Text

Duane Arnold - Response to Request for Additional Information, License Amendment Request (TSCR-144) to Revise and Relocate Pressure and Temperature Limit Curves to a Pressure and Temperature Limits Report - MF6617
	ML16055A126
Person / Time
Site:	Duane Arnold, PROJ0669
Issue date:	02/19/2016
From:	Vehec T A; NextEra Energy Duane Arnold
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	MF6617, NG-16-0042
	Download: ML16055A126 (14)
	v • d • e

NEx~era Attachment 4 Contains Proprietary Information Withhold Attachment 4 from Public Disclosure in Accordance with 10 CFR 2.390 February 19, 2016 NG-1 6-0042 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk -Washington, DC 20555-0001 Duane Arnold Energy Center Docket No. 50-331 Renewed Op. License No. DPR-49 Response to Request for Additional Information, License Amendment Request (TSCR-144) to Revise and Relocate Pressure and Temperature Limit Curves to a Pressure and Temperature Limits Report -MF6617

References:

1)License Amendment Request (TSCR-144) to Revise and Relocate Pressure and Temperature Limit Curves to a Pressure and Temperature Limits Report, NG-15-0235, dated July 30, 2015 ('ML15253A310 and ML15253A311)

2) Electronic Communication, Request for Additional Information, License Amendment Request to Revise and Relocate Pressure and Temperature limit curves to a Pressure and Temperature Limit Renort- MF6617. dated January 31. 2016 In the Reference I letter, NextEra Energy Duane Arnold, LLC (hereafter NextEra Energy Duane Arnold) submitted a License Amendment Request for the Duane Arnold Energy Center (DAEC) pursuant to 10 CFR 50.90. Subsequently, the NRC Staff requested, via Reference 2, additional information regarding that application.

Attachment 4 transmitted herewith contains Proprietary Information.

When separated from Attachment 4, this document is decontrolled.

SAbbl NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324 Document Control Desk NG-l16-0042 Page 2 of 2 The Enclosures to this letter contain the requested information.

This additional information does not impact the 10 CFR 50.92 evaluation of "No Significant Hazards Consideration" previously provided in the referenced application.

This letter does not contain any new commitments or change any existing commitments.

If you have any questions or require additional information, please contact J. Michael Davis at 319-851-7032.

I declare under penalty of perjury that the foregoing is true and correct.-ecu).d on February 18, 2016 T. A. Vehec Vice President, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC Enclosure 1: Enclosure 2: Enclosure 3: Enclosure 4: NextEra Energy Duane Arnold Response to SRXB RAIs 1 and 2 EPRI Affidavit for Withholding Proprietary Information From the Public NextEra Energy Duane Arnold Response to EVIB PALI 1with Redacted Non-Proprietary BWRVlP-135 Sections NextEra Energy Duane Arnold Response to EVIB RALI 1with Proprietary BWRVIP-135 Sections cc: NRC Regional Administrator NRC Resident Inspector NRC Project Manager A. Leek (State of lowa)Attachment 4 transmitted herewith contains Proprietary Information.

When separated from Attachment 4, this document is decontrolled.

Enclosure 1 to NG-16-0042 Response to Request for Additional Information, License Amendment Request (TSCR-144) to Revise and Relocate Pressure and Temperature Limit Curves to a Pressure and Temperature Limits Report NextEra Energqy Duane Arnold Response to SRXB RAt 1 and RAI 2 2 pages follow Response to Request for Additional Information, License Amendment Request (TSCR-144) to Revise and Relocate Pressure and Temperature Limit Curves to a Pressure and Temperature Limits Report Reactor Systems Branch (SRXB) SRXB -RAI 1 Section 3.2, Adjusted Reference Temperature (ART) and Fluence, states that the fluence used in the development of the ART values were calculated using the NRC approved RAMA methodology found in References

7. 7 and 7.8. DAEC further references in Reference 7.10 an amendment dated August 25, 2003,"Duane Arnold Energy Center- Issuance of Amendment Regarding Pressure and Temperature Limit Curves," (ML 0323 10536) using the GE neutron fluence method in the GE Licensing Topical Report NED O-32983P-A.

The proposed PTLR (ML 15253A3 11) references using the RAMA methodology in TransWare Report No. DAE-FLM-OO1-R-O04, Revision 0, "Duane Arnold Energy Center Fluence Assessment Report -End of Cycle 24," dated April 3, 2015.Additionally, the PTLR also references the same SE using the GE method as the application discussed earlier. Lastly, in reviewing of neutron fluence methodologies approved for DAEC, the RAMA method is approved for Duane Arnold in its license renewal application for operation out to 54 effective furll power years (EFPY). It is unclear to the NRC staff how the GE and RAMA fluence methodologies are being applied for the proposed PTLR. The NRC staff requests that the licensee provide an explanation and any information regarding how the RAMA fluence methodology is being applied to DAEC for the proposed PTLR.NextEra Energy Response:

The GE fluence methodology is not being used in the proposed DAEC PTLR. The fluence used in the development of irradiation em brittlement projections or adjusted reference temperature (ART) projections for the reactor vessel materials for 32 EFPY and 54 EFPY was based on the RAMA fluence methodology in TransWare Report No. DAE-FLM-001-R-004, Revision 0, "Duane Arnold Energy Center Fluence Assessment Report -End of Cycle 24," dated April 3, 2015 which is identified in Attachment 1, Section 3.2 of the LAR (ML15253A311).

Attachment 1, Section 3.4 of the LAR, identifies the basis for the lowest service temperature (LST) and cites the 2003 SE as confirmation of the LST value which is an initial property unaffected by fluence. Attachment 5 and Attachment 6, Section 5.0 of the LAR, also references the prior P-T limit curve submittal prepared by GE [Reference 8] for reactor vessel material initial property chemistry values only, which are initial properties unaffected by fluence.

Response to Request for Additional Information, License Amendment Request (TSCR-144) to Revise and Relocate Pressure and Temperature Limit Curves to a Pressure and Temperature Limits Report SR)(B -RAI 2 When comparing the proposed PTLR P/T curves for 32 EFPY to the current PIT curves in TS for 32 EFPY, the NRC staff noticed there is a difference in the P-IT curves. The NRC staff requests that the licensee provide an explanation regarding the differences seen between the current T.S P/IT curves for 32 EFPY and the PrOPosed PTLR P/IT curves for 32 EFPY.NextEra Energy Response:

The 32 EFPY curves provided in Attachment 5 and 6 of the LAR were part of a P-T Limit curve calculation package that included both the 32 EFPY and 54 EFPY P-T limit curves that were prepared in 2008 to support license renewal but never submitted for approval.

Subsequently, the calculation package that contained both the 32 EFPY and 54 EFPY P-T limit curves was updated with the latest fluence analysis using the RAMA methodologies and incorporating the results of the most recent Duane Arnold plant specific surveillance capsule tests and fluence results (BWRVIP-279NP).

Although both curves periods of applicability were updated and submitted, Duane Arnold will transition to the 54 EFPY P-T curves upon approval of the PTLR as DAEC is nearing 32 EFPY. The 32 EFPY P-T limit curves in the PTLR will not be used.The differences in the current 32 EFPY Technical Specifications (TS) P-T limit curves and the proposed 32 EFPY PTLR curves in Attachment 5 and 6 of the LAR are the result of incorporation of the updated chemistry factor for surveillance plate, most recent fluence analysis through end of cycle 24 using the RAMA methodology, and a 25°F/hr heat up rate for the hydrostatic test (Curve A). The updated RAMA fluence for the limiting N2 nozzle is also less than projected in the previous 2003 submittal for the current 32 EFPY TS P-T curves resulting in less restrictive PTLR curves. As a result, the 32 EFPY PTLR overall Curve A includes the intersection of the non-beltline 10OCFR50 Appendix G flange limit where the 32 EFPY TS curves were lower and to the right of the flange limit.Other differences noted are the inclusion of the "non-beltline" doffed line on all the PTLR curves which includes the I0CFR50 Appendix G stressed flange limitation.

The current 32 EFPY TS curves did not show this line because it was bounded by Curve A, although it was calculated and provided in the 2003 License amendment request submittal.

Enclosure 2 to NG-16-0042 Response to Request for Additional Information, License Amendment Request (TSCR-144) to Revise and Relocate Pressure and Temperature Limit Curves to a Pressure and Temperature Limits Report.EPRI Affidavit for Withhold inq Proprietary Information From the Public 4 pages follow

~j ELECTRIC POWER~ RESEARCH INSTITUTE NEIL WILMSHURST Vice President and Chief Nuclear Officer Ref. EPRI Project Number 669 February 16, 2016 Document Control Desk Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission.

Washington, DC 20555-0001

Subject:

Request for Withholding of the following Proprietary Information Included in: NextEra Energy Duane Arnold, LLC, Duane Arnold Energy Center Submittal to the NRC for "Response to Request for Additional Information

-[AR to Revise and Relocate Pressure and Temperature Limit Curves to a Pressure and Temperature Limits Report -MF6617 ," Enclosure 2, NextEra Energy Duane Arnold Response to EVIB RAI- with Proprietary EPRI BWRVIP-1 35 Rev 3 Sections, "BWR Vessel and Internals Project Integrated Surveillance Program (ISP) Data Source Book and Plant Evaluations, 3002003144, Technical Report, December 2014" To Whom It May Concern: This is a request under 10 C.F.R. §2.390(a)(4) that the U.S. Nuclear Regulatory Commission

("NRC") withhold from public disclosure the report identified in the enclosed Affidavit consisting of the proprietary information owned by Electric Power Research Institute, Inc. ("EPRI") identified in the attached report. Proprietary and non-proprietary versions of the Response and the Affidavit in support of this request are enclosed.EPRI desires to disclose the Proprietary Information in confidence to assist the NRC review of the enclosed submittal to the NRC by NextEra Energy Duane Arnold, LLC. The Proprietary Information is not to be divulged to anyone outside of the NRC or to any of its contractors, nor shall any copies be made of the Proprietary Information provided herein. EPRI welcomes any discussions and/or questions relating to the information enclosed.If you have any questions about the legal aspects of this request for withholding, please do not hesitate to contact me at (650) 855-2271.

Questions on the content of the Report should be directed to Andy McGehee of EPRI at (704) 502-6440.i(ncerely, Attachment(s) c: Sheldon Stuchell, NRC (sheldon.stuchell@nrc.gov)

Together ...Shaping the Future of Electricity 1300 West W.T. Harris Boulevard, Charlotte, NC 28262-8550 USA

704.595.2732

Mobile 704.490.2653

nwilmshurst@epri.com RESEARCH INSTITUTE AFFIDAVIT RE: Request for Withholding of the Following Proprietary Information Included In: NextEra Energy Duane Arnold, LLC, Duane Arnold Energy Center Submittal to the NRC for "Response to Request for Additional Information

-LAR to Revise and Relocate Pressure and Temperature Limit Curves to a Pressure and Temperature Limits Report -MF6617 ," Enclosure 2, NextEra Energy Duane Arnold Response to EVIB RAI-1 with Proprietary EPRI BWRVIP-135 Rev 3 Sections, "BWR Vessel and Internals Project Integrated Sunveillance Program (ISP) Data Source Book and Plant Evaluations, 3002003144, Technical Report, December 2014" I, Neil Wilmshurst, being duly sworn, depose and state as follows: I am the Vice President and Chief Nuclear Officer at Electric Power Research Institute, Inc. whose principal office is located at 3420 Hillview Avenue, Palo Alto, CA. ("EPRr") and I have been specifically delegated responsibility for the above-listed report that contains EPRI Proprietary Information that is sought under this Affidavit to be withheld "Proprietary Information".

I am authorized to apply to the U.S. Nuclear Regulatory Commission

("NRC") for the withholding of the Proprietary Information on behalf of EPRI.EPRI Proprietary Information is identified in the above referenced report by a solid underline inside double brackets.

An example of such identification is as follows:{FThis sentence is an example.{E} Tables containing EPRI Proprietary Information are identified with double brackets before and after the object. In each case, the superscript notation {E} refers to this affidavit as the basis for the proprietary determination. EPRI requests that the Proprietary Information be withheld from the public on the following bases: WithholdinQ Based Upon PrivileQed And Confidential Trade Secrets Or Commercial Or Financial Information (see e..q., 10 C.F.R. § 2.390(a)(4):

a. The Proprietary Information is owned by EPRI and has been held in confidence by EPRI. All entities accepting copies of the Proprietary Information do so subject to written agreements imposing an obligation upon the recipient to maintain the confidentiality of the Proprietary Information.

The Proprietary Information is disclosed only to parties who agree, in writing, to preserve the confidentiality thereof.b. EPRI considers the Proprietary Information contained therein to constitute trade secrets of EPRI. As such, EPRI holds the Information in confidence and disclosure thereof is strictly limited to individuals and entities who have agreed, in writing, to maintain the confidentiality of the Information.

c. The information sought to be withheld is .considered to be proprietary for the following reasons. EPRI made a substantial economic investment to develop the Proprietary Information and, by prohibiting public disclosure, EPRI derives an economic benefit in the form of licensing royalties and other additional fees from the confidential nature of the Proprietary Information.

If the Proprietary Information were publicly available to consultants and/or other businesses providing services in the electric and/or nuclear power industry, they would be able to use the Proprietary Information for their own commercial benefit and profit and without expending the substantial economic resources required of EPRI to develop the Proprietary Information.

d. EPRI's classification of the Proprietary Information as trade secrets is justified by the Uniform Trade Secrets Act which California adopted in 1984 and a version of which has been adopted by over forty states. The California Uniform Trade Secrets Act, California Civil Code §§3426 -34.26.11, defines a "trade secret" as follows: "'Trade secret' means information, including a formula, pattern, compilation, program device, method, technique, or process, that: (1) Derives independent economic value, actual or potential, from not being generally known to the public or to other persons who can obtain economic value from its disclosure or use; and (2)lIs the subject of efforts that are reasonable under the circumstances to maintain its secrecy."~

e. The Proprietary Information contained therein are not generally known or available to the public. EPRI developed the Information only after making a determination that the Proprietary Information was not available from public sources. EPRI made a substantial investment of both money and employee hours in the development of the Proprietary Information.

EPRI was required to devote these resources and effort to derive the Proprietary Information. As a result of such effort and cost, both in terms of dollars spent and dedicated employee time, the Proprietary Information is highly valuable to EPRI.f. A public disclosure of the Proprietary Information would be highly likely to cause substantial harm to EPRI's competitive position and the ability of EPRI to license the Proprietary Information both domestically and internationally. The Proprietary Information can only be acquired and/or duplicated by others using an equivalent investment of time and effort.I have read the foregoing and the matters stated herein are true and correct to the best of my knowledge, information and belief. I make this affidavit under penalty of perjury under the laws of the United States of America and under the laws of the State of North Carolina. Executed at 1300 W WT Harris Blvd being the premises and place of business of Electric Power Research Institute, Inc.Neil Wilmshurst (State of North Carolina)(County of Mecklenburg) Subscribed and swr to (or affirmed) before be the person(s) who appeared before me.Signature .Q. 4 S me on this of by ,proved to me on the basis of satisf~tory evide-nnce to (Seal)My Commission Expires of f ,z ,20_J_ Enclosure 3 to NG-16-0042 Response to Request for Additional Information, License Amendment Request (TSCR-144) to Revise and Relocate Pressure and Temperature Limit Curves to a Pressure and Temperature Limits Report NextEra Energy Duane Arnold Response to EVIB RAI 1 with Redacted Non-Proprietary BWRVIP-I135 Sections 44 pages follow Response to Request for Additional Information, License Amendment Request (TSCR-144) to Revise and Relocate Pressure and Temperature Limit Curves to a Pressure and Temperature Limits Report Vessels and Internals Inteqrity Branch (EVIB)RAIl1 Provide the following reference from Enclosure 5 of the July 30, 2015 submittal to provide supporting in formation regarding the data and methodology necessary for determining best estimate chemistries and the adjustment of material chemistry factors: Enclosure 5, Reference 13: Duane Arnold specific sections of "B WRVIP-135, Revision 3: BWR Vessel and Internals Project, Integrated Surveillance Program (ISP) Data Source Book and Plant Evaluations," Palo Alto, CA, 2014, and any related follow-on documents containing data specific to Duane Arnold.NextEra Energy Response: The BWRVIP-135 revision 3 is an EPRI proprietary document. NextEra Energy will provide the requested Duane Arnold Specific sections along with the proprietary Affidavit including the following:

1) Cover Page, Page i, Page ii, identifying the official title and proprietary disclosure.

2) Page 2-22 & 2-23, The Duane Arnold Plant specific evaluation of the representative surveillance materials.

3) Appendix A-3 (Pages A-3-1 thru A-3-1 9) Plate Surveillance data.4) Appendix B-5 (Pages B-5-1 thru B-5-1 9) Weld Surveillance data.

Attachment 4 Contains Proprietary Information Withhold Attachment 4 from Public Disclosure in Accordance with 10 CFR 2.390 Enciosure 4 to NG-1 6-0042 Response to Request for Additional Information, License Amendment Request (TSCR-144) to Revise and Relocate Pressure and Temperature Limit Curves to a Pressure and Temperature Limits Report NextEra Enerqy Duane Arnold Response to EVIB RAI I with Proprietary BWRVIP-135 Sections Attachment 4 transmitted herewith contains Proprietary Information. When separated from Attachment 4, this document is decontrolled. 44 pages follow Response to Request for Additional Information, License Amendment Request (TSCR-1 44) to Revise and Relocate Pressure and Temperature Limit Curves to a-Pressure and Temperature Limits Report Vessels and Internals Integrity Branch (EVIB)RAIl1 Provide the following reference from Enclosure 5 of the July 30, 2015 submittal to provide supporting in formation regarding the data and methodology necessary for determining best estimate chemistries and the adjustment of material chemistry factors: Enclosure 5, Reference 13: Duane Arnold specific sections of "B WRVIP-135, Revision 3: BWR Vessel and Internals Project, Integrated Surveillance Program (ISP) Data Source Book and Plant Evaluations," Palo Alto, CA, 2014, and any related follow-on documents containing data specific to Duane Arnold.NextEra Energy Response: The BWRVIP-135 revision 3 is an EPRI p~roprietary document. NextEra Energy will provide the requested Duane Arnold Specific sections along with the proprietary Affidavit including the following:

1) Cover Page, Page i, Page ii, identifying the official title and proprietary disclosure.

2) Page 2-22 & 2-23, The Duane Arnold Plant specific evaluation of the representative surveillance materials.

3) Appendix A-3 (Pages A-3-1 thru A-3-1 9) Plate Surveillance data.4) Appendix B-5 (Pages B-5-1 thru B-5-1 9) Weld Surveillance data NEx~era Attachment 4 Contains Proprietary Information Withhold Attachment 4 from Public Disclosure in Accordance with 10 CFR 2.390 February 19, 2016 NG-1 6-0042 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk -Washington, DC 20555-0001 Duane Arnold Energy Center Docket No. 50-331 Renewed Op. License No. DPR-49 Response to Request for Additional Information, License Amendment Request (TSCR-144) to Revise and Relocate Pressure and Temperature Limit Curves to a Pressure and Temperature Limits Report -MF6617

References:

1)License Amendment Request (TSCR-144) to Revise and Relocate Pressure and Temperature Limit Curves to a Pressure and Temperature Limits Report, NG-15-0235, dated July 30, 2015 ('ML15253A310 and ML15253A311)

2) Electronic Communication, Request for Additional Information, License Amendment Request to Revise and Relocate Pressure and Temperature limit curves to a Pressure and Temperature Limit Renort- MF6617. dated January 31. 2016 In the Reference I letter, NextEra Energy Duane Arnold, LLC (hereafter NextEra Energy Duane Arnold) submitted a License Amendment Request for the Duane Arnold Energy Center (DAEC) pursuant to 10 CFR 50.90. Subsequently, the NRC Staff requested, via Reference 2, additional information regarding that application.

Attachment 4 transmitted herewith contains Proprietary Information. When separated from Attachment 4, this document is decontrolled. SAbbl NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324 Document Control Desk NG-l16-0042 Page 2 of 2 The Enclosures to this letter contain the requested information. This additional information does not impact the 10 CFR 50.92 evaluation of "No Significant Hazards Consideration" previously provided in the referenced application. This letter does not contain any new commitments or change any existing commitments. If you have any questions or require additional information, please contact J. Michael Davis at 319-851-7032. I declare under penalty of perjury that the foregoing is true and correct.-ecu).d on February 18, 2016 T. A. Vehec Vice President, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC Enclosure 1: Enclosure 2: Enclosure 3: Enclosure 4: NextEra Energy Duane Arnold Response to SRXB RAIs 1 and 2 EPRI Affidavit for Withholding Proprietary Information From the Public NextEra Energy Duane Arnold Response to EVIB PALI 1with Redacted Non-Proprietary BWRVlP-135 Sections NextEra Energy Duane Arnold Response to EVIB RALI 1with Proprietary BWRVIP-135 Sections cc: NRC Regional Administrator NRC Resident Inspector NRC Project Manager A. Leek (State of lowa)Attachment 4 transmitted herewith contains Proprietary Information. When separated from Attachment 4, this document is decontrolled. Enclosure 1 to NG-16-0042 Response to Request for Additional Information, License Amendment Request (TSCR-144) to Revise and Relocate Pressure and Temperature Limit Curves to a Pressure and Temperature Limits Report NextEra Energqy Duane Arnold Response to SRXB RAt 1 and RAI 2 2 pages follow Response to Request for Additional Information, License Amendment Request (TSCR-144) to Revise and Relocate Pressure and Temperature Limit Curves to a Pressure and Temperature Limits Report Reactor Systems Branch (SRXB) SRXB -RAI 1 Section 3.2, Adjusted Reference Temperature (ART) and Fluence, states that the fluence used in the development of the ART values were calculated using the NRC approved RAMA methodology found in References

7. 7 and 7.8. DAEC further references in Reference 7.10 an amendment dated August 25, 2003,"Duane Arnold Energy Center- Issuance of Amendment Regarding Pressure and Temperature Limit Curves," (ML 0323 10536) using the GE neutron fluence method in the GE Licensing Topical Report NED O-32983P-A.

The proposed PTLR (ML 15253A3 11) references using the RAMA methodology in TransWare Report No. DAE-FLM-OO1-R-O04, Revision 0, "Duane Arnold Energy Center Fluence Assessment Report -End of Cycle 24," dated April 3, 2015.Additionally, the PTLR also references the same SE using the GE method as the application discussed earlier. Lastly, in reviewing of neutron fluence methodologies approved for DAEC, the RAMA method is approved for Duane Arnold in its license renewal application for operation out to 54 effective furll power years (EFPY). It is unclear to the NRC staff how the GE and RAMA fluence methodologies are being applied for the proposed PTLR. The NRC staff requests that the licensee provide an explanation and any information regarding how the RAMA fluence methodology is being applied to DAEC for the proposed PTLR.NextEra Energy Response: The GE fluence methodology is not being used in the proposed DAEC PTLR. The fluence used in the development of irradiation em brittlement projections or adjusted reference temperature (ART) projections for the reactor vessel materials for 32 EFPY and 54 EFPY was based on the RAMA fluence methodology in TransWare Report No. DAE-FLM-001-R-004, Revision 0, "Duane Arnold Energy Center Fluence Assessment Report -End of Cycle 24," dated April 3, 2015 which is identified in Attachment 1, Section 3.2 of the LAR (ML15253A311). Attachment 1, Section 3.4 of the LAR, identifies the basis for the lowest service temperature (LST) and cites the 2003 SE as confirmation of the LST value which is an initial property unaffected by fluence. Attachment 5 and Attachment 6, Section 5.0 of the LAR, also references the prior P-T limit curve submittal prepared by GE [Reference 8] for reactor vessel material initial property chemistry values only, which are initial properties unaffected by fluence. Response to Request for Additional Information, License Amendment Request (TSCR-144) to Revise and Relocate Pressure and Temperature Limit Curves to a Pressure and Temperature Limits Report SR)(B -RAI 2 When comparing the proposed PTLR P/T curves for 32 EFPY to the current PIT curves in TS for 32 EFPY, the NRC staff noticed there is a difference in the P-IT curves. The NRC staff requests that the licensee provide an explanation regarding the differences seen between the current T.S P/IT curves for 32 EFPY and the PrOPosed PTLR P/IT curves for 32 EFPY.NextEra Energy Response: The 32 EFPY curves provided in Attachment 5 and 6 of the LAR were part of a P-T Limit curve calculation package that included both the 32 EFPY and 54 EFPY P-T limit curves that were prepared in 2008 to support license renewal but never submitted for approval. Subsequently, the calculation package that contained both the 32 EFPY and 54 EFPY P-T limit curves was updated with the latest fluence analysis using the RAMA methodologies and incorporating the results of the most recent Duane Arnold plant specific surveillance capsule tests and fluence results (BWRVIP-279NP). Although both curves periods of applicability were updated and submitted, Duane Arnold will transition to the 54 EFPY P-T curves upon approval of the PTLR as DAEC is nearing 32 EFPY. The 32 EFPY P-T limit curves in the PTLR will not be used.The differences in the current 32 EFPY Technical Specifications (TS) P-T limit curves and the proposed 32 EFPY PTLR curves in Attachment 5 and 6 of the LAR are the result of incorporation of the updated chemistry factor for surveillance plate, most recent fluence analysis through end of cycle 24 using the RAMA methodology, and a 25°F/hr heat up rate for the hydrostatic test (Curve A). The updated RAMA fluence for the limiting N2 nozzle is also less than projected in the previous 2003 submittal for the current 32 EFPY TS P-T curves resulting in less restrictive PTLR curves. As a result, the 32 EFPY PTLR overall Curve A includes the intersection of the non-beltline 10OCFR50 Appendix G flange limit where the 32 EFPY TS curves were lower and to the right of the flange limit.Other differences noted are the inclusion of the "non-beltline" doffed line on all the PTLR curves which includes the I0CFR50 Appendix G stressed flange limitation. The current 32 EFPY TS curves did not show this line because it was bounded by Curve A, although it was calculated and provided in the 2003 License amendment request submittal. Enclosure 2 to NG-16-0042 Response to Request for Additional Information, License Amendment Request (TSCR-144) to Revise and Relocate Pressure and Temperature Limit Curves to a Pressure and Temperature Limits Report.EPRI Affidavit for Withhold inq Proprietary Information From the Public 4 pages follow ~j ELECTRIC POWER~ RESEARCH INSTITUTE NEIL WILMSHURST Vice President and Chief Nuclear Officer Ref. EPRI Project Number 669 February 16, 2016 Document Control Desk Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission. Washington, DC 20555-0001

Subject:

Request for Withholding of the following Proprietary Information Included in: NextEra Energy Duane Arnold, LLC, Duane Arnold Energy Center Submittal to the NRC for "Response to Request for Additional Information -[AR to Revise and Relocate Pressure and Temperature Limit Curves to a Pressure and Temperature Limits Report -MF6617 ," Enclosure 2, NextEra Energy Duane Arnold Response to EVIB RAI- with Proprietary EPRI BWRVIP-1 35 Rev 3 Sections, "BWR Vessel and Internals Project Integrated Surveillance Program (ISP) Data Source Book and Plant Evaluations, 3002003144, Technical Report, December 2014" To Whom It May Concern: This is a request under 10 C.F.R. §2.390(a)(4) that the U.S. Nuclear Regulatory Commission ("NRC") withhold from public disclosure the report identified in the enclosed Affidavit consisting of the proprietary information owned by Electric Power Research Institute, Inc. ("EPRI") identified in the attached report. Proprietary and non-proprietary versions of the Response and the Affidavit in support of this request are enclosed.EPRI desires to disclose the Proprietary Information in confidence to assist the NRC review of the enclosed submittal to the NRC by NextEra Energy Duane Arnold, LLC. The Proprietary Information is not to be divulged to anyone outside of the NRC or to any of its contractors, nor shall any copies be made of the Proprietary Information provided herein. EPRI welcomes any discussions and/or questions relating to the information enclosed.If you have any questions about the legal aspects of this request for withholding, please do not hesitate to contact me at (650) 855-2271. Questions on the content of the Report should be directed to Andy McGehee of EPRI at (704) 502-6440.i(ncerely, Attachment(s) c: Sheldon Stuchell, NRC (sheldon.stuchell@nrc.gov) Together ...Shaping the Future of Electricity 1300 West W.T. Harris Boulevard, Charlotte, NC 28262-8550 USA

704.595.2732
Mobile 704.490.2653
nwilmshurst@epri.com RESEARCH INSTITUTE AFFIDAVIT RE: Request for Withholding of the Following Proprietary Information Included In: NextEra Energy Duane Arnold, LLC, Duane Arnold Energy Center Submittal to the NRC for "Response to Request for Additional Information

-LAR to Revise and Relocate Pressure and Temperature Limit Curves to a Pressure and Temperature Limits Report -MF6617 ," Enclosure 2, NextEra Energy Duane Arnold Response to EVIB RAI-1 with Proprietary EPRI BWRVIP-135 Rev 3 Sections, "BWR Vessel and Internals Project Integrated Sunveillance Program (ISP) Data Source Book and Plant Evaluations, 3002003144, Technical Report, December 2014" I, Neil Wilmshurst, being duly sworn, depose and state as follows: I am the Vice President and Chief Nuclear Officer at Electric Power Research Institute, Inc. whose principal office is located at 3420 Hillview Avenue, Palo Alto, CA. ("EPRr") and I have been specifically delegated responsibility for the above-listed report that contains EPRI Proprietary Information that is sought under this Affidavit to be withheld "Proprietary Information". I am authorized to apply to the U.S. Nuclear Regulatory Commission ("NRC") for the withholding of the Proprietary Information on behalf of EPRI.EPRI Proprietary Information is identified in the above referenced report by a solid underline inside double brackets. An example of such identification is as follows:{FThis sentence is an example.{E}}} Tables containing EPRI Proprietary Information are identified with double brackets before and after the object. In each case, the superscript notation {E} refers to this affidavit as the basis for the proprietary determination. EPRI requests that the Proprietary Information be withheld from the public on the following bases: WithholdinQ Based Upon PrivileQed And Confidential Trade Secrets Or Commercial Or Financial Information (see e..q., 10 C.F.R. § 2.390(a)(4):