ML103500525

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Response to Request for Additional Information Regarding the License Amendment Request for Extended Power Uprate Operation (TAC No. ME1476) - Steam Dryer
ML103500525
Person / Time
Site: Nine Mile Point Constellation icon.png
Issue date: 12/10/2010
From: Belcher S
Constellation Energy Nuclear Group, EDF Group, Nine Mile Point
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME1476
Download: ML103500525 (23)
v • d • e


Text

This letter forwards proprietary information in accordance with 10 CFR 2.390. The balance of this letter may be considered non-proprietary upon removal of Attachments 6 through 8.

Sam Belcher P.O. Box 63 Vice President-Nine Mile Point Lycoming, New York 13093 315.349.5200 315.349.1321 Fax CENG.

a joint venture of o*nstellation

  • erlv Energy e NINE MILE POINT NUCLEAR STATION December 10, 2010 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001.

ATTENTION: Document Control Desk

SUBJECT:

Nine Mile Point Nuclear Station Unit No. 2; Docket No. 50-410 Response to Request for Additional Information Regarding Nine Mile Point Nuclear Station, Unit No. 2 - Re: The License Amendment Request for Extended Power Uprate Operation (TAC No. ME 1476) - Steam Dryer

REFERENCES:

(a) Letter from K. J. Polson (NMPNS) to Document Control Desk (NRC), dated May 27, 2009, License Amendment Request (LAR) Pursuant to 10 CFR 50.90:

Extended Power Uprate (b) Letter from R. Guzman (NRC) to S. L. Belcher (NMPNS), dated October 6, 2010, Request for Additional Information Regarding Nine Mile Point Nuclear Station, Unit No. 2 - Re: The Steam Dryer Review of the Licensing Amendment Request for Extended Power Uprate Operation (TAC No. ME 1476)

(c) Letter from J. Pacher (NMPNS) to Document Control Desk (NRC), dated November 5, 2010, Response to Request for Additional Information Regarding Nine Mile Point Nuclear Station, Unit No. 2 - Re: The License Amendment Request for Extended Power Uprate Operation (TAC No. ME1476) - Steam Dryer Nine Mile Point Nuclear Station, LLC (NMPNS) hereby transmits revised and supplemental information in support of a previously submitted request for amendment to Nine Mile Point Unit 2 (NMP2) Renewed Operating License (OL) NPF-69. The request, dated May 27, 2009 (Reference a), proposed an amendment to increase the power level authorized by OL Section 2.C.(1), Maximum Power Level, from 3467 megawatts-thermal (MWt) to 3988 MWt.

This letter forwards proprietary information in accordance with 10 CFR 2.390. The balance of this letter may be considered non-proprietary upon removal of Attachments 6 through 8.

Document Control Desk December 10, 2010 Page 2 By letter dated October 6, 2010 (Reference b), the NRC staff requested additional information (RAI) regarding the steam dryer. Originally, NMPNS responded to the steam dryer RAIs on November 5, 2010 (Reference c). This response included commitments to provide additional information by December 10, 2010. Attachment 1 (non-proprietary) and Attachment 6 (proprietary) provide the additional information in the form of revised RAI responses. Continuum Dynamics Incorporated (CDI) Report No. 10-09 is provided as Attachment 3 (non-proprietary) and Attachment 7 (proprietary). CDI Report No. 10-10 is provided as Attachment 4 (non-proprietary) and Attachment 8 (proprietary).

Attachments 6 through 8 are considered to contain proprietary information exempt from disclosure pursuant to 10 CFR 2.390. Therefore, on behalf of CDI, NMPNS hereby makes application to withhold these attachments from public disclosure in accordance with 10 CFR 2.390(b)(1). The affidavits from CDI detailing the reason for the request to withhold the proprietary information are provided in . A copy of the CDI affidavit originally provided on November 5, 2010 is included because the CDI proprietary information provided in the responses to the RAIs in Attachment 6 was originally submitted on November 5, 2010.

Within two months of final resolution of NRC RAls regarding the steam dryer analysis methodology, NMPNS will submit a revision to CDI Report No. 10-12, Design and Stress Evaluation of Nine Mile Point Unit 2 Steam Dryer Modifications for EPU Operation. Attachment 2 describes the new commitment contained within this submittal.

Should you have any questions regarding the information in this submittal, please contact J. J. Dosa, Director Licensing, at (315) 349-5219.

Very truly yours,

Document Control Desk December 10, 2010 Page 3 STATE OF NEW YORK TO WIT:

COUNTY OF OSWEGO I, Sam Belcher, being duly sworn, state that I am Vice President - Nine Mile Point, and that I am duly authorized to execute and file this response on behalf of Nine Mile Point Nuclear Station, LLC. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other Nine Mile Point employees and/or consultants. Su h information has been reviewed in accordance with company practice and I believe it to be reliable. .

Subscribed and sworn before me, a Notary Public in and for the State of New York and County of QSý , this iD dayof 'ecen't*_C

__\Iii ,2010.

WITNESS my Hand and Notarial Seal: /4* 0L4,"4_/

Notary Public My Commission Expires:

Date Nt PUbU In the Staft o Mew q Osweqgo out Reg. No. 01D080w29 SB/STD My Cmdnulua P11 W2M2013 9

Attachments:

1. Response to Request for Additional Information Regarding License Amendment Request for Extended Power Uprate Operation (NON-PROPRIETARY)
2. List of Regulatory Commitments
3. CDI Report No. 10-09NP, ACM Rev. 4.1: Methodology to Predict Full Scale Steam Dryer Loads from In-Plant Measurements, Revision 2 (NON-PROPRIETARY)
4. CDI Report No. 10-1ONP, Acoustic and Low Frequency Hydrodynamic Loads at CLTP Power Level on Nine Mile Point Unit 2 Steam Dryer to 250 Hz Using ACM Rev. 4.1, Revision 2 (NON-
5. Affidavits From Continuum Dynamics Incorporated (CDI) Justifying Withholding Proprietary
6. Response to Request for Additional Information Regarding License Amendment Request for Extended Power Uprate Operation (PROPRIETARY)
7. CDI Report No.10-09P, ACM Rev. 4.1: Methodology to Predict Full Scale Steam Dryer Loads from In-Plant Measurements, Revision 2 (PROPRIETARY)

Document Control Desk December 10, 2010 Page 4

8. CDI Report No.10-10P, Acoustic and Low Frequency Hydrodynamic Loads at CLTP Power Level on Nine Mile Point Unit 2 Steam Dryer to 250 Hz Using ACM Rev. 4.1, Revision 2 (PROPRIETARY) cc: NRC Regional Administrator, Region I NRC Resident Inspector NRC Project Manager A. L. Peterson, NYSERDA (w/o Attachments 6 through 8)

ATTACHMENT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR EXTENDED POWER UPRATE OPERATION (NON-PROPRIETARY)

Certain information, considered proprietary by Continuum Dynamics Incorporated, has been deleted from this Attachment. The deletions are identified by double square brackets.

Nine Mile Point Nuclear Station, LLC December 10, 2010

ATTACHMENT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR EXTENDED POWER UPRATE OPERATION (NON-PROPRIETARY)

By letter dated May 27, 2009, as supplemented on August 28, 2009, December 23, 2009, February 19, 2010, April 16, 2010, May 7, 2010, June 3, 2010, June 30, 2010, July 9, 2010, July 30, 2010, October 8, 2010, October 28, 2010, and November 5, 2010, Nine Mile Point Nuclear Station, LLC (NMPNS) submitted for Nuclear Regulatory Commission (NRC) review and approval, a proposed license amendment requesting an increase in the maximum steady-state power level from 3467 megawatts thermal (MWt) to 3988 MWt for Nine Mile Point Unit 2 (NMP2).

By letter dated October 6, 2010, the NRC staff requested additional information (RAI) regarding the steam dryer. NMPNS responded to the steam dryer RAIs on November 5, 2010. This response included commitments to provide additional information by December 10, 2010. This attachment provides the additional information in the form of revised RAI responses.

The NRC request is repeated (in italics), followed by the NMPNS response.

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ATTACHMENT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR EXTENDED POWER UPRATE OPERATION (NON-PROPRIETARY)

NMP2-EMCB-SD-RAI-6 S01 (a)

The applicant is requested to provide updated NMP2 main steam line (MSL) data and dryer loads in a revision to Continuum Dynamics, Inc. (CDI) Report No.10-lOP, "Acoustic and low frequency hydrodynamic loads at CLTP [current licensed thermal power] level on Nine Mile Point Unit 2 Steam Dryer to 250 hertz (Hz) using ACM Rev. 4.1, "following resolution of the follow-up RAI NMP2-EMCB-SD-RAI-8 SO].

Original NMNPS Response A revised CDI Report No. 10-loP will be provided that includes the details of the response to NMP2-EMCB-SD-RAI-8 SOI by December 10, 2010.

Final NMPNS Response Revision 2 of CDI Report No. 10-10 is provided as Attachment 4 (non-proprietary) and Attachment 8 (proprietary).

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ATTACHMENT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR EXTENDED POWER UPRATE OPERATION (NON-PROPRIETARY)

NMP2-EMCB-SD-RAI-6 S01 (b)

As described in CDI Report JO-11P, "Stress Assessment of Nine Mile Point Unit 2 Steam Dryer Using the Acoustic Circuit Model Rev. 4.1," dated June 30, 2010, and CDI Report 10-12P, "Design and Stress Evaluation of Nine Mile Point Unit 2 Steam Dryer Modifications for EPU Operation," dated July 30, 2010, the applicant considered several modifications at high-stress locations and showed that the corresponding minimum alternating stress ratio (SR-a) for the dryer with all the modifications implemented is 2.85 at CLTPpower level. With velocity-square bump-upfactor (( )), the stress ratio at EPU would be greaterthan 2.0. However, as discussed in supplementary RAI NMP2-EMCB-SD-RAI-17 SO1, the bump-up factor may be higher than velocity-square. Therefore, the minimum alternating stress ratio at EPUpower level for some of the locations identified in the above three groups may be less than 2.0. The licensee is requested to reevaluate the alternatingstress ratiosfor the high-stress locations (Groups 1-4 locations) after the supplementary RAI NMP2-EMCB-SD-RAI-1 7 SO1 related to bump-up factor and RAI NMP2-EMCB-SD-RAI-8 SOJ(a) relatedto coherence estimates are resolved Original NMNPS Response The response to NMP2-EMCB-SD-RAI-17 SO0 concludes that the appropriate bump-up factor remains velocity squared. Thus, re-evaluation is not required to address NMP2-EMCB-SD-RAI- 17 SO 1.

A revision to this RAI response will be issued to address the final response to NMP2-EMCB-SD-RAI-8 SO 1(a) by December 10, 2010.

Final NMPNS Response The response to NMP2-EMCB-SD-RAI-17 SOI concludes that the appropriate bump-up factor remains velocity squared. Thus, re-evaluation is not required to address NMP2-EMCB-SD-RAI-17 SO 1.

The stresses tabulated in Tables 8 - 10 of Revision 0 of CDI Report 10-12 submitted in NMPNS letter dated July 30, 2010, are recomputed using the new Acoustic Circuit Model (ACM) Rev. 4.1 loads described in Revision 2 of CDI Report Nos. 10-09 and 10-10 provided in this letter. Table 8 of Revision 0 of CDI Report 10-12 submitted in NMPNS letter dated July 30, 2010, listed the stress ratios of high stress locations in Groups I - 4 before and after the modifications described in the same report. This table is reproduced at the same locations (see Table RAI-6 SO1 (b)-l). The first eight columns of Table RAI-6 SOI(b)-I are taken from Revision 0 of CDI Report 10-12 submitted in NMPNS letter dated July 30, 2010, with the alternating stress ratios computed using the previous ACM model loads developed in Rev. I of CDI Report 10-10 submitted in NMPNS letter dated June 30, 2010. The second to last column of Table RAI-6 S01 (b)-I reports the stress ratios obtained at the same locations using the new ACM Rev. 4.1 model described in Revision 2 of CDI Report Nos. 10-09 and 10-10 provided in this letter. In general, these stress ratios using the new acoustic loads are higher relative to the prior ones.

For the Group I modifications, the limiting stress ratios increase between 20 and 27%, further improving the margins that were already adequate under the previous ACM acoustic loads. Note that the modifications at these locations are still needed to achieve adequate margin at Extended Power Uprate (EPU). The Group 2 locations were addressed by adding a curved reinforcement plate on the middle hood outboard of the closure plate. This modification significantly reduced the alternating stresses. With the revised ACM Rev. 4.1 loads and the modification, these stresses remain low with a limiting alternating 3 of 16

ATTACHMENT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR EXTENDED POWER UPRATE OPERATION (NON-PROPRIETARY) stress ratio on these nodes of 16.37. Group 3 stresses reduce between 9% and 15% (stress ratios increase by these amounts), with the limiting alternating stress ratio on these locations being 3.39 in the post-modification dryer. Of the Group 4 nodes, stresses at all locations remain above the target levels with ample margin in the post-modification dryer. The lowest alternating stress ratio of all Group 4 members is 3.13 using the revised ACM Rev. 4.1 acoustic loads.

These loads lead to alternating stress ratios on the drain channel/skirt weld that meet margin without any modification. Using the previous loads, the limiting alternating stress ratio (SR-a) on these welds was 2.65, which is slightly below the target value. Thus, a wrap-around weld was proposed for these locations to increase the limiting alternating stress ratio to 4.09. Using the new load, the limiting alternating stress ratio with this weld reinforcement increases to 4.75. However, even without this reinforcement, the alternating stress ratio remains above 3.09 as shown in the final column of the modified Table RAI-6 SOI (b) - 1, indicating that no modification of this location is needed.

Tables 9 and 10 in Revision 0 of CDI Report 10-12 submitted in NMPNS letter dated July 30, 2010, were developed to list the various kinds of limiting stress ratio (primary, alternating; on or away from a weld).

Table 9 of Revision 0 of CDI Report 10-12 submitted in NMPNS letter dated July 30, 2010 was generated by assuming that the closure plate attachment welds were reinforced. Because they only introduce localized changes in the stresses, the attachment weld reinforcements were analyzed on the basis of stress reduction factors (SRFs). These reinforcements were originally necessary because of high stresses caused by vibrations of the closure plate. Subsequently, it was decided to reinforce the closure plates themselves using stiffening ribs. Since stiffening of the closure plate would likely reduce the stresses at the attachment welds, the dryer was reanalyzed without the thickened/reinforced closure plate attachment welds (i.e., without the SRFs applied at these locations). This resulted in Table 10 of Revision 0 of CDI Report 10-12 submitted in NMPNS letter dated July 30, 2010 which listed the alternating stress ratios at the welds.

Using the latest ACM Rev. 4.1 acoustic loads, the stresses are recalculated at the same high stress locations. The main observations are as follows. First, with regard to Table 9 of Revision 0 of CDI Report 10-12 submitted in NMPNS letter dated July 30, 2010, the limiting alternating stress ratio using the most recent loads in Revision 2 of CDL Report Nos. 10-09 and 10-10 provided in this letter increases from 2.85 to 3.09 as shown in Tables RAI-6 SOI (b) - 2 and - 3. The maximum stress ratio (SR-P) increased slightly from 1.25 to 1.26. Most stress ratios show a small increase using the latest ACM acoustic loads. Next, the re-evaluated alternating stress ratios of Table 10 of Revision 0 of CDI Report 10-12 submitted in NMPNS letter dated July 30, 2010, corresponding to the dryer with the existing (non-reinforced) closure plate attachment welds, are seen to remain at 3.09 and higher (see Table RAI-6 SOI (b) - 4. Of the closure plate attachment weld locations listed in Table RAI-6 SO0 (b)-3, the limiting alternating stress ratio is 3.52, further confirming that reinforcement of these welds is unnecessary under the acoustic loads estimated using the latest ACM Rev. 4.1 model in Revision 2 of CDI Report Nos. 10-09 and 10-10 provided in this letter.

Within two months of final resolution of NRC RAIs regarding the steam dryer analysis methodology, NMPNS will submit a revision to CDI Report No. 10-12, Design and Stress Evaluation of Nine Mile Point Unit 2 Steam Dryer Modifications for EPU Operation.

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ATTACHMENT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR EXTENDED POWER UPRATE OPERATION (NON-PROPRIETARY)

Table RAI-6 S01 (b) - I Recalculation of Table 8 of Revision 0 of CDI Report 10-12 submitted in NMPNS letter dated July 30,2010, using Revision 4.1 ACM Model Obtained from Revision 0 of CDI Report 10-12 Calculated using current ACM 4.1 submitted in NMPNS letter dated July 30, 2010 as summarized in Revision 2 of CDI Report Nos. 10-09 and 10-10 Location GROUP SRF node SR-a  % Freq. Dom. SR-a SR-a SR-a Shift Freq. [Hz] Post Mod.(c) Post Mod w/o SRF (ACM 4.1) (d) (ACM 4.1) (d)

1. Side Plate/Brace 1 0.6(5) 89649 1.56 -5 139.7 5.77 6.95
3. Side Plate/Brace 1 1 89646 1.74 5 103.3 3.33 4.22
7. Side Plate/Brace I 0.6(5) 89652 2.35 -5 139.7 8.03 9.68
2. Hood Reinforcement/Middle Hood 2 1 98275 1.62 10 109.0 19.74 24.48
8. Hood Reinforcement/Middle Hood 2 1 90126 2.35 10 109.0 18.39 19.30
9. Hood Reinforcement/Middle Hood 2 1 98268 2.38 -7.5 146.1 18.66 21.91
10. Hood Reinforcement/Middle Hood 2 1 90949 2.57 2.5 190.7 21.38 16.37
4. Hood Support/Inner Hood 3 l(b) 95636 2.17 -10 51.2 3.10 3.53
5. Hood Support/Inner Hood 3 1(b) 95650 2.27 -10 51.2 4.23 4.61
6. Hood Support/Inner Hood 3 l(b) 95642 2.28 2.5 44.1 2.94 3.39
11. Hood Support/Outer Base 4 1(b) 95428 2.65 5 48.6 4.27 4.67 Plate/Middle Backing Bar
14. Hood Support/Outer Cover 4 l(b) 95267 2.71 -10 60.5 2.88 3.13 Plate/Outer Hood
12. Submerged Drain 4 1 93430 2.65 5 51.8 4.18 4.75 3.09 Channel/Submerged Skirt
15. Submerged Drain 4 1 84597 2.72 2.5 104.0 4.09 4.93 3.21 Channel/Submerged Skirt
13. Hood Support/Middle Hood 4 l(b) 96022 2.68 -5 53.4 4.05 4.22 Notes.

(a) Node numbers are retained for further reference.

(1-11) Appropriate stress reduction factor for the welds and modifications listed in Table 1 of Revision 0 of CDI Report 10-12 submitted in NMPNS letter dated July 30, 2010, have been applied. The number refers to the particular location and corresponding stress reduction factor in Table 1 of Revision 0 of CDI Report 10-12 submitted in NMPNS letter dated July 30, 2010.

(b) Weld Factor (WF)=1.4 (C) Post - modification value reported in Revision 0 of CDI Report 10-12 submitted in NMPNS letter dated July 30, 2010.

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ATTACHMENT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR EXTENDED POWER UPRATE OPERATION (NON-PROPRIETARY)

(d) Post - modification value obtained using the revised ACM 4.1 loads methodology described in Revision 2 of CDI Report No. 10-09 and applied to the NMP2 steam dryer as described in Revision 2 of CDI Report No 10-10.

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ATTACHMENT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR EXTENDED POWER UPRATE OPERATION (NON-PROPRIETARY)

Table RAI-6 S01 (b) - 2 Recalculation of stresses, stress ratios and limiting frequency shifts in Table 9 of Revision 0 of CDI Report 10-12 submitted in NMPNS letter dated July 30, 2010, using the Revision 4.1 ACM Model Stress Weld Location Location (in.) node(a) Stress Intensity (psi) Stress Ratio  % Freq.

Ratio x y z Pm Pm+Pb Salt SR-P SR-a Shift SR-P No 1. Inner Side Plate 3.1 119 0.5 37229 7499 9024 654 2.25 18.90 7.5

2. Thin Vane Bank Plate -15.6 -118.4 0.6 2558 4855 5271 254 3.48 48.75 -2.5
3. Support/Seismic Block 10.2 123.8 -9.5 113286 4567 4567 1518 3.70 8.15 10 SR-a No 1. Brace 32.9 -27.2 69.8 70703 1014 4033 3975 6.29 3.11 5
2. Inner Hood 31.1 -33.7 78.1 70266 1163 3495 3461 7.25 3.57 2.5
3. Inner Hood 79.6 85.5 75.8 37811 3035 3250 2964 5.57 4.17 -10 SR-P Yes 1. Upper Support Ring (USR)/Support/Seismic Block -6.9 -122.3 -9.5 113554 7378 7378 1059 1.26 6.49 0
2. Side Plate Ext/Inner Base Plate 16.3 119 0 94143 7014 9918 531 1.33 12.94 2.5
3. Tie Bar 49.3 108.1 88 141275 6058 6058 1034 1.53 6.64 0
4. Inner Side Plate/Inner Base Plate -2.3 -119 0 99200 4487 8078 760 1.73 9.04 7.5 5 Thin Vane Bank Plate/Hood Support/Inner 24.1 -59.5 0 85191 5042 5166 1405 1.84 4.89 5 Base Plate
6. Hood Support/Middle Base Plate/Inner -39.9 0 0 85723 4852 5101 1818 1.92 3.78 2.5 Backing Bar/Inner Hood(b)
7. Side Plate/Top Plate 17.6 119 88 91215 939 7424 1689 1.88 4.07 5
8. Closure Plate/Backing Bar/Inner Hood 39.9 108.6 0.5 93062 5018 5074 690 1.85 9.95 7.5
9. Hood Support/Outer Base Plate/Middle Backing Bar -71.3 0 0 95428 4714 5220 2015 1.97 3.41 5
10. Outer Cover Plate/Outer Hood 102.8 -58.1 0 94498 1049 7225 946 1.93 7.26 2.5
11. Hood Support/Middle Base Plate/Inner Backing -39.9 59.5 0 90468 4444 4533 1347 2.09 5.10 0 Bar/Inner Hood(b)
12. Hood Support/Outer Cover Plate/Outer Hood(1 1) -102.8 28.4 0 95267 4709 4735 2197 1.97 3.13 5 Notes.

(a) Node numbers are retained for further reference.

(1-11) Appropriate stress reduction factor for the welds and modifications listed in Table I of Revision 0 of CDI Report 10-12 submitted in NMPNS letter dated July 30, 2010, have been applied. The number refers to the particular location and corresponding stress reduction factor in Table 1 of Revision 0 of CDI Report 10-12 submitted in NMPNS letter dated July 30, 2010.

(b) WF=1.4 7 of 16

ATTACHMENT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR EXTENDED POWER UPRATE OPERATION (NON-PROPRIETARY)

Table RAI-6 S01 (b) - 3 Recalculation of stresses, stress ratios and limiting frequency shifts in Table 9 (cont.) of Revision 0 of CDI Report 10-12 submitted in NMPNS letter dated July 30, 2010 using the Revision 4.1 ACM Model Stress Weld Location Location (in.) node(a) Stress Intensity (psi) Stress Ratio  % Freq.

Ratio x y z Pm Pm+Pb Salt SR-P SR-a Shift SR-a Yes 1. Outer Cover Plate/Outer Hood -102.8 -1 0 95236 1181 2619 2222 5.32 3.09 -10

2. Hood Support/Outer Cover Plate/Outer Hood(11) -102.8 28.4 0 95267 4709 4735 2197 1.97 3.13 5
3. Hood Support/Inner Hood(b) -36.8 0 46.9 95644 798 2176 2034 6.41 3.38 -2.5
4. Top Thick Plate/Inner Hood/Top Plate 24.1 -30.6 88 85512 786 2235 2133 6.24 3.22 2.5
5. Hood Support/Outer Base Plate/Middle Backing Bar 71.3 0 0 98067 4437 4662 2073 2.10 3.31 2.5
6. Thick Vane Bank Plate/Thin Vane Bank Plate/Side -24.1 119 11.6 90170 823 2303 2009 6.05 3.42 5 Plate/Side Plate Ext/End Plate
7. Hood Support/Inner Hood(b) 32.4 0 72.5 99540 593 2522 2166 5.53 3.17 5
8. Hood Support/Inner Hood(b) -38.2 0 34.9 95638 797 1983 1955 7.03 3.51 -2.5
9. Side Plate/Top Plate -80.2 -85.2 88 93031 506 2347 1888 5.94 3.64 5
10. Entry Bottom Perf/Side Plate/End Plate 24.1 119 23.7 91154 1283 2701 1954 5.16 3.52 -5 3 -85.2 87 89317 1072 4195 1677 3.32 4.10 2.5
11. Closure Plate/Middle Hood( ) 60.2
12. Side Plate/Brace( 5 ) 79.7 85.2 31.2 89646 1604 1797 1627 5.79 4.22 2.5

.. .. 13. Hood Support/Inner Hood(b) -36.5 59.5 48.8 90430 745 2023 1884 6.89 3.65 -2.5

14. Hood Support/Middle Hood(b) -63.8 0 72.5 96037 448 2164 1819 6.44 3.78 7.5
15. Outer Cover Plate/Man Way Overlap -106.5 12.5 0 87488 724 2386 1826 5.84 3.76 -10 Notes (a) Node numbers are retained for further reference.

(1-11) Appropriate stress reduction factor for the welds and modifications listed in Table lof Revision 0 of CDI Report 10-12 submitted in NMPNS letter dated July 30, 2010, have been applied. The number refers to the particular location and corresponding stress reduction factor in Table 1 of Revision 0 of CDI Report 10-12 submitted in NMPNS letter dated July 30, 2010.

(b) WF=1.4 8 of 16

ATTACHMENT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR EXTENDED POWER UPRATE OPERATION (NON-PROPRIETARY)

Table RAI-6 S01 (b) - 4 Recalculation of stresses, stress ratios and limiting frequency shifts in Table 10 of Revision 0 of CDI Report 10-12 submitted in NMPNS letter dated July 30,2010, using the Revision 4.1 ACM Model Stress Weld Location Location (in.) node(a) Stress Intensity (psi) Stress Ratio  % Freq.

Ratio x y z Pm Pm+Pb Salt SR-P SR-a Shift SR-a Yes 1. Closure Plate/Middle Hood 60.2 -85.2 87 89317 1247 4878 1949 2.86 3.52 2.5

2. Outer Cover Plate/Outer Hood -102.8 -1 0 95236 1181 2619 2222 5.32 3.09 -10
3. Hood Support/Outer Cover Plate/Outer Hood (11) -102.8 28.4 0 95267 4709 4735 2197 1.97 3.13 5

.. .. 4. Hood Support/Inner Hood(b) -36.8 0 46.9 95644 798 2176 2034 6.41 3.38 -2.5

5. Top Thick Plate/Inner Hood/Top Plate 24.1 -30.6 88 85512 786 2235 2133 6.24 3.22 2.5
6. Hood Support/Outer Base Plate/Middle Backing Bar 71.3 0 0 98067 4437 4662 2073 2.10 3.31 2.5
7. Thick Vane Bank Plate/Thin Vane Bank Plate/Side -24.1 119 11.6 90170 823 2303 2009 6.05 3.42 5 Plate/Side Plate Ext/End Plate
8. Hood Support/Inner Hood(b) 32.4 0 72.5 99540 593 2522 2166 5.53 3.17 5
9. Hood Support/Inner Hood(b) -38.2 0 34.9 95638 797 1983 1955 7.03 3.51 -2.5
10. Side Plate/Top Plate -80.2 -85.2 88 93031 506 2347 1888 5.94 3.64 5
11. Closure Plate/Inner Hood -28.8 -108.6 87 95975 3616 5445 1715 2.56 4.00 5
12. Entry Bottom Perf/Side Plate/End Plate 24.1 119 23.7 91154 1283 2701 1954 5.16 3.52 -5
13. Top Thick Plate/Side Plate/Closure Plate 47.1 -108.6 87.2 96096 2488 3735 1679 3.73 4.09 2.5
14. Side Plate/Brace( 5 ) 79.7 85.2 31.2 89646 1604 1797 1627 5.79 4.22 2.5
15. Hood Support/Inner Hood(b) -36.5 59.5 48.8 90430 745 2023 1884 6.89 3.65 -2.5

.. .. 16. Hood Support/Middle Hood(b) -63.8 0 72.5 96037 448 2164 1819 6.44 3.78 7.5

17. Outer Cover Plate/Man Way Overlap -106.5 12.5 0 87488 724 2386 1826 5.84 3.76 -10 Notes (a) Node numbers are retained for further reference.

(1-11) Appropriate stress reduction factor for the welds and modifications listed Table 1 of Revision 0 of CDI Report 10-12 submitted in NMPNS letter dated July 30, 2010, have been applied. The number refers to the particular location and corresponding stress reduction factor in Table 1 of Revision 0 of CDI Report 10-12 submitted in NMPNS letter dated July 30, 2010.

(b) WF=1.4 9 of 16

ATTACHMENT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR EXTENDED POWER UPRATE OPERATION (NON-PROPRIETARY)

NMP2-EMCB-SD-RAI-8 S01 (a)

CDI Report No.10-09P, "ACM Rev. 4.1: Methodology to predict full-scale steam dryer loads from in-plant measurements,"Rev. 1, June 2010, states that a new version of the ACM, Rev. 4.1, is being used to simulate the NMP2 fluctuating steam dryer loads. The ACM 4.1 uses a ff

)) applied to both the NMP2 data, as well as the QC2 benchmark data, as describedin Section 5.1 of the report. The NRC staff has reviewed this (( )) and concludes that ((

)). Also, coherence uncertainties can be computed for very low coherences. Therefore, there is ((

)). In addition, there is ((

f]. The NRC staff requests the applicant to determine the ((

)) such that they are conservative andprovide the technical basisfor the estimates.

Original NMNPS Response Based on the NRC RAI and the discussions between NMPNS and the NRC staff on September 23, 2010, NMPNS is re-formulating the Acoustic Circuit Model (ACM) Rev. 4.1 model so that:

1. ((
2. ((

)) The application of the model to the NMP2 steam dryer is then done consistent with the benchmark analysis.

Interim benchmark results are shown in Figure RAI-8 SO 1(a) - 1. These figures are typical of the revised benchmark using this approach and should be compared to Figures 6.2f and 6.2h of CDI Report No.10-09P, Rev. 1 (submitted by NMPNS letter dated June 30, 2010). This approach addresses the concern raised in the RAI with regard to the application of the coherence filter. A revised benchmark report (CDI Report No.10-09P) and NMP2 specific loads report (CDI Report No.10-10P) will be provided based on this approach by December 10, 2010.

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))

Figure RAI-8 S01 (a) Power Spectral Density (PSD) comparison at 790 Megawatt Electric (MWe) for pressure sensor data (black curves) and current Acoustic Circuit Model (ACM) Rev. 4.1 prediction (red curves), for P12 (top) and P21 (bottom) 11 of 16

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Final NMPNS Response A revised benchmark report (Revision 2 of CDI Report No. 10-09) and NMP2 specific loads report (Revision 2 of CDI Report No. 10-10) are provided in Attachments 3 and 4 (non-proprietary) and Attachments 7 and 8 (proprietary).

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NMP2-EMCB-SD-RAI-8 S01 (c)

The applicant is requested to provide the signal processing and time recordparameters, such as time record length, window length, window type, number of averages, and any other parameters of interest, used to compute the QC2 benchmark MSL spectra and coherences. The applicant should also explain whether the same time record and signal processing parameters are used for the NMP2 MSL measurements and calculations. If the parameters are different, then the applicant is requested to establish the effects of the differences on the estimated dryer loads and stresses.

NMNPS Response The differences between the QC2 and NMP2 signals are shown below:

Pi nt Samples/sec Sample Time (sec) Points Analyzed QC2 2000 65.5 131,072 N1\ 4P2 2500 104.9 . 262,144 Table RAI-8 SO1 (c) - I - Differences Between QC2 and NMP2 Signals The delta frequency is less than 0.16 Hz. The windowing for coherence and power spectral density (PSD) are 1 Hz. There should be no effect on the estimated dryer loads and stresses as a result of the differences summarized in Table RAI-8 SO 1 (c) - 1.

Revised NMPNS Response The signals from QC2 and NMP2 are compared as shown in the following table:

Plant Samples/sec Sample Time (see) Points Analyzed Windowing QC2 2000 65.5 131,072 Hanning NMP2 2500 104.9 262,144 Hanning Table RAI-8 SO 1 (c) Differences Between QC2 and NMP2 Signals The delta frequency is less than 0.16 Hz. Windowing for coherence and PSD is 1 Hz. Based on engineering judgment, there is no significant effect on the estimated dryer loads and stresses as a result of the differences summarized in Table RAI-8 SO 1 (c) - 1.

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NMP2-EMCB-SD-RAI-8 S01 (d)

It is well established that the accuracy and uncertainty of complex dynamic fluid-structure simulation tools are frequency dependent. The applicant is requested to provide a table of bias errors and uncertaintiesfor the ACM 4.1 overfrequency ranges consistent with those usedfor the ACM 4.0.

Original NMNPS Response NMPNS will revise the ACM Rev. 4.1 model to provide bias and uncertainty values over frequency ranges consistent with those used for ACM Rev. 4.0 by December 10, 2010. These bias and uncertainty values will be very similar to those shown in Figure RAI-8 SO 1 (d) - 1. These were previously provided to the NRC staff at the March 18, 2010 meeting.

Figure RAI-8 SO1 (d) Bias and Uncertainty Values Provided at Meeting Conducted on March 18, 2010 Final NMPNS Response A revised benchmark report (Revision 2 of CDI Report No. 10-09) is provided in Attachment 3 (non-proprietary) and Attachment 7 (proprietary).

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NMP2-EMCB-SD-RAI-23 S01 In its previous RAI response, the applicant conservatively shows that the drain channelflaw will not experience fatigue crack growth during EPU operation because the fatigue stresses acting at the flaw location are not high. However, the NRC staff requests the applicant to re-evaluate its response to this RAI, in light of addressing the supplementary RAls above related to the ACM 4.1 code and bump-up factor.

Original NMPNS Response Based on the response to NMP2-EMCB-SD-RAI-17 S01, a re-evaluation is not required to address NMP2-EMCB-SD-RAI- 17 SO L.

A revision to this RAI response will be issued to address the final response to NMP2-EMCB-SD-RAI-8 SO 1(a) by December 10, 2010.

Final NMPNS Response Based on the response to NMP2-EMCB-SD-RAI-17 S01, a re-evaluation is not required to address NMP2-EMCB-SD-RAI-17 SO1.

In the previous response to NMP2-EMCB-SD-RAI-23 submitted by NMPNS on May 7, 2010, a list of the conservatisms utilized in the skirt/drain channel flaw evaluation were provided. It was discussed that the appropriate and conservative stress measure for this evaluation is the alternating stress intensity in the skirt. In the previous analysis submitted by NMPNS on May 7, 2010, this stress intensity at EPU was 215 pounds per square inch (psi) which corresponds to a range in the mode I stress intensity factor, AKI=0.44 ksi-in' (see the second item in the list of conservatisms on page 20 of the previous response to NMP2-EMCB-SD-RAI-23 submitted by NMPNS on May 7, 2010) using the methodology described in Structural Integrity Associates (SIA) Report 0801273.401 Revision 1 submitted in NMPNS letter dated May 27, 2009. That value corresponded to a Rev. 4.0 ACM model and used low power noise subtraction to estimate the EPU loads. Using the most recent ACM Rev. 4.1 model to estimate acoustic loads as described in Revision 2 to CDI Report Nos. 10-09 and 10-10 provided in this letter and no low power noise subtraction, the stress in the skirt at the limiting stress condition is 156 psi at CLTP and 216 psi at the predicted EPU level. This latter value is very close to the previous prediction (215 psi) and yields the same mode I stress intensity factor. Therefore, there is no change in the conclusions of the prior fatigue crack growth (FCG) assessment of this flaw, and since AKI=0.44 ksi-in' is well below the threshold value of AKTH= 2 .0 ksi-in' needed for crack propagation to occur, no FCG at EPU is predicted.

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NMP2-EMCB-SD-RAI-24 S01 The applicant states that the inspection and the stress analysis results show that the indication in the drain channel-to-skirt vertical weld is not related to flow-induced vibration (FIV)fatigue because (1) the stresses at this weld are low, and (2) the multiple inspections have not shown any growth. The NRC staff requests the applicant to re-evaluate its response to this RAI, in light of addressing the supplementary RAls above to show that the stress analysis resultsfor the NMP2 steam dryer at CLTP are acceptable.In addition, the applicant should note the frequency of the fatigue stresses, with amplitude greater than 13,600 pounds per square-inch, can be lower than 1 Hz, and it may take several operating cycles for crack initiation.

Original NMPNS RESPONSE Based on the response to NMP2-EMCB-SD-RAI-17 SOI, a re-evaluation is not required to address NMP2-EMCB-SD-RAI- 17 SO 1.

A revision to this RAI response will be issued to address the final response to NMP2-EMCB-SD-RAI-8 SOI(a) by December 10, 2010.

While the potential exists for very low frequency to exist, these frequencies do not increase with steam line velocity. Long term monitoring in accordance with BWRVIP-139 will ensure the indications remain stable. No additional evaluation is warranted.

Final NMPNS Response Based on the response to NMP2-EMCB-SD-RAI-17 SOl, a re-evaluation is not required to address NMP2-EMCB-SD-RAI-17 SOL.

As detailed in the current response to NMP2-EMCB-SD-RAI-23 SOI, there is virtually no change in the limiting skirt stress, so the conclusion that no FCG of this putative flaw will occur remains valid.

While the potential exists for very low frequencies to exist, these frequencies do not increase with steam line velocity. Long term monitoring in accordance with BWRVIP-139-A will ensure the indications remain stable. No additional evaluation is warranted.

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ATTACHMENT 2 LIST OF REGULATORY COMMITMENTS Nine Mile Point Nuclear Station, LLC December 10, 2010

ATTACHMENT 2 LIST OF REGULATORY COMMITMENTS The following table identifies the actions committed to in this document by Nine Mile Point Nuclear Station, LLC. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

Direct questions regarding these commitments to J. J. Dosa, Director Licensing, at (315) 349-5219.

REGULATORY COMMITMENT DUE DATE Within two months of final resolution of NRC RAIs Within two months of final resolution of NRC regarding the steam dryer analysis methodology, RAIs regarding the steam dryer analysis NMPNS will submit a revision to CDI Report No. methodology 10-12, Design and Stress Evaluation of Nine Mile Point Unit 2 Steam Dryer Modifications for EPU Operation.

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