RS-05-053, Technical Documentation Related to Analysis and Design of New Quad Cities Steam Dryers, and Responses to Requests for Additional Information Related to EPU Operation at Dresden and Quad Cities Nuclear Power Stations
| ML051230020 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Quad Cities  |
| Issue date: | 04/28/2005 |
| From: | Simpson P Exelon Generation Co, Exelon Nuclear |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RS-05-053 | |
| Download: ML051230020 (15) | |
Text
- -
Exek1n .
Exelon Generation www.exeloncorp.com Nuclear 4300 Winfield Road Warrenville, IL 60555 RS-05-053 April 28, 2005 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265
Subject:
Technical Documentation Related to Analysis and Design of New Quad Cities Steam Dryers, and Responses to Requests for Additional Information Related to EPU Operation at Dresden and Quad Cities Nuclear Power Stations
References:
- 1. Letter from J. A. Benjamin (Exelon Generation Company, LLC) to U. S. NRC, "Commitments and Information Related to Extended Power Uprate," dated April 2, 2004
- 2. Letter from K. R. Jury (Exelon Generation Company, LLC) to U. S. NRC, "Commitments and Plans Related to Extended Power Uprate Operation,"
dated May 12, 2004 In the referenced letters, Exelon Generation Company, LLC (EGC) made several commitments regarding the operation of Dresden Nuclear Power Station (DNPS), Units 2 and 3, and Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2, including a commitment to limit operation of the QCNPS units to pre-extended power uprate (EPU) power, except for brief periods to collect data, until NRC approval is obtained to return to long-term operation at EPU power. In anticipation of a request from EGC to return the QCNPS units to long-term operation at EPU power, the NRC requested that EGC provide additional information to support a review of issues related to operation of the DNPS and QCNPS units at EPU power levels. The attachments to this letter contain information to support the NRC's review.
Attachments 1, 2, and 3 contain information that is considered proprietary to General Electric (GE). Therefore, EGC requests that this information be withheld from public disclosure in accordance with 10 CFR 2.390, "Public inspections, exemptions, requests for withholding,"
paragraph (a)(4), and 10 CFR 9.17, "Agency records exempt from public disclosure," paragraph
- *, 1pol
I April 28, 2005 U. S. Nuclear Regulatory Commission Page 2 (a)(4). An Affidavit attesting to the proprietary nature of these documents in included in the attachments. EGC plans to provide non-proprietary versions of these documents at a later date.
Should you have any questions concerning this letter, please contact Mr. Thomas G. Roddey at (630) 657-2811.
Respectfully, Patrick R. Simpson Manager - Licensing Attachments:
- 1. Affidavit and "Quad Cities 2 New Dryer SMT Loads," C.D.I. Technical Note No. 05-04, Revision 5, GE Proprietary, dated April 2005
- 2. Affidavit and "Engineering Report for Quad Cities Unit 1 Scale Model Testing,"
NEDC-33192P, GE Proprietary, dated April 2005
- 3. Affidavit and "Quad Cities Units 1 and 2 Replacement Steam Dryer Analysis Stress, Dynamic and Fatigue Analyses for EPU Conditions," GE-NE-0000-0034-3781, Revision 0, GE Proprietary, dated April 2005
- 4. "Fatigue Analysis of the Quad Cities Replacement Dryer," XGEN 2005-1, Revision 2, dated April 2005
- 5. "Steam Dryer Vibration Instrumentation, "Installation Specification, GE Report 26A6493, Revision 3, dated April 22, 2005
- 6. "Dryer Vibration Instrumentation," Design Specification, GE Report 26A6395, Revision 1, dated April 22, 2005
- 7. "Steam Dryer Vibration Measurement," Test Specification, GE Report 26A6388, Revision 3, dated April 20, 2005
- 8. "FIV Sensors, Signal Cond. & Data Acquis. System for Dryer Test," Design Specification, GE Report 26A6366, Revision 2, dated April 22, 2005
- 9. "Data Acquisition System Installation and Test Procedure," Test Procedure, GE Report 26A6499, Revision 2, dated April 22, 2005
- 10. "Charge Converter, Junction Box &.Signal Conditioning," Test Procedure, GE Report 26A6485, Revision 2, dated April 22, 2005
- 11. "Sensors in the String Assembly Before & After Installation," Test Procedure, GE Report 26A6484, Revision 2, dated April 22, 2005
- 12. "Steam Dryer Hammer Test Specification," Test Specification, GE Report 26A6380, Revision 2, dated April 22, 2005
April 28, 2005 U. S. Nuclear Regulatory Commission Page 3 cc: Regional Administrator - NRC Region IlI NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector- Quad Cities Nuclear Power Station Illinois Emergency Management Agency - Division of Nuclear Safety
ATTACHMENT 1 Affidavit and "Quad Cities 2 New Dryer SMT Loads," C.D.I.
Technical Note No. 05-04, Revision 5, dated April 2005
General Electric Company AFFIDAVIT I, James Kiapproth, state as follows:
(1) I am Manager, Engineering, General Electric Company ("GE") and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.
(2) The information sought to be withheld is contained in Continuum Dynamics, Inc.
report, C.D.I. Technical Note No. 05-04, Quad Cities 2 New Dryer SMT Loads, Revision 5, (This report contains GE Proprietary Information), dated April 2005.
The proprietary information is delineated by brackets on pages containing "GE Proprietary Information" in the header. In each case, the superscript notation 3 )
refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.
(3) In making this application for withholding of proprietary information of which it is the owner, GE relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec 1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) for "trade secrets" (Exemption 4). The material for which exemption from disclosure is here sought also qualify under the narrower definition of "trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Proiect v. Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704F2dl280 (DC Cir. 1983).
(4) Some examples of categories of information which fit into the definition of proprietary information are:
- a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by General Electric's competitors without license from General Electric constitutes a competitive economic advantage over other companies;
- b. Information which, if used 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 of a similar product;
- c. Information which reveals aspects of past, present, or future General Electric customer-funded development plans and programs, resulting in potential products to General Electric;
- d. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.
CDI Tech Note No. 05-04 Rev 5 Dryer SMT Loads.doc Affidavit Page 1
. t The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs 4(a), and (4)b, above.
(5) To address 10 CFR 2.390 (b) (4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GE, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GE, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.
(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to such documents within GE is limited on a "need to know" basis.
(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GE are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.
(8) The information identified in paragraph (2) above, is classified as proprietary because it contains GE's benchmarking details for analysis of the design of the BWR Steam Dryer. Development of this information and its application for the design, procurement and analysis methodologies and processes for the Steam Dryer program was achieved at a significant cost to GE, on the order of approximately two million dollars.
The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GE asset.
(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GE's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GE's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate CDI Tech Note No. 05-04 Rev 5 Dryer SMT Loads.doc Affidavit Page 2
evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.
The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GE.
The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.
GE's competitive advantage will be lost if its competitors are able to use the results of the GE experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.
The value of this information to GE would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GE of the opportunity to exercise its competitive advantage to seek and adequate return on its large investment in developing these very valuable analytical tools.
I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.
Executed on this OZ day of ksQi L 2005.
James Klapproth General Electric Company CDI Tech Note No. 05-04 Rev 5 Dryer SMT Loads.doc Affidavit Page 3
ATTACHMENT 2 Affidavit and "Engineering Report for Quad Cities Unit 1 Scale Model Testing," NEDC-33192P, GE Proprietary, dated April 2005
General Electric Company AFFIDAVIT I, George B. Stramback, state as follows:
(1) I am Manager, Regulatory Services, General Electric Company ("GE") and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.
(2) The information sought to be withheld is contained in GE report, NEDC-33192P, EngineeringReport for Quad Cities Unit I Scale Model Testing, Class III (GE Proprietary Information), dated April 2005. The proprietary information is delineated by a double underline inside double square brackets. Figures and large equation objects are identified with double square brackets before and after the object. In each case, the superscript notation 3 ) refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.
(3) In making this application for withholding of proprietary information of which it is the owner, GE relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) for "trade secrets" (Exemption 4). The material for which exemption from disclosure is here sought also qualify under the narrower definition of "trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704F2dl280 (DC Cir. 1983).
(4) Some examples of categories of information which fit into the definition of proprietary information are:
- a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by General Electric's competitors without license from General Electric constitutes a competitive economic advantage over other companies;
- b. Information which, if used 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 of a similar product;
- c. Information which reveals aspects of past, present, or future General Electric customer-funded development plans and programs, resulting in potential products to General Electric;
- d. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.
GBS-05-03-Af QC1 Dryer Eng Rpt Scale Model Testing GE-NE-32-2219.doc Affidavit Page I
The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a., and (4)b, above.
(5) To address 10 CFR 2.390 (b) (4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GE, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GE, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.
(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to such documents within GE is limited on a "need to know" basis.
(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GE are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.
(8) The information identified in paragraph (2), above, is classified as proprietary because it contains GE's scale model testing details for analysis of the design of the BWR Steam Dryer. Development of this information and its application for the design, procurement and analyses methodologies and processes for the Steam Dryer Program was achieved at a significant cost to GE, on the order of approximately two million dollars.
The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GE asset.
(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GE's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GE's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.
The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GE.
GBS-05-03-Af QC1 Dryer Eng Rpt Scale Model Testing GE-NE-32-2219.doc Affidavit Page 2
The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.
GE's competitive advantage will be lost if its competitors are able to use the results of the GE experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.
The value of this information to GE would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GE of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing these very valuable analytical tools.
I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.
Executed on this o day of AA 2005.
Ggge B-. Stramback General Electric Company GBS-05-03-Af QC1 Dryer Eng Rpt Scale Model Testing GE-NE-32-2219.doc Affidavit Page 3
ATTACHMENT 3 Affidavit and "Quad Cities Units 1 and 2 Replacement Steam Dryer Analysis Stress, Dynamic and Fatigue Analyses for EPU Conditions," GE-NE-0000-0034-3781, Revision 0, GE Proprietary, dated April 2005
General Electric Company AFFIDAVIT I, George B. Stramback, state as follows:
(1) I am Manager, Regulatory Services, General Electric Company ("GE") and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.
(2) The information sought to be withheld is contained in GE Proprietary report, GE-NE-0000-0034-3781P, Quad Cities Units 1 and 2 Replacement Steam DryerAnalysis Stress, Dynamic and Fatigue Analyses for EPU Conditions, Revision 0, Class III (GE Proprietary Information), dated April 2005. The proprietary information is delineated by a double underline inside double square brackets. Figures and large equation objects are identified with double square brackets before and after the object. In each case, the superscript notation 3 ) refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.
(3) In making this application for withholding of proprietary information of which it is the owner, GE relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) for "trade secrets" (Exemption 4). The material for which exemption from disclosure is here sought also qualify under the narrower definition of "trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Proiect v. Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704F2dI280 (DC Cir. 1983).
(4) Some examples of categories of information which fit into the definition of proprietary information are:
- a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by General Electric's competitors without license from General Electric constitutes a competitive economic advantage over other companies;
- b. Information which, if used 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 of a similar product;
- c. Information which reveals aspects of past, present, or future General Electric customer-funded development plans and programs, resulting in potential products to General Electric;
- d. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.
GBS-05-03-Af QC Dryer Stress Dynamic Fatigue Analyses for EPU GE-NE-34-378 IP.doc Affidavit Page I
The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a., and (4)b, above.
(5) To address 10 CFR 2.390 (b) (4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GE, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GE, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.
(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to such documents within GE is limited on a "need to know" basis.
(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GE are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.
(8) The information identified in paragraph (2), above, is classified as proprietary because it contains details of steam dryer stress, dynamic and fatigue analyses of the design of the BWR Steam Dryer. Development of this information and its application for the design, procurement and analyses methodologies and processes for the Steam Dryer Program was achieved at a significant cost to GE, on the order of approximately two million dollars.
The development of the evaluation process along with the interpretation and application of the analytical results is derived from the extensive experience database that constitutes a major GE asset.
(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GE's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GE's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.
The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GE.
GBS-05-03-Af QC Dryer Stress Dynamnic Fatigue Analyses for EPU GE-NE-34-3781P.doc Affidavit Page 2
The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.
GE's competitive advantage will be lost if its competitors are able to use the results of the GE experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.
The value of this information to GE would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GE of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing these very valuable analytical tools.
I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are true and correct to the best of my knowledge, information, and belief.
Executed on this '/Lday of & 2005.
Geo ge B. Stramback General Electric Company GBS-05-03-Af QC Dryer Stress Dynamic Fatigue Analyses for EPU GE-NE-34-378 I P.doc Affidavit Page 3