ML16048A441
ML16048A441 | |
Person / Time | |
---|---|
Site: | Peach Bottom ![]() |
Issue date: | 02/17/2016 |
From: | Borton K Exelon Generation Co |
To: | Document Control Desk, Office of Nuclear Reactor Regulation |
Shared Package | |
ML16048A440 | List: |
References | |
TAC ME9631, TAC ME9632 LTR-BWR-ENG-16-003-NP | |
Download: ML16048A441 (32) | |
Text
Attachment 1 contains Proprietary Information.
When separated from Attachment 1, this document is decontrolled.
10 CFR 50.4 10 CFR 2.390 February 17, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Unit 3 Renewed Facility Operating License No. DPR-56 NRC Docket No. 50-278
Subject:
Extended Power Uprate: Results of Unit 3 Replacement Steam Dryer Power Ascension Testing
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)
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 continued structural integrity of the replacement steam dryer (RSD)) during initial EPU power ascension. This letter satisfies Unit 3 License Conditions 2.C.(15)(b)2 and 2.C.(15)(e) by providing the results of the Unit 3 RSD power ascension testing, including a final load definition, and the results of a complete re-analysis using end-to-end biases/uncertainties from Peach Bottom Unit 2 benchmarking at EPU conditions.
PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390
U.S. Nuclear Regulatory Commission Extended Power Uprate: Results of Unit 3 RSD Power Ascension Testing February 17, 2016 Page 2 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 me at (610) 765-5528.
Respectfully, Kevin F. Borton Manager, Power Uprate Licensing Exelon Generation Company, LLC Attachments:
- 1. Peach Bottom Unit 3 Replacement Steam Dryer Report at EPU Conditions -
Proprietary, Westinghouse Electric Company LLC LTR-BWR-ENG-16-003-P
- 2. Peach Bottom Unit 3 Replacement Steam Dryer Report at EPU Conditions - Non-Proprietary, Westinghouse Electric Company LLC L TR-BWR-ENG-16-003-NP
- 3. Affidavit cc:
USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, PBAPS USNRC Project Manager, PBAPS R. R. Janati, Commonwealth of Pennsylvania S. T. Gray, State of Maryland w/attachments w/attachments w/attachments w/o proprietary attachment w/o proprietary attachment Peach Bottom Atomic Power Station Unit 3 NRC Docket No. 50-278 PBAPS Unit 3 Replacement Steam Dryer Report at EPU Conditions - Non-Proprietary Westinghouse Electric Company LLC LTR-BWR-ENG-16-003-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 3 License Condition 2.C.(15)(b)2 and 2.C(15)(e), EGC is providing the Unit 3 replacement steam dryer (RSD) power ascension testing results.
Westinghouse Non-Proprietary Class 3 Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, PA 16066 USA
© 2016 Westinghouse Electric Company LLC All Rights Reserved LTR-BWR-ENG-16-003-NP Peach Bottom Unit 3 Replacement Steam Dryer Report at EPU Conditions Revision 0
Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-16-003-NP 2
Table of Contents 1
Introduction and Summary.................................................................................................................. 3 2
Instrumentation Summary................................................................................................................... 4 3
Main Steam Line Data........................................................................................................................ 5 4
High Cycle Fatigue Analysis Summary.............................................................................................. 8 5
Updated Limits.................................................................................................................................. 15 6
Conclusions....................................................................................................................................... 20 7
References......................................................................................................................................... 21
Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-16-003-NP 3
1 INTRODUCTION AND
SUMMARY
In December of 2015, Peach Bottom Atomic Power Station (PBAPS) Unit 3 reached full extended power uprate (EPU) conditions. A high-cycle fatigue assessment of the PBAPS Unit 3 replacement steam dryer has been completed utilizing main steam line (MSL) data obtained at EPU conditions. The assessment is a complete reanalysis using the Westinghouse steam dryer acoustic/structural methodology, Acoustic Circuit Enhanced (ACE) Revision 3.1. ACE Revision 3.1 includes the end-to-end biases and uncertainties (B/U) from the Peach Bottom Unit 2 benchmarking at EPU conditions. Additionally, the reanalysis considers the effects of non-main steam line acoustic (NMSLA) loads. This report provides the load definition and the results of the high-cycle fatigue assessment to fulfill the requirements found in Peach Bottom Unit 3 Renewed Facility Operating License, condition 2.C.(15)(b)2 and 2.C.(15)(e) regarding potential adverse flow effects (Reference 1).
Based on the assessments performed, it has been determined that the minimum alternating stress ratio (MASR) at EPU conditions (3951 MWt) [
]a,b,c
Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-16-003-NP 4
2 INSTRUMENTATION
SUMMARY
The status of the upper MSL strain gauges during PBAPS Unit 3 power ascension is provided in Table 2-1. At all power levels, the channels that had [
]a,c Inactive channels are indicated with grey shading.
Table 2-1 PBAPS Unit 3 MSL Strain Gauge Status a,b,c
Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-16-003-NP 5
3 MAIN STEAM LINE DATA A summary of the MSL data collected during the Unit 3 power ascension is provided in this section.
Figure 3-1 through Figure 3-4 show comparison plots of the MSL power spectral density (PSD) for different datasets leading up to EPU. The blue curve represents the Unit 3 data near 100% CLTP, collected following the EPU outage. The red and green curves represent the Unit 3 data collected near 104% CLTP and 108% CLTP, respectively. The solid black curve represents data collected from Unit 3 near 112% CLTP (EPU) and the dashed black curve represents data collected from Unit 2 near EPU.
Figure 3-1: MSL Pressure PSD Comparison - MSL A a,b,c
Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-16-003-NP 6
Figure 3-2: MSL Pressure PSD Comparison - MSL B Figure 3-3: MSL Pressure PSD Comparison - MSL C a,b,c a,b,c
Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-16-003-NP 7
Figure 3-4: MSL Pressure PSD Comparison - MSL D a,b,c
Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-16-003-NP 8
4 HIGH CYCLE FATIGUE ANALYSIS
SUMMARY
A structural reanalysis was performed using data collected at EPU power level. The analysis considered both the [
]a,c Table 4-1 presents the limiting replacement steam dryer high-cycle fatigue stress ratios for Unit 3 at EPU conditions.
Table 4-1 PBAPS U3 Stress Ratio Summary at EPU Conditions X
X X
X X
X X
X X
X X
X X
X X
X X
X X
X X
X X
The previously predicted MASR values were [ ]b for the upper and lower dryer, respectively.
These were provided in the [
x ]a,c
[
]a,b,c The updated limit curves are provided in Section 5.
a,b,c
Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-16-003-NP 9
Figure 4-1 through Figure 4-4 show the [
]a,c Figure 4-1 Cumulative Stress PSD for [ ]a,c a,b,c
Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-16-003-NP 10 Figure 4-2 Cumulative Stress PSD for [ ]a,c a,b,c
Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-16-003-NP 11 Figure 4-3 Cumulative Stress PSD for [ ]a,c a,b,c
Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-16-003-NP 12 Figure 4-4 Cumulative Stress PSD for [ ]a,c a,b,c
Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-16-003-NP 13 Figure 4-5 Cumulative Stress Plot, Unit 2 EPU - [xxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxx]a,b,c a,b,c
Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-16-003-NP 14 Figure 4-6 Cumulative Stress Plot, Unit 2 EPU - [xxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxx]a,b,c a,b,c
Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-16-003-NP 15 5
UPDATED LIMITS 5.1 Updated [ ]a,c The [
]a,c Table 5-1: Unit 3 Updated [ ]a,c XxxxX X
XxxxX XxxxX XxxxX xxxxxxxxx.xxxxxxxxxxxxxxx
The limits in Table 5-1 represent the calculated operating margin for [ ]a,c at PBAPS Unit 3.
a,b,c
Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-16-003-NP 16 5.2 Updated MSL Acoustic (ACE) Limits Limit curves for the MSL acoustic frequency ranges were updated based on the [
]a,c The limit curves are shown in Figure 5-1 through Figure 5-8 along with the collected MSL data at EPU.
Figure 5-1: ACE - Updated Limit Curves - [ ]a Figure 5-2: ACE - Updated Limit Curves - [ ]a a,b,c a,b,c
Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-16-003-NP 17 Figure 5-3: ACE - Updated Limit Curves - [ ]a Figure 5-4: ACE - Updated Limit Curves - [ ]a a,b,c a,b,c
Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-16-003-NP 18 Figure 5-5: ACE - Updated Limit Curves - [ ]a Figure 5-6: ACE - Updated Limit Curves - [ ]a a,b,c a,b,c
Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-16-003-NP 19 Figure 5-7: ACE - Updated Limit Curves - [ ]a Figure 5-8: ACE - Updated Limit Curves - [ ]a a,b,c a,b,c
Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-16-003-NP 20 6
CONCLUSIONS The results of the high-cycle fatigue assessment verify the continued structural integrity of the PBAPS Unit 3 replacement steam dryer at EPU conditions. The assessment of the Unit 3 replacement steam dryer included a complete reanalysis using ACE Revision 3.1, with end-to-end B/Us from Peach Bottom Unit 2 benchmarking at EPU conditions.
The flow-induced vibration load fatigue margin for the steam dryer and the resulting limit curves have been established. Therefore, this report satisfies the requirements found in Peach Bottom Unit 3 Renewed Facility Operating License Condition 2.C.(15)(b)2 and 2.C.(15)(e) regarding potential adverse flow effects.
Based on the assessments performed, it has been determined that the MASR at EPU conditions [
xxx xxxx ]a,b,c Therefore, all steam dryer locations have margin with a stress ratio greater than the acceptance limit of 1.0.
Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-16-003-NP 21 7
REFERENCES
- 1.
Peach Bottom Atomic Power Station, Unit 3 Renewed Facility Operating License, Unit 3 License Condition (15).
- 2.
LTR-BWR-ENG-15-113, Peach Bottom Unit 3 Replacement Steam Dryer Limit Curves Evaluation at 106% CLTP, November 25, 2015.
- 3.
Letter to NRC from Exelon, Extended Power Uprate: Unit 3 Replacement Steam Dryer Revised Analysis Report, Supplement 1, October 2, 2015 (LTR-BWR-ENG-15-076-P, Rev 1).
Peach Bottom Atomic Power Station Unit 3 NRC Docket No. 50-278 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.
@Westinghouse U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA Direct tel: (412) 374-4643 Direct fax: (724) 940-8560 e-mail: greshaja@westinghouse.com CAW-16-4377 February 15, 2016 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
LTR-BWR-ENG-16-003-P, Revision 0, "Peach Bottom Unit 3 Replacement Steam Dryer Report at EPU Conditions" (Proprietary)
The Application for Withholding Proprietary Information from Public Disclosure is submitted by Westinghouse Electric Company LLC (Westinghouse), pursuant to the provisions of paragraph (b)( 1) of Section 2.390 of the Commission's regulations. It contains commercial strategic information proprietary to Westinghouse and customarily held in confidence.
The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW 4377 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-16-4377, 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.
James A. Gresham, Manager Regulatory Compliance
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF BUTLER:
AFFIDAVIT ss CAW-16-4377 February 15, 2016 I, Henry A. Sepp, 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.
CRE-Systems and Components Engineering
2 CAW-16-4377 (1)
I am Director, CRE-Systems and Components Engineering, 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 Mfidavit in conformance with the provisions of 10 CPR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Mfidavit.
(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
3 CAW-16-4377 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.
(b)
It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.
(c)
Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.
(d)
It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.
(e)
It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.
(f)
It contains patentable ideas, for which patent protection may be desirable.
(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.
4 CAW-16-4377 (d)
Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.
(e)
Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.
(f)
The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.
(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)
The proprietary information sought to be withheld in this submittal is that which is appropriately marked in LTR-BWR-ENG-16-003-P, Revision 0, "Peach Bottom Unit 3 Replacement Steam Dryer Report at EPU Conditions" (Proprietary), 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 high-cycle fatigue assessment of the replacement steam dryer at Peach Bottom Atomic Power Station (PBAPS) Unit 3 at extended power uprate (EPU) conditions, and may be used only for that purpose.
5 CAW-16-4377 (a)
This information is part of that which will enable Westinghouse to assist Exelon Generation in fulfilling the requirements specified in the PBAPS Unit 3 Renewed Facility Operating License.
(b)
Further this information has substantial commercial value as follows:
(i)
Westinghouse plans to sell the use of similar information to its customers for the purpose of plant specific replacement steam dryer analysis for licensing basis applications.
(ii)
Westinghouse can sell support and defense of industry guidelines and acceptance criteria for plant-specific applications.
(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 high-cycle fatigue assessment of the replacement steam dryer at extended power uprate (EPU) conditions for PBAPS Unit 3 with regards to the PBAPS Unit 3 license conditions, 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 that Westinghouse customarily holds in confidence is 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 tp 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.