ML14105A385

Attachment 8: WCAP-17635-NP, Rev. 3, Comprehensive Vibration Assessment Program

ML14105A385
Person / Time
Site:	Peach Bottom
Issue date:	04/11/2014
From:	Zalewski T Westinghouse
To:	Office of Nuclear Reactor Regulation
Shared Package
ML14105A383	List: ML14105A384 ML14105A385 ML14105A386 ML14105A387 ML14105A388
References
CAW-14-3939, CAW-14-3940, CAW-14-3941, CAW-14-3942, CAW-14-3944 WCAP-17635-NP, Rev 3
Download: ML14105A385 (31)

Text

Attachment 8 Peach Bottom Atomic Power Station Units 2 and 3 NRC Docket Nos. 50-277 and 50-278 WCAP-17635, Rev 3, Comprehensive Vibration Assessment Program

Westinghouse Non-Proprietary Class 3 WCAP-17635-NP - Enclosure 15A April 2014 Revision 3 Peach Bottom Atomic Power Station Unit 2 and Unit 3 Replacement Steam Dryer Comprehensive Vibration Assessment Program (CVAP)

Westinghouse

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-17635-NP- Enclosure 15A Revision 3 Peach Bottom Atomic Power Station Unit 2 and Unit 3 Replacement Steam Dryer Comprehensive Vibration Assessment Program (CVAP)

April 2014 Author: Tom Zalewski*

Project Manager, Engineering Services Reviewer: Brad Maurer*

Plant Licensing Approved: Karen Fujikawa*

Manager, BWR Plant and Stress Analysis

• Electronically approved records are authenticated in the electronic document management system.

Westinghouse Electric Company LLC 1000 Westinghouse Drive Cranberry Township, PA 16066

© 2014 Westinghouse Electric Company LLC All Rights Reserved WCAP- 17635-NP -Enclosure 15A

ii RECORD OF REVISIONS Description Completed Original issue 8/28/12 Revised in accordance with customer audit. Due to the extent of revisions, 9/24/12 change bars are not used.

Revised to reflect change from ACM 4.1 to ACE Rev. 2 and ACE+SPM Rev. 2 3/6/14 methodologies.

Revised Table 5-1 and Section 7. See EDMS WCAP- 17635-NP - Enclosure 15A April 2014 Revision 3

iii TABLE OF CONTENTS R E C O RD OF REV ISION S .......................................................................................................................... ii L IS T O F TA B L ES ....................................................................................................................................... iv LIS T OF F IGU RE S ..................................................................................................................................... iv LIST OF EN C L O SU RE S ............................................................................................................................ iv ACRONYMS AND ABBREVIATIONS ...................................................................................................... v O

OV ERV IE W ................................................................................................................................. 1-1 1.1 REGULATORY BASIS AND GUIDANCE ................................................................................. 1-1 2 BACKGROUND, DESIGN OVERVIEW, AND CVAP ........................................................... 2-1 2.1 DESIGN OF THE REPLACEMENT STEAM DRYER .............................................................. 2-1 2.1.1 MODELING TECHNIQUES FOR DESIGN .................................................................. 2-2 2.1.2 M ATE RIA L ..................................................................................................................... 2-3 2.1.3 TREATMENT OF STRUCTURAL DAMPING ............................................................. 2-3 2.2 COMPREHENSIVE VIBRATION ASSESSMENT PROGRAM (CVAP) .................................. 2-3 2.2.1

SUMMARY

DESCRIPTION ........................................................................................... 2-3 2.2.2 C LA SSIFIC AT IO N ......................................................................................................... 2-5 3 ANALYSIS OF THE REPLACEMENT STEAM DRYER .......................................................... 3-1 3.1 ACOUSTIC CIRCUIT ENHANCED ........................................................................................... 3-1 3.2 SCALE MODEL TESTING OF THE REPLACEMENT STEAM DRYER ................................ 3-1 3.3 STRESS ANALYSIS OF THE REPLACEMENT STEAM DRYER ........................................... 3-1 4 MEASUREMENT PROGRAM OVERVIEW ............................................................................. 4-1 4.1 INSTRUMENTATION PROVIDED WITH THE REPLACEMENT STEAM DRYER (PBA PS UN IT 2, PRO TO TY PE) ................................................................................................. 4-1 4.2 INSTRUMENTATION ON THE MAIN STEAM LINES (PBAPS UNIT 2 AND PBAPS U N IT 3 ) ......................................................................................................................................... 4 -1 5 INSPECTION PROGRAM OVERVIEW .................................................................................... 5-1 5.1 INSPECTION PLAN DESCRIPTION .................................................................................... 5-1 5.2 INTERGRANULAR STRESS CORROSION CRACKING (IGSCC) AND HIGH CYCLE FATIGUE CRACKING CONSIDERATIONS ............................................................................. 5-1 5.3 PRE-INSTALLATION INSPECTIONS ....................................................................................... 5-1 5.4 DRYER INSPECTION PLAN FOLLOWING FIRST CYCLE OF OPERATION ..................... 5-1 5.5 INSPECTIONS SUBSEQUENT TO THE FIRST OPERATING CYCLE INSPECTION .......... 5-5 6 POWER ASCENSION PROGRAM OVERVIEW ....................................................................... 6-1 7 N R C WRITTEN REPO RT S ......................................................................................................... 7-1 8 RE FE RE N C E S ............................................................................................................................. 8-1 WCAP- 17635-NP - Enclosure 15A April 2014 Revision 3

iv LIST OF TABLES Table 2-1 Comparison of Key Steam Dryer Parameters ........................................................................... 2-8 Table 2-2 Comparison of Key Reactor Pressure Vessel Parameters ......................................................... 2-8 Table 2-3 Comparison of Key Hydraulic Parameters ............................................................................... 2-9 Table 2-4 Comparison of Key Main Steam Line Parameters .................................................................... 2-9 Table 5-1 Inspection Locations for Unit 2 and Unit 3 RSD Following 1st Cycle of Operation at EPU C on dition s ................................................................................................................................. 5-3 Table 5-2 Inspection Locations for Both Plants Subsequent to the First Operating Cycle Inspection ..... 5-6 LIST OF FIGURES Figure 2-1 Westinghouse Replacement Steam Dryer Configuration .................................................... 2-1 Figure 5-1 V iew of O uter Hood ................................................................................................................ 5-4 Figure 5-2 Top V iew of RSD .................................................................................................................... 5-4 Figure 5-3 B ottom View of R SD .............................................................................................................. 5-5 LIST OF ENCLOSURES Enclosure B. 1 "Acoustic Load Definition" Enclosure B.2 "Replacement Steam Dryer Structural Evaluation for High-Cycle Acoustic Loads" Enclosure B.3 "ASME Code Stress Report" Enclosure B.4U2 "Peach Bottom Unit 2 Replacement Steam Dryer Power Ascension Program Description for Extended Power Uprate" Enclosure B.4U3 "Peach Bottom Unit 3 Replacement Steam Dryer Power Ascension Program Description for Extended Power Uprate" Enclosure B.5 "Replacement Steam Dryer Four-Line Subscale Acoustic Test Data Evaluation and Derivation of CLTP-to-EPU Scaling Spectra" Enclosure B.6 "Processing of MSL Strain Gauge Data and Computation of Predicted EPU Signature" Enclosure B.7 "Instrumentation Description for the Peach Bottom Unit 2 Replacement Steam Dryer" WCAP-17635-NP - Enclosure 15A April 2014 Revision 3

V ACRONYMS AND ABBREVIATIONS ACE Acoustic Circuit Enhanced ACE+SPM Acoustic Circuit Enhanced + Skirt Protection Model BWR Boiling Water Reactor CLTP Current Licensed Thermal Power CVAP Comprehensive Vibration Assessment Program DAS Data Acquisition System EPU Extended Power Uprate FIV Flow Induced Vibration FEM Finite Element Model GDC General Design Criteria LAR License Amendment Request MCO Moisture Carryover MSL Main Steam Line NRC Nuclear Regulatory Commission OD Outside Diameter OE Operating Experience OEM Original Equipment Manufacturer OLTP Original Licensed Thermal Power PBAPS Peach Bottom Atomic Power Station RG Regulatory Guide RPV Reactor Pressure Vessel RSD Replacement Steam Dryer SAFDL Specified Acceptable Fuel Design Limits SG Strain Gauge SRP Standard Review Plan SRV Safety Relief Valve SSC Systems, Structures, and Components SSV Steam Safety Valve ANSYS, ANSYS Workbench, AUTODYN, CFX, FLUENT and any and all ANSYS, Inc. brand, product, service and feature names, logos and slogans are registered trademarks or trademarks of ANSYS, Inc. or its subsidiaries in the United States or other countries. All other brand, product, service and feature names or trademarks are the property of their respective owners.

WCAP- 17635-NP - Enclosure 15A April 2014 Revision 3

1-1 1 OVERVIEW Exelon Nuclear is in the process of submitting extended power uprate (EPU) applications for the Peach Bottom Atomic Power Station (PBAPS) Unit 2 and PBAPS Unit 3 plants. As part of the EPU License Amendment Request (LAR), Exelon is proposing to replace the existing Original Equipment Manufacturer (OEM) parallel panel steam dryers with a Westinghouse 3-ring octagonal steam dryer.

The purpose of this document is to describe the Comprehensive Vibration Assessment Program (CVAP) for the replacement steam dryers (RSD) for these plants and to demonstrate the acceptability of the program to the applicable U.S. Nuclear Regulatory Commission (NRC) regulatory requirements and guidance. As such, this document provides an overview of the site-specific analysis, measurement and inspection programs documented in Enclosures B. 1 through B.7 of this attachment that verify the structural integrity of the PBAPS Units 2 and 3 replacement steam dryers.

Section 2 of this report provides an overview of the replacement steam dryer design and analysis techniques as well as a summary description of the CVAP and the classification strategy for the prototype and non-prototype plants. Section 3 identifies additional enclosures to this attachment that provide: (1) a summary of the analysis methods and results for determining acoustic loads and acoustic stresses on the dryer, (2) a description of the subscale testing used for deriving scaling spectra from current licensed thermal power (CLTP) with the OEM dryer to EPU conditions with the RSD, and (3) analysis description and results for the ASME stress report. Section 4 describes the instrumentation to be provided on the PBAPS Unit 2 prototype plant and on the PBAPS Unit 3 non-prototype plant that will provide the data used for determination of the stresses on the RSD and to verify the predictive analysis is adequate to confirm the calculation of those stresses. Section 5 provides the RSD inspection plan description for both the prototype and non-prototype plant dryers. Section 6 identifies the LAR enclosure for the power ascension test program. Section 7 provides a summary of the content and schedule for NRC reports.

Section 8 provides a list of references.

1.1 REGULATORY BASIS AND GUIDANCE Reactor internals components, including the steam dryer, must be designed to meet the requirements of the applicable NRC General Design Criteria (GDC), commensurate with their safety function. Although some internals components, such as the steam dryers, perform no safety function, they must retain their structural integrity to avoid generation of loose parts that may adversely impact the capability of other systems, structures, and components (SSCs) to perform their safety function. The NRC's acceptance criteria for EPU conditions per the guidance of RS-00 1, "Review Standard for Extended Power Uprates,"

are based on 10 CFR 50.55a and the following GDC's.

• 10 CFR 50.55a and GDC-1 require that SSCs important to safety be designed, fabricated, erected, constructed, tested, and inspected to quality standards commensurate with the importance of the safety functions to be performed, and address adverse flow effects.

" GDC-2 requires that SSCs important to safety be designed to withstand the effects of earthquakes combined with the effects of normal or accident conditions.

WCAP- 17635-NP - Enclosure 15A April 2014 Revision 3

1-2 GDC-4 requires that SSCs important to safety be designed to accommodate the effects of and to be compatible with the environmental conditions associated with normal operation, maintenance, testing, and postulated accidents, and includes acoustic vibration loads, operational transients, and postulated pipe rupture transient.

GDC-10 requires that the reactor core be designed with appropriate margin to assure that specified acceptable fuel design limits (SAFDLs) are not exceeded during any condition of normal operation, including the effects of anticipated operational occurrences. There must be no adverse impact on fuel, reactivity control, or core cooling.

Specific guidance for meeting these regulations is provided in Standard Review Plan (SRP) 3.9. 1, "Special Topics for Mechanical Components," SRP 3.9.2, "Dynamic Testing and Analysis of Systems, Structures, and Components," SRP 3.9.3, "ASME Code Class 1, 2, and 3 Components and Component Supports, and Core Support Structures," and SRP 3.9.5, "Reactor Pressure Vessel Internals." The SRPs (SRP 3.9.2 and SRP 3.9.5) reference Regulatory Guide (RG) 1.20 and emphasize vibration prediction through analysis and measurement programs, monitoring of plant data and inspection programs to verify no adverse flow effects during power ascension and long-term power operation.

Exelon has defined a program that will demonstrate the integrity of the steam dryers is maintained during EPU power ascension and EPU power operation consistent with the requirements of the GDCs. This document describes the predictive analysis, measurement program, and inspection program to verify the structural integrity of the steam dryer for flow-induced vibrations. It also describes how the guidance of RG 1.20 is applied for PBAPS Unit 2 and PBAPS Unit 3 replacement steam dryers. Included in Section 2.2 is identification of PBAPS Unit 2 as the prototype plant and PBAPS Unit 3 as a non-prototype Category I plant as well as the basis for these classifications consistent with the guidance of RG 1.20.

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2-1 2 BACKGROUND, DESIGN OVERVIEW, AND CVAP This section provides an overview of the replacement steam dryer design and analysis techniques as well as a summary description of the CVAP and the classification strategy for the prototype and non-prototype plants.

2.1 DESIGN OF THE REPLACEMENT STEAM DRYER For the Exelon EPU Replacement Steam Dryer project, a robust design for the PBAPS Unit 2 and PBAPS Unit 3 plants was developed with panels arranged in a concentric polygon shape. The general layout of this dryer is shown in Figure 2-1.

a,c Figure 2-1 Westinghouse Replacement Steam Dryer Configuration a.c April 2014 WCAP- Enclosure 15A 1763 5-NP -- Enclosure WCAP-17635-NP 15A April 2014 Revision 3

2-2 a,c 2.1.1 Modeling Techniques for Design 2.1.1.1 Load Definition Modeling a,c Details of the load definition modeling are provided in the Acoustic Load Definition Report (Enclosure B. 1 of this attachment).

WCAP-17635-NP - Enclosure 15A April 2014 Revision 3

2-3 2.1.1.2 Structural Evaluation Modeling The process used to perform the steam dryer structural 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 intent of the acoustic qualification of the dryer is to assess the potential for high-cycle fatigue (Enclosure B.2 of this attachment). Structural qualification of the replacement dryer for the remaining duty cycle of events applicable to the operating system of the applicable plants is documented in the ASME Code Stress Report (Enclosure B.3 of this attachment).

a,c 2.1.2 Material The steam dryer is fabricated of stainless steel plates, bars, and forgings. The physical properties are listed in the ASME Code Stress Report (Enclosure B.3 of this attachment).

2.1.3 Treatment of Structural Damping L

ac 2.2 COMPREHENSIVE VIBRATION ASSESSMENT PROGRAM (CVAP)

This section provides a summary description of the CVAP for the PBAPS Unit 2 and PBAPS Unit 3 plant RSD programs at EPU conditions. It also describes the basis for the categorization of PBAPS Unit 2 as the prototype and for PBAPS Unit 3 as non-prototype Category I as defined in Regulatory Guide 1.20, Revision 3.

2.2.1 Summary Description The CVAP for the RSD at EPU conditions for PBAPS Unit 2 and PBAPS Unit 3 plants, consistent with Regulatory Guide 1.20, includes a vibration and fatigue analysis, a vibration measurement program, an inspection program, and a correlation of their results. Details of the analysis are discussed in Section 3, WCAP- 17635-NP - Enclosure 15A April 2014 Revision 3

2-4 the vibration measurement programs are described in Section 4, and the inspection programs are described in Section 5.

The structural analysis for the steam dryer consists of two components: (1) the acoustic loads on the dryer generated as a result of dynamic steam flow effects in the MSLs, and (2) the nonacoustic loads such as deadweight, differential pressure, and seismic.

a,c The CVAP Inspection Plan for the prototype PBAPS Unit 2 plant, consistent with Section 2.3 of Regulatory Guide 1.20, involves an inspection of the steam dryer for any evidence of damage due to flow-induced vibration following a full cycle of plant operation. The inspection is scheduled for the first refueling outage following the installation of the dryer and operation at EPU conditions, consistent with References 1 and 2 (See Section 5). The results of inspections at similar plants using a similar dryer design have been factored into the determination of inspection locations on this dryer. The Unit 3 dryer inspection is consistent with section 3.1.3 of Regulatory Guide 1.20. The inspections of the non-prototype dryer will incorporate any lessons learned as a result of the inspection on the prototype dryer. Additional details of the inspection plans are discussed in Section 5.

WCAP-17635-NP -Enclosure 15A April 2014 Revision 3

2-5 2.2.2 Classification This section provides a basis for the classification of PBAPS Unit 2 as the prototype plant and PBAPS Unit 3 as non-prototype Category I plant.

The PBAPS Unit 2 prototype RSD is planned to be installed during a scheduled refueling outage in October 2014 and the EPU power ascension program for that RSD will be conducted following that outage. A report will be submitted to the NRC, as described in Section 7, which documents the correlation of the predicted acoustic loads on the RSD with the RSD stress measured by the instrumentation on the RSD.

The PBAPS Unit 3 non-prototype RSD is planned to be installed during a scheduled refueling outage in September 2015 and the EPU power ascension program for that RSD will be conducted following that outage.

During the next scheduled Unit 2 refueling outage following EPU operation in September 2016, the Unit 2 prototype RSD will be inspected to further confirm the measured RSD performance during EPU operation. The results of the prototype RSD inspection will be included as part of the Preliminary Report described in Section 7.

The sequencing described above in 2014 through 2016 is acceptable for designating the PBAPS Unit 3 RSD as non-prototype category I because:

• The PBAPS Unit 3 RSD is substantially the same as the PBAPS Unit 2 RSD. Any nominal dryer and reactor pressure vessel differences are accounted for in the subscale testing results, the ACE and ACE+SPM load definitions, the structural analysis, the power ascension programs, and power ascension limits.

Upon completion of the Peach Bottom Unit 2 EPU power ascension, a re-benchmarking of the ACE 2.0 methodology will be performed. This re-benchmarking will utilize the Unit 2 direct dryer strain gauges and determine end-to-end Bias and Uncertainties (B/Us) at EPU conditions.

This newly re-benchmarked ACE methodology will then be applied to Unit 3 to determine and update the structural analyses and stress ratios. With these revised stress ratios, the limit curves for Peach Bottom Unit 3 will be updated.

Execution of the power ascension plan (and associated limit curves) for the PBAPS Unit 3 non-prototype RSD will ensure that sufficient margin to ASME Code stress limits is maintained during full EPU operating conditions.

This approach meets the underlying regulatory requirements of Regulatory Guide 1.20 set forth in the GDCs and SRPs by: (1) having verified no adverse flow effects during power ascension and having not experienced any adverse in-service vibration phenomena during EPU operation, (2) having demonstrated the ability to predict dryer acoustic responses via an analysis and measurement program, (3) having a start up testing and monitoring program, and (4) having an acceptable inspection program.

WCAP- 17635-NP - Enclosure 15A April 2014 Revision 3

2-6 2.2.2.1 Prototype (Peach Bottom Unit 2)

Although a Westinghouse RSD design has been approved, installed, and benchmarked previously at a domestic plant, the first Westinghouse RSD to be installed in the PBAPS Unit 2 plant will be considered a prototype per RG 1.20, Section 1.1. A prototype, consistent with RG 1.20, Section 1.1, is a configuration that represents a first of a kind or unique design. The PBAPS Unit 2 plant, operating at EPU power level conditions and using the Westinghouse RSD design represents, as of the date of this application, such a first of a kind configuration.

The PBAPS Unit 2 CVAP, as described in this report and in the reference documents herein, is consistent with the guidance contained in RG 1.20 for an acceptable CVAP for reactor internals for a prototype plant. This includes analysis, measurement and inspection programs as well as a correlation and evaluation of results.

2.2.2.2 Non-Prototype Category I This subsection describes the basis for the non-prototype Category I classification for the PBAPS Unit 3

RSD, 2.2.2.2.1 Regulatory Guide 1.20 a,c 2.2.2.2.2 Comparison of Plant Differences b,c b,c WCAP- 17635-NP - Enclosure 15A April 2014 Revision 3

2-7 b,c WCAP- 17635-NP - Enclosure 15A April 2014 Revision 3

2-8 Table 2-1 Comparison of Key Steam Dryer Parameters b,c Table 2-2 Comparison of Key Reactor Pressure Vessel Parameters b,c WCAP- 17635-NP - Enclosure 15A April 2014 Revision 3

2-9 Table 2-3 Comparison of Key Hydraulic Parameters bc Table 2-4 Comparison of Key Main Steam Line Parameters b,c WCAP- 17635-NP - Enclosure 15A April 2014 Revision 3

2-10 Table 2-4 Comparison of Key Main Steam Line Parameters (cont'd)

Ib,c WCAP-17635-NP - Enclosure 15A April 2014 Revision 3

3-1 3 ANALYSIS OF THE REPLACEMENT STEAM DRYER 3.1 ACOUSTIC CIRCUIT ENHANCED Qualifying the Westinghouse steam dryer design for acoustic pressure loads originating from flow-induced vibration phenomena requires defining the effects of acoustic pressure loads on the structure. The details of how these loads are calculated, including a description of the acoustic pressure wave model, acoustic load definition development, and development of an EPU acoustic load definition are provided in the Acoustic Load Definition Report (Enclosure B. 1 of this attachment).

3.2 SCALE MODEL TESTING OF THE REPLACEMENT STEAM DRYER ac 3.3 STRESS ANALYSIS OF THE REPLACEMENT STEAM DRYER An overview of the stress evaluation is provided in Subsection 2.1.1.2. The objective of that analysis is to show that the maximum alternating stress intensity anywhere in the dryer is less than the material endurance strength. [ rc Enclosures B. 1 and B.2 of this attachment provide a detailed description of load application, structural analysis, and analysis results for acoustic stresses.

The replacement steam dryer is analyzed according to the guidelines in the I". Enclosure B.3 of this attachment provides the analysis description and results for the stresses resulting from the loads due to deadweight, earthquake, and differential pressure, which are in turn combined with the acoustic stresses as described in that enclosure to determine the total stress on the dryer.

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4-1 4 MEASUREMENT PROGRAM OVERVIEW This section describes the direct dryer instrumentation to be provided on the PBAPS Unit 2 prototype plant. It also describes the instrumentation that will provide the data used for determination of the stresses on the RSD and to ensure the predictive analysis adequately confirms the calculation of those stresses for both PBAPS Unit 2 and Unit 3.

4.1 INSTRUMENTATION PROVIDED WITH THE REPLACEMENT STEAM DRYER (PBAPS UNIT 2, PROTOTYPE) a,c 4.2 INSTRUMENTATION ON THE MAIN STEAM LINES (PBAPS UNIT 2 AND PBAPS UNIT 3) a,c WCAP- 17635-NP - Enclosure 15A April 2014 Revision 3

4-2 a,c WCAP- 17635-NP - Enclosure 15A Anril 2014 Revision 3

5-1 5 INSPECTION PROGRAM OVERVIEW 5.1 INSPECTION PLAN DESCRIPTION This section provides the RSD inspection plan description for both the prototype and non-prototype plant dryers.

5.2 INTERGRANULAR STRESS CORROSION CRACKING (IGSCC) AND HIGH CYCLE FATIGUE CRACKING CONSIDERATIONS a,c 5.3 PRE-INSTALLATION INSPECTIONS Consistent with BWRV[P- 181-A recommendations, a pre-installation inspection will be performed to confirm dimensional tolerances for all replacement steam dryers. Surface roughness and weld finish will also be confirmed to be consistent with BWRVIP-181-A. Subsequent dryer inspections can be compared to the results of the pre-service inspection.

5.4 DRYER INSPECTION PLAN FOLLOWING FIRST CYCLE OF OPERATION L j a,c WCAP-17635-NP - Enclosure 15A April 2014 Revision 3

5-2 a,c WCAP- 17635-NP - Enclosure 15A April 2014 Revision 3

5-3 Table 5-1 Inspection Locations for Unit 2 and Unit 3 RSD Following Vst Cycle of Operation at EPU Conditions

-[ac WCAP- 17635-NP - Enclosure 15A April 2014 Revision 3

5-4 a,c Figure 5-1 View of Outer Hood a,c Figure 5-2 Top View of RSD WCAP- 17635-NP - Enclosure 15A April 2014 Revision 3

5-5 a,c Figure 5-3 Bottom View of RSD 5.5 INSPECTIONS SUBSEQUENT TO THE FIRST OPERATING CYCLE INSPECTION a,c WCAP- 17635-NP - Enclosure 15A April 2014 Revision 3

5-6 Table 5-2 Inspection Locations for Both Plants Subsequent to the First Operating Cycle Inspection a,c i

WCAP-17635-NP - Enclosure 15A April 2014 Revision 3

6-1 6 POWER ASCENSION PROGRAM OVERVIEW The power ascension test program is divided into two parts to facilitate testing: from startup to 100% of CLTP conditions and from 100% CLTP to EPU conditions. The details of the test including the data acquisition system, instrument description, procedure for data collection, comparison of data with design data, and actions to be taken if acceptance criteria are not met are provided in the Replacement Steam Dryer Power Ascension Program Description for Extended Power Uprate Report (Enclosure B.4 of this attachment).

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7-1 7 NRC WRITTEN REPORTS Exelon will provide the following written reports following completion of power ascension testing and inspections:

1. Unit 2 - The results of the power ascension testing to verify the continued structural integrity of the steam dryer shall be submitted to the NRC staff in a report in accordance with 10 CFR 50.4.

The report shall include a final load definition and stress report of the steam dryer, including the results of a complete re-analysis using the end-to-end B/Us determined at EPU conditions and a comparison of predicted and measured pressures and strains on the RSD. The report shall be submitted within 90 days of the completion of EPU power ascension testing for Peach Bottom Unit 2.

2. Unit 3 - At least 90 days prior to the start of the Peach Bottom Unit 3 EPU outage, Exelon Generation Company shall revise the Peach Bottom Unit 3 RSD analysis utilizing the Unit 2 on-dryer strain gauge based end-to-end Bias errors and Uncertainties (B/Us) at EPU conditions, and submit the information including the updated limit curves for Unit 3 to the NRC as a report in accordance with 10 CFR 50.4.

3. Unit 3 - The results of the power ascension testing to verify the continued structural integrity of the steam dryer shall be submitted to the NRC staff in a report in accordance with 10 CFR 50.4.

The report shall include a final load definition and stress report of the steam dryer, including the results of a complete re-analysis using the end-to-end B/Us from Peach Bottom Unit 2 benchmarking at EPU conditions. The report shall be submitted within 90 days of the completion of EPU power ascension testing for Peach Bottom Unit 3.

4. Unit 2 and Unit 3 - During the first two scheduled refueling outages after reaching EPU conditions, a visual inspection shall be conducted of the steam dryer as described in the inspection guidelines contained in Section 5 of this document. The results of the visual inspections of the steam dryer shall be submitted to the NRC staff in a report in accordance with 10 CFR 50.4. The report shall be submitted within 90 days following startup from each of the first two respective refueling outages.

5. Unit 2 and Unit 3 - Within 6 months following completion of the second refueling outage, after the implementation of the EPU, Exelon shall submit a long-term steam dryer inspection plan based on industry operating experience along with the baseline inspection results.

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8-1 8 REFERENCES

1. BWRVIP-139-A, "BWR Vessel and Internals Project Steam Dryer Inspection and Flaw Evaluation Guidelines", EPRI 1018794, July 2009.

2. BWRVIP-18 1-A "BWR Vessel and Internals Project Steam Dryer Repair Design Criteria" EPRI 1020997, July 2010.

3. U.S. Nuclear Regulatory Commission, Regulatory Guide 1.20, Revision 3, "Comprehensive Vibration Assessment Program for Reactor Internals During Preoperational and Initial Startup Testing," March 2007.

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