RS-05-179, Submittal of Response to Quad Cities Steam Dryer Open Issues

Submittal of Response to Quad Cities Steam Dryer Open Issues

ML060030123
Person / Time
Site:	Dresden, Quad Cities
Issue date:	12/22/2005
From:	Simpson P Exelon Generation Co, Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-05-179
Download: ML060030123 (22)

Text

ExekrnSM Exelon Generation www.exeloncorp.com Nuclear 4300 Winfield Road Warrenville, IL 60555 RS-05-1 79 December 22, 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:

Response to Quad Cities Steam Dryer Open Issues On November 8 and 9, 2005, Exelon Generation Company, LLC, (Exelon) met with the NRC technical staff to discuss the results and conclusions of evaluations performed to demonstrate the acceptability of the Quad Cities Nuclear Power Station (QCNPS) replacement steam dryers for long-term operation at extended power uprate (EPU) conditions. As a result of this meeting, the NRC requested that Exelon provide additional information to support the NRC review of steam dryer related issues and, ultimately, closure of the issues related to operating the QCNPS units at EPU power levels. The attachments to this letter contain the information to support the NRC's review.

Attachment 1 of this letter contains an overall summary of each of the remaining open issues and the associated information that resolves each of them. These responses, in part, refer to technical reports that are enclosed with this letter.

Attachment 1 and the enclosures to this letter contain information considered proprietary to General Electric (GE). Therefore, Exelon 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 (a)(4). An Affidavit attesting to the proprietary nature of these documents is included in Attachment 1. A non-proprietary version of Enclosure 7 of Attachment 1 will be provided at a later date. Attachment 2 contains a non-proprietary version of Attachment 1 without the enclosures.

'A OC

_A0SB

December 22, 2005 U. S. Nuclear Regulatory Commission Page 2 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 Exelon Response to NRC Open Issues Concerning the Quad Cities Units 1 and 2 Replacement Steam Dryers (Proprietary)

2. Exelon Response to NRC Open Issues Concerning the Quad Cities Units 1 and 2 Replacement Steam Dryers (Non-Proprietary)

GE Energy Nuclear Richard J. Bodily Project Manager Exelon Integrated Steam Dryer 6705 Vallecitos Rood, Sunol, CA 94586, USA T 925-862-4410 T 408-925-1806 F 910-341-2805 richard.bodily@ge.com GE-ENG-DRY-159 December 17, 2005 To: Alan Bontjes (Exelon)

Authors: B.Branlund (GE)

Subject:

Review of Failure Modes for Quad Cities Unit 1 Replacement Dryer

Reference:

1. "GE - Quad & Dresden Dryer Performance Program," Exelon Business Services Co., Contract 75766, July 30, 2004.

Dear Alan:

As part of the Exelon Integrated Steam Dryer Project, GE is providing the subject attached engineering documents for review by the NRC. These documents have been verified in accordance with GE's Quality Assurance program.

The Attachment 3 affidavit identifies that the designated information has been handled and classified as proprietary to GE. The designated information issuitable for review by the NRC when accompanied by the attached affidavit. GE hereby requests that the designated information be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390 and 9.17.

GE requests that any transmittal of this proprietary information to the NRC be accompanied by the enclosed affidavit and proprietary notice. Inorder to maintain the applicability of the affidavit and to meet the requirements of 10CFR2.390, the transmittal to the NRC should:

1) faithfully reproduce the proprietary information,

2) preserve the proprietary annotations, and

3) include the words similar to "GE Proprietary Information" at the top of first page and each page containing the proprietary information.

Based on past discussions with the NRC, GE has been encouraged to request its customers to provide a paragraph similar to the following paragraph for inclusion in their transmittal letters in order to clearly indicate the proprietary nature of the information and to document the source of the proprietary information as indicated in the GE affidavit.

"The enclosed document contains proprietary information as defined by 10CFR2.390.

GE, as the owner of the proprietary information, has executed the enclosed affidavit, which identifies that the enclosed proprietary information has been handled and

GE-ENG-DRY-141 classified as proprietary, is customarily held in confidence, and has been withheld from public disdosure. The proprietary information was provided to Entergy in a GE transmittal that identifies the document and the affidavit. GE hereby requests that the enclosed proprietary information be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390 and 9.17. A non-proprietary version of the document is also provided.*

Further, 10CFR2.390 requires that the proprietary information be incorporated, as far as possible into a separate paper Therefore, Attachment 2 hereto contains the non-proprietary and redacted report, and the proprietary information is provided in Attachment 1. GE requests that the non-proprietary version be a hard copy. If an electronic copy of the non-proprietary information is provided to the NRC, GE requests that the non-proprietary information be removed from the file, not simply hidden with white fonts, hidden text or covered with electronic-drawn boxes, which can be readily defeated to reveal the proprietary information.

If you have any questions related to the enclosures, please contact the undersigned at (925) 862-4410.

Very truly yours, Richard J. Bodily cc James Meister (Exelon)

Roman Gesior (Exelon)

Guy Deboo (Exelon)

Robert Stachniak lExelon)

Roy Hunnicutt (Exelon)

Thomsa Roddey (Exelon) - GENE-0000-0048-8406-01-P, Review of Failure Modes for Quad Cities Unit 1 Replacement Dryer' - (Proprietary) - GENE-0000-0048-8406-01-NP, 'Review of Failure Modes for Quad Cities Unit 1 Replacement Dryer' - (Non-Proprietary) - Affidavit, George B.Stramback, doted December 17,2005 Page 2 of 2

GE-ENG-DRY-159 ATTACHMENT 2 GE-ENG-DRY-159 "Review of Failure Modes for Quad Cities Unit 1 Replacement Dryer", GENE-0000-0048-8406-01-NP NON PROPRIETARY NOTICE This is a non proprietary version of the document GENE-0000-0048-8406-01-P, which has the proprietary information removed. Portions of the document that have been removed are indicated by an open and closed bracket as shown here (( )).

GENE-0000-0048-8406-0 1-NP Class I December 2005 Review of Failure Modes for Quad Cities Unit 1 Replacement Dryer

Non Proprietary Version GENE-0000-0048-8406-01-NP IMPORTANT NOTICE REGARDING THIE CONTENTS OF THIS REPORT Please Read Carefully NON PROPRIETARY NOTICE This is a non proprietary version of the document GENE-000O-0048-8406-01-P, which has the proprietary information removed. Portions of the document that have been removed are indicated by an open and closed bracket as shown here (( )).

IMPORTANT NOTICE REGARDING CONTENTS OF THIS REPORT Please Read Carefully The only undertakings of the General Electric Company (GENE) with respect to the information in this document are contained in the contract between EXELON and GENE, and nothing contained in this document shall be construed as changing the contract. The use of this information by anyone other than EXELON or for any purpose other than that for which it is intended, is not authorized; and with respect to any unauthorized use, GENE makes no representation or warranty, express or implied, and assumes no liability as to the completeness, accuracy, or usefulness of the information contained in this document, or that its use may not infringe upon privately owned rights.

Page i

Non Noixielfty Version Poprieary Non VsionGENE-00OQ0-0048.S40"1-O Process/Product Failure Modes and Effects Analysis (FMEA)

Process or Prod Review or Failure Modes for ud Cties Unit I Repeocment Dryer Preard by. RB, D8D, HSM, DW DCP, RMH, Name: - . LW V , ,

ResponrO. ftAl~i, HOn, Wlefttein, RePOs Vee Pappone FA Dat Pic) .. 1i21/5, o e.

Penie .

Notes regarding Process SteplPawt design and Potential Potential Failre Actions Number modeling Failure Mode Effects SEV Potential Causes OCC Current Controls DET RPN Recommended Resp.

Also see Reference I Inwhalways Whd lthe bneof the How severe Wh am the causes of How oten nWat ethe edeting H rwed Caculated ht we the action for Who is Figue 63 for can the process Failure Mode on the cun Is the effect the Faelure Mode? does the controls and procedures can you reducn the occurrence, responsible for steam dryer model tep go ~ c eer? on the Cause or that prevent the Cause or deteetthe decresing severty or the customer? Failure Failure Mode? Cueor lrcngdetection? recommended Mode Fa action?

aEiGN an High cycie I I [ I Assum Detection I I Inspect with a remot Exeon MODELING: f a Initiation durng Inspection Can vehiole while Inthe d igue be npeted writ a equipment pool during rowth.

Gcr remote vehift while in next orise he equipnent pool.

Reference 2 . Table 3.1. D Reree Figure 6 n

STRES R ed As Detection model an the re duhng Nnrl were reduced -ee Ope n: n Revised Desin Marbi (Refrence 2) I DRF oOot74 Page 1 of 6 Sec"ion 4

Non Proprietary Version GENE-OOM-0043-840"1-NP Process or Product Review ofFalte Mode for Quad Cfte Unit I Replaemet Dyer Prepared by: Fa DBD, HSM, 00, DCP, RMH, Name: ._ LWVWP Respon**b Bwend, Horn, Wellst ResponseWV~re Psppone FMEEAData(Orig) 11105 Rev. O Pence _ _ _ _ _ _ . _ ..

Notes regarding Process SteplPart design and Potential Potential Failure Actions Number -modeling Failure Mode Effects SEV Potential Causes OCC Current Controls DET RPN Recommended Resp.

AMso see Reference I Inwhatays t the pactdthe Howseve Wtt arethe causesof How often VIt are the existing Howwel Cabulated Vat are the actions for o is Figure 8-3 for hu Om1th PIo Failu Mode on te is the ct the Falkire Mode? does the controls and procedures can you reduc*n the occurrence. responsible for steam dryer 1model step go wrnceeeon fte Cause or tha prevent the Cause or deetthe deraigseverity or the cusioner? Failure Failure Mode? Cause or prxIg detectIon? recomMended Mode Falr action?

occur? Mode?

DESIGN and Hih cce I I U I Assu Detection I I Inspec while in the Exelon MODELNG: f[ fatigpe Itation d Ingnspection: equipment pool dur"g n nd tgue bdernal Inspection next outae. Note: this is grcirowth. recomm8~ended obe only Reference 2 - Table an external inspection 3-1 Referce 1- FIPure 6-25 STRESS: II Assuae Detection dn Nr a 11~~~~ .prto:[

DRF 00004045-4374 Page 2 d 6 Section 0000 0

Non Proprietary Version GENE-0000-0043-940"1-NP ressor Pro Revew of Filre Modes Wruad Citis Unit 1 Rep oement Dryer Preparedby: RB, CDO,HSM, O OCP, RMH, Name: LWVP ResponsibW Brertud. Ho-. Welste , Responsible Vel P e FMEADat(Ore r0) J RRev. O Penme ___- -

Notes regarding Process Step/Padt design and Potential Potential Failure Actions Number modeling Failure Mode Effects SEV Potential Causes OCC Current Controls DET RPN Recommended Resp.

Also see Reference 1 Inwhatways V te Itlmpactfdthe Howsevere Uhat Barthe causesof HIow often W" are the exiting HowweMl Caboulated Whd are the actions for Who is FIgure 43for fun C81 the po Failuer Mode on the dh the e fttFaliure Mode? does the contols and procedure can you reduc the occurMnoe, eo be for steam dryer model temdyrmdpe o  ? on lth cuftomer? Cause Fallure or ttFailure Mode?w Camuor detet prevent Cueor the dereaing severty or IMprMin deteCton? th recommended Mode Fallure action?

occur? Mode?

DESK3N and High cye I A Detetion I 1 Insped with a remote Exelon D MODELING: fafti t durIng Ispection: Can vehcl while Inthe, and e be inspected with a equipmert pod during Referen 2 -Table 3-1 Wwft remote vehicle While In next outage the QUIPmet poOL Reene t- Figure 626.

STRESS: i AssumeDetctio n

.dung Nomnal L I I I IOperaton Q 1 DRF 0000-045-4374 Page 3d 6 Section 0000-0048-400

Non Prq)rietwy Version OLNE-0000-0048-9406-01-NP Process or Product ReiewofFalue Modesfor Quad Cities Unit I Replacement DWyer Prepared by: RB, DBD, HSh, DWS. OCP, RMH, Name: _ . LW, VVWP Responsible: Brnund, Horn, Wilseh, Resposble Verlifer Paoe FMEA Date (06g) 112jU05 Rev. O Pence _ ... _

Notes regarding Process Step/Part design and Potential Potential Failure Actions Number modeling Failure Mode Effects SEV Potential Causes MCC Current Controls DET RPM Recommended Resp.

Also see Reference 1 Inwhat ways i sthe impact othe Howsevere VWhtarathe causesof How oten What are the eristing Howwel Cateulated tat are the actions for Vho is Figure &3 for RA can the Po Fallure Mode on tbe isthsefed the Falure Mtod? does he n s nd p dures can you reducin the occurrence. responsible for steam dryer model stp go w g? custa e? on the Cause or hat prevent the Cause or Cueor de the decreasing severity or the customer? Failure FailUre Mode? Improilng detection? recommended Mode Failure action?

occur? Mode?

DESIGN D and High cycle I Assune DetectIon 1 9 Inspect with a remote Exelon MhELING: f fatigue nitiation du1ing Inspection: Can vehicle while in tle n and ftgue be inspected with a equipment pool durin grat h remote vehicle Mhile In neot oulage Reference 2 - Table 3-1 the equiPment pool.

It D Reeec

1. F~gur 6-STRESS: If Assume Detection dwing onnal Operati~on: II DRF 0000-0045-4374 Page 4 d 6 Section 00000048-840f

Non Proprietary Version GENE-0000-0048-9406-01-NP Process or Product Review of Failure Modes for _ued Cities Unit 1Replacement Dryer Name: LW, W__

Responsible: eranenmd, Nam, Walleten, ResponsiblV er. Pappone FMEA~ate(Orig) 11105 Rev. O Pence _ _

Notes regarding Process Step/Part design and Potential Potential failure Actins Number modeling Failure Mode Effects SEV Potential Causes 0CC Current Controls DET RPN Recommended Resp.

Also see Reference I In whatways Vat stheimpact ofthe Howsevere What are the causesof How often at are the efisting Howwell Calaulated What are the actions for V~ho Is Figure 6-3 br hll c the procem Failure Mode on ihe Is the e the FaIlure Mode? does the controts and procedures can you reduoing the occurre", responsible for steam dryer model ste gowrong? tomer? on te Cause or that prevent the Cause or debte the Failure decreasing sevit or the u Failure Mode? Cau or Imprvtn detetion? recommended Mode Failure action?

__.__._._occur? Mode?

DESIGN and High cycle [

n MODELING: n fht Inietion 5 Detection dIng Inspecthon: Can

. 5 Inspect with a remote vehicle while in the Exelon and fatigue be Inspected with a equipment pool durfg Reference 2- Table 31 crackgrowlh.

Dl remote vehicle while hi the equipment pool.

nextoutage Reference I- Figure 642 d solid model from n n

Referenoe 3- Fine 6-

72.

STRESS: (n AssueDetection durig Nornrl l n emfion:1l DRF 0000.-045-4374 Page 5ot6 Section 000-0048-8406

Nan Proprietry Vasion GENE-000"048-940&01-NII Process or Product Review of Failure Modes for _uad Cities Unit I Replacement Dryer Prepared by: R8 OD, HSM, D L . CP, RMH, l

Name: LW, _ ___

Responsible: Branlind, Horn, Weiste, ResponsibeVefer Pappone FMEADate(Orig) 11Q1105 Rev. O Pence Notes regarding Process Step/Part design and Potential Potential Failure Actions Number modeling Failure Mode Effects SEV Potential Causes OCC Current Controls DET RPN Recommended Resp.

Also see Reference 1 Inwhatys t ct e Howsevere What are the causes of How often "hatare the edisn Howwel Caluted Vhat are the actions for Who is Figure 6 3 can hMe process Failure Mode on the Isth effect the Failure Mode? does the controls and procedures can you reducing the occurrence, responsible for steam dryer model s owron? customer? on the Cause or fhat prevent the Cause or detec the decreasing severity or the customer? Failure Failure Mode? Cause or improving detection? recommended Mode Failure action?

. . _ occur? Mode?

DESIGN and High cycle I I Assume Detection I 1 Inspect with a remote Exelon F MODELING: fau Initation during lnspectlon Can vehicle while in the it and tatigue be Inspected with a equipment pool during Reeence 2 - Table 3-1 coc growth. remote vehicle while in next outage teequipment pool, Reference 1-Figre 65 STRESS [A me Detection during Nornul I IOperation11if 1

Nomenciature:

SEV How severe iste effect on the customer?

0CC How often does theCae or Failure Mode occur?

DET -ow well can you detect the Cause or Failure Mode?

Value 1= Low, 5 a MedIum, 9 a High - either severity OME).

likelihood of o uwere (0CC) or ability to deted (DET) - (a lower value is bett RPN wSEVOOCIET Failure For the purposes of this FM EA failure isdefined a crack initiation and propagation with the potential for generating a ibose pat References 1. L Wiltein, atal, "uad Cities Unit I Replacment Steam Dryer Stess and Fatigue Analysis at EPU Power Leve-of 2957 M% Based on Measured EPU Condtlions," GE-NE, Sunol, CA, August 2005, (GENE40000-43-5391-01P, Revision 1). GE Propeary information

2. L WVlatein and l Wal-, 'Qua Cities Units I arid 2 Replacement Steam Dryer Analysis Stess, Dynamic, and Fatigue 8upp n Analysis for EPU Oondtions." GE-NE Sunol, CA, December 2005, (GENE-M-0D46-5358-01 Rev 1-P) GE Proprietary Infrmation

3. OQuad Cities Units l end 2 Replace Steam Dyer Analysis Stress, Dynamic, and Fatigue Analyses for EPU Conditions! DRF GE-NE.0000034-3781, DRF Section GE-NE4000039-4902, Revision 0,Class III,April 2005 CRF OOO-0o045-4374 Page 6o 6 Section 0000-0048-6406

GE-ENG-DRY-159 ATTACHMENT 3 GE-ENG-DRY-159 Affidavit

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 GENE-0000-0048-8406-01-P, Review of Failure Modes for Quad Citis Unit I Replacement Lhyer, Class HI (GE Proprietary Information), dated December 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 notationt') 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 (TFOIA"), 5 USC Sec. 552(bX4), and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CER 9 .17(aX 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, Criical Mas Enerm Proijet v Nuclear Reg1gWCormissiM 975F2d871 (DC Cir. 1992), and Public Citizen ealth Research Group v. FDA, 704F2d1280 (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 prvention 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-05-07-Af QC I Dryer Failure Modes GENE-4-8406-t1-Pdoc 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 maiketing function (or his delegate), and by the Lgal 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 Gs comprehensive BWR safty 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 iith NRC-approved methods.

The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GE.

GBS-05A07-AfQC I Dryer Failret Modes GENE48-8406-01-P oe 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 verifyF 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 pejuIy 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 of Cday 205.

.: i day of _ _ _ _ _ _ _ _ _ _ _ _ _

GegeB. Stramb General Electric Company QHS4-057-Af QC 1 Dryer Failure Modes GENE94440601i -P~doc Affdavit Page 3

GENE-0000-0045-5505-01 October 2005 Response to NRC Concern on Quad Cities Steam Dryer Startup Criteria NON PROPRIETARY NOTICE This is a non proprietary version of the document GE-NE-0000-0045-5505-01-P, which has the proprietary information removed. Portions of the document that have been removed are indicated by an open and closed bracket as shown here (( ].

Page I of 5

GENE-0000-0045-5505-01 October 2005 Response to NRC Concern on Quad Cities Steam Dryer Startup Criteria NRC RAI: The NRC wants to see if Exelon met startup criteria on QC2 for strain gage locations S-5, S-7, and S-9 using calculated stresses (Using the modified action levels generated during the QC2 startup testing and the final stresses calculated for various components, determine whether any criteria were exceeded for strain gages).

Response (prepared by Richard Wu, eDRF Section 0000-0045-5505):

References:

1. "Quad Cities Replacement Steam Dryer Instrumentation Acceptance Criteria" GENE, DRF 0000-0032-1827, Section 0000-0036-2077, Revision 0, April 2005.

2. "Quad Cities Units I and 2 Replacement Steam Dryer Analysis Stress, Dynamic, and Fatigue Analyses for EPU Conditions" DRF GE-NE- 0000-0034-3781, Section GE-NE-0000-0039-4902, Revision 0, April 2005.

3. "Quad Cities Replacement Steam Dryer Improved Acceptance Criteria for Strain Gages S-5 and S-T' GENE, DRF 0000-0040-7752-01, Section 0000-0040-7755, Revision 0, May 2005.

4. "Quad Cities Replacement Steam Dryer Revised Acceptance Criteria for Strain Gage S-7" GENE, DRF 0000-0040-7752-03 RI, Section 0000-0040-7755 Revision 2, June 2005.

5. "Quad Cities Unit 2 Replacement Steam Dryer Vibration Instrumentation Program Plant Startup Test Report" GE-NE- 0000-0044-2240-01, Section 0000-0030-1241 Revision 0, August 2005.

6. "Quad Cities Unit 2 Replacement Steam Dryer Stress and Fatigue Analysis Based on Measured EPU Conditions" DRF GENE- 0000-0043-3105-01, July 2005.

7. "QC 1 & 2 Replacement Steam Dryer Stress, Dynamic, and Fatigue Supplementary Analysis for EPU Conditions" DRF GENE- 0000-0046-5358, Section 0000-0046-5359, October 2005.

8. "Fatigue Stress Threshold Criteria for use in the Exelon Replacement Steam Dryer", GENE-0000-0034-8374, October 2004.

A startup test was performed on the QC2 new steam dryer. The new steam dryer was instrumented with strain gages (Reference I) that are located on components where finite element analysis (FEA, Reference 2) predicted high stresses (as listed in Table 1). Of the strain gages installed, only S strain gages were operable throughout the startup program.

Page 2 of 5

GENE-0000-0045-5505-01 October 2005 Two levels of strain measurement acceptance criteria were established (Reference 1):

Level A and Level B.

Level A [

1]

Level B I{

]i Table I Hiigh Stress Locations Monitored Directly by Strain Gages Strain Gage Gage Location Components Monitored

,I ii]

These allowable stress limits were used to calculate the strain gage acceptance criteria based on two sets of pre-test predicted fluid dynamic loads from Continuum Dynamics Inc (CDI): Scaled Model Test (SMT) load and In-plant load. The calculated strains at each gage location, with the maximum stress normalized to the acceptance stress limit for the appropriate level, are the strain gage acceptance criteria. For each of the two pre-test predicted loads, three time history stress responses were calculated with ([

)) scaled time intervals (Reference 2). Thus, for each strain gage, there are six criteria. The minimum of the six was conservatively selected as the acceptance criterion (Table 2). Also presented in Table 2 are startup test measured strains at ((

Page 3 of 5

GENE-0000-0045-5505-01 October 2005 1]

Table 2 QC2 Startup Test Strain Gage Acceptance Criteria using Pre-test Predicted SMT and In-Plant Loads

1. 4. 4

4. + +

+ 1* 1*

I. 4. 1*

1. 4. 4.

11]

___________ A. A. A.

During QC2 startup testing, the new steam dryer was also instrumented with pressure sensors, and the steam lines were instrumented with strain gages. Incorporating the measured steam line strain gage data with the benchmarked acoustic circuit model, a modified set of steam dryer loads (post -test predicted loads) was also developed.

Using these modified post-test predicted dryer loads, three time history stress responses were again calculated with ((

(References 6 and 7). Based on these stresses, a modified set of strain gage acceptance criteria was established as shown in Table 3. The procedures used to determine the modified strain gage acceptance criteria were identical to those used for the strain gage acceptance criteria based on the stresses calculated using pre-test predicted In-plant and SMT loads.

Example calculations are given in the following for Strain Gage S-9 (outer hood gage).

The governing case for this gage is the stress and strain responses with the nominal time interval:

((

11 Page 4 of 5

GENE-0000-0045-5505-01 October 2005 The data in Table 3 demonstrates that all measured strains are considerably below the modified allowable limits for both Level A and Level B. Therefore, using the modified action levels generated during the QC2 startup testing and the final stresses calculated for various components, no criteria was exceeded for all strain gages.

Table 3 QC2 Startup Test Strain Gage Acceptance Criteria using Post-test Acoustic Circuit Model Load

[II Figure 1 Time History Peak Stress Intensity, Outer Hood

((

1]

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