testing and Planned EPU Testing." no change is required. However, ML083230111 The 2 nd line item states: compliance with RG 1.20 requires more "SteamDryer: The purpose of this test is to measure moisture testing for the RSD. The additional testing content in main steam." of the RSD for EPU conditions is provided in the RSD - PATP provided in Enclosure 1, Appendix 5 of this letter.

L-MT-08-052, Enclosure 9, Table 2 addresses "PlannedEPU PowerAscension Testing." This item is valid for the RSD. Therefore, EPU LAR Table 2, pg 27 The 2 nd line item addresses "Steam Dryer/Separator no change is required. However, ML083230111 Performance," and states: compliance with RG 1.20 requires more "Samples will be taken and measurements will be made at testing for the RSD. The additional testing selected EPU power levels to determine steam of the RSD for EPU conditions is provided dryer/separatorperformance (i.e., moisture carryover). For in the RSD - PATP provided in Enclosure this testing main steam line moisture content is considered 1, Appendix 5 of this letter.

equivalent to the steam separator-dryermoisture carryover.

Sampling and analysis will be in accordancewith existing plant procedures."

L-MT-1 0-046 , Appendix 3 Page 17 of 25 Letter No. Locations Applicable Contents/Issues Required Actions or Resolution ADAMS No. Evaluated L-MT-08-052, Enclosure 10, all Enclosure 10 is the "PipingFlow Induced Vibration Monitoring L-MT-08-052, Enclosure 10 is not affected EPU LAR Program." by the RSD. Therefore, no further actions ML083230111 are required.

L-MT-08-052, Enclosure 11, all Enclosure 11 is the "Steam Dryer Dynamic Stress Evaluation," L-MT-08-052, Enclosure 11 of L-MT EPU LAR proprietary version. 052 is superseded in its entirety with ML083230111 equivalent analyses for the RSD, except as follows:

o Enclosure 11, Sections 2 and 3 provide a description of the analytical methods and subscale testing used to analyze the behavior of the SRV standpipes and the instrumentation used on the MSLs.

This is still valid for the RSD.

o Enclosure 11, Attachment I provides the results of the flow induced vibration (FIV) monitoring performed for MNGP.

This is still valid for the RSD.

o Enclosure 11, Attachment II (acoustic model) was used as a subscale test comparison to the acoustic model provided in Enclosure 5 to this letter.

Based on this assessment the following change is made to the cover page for Enclosure 11: "This enclosure contains information regardingthe MNGP steam dryer that is no longer accurate. See NSPM letter L-MT-10-046 for information concerning the MNGP replacementsteam dryer (RSD). Based on review this enclosure is supersededin it entirety with the following exceptions:

o Enclosure 11, Sections 2 and 3 provide a description of the analytical methods and subscale testina used to analyze

L-MT-1 0-046 , Appendix 3 Page 18 of 25 Letter No. Locations Applicable Contents/issues Required Actions or Resolution ADAMS No. Evaluated the behaviorof the SRV standpipes and the instrumentation used on the MSLs.

This is still valid for the RSD.

o Enclosure 11, Attachment I provides the results of the flow induced Vibration monitoring performed for MNGP. This is still valid for the RSD.

o Enclosure 11, Attachment II was used as a subscale test comparison to the acoustic model provided in L-MT 046, Enclosure 5."

L-MT-08-052, Enclosure 12 Enclosure 12 is the "Continuum Dynamics, Inc Affidavit." This Enclosure 12 of L-MT-08-052 is considered EPU LAR is applicable only to Enclosure 11 of L-MT-08-052. historical information. No further action is ML083230111 required.

L-MT-08-052, Enclosure 13, all Enclosure 13 is the "Steam Dryer Dynamic Stress Evaluation," L-MT-08-052, Enclosure 13 is superseded EPU LAR nonproprietary version. in its entirety with an equivalent ML083230111 nonproprietary analysis for the RSD, except for portions noted above for Enclosure 11.

Based on this assessment the following change is made to the cover page for Enclosure 13: "This enclosure contains information regardingthe MNGP steam dryer that is no longer accurate. See NSPM letter L-MT-10-046 for information concerningthe MNGP replacement steam dryer (RSD). Based on review this enclosure is superseded in it entirety with the following exceptions:

o Enclosure 13, Sections 2 and 3 provide a description of the analyticalmethods and subscale testing used to analyze the behaviorof the SRV standpipes and the instrumentationused on the MSLs.

L-MT-1 0-046 , Appendix 3 Page 19 of 25 Letter No. Locations Applicable Contents/issues Required Actions or Resolution ADAMS No. Evaluated This is still valid for the RSD.

o Enclosure 13, Attachment I provides the results of the flow induced vibration monitoringperformed for MNGP. This is still valid for the RSD.

o Enclosure 13, Attachment II was used as a subscale test comparison to the acoustic model provided in L-MT 046, Enclosure 5."

L-MT-08-052, Enclosure 14, all Enclosure 14 is the "MidwestIndependent System Operator L-MT-08-052, Enclosure 14 is not affected EPU LAR (MISO) Grid Stability Study Summary" by the RSD. Therefore, no further actions ML083230111 are required.

L-MT-08-052, Enclosure 15, all Enclosure 15 is the "Identificationof Risk Implications Due to L-MT-08-052, Enclosure 15 is not affected EPU LAR Extended Power Uprate at Monticello" by the RSD. Therefore, no further actions ML083230111 are required.

L-MT-08-052, Enclosure 16, pg Enclosure 16 addresses "Table of Docketed NRC Acceptance L-MT-08-052, Enclosure 16, page 1, only EPU LAR 1 and 6 Review Questions and NMC Response Letters Associated provides historical information, and thus, is ML083230111 with the March 31, 2008 Monticello EPU LAR Submittal." not subject to change. However, L-MT Page 1, 2 nd paragraph states: 052, Enclosure 11 is superseded in its "It should be noted that NSPM acceptance review responses entirety, except as described above.

to NRC questions associatedwith the steam dryer contained L-MT-08-052, Enclosure 16, page 6, in this enclosure may have been superseded by information addresses information with respect to the contained in Enclosure 11." information11.

CISD. This Enclosure MT-08-052, stated in L-..

wasASprovided Page 6, all questions from the Mechanical & Civil Engineering above this information is superseded.

Branch - EMCB except the 4 th question concern issues applicable to the CISD. No changes are required as this is considered historical information.

L-MT-10-046 , Appendix 3 Page 20 of 25 Letter No. Locations Applicable Contents/issues Required Actions or Resolution ADAMS No. Evaluated L-MT-08-052, Enclosure 17, Enclosure 17 is NSPM's responses to NRC review items The portions of L-MT-08-052, Enclosure EPU LAR Attachments and documented in the June 26, 2008 NRC non-acceptance letter. 17, its attachments and appendix and all ML083230111 Appendix, except Pages 1 - 3 of Enclosure 17 address "Steam Dryer Structural references to them that are applicable to Task Report Integrity".for the CISD. Most of the attachments and appendix the CISD, are superseded by Enclosures 2 T1004. to Enclosure 17 address CISD flaws. - 9 of this letter.

EEEB EQ issues are also included in Enclosure 17 and are EEEB EQ issues are not adversely not impacted by the RSD. affected by the RSD, and do not require change.

Based on this assessment the following change is made to the cover page for Enclosure 17: "This enclosure contains information regardingthe MNGP steam dryer that is no longer accurate. See NSPM letter L-MT-10-046 for information concerningthe MNGP replacement steam dryer (RSD). Based on review this enclosure is superseded in it entirety with the following exceptions:

o Task Report T1004 is still applicable.

o EEEB EnvironmentalQualification descriptions are still applicable.

L-MT-08-052, Enclosure 17, Page i only identifies a moisture carryover related change to The MCO assumed for EPU is 0.5%, while EPU LAR Task Report Page 14. the predicted MCO for the RSD is < 0.1%.

ML083230111 T1004, pg i, pg The EPU Inputs/Impacts column states "Normalradiation Thus, the applicable RAI response bounds 14, Item 3 doses under EPU conditions plant-wide based on calculation EPU operation with the RSD. Therefore, CA-08-067 [97]. This calculation includes the EPU moisture no change is required.

carry-overaffects for Reactor Building Volumes 5 and 8 and Turbine Building Volumes 2, 3, 13, 14, 25, 41, 42, and 44 as prescribed in Task Report T0803 [112]."

L-MT-1 0-046 , Appendix 3 Page 21 of 25 Letter No. Locations Applicable Contents/issues Required Actions or Resolution ADAMS No. Evaluated L-MT-08-052, Enclosure 17, Section 3.4.7 addresses a "Normaland Accident Radiation The MCO assumed for EPU is 0.5%, while EPU LAR Task Report Evaluation." The 1 st paragraph has the statement "Under the predicted MCO for the RSD is < 0.1%.

ML083230111 T1004, S3.4.7, EPU, the normal plant doses are generally increasedby 13% Thus, the applicable RAI response bounds pg 53 over CLTP doses while some steam line containing areas also EPU operation with the RSD. Therefore, experience increaseddoses during shut-down due to moisture no change is required.

carry-overissue related to EPU."

L-MT-08-091, Cover letter and The purpose for this letter and enclosure is to provide the L-MT-08-091 (including Enclosure 1) is Acceptance Enclosure 1 Steam Dryer Outer Hood Submodel Analysis applicable to the only applicable to the CISD. Therefore, L-Review CISD. MT-08-091 is superseded in its entirety by Supplement the RSD analyses provided in Enclosures 2 ML083500099 - 9 of this letter.

L-MT-09-002, NA The contents of this letter have been evaluated and it was No further actions are required.

RAI Response determined that this letter is not affected by the change from ML090360545 the CISD to the RSD.

L-MT-09-003, NA The contents of this letter have been evaluated and it was No further actions are required.

RAI Response determined that this letter is not affected by the change from ML090300303 the CISD to the RSD.

L-MT-09-004, NA The contents of this letter have been evaluated and it was No further actions are required.

RAI Response determined that this letter is not affected by the change from ML090710679 the CISD to the RSD.

L-MT-09-005, Cover letter and The purpose for this letter and enclosure is to revise the "Flaw L-MT-09-005 (including Enclosure 1) is LAR Revision Enclosure 1 Evaluation and Vibration Assessment of Existing Monticello only applicable to the CISD. Therefore, L-ML093620023 Steam Dryer Flaws for Extended Power Uprate"for the CISD. MT-09-005 is superseded in its entirety by Enclosure 1 of L-MT-09-005 superseded the CISD flaw the RSD analyses provided in Enclosures 2 evaluation portions of Enclosure 17 of L-MT-08-052. - 9 of this letter.

Environmental qualification portions of Enclosure 17 are still valid and were not revised.

L-MT-09-017, NA The contents of this letter have been evaluated and it was No further actions are required.

RAI Response determined that this letter is not affected by the change from ML090790388 the CISD to the RSD.

L-MT-10-046 , Appendix 3 Page 22 of 25 Letter No. Locations Applicable Contentsllssues Required Actions or Resolution ADAMS No. Evaluated L-MT-09-018, NA The contents of this letter have been evaluated and it was No further actions are required.

RAI Response determined that this letter is not affected by the change from ML090560464 the CISD to the RSD.

L-MT-09-025, NA The contents of this letter have been evaluated and it was No further actions are required.

RAI Response determined that this letter is not affected by the change from ML091130636 the CISD to the RSD.

L-MT-09-026, Enclosure 1, Page 6, item 3 addresses a change in the low reactor water The dP across the RSD at EPU conditions RAI Response response to EICB level scram analytical limit, because increased steam flow at is less than the dP across the CISD at ML091410120 RAI No.1, pg 6, EPU causes increases the differential pressure (dP) across CLTP conditions. The net effect of the item 3, and the current steam dryer. If reactor water level drops below the lower dryer dP is the reactor low water associated level of the steam dryer skirt, resulting steam bypassing the level scram will occur at a slightly higher Attachment 1 dryer flows past the variable leg reactor water level instrument level.

calculation CA- tap and creates a Bernoulli effect pressure reduction indicated This makes the safety analyses that use 95-073 R4 as a non-conservative increase in reactor water level, that scram slightly more conservative.

Therefore, maintaining the analytical limit change, discussed in the RAI response, as conservative. Leaving the calculation unchanged is conservative and appropriate. No change is required.

L-MT-09-026, Response to Paragraph 4.8 states "MNGPEPU Task Report T2005, The MCO assumed for EPU is 0.5%, while RAI Response EICB RAI No. 1, Moisture Carryoverin MSL (ECI 1845). This input evaluates the predicted MCO for the RSD is < 0.1%.

ML091410120 Enclosure 1, the effect of increased moisture carryoveron the main steam Thus, the applicable RAI response bounds Attachment 1, flow instrumentation." EPU operation with the RSD. Therefore, CA-95-075, pg 3 no change is required.

L-MT-09-026, Response to Paragraph 6.5.9 states "Task Report T2005 (Input 4.8) The MCO assumed for EPU is 0.5%, while RAI Response EICB RAI No.1, assessed the effect of increasedmoisture carryoveron the the predicted MCO for the RSD is < 0.1%.

ML091410120 Enclosure 1, main steam flow instrumentationat EPU conditions. The - Thus, the applicable RAI response bounds Attachment 1, increase in measured pressure drop with moisture increase EPU operation with the RSD. Therefore, CA-95-075, pg 13 was found to have an insignificantinfluence on the main no change is required.

steam flow instrumentation."

L-MT-09-027, NA The contents of this letter have been evaluated and it was No further actions are required.

RAI Response determined that this letter is not affected by the change from ML092320064 the CISD to the RSD.

L-MT-10-046 , Appendix 3 Page 23 of 25 Letter No. Locations Applicable Contents/issues Required Actions or Resolution ADAMS No. Evaluated L-MT-09-029, NA The contents of this letter have been evaluated and it was No further actions are required.

RAI Response determined that this letter is not affected by the change from ML091520133 the CISD to the RSD.

L-MT-09-042, Response to RAI question 3 addresses local dose rate increases due to the The MCO assumed for EPU is 0.5%, while RAI Response Reactor increased flows and the increased MCO assumed for the the predicted MCO for the RSD is < 0.1%.

ML091671787 Inspection CISD. Thus, the applicable RAI responses bound Branch RAI 3 EPU operation with the RSD. Therefore, no change is required.

L-MT-09-043, Responses to RAI questions 4, 8 - 20 address issues specific to the CISD (ie RAI responses 4, 8 - 20 are superseded RAI Response EMCB RAIs, stress ratios or cracks in the CISD). These questions are not by analyses performed on the RSD .(see ML092260436 Enclosures 1 relevant to the RSD. enclosures 2 - 9 of this letter). The balance (Nonproprietary) of the RAI questions and responses and 3 continue to be applicable since they cover (Proprietary) instrument signal filtering/conditions.

Based on this assessment the following change is made to the cover page for Enclosure 1 and 3: "RAI responses 4, 8-20 are superseded by analyses performed for the replacement steam dryer. See NSPM letter L-MT-10-046 for the revised analyses."

L-MT-09-044, Response to The response addresses a summary report for the shell and The conclusions in the response are not RAI Response EMCB RAI 25, top head includes a summary of all major discontinuities in the affected by the RSD. No further actions ML092390332 Enclosures 1 & 3, shell and top head, which includes the steam dryer hold down are required.

pgs 39, 40 bracket and support bracket.

L-MT-09-045, EEEB RAIs A portion of the RAIs address environmental qualification The only issues that could be applicable RAI Response (EQ). are radiation doses of which the effects of ML091470559 MCO could be a contributor. However, the MCO assumed for EPU is 0.5%, while the predicted MCO for the RSD is < 0.1%.

Thus, the applicable RAI responses bound EPU operation with the RSD. Therefore, no change is required.

L-MT-10-046 Enclosure 1, Appendix 3 Page 24 of 25 Letter No. Locations Applicable Contents/issues Required Actions or Resolution ADAMS No. Evaluated L-MT-09-046, NA The contents of this letter have been evaluated and it was No further actions are required.

RAI. Response determined that this letter is not affected by the change from ML091670410 the CISD to the RSD.

L-MT-09-047, NA The contents of this letter have been evaluated and it was No further actions are required.

TS Revision determined that this letter is not affected by the change from ML092440171 the CISD to the-RSD.

L-MT-09-048, NA The contents of this letter have been evaluated and it was No further actions are required.

RAI Response determined that this letter is not affected by the change from ML091 the CISD to the RSD.

L-MT-09-049, NA The contents of this letter have been evaluated and it was No further actions are required.

RAI Response determined that this letter is not affected by the change from ML092090219 the CISD to the RSD.

L-MT-09-072, NA The contents of this letter have been evaluated and it was No further actions are required.

Draft SE determined that this letter is not affected by the change from review the CISD to the RSD.

L-MT-09-073, NA The contents of this letter have been evaluated and it was No further actions are required.

RAI Response determined that this letter is not affected by the change from ML092430088 the CISD to the RSD.

L-MT-09-083, Enclosure 1 Enclosure 1 to the referenced letter provided CISD limit L-MT-09-083 (including Enclosure 1) is RAI Response . curves. only applicable to the CISD. Therefore, L-ML092390321 MT-09-083 is superseded in its entirety by the limit curves for the RSD. Limit curves for the RSD are provided in Enclosure 7 to this letter.

L-MT-09-088,-. NA The contents of this letter have been evaluated and it was No further actions are required.

LAR PUSAR determined that this letter is not affected by the change from Rev the CISD to the RSD.

L-MT-09-097, NA The contents of this letter have been evaluated and it was No further actions are required.

Review Delay determined that this letter is not affected by the change from letter the CISD to the RSD.

ML092870159

L-MT-1 0-046 , Appendix 3 Page 25 of 25 Letter No. Locations Applicable Contentsllssues Required Actions or Resolution ADAMS No. Evaluated L-MT-09-1 00, NA The contents of this letter have been evaluated and it was No further actions are required.

M+ to EPU link determined that this letter is not affected by the change from request the CISD to the RSD.

ML093030035 L-MT-1 0-002, NA The contents of this letter have been evaluated and it was No further actions are required.

EPU LAR determined that this letter is not affected by the change from Update the CISD to the RSD.

ML100270020 L-MT-1 0-007, Replacement The letter discusses installation of the RSD under CLTP No further actions are required.

Information Steam Dryer conditions and is not applicable to the EPU licensing process.

Letter Introduction ML100550127

ENCLOSURE10 AFFIDAVITS FOR WITHHOLDING PROPRIETARY DOCUMENTS 68 pages follow

Enclosure 10 Affidavits for Withholding Proprietary Documents The table below provides an index to the affidavits provided within this enclosure. The index correlates the affidavit with the document each affidavit supports.

Letter and Affidavit # Enclosure number - Document number & Name No letter Enclosure 1, Appendix 4 - General Electric -Hitachi GE-Hitachi Nuclear Energy document NEDC-33322P, Revision 3, pages 2-52 Americas LLC Affidavit and 2-55 LTR-EP-1 0-058 Enclosure 2 - WCAP-1 7085-P, Revision 1, "Monticello Affidavit CAW-10-2852 Replacement Steam Dryer Structural Evaluation for High-Cycle Acoustic Loads" LTR-EP-10-063 Enclosure 3 - SES 09-127-P, Revision 2, "Monticello Affidavit CAW-10-2873 Steam Dryer Replacement - Structural Verification of Steam Dryer" LTR-EP-10-053 Enclosure 4 - SES 09-129-P, Revision 2, "Monticello -

Affidavit CAW-10-2860 Steam Dryer Replacement Moisture Carryover Analysis" LTR-EP-10-050 Enclosure 5 - WCAP-17251-P, Revision 0 "Monticello Affidavit CAW-1 0-2857 Replacement Steam Dryer Four Line Acoustic Subscale Testing Report" LTR-EP-10-051 Enclosure 6 - WCAP-17252-P, Revision 0, "Acoustic Affidavit CAW-1 0-2837 Loads Definition for the Monticello Steam Dryer Replacement Project" LTR-EP-10-057 Enclosure 7 - LTR-A&SA-09-32, Revision 2, "Limit Affidavit CAW-1 0-2867 Curves for Monticello Power Ascension During 2011 Outage" No letter Enclosure 8 - LTR-EP-10-059, Revision 1, "Monticello Affidavit CAW-10-2875 Replacement Steam Dryer Differential Pressure Methodology Discussion" No letter Enclosure 9 - LTR-EP-10-062, Revision 1, P-Affidavit CAW-10-2872 Attachment, "Monticello Replacement Steam Dryer Regulatory Guide 1.20, Revision 3, Compliance Matrix, Revision 1"

NEDC-33322P, Revision 3 GEHT Proprietary Information 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 GEH Licensing Topical Report NEDC-33322P, "Safety Analysis Report for Monticello Constant Pressure Power Uprate",

Revision 3, Class III (GEH Proprietary Information), October 2008. GEH proprietary information text in NEDC-33322P Revision 3 is identified by a dark red dotted underline inside double square brackets ((This sentence is an example.:{3 1)). Figures and large equation objects containing GEH proprietary information are identified with double square brackets before and after the object. 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 lbr 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.

NEDC-33322P Revision 3 Affidavit Page I of 3

NEDC-33322P, Revision 3 GEH Proprietary Information 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 2.3 90(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 detailed results and conclusions regarding supporting evaluations of the safety-significant changes necessary to demonstrate the regulatory acceptability of the "Safety Analysis Report for Monticello Constant Pressure Power Uprate" for a GEH Boiling Water Reactor ("BWR"). The analysis utilized analytical models and methods, including computer codes, which GEH has developed, obtained NRC approval of, and applied to perform evaluations of Constant Pressure Power Uprate analysis for a GEH BWR.

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 costL 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.

NEDC-33322P Revision 3 Affidavit Page 2 of 3

NEDC-33322P, Revision 3 GEH Proprietary Information T'he 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 October 2008.

Tim E. Abney Vice President, Services Licensing Regulatory Affairs GE-Hitachi Nuclear Energy Americas LLC NEDC-33322P Revision 3 Affidavit Page 3 of 3

Westinghouse Electric Company*

• Westinghouse Nuclear Services P.O., Box 355 Pittsburgh, Pennsylvania 15230-0355 USA U.S; Nuclear Regilatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (412) 374-3846 Washington, DC 20555-0001 e-mail: gresliaja@westinghouse.com.

Proj letter: LTR-EP-I0-058 CAW-1 0-2852 June 24, 2010 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

WCAP-17085-P, Revision 1, "Monticello Replacement Steam Dryer Structural Evaluation for High-Cycle Acoustic Loads," (Proprietary)

The proprietary information for which withholding is being requested in the above-referenced report is further identified inAffidavit CAW-I*O-2852 signed by the'owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 1.OCFR Section 2.390 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanying affidavit' by Xcel Energy Inc.

Correspondence vith respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference thisletter, CAW-10-2852 and should be addressed to J. A. Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355i Very. truly yours, J. A. Gresham, Manager Regulatory Compliance and Plant Licenising Enclosures.

CAW-10-2852 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally~appeared R. M. Span who, being by me duly sworn according to law, deposes:and says that he is authorized to execute this Affidavit on behalf of Westinhghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this

.Affidavit are true'and correct to the best of his knowledge, information, and belief:

R.M. Span, Principal Engineer Regulatory Compliance and Plant Licensing Sworn 'to and subscribed before me this 24th day of June.2010 Noary Public' COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Renee Giampole, Notary Public Penn Township, Wesatmoroland County My Commission Expires September 25, 2013

2 CAW-10-2852 (1) 1am Principal Engineer, Regulatory Compliance and Plant Licensing, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

(2) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.

Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential 'competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of

3 CAW-10-2852 Westinghouse's competitors without license from Westinghouse constitutes a competitive, economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, 'e.g., by optimization or improved marketability.

(c) Its use 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 a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

There are sound policy reasons behind the Westinghouse system which include the following:

(a) The use of such information by Westinghouse gives Westinghouse acompetitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.

(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

4 CAW-10-2852 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.

(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390; it is to be received in confidence by the Commission.

(iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.

(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP-17085-P, Revision 1, "Monticello Replacement Steam Dryer Structural Evaluation for High-Cycle Acoustic Loads," (Proprietary) dated June 2010, for submittal to the Commission, being transmitted by Xcel Energy letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with the Monticello Extended Power Uprate submittal, and may be used only for that purpose.

This information is part of that which will enable Westinghouse to:

(a) Provide detailed design information to Xcel Energy.

5 CAW-10-2852 Further this information has substantial commercial value as follows:

(a) Westinghouse plans to sell the use of similar information to its customers for purpose of Replacement Steam Dryers.

(b) Westinghouse can sell support and defense of Steam Dryer design.

(c) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar analyses and designs and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.

In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.

Further the deponent sayeth not.

PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.

In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).

COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

Xcel Energy Letter for Transmittal to the NRC The following paragraphs should be included in your letter to the NRC:

Enclosed are:

1. 4 copies of WCAP- I7085-P, Revision 1, "Monticello Replacement Steam Dryer Structural Evaluation for High-Cycle Acoustic Loads," (Proprietary)

2. 2 copies of WCAP-1 7085-NP, Revision 1, "Monticello Replacement Steam Dryer Structural Evaluation for High-Cycle Acoustic Loads," (Non-Proprietary)

Also enclosed is the Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-10-2852, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice.

As Item I contains information proprietary to Westinghouse Electric Company LLC, it is supported by an affidavit signed by Westinghouse, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations.

Accordingly, it is respectfully-requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.

Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse affidavit should reference CAW-10-2852 and should be addressed to J. A. Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.

B Westinghouse Nuclear Services Westinghouse P.O. Box 355 Electric Company Pittsburgh, Pennsylvania 15230-0355.

USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax. (412) 374-3846 Washington, DC 20555-0001 e-mail: greshaja@westinghouseco0m Proj letter !LTR-EP-10-063, Revision I CAW-10-2873 June 29, 2010 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

SES 09-.127-P, Revision 2, "Monticello Steam Dryer Replacement - Structural verification of Steam Dryer" '(Proprietary)

Theproprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-10-2873 signed by the.owner of the proprietary information, Westinghouse. Electric Company'LLC. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4)of 10 CFR Section.2.390 oftthe Commission's regulations.

Accordingly,this letter V1utlolrizes the utilization of the accompanying affidavit by Xce/Energy, inc.

Correspondence with respectto the proprietary aspects of the application for withiholding or the Westinghouse affidavit should reference this letter, CAW-l 0-2873 and should be addressed to J. A. Gresharn, Manager, Regulatory Compliance and Plant Licensing, Westinghlouse .Eletric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.

Very truly yodrs, J. A. Gresham; Manager Regulatory Compliance and Plant: Licensing Enclosures

CAW-10-2873' AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personallyappeared JI A. Gresham, who, being by me. duly sworn according to law, deposes and says that he~is authorized to execute this Affidavit on behalf of Westinghouse Electric Company L_,LC (Westinghouse), and that the averments of fact setfforth in this Affidavit are true and correct to the best of his knowledge, information, and belief:

/J. A. Gresham, Manager Regulatory Compliance and Plant Licensing Sworn to and subscribed before me this 29th day of June 2010 Notary Public

..COMMONWEALTH OF.PIENNSYLVANIA NOiARIAL SEAL Renee Giompole, Notary Public "nn Township, Westmoreland County

-'isslon Expir.SzSeptember 25 2013

2, CAW-10-2873 (1) lai Manager, Regulatory Compliance and Plant Licensing, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing tile proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedingg, and am authorized to-apply for its withholding on behalf of Westinghouse.

(2) I am making this Affidavit in conformance:with the provisions of 10.CFR Section 2.390 of the Commission's regulations andin conjunction with .the.Westinghouse Application for Withholding Proprietary lnformation from Public Disclosure accompanying this Affidavit.

(3) 1have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial. inFormation.

(4) Pursuant to the provisions olfparagraph (b)(4) of Section 2.390 of the .Cop)missioni'sregulations, the following is furnished forconsideration by the Commission in determining wvhether the information sought to bc Withheld fromipublic disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse..

(ii). The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determiining the types of information customnarily held in confidence by it and, in that connection, utilizes a system to determine when and whether.t6 hold certain types of information in

'confidence., Tile application of that'system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.,

Under that system, information is held in confidence.if it falls in one or more of several types, the&release of which might result:tintile loss of an .existing or potential competitive advantage, as follows:

(a) The, informationt reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of

3 CAW*1 0-2873 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the, application of wliich data secures a competitive economic advantage, e.g., by optimization or improved marketability.

(c) Its use 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 a-similar product.

(d) It reveals cost or price informnationproduction capacities, budget levels, or cominercial strategies of Westinghouse,; its customers or suppliers.

(e) Itreveals aspects of past, present, or future Westinghouse or customer funded

.development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for Which patent protection may be desirable.

T'here are sound policy reasons behind the Westinghouse system which include the follow!ing:

(a) The use of such information byWestinghouse gives Westinghouse a competitive.

advantage over its competitors. It-is, therefore, withheld from disclosure to protect the Westingh!ouse competitive position.

(b) Itis information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghousb*ability to sell products and services involving the use of the information.

(c) Use by our-competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

4 CAW-10-2873 (d) Each component of proprietary information pertinent toa particular competitive, advantage is potentially as valuable as thetotal competitive advantage. If competitors acquire components of proprietary information, any one component may-be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse' in the world market, and thereby give a market advantage to the competition of those countries.

(f) 'The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competiti ve advantage.

(iii) The information is being transmitted to theCommission in confidence and, under the.

provisions of 10 CFR Section 2.390; it is to be received in co0nfidence by theý Commission.

(iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowiedge and belief.

(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in SES 09m 127-P, Revision 2, "'Monticello Steam Dryer Replacement - Structural Verification of Steam Dryer" (Proprietary) dated June 28,;2010, for submittal to the Commission, beingtransmitted by Xcel Energyletter and Applicationfor Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted byWestinghouse is that associated with the Monticello Extended Power Uprate submittal, and may be used only for that purpose.

This information is part of that wvhich will enable Westinghouse to:

(a) Provide detailed design information toXcel.

5 CAW-10-2873..

Further this information has substantial commercial:value as fllows:

(a) Westinghouse plansto sell the.tuse of similar Information to its customers for purpose of Replacement Steam Dryers.

(b) Westinghotuse can sell support and defense of Steam Dryer design, (c) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

Publicd isclosure of this proprietary. information is likely to cause substantial harm to the competitive position of Westinghouse.because it would enhance the ability of competitors to provide similar analyses and, designs and. Iicensingdefense services, for commercial power reactors without commensurate expenses.. Also, public disclosureof the information would enable others to use the informatioi to meet NRC requirements for licensing documentation without purchasing the right to use the informantion.

The development of the technology described in partby the information is the result of, applying the results of many years of experience in an intensiveWestinghouse effort and the expenditure of a considerable sum of money.

In order for competitors of Westingghouse to duplicate-this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would laveto be expended.

Further the deponent-sayeth not.

PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and/or non-proprietary versions of documents fuirnished.to the NRC in confnection with requests for generic: and/!rplant-specific review and approval.

In order to conform.to the requirements ofl 0 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the.informaition which is proprietary in the proprietary versions is contained withihi brackets,-and where the proprietary, informati0n has been deleted in the non-proprietary versions, only-the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted).. The justification for claiming the information:

so designatedas proprietary is indicated in. both versions by means of *ower case letters (a) through (f) located as a supelrscript immediately following the brackets enclosing eachi.item ofl. information being identified as proprietary or in the margin opposite stich information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant tol10 CFR 2.390(b)( 1).

COPYRIGHT NOTICE The reports transmitted herewitheach bear a Westinghouse copyright notice. The NRC is permitted to make the numberof copiesof the information contained in these reports which are necessary for its internal use in :connection with generic *iand plant-specific revievws and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation ofa license, permit, order, or regulation subject to tthe reqtiirements of 10 CFR 2.390 regarding restrictions on public disclosure tothe extent such inffirmation has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions ofthese reports, the NRC is permitted, to make the number of copies beyond those necessary for its internal use which are necessary in order to have:one copy available forpublic viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations' if.

the number of copies submitted is' insufficientfor this purpose. Copies made by the NRC must include tile copyright. notice in all instances and the proprietary notice if the original was identified as proprietary.

'Xcel Energy Letter for Transmittal to the NRC The following paragraphs should be included in your letter to the NRC; Enclosed are:

1. 4.copies of SES09-127.-P, Revision 2, "Monticello Steam- Dryer Replacement-Structural Verification of Sieam .Drye;" (Proprietiary)

2. 2 copies of SES 09-127-NP,. Revision 2, "IMonticello Steam Dryer Replacement - Structural Verification of Steam Dryer" (Non-Proprietary)

Also enclosed is the Westinghouse Application for Withholding Proprietary Information from: Public Disclosure CAW-l0-2873, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice.

As Item I contains informiation proprietary to Westinghouse Electric Company LLC, it is supported by an affidavit signed byWestinghouse, the owner of the information. The affidavit setsforth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations.

Accordingly, it is respectfully requested that the inf6rmation which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2j390of the Commission's regulations.

Correspondence with respect to the copyright.or proprietary aspects of the items listed above or the

supporting Westinghouse affidavit should reference CAW-] 0-2873 and should be addressed to J. A, Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company*LLC, P.O. Box 355, Pittsburgh,.Pennsylvania 15230-0355.

• We.stinghouse Westinghouse Electric Company Nuclear Services P.O. Box 355 Pittsburgh, Pennsylvania 15230-0355 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document .Control Desk Direct fax: (412) 374-3846 Washington, DC 20555-0001 e-mail: greshaja@westingliouse.com Proj letter: LTR-EPml 0-053 CAW-10-2860 June 18,2010 APPLICATION FOR WIT1HOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

SES09-129, Revision 2, "Monticello Steam Dryer.Replacement Moisture Canyover Analysis" (Proprietary)

The proprietary information for which withholding is being~requested in the above-referenced report is further identified in Affidavit CAW-l0-2860 signed by the owner of the proprietary information, Westinghouse Eleciric CQompany LLC. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificitythe considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Xcel Energy Inc.

Correspondencew itlh respect to the proprietary aspects of the application for withholding or the West.inghouse affidavit shoutld reference this letter, CAW-10-2860 and should be addressed to J. A. Gresham, Manager, Regulatory Compliance and Plant Licensing, WestinghouseElectric Company LLC, P.O.Box 355, Pittsburgh, Pennsylvania 15230-0355.

Ve ruly.ors,

.IA.Gresham, Manager Regulatory Comnpliance and Plant:Licensing.

Enclosures

CAW-10-2860 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

.ss COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally appeared J. A.Gresham, who, being.by me duly.

sworn according tolaw, deposes and says that he. is iauthorized to execiute this§ Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the aveI.ients of fact set forth in this Affidavit are true and correct to the best of his knowledge, informati6n,4and belief:

A..,Gresham, Manager Regulatory Comnpliance andPlant Licensing Sworn to and subscribed before me:

this 18th day of June 2010 Notary Public.

'COMMONWEALTH OFPEi!NýSYLY RNOTARIALSj Ren GiaImpoge, Notr Pu blic Inee T~~wnsh~pWet or ýnd C66nty OITS0n Expires Septemb~f 2ý5.2013

2 CAW- 10-2860 (1) I am Manager, Regulatory Compliance and Plant Licensing, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

(3) 1have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.

Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The.information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of

3 CAW- 10-2860 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.

(c) Its use 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 a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

There are sound policy reasons behind the Westinghouse system which include the following:

(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products' and services involving the use of the information.

(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

4 CAW-10-2860 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.

(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390; it is to be received in confidence by the Commission.

(iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.

(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in SES09-129, Revision 2, "Monticello Steam Dryer Replacement Moisture Carryover Analysis" (Proprietary), dated June 18, 2010, for submittal to the Commission, being transmitted by Excel Energy letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with the Monticello Extended Power Uprate submittal, and may be used only for that purpose.

This information is part of that which will enable Westinghouse to:

(a) Provide detailed design and performance information to Xcel Energy.

5 CAW- I0-2860 Further this information has substantial commercial value as follows:

(a) Westinghouse plans to sell the use of similar information to its customers for purpose of Replacement Steam Dryers.

(b) Westinghouse can sell support and defense of Steam Dryer design.

(c) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar analyses and designs and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouseeffort and the expenditure of a considerable sum of money.

In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.

Further the deponent sayeth not.

PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.

In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the bracketý in the proprietary versions having been deleted). The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being

• identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).

COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

Xcel Energy Letter for Transmittal to the NRC The following paragraphs should be included in your letter to the NRC:

Enclosed are:

1. 4 copies of SES'09-129, Revision 2, "Monticello Steam Dryer Replacement Moisture Carryover Analysis" (Proprietary)

Also enclosed is the Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-10-2860, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice.

As Item I contains information proprietary to Westinghouse Electric Company LLC, it is supported by an affidavit signed by Westinghouse, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations.

Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.

Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse affidavit should reference CAW-1 0-2860 and should be addressed to J. A. Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.

• Westinghouse Westinghouse Electric Company Nuclear Services P.O. Box 355 Pittsburgh, Pennsylvania 15230-0355 USA U.S. NuclearRegulatory Commission Direc tel. (412) 374-4643 Document Control Desk Direct fax: (4 [2) 374-3846 Washington, DC 20555-0001 e-maii:, greshaja @.westinghouse.com Proj letter. LTR-EP 1*O050

CAW-] 0-2857.

June16,2010:

APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

WCAP-17251 -P, Revision 0, "Monticello Replacement Steam Dryer Four-Line Acoustic Subscale Testing Report," (Proprietary)

The proprietary information for :which-withholding is being requested in the above-referenced report is further identified in Affidavit CAW-10-2857 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulationsi' Accordingly, this letter authorizes the utilization of the accompanying affidavit by Xcel Energy Inc.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westing-house affidavit should 'reference this letter, CAW-1I0L2857 and should be addressed to J. A., Gresharn, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.

VeryltrulYy y rs, A. Gresham, Manager Regu.atory Compliance and Plant Licensing Enclosures

CAW-1 0-2857.

AFFIDAVIT.

COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF ALLEGHENY; Before me, the'iundersigned authority, personally hppeared J. A. Gresham, who, being by me duly sworn according to law, deposes and says that he is authboized to execute this-Affidavit on behalf of Westinghouse Electric Company, LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his:knowledge, information, and belief:'

J.A. Gresham, Manager Regulatory Compliance and Plant Licensing Sworn to and subscribed before me this 16th day of June 20 10:

Notary Public COMMONWEALTH OFP IPENNSYLVANIA Ree n~i ~~ o e ,NotarySEL P ub lic 1Pennflronship, WestmnoreiendCdunty 1,y .cr~mlnssjon Expires Septlember 25, 2013

2 CAW- 10-2857 (1) I am Manager, Regulatory Compliance and Plant Licensing, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

(2) l am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

(3) 1have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.

Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

.(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of

3 CAW-1 0-2857 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.

(c) Its use 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 a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) 'It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

There are sound policy reasons behind the Westinghouse system which include the following:

(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.

(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

4 CAW-10-2857 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.

(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390; it is to be received in confidence by the Commission.

(iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.

(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP-1725 1-P, Revision 0, "Monticello Replacement Steam Dryer Four-Line Acoustic Subscale Testing Report," (Proprietary) dated June 2010, for submittal to the Commission, being transmitted by Xcel'Energy letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with the Monticello Extended Power Uprate submittal, and may be used only for that purpose.

This information is part of that which will enable Westinghouse to:

(a) Provide detailed design information to Xcel Energy.

5 CAW-10-2857 Further this information has substantial commaercial value as follows:

(a) Westinghouse plans to sell the use of similar information to its customers for purpose of Replacement Steam Dryers.

(b) Westinghouse can sell support and defense of Steam Dryer design.

(c) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive, position of Westinghouse because it would enhance the ability of competitors to provide similar analyses and designs and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.

In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.

Further the deponent sayeth not.

PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.

In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidenceidentified in Sections (4)(ii)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).

COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

Xcel Energy Letter for Transmittal to the NRC The following paragraphs should be included in your letter to the NRC:

Enclosed are:

1. 4 copies of WCAP-17251-P, Revision 0,."Monticello Replacement Steam Dryer Four-Line Acoustic Subscale Testing Report," (Proprietary)

2. 2 copies of WCAP-17251-NP, Revision 0, "Monticello Replacement Steam Dryer Four-Line Acoustic Subscale Testing Report," (Non-Proprietary)

Also enclosed is the Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-10-2857, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice.

As Item I contains information proprietary to Westinghouse Electric Company LLC, it is supported by an affidavit signed by Westinghouse, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations.

Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.

Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse affidavit should reference CAW-10-2857 and should be addressed to J. A. Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.

BeWestinghouse Nuclear BoxServices 355 Electric Company Westinghouse P.O.

Pittsburgh, Pennsylvania 15230-0355 USA U.S. Nuclear Regulatory Commission Direct tel: (4.12) 374-4643

'DocumentControl Desk Direct fx: (412) 374-3846.

Washington, DC 20555-0001 e-mail: greshaja@westinghouse.com Proj letter: LTR-El-10-051 CAW- 10-2837 June 16, 2010 APPLICATION FOR WITHI-IOLDING PROPRIETARY INFORMATION FROM PUB Lic DISCLOSURE

Subject:

WCAP-1 7252-P, Revision 0, "Acoustic Loads Definition for the Monticello Steam Dryer Replacement Project," (Proprietary)

The proprietary information for which withholding is being requestedniii the above-referenced report is further identified in AffidavitCAW-10-2837 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by-the Commission and addresses with specificitythe considerations listed in paragraph (b)(4) of 10 CFR.Section 2.390 of the Commission's regUlations..

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Xcel Energy Inc.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-10-2837 and should be addressed to J, A, Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse-Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230.0355.

Very truly y prs; J. A. Gresharn, Manager Regulatory Compliance and Plant Licensing Enclosures

CAWW- 0-2837 AFFIDAVIT COMMONWEALTH! OF PENNSYLVANIA:

ss COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally appeared J. A. Gresham, who, being by me duly sworn according to law, deposes and says ihat he is authorized to execute this Affidavit 6n behalf.of Westinghouse Electr(ic Company LLC (Westinghou se), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowiledge, information, and belief:

J.A.Gresham, Manage Regulatory Compliance and Plant Licensing Sworn to and subscribed before-me this 16th day of June 2010 Notary Public

COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Renee Giampole, Notary Public Penn Township, Westmoreland County My Commission Expires September 25, 2013

2 CAW-10-2837 (1) I am Manager, Regulatory Compliance and Plant Licensing, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

(2) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

(3) 1 have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.

Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of

3 CAW-10-2837 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.

(c) Its use 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 a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

There are sound policy reasons behind the Westinghouse system which include the following:

(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.

(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

4 CAW-10-2837 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.

(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390; it is to be received in confidence by the Commission.

(iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.

(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP-17252-P, Revision 0, "Acoustic Loads Definition for the Monticello Steam Dryer Replacement Project," (Proprietary) dated June 2010, for submittal to the Commission, being transmitted by Xcel Energy letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with the Monticello Extended Power Uprate submittal and may be used only for that purpose.

This information is part of that which will enable Westinghouse to:

(a) Provide detailed design information to Xcel Energy.

5 CAW-10-2837 Further this information has substantial commercial value as follows:

(a) Westinghouse plans to sell the use of similar information to its customers for purpose of Replacement Steam Dryers.

(b) Westinghouse can sell support and defense of Steam Dryer design.

(c) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar analyses and designs and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.

In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.

Further the deponent sayeth not.

PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.

In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information' so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).

COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

Xcel Energy Letter for Transmittal to the NRC The following paragraphs should be included in your letter to the NRC:

Enclosed are:

1. 4 copies of WCAP- 17252-P, Revision 0, "Acoustic Loads Definition for the Monticello Steam Dryer Replacement Project," (Proprietary).

2. 2 copies of WCAP-17252-NP, Revision 0, "Acoustic Loads Definition for the Monticello Steam Dryer Replacement Project," (Non-Proprietary)

Also enclosed is the Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-10-2837, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice.

As Item I contains information proprietary to Westinghouse Electric Company LLC, it is supported by an affidavit signed by Westinghouse, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations.

Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.

Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse affidavit should reference CAW-10-2837 and should be addressed to J. A. Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.

O Westinghouse Westinghouse Electric Company Nuclear Services PO. Box 355 Pittsburgh, Pennsylvania 15230-0355 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax; .(412) 374-3846 Washington,; DC 20555-0001 e-mail: grcshaja@westinghouse.comi Proj lette:r' LTR-EP- 10-057 CAW-I 0-2867 June 24, 20 10 APPLICATION FOR WITHHOLDING PROPRIETARY

-INFORMATIONFROM PUBLIC DISCLOSURE

Subject:

LTR-A&SA-09-32, Revision 2, "Limit Curves for Monticello Power Ascension During 2011 Outage," (Proprietary)

The proprietary information for vwhich withhiolding is being requested in the above-referenced re'port is further identified in Affidavit CAW-]0-2867 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, whlich accompanies this letter, sets.forth the basis on whichthe information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2,390 of the Commission's, regulations.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Xcel Energy Inc.

Correspondence wVith respect to the proprietary aspects of the application for withholding or the.

Westinghouse affidavit should referencelthis letter, CAW-10-2867 and should be addressed to J. A. Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box. 355, Pittsburgh, Pennsylvania 15230-0355, Regulatory Compliance and Plnit Likensing Enclosures

CAW- 10-2867 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF ALLEGHENY:

Before me, the uhdersigned authority, personally appeared J. A. Greshanm,,whlo, being by. me duly sworn according to law,' deposes and says thitr lie is authorized to execute this Affidavit on. behlalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of factset forth in this Affidavit are trueand correct to the best of his kno*ledge, information,andbelief:

J.A. Gresham, Manager Regulatory Compliance and Plant Licensing Sworn to and subscribed before me this 24th day of June 2010 Notarg Pblic~

COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL_

Renee Giampole,.Notary Public Penn Township, WestmorelandCounty My Commission Expires Seplember 25, 2013

2 CAW-1 0-2867 (1) I am Manager, Regulatory Compliance and Plant Licensing, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.

Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of

3 CAW-10-2867 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process.(or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.

(c) Its use 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 a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

There are sound policy reasons behind the Westinghouse system which include the following:

(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.

(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

4 CAW-10-2867 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key-to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.

(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390; it is to be received in confidence by the Commission.

(iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.

(v) The proprietary information sought to be withheld in this submittal is marked in LTR-A&SA-09-32, Revision 2, "Limit Curves for Monticello Power Ascension During 2011 Outage," (Proprietary), for submittal to the Commission, being transmitted by Xcel Energy letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with the Monticello Extended Power Uprate submittal, and may be used only for that.purpose.

This information is part of that which will enable Westinghouse to:

(a) Provide detailed design information to Xcel Energy.

5 CAW-1 0-2867 Further this information has substantial commercial value as follows:

(a) Westinghouse plans to sell the use of similar information to its customers for purpose of Replacement Steam Dryers performance during power uprates.

(b) Westinghouse can sell support and defense of Steam Dryer design.

(c) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar analyses and designs and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.

In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be perfo-rmed and a significant manpower effort, having the requisite talent and experience, would have to be expended.

Further the deponent sayeth not.

PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.

In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the

-types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).

COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding.: With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

Xcel Energy Letter for Transmittal to the NRC The following paragraphs should be included in your letter to the NRC:

Enclosed are:

1. 4 copies of LTR-A&SA-09-32, Revision 2, "Limit Curves for Monticello Power Ascension During 2011 Outage," (Proprietary)

Also enclosed is the Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW- 10-2867, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice.

As Item I contains information proprietary to Westinghouse Electric Company LLC, it is supported by an affidavit signed by Westinghouse, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations.

Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.

Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse affidavit should reference CAW-10-2867 and should be addressed to J. A. Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.

Westinghouse Electric Company Pittsburgh, Pennsylvania 15230-0355 USA U .S.. Nuclear Regulatory Commission Direct tel: ý(412) 374-4643 Document Control Desk Direct fax: (412) 374-3846 Washington,:DC 20555-0001 e-mail: greshaja@westinghouse.coIm CAW-10-2875

June; 29, 2010 APPLICATION FOR WITHHOOLDINGTPROPR[ETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

LTR-EP-10-059, Revision i, WMonticello Replacement Steam Dryer Differential Pressure.

Methodology Discussion," (Proprietary)

The proprietary information for which withholding is being requested:in the above-referenced letter-is further identified in Affidavit CAW-10-2875 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld friom pUblic disclosure by the Commission aid addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.

Accordingly,.this letter authorizes the utilization of the accompany'ing aiffidavit by Xcel. Energy, Inc.

Correspondence with respect to the proprietary aspects of the application for witliholding or the Westinghouse affidavit shoul Id refer'ence this letter, CAW- 10-2875 and shou Id be addressed to J.A. Gresham, Manager, Regulatory'Compliance and Plani Licensing, Westinghouse Electric Company LLC, P.O Box 355, Pittsburgh, Pennsylvania 15230-0355.

Very trtilyyours, 2

)j: A..Gresham;.Manager Regulatory Compliance and Plant Licensing Enclosures

CAW-1 0-2875 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ssý COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally appeared I. A. Gresham, who, being byrme duly sworn according to !aw, deposes and says that. he is authorized to eXecute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:

A. Gresham, Manager Regulatory Compliance and Plant Licensing Sworn to and subscribed before me this 29th day of June 2010 SNotry bjc COMMONWEALTH OF PENNSYLVANIA NoTARIAL SEAL.

Renee Giempole, Notery Publloa1 FPenn Township, Westmoreland County MY cohimisslon Explies Septemrber2M, 2013

2 2CA W-710-2875 (1) I am Manager, Regulatory Compliance and PlantLicensing, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as sluch,:! have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and.am authorized to apply for its withholding on behalf of Westinghouse.

(2) 1am making this Affidavit inconformaiace with the provisions. of 10 CFR:Section 2.390 of the

,Commission's regulations and in conjunction With the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.,

(3) 1 have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.,

(4) Pursuant to the provisions of paragraph(b)(4) of Section.2.390 of the Comnmission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withhe-la from public disclosure is owned and has been held in confidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinglhouse and not customarily disclosed to the public. Westinghousehas a rationa! basis foir determining the types ofinformatio customarily held in confidence by it and, in that connection,.

utilizes a systen1i to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and -provides the rational basis required.

Under that system, information is held in.confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The informationreveals the distihguishing aspects of aprocess (or component,.

structure, tool, method, etc.) where prevention of its use by. any of

3 CAW-10-2875 Westin'ghouse's cormpetitors without licensefrom Westinghouse constitutes a competitive econom ic advantage over other companies.

(b) It consists of supporting data, includingitest data, relative to aprocess (or component, structure, tool, method, etc.),,the application of which data secures a competitive economic advantage, e.g., by o ptiniization or improved marketability, (c) Its use by a competitor would*reduce his expenditure ofresources or improve his:

competitive position in the design, manufacture, shipment,"installation, assurance of quality, or licensing a similar product.

(d) It reveals cost or price information; production capacities, budget levels,0or

,commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial Value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

There are sound policyreasons behind the Westinghouse system which include the following:

(a) Theuse of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to proItect the Westinghouse competitive position.

(b) It is information that is marketable in many ways. The extent to which.such information is available to competitors diminishes the Westinghouse ability to sell products.and :services involving the use of the information.

(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at :ourexpense.

A4 CAW-10-2875 (d) Each componentof proprietary information pertinent to a particular competitive advantage is potentially asvaluable as the total competitive advantage. If competitors acquire components of proprietary information, any one component.

may be the key to the entire puzzle, thereby depriving Westinghouse of a competiive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.

(0 The WestinglIouse capacity to invest corporate assets in research and development depends upon the success in.obtaining and maintainiing a competitive, advantage.

(iii) The information is being transmitted to the Commission in confidence and, under the provisions of.! 0 CFR Section 2.390; it is:to be received in confidence by the Commission.

(iv) The information sought to be protected is not available in publicsources or available information has not been previously employed in the same original manner or method.to the best of our knowledge and belief.

(v) The proprietary information sought to be withheld in this submittal is LTR-EP-l0-059, Revision 1, "Monticello Replacement Steam Dryer Differential Pressure Methodology Discussion,"'(Proprietary) dated June 24, 2010, for submittal to the Commission, being transmitted by Xel Energy letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document ControlDesk. The proprietary.

information as submitted by Westinghouse is~that associated with the Monticello Extended Power Uprate submittal, and may be used only for that purpose.

This information is part.of that which will enable Westinghouse to:

(a) Provide detailed desigii information to Xcel Energy.

15 CAW;1 0-2875 Further this information has substantial commercial value as follows::

(a) Westinghouse plans to sell the use ofsirnilar information tb its custohiner'sfor purpose of Replaceimient Steam Dry&ers performance during power uprates.

(b) Westingh0ouse~can sell support and defense of Steam Dryer design.

(c) The inforlnation.requested to be withheld:reveals the distinguishing aspects of a methodology which was developed byWestinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive:position of Westinghouse because it: would enhance the ability of competitors to provide similar analyses and designs and licensing defense services for commercial poweir'eactors without commensurate expenses. Also, public disclosure of the information would enable-others to use the information to meet NRC requiremfients.fdr licensing documentation without purchasing thd:right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effott and the expenditure of a considerable sumn of money.

In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to-be performed and asignificant manpower effort, having the requisite talent and'experience, woould have to be expended.

Further'the deponent sayeth not.

PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in.connection with requests for generic and/orplant-specific review and approval.

In order to confonrm to the requirements of 10 CER 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the infornation which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has beendeleted in the non-proprietary versions, only the brackets remain (the information that was contained within the bracketsin the proprietary versions having been deleted). Thejustification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (t) located as a superscript immediately following the brackets'enclosing each itern of information being identified as proprietary or in the margin opposite such information. These'lower case ,.letters r.efer to the types of information'Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f of the affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).

COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NýRC is permitted to make .the number of copies of theý information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transferrenewal, modification, suspension, revocation, or violation o0f a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public

.disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make thenumber of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the, appropriate docket files in the public document room in Washington, DC.and in local public'documentrooms as may berequired by NRC regulations'if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

Xce 'Energy Letter for Transmittal to the NRC The following paragraphs should be included in your letter tothe NRC.

Enclosed are:

I.. - copies of LTR-EP-] 0-059, Revision :1, "Monticello Replacement Steam Dryer Differential Pressure Methodology Discussion," (Proprietary)

Also enclosed is the WestinghoumseApplication fori Withholding;Proprietary Information from Public Disclosure CAW-] 0-2875, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice.

As Itenfi 1 containg information proprietary to Westinghouse Electric Company LLC, it is supported by an.

affidavit signed by Westinghpuse, the owvner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission'is regulations.

Accordingly, it is respectfully requested that the-information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10CFR Section 2.390 oftthe Commission's regulations.

Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse affidavit should reference CAW-1 0-2875 and should be addressed to J. A. Gresham, Manager, Regulatory Compliance :and Plant Licensing, Westinghouse Electric.

Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.

SWestinghouse Nuclear Services Westinghouse P.O. Box 355 Electric Company Pittsburgh, Pennsylvania 15230-0355 USA U.S. Nuclear Regulatoy Commission Direct tel: (412) 374A4643.

Document Control Desk Direct fax: (412) 374-3846:

Washington, DC 20555-0001 e-mail; greshiaja@westinghouse.com CAW-10-2872 June 29, 2010 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE Subje6t; LTR-EP-I 0-062, Revision 1, P-Attachment, "Monticell6Replacement Steam Dryer Regulatory Guide 1.20, Revision 3, Compliance Matrix, Revision 1" (Proprietary).

The proprietary information: for Which withholding isbeing requested in the above-referenced letter is further identified in Affidavit CAW-10-2872 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit; which accompanies this letter, sets-forth the basis on which the information may be withheld from public disclosure by the Commission and addresses-with specificity the considerations listed in paragraph (b)(4) of 10 .CFR Section 2.390 of the Commission's regulations.

Accordingly, this.letter authorizes the utilization of the accompanying affidavit by Xcel Energy, Inc.

Correspondence with respect to the proprietary aspects of the application for withhoilding or the Westinghouse affidavit should. reference this letter, CAW-10-2872 and should be addressed to J. A. Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Bbx'355, Pittsburg h, Pennsylvania 15230 0355.

Very truly yours, A.Gresham, Manager

• • J.

Regulatory Compliance and Plant Licensing Enclosures

CAW- 10-2872:

AFFIDAVIT COMMONWEALTH4 OF PENNSYLVANIA:

ss COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally appeared J. A. Gresham, who,, being by me duly s**V m iaccordingto law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC,(Westinghlouse), and that the averments of hict setforth in this Affidavit are true and'correct to the best of..hi sknowledge, inform-ation, and belief:

i Greshar, Manager Regulatory Compliance and Plant Licensing Sworn to and subscribed before me this 29th day of June 2010

• ki Pblicl

.COMMONWEALTH OF.PENNSYLVANIA 1 ... NOtARIAL SEAL Renee Giampole, Notary Public Penn Township, Westmoreland County My C6nmmission ExpIres September 25, 20113

!:2. CAW-10-2872 (1) 1.am Manager, Regulatory Compliance.and Plant Licensing, in.NuclearServices, Westinghouse Electric Company LLC'(Westinghouse), and as such, I have. been specifically delegated the function of reviewing the proprietary inforination sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized tos applyfor its withholding on behalf of Westinghouse.

(2) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in.conjUnction with the Westinghouse Application for Withholding

.:.Proprietary Information from Public Disclosure accompanying this Affidavit.

(3) 1 have personal knowledge of the criteria, and procedures utilized by Westinghlo use in designating information as a trade secretIprivileged or as confidential commercial or financial inforation.

(4) Pursuantto the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought tobe withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.

(ii) The information is of atype customarily held in confidence by Westinghouse and not.

customarily disclosed to the public. Westinghouse .hasa rational basis for determining the types of information customarily. held in.coinfidence~by it and:, in that: connection, utilizes.a system todetermine when and-whether to hold certain types of information in confidence. The application of that system and the substance ofthat system constitutes, Westinghouse policy and provides thle rational basis required.

Under, that systemn, inform-ation is held in confidence if it falls in one or more of several types, the release of which might.result in the loss of an existing or potential competitive.

advantage, as follows:

(a) The information reveals the-distinguishing aspects of a process (or component, structure, tool,.method, etc.) where prevention of its use by any of

3 CAW* l0-2872 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other c6panies.

(b) It consists of supporting data,, including test data, relative to a pOrocess (or component, structure, tool, method, etc.), the application of whichrdata securesa.

competitive economic advantage, e,g., by optimization or improved marketability.

(c). Its use bya competitor would reduce his expenditure of resources or improve his ompetitive: position in the design; manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d) It reveals cost or price infornation, production' capacities,; budget levels,.or c'ommercial strategi6s of Westinghouse,. its customers or suppliers.

(e) It reveals aspects of past,: present, or future Westinghouse or customer funded development plans and programs of potentiai commcrcial value to Westinghouse.

(f) It contains patentable ideas,. for which patent protection may be desirable.

There re ounid policy 'reasons behind the. Westinghouse system which include the following:

(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protecttlle Westinghouse competitive position.

(b) it is information that is marketable in many ways. The, extent to which such information is available"tCocompetitors diminishes the Westinghouse abilityto sell products and services involving the use of the information.

(c) Use by our competitorwould put Westinghouse at a competitive disadvantage by reducing~his expenditure of resources at our expense.

4 CAW-1:0-28721 (d) Each component of proprietary information pertinment to a'particular competitive advantage is potentially.as valuable as the total.competitive advantage. If competitors acquire components of proprietary information, anyone component may be the key to the entire puzzle, thereby depriving Westinghouse of a

competitive advantage; (e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give'a market advantage to thle competition.of those countries.

(0 The1 Westinghouse capacity to invest corporate assets in research and development depends upon the success'in obtaining and maintaining a competitive advantage.

(!it) Thle information is being.transmnitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390; itis to bereceived in confidence by the Commission.

.(iv) The informationsought to be protected is not available in public sources or available information has not been previously empIoyed in the same original mariner or method to the best of our knowledge and belief (v) The proprietary in-f6rmation sought to be withheld:in this submittal is. appropriately marked in LTR-EP-10-062, Revision 1, P-Attachment,"Monticello Replacement Steam.

Dryer Regulatory Guide 1.20, Revision 3, Compliance Matrix, Revision 1" (Proprietary) dated 'June .2010, for submittal to the Commission, being transmitted by Xcel Energy letterand Application for Withhi.ding ProprietarylInformation from Public Disclosure, to the Document Control:Desk. The proprietary information as submitted by Wcstinghouse is that associated with the Monticello Extended Power Uprate submittal, and may be used only f6r that purpose.

This information is part of that whic6. will enable Westinghouse. to;:

(a) Provide detailed design information to Xcel.

.5 CAW-10-2872 Further this information has substantial commercial.Value as follows:

(a) Westinghouse plans to sell the use of similar infoniation to its customers for pnrpose of Replacement Steam Dryers performance during power uprates.

(b) Westinghouse can sell support and defense of Steam Dryer design.

(c) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

Public disclosureofthis proprietary information is likely tocause. substantia.l hann to the competitive position, of Westinghouse becauiseit would enhance, the ability of competitors to provide similar analyses antdeSigns and licensing defen services for commercial power reactors without commensurate expenses. Also;: public disclosure of.-

the information would enable others to0 se the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of tle technologydescribed in part-by th.e information is the result of applying the results of many years of experience in an intensive Westinghouse effort and.

the expenditure of a considerable sunm of money.

In order for competitors of Westinghouse :to duplicate this information, similar technical programs& 06hld have to be performed and a significant manpower effort, having the requisite talent and experience,would have to be expended.

Further. the deponent sayethlnot.

PROPRIETARY INFORMATION NOTICE Transmitted herewith are:proprietary and/or non-proprietary versions of documents, furnished to thle NRC

.in connection with requests for generic and/or plant-specific review and approval.

In order to conform to the requiirements of I10 CFR 2.390 of the Commission's'regulations concerning the protection of proprietary information so submitted to the NRC, the information which isproprietary in the.

proprietary versions is contained:withih bracketsand where theplroprietaiy information has been deleted in the.inofinproprietary Versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters(a).through (f)

,located as a superscript immediately followiilg the brackets enclosing each item of information being identified as proprietary orin' the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).

COPYRIGHT NOTICE Thereports transmitted herewith each bear a Westinghouse copyright notice. The NRC is pemitted to make the number ofcopiesiof the.information contained in these reports which are necessary for its internal use in connection with generic and-plant-specific reviews and approvals as Well as the issuance, denial, amendment, transfer,:renewal, modification, Suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in.

order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in.local public document rooms as may be required by NRC regulations if the number of 'opies-submitted is insufficient for this purpose. Copies made by the NRC must ihiclude the Icopyright notice in all instances, and the proprietary notice ifthe original was identified as proprietary.

Xcel Energy Letter for Transmittal to-the NRC The following paragraphs should be included in yourletter to the. NRC:

Enclosed are:

1. 4 copies of LTR-EP-I0-062, Revision 1, P-Attaclhment, "Monticello ReplacementSteam Dryer.

Regulatory Guide 1.20, Revision3, Compliance Matrix, Revision .1" (Proprietary)

2. 2 copies of LTR-EP-10-062, Revision 1, NP-Attachment, "'Monticello Replacement Steamn Dryer Regulatory Guide 1.20, Revision 3, Compliance Matrix, Revision 1":(Non-Proprietary)

Also enclosed is the Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-10-2872, accompanying Affidavit, Proprietary Information Notice, and Copyright

.Notice.

As Item 1.contains information proprietary to Westinghouse Electric Company LLC, it is supported by an ataffidavit-signed by Westinghouse, the owner of the infornation. The affidavit sets forthl.the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations.

Accordingly, lit is. respectfully requested:that the infonnation which is proprietaryIto Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of0the.Commission's regulations.

Correspondence with respect to the copyright or proprietary Eispects of the items listed above or the

-supporting Westinghouse affid,lvit should reference CAW-1 0-2872 and should be addressed to J. A. Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.

ENCLOSURE 11.

SUMMARY

OF EPU COMMITMENTS INCLUDING COMMITMENTS ASSOCIATED WITH THE REPLACEMENT STEAM DRYER Page1 of 5

L-MT-10-046 1 Page 2 of 5 NRC Commitments from Monticello EPU Correspondence Below is the complete list of NRC commitments for the EPU project prior to issuance of this supplement.

No. Letter No. Date Commitment text Status 1 L-MT-08-052 NSPM will inspect the steam dryer during the next Active 11/5/2008 refueling outage to confirm no unexpected changes in crack length on the steam dryer.

2 L-MT-09-017 The steady state bypass void fraction for the EPU Active 3/19/2009 core will be calculated using the method described by the NSPM response to NRC RAI SNPB-7 of L-MT-09-017.

3 L-MT-09-043 NSPM will provide the evaluation of steam dryer Active 8/12/2009 structural integrity to the NRC staff prior to further increases in reactor power when increasing to power levels above CLTP.

4 L-MT-09-043 NSPM will perform outage steam dryer inspections Active 8/12/2009 based on the guidance of BWRVIP.

5 L-MT-09-044 Confirmation that Feedwater and Condensate pump Active 8/21/2009 and heater replacement modifications are complete and meet the code allowables will be provided to the NRC prior to implementation of the EPU license amendment request.

6 L-MT-09-044 Confirmation that modification of support TWH-143 Active 8/21/2009 is complete will be provided to the NRC prior to implementation of the EPU license amendment request.

7 L-MT-09-046 NSPM will perform an analysis prior to RF025 to Active 6/12/2009 predict combined Condensate and Feedwater system performance for normal operation and for transients including Single Feedwater pump trip, Feedwater Control System Failure and Single Condensate Pump Trip. Acceptance criteria will include adequate margin to preclude loss of both reactor feedwater pumps from low suction pressure or flow.

8 L-MT-09-046 Prior to RF025, the USAR will be revised to indicate Active 6/12/2009 that the emergency heat load of 24.7 MBTU/hr occurs approximately 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> after shutdown.

L-MT-1 0-046 1 Page 3 of 5 9 L-MT-09-048 NSPM commits to evaluating the changes in Active 7/13/2009 condensate and feed pump area heat load to confirm temperatures remain within design limits prior to RF025. If necessary, modifications to the HVAC system for this area will be implemented to maintain these areas within the design limits.

10 L-MT-09-100 If NRR agrees to review the MELLLA+ LAR Active 10/28/2009 concurrent with the EPU LAR, NSPM will commit in the MELLLA+ LAR to resolve the CAP section in the same manner as the issue is resolved for the delayed EPU amendment.

Revised Commitments By this supplement the following commitments are changed:

Commitment 3 is no longer applicable as this commitment was only applicable to the CISD. Commitment 3 states that: "NSPMwill provide the evaluation of steam dryer structuralintegrity to the NRC staff priorto furtherincreases in reactorpower when increasingto power levels above CLTP." This commitment was made based up on the use of the CISD. The CISD is being replaced by the RSD, therefore this commitment is no longer required.

In addition, Regulatory Guide 1.20, revision 3, section 2.2 requires that a structural integrity evaluation of the replacement steam dryer (RSD) be performed before increasing above CLTP. The Replacement Steam Dryer - Power Ascension Test Plan (RSD - PATP) requires an evaluation of the RSD structural integrity be completed at various power levels. The RSD-PATP is being added as commitment 11. See the summary provided under New Commitments below.

Completed Commitments Commitment 1 is considered complete. Commitment 1 states that: "NSPM will inspect the steam dryerduring the next refueling outage to confirm no unexpected changes in crack length on the steam dryer." This commitment was completed during RF024. This commitment was made in November 2008 and was satisfied by inspection of the CISD during the 2009 refueling outage. Therefore, this commitment is considered complete.

Commitment 2 is considered complete. Commitment 2 states that: "The steady state bypass void fraction for the EPU core will be calculated using the method described by the NSPM response to NRC RAI SNPB-7 of L-MT-09-017." This commitment was completed by completion of the Cycle 25 Safety Reload Licensing Report (SRLR). The bypass void fraction was reported in Appendix I of the Cycle 25 SRLR report.

L-MT-1 0-046 1 Page 4 of 5 Commitment 10 is considered complete. Commitment 10 states that: If NRR agrees to review the MELLLA+ LAR concurrent with the EPU LAR, NSPM will commit in the MELLLA+ LAR to resolve the CAP section in the same manner as the issue is resolved for the delayed EPU amendment. On November 23, 2009, the NRC agreed to review the MELLLA+ LAR for review since the "...the MELLLA+ amendment to the EPU amendment satisfied the criteriafor 'rarecircumstances' stated in Office Instruction LIC-109." Therefore, this commitment is considered complete. A separate commitment was made in the MELLLA+ LAR to resolve the CAP issue.-

New Commitments NSPM proposes new commitment 11. The commitment is as follows:

As part of MNGP restart following installation of the replacement steam dryer, NSPM will implement the RSD - PATP found in Enclosure 1, Appendix 5 of this letter.

This commitment is discussed in section 4.2.1 of Enclosure 1. The commitment is required to satisfy the requirements of Regulatory Guide 1.20. The RSD - PATP contains requirements from Regulatory Guide 1.20 concerning testing and reporting requirements for the RSD.

Final List of EPU Commitments Based on these changes and the revised commitments associated with this supplement the revised EPU commitments table is as follows:

No. Letter No. Date Commitment text Status 1 L-MT-08-052 NSPM will inspect the steam dryer during the Complete -

11/5/2008 next refueling outage to confirm no performed in unexpected changes in crack length on the RF024.

steam dryer.

2 L-MT-09-017 The steady state bypass void fraction for the Complete -

3/19/2009 EPU core will be calculated using the method provided in described by the NSPM response to NRC Cycle 25 RAI SNPB-7 of L-MT-09-017. SRLR.

3 L-MT-09-043 NSPM will provide the evaluation of steam Deleted -

8/12/2009 dryer structural integrity to the NRC staff Commitment prior to further increases in reactor power no longer when increasing to power levels above required.

CLTP.

4 L-MT-09-043 NSPM will perform outage steam dryer Active 8/12/2009 inspections based on the guidance of BWRVIP.

L-MT-1 0-046 1 Page 5 of 5 5 L-MT-09-044 Confirmation that Feedwater and Active 8/21/2009 Condensate pump and heater replacement modifications are complete and meet the code allowables will be provided to the NRC prior to implementation of the EPU license amendment request.

6 L-MT-09-044 Confirmation that modification of support Active 8/21/2009 TWH-143 is complete will be provided to the NRC prior to implementation of the EPU license amendment request.

7 L-MT-09-046 NSPM will perform an analysis prior to Active 6/12/2009 RF025 to predict combined Condensate and Feedwater system performance for normal operation and for transients including Single Feedwater pump trip, Feedwater Control System Failure and Single Condensate Pump Trip. Acceptance criteria will include adequate margin to preclude loss of both reactor feedwater pumps from low suction pressure or flow.

8 L-MT-09-046 Prior to RF025, the USAR will be revised to Active 6/12/2009 indicate that the emergency heat load of 24.7 MBTU/hr occurs approximately 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> after shutdown.

9 L-MT-09-048 NSPM commits to evaluating the changes in Active 7/13/2009 condensate and feed pump area heat load to confirm temperatures remain within design limits prior to RF025. If necessary, modifications to the HVAC system for this area will be implemented to maintain these areas within the design limits.

10 L-MT-09-100 If NRR agrees to review the MELLLA+ LAR Complete -

10/28/2009 concurrent with the EPU LAR, NSPM will NRC commit in the MELLLA+ LAR to resolve the acceptance CAP section in the same manner as the of MELLLA+

issue is resolved for the delayed EPU LAR.

amendment.

11 L-MT-10-046 As part of MNGP restart following installation Active 6/30/2010 of the replacement steam dryer, NSPM will implement the Power Ascension Test Plan found in Enclosure 1, Appendix 5 of this letter.