ML15096A008

Extended Power Uprate: Response to Replacement Steam Dryer Requests for Additional Information

ML15096A008
Person / Time
Site:	Peach Bottom
Issue date:	04/05/2015
From:	David Helker Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML15096A006	List: ML15096A008
References
LTR-BWR-ENG-15-032-NP
Download: ML15096A008 (37)

Text

PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 10 CFR 50.4 10 CFR 2.390 April 5, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Unit 2 Renewed Facility Operating License No. DPR-44 NRC Docket No. 50-277

Subject:

Extended Power Uprate: Response to Replacement Steam Dryer Requests for Additional Information

Reference:

1. NRC Letter to Exelon, Peach Bottom Atomic Power Station, Units 2 and 3 - Issuance of Amendments Re: Extended Power Uprate (TAC Nos.

ME9631 and ME9632), dated August 25, 2014 (ADAMS Accession No. ML14133A046)

2. Exelon letter to the NRC, Extended Power Uprate: Request for NRC Approval of Revision to Methodology for Establishing Replacement Steam Dryer Strain Limits, dated February 3, 2015 (ADAMS Accession No. ML15034A573)

3. Exelon letter to the NRC, Extended Power Uprate: Response to Replacement Steam Dryer Requests for Additional Information, dated March 24, 2015 (ADAMS Accession No. ML15083A559)

4. NRC Letter to Exelon, NRC Staff Review of Request for Approval of Revision to Methodology for Establishing Replacement Steam Dryer Strain Limits (TAC NO. MF4792), dated March 27, 2015 (ADAMS Accession No. ML15033A489).

In accordance with 10 CFR 50.92, the NRC issued Reference 1, License Amendment Nos.

293 and 296 to the Peach Bottom Atomic Power Station (PBAPS) Renewed Facility Operating Licenses (FOLs) to increase the authorized maximum power level from 3514 megawatts thermal (MWt) to 3951 MWt. This change to power level is considered an extended power uprate (EPU).

The amended FOLs contain specific license conditions that control the monitoring, evaluating, and taking prompt action in response to potential adverse flow effects as a result of the EPU on plant structures, systems, and components (including verifying the Attachment 1 contains Proprietary Information.

When separated from Attachment 1, this document is decontrolled.

U.S. Nuclear Regulatory Commission Response to Replacement Steam Dryer RAI April5,2015 Page2 continued structural integrity of the replacement steam dryer (RSD)) during initial EPU power ascension.

As described in Exelon Generation Company, LLC (EGC) letter dated February 3, 2015 (Reference 2), data collected at near the previously licensed thermal power level identified low frequency loads on the RSD that were not previously predicted. The NRC staff reviewed the information regarding the revised methodology and provided a request for additional information (RAI). The EGC response to that request was submitted on March 24, 2015 (Reference 3). The NRC determined the response provided reasonable assurance of RSD structural integrity and approved power ascension up to 104% of 3514 MWt (Reference 4). The NRC Staff also requested additional information to support further review of the RSD methodology. This letter provides the response to that RAI.

Westinghouse Electric Company (WEC) considers portions of the information provided in the Attachment 1 response proprietary and, therefore, exempt from public disclosure pursuant to 10 CFR 2.390. In accordance with 10 CFR 2.390 and in support of this request for withholding, an affidavit executed by WEC is provided in Attachment 3.

There are no regulatory commitments contained in this letter.

Should you have any questions concerning this letter, please contact Mr. Ken Ainger at (630) 657-3330.

Respectfully, David P. Helker Manager, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments:

1. Response to Request for Additional Information - Proprietary, Westinghouse Electric Company LLC LTR-BWR-ENG-15-032-P

2. Response to Request for Additional Information - Non-Proprietary, Westinghouse Electric Company LLC LTR-BWR-ENG-15-032-NP

3. Affidavit cc: USNRC Region I, Regional Administrator w/attachments USNRC Senior Resident Inspector, PBAPS w/attachments USNRC Project Manager, PBAPS w/attachments R. R. Janati, Commonwealth of Pennsylvania w/o proprietary attachment S. T. Gray, State of Maryland w/o proprietary attachment

Attachment 2 Peach Bottom Atomic Power Station Unit 2 NRC Docket No. 50-277 Response to Request for Additional Information - Non-Proprietary Westinghouse Electric Company LLC LTR-BWR-ENG-15-032-NP The Nuclear Regulatory Commission (NRC) issued Amendment Nos. 293 and 296 to Renewed Facility Operating License Nos. DPR-44 and DPR-56 for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3 (ADAMS Accession No. ML14133A046).

These amendments authorized an increase in the maximum licensed thermal power level for PBAPS, Units 2 and 3, from 3514 megawatts thermal (MWt) to 3951 MWt, which is an increase of approximately 12.4 percent.

In accordance with PBAPS Unit 2 License Condition 2.C(15)(d)3, EGC requested NRC approval for a revision to the methodology for establishing the RSD strain limits and provided additional information in letters dated February 3, 2015 (ADAMS Accession No. ML15034A573) and March 24, 2015 (ADAMS Accession No. ML15083A559). The NRC staff has reviewed that information, approved further power ascension, and requested additional information on March 27, 2015. The response to that request is provided in this attachment.

Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-032-NP Response to the U.S. NRC Requests for Additional Information Relative to the Peach Bottom Replacement Steam Dryer Acoustic/Structural Analyses Set April 5, 2015 Westinghouse Electric Company LLC 1000 Westinghouse Drive Cranberry Township, PA 16066 USA

© 2015 Westinghouse Electric Company LLC All Rights Reserved

Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-032-NP

RAI-10

Acceptance criteria for non-main steam line (MSL) acoustic methodology The following comments and RAIs address the remaining unresolved issues associated with the licensees proposed non-MSL acoustic methodology. Satisfactory response to these comments and RAIs will provide reasonable assurance of the methodology conservatism and support a decision to allow power ascension to proceed.

Observations on the information submitted so far:

Using (( )) to infer the alternating stress state in a steam dryer is, in principle, acceptable.

Statistical studies of the peak measured strains on the dryer hood and skirt by the licensee appear to show that ((

)) with guidelines in NUREG 0484. The licensee indicated that cumulative distribution function (CDF) curves were developed, ((

))

To further validate the licensees findings from its analysis, the NRC staff requests that the CDF curves for SG4 and SG20 be provided for review.

The ((

)) does not have a sound technical basis. Therefore, this raises concerns regarding the stress analysis of the PBAPS Unit 2 steam dryer. All ((

)) do not seem to be included in the current analysis, raising the concern that the

(( )) may not be an appropriate upper bound. Also, the ((

)) These problems with the approach used to date lead to

((

)) adding further uncertainty to the accuracy of the current calculations.

The general methodology as submitted by the licensee is reasonable, but the ((

)) must be complete and representative of low frequency (less than 50 Hz) strains and stresses in all major dryer components (outer hoods, inner and middle hoods, and skirt), and the approach used to determine the (( )) in the analysis must be revised as follows:

a) Due to possible inaccuracies in the ((

)) a frequency shift of at least +/-10% must be considered to ensure that all (( )) are included in the analyses.

b) (( )) used in the analysis should be submitted, and demonstrated to be reasonable for use on the outer hood, middle/inner hood, and skirt, regardless of whether the (( ))

1

Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-032-NP c) The (( )) should be based on attempting to match as closely as possible ((

))1 d) The simulated (( )) should bound the measured ones.

e) Simulated (( )) should be reasonably consistent with those measured.

f) The (( )) must be used to estimate the top 5 maximum stresses and their locations on the upper and lower dryer.

In addition, the following information is requested, prior to the meeting on March 26, 2015:

g) For each of the (( )) please provide ((

)) at each of the strain gage locations on the hood.

h) Please confirm whether the outer hood, middle hood and inner hood are dynamically coupled.

1

((

))

2

Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-032-NP

Response

RAI-10a)

In the original non-main steam line acoustic (NMSLA) stress calculation (RAI 1a describes the method, and RAI-1d provides the results), [

]a,c The [

]a,c The results are provided in Table RAI-10a-1.

Table RAI-10a-2 [

]a,c All results [ ]a,c Table RAI-10a-1: Maximum NMSLA Stress, Upper Dryer a,c Table RAI-10a-2: Maximum NMSLA Stress, Lower Dryer a,c 3

Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-032-NP RAI-10b)

[

]a,c As discussed [

]a,c Additionally,

[

]a,c As part of the evaluation [

]a,c A comparison of [

]a,c For the hoods, [

]a,c The results [

]a,c Thus the [

]a,c In addition, [

]a,c As shown [

]a,c Based on the above, [

]a,c 4

Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-032-NP RAI-10c)

RAI-10c), RAI-10d), RAI-10e), RAI-10f)

RAI-10, parts c through f [

]a,c 5

Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-032-NP a,c Figure RAI-10c-1: [ ]a,c 6

Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-032-NP a,c Figure RAI-10c-2: [ ]a,c

[

]a,c 7

Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-032-NP a,c Figure RAI-10c-3: [ ]a,c a,c Figure RAI-10c-4: [ ]a,c 8

Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-032-NP

[

]a,c Table RAI-10c-1: [ ]a,c a,c Table RAI-10c-2 [

]a,c 9

Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-032-NP Table RAI-10c-2: [ ]a,c a,c

[

]a,c 10

Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-032-NP Table RAI-10c-3: [ ]a,c a,c

[

]a,c Additional NRC request:

[

]a,c 11

Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-032-NP a,c Figure RAI-10c-5: [ ]a,c a,c Figure RAI-10c-6: [ ]a,c 12

Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-032-NP RAI-10g)

[

]a,c Tables RAI-10g-1 through RAI-10g-3 [

]a,c Table RAI-10g-1: Peach Bottom Unit 2 Replacement Steam Dryer Modal Displacements a,c 13

Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-032-NP a,c 14

Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-032-NP a,c 15

Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-032-NP a,c 16

Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-032-NP Table RAI-10g-2: Peach Bottom Unit 2 Replacement Steam Dryer Modal Strains at Top Surface a,c 17

Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-032-NP a,c 18

Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-032-NP a,c 19

Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-032-NP a,c 20

Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-032-NP Table RAI-10g-3: Peach Bottom Unit 2 Replacement Steam Dryer Modal Strains at Bottom Surface a,c 21

Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-032-NP a,c 22

Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-032-NP a,c 23

Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-032-NP a,c 24

Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-032-NP RAI-10h)

[

]a,c 25

Attachment 3 Peach Bottom Atomic Power Station Unit 2 NRC Docket No. 50-277 AFFIDAVIT Note contains proprietary information as defined by 10 CFR 2.390.

WEC, as the owner of the proprietary information, has executed the enclosed affidavit, which identifies that the proprietary information has been handled and classified as proprietary, is customarily held in confidence, and has been withheld from public disclosure. The proprietary information has been faithfully reproduced in the attachment such that the affidavit remains applicable.

inghouse Westinghouse Electric Company Engineering, Equipment and Major Projects 1000 Westinghouse Drive, Building 3 Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (724) 940-8560 11555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852 Proj. ltr: WEC-PCH-RSD-15-061 CAW-15-4155 April 2, 2015 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

LTR-BWR-ENG-15-032-P, "Response to the U.S. NRC Requests for Information Relative to the Peach Bottom Replacement Stearn Dryer Acoustic/Structural Analyses Set" The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-15-4155 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The Affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.

• Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Exelon Generation.

Correspondence with respect to the proprietary aspects of the Application for Withholding or the Westinghouse Affidavit should reference CAW-15-4155, and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 3 Suite 310, Cranberry Township, Pennsylvania 16066.

Very truly yours, i~ger Regulatory Compliance Enclosures

CAW-15-4155 April 2, 2015 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

SS COUNTY OF BUTLER:

I, James A Gresham, am authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief.

4:mes A Gresham, Manager Regulatory Compliance

2 CAW-15-4155 (1) I am Manager, Regulatory Compliance, Westinghouse Electric Company LLC (Westinghouse),

and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

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

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

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

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

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

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

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

3 CAW-15-4155 (b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

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

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

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

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

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

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

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

(d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component

4 CAW-15-4155 may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

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

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

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

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

(vi) Th~ proprietary information sought to be withheld in this submittal is that which is appropriately marked in LTR-BWR-ENG-15-032-P, "Response to the U.S. NRC Requests for Information Relative to the Peach Bottom Replacement Steam Dryer Acoustic/Structural Analyses Set" for submittal to the Commission, being transmitted by Exelon Generation letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with the NRC's review of a revised methodology for determining RSD strain limits for PBAPS Unit 2, and may be used only for that purpose.

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

(i) Assist Exelon Generation in obtaining NRC review and approval of a revised methodology for determining RSD strain limits for PBAPS Unit 2.

5 CAW-15-4155 (b) Further this information has substantial commercial value as follows:

(i) Westinghouse plans to sell the use of this information to its customers for purposes of plant specific replacement steam dryer analysis for licensing basis applications.

(ii) Its use by a competitor would improve their competitive position in the design and licensing of a similar product for BWR steam dryer analysis methodology.

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

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

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

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

Further the deponent sayeth not.

PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and non-proprietary versions of documents furnished to the NRC associated with the NRC' s review of a revised methodology for determining RSD strain limits with regard to RSD analysis benchmarking for PBAPS Unit 2, and may be used only for that purpose.

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

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