ML12249A063

From kanterella
Jump to navigation Jump to search
Response to Request for Voluntary Response to Petition from Barry Quigley Regarding Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2 High-Energy Line Break Analysis
ML12249A063
Person / Time
Site: Byron, Braidwood  Constellation icon.png
Issue date: 08/31/2012
From: Gullott D
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-1 2-145
Download: ML12249A063 (22)
v • d • e


Text

4300 Winfield Road Warrenville. IL 60555

~ EM

~

ue eration630 657 2000 Office EZ1el~bU% Gene ration..)

Proprietary Information - Withhold From Public Disclosure Under 10 CFR 2.390 RS-1 2-145 10 CFR 2.206 August 31, 2012 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN-50-457 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455

Subject:

Response to a Request for Voluntary Response to Petition From Barry Quigley Regarding Byron Station, Unit Nos. 1 and 2, and Braidwood Station, Units 1 and 2 High-Energy Line Break Analysis

References:

1) E-mail from Barry Quigley to the U.S. Nuclear Regulatory Commission, "Petition Pursuant to 2.206," dated April 20, 2012 (ADAMS Accession No. ML12130A318).
2) Letter from J. S. Wiebe (U.S. Nuclear Regulatory Commission) to M. J. Pacilio (Exelon Generation Company, LLC), "Request for Voluntary Response to Petition From Barry Quigley Regarding Byron Station, Unit Nos. 1 and 2, and Braidwood Station, Units 1 and 2 High-Energy Line Break Analysis (TAC Nos. ME8462, ME8463, ME8464, and ME8565)," dated August 2, 2012.

Exelon Generation Company, LLC (EGC) is voluntarily providing information related to a 10 CFR 2.206 Petition review of High Energy Line Break Evaluations for the Byron Station, Unit 1 and 2, and Braidwood Station, Units 1 and 2. On April 20, 2012, EGC received a copy of a petition that was submitted to the U.S. Nuclear Regulatory Commission (NRC) pursuant to 10 CFR 2.206 (Reference 1). Subsequent to receipt of this information, the NRC informed EGC of its right to submit a voluntary response to the issues identified by the petitioner (Reference 2).

This letter provides information related to the petition review. Attachment 1 restates the items (a) through (f) from Reference 2, with a discussion concerning the information and a copy of related references provided in Attachments 2 through 7 to this letter.

Attachments 2 through 7 contain information proprietary to EGC, they are supported by an affidavit signed by EGC, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the NRC under (a)(4) of 10 CFR 2.390 and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Attachments 2 through 7 contain Proprietary Information. Withhold From Public Disclosure Under 10 CFR 2.390. When separated from Attachments 2 through 7, this document is decontrolled.

,4?ov[

njg

August 31, 2012 U. S. Nuclear Regulatory Commission Page 2 2.390, "Public inspections, exemptions, requests for withholding." In addition, the documents identify by name individuals involved in the evaluations reflected in the attachments and reflect personnel information, the disclosure of which would constitute an unwarranted invasion of personal privacy. Such information is exempt from disclosure under 10 CFR 2.390(a)(6).

Accordingly, it is respectfully requested that the information that is proprietary to EGC and personal information be withheld from public disclosure in accordance with 10 CFR 2.390.

Attachments 2 through 7 are proprietary in their entirety. Redacted versions of the proprietary attachments are not included. If the NRC disagrees with EGC's position and is inclined to publicly disclose EGC's proprietary or personnel information, EGC respectfully requests that it be provided with prior notice and an opportunity to redact especially sensitive commercial proprietary or privileged information.

As explained in the attached affidavit, a copy of this response is being provided to the petitioner, Mr. Barry Quigley, for his information. There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Richard W.

McIntosh at (630) 657-2816.

Respectfully, David M. Gullott Manager - Licensing Exelon Generation Company, LLC Attachments: 1. Information Related to a 10 CFR 2.206 Petition of High Energy Line Breaks at Braidwood and Byron Stations

2. Technical Evaluation 389421, Evaluation of High Temperature and Humidity Intake Air on Diesel Engine Operation - (PROPRIETARY)
3. Evaluation EC 385208, Susceptibility of Safety Related Equipment and Components - (PROPRIETARY)
4. Operability Evaluation 11-005: Turbine Building HELB Analysis Input Errors (Byron) - (PROPRIETARY)
5. Operability Evaluation 11-006: Turbine Building HELB Analysis Input Errors (Braidwood) - (PROPRIETARY)
6. Operability Evaluation 12-004: HELB Load Not Considered in Structural Calculation (Braidwood) - (PROPRIETARY)
7. Operability Evaluation 12-005: HELB Load Not Considered in Structural Calculation (Byron) - (PROPRIETARY)
8. Affidavit

August 31, 2012 U. S. Nuclear Regulatory Commission Page 3 cc:

NRC Regional Administrator, Region III NRC Senior Resident Inspector, Braidwood Station NRC Senior Resident Inspector, Byron Station NRC Project Manager, NRR - Braidwood and Byron Stations Mr. Barry Quigley - Byron Station

Bcc (w/out Attachments 2 through 8):

Site Vice President - Braidwood Station Site Vice President - Byron Station Director - Licensing and Regulatory Affairs Manager - Licensing, Braidwood and Byron Stations Regulatory Assurance Manager - Braidwood Station Regulatory Assurance Manager - Byron Station Exelon Document Control Desk - Licensing Commitment Tracking Coordinator - MidWest (M. Mathews)

D. Spitzer (Byron)

W. Feimster (Byron)

G. Hagemann (Byron)

E. Englert (Byron)

J. Bashor (Braidwood)

M. Hobbs (Braidwood)

M. Abbas (Braidwood)

T. Cole (Braidwood)

D. Milroy (Cantera)

R. McIntosh (Cantera)

L. Simpson (Cantera)

D. Galanis (Cantera)

T. Loch (Cantera)

J. Freeman (Cantera)

ATTACHMENT 1 INFORMATION RELATED TO A 10 CFR 2.206 PETITION OF HIGH ENERGY LINE BREAKS AT BRAIDWOOD AND BYRON STATIONS This attachment provides information related to a 10 CFR 2.206 Petition review of High Energy Line Break (HELB) Evaluations for the Byron Station, Unit 1 and 2, and Braidwood Station, Units 1 and 2. This attachment restates items (a) through (f) from Reference 2, with a discussion concerning the information provided.

DISCUSSION:

A response to the Reference 2 items (a) through (f) follows.

"a. Provide the current emergency diesel generator operability evaluation and prior revisions, including the consideration of the potential for combustion air intake to be diluted with steam. Include the basis documents referenced in the operability evaluations, including calculations and supporting analysis. If engineering judgment is relied on, provide the qualitative basis for this judgment if not clearly specified in the operability evaluation."

Response to Item (a):

The impact of the Emergency Diesel Generators (EDGs) ingesting high temperature, high humidity air during an automatic start coincident with a HELB in the Turbine Building (TB) was evaluated in Engineering Technical Evaluation No. 389421. This Technical Evaluation is provided in Attachment 2 along with the following references:

Byron / Braidwood Issue Reports (1365451, 1365361)

Relevant pages from Sargent and Lundy Braidwood and Byron Diesel Engine Generator Sets Specification F-2742/L-2742 "b. Provide the current engineered safety feature (ESF) switchgear room protective relay operability determination and prior revisions, including the consideration of high temperatures on setpoints. Include the basis documents referenced in the operability evaluations, including calculations and supporting analysis. If engineering judgment is relied on, provide the qualitative basis for this judgment if not clearly specified in the operability evaluation."

Response to Item (b):

The impact of a TB HELB on safety related equipment and components in the ESF switchgear rooms is evaluated in Engineering Evaluation No. 385208, Revision 2. This engineering evaluation, along with Revisions 0 and 1, are provided in Attachment 3.

Associated references can be provided upon request.

Page 1 of 5

ATTACHMENT 1 INFORMATION RELATED TO A 10 CFR 2.206 PETITION OF HIGH ENERGY LINE BREAKS AT BRAIDWOOD AND BYRON STATIONS "c. Provide the analysis of the Turbine Building high-energy line break (HELB) impact on the structural integrity of ESF switchgear room walls."

Response to Item (c):

The existing structural analysis for ESF Switchgear room walls does not include the impact of HELB loadings. As a result, this issue was entered into the sites' Corrective Action Program (CAP). The ESF switchgear room structural wall operability is assessed and documented in Operability Evaluation 12-004, Revision 1 (Braidwood) / 12-005, Revision 1 (Byron). These operability evaluations are provided in Attachments 6 and 7.

"d. Provide a description of the methodology used for Turbine Building HELB analysis (i.e., "lumped volume," or "sub-divided volume" as available in the GOTHIC Code, or other methodology), including the basis for its use and if and when the NRC has approved such methodology for this application. Include a discussion of the code of record (Kitty6) and whether or not its use is appropriate."

Response to Item (d):

Presently the TB HELB analysis of record uses the KITTY6 computer code with a lumped volume approach to determine thermal effects (temperature and humidity).

The KITTY6 computer code was used for the original HELB equipment qualification analyses performed in the 1990s. KITTY6 is a proprietary code developed by Sargent and Lundy (S&L) and is verified and validated under the S&L Quality Assurance Program. The details of the KITTY6 pedigree are discussed in Byron Operability Evaluation 11-005, Revision 4 and Braidwood Operability Evaluation 11-006, Revision 3 (Attachments 4 and 5).

EGC considers the KITTY6 code to remain appropriate for temperature and humidity impacts since it accurately implements methodologies provided in Section 6.2.1.2, "Subcompartment Analysis," of NUREG-0800.

Due to some KITTY6 limitations regarding its efficient use (e.g., its proprietary nature prevents third party reviews, lack of modeling versatility, and availability of more state of the art codes), the long term use of KITTY6 to support the HELB licensing and design bases will be evaluated as part of the efforts to reconstitute the TB HELB analysis.

GOTHIC and KITTY6 are presently used to support the operability of the components impacted by a TB HELB. GOTHIC is also used to support the structural operability of the EDG rooms, ESF Switchgear rooms, and the Miscellaneous Electrical Equipment Rooms (MEERs). The initial GOTHIC analyses used in the structural operability evaluations provided in Attachments 6 and 7 utilize a "lumped volume" approach. As discussed below, if EGC intends to incorporate GOTHIC into the Byron and Braidwood licensing and design bases, the changes will be evaluated in accordance with 10 CFR 50.59 to determine if prior NRC approval is required.

To support our evaluation of the 10 CFR 2.206 petition, EGC is performing additional TB dynamic pressurization models using the GOTHIC software code. These new models will use some lumped volumes as well as some subdivided volumes. The results of these additional analyses will be available for review upon completion (estimated in late September 2012).

Page 2 of 5

ATTACHMENT 1 INFORMATION RELATED TO A 10 CFR 2.206 PETITION OF HIGH ENERGY LINE BREAKS AT BRAIDWOOD AND BYRON STATIONS "e. Provide the plan and schedule for completing an assessment of the Turbine Building HELB issues, including an analysis of licensing basis and impact on equipment operability. Also include the following information:

1. The plan and schedule for extent of condition review of HELB areas other than the Turbine Building,
2. The plan and schedule for any decisions related to use of methodology such as when to use the GOTHIC or Kitty6 Code,
3. The plan for keeping up-to-date equipment operability evaluations for Braidwood and Byron, and
4. Whether Exelon has considered having an independent third-party review the plan scope, plan implementation, and resolution of assessment results. If Exelon plans to have an independent third party review performed, include the plan and schedule for this review."

Response to Item (e):

EGC is presently designing and installing safety-related back draft dampers on specific walls to prevent the mass and energy resulting from a TB HELB from entering rooms containing safety related equipment. These back draft dampers, coupled with actions to replace existing fire dampers, installing ventilation auto-restart capability, and installing HELB pressure and temperature sensors, are intended to prevent TB HELB atmosphere from impacting equipment in the EDG rooms, ESF Switchgear rooms, and MEERs. The installation of these plant changes is scheduled to complete by January 2013.

A separate project is in progress to address the questions related to the 10 CFR 2.206 petition. Presently, EGC is evaluating a TB HELB utilizing the GOTHIC Code with subdivided volumes. The following are the key milestones towards completion of this activity.

GOTHIC modeling / analysis to determine time delays (Vendor #1)

Owner Acceptance Review of the Vendor #1 GOTHIC model (EGC)

Transmit new mass and energy information to Vendor #2 (EGC) 3D (subdivided) GOTHIC model (Vendor #2)

Review 3D (subdivided) GOTHIC model (Vendor #3)

Owner Acceptance Review of the 3D (subdivided) GOTHIC model (EGC)

Evaluate 3D (subdivided) GOTHIC model for further actions (EGC)

The GOTHIC subdivided modeling and analyses are scheduled to complete in early October 2012.

Upon completion of the physical modifications, and the GOTHIC modeling and analyses to support both operability and the 2.206 petition, EGC will perform a cumulative engineering Page 3 of 5

ATTACHMENT 1 INFORMATION RELATED TO A 10 CFR 2.206 PETITION OF HIGH ENERGY LINE BREAKS AT BRAIDWOOD AND BYRON STATIONS evaluation of the TB HELB issues. This evaluation will include an assessment of the codes and methodologies available to determine if changes to the current licensing basis and design basis are warranted. Changes to the licensing basis and design basis will be performed and controlled in accordance with EGC processes; including the evaluation of changes in accordance with 10 CFR 50.59 to determine if prior NRC approval is required.

Based on the schedule for completion of the above listed activities, it is planned that this cumulative engineering evaluation will be completed in the first quarter of 2013. As part of the cumulative engineering evaluation's development, EGC is considering an independent third party review of this cumulative engineering evaluation.

The expected completion dates provided above are based on present information and may change. The Byron and Braidwood NRC Senior Resident Inspectors will continue to be briefed on project status and any schedule changes.

The issues related to the TB HELB were initially identified during reviews to support the Measurement Uncertainty Recapture (MUR) project. The MUR reviews did not identify HELB related issues in areas other than the TB. As part of the extent of condition review, EGC is reviewing high energy line cracks in the Auxiliary Building.

The continuing actions related to TB HELB resolution could result in new information that challenges the existing analyses and/or conclusions. New information will be assessed and dispositioned in accordance with the EGC Corrective Action Program, which involves; documenting new information in an Issue Report and then evaluating the impact on system, structure, and component (SSC) operability. In the event that the new information impacts the conclusion or justification of an existing operability evaluation, the CAP process will drive re-evaluation of SSC operability.

f. Provide any other information that you believe would be helpful to the NRC in resolving the April 20, 2012, 10 CFR 2.206, petition.

Response to Item (f): provides all the revisions of the formal Operability Evaluations for the TB HELB issue (Byron 11-005 and 12-005, Braidwood 11-006 and 12-004). These Operability Evaluations were prepared in accordance Exelon Procedures. EGC has not identified any other information necessary to help the NRC resolve the 10 CFR 2.206 petition.

Page 4 of 5

ATTACHMENT 1 INFORMATION RELATED TO A 10 CFR 2.206 PETITION OF HIGH ENERGY LINE BREAKS AT BRAIDWOOD AND BYRON STATIONS

REFERENCES:

1. E-mail from Barry Quigley to the U.S. Nuclear Regulatory Commission, "Petition Pursuant to 2.206," dated April 20, 2012 (ADAMS Accession No. ML12130A318).
2. Letter from J. S. Wiebe (U.S. Nuclear Regulatory Commission) to M. J. Pacilio (Exelon Generation Company, LLC), "Request for Voluntary Response to Petition From Barry Quigley Regarding Byron Station, Unit Nos. 1 and 2, and Braidwood Station, Units 1 and 2 High-Energy Line Break Analysis (TAC Nos. ME8462, ME8463, ME8464, and ME8565),"

dated August 2, 2012.

3. Technical Evaluation 389421, Evaluation of High Temperature and Humidity Intake Air on Diesel Engine Operation, (Attachment 2)
4. Issue Report (IR) 1365451 - Byron, "Questions Regarding Turbine Bldg HELB," initiated on 5/11/2012, (Attachment 2)
5. IR 1365361 - Braidwood, "Questions Regarding Turbine Building HELB," initiated on 5/11/2012, (Attachment 2)
6. Relevant Pages of Specification for EDG, F-2742/L-2742, (Attachment 2)
7. Electrical Evaluation, EC 385208, "Susceptibility of Safety Related Equipment and Components," Approved 6/28/2012, Revision 2; (Including Revisions 0 and 1, approved 07/14/2011), (Attachment 3)
8. Byron Operability Evaluation 11-005, "Turbine Building HELB Analysis Input Errors," [also referenced as EC 383599, Revision 0 through 4], (Attachment 4)
9. Byron and Braidwood Turbine Building HELB Analysis Summary, dated October 4, 2011,

[also with header of EC 383599, Revision 3, Attachment 1, Main Body], (refer to the embedded files shown in Attachment 4).

10. Braidwood Operability Evaluation 11-006, Turbine Building HELB Analysis Input Errors, Revision 3 approved 7/15/2011, (Attachment 5)
11. Braidwood Operability Evaluation 12-004, HELB Load Not Considered in Structural Calculation, Revision 1, approved 7/24/2012 (Attachment 6).
12. Byron Operability Evaluation 12-005, HELB Load Not Considered in Structural Calculation

[also referred to EC 389402], Revision 1, approved 7/24/2012 (Attachment 7)

Page 5 of 5 Affidavit

AFFIDAVIT OF DAVID M. GULLOTT DOCKET NOS STN 50-454, STN 50-455, STN 50-456, STN 50-457 1, David M. Gullott, Licensing Manager, Exelon Generation Company, LLC, do hereby affirm and state:

1. I am a Licensing Manager for Exelon Generation Company, LLC (EGC), and I am authorized to execute this affidavit on behalf of EGC.
2. I am further authorized to review the documents sought to be withheld from public disclosure in response to the August 2, 2012, letter from the Nuclear Regulatory Commission requesting that EGC provide a voluntary response to a Petition from Barry Quigley Regarding Byron Station Units 1 and 2 and Braidwood Station Units 1 and 2, High Energy Line Break Analysis (ascension number ML12208A338).
3. I am also authorized to apply to the NRC for the withholding of the aforementioned documents from public disclosure under 10 C.F.R. §§ 2.390(a)(4) and 9.17(a)(4) on the grounds that the documents contain confidential or privileged commercial information.

The documents EGC seeks to withhold from public disclosure have been marked "Proprietary" and are summarized in the attachment to my Affidavit.

4. On behalf of EGC, I request that the documents marked by EGC as "Proprietary" and described in the attached list (Appendix 1) be withheld, in their entirety, by the NRC from public disclosure.
5. In making this application for withholding of proprietary and confidential information of which EGC is the owner, EGC relies on 10 C.F.R. § 2.390(a)(4) and 10 C.F.R. 9.17(a)(4).

The proprietary documents contain confidential or privileged commercial information.

6. The proprietary information described in Appendix 1 should be withheld from disclosure by the NRC pursuant to the policy reflected in 10 C.F.R. § 2.390(a)(4), and for the following reasons to be considered pursuant to 10 CFR § 2.390(b)(4):
i. The documents contain information that was collected and evaluated pursuant to an internal self-evaluation process in accordance with EGC processes and procedures of the Exelon Nuclear Management Model.
a. The Management Model is a set of confidential policies and procedures that enable EGC to consistently achieve excellence in all key dimensions of its business. It documents proven ways of achieving excellence and defines how EGC executes and manages performance and assesses results. EGC expended significant resources, in terms of time and money, to develop, implement, and update the Management Model. EGC derives economic benefit from the Management Model in terms of increased efficiency and improved results as well as revenue generated from EGC's sale or licensing of the Management Model.

Affidavit of David Gullott Page 1 of 3

b. The operability evaluations, technical evaluations, and engineering change evaluations that EGC is voluntarily providing to the NRC were created in accordance with procedures and processes under the Management Model and at significant cost to EGC. The documents that are the subject of the August 2 letter were prepared pursuant to the Management Model and reflect questions asked, information collected, and evaluation processes that are embedded in the Management Model procedures. The information reflected in the document could not be easily acquired or duplicated by others without others doing their own evaluation and assessment. EGC protects this type of information from public disclosure and providing the documents to the public would circumvent EGC's efforts to protect its intellectual property and would result in competitive harm to EGC. These documents should, therefore, be withheld under §§ 2.930(a)(4) and 9.17(a)(4).
c. In addition, the documents contain information that was provided by contractors and vendors that EGC retained, at its own expense, to assist in the evaluation.

EGC considers the information provided by the contractors and vendors to be confidential, and the conditions of the relationship require or assume confidentiality of information provided by the contractors or vendors.

ii. The documents were not prepared for submission to the NRC. EGC is providing the documents voluntarily and not pursuant to a regulatory obligation.

iii. The documents are now, and have been, held in confidence by EGC. EGC does not customarily make these documents available to the public. EGC has not authorized making the documents available through public sources.

v. EGC is providing the NRC with the documents and information in confidence.

vii. In addition, EGC's evaluation is ongoing and updated as new information becomes available. Disclosure of preliminary information could result in misinterpretation or misuse of the data.

7. Barry Quigley, the individual who filed the 2.206 Petition to which the NRC now seeks a voluntary response, is an employee of EGC and has access to each of the documents identified in Appendix 1 through his employment with EGC. The documents at issue are confidential and proprietary under Exelon's Corporation Code of Business Conduct and Exelon's Corporate Procedure for Protecting Exelon Information. As an employee of EGC, Mr. Quigley is required and expected to comply with these policies and procedures.

EGC will provide to Mr. Quigley, in his capacity as an employee of EGC, a copy of the documents identified in Appendix 1, subject to EGC's confidentiality policies and procedures. Accordingly, any public policy interest in disclosing the documents is mitigated by the fact that the individual who submitted the 2.206 Petition already has access to the documents.

Affidavit of David Gullott Page 2 of 3

I declare under penalty of perjury that the foregoing affidavit and statements therein are true and correct to the best of my knowledge, information, and belief.

David'RGullott Licensing Manager Exelon Generation Company, LLC Date:

8el 11 If.

Affidavit of David Gullott Page 3 of 3

Appendix 1 Appendix 1: Information that Should Be Withheld from Public Disclosure

Revision, Description of bcument C

Rason s).to Withhold Rev 0 Byron Operability Evaluation 11-005, Turbine Building HELB Analysis Errors (1) Internal document created for EGC's own use, submitted to the NRC voluntarily, in confidence, and not pursuant to a regulatory requirement; (2) Exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.17(a)(4) because the information reflected in the document is confidential or privileged commercial information that was collected, that was prepared in accordance with, and that reflects processes, questions, and elements of the Exelon Nuclear Management Model procedures, which EGC developed at significant cost and from which EGC generates revenue through sale or lease of the Management Model; EGC has expended significant resources in terms of time and money to develop the information reflected in the document; the information reflected in the document could not be easily acquired or duplicated by others without others doing their own evaluation and assessment; EGC maintains the document and information in the document, including information provided by vendors and contractors, confidentially and keeps the information from its competitors and unauthorized third parties; and release to the public would circumvent EGC's efforts to maintain the confidentiality of its processes, information, and intellectual property, and place it at a competitive disadvantage.

Appendix 1 Appendix 1: Information that Should Be Withheld from Public Disclosure Dae; or of Document 1 0-* 9 kke vi-s io Y

16 n Rev 1 Byron Operability Evaluation 11-(1) Internal document created for EGC's own use, submitted to the NRC voluntarily, in 005, Turbine Building HELB confidence, and not pursuant to a regulatory requirement; Analysis Errors (2) Exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.17(a)(4) because the information reflected in the document is confidential or privileged commercial information that was collected, that was prepared in accordance with, and that reflects processes, questions, and elements of the Exelon Nuclear Management Model procedures, which EGC developed at significant cost and from which EGC generates revenue through sale or lease of the Management Model; EGC has expended significant resources in terms of time and money to develop the information reflected in the document; the information reflected in the document could not be easily acquired or duplicated by others without others doing their own evaluation and assessment; EGC maintains the document and information in the document, including information provided by vendors and contractors, confidentially and keeps the information from its competitors and unauthorized third parties; and release to the public would circumvent EGC's efforts to maintain the confidentiality of its processes, information, and intellectual property, and place it at a competitive disadvantage.

Rev 2 Byron Operability Evaluation 11-(1) Internal document created for EGC's own use, submitted to the NRC voluntarily, in 005, Turbine Building HELB confidence, and not pursuant to a regulatory requirement; Analysis Errors (2) Exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.17(a)(4) because the information reflected in the document is confidential or privileged commercial information that was collected, that was prepared in accordance with, and that reflects processes, questions, and elements of the Exelon Nuclear Management Model procedures, which EGC developed at significant cost and from which EGC generates revenue through sale or lease of the Management Model; EGC has expended significant resources in terms of time and money to develop the information reflected in the document; the information reflected in the document could not be easily acquired or duplicated by others without others doing their own evaluation and assessment; EGC maintains the document and information in the document, including information provided by vendors and contractors, confidentially and keeps the information from its competitors and unauthorized third parties; and release to the public would circumvent EGC's efforts to maintain the confidentiality of its processes, information, and intellectual property, and place it at a competitive disadvantage.

Al -2

Appendix I Appendix 1: Information that Should Be Withheld from Public Disclosure

-. o:

D-t*oiptionof D m

'Reason(s)-to.Withhold Rev 3 Byron Operability Evaluation 11-(1) Internal document created for EGC's own use, submitted to the NRC voluntarily, in 005, Turbine Building HELB confidence, and not pursuant to a regulatory requirement; Analysis Errors (2) Exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.17(a)(4) because the information reflected in the document is confidential or privileged commercial information that was collected, that was prepared in accordance with, and that reflects processes, questions, and elements of the Exelon Nuclear Management Model procedures, which EGC developed at significant cost and from which EGC generates revenue through sale or lease of the Management Model; EGC has expended significant resources in terms of time and money to develop the information reflected in the document; the information reflected in the document could not be easily acquired or duplicated by others without others doing their own evaluation and assessment; EGC maintains the document and information in the document, including information provided by vendors and contractors, confidentially and keeps the information from its competitors and unauthorized third parties; and release to the public would circumvent EGC's efforts to maintain the confidentiality of its processes, information, and intellectual property, and place it at a competitive disadvantage.

Rev 4 Byron Operability Evaluation 11-(1) Internal document created for EGC's own use, submitted to the NRC voluntarily, in 005, Turbine Building HELB confidence, and not pursuant to a regulatory requirement; Analysis Errors (2) Exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.17(a)(4) because the information reflected in the document is confidential or privileged commercial information that was collected, that was prepared in accordance with, and that reflects processes, questions, and elements of the Exelon Nuclear Management Model procedures, which EGC developed at significant cost and from which EGC generates revenue through sale or lease of the Management Model; EGC has expended significant resources in terms of time and money to develop the information reflected in the document; the information reflected in the document could not be easily acquired or duplicated by others without others doing their own evaluation and assessment; EGC maintains the document and information in the document, including information provided by vendors and contractors, confidentially and keeps the information from its competitors and unauthorized third parties; and release to the public would circumvent EGC's efforts to maintain the confidentiality of its processes, information, and intellectual property, and place it at a competitive disadvantage.

Al -3

Appendix 1 Appendix 1: Information that Should Be Withheld from Public Disclosure bateor

-D m nt,.

..........., o escriptionof Douet

~

Ra~~~o itfh6ld:~

Rev 0 Braidwood Operability Evaluation (1) Internal document created for EGC's own use, submitted to the NRC voluntarily, in 11-006, Turbine Building HELB confidence, and not pursuant to a regulatory requirement; Analysis Input Errors (2) Exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.17(a)(4) because the information reflected in the document is confidential or privileged commercial information that was collected, that was prepared in accordance with, and that reflects processes, questions, and elements of the Exelon Nuclear Management Model procedures, which EGC developed at significant cost and from which EGC generates revenue through sale or lease of the Management Model; EGC has expended significant resources in terms of time and money to develop the information reflected in the document; the information reflected in the document could not be easily acquired or duplicated by others without others doing their own evaluation and assessment; EGC maintains the document and information in the document, including information provided by vendors and contractors, confidentially and keeps the information from its competitors and unauthorized third parties; and release to the public would circumvent EGC's efforts to maintain the confidentiality of its processes, information, and intellectual property, and place it at a competitive disadvantage.

Rev I Braidwood Operability Evaluation (1) Internal document created for EGC's own use, submitted to the NRC voluntarily, in 11-006, Turbine Building HELB confidence, and not pursuant to a regulatory requirement; Analysis Input Errors (2) Exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.17(a)(4) because the information reflected in the document is confidential or privileged commercial information that was collected, that was prepared in accordance with, and that reflects processes, questions, and elements of the Exelon Nuclear Management Model procedures, which EGC developed at significant cost and from which EGC generates revenue through sale or lease of the Management Model; EGC has expended significant resources in terms of time and money to develop the information reflected in the document; the information reflected in the document could not be easily acquired or duplicated by others without others doing their own evaluation and assessment; EGC maintains the document and information in the document, including information provided by vendors and contractors, confidentially and keeps the information from its competitors and unauthorized third parties; and release to the public would circumvent EGC's efforts to maintain the confidentiality of its processes, information, and intellectual property, and place it at a competitive disadvantage.

A1 -4

Appendix I Appendix 1: Information that Should Be Withheld from Public Disclosure Date o-RvsnDescriptix o~cment Rason(s,)to0 Wi thh old.7<-.

Rev 2 Braidwood Operability Evaluation (1) Internal document created for EGC's own use and not pursuant to regulatory 11-006, Turbine Building HELB requirements or for submission to the NRC; Analysis Input Errors (2) Exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.17(a)(4) because the information reflected in the document was collected and prepared as part of the self-evaluation process which will be eroded if the confidence in the system and development of information is revealed wholesale to the public; the self-evaluation process, including collection and evaluation of information, is ongoing, so the document is still a work in progress; EGC has expended significant resources in terms of time and money to develop the information reflected in the document; the information reflected in the document could not be easily acquired or duplicated by others without others doing their own evaluation and assessment; EGC maintains the document and information in the document confidentially and keeps the information from its competitors and unauthorized third parties; and release to the public would circumvent EGC's efforts to maintain the confidentiality of its processes and information and place it at a competitive disadvantage.

Rev 3 Braidwood Operability Evaluation (1) Internal document created for EGC's own use and not pursuant to regulatory 11-006, Turbine Building HELB requirements or for submission to the NRC; Analysis Input Errors (2) Exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.17(a)(4) because the information reflected in the document was collected and prepared as part of the self-evaluation process which will be eroded if the confidence in the system and development of information is revealed wholesale to the public; the self-evaluation process, including collection and evaluation of information, is ongoing, so the document is still a work in progress; EGC has expended significant resources in terms of time and money to develop the information reflected in the document; the information reflected in the document could not be easily acquired or duplicated by others without others doing their own evaluation and assessment; EGC maintains the document and information in the document confidentially and keeps the information from its competitors and unauthorized third parties; and release to the public would circumvent EGC's efforts to maintain the confidentiality of its processes and information and place it at a competitive disadvantage.

Al -5

Appendix 1 Appendix 1: Information that Should Be Withheld from Public Disclosure

'Date or, eRvisioij

  • Description of DOcument

~Reason(s) to Withhold-

. V- -

Exelon Technical Evaluation 389421, Evaluation of High Temperature and Humidity Intake Air on Diesel Engine Operation (also including references: Byron IR 1365451, Braidwood IR 136536 1, and 2 pages from Sargent

& Lundy Braidwood and Byron Diesel Engine Generator Set Specification F-2741/L-2742 dated 4/18/1977)

(1) Internal document created for EGC's own use, submitted to the NRC voluntarily, in confidence, and not pursuant to a regulatory requirement; (2) Exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.17(a)(4) because the information reflected in the document is confidential or privileged commercial information that was collected, that was prepared in accordance with, and that reflects processes, questions, and elements of the Exelon Nuclear Management Model procedures, which EGC developed at significant cost and from which EGC generates revenue through sale or lease of the Management Model; EGC has expended significant resources in terms of time and money to develop the information reflected in the document; the information reflected in the document could not be easily acquired or duplicated by others without others doing their own evaluation and assessment; EGC maintains the document and information in the document, including information provided by vendors and contractors, confidentially and keeps the information from its competitors and unauthorized third parties; and release to the public would circumvent EGC's efforts to maintain the confidentiality of its processes, information, and intellectual property, and place it at a competitive disadvantage.

L

-I-Rev 0 Exelon Engineer Change Evaluation 385208 (1) Internal document created for EGC's own use, submitted to the NRC voluntarily, in confidence, and not pursuant to a regulatory requirement; (2) Exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.17(a)(4) because the information reflected in the document is confidential or privileged commercial information that was collected, that was prepared in accordance with, and that reflects processes, questions, and elements of the Exelon Nuclear Management Model procedures, which EGC developed at significant cost and from which EGC generates revenue through sale or lease of the Management Model; EGC has expended significant resources in terms of time and money to develop the information reflected in the document; the information reflected in the document could not be easily acquired or duplicated by others without others doing their own evaluation and assessment; EGC maintains the document and information in the document, including information provided by vendors and contractors, confidentially and keeps the information from its competitors and unauthorized third parties; and release to the public would circumvent EGC's efforts to maintain the confidentiality of its processes, information, and intellectual property, and place it at a competitive disadvantage.

Al -6

Appendix I Appendix 1: Information that Should Be Withheld from Public Disclosure Date or.6f pD e.t-

.W ithhold Descriti Dof curnen t'ith Rev I Exelon Engineer Change (1) Internal document created for EGC's own use, submitted to the NRC voluntarily, in Evaluation 385208 confidence, and not pursuant to a regulatory requirement; (2) Exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.17(a)(4) because the information reflected in the document is confidential or privileged commercial information that was collected, that was prepared in accordance with, and that reflects processes, questions, and elements of the Exelon Nuclear Management Model procedures, which EGC developed at significant cost and from which EGC generates revenue through sale or lease of the Management Model; EGC has expended significant resources in terms of time and money to develop the information reflected in the document; the information reflected in the document could not be easily acquired or duplicated by others without others doing their own evaluation and assessment; EGC maintains the document and information in the document, including information provided by vendors and contractors, confidentially and keeps the information from its competitors and unauthorized third parties; and release to the public would circumvent EGC's efforts to maintain the confidentiality of its processes, information, and intellectual property, and place it at a competitive disadvantage.

Rev 2 Exelon Engineer Change (1) Internal document created for EGC's own use, submitted to the NRC voluntarily, in Evaluation 385208 confidence, and not pursuant to a regulatory requirement; (2) Exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.17(a)(4) because the information reflected in the document is confidential or privileged commercial information that was collected, that was prepared in accordance with, and that reflects processes, questions, and elements of the Exelon Nuclear Management Model procedures, which EGC developed at significant cost and from which EGC generates revenue through sale or lease of the Management Model; EGC has expended significant resources in terms of time and money to develop the information reflected in the document; the information reflected in the document could not be easily acquired or duplicated by others without others doing their own evaluation and assessment; EGC maintains the document and information in the document, including information provided by vendors and contractors, confidentially and keeps the information from its competitors and unauthorized third parties; and release to the public would circumvent EGC's efforts to maintain the confidentiality of its processes, information, and intellectual property, and place it at a competitive disadvantage.

Al -7

Appendix 1 Appendix 1: Information that Should Be Withheld from Public Disclosure

-Date'or--ResnstoWthl.

.Revisi 6 rY><

Description of -cument

.Reson(s)

Rev 0 Operability Evaluation Braidwood (1) Internal document created for EGC's own use, submitted to the NRC voluntarily, in 12-004/Byron 12-005, HELB Load confidence, and not pursuant to a regulatory requirement; Not Considered In Structural (2) Exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.17(a)(4) because the Calculation information reflected in the document is confidential or privileged commercial information that was collected, that was prepared in accordance with, and that reflects processes, questions, and elements of the Exelon Nuclear Management Model procedures, which EGC developed at significant cost and from which EGC generates revenue through sale or lease of the Management Model; EGC has expended significant resources in terms of time and money to develop the information reflected in the document; the information reflected in the document could not be easily acquired or duplicated by others without others doing their own evaluation and assessment; EGC maintains the document and information in the document, including information provided by vendors and contractors, confidentially and keeps the information from its competitors and unauthorized third parties; and release to the public would circumvent EGC's efforts to maintain the confidentiality of its processes, information, and intellectual property, and place it at a competitive disadvantage.

A1 - 8

Appendix 1 Appendix 1: Information that Should Be Withheld from Public Disclosure k

Date;-ri Description of Document

.7I easonI(to Withhold Rev I Operability Evaluation Braidwood (1) Internal document created for EGC's own use, submitted to the NRC voluntarily, in 12-004/Byron 12-005, HELB Load confidence, and not pursuant to a regulatory requirement; Not Considered In Structural (2) Exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.17(a)(4) because the Calculation, Revisions 0 and 1.

information reflected in the document is confidential or privileged commercial information that was collected, that was prepared in accordance with, and that reflects processes, Attachments of Revision I include:

questions, and elements of the Exelon Nuclear Management Model procedures, which EGC (1) Numerical Applications, Inc.,

developed at significant cost and from which EGC generates revenue through sale or lease Review of Byron/Braidwood 426' of the Management Model; EGC has expended significant resources in terms of time and Level Turbine Building HELB money to develop the information reflected in the document; the information reflected in the Model document could not be easily acquired or duplicated by others without others doing their (2) Computation of Available Wall own evaluation and assessment; EGC maintains the document and information in the Differential Pressure Margin document, including information provided by vendors and contractors, confidentially and (3) Byron/Braidwood Station U1 &

keeps the information from its competitors and unauthorized third parties; and release to the U2, Auxiliary Building Areas 1 &4 public would circumvent EGC's efforts to maintain the confidentiality of its processes, Functionality Evaluation Summary information, and intellectual property, and place it at a competitive disadvantage.

Main Divider Walls for DG Rooms, ESF Switchgear Rooms and MEERs prepared by Sargent and Lundy (4) Byron/Braidwood Station UI &

U2, Auxiliary Building Areas 1 &4 L-Line Wall Functionality Evaluation Summary Main prepared by Sargent and Lundy (5) Byron/Braidwood Station UI &

U2 Summary of GOTHIC Output A1 -9

Retrieved from "https://kanterella.com/w/index.php?title=ML12249A063&oldid=5252582"