View source for GO2-21-016, License Amendment Request to Change Technical Specification 3.4.11 Reactor Coolant System Pressure and Temperature Limits

{{Adams
| number = ML21299A182
| issue date = 10/13/2021
| title = License Amendment Request to Change Technical Specification 3.4.11 Reactor Coolant System Pressure and Temperature Limits
| author name = Dittmer J
| author affiliation = Energy Northwest
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000397
| license number = 
| contact person = 
| case reference number = GO2-21-016
| package number = ML21299A181
| document type = Letter type:GO, License-Application for Facility Operating License (Amend/Renewal) DKT 50, Technical Specification, Bases Change
| page count = 87
| project = 
| stage = Request
}}

=Text=
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Proprietary - Withhold under 10 CFR 2.390. Enclosure 7 contains PROPRIETARY information.
ENERGY J Kent Dittmer Columbia Generating Station NORTHWEST P.O. Box 968, PE01 Richland, WA 99352-0968 Ph. 509.377.4348 l F. 509.377.4150 jkdittmer@energy-northwest.com October 13, 2021 GO2-21-016                                                                                     10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

==Subject:==
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 LICENSE AMENDMENT REQUEST TO CHANGE TECHNICAL SPECIFICATION 3.4.11 REACTOR COOLANT SYSTEM PRESSURE AND TEMPERATURE LIMITS

==Reference:==
NUREG-2123 "Safety Evaluation Report Related to the License Renewal of Columbia Generating Station," published May 2012

==Dear Sir or Madam:==

Pursuant to 10 CFR 50.90, Energy Northwest hereby requests a license amendment to revise the Columbia Generating Station (Columbia) Technical Specification (TS) 3.4.11 Reactor Coolant System (RCS) Pressure and Temperature (P/T) Limits. This amendment will replace the P/T curves for Inservice Leak and Hydrostatic Testing, Non-Nuclear Heating and Cooldown, and Nuclear Heating and Cooldown currently illustrated as TS Figures 3.4.11-1, 3.4.11-2, and 3.4.11-3, respectively. This submittal satisfies the license renewal commitment identified in Appendix A Table A-1, "Columbia License Renewal Commitments" of the reference as Item Number 54 which states:
The Columbia P-T limit curves were revised in 2005 to include the effects of power uprate to 3486 MWt. The P-T limits are valid for 33.1 EFPY through the end of the currently licensed period. P-T limits for the period of extended operation will be calculated using the most accurate fluence projections available at the time of the recalculation. The projections may be adjusted if there are changes in core design or if additional surveillance capsule results show the need for an adjustment. The projected ART for the period of extended operation gives confidence that future P-T curves will provide adequate operating margin. License amendment requests to revise the P-T limits will be submitted to the NRC for approval, when necessary to comply with 10 CFR 50 Appendix G, as part of the Reactor Vessel Surveillance Program.
Therefore, the Energy Northwest P/T limit curves proposed in this License Amendment Request (LAR) are based on analyses projected to the end of the period of extended operation (PEO) as required by 10 CFR 54.21(c)(1)(ii).
When Enclosure 7 is removed from this letter, the letter and remaining Enclosures are NON-PROPRIETARY

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Proprietary - Withhold under 10 CFR 2.390. Enclosure 7 contains PROPRIETARY information.
GO2-21-012 Page 2 of 3 The proposed change has been evaluated in accordance with 10 CFR 50.91(a)(1) using criteria in 10 CFR 50.92(c) and it has been determined that this change involves no significant hazards considerations. The bases for these determinations are included in Enclosure 1 of this submittal.
The proposed TS markup pages are included as Enclosure 2 and clean pages of the proposed TS changes are included as Enclosure 3 of this submittal. Markups of the proposed TS Bases are included for information only as Enclosure 4 of this submittal.
Enclosure 5 to this amendment request contains the non-proprietary version of the GE Hitachi Nuclear Energy Report NEDO-33929, "Energy Northwest/Columbia Generating Station Pressure and Temperature Limits Report (PTLR) up to 54 Effective Full-Power Years," Revision 0. Enclosure 7 contains the proprietary version of GE Hitachi Nuclear Energy Report NEDO-33929. GE Hitachi and the Electric Power Research Institute (EPRI) consider certain information contained in Enclosure 7 to be proprietary and, therefore, it is requested that it be withheld from public disclosure in accordance with 10 CFR 2.390. Enclosure 6 contains the associated affidavits for the request to be withheld from public disclosure. When Enclosure 7 is removed from this letter, the letter and remaining Enclosures are non-proprietary.
This letter and its enclosures contain no regulatory commitments.
The proposed P/T limit curves are expected to be approved and implemented prior to entering PEO and before the current P/T limit curves expire. Therefore, Energy Northwest requests approval of the proposed amendment by October 1, 2023. Energy Northwest also requests a 60-day implementation period upon approval of this request.
There are no new commitments associated with this submittal. The PEO begins December 21, 2023.
This submittal does not address License Renewal (LR) Commitments No. 69 or No. 70.
LR Commitment No. 69 of Table A-1 of Reference 1 requires re-evaluation of the flaws near the reactor pressure vessel (RPV) beltline welds BG and BM for the PEO. LR Commitment No. 70 of Table A-1 of Reference 1 requires a 54-EFPY equivalent margin analysis for the embrittlement (upper shelf energy) of the reactor vessel N12 (pre-instrumentation) nozzle forgings which is to be completed and submitted no later than two years prior to entering the PEO or December 20, 2021. These two commitments will be addresses under a separate submittal.
In accordance with 10 CFR 50.91, Energy Northwest is notifying the State of Washington of this amendment request by transmitting a copy of this letter and enclosures to the designated State Official.
When Enclosure 7 is removed from this letter, the letter and remaining Enclosures are NON-PROPRIETARY

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Proprietary - Withhold under 10 CFR 2.390. Enclosure 7 contains PROPRIETARY information.
GO2-21-012 Page 3 of 3 If there are any questions or if additional information is needed, please contact Mr. R. M. Garcia, Licensing Supervisor, at (509) 377-8463.
I declare under penalty of perjury that the foregoing is true and correct.
                                #
Executed this ______                # "
day of ___________, 2021.
Respectfully, J. Kent Dittmer Vice President, Engineering

==Enclosures:==
As stated cc: NRC RIV Regional Administrator NRC NRR Project Manager NRC Senior Resident Inspector CD Sonoda - BPA EFSECutc.wa.gov - EFSEC E Fordham - WDOH R Brice - WDOH L Albin - WDOH When Enclosure 7 is removed from this letter, the letter and remaining Enclosures are NON-PROPRIETARY

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GO2-21-016 Enclosure 1 Page 1 of 8 EVALUATION OF PROPOSED TECHNICAL SPECIFICATION CHANGE 1.0        

==SUMMARY==
DESCRIPTION This evaluation supports a License Amendment Request (LAR) to Columbia Generating Station (Columbia) Technical Specification (TS) Limiting Condition for Operation (LCO) 3.4.11, "RCS Pressure and Temperature (P/T) Limits". This proposed amendment is in response to NUREG-2123 Table A-1 Item 70 (Reference 1) and will replace the P/T curves for Inservice Leak and Hydrostatic Testing, Non-Nuclear Heating and Cooldown, and Nuclear Heating and Cooldown currently illustrated as TS Figures 3.4.11-1, 3.4.11-2, and 3.4.11-3, respectively. The P/T limit curves proposed in this LAR were based on analyses projected to the end of the period of extended operation (PEO) as required by 10 CFR 54.21(c)(1)(ii).
Implementation of this LAR will result in no physical modification to the plant. This proposed change has no adverse effect on the plant or plant safety.
2.0        DETAILED DESCRIPTION 2.1        System Design and Operation Each P/T limit curve defines an acceptable region for normal plant operation. The usual use of the curves is operational guidance during heatup or cooldown maneuvering, when pressure and temperature indications are monitored and compared to the applicable curve to determine that operation is within the allowable operating region.
The curves also provide guidance during certain other operations such as inservice leak and hydrostatic testing.
The LCO establishes operating limits that provide a margin to brittle failure of the reactor pressure vessel (RPV) and piping of the reactor coolant pressure boundary (RCPB). The vessel is the component most subject to brittle failure. Therefore, the LCO limits apply mainly to the vessel. 10 CFR 50, Appendix G (Reference 2), requires the establishment of P/T limits for material fracture toughness requirements of the RCPB materials. 10 CFR 50, Appendix G on fracture toughness requirements requires an adequate margin to brittle failure during normal operation, anticipated operational occurrences, and system hydrostatic tests. It mandates the use of the American Society of Mechanical Engineers (ASME) Code, Section III, Appendix G (Reference 3). Due to the effects of neutron irradiation embrittlement accumulated by the reactor, the P/T limit curves contained in plant TSs are updated periodically to ensure that the limit curves are always valid beyond the effective full-power years (EFPY) that the plant has accumulated.

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GO2-21-016 Enclosure 1 Page 2 of 8 2.2        Current Technical Specifications Requirements LCO 3.4.11 requires the reactor coolant system (RCS) pressure, temperature, heatup and cooldown rates, and the recirculation loop temperature requirements be maintained within limits and provides the Conditions, Required Actions, and Completion Times that must be met in order to maintain the required safety margin. The Conditions, Required Actions, and Completion Times will remain unchanged by this proposed amendment.
The proposed change consists of new TS figure(s) to provide updated limits for operation.
2.3        Reason for the Proposed Change The Columbia Final Safety Analysis Report (FSAR) Section 4.3.2.8, Table 4.3-1 provides fluence values at 51.6 EFPY of reactor operation. As stated in Reference 4, GE Hitachi incorporated the fluence analyses into a personal computer worksheet to allow production of fluence estimates at other EFPY. For purposes of license renewal, the reported fluence was linearly extrapolated from 33.1 EFPY (the original 40-year end of life estimate) through 51.6 EFPY to 54 EFPY.
In response to an NRC request for information (RAI), Energy Northwest provided the information in Reference 4 which contained RPV material embrittlement analysis results based on a neutron fluence out to 54 EFPY using actual reactor core power histories to-date and conservative estimates of future core designs extending operation to 60 years.
However, Reference 4 did not include new P/T curves to update TS 3.4.11. The current TS P/T curves are limited to 33.1 EFPY requiring the current P/T curves to be revised and replaced to allow operation to the end of the PEO.
2.4        Description of the Proposed Change The proposed license amendment will provide updated P/T curves. No other changes to the TS are required.

==3.0        TECHNICAL EVALUATION==

10 CFR 50 Appendix G, Fracture Toughness Requirements, requires the establishment of P/T limits for reactor coolant pressure boundary materials and requires an adequate margin to brittle failure be maintained during normal operation, anticipated operational occurrences, and system hydrostatic tests. The P/T limits are not derived from Design Basis Accident analyses. The P/T limits are acceptance limits in themselves, because operation in accordance with these limitations precludes operation in an unanalyzed condition.
Composite P/T curves were generated for each of the Pressure Test, Core Not Critical and Core Critical conditions at 54 EFPY. The composite curves were generated by enveloping the most restrictive P/T limits from the separate bottom head, beltline, upper

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GO2-21-016 Enclosure 1 Page 3 of 8 vessel and closure assembly P/T limits. Separate P/T curves were developed for the upper vessel, beltline, and bottom head for the Pressure Test and Core Not Critical conditions.
The P/T curves are established to the requirements of 10 CFR 50, Appendix G to assure that brittle fracture of the reactor vessel is prevented. Part of the analysis involved in developing the P/T curves is to account for irradiation embrittlement effects in the core region, or beltline. The method used to account for irradiation embrittlement is described in Regulatory Guide (RG) 1.90, "Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence." Rev. 2 (Reference 11). The key parameters which characterize a material's fracture toughness are the reference temperature of nil-ductility transition (RTNDT) and the Upper Shelf Energy (USE). These parameters are defined in 10 CFR 50, Appendix G (Reference 2), and in Appendix G of the ASME Boiler and Pressure Vessel Code, Section XI (Reference 3). These documents also contain the requirements used to establish the P/T operating limits to avoid brittle fracture. The method used to account for irradiation embrittlement is described in Regulatory Guide 1.99, Radiation Embrittlement of Reactor Vessel Materials, Revision 2.
The fluence calculations for the 54 EFPY P/T curve evaluation were not benchmarked against any dosimetry. GE Hitachi Licensing Topical Report, NEDC-32983P-A (Reference 7), was used in calculating the fluence and is compliant with RG 1.190 (Reference 11)." Reference 7 has been approved by the NRC in Reference 8.
The P/T curves in this submittal represent 54 EFPY, where 54 EFPY represents the end of the 60-year license. The 1998 Edition of the ASME Boiler and Pressure Vessel Code including 2000 Addenda was used in this evaluation in accordance with the GE Hitachi Licensing Topical Report NEDC-33178P-A (Reference 9). The values used to determine the initial RTNDT were obtained from the Certified Material Test Reports (CMTRs) for Columbia. The initial RTNDT for all materials remain unchanged from values previously reported for Columbia in Reference 5, except for the Water Level Instrumentation nozzles (N12, N13, N14) with Heat 219972 Lot 1. The initial RTNDT of these water level instrument nozzles were decreased to -20&deg;F, following the discussion provided to GEH in Reference 6.
The GEH Pressure-Temperature Limits Report for Columbia, provided as Enclosure 5 (non-proprietary) and Enclosure 7 (proprietary), demonstrates the technical methods and contains the data for producing the composite P/T limit curves, which are proposed to be used to update the TS. The proposed P/T limit curves have been developed utilizing the methodology of Regulatory Guide 1.190 and ASME Section XI. In addition, the analysis conforms to the requirements of 10 CFR 50, Appendix G, which ensures that the most limiting material is considered in the development of the P/T limit curves.
The results confirm that operation for 60 years (54 EFPY) has no direct impact on Columbia's operation with respect to the RPV fracture toughness as summarized below.

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GO2-21-016 Enclosure 1 Page 4 of 8 x     The 60-year Adjusted Reference Temperature (ART) of the limiting beltline material for the extended license remains below 200&deg;F [Nil-Ductility Transition (RTNDT) Limit].
x     The USE values for the reactor vessel beltline materials remain within the limits of 10 CFR 50 Appendix G for 60 years (54 EFPY).
x     The USE values for the N6 LPCI and N12 WLI nozzles remain within the limits of 10 CFR 50 Appendix G for 60 years (54 EFPY).
x     Equivalent margin analysis (EMA) were performed and bound all other plate and weld beltline materials.
3.1        Impact on Submittals under Review by NRC The NRC is presently reviewing the following Energy Northwests licensing requests:
x     LAR to adopt TSTF-546 Revise APRM Channel Adjustment SR. Submitted
under GO2-21-042, NRC acceptance {{letter dated|date=June 11, 2021|text=letter dated June 11, 2021}} x     LAR to revise License Renewal Condition 2.C(35). Submitted under GO2-21-012, NRC acceptance {{letter dated|date=May 14, 2021|text=letter dated May 14, 2021}} x     LAR to Adopt TSTF-439"Eliminate Second Completion Times Limiting Time from Discovery of Failure toMeet an LCO" Submitted under GO2-20-108, NRC acceptance letter dated December 22, 2020 x     On-Site Cooling System Sediment Disposal submitted under GO2-20-104, NRC
acceptance {{letter dated|date=February 8, 2021|text=letter dated February 8, 2021}} These requests are unaffected by this submittal.

==4.0        REGULATORY EVALUATION==

The Columbia FSAR Chapter 3 provides detailed discussion of Columbias compliance with the applicable regulatory requirements and guidance. The proposed TS amendment:
x     does not result in any change in the qualifications of any component; and x     does not result in the reclassification of any components status in the areas of shared, safety-related, independent, redundant, and physically or electrically separated.
4.1        Applicable Regulatory Requirements and Conformance 4.1.1 10 CFR 50, Appendix A General Design Criteria (GDC)
GDC 14, "Reactor Coolant Pressure Boundary," requires in part that "the reactor coolant pressure boundary shall be designed, fabricated, erected, and tested so as to have an extremely low probability of abnormal leakage, of rapidly propagating failure, and of gross rupture."

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GO2-21-016 Enclosure 1 Page 5 of 8 GDC 30, "Quality of Reactor Coolant Pressure Boundary," requires, in part, that "components that are part of the reactor coolant pressure boundary shall be designed, fabricated, erected, and tested to the highest practical quality standards."
GDC 31, "Fracture Prevention of Reactor Coolant Pressure Boundary," requires, in part, that "the reactor coolant pressure boundary shall be designed with sufficient margin to assure that when stressed under operating, maintenance, testing, and postulated accident conditions (1) the boundary behaves in a nonbrittle manner and (2) the probability of rapidly propagating fracture is minimized." "The design shall reflect consideration of service temperatures and other conditions of the boundary material under operating, maintenance, testing, and postulated accident conditions and the uncertainties in determining (1) material properties, (2) the effects of irradiation on material properties, (3) residual, steady state and transient stresses, and (4) size of flaws."
Regulatory Guide (RG) 1.190 (Reference 11) describes methods and assumptions acceptable to the NRC staff for determining the pressure vessel neutron fluence. These methods are directly applicable to the determination of RTNDT and RTPTS. This RG is intended to ensure the accuracy and reliability of the fluence determination required by General Design Criteria (GDC) 14, 30 and 31 of 10 CFR 50 Appendix A. The NRC approved the RPV fluence calculation methodology used for this proposed license amendment request on November 17, 2005 (Reference 8).
4.1.2 10 CFR 50, Appendix G - Fracture Toughness Requirements Appendix G of 10 CFR 50 specifies fracture toughness requirements for ferritic materials of pressure-retaining components of the reactor coolant pressure boundary of light water nuclear power reactors to provide adequate margins of safety during any condition of normal operation, including anticipated operational occurrences and system hydrostatic tests, to which the pressure boundary may be subjected over its service lifetime. Columbias revised P/T curves were developed in compliance with this guidance.
4.1.3 Conformance to Regulatory Requirements The proposed change has been evaluated to determine whether application of regulations and requirements continue to be met. As shown in Enclosure 7, the proposed P/T limit curves have been developed utilizing the methodology of Regulatory Guide 1.190. This guide is intended to ensure the accuracy and reliability of the fluence determination required by GDCs 14, 30, and 31 of Appendix A.

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GO2-21-016 Enclosure 1 Page 6 of 8 5.0        PRECEDENT Precedent Examples Plant                          Submittal Date    Approval Date Browns Ferry Nuclear Plant, Unit 3                   January 27, 2015 January 7, 2016 Beach Bottom Units 2 and 3                           April 27, 2012   April 1 2013 River Bend, Unit 1                                   April 2, 2018    January 17, 2019 The revised Columbia P/T curves as well as the P/T curves identified in the above submittals were developed in accordance with the following GEH Licensing Topical Reports.
x    Reference 7: Topical Report NEDC-32983P-A, Revision 2 which provides a methodology intended for the determination of the fast neutron fluence accumulated by the pressure vessel and internal components of U.S. boiling-water reactor (BWR) plants.
x    Reference 9: Topical Report NEDC-33178P-A, Revision 1, "GE Hitachi Nuclear Energy Methodology for Development of Reactor Pressure Vessel Pressure-Temperature Curves" (ADAMS Accession No. ML092370487) which provides generic upper vessel and bottom head P/T limit curves along with beltline curves that are shifted by the plant-specific adjusted reference temperature, as described in RG 1.99, Revision 2, as well as guidance on the application of the 1998 edition, 2000 addenda of the ASME Boiler and Pressure Vessel (BPV) Code, Section XI, Appendix G and 10 CFR Part 50, Appendix G. Approved in Reference 10.
The precedent examples cited used the same approved methodology as the Columbia analysis and therefore, support the approval of this submittal.
6.0        SIGNIFICANT HAZARDS CONSIDERATION This license amendment request will revise the Columbia Generating Station (Columbia) Technical Specification (TS) 3.4.11 Reactor Coolant System (RCS)
Pressure and Temperature (P/T) Limits for operation and provide revised P/T curves out to 54 effective full-power year (EFPY). Energy Northwest has evaluated whether a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below.
: 1)      Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.

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GO2-21-016 Enclosure 1 Page 7 of 8 The P/T limits are not derived from design basis accident analyses. The P/T limits are acceptance limits in themselves. Operation in accordance with these limitations precludes operation in an unanalyzed condition. Therefore, there is no significant increase in the probability or consequences of an accident previously evaluated.
: 2)      Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously analyzed?
Response: No.
The P/T limits are not derived from design basis accident analyses. The P/T limits provide an operating window such that operation in accordance with these limitations precludes operation in an unanalyzed condition. The new P/T curves do not change how any structure, system, or component operates. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3)      Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
The P/T limits are not derived from design basis accident analyses. As such, operation in accordance with these limitations precludes operation in an unanalyzed condition which preserves the existing safety margins. Therefore, the proposed change does not involve a significant reduction in the margin of safety.
Based on the above, Energy Northwest concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

==7.0        CONCLUSION==
S Based on the considerations discussed above: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the applicable regulations as identified herein, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

==8.0        ENVIRONMENTAL CONSIDERATION==

Energy Northwest has determined that the proposed amendment would change requirements with respect to installation or use of a facility component located within Columbia's restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. Energy Northwest has evaluated the proposed change and

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GO2-21-016 Enclosure 1 Page 8 of 8 has determined that the change does not involve, (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criteria for categorical exclusion in accordance with 10 CFR 51.22(c)(9).
Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

==9.0        REFERENCES==
: 1. NUREG-2123 "Safety Evaluation Report Related to the License Renewal of Columbia Generating Station", published May 2012
: 2. 10 CFR 50, Appendix G - Fracture Toughness Requirements
: 3. ASME, Boiler and Pressure Vessel Code, Section III, Appendix G
: 4. GO2-04-107 from D. K. Atkinson (Energy Northwest) to U.S. NRC, "License Amendment Request to Revise Technical Specification 3.4.11 Reactor Coolant System (RCS) Pressure Temperature (P/T) Limits," dated June 9, 2004
: 5. GE Nuclear Energy, "Washington Public Power Supply System WNP-2 RPV Surveillance Materials Testing and Analysis", Document No. GE-NE-B1301809-01, dated March 1997
: 6. Letter 2020-06-01 from J. A. Brownell (Energy Northwest) to K. Baucom (GEH),
                         "Design Input Request CGS Pressure - Temperature Curves (005N1693 Revision 1)", Letter number 2020-06-01, dated June 22, 2020
: 7. GE-Hitachi Nuclear Energy Topical Report NEDC-32983P-A, Revision 2, "General Electric Methodology for Reactor Pressure Vessel Fast Neutron Flux Evaluations," dated January 2006 (ADAMS Accession No. ML072480121)
: 8. Letter from H. N. Berkow, (NRC) to G. B. Stramback (GE), "Final Safety Evaluation Regarding Removal of Methodology Limitations for NEDC-32983P-A, "General Electric Methodology for Reactor Pressure Vessel Fast Neutron Flux Evaluation", dated November 17, 2005
: 9. GEH Nuclear Energy, NEDC-33178P-A, Revision 1, "GE Hitachi Nuclear Energy Methodology for Development of Reactor Pressure Vessel Pressure-Temperature Curves", dated June 2009
: 10. Letter from T. B. Blount (NRC) to D. Coleman (BWROG Chair), "Final Safety Evaluation for Boiling Water Reactors Owners' Group Licensing Topical Report NEDC-33178P, General Electric Methodology for Development of Reactor Pressure Vessel Pressure-Temperature Curves", dated April 27, 2009.
: 11. Regulatory Guide 1.190 "Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence," dated March 2001

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GO2-21-016 Enclosure 2 Proposed Columbia Technical Specification Changes (Mark-Up)

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RCS P/T Limits 3.4.11
                                                                  +-
1400 RE E,
1300                                                                                         ESSEL, t
                                                      --+----
OM HEAD 1200 EL TUNE CURVES 1100                                             -----+- -  -+---   ..., ADJUSTED AS SHOWN:
ci                                                                                EFPY SHIFT (&deg;F) i "iii                                                                                  33.1     35 Q.
1000 w                                                                             HEATUP/COOLD OWN
:I:
0.. 900                                                                      RA TE OF COOLANT
                               ~
_.                                                                                   .5. 20&deg;F/HR w                       800 PSIG
                               ~     800                 68&deg;F
                               ~
a::
g     700
                               ~
w a::   600 ACCEPTABLE AREA OF 31::
                              ....                                                                        OPERATION TO THE i
::i    500 RIGHT OF THIS CURVE w
a::
::::)
                              ~      400 w
a::
Q..
300
                                                                                                              --UPPER VESSEL AND BELTLINE LIMITS
                                                                                                              ******BOTTOMHEAD CURVE 0
0        25       50     75     100    125     150   175    200 MINIMUM REACTOR VESSEL METAL TEMPERATURE
(*F)
Figure 3.4.11-1 (page 1 of 1)
Inservice Leak and Hydrostatic Testing Curve Columbia Generating Station                              3.4.11-5          Amendment No. 169,193 225

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RCS P/T Limits 3.4.11 1400                                                                                                         RE 28&deg;F FO                 E, ESSEL, J-1300 OM HEAD 1200 A **-
L TLINE CURVES ci 1100              ~1 -r-'-----+------+
1035 PSIG       I             .--'10_3_5_P-SI.._G~
JUSTED AS SHOWN:
EFPY SHIFT (&deg;F) 33.1      35 i
                   'iii                         109.3&deg;F       I                    148.1&deg;F a.
1000 e
w                                                                                        HEATUP/COOLDOW N
:c 900 RATE OF COOLANT
                                                                                                                     ~ 100&deg;F/HR
                   ..J w
                   ~        800 g
                   ~
700
                   ~
w IX       600                                                                           ACCEPTABLE AREA OF
                    ~                                                                                     OPERATION TO THE I-                                                                                    RIGHT OF THIS CURVE
                    ~       500 w
0:::
::)
                    ~       400 w
0:::              BOTTOM
: a.                 HEAD 300         68&deg;F
                                                                                                             -UPPER VESSEL 200                                                                                          AND BEL TLINE LIMITS 100                                          80&deg;F
                                                                                                             * * * * *
* BOTTOM HEAD CURVE 0
50      75    100   125    150     175       200     225 250 MINIMUM REACTOR VESSEL METAL TEMPERATURE
(*F)
Figure 3.4.11-2 (page 1 of 1)
Non-Nuclear Heating and Cooldown Curve Columbia Generating Station                                3.4.11-6                    Amendment No. 169,193 225

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RCS P/T Limits 3.4.11 1400 INITIAL RTn A
1300                                                                      28&deg;F FO      EL TUNE, 34 &deg;F. OR UPPER ESSEL, 1200                                                                                AND OR BOTTOM HEAD 1100 1035 PSIG ci                                                           1aa.1&deg;F
                        'iii
                        !i0.
1000 BEL TLINE CURVE ADJUSTED AS SHOWN:
w                                                                                  EFPY      SHIFT (&deg;F)
:::c                                                                                 33.1          35 Q..      900 0
I-
                         ...I w
en      800                                                                      HEATUP/CO OLDOWN en
                         !s!                                                                               RATE OF COOLANT 0::                                                                                    ~ 100&deg;F/HR 0       700 I-(.)
c(
w 0:::    600
                         ~
I-
                          ~
::i    500                                                                   ACCEPTABL E AREA OF w                                                                            OPERATION TO THE 0:::
::,                                                                          RIGHT OF THIS CURVE en      400 en w
0:::
Q..
300 200
                                                                                                         -BELTLIN EAND NON-BEL TUNE 100                                      . ----+-  --+-   -+---+             LIMITS 25         75   100 125 150 175 200 225 250 275 300 MINIMUM REACTOR VESSEL METAL TEMPERATU RE
(*F)
Figure 3.4.11-3 (page 1 of 1)
Nuclear Heating and Cooldown Curve Columbia Generating Station                            3.4.11-7                Amendment No. 169,193 225

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GO2-21-016 Enclosure 3 Proposed Columbia Technical Specification Changes (Re-Typed)

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5&637/LPLWV
                                                                                                                                                                                                                                                               
I 1400                                                                                                                I I
I I
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GO2-21-016 Enclosure 4 Technical Specification Bases Markup Pages (Information Only)

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RCS P/T Limits B 3.4.11 BASES SURVEILLANCE REQUIREMENTS (continued)
SR 3.4.11.9 is modified by a Note that requires the Surveillance to be initiated 12 hours after RCS temperature d 100&deg;F in MODE 4. The Notes contained in these SRs are necessary to specify when the reactor vessel flange and head flange temperatures are required to be verified to be within the specified limits.
REFERENCES              1.       10 CFR 50, Appendix G.
: 2.       ASME, Boiler and Pressure Vessel Code, Section III, Appendix G.
: 3.       ASTM E 185-82, July 1982.
: 4.       10 CFR 50, Appendix H.
: 5.       Regulatory Guide 1.99, Revision 2, May 1988.
: 6.       ASME, Boiler and Pressure Vessel Code, Section XI, Appendix E.
: 7.       Letter from D.G. Eisenhut (NRC) to D.W. Mazur (WPPSS), "Issuance of Facility Operating License NPF WPPSS Nuclear Project No. 2," dated December 20, 1983.
: 8.       Letter from B.J. Benney (NRC) to J.V. Parrish (EN), "Columbia Generating Station - Issuance of Amendment Re: Reactor Coolant System (RCS) Pressure and Temperature Limits (TAC No. MC3591)," Issuance of Amendment No. 193, dated May 12, 2005.
Replace with NRC SE
: 9.       10 CFR 50.36(c)(2)(ii).
information when approved.
: 10.       FSAR, Section 15.4.4.
: 11.       FSAR, Section 5.3.1.6.
Columbia Generating Station                   B 3.4.11-9                                  Revision 73

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GO2-21-016 Enclosure 5 GEH Report NEDO-33929, "Energy Northwest/Columbia Generating Station Pressure and Temperature Limits Report (PTLR) up to 54 Effective Full-Power Years," Revision 0 (Non-Proprietary)

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               -            HITACHI                                        GE Hitachi Nuclear Energy NEDO-33929 Revision 0 November 2020 Non - Proprietary Information Energy Northwest/Columbia Generating Station Pressure and Temperature Limits Report (PTLR) up to 54 Effective Full-Power Years Copyright 2020 GE-Hitachi Nuclear Energy Americas LLC All Rights Reserved

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NEDO-33929 Revision 0 Non - Proprietary Information INFORMATION NOTICE This is a non-proprietary version of the document NEDC-33929P, Revision 0, which has the proprietary information removed. Portions of the document that have been removed are indicated by open and closed brackets as shown here ((              )).
IMPORTANT NOTICE REGARDING CONTENTS OF THIS REPORT Please Read Carefully The design, engineering, and other information contained in this document are furnished for the purpose of supporting the Columbia Generating Station project in proceedings before the United States (US) Nuclear Regulatory Commission (NRC). The only undertakings of GEH with respect to the information in this document are contained in the contract between Energy Northwest and GEH, and nothing contained in this document shall be construed as changing the contract. The use of this information by anyone other than Energy Northwest, or for any purpose other than that for which it is furnished by GEH is not authorized; and with respect to any unauthorized use, GEH 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 privately owned rights.
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NEDO-33929 Revision 0 Non - Proprietary Information Revision Summary Revision                                               Description 0         Initial Issue
                                                                      
                                                                                   
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NEDO-33929 Revision 0 Non - Proprietary Information Table of Contents Section                                                                                                                                       Page ACRONYMS .............................................................................................................................. vi 1.0                Purpose ...................................................................................................................1
2.0                Applicability ...........................................................................................................1
3.0                Methodology ..........................................................................................................1
4.0                Operating Limits ..................................................................................................10
5.0                Discussion ............................................................................................................12
6.0                References ............................................................................................................13
Appendix A         Reactor Vessel Material Surveillance Program ...................................................24
Appendix B         CGS Reactor Pressure Vessel P-T Curve Supporting Plant-Specific Information
                                 ..............................................................................................................................25
Appendix C         CGS Reactor Pressure Vessel P-T Curve Checklist.............................................37
Appendix D          Sample P-T Curve Calculations ..........................................................................42
List of Tables Table 1            CGS Tabulation of Curves - 54 EFPY ............................................................... 17
Table B-1          CGS Initial RTNDT Values for RPV Plate and Flange Materials......................... 27
Table B-2          CGS Initial RTNDT Values for RPV Nozzle Materials ........................................ 28
Table B-3          CGS Initial RTNDT Values for RPV Weld Materials........................................... 29
Table B-4          CGS Initial RTNDT Values for RPV Appurtenance and Bolting Materials ......... 30
Table B-5          CGS Adjusted Reference Temperatures for up to 54 EFPY ............................... 31
Table B-6          CGS RPV Beltline P-T Curve Input Values for 54 EFPY .................................. 35
Table B-7          CGS Definition of RPV Beltline Region (1)....................................................... 36
Table C-1          CGS Checklist ..................................................................................................... 38
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NEDO-33929 Revision 0 Non - Proprietary Information List of Figures Figure 1 - CGS Composite Curve A (Pressure Test P-T Curves) Effective for up to 54 EFPY .. 14
Figure 2 - CGS Composite Curve B (Core Not Critical P-T Curves) Effective for up to 54 EFPY
             ....................................................................................................................................................... 15
Figure 3 - CGS Limiting Curve C (Core Critical P-T Curve) Effective for up to 54 EFPY ....... 16
Figure B Schematic of the CGS RPV Showing Arrangement of Vessel Plates and Welds ... 26
             
             
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NEDO-33929 Revision 0 Non - Proprietary Information ACRONYMS Acronym                             Definition
               %Cu                                 Weight percent Copper
               %Ni                                 Weight percent Nickel 1/4T                                1/4 depth into the vessel wall from the inside diameter 3/4T                                3/4 depth into the vessel wall from the inside diameter ART                                 Adjusted Reference Temperature ASME                               American Society of Mechanical Engineers BAF                                 Bottom of Active Fuel BWR                                 Boiling Water Reactor BWR/6                               BWR Product Line 6 BWRVIP                              BWR Vessel and Internals Project CBI                                 Chicago Bridge & Iron CF                                  Chemistry Factor CGS                                 Columbia Generating Station CMTR                               Certified Material Test Report CRD                                 Control Rod Drive Curve A                             P-T Curves Applicable to Hydrotest (or Pressure Test) Operation Curve B                             P-T Curves Applicable to Core Not Critical Operation Curve C                             P-T Curves Applicable to Core Critical Operation
               &deg;F                                  Degree Fahrenheit T                                   Temperature vi
                                                                   

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NEDO-33929 Revision 0 Non - Proprietary Information Acronym                             Definition EFPY                                Effective Full Power Years EPRI                                Electric Power Research Institute FW                                  Feedwater GE                                 General Electric Company GEH                                 GE Hitachi Nuclear Energy ID                                  Inside Diameter ISP                                 Integrated Surveillance Program KI                                  Stress Intensity Factor KIr                                 Allowable Fracture Toughness LPCI                                Low Pressure Coolant Injection LTR                                 Licensing Topical Report N6                                  Low Pressure Coolant Injection Nozzle N12                                 Water Level Instrumentation Nozzle N13                                 Water Level Instrumentation Nozzle N14                                 Water Level Instrumentation Nozzle n/cm2                               neutrons per square centimeter (measure of fluence)
NDT                                 Nil-ductility Transition NRC (or USNRC)                      United States Nuclear Regulatory Commission P/T                                 Pressure/Temperature P-T                                 Pressure-Temperature PTLR                                Pressure and Temperature Limits Report vii
                                                                    

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NEDO-33929 Revision 0 Non - Proprietary Information Acronym                             Definition PVP                                 Pressure Vessels and Piping PVRC                                Pressure Vessel Research Council RCPB                                Reactor Coolant Pressure Boundary RCS                                 Reactor Coolant System RG 1.190                            Regulatory Guide 1.190 RG 1.99                            Regulatory Guide 1.99, Revision 2 RPV                                Reactor Pressure Vessel RTNDT                               Reference Temperature of Nil Ductility Transition RVID                                Reactor Vessel Integrity Database (by NRC) i                                  Standard Deviation on Initial RTNDT Standard Deviation on RTNDT Shell #                             RPV Shell Ring Number (see Figure B-1)
SSP                                Supplemental Surveillance Program T                                   Temperature TAF                                Top of Active Fuel TS                                  Technical Specification UFSAR                              Updated Final Safety Analysis Report US                                 United States WLI                                 Water Level Instrumentation WRC                                 Welding Research Council viii
                                                                   

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NEDO-33929 Revision 0 Non - Proprietary Information 1.0        Purpose The purpose of the Columbia Generating Station (CGS) Pressure and Temperature Limits Report (PTLR) is to present operating limits relating to:
: 1. Reactor Coolant System (RCS) Pressure versus Temperature limits during Heatup, Cooldown and Hydrostatic/Class 1 Leak Testing;
: 2. RCS Heatup and Cooldown rates;
: 3. Reactor Pressure Vessel (RPV) to RCS coolant delta temperature ('T) requirements during Recirculation Pump startups;
: 4. RPV bottom head coolant temperature to RPV coolant temperature 'T requirements during Recirculation Pump startups;
: 5. RPV head flange bolt-up temperature limits.
This report has been prepared in accordance with the requirements of Technical Specification (TS) 3.4.11, Reactor Coolant System (RCS) Pressure and Temperature Limits.
2.0        Applicability This report is applicable to the CGS RPV for up to 54 Effective Full Power Years (EFPY).
The following TS is affected by the information contained in this report:
TS 3.4.11         RCS Pressure and Temperature (P/T) Limits 3.0        Methodology The limits in this report were derived from the NRC-approved methods listed in TS 3.4.11, using the specific revisions listed below:
: 1. The neutron fluence was calculated per Licensing Topical Report, General Electric Methodology for Reactor Pressure Vessel Fast Neutron Flux Evaluations, NEDC-32983P-A, Revision 2, January 2006, approved in Reference 1.
: 2. The pressure and temperature limits were calculated per GE Hitachi Nuclear Energy Methodology for Development of Reactor Pressure Vessel Pressure-Temperature Curves, NEDC-33178P-A, Revision 1, June 2009, approved in Reference 2.
This PTLR incorporates the following items and changes:
x      Initial issuance of the PTLR for a 60-year license (54 EFPY).
x      Application of GEH Topical Report for CGS Pressure-Temperature (P-T) Curves x      Incorporation of new fluence results for 54 EFPY 1
                                                                    

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NEDO-33929 Revision 0 Non - Proprietary Information x       Application of the Integrated Surveillance Program (ISP) testing and analysis results that are applicable to CGS P-T curves 3.1       Chemistry The vessel beltline copper and nickel values were obtained from CGS plant-specific vessel purchase order records, Certified Material Test Reports (CMTR), or are values previously approved by the NRC, and remain unchanged from previous submittals. Surveillance materials are evaluated using the adjusted chemistry factors obtained from BWRVIP-135 (Reference 3). Best estimate chemistries for other beltline materials were also considered from Reference 3.
The chemistry factors (CF) for all materials are calculated based upon the requirements of Regulatory Guide 1.99, Revision 2 (RG 1.99, Reference 10).
3.2       Fluence The peak RPV inside diameter (ID) fluence at the inner surface of the RPV cladding within the vessel used in the P-T curve evaluation for CGS at 54 EFPY is 1.28e18 n/cm2. This value was calculated using methods that comply with the guidelines of Regulatory Guide 1.190 (RG 1.190) (Reference 11) as discussed in Reference 1. This fluence applies to the lower-intermediate shell (Shell #2) plates. The fluence at the lower-intermediate shell longitudinal axial (vertical) welds is 7.73e17 n/cm2. The fluence at the elevation of the girth weld between the lower shell (Shell #1) plate and lower-intermediate shell (Shell #2) is 4.20e17 n/cm2. This fluence also applies to the lower shell plates. The fluence at the lower shell longitudinal axial welds is 2.97e17 n/cm2. The peak fluence at the bottom of N12 WLI nozzle is 3.72e17 n/cm2. The peak fluence at the bottom of N6 LPCI nozzle is 5.81e17 n/cm2.
3.3       Initial Reference Temperature of Nil Ductility Transition (RTNDT)
The method for determining the Initial Reference Temperature of Nil-Ductility Transition (RTNDT) for all vessel materials is that defined in Section 4.1.2 of Reference 2. Initial RTNDT values for all vessel materials considered in developing the P-T curves are presented in tables in Appendix B.
The N6 LPCI and N12 WLI nozzles are evaluated for ART. As the N12 WLI weld material is Inconel, for which fracture toughness evaluations are not required, only the N12 WLI forging material is evaluated. The N6 LPCI nozzle weld and forging material are both evaluated for fracture toughness.
The update to the initial RTNDT for N12 WLI forging material (Heat #219972 Lot 1) which was already submitted to NRC is summarized as follows. The Chicago Bridge & Iron (CBI) purchase specification for this material demonstrates a required drop weight testing at an impact temperature of ((` ` ` &deg;` ` ` ` ` )), consistent with the N12 Certified Material Test Reports (CMTR). Sufficient information is available to determine that the impact temperature of 2
                                                                         

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NEDO-33929 Revision 0 Non - Proprietary Information
((` ` ` &deg;` ` ` ` ` )) was met, resulting in a drop weight NDT temperature of ((` ` ` &deg;` ` ` ` ` ` ` ` ` ` ` ` ` `
                        )). Considering that the acceptance criteria for the impact temperature was met, the drop weight NDT temperature was updated to ((` ` ` &deg;` ` ` ` ` )). This drop weight NDT temperature produces the updated N12 WLI forging material (Heat #219972 Lot 1) initial RTNDT of ((`
                        ` ` &deg;` ` ` ` ` )), as shown in Table B-2. In addition, this methodology applies to the instrumentation nozzles N13 and N14 (Heat #219972 Lot 1) and are updated in Table B-2 to have an initial RTNDT of ((` ` ` &deg;` ` ` ` ` )).
3.4         Adjusted Reference Temperature (ART)
The ART values for 54 EFPY included in Appendix B are developed considering the latest BWRVIP Integrated Surveillance Program (ISP) published surveillance data available that is representative of the applicable materials in the CGS RPV (Reference 3). As the ISP plate material, heat B0673-1, is not identical to the target vessel material, the ISP data is not considered in the development of P-T curves. The ISP weld material, heat 5P6756, is identical to the target vessel material (5P6756). Therefore, the ISP weld data is considered in the development of P-T curves. The CF value for weld is updated with ISP data and used for the determination of ART. This ART is not limiting with respect to the ART.
3.5         Surveillance Program As discussed in Appendix A, CGS participates in the ISP. Two of the surveillance capsules, installed at plant startup, remain in the vessel, while the third capsules holder was found failed in refueling outage R23 (2017) and removed. As CGS is not a host plant, the three (3) surveillance capsules have an ISP status designation of deferred per Reference 4.
BWRVIP-135 (Reference 3) provides the representative surveillance data considered in determining the chemistry and any fitted or adjusted CFs for the beltline materials for CGS.
Excerpt from Reference 3:
Target Vessel Materials and ISP Representative Materials for Columbia Target Vessel Materials                             ISP Representative Materials Weld                           SP6756                                 SP6756 Plate                         C 1272-1                                B0673-1 T. Shift R      ults tor W Id Heat 5P6756 Cu        NI            Flu nee Cap uJe                                                              AT. (*F)
(wt%)     (wt%)    (10&deg; n/cm*, E > 1 MeV)
R       Bend 183&deg;                                      11.6                53.7 SSPF                                            19.364               61.9 0.06      0.93 SSPH                                            15.766               63.7 SSPC                                             2.93                23.6 3
                                                                              

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NEDO-33929 Revision 0 Non - Proprietary Information As seen above, the ISP representative plate, heat B0673-1, is not identical to any CGS vessel beltline plate. Therefore, this ISP data is not used in the development of P-T curves.
For CGS, the ISP representative weld, heat 5P6756, is the identical heat as the CGS lower shell and lower-intermediate circumferential (girth) weld heat (5P6756). This heat was contained in one (1) River Bend and three (3) BWR Supplemental Surveillance Program (SSP) capsules that have been tested and analyzed. It is noted that the maximum scatter in the fitted data falls within the 1-sigma value of 28&deg;F from RG 1.99. BWRVIP-135 also provides best estimate chemistries that are used in the ART evaluation. The best estimate chemistry for ISP weld heat is defined as 0.08% Cu and 0.936% Ni. The CF from RG 1.99 is 82&deg;F (Table CFSurvChem in Equation 1) and the fitted CF is ((116.9&deg;F {E})) (CFFittedData in Equation 1). The CGS limiting vessel chemistry for this material is 0.08% Cu and 0.936% Ni, from the best estimate chemistry for ISP. Using RG 1.99, the CF is 108.0&deg;F (Table CFVesselChem in Equation 1). As the ISP weld material is identical to the vessel target material, the ART table evaluates the ISP weld material using an adjusted CF and is therefore permitted to reduce the margin term as defined in RG 1.99, Position 2.1.
The CF for a weld material that has more than two (2) data points is determined by calculating an adjusted CF in accordance with RG 1.99. The adjusted CF is determined using the following equation:
                         .                                       (1)
For CGS, the adjusted CF = (108&deg;F / 82&deg;F) * ((116.9&deg;F = 153.97&deg;F {E})).
As ((153.97&deg;F {E})) is greater than 108&deg;F, and the surveillance data is credible, the adjusted CF of ((153.97&deg;F {E}))is used in the ART evaluation. This material was considered in determining the limiting ART for the P-T curves.
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NEDO-33929 Revision 0 Non - Proprietary Information Excerpt from Reference 3:
T., Shift Results for Weld Heat 5P6214B Cu           Ni                 Fluence Capsule (wt% )      (wt%)        (10 17 n/cm 2,E > 1 MeV)
AT.,(0 F)
Perry 3&deg;                                                   3.18           -20.5 0.027        0.94 Perry 1n&deg;                                                   10.8            40.4 SSPD                                                     10.317           3.1 SSPE                                                     17.704           4.1 SSPG                                                     19.461          34.0 0.01        0.90 SSPI                                                     27.478          22.5 SSPA                                                      4.09           -26.4 SSPB                                                      5.26            15.7 In addition, per BWRVIP-135, as seen above, ISP surveillance data for weld 5P6214B should be used to evaluate the ART for Columbia vessel beltline (N6 LPCI weld 5P6214B).
This heat was contained in two (2) Perry and six (6) BWR Supplemental Surveillance Program (SSP) capsules that have been tested and analyzed. It is noted that the maximum scatter in the fitted data falls within the 1-sigma value of 28&deg;F from RG 1.99.
BWRVIP-135 also provides best estimate chemistries that are used in the ART evaluation.
The best estimate chemistry for ISP weld heat is defined as 0.019% Cu and 0.828% Ni.
The CF from RG 1.99 is 20&deg;F (Table CFSurvChem in Equation 1) and the fitted CF is
((43.28&deg;F {E})) (CFFittedData in Equation 1). The CGS limiting vessel chemistry for this material is 0.019% Cu and 0.828% Ni, from the best estimate chemistry for ISP. Using RG 1.99, the CF is 27.0&deg;F (Table CFVesselChem in Equation 1). As the ISP weld material is identical to the vessel target material, the ART table evaluates the ISP weld material using an adjusted CF and is therefore permitted to reduce the margin term as defined in RG 1.99, Position 2.1.
The CF for a weld material that has more than two (2) data points is determined by calculating an adjusted CF in accordance with RG 1.99. The adjusted CF is determined using the following equation:
                         .                                               (1)
For CGS, the adjusted CF = (27&deg;F / 20&deg;F) * ((43.28&deg;F = 58.43&deg;F {E})).
As ((58.43&deg;F {E})) is greater than 27&deg;F, and the surveillance data is credible, the adjusted CF of ((58.43&deg;F {E}))is used in the ART evaluation. This material was considered in determining the limiting ART for the P-T curves.
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NEDO-33929 Revision 0 Non - Proprietary Information Should actual surveillance capsules be withdrawn and tested from the CGS RPV (e.g.,
status change to be an ISP host plant under the BWRVIP ISP), compliance with 10 CFR 50 Appendix H requirements on reporting test results and evaluations on the effects to plant operations parameters (e.g., P-T limits, hydrostatic and leak test conditions) will be in accordance with Section 3 of Reference 3.
3.6           Beltline Weld Flaw Indications CGS has two RPV indications. These indications were not reviewed in this report.
3.7           Thickness Discontinuities For CGS, there are four (4) thickness discontinuities in the RPV as follows:
x       Lower shell to bottom head torus x       Lower shell to lower intermediate shell x       Upper intermediate shell to upper shell x       Bottom head radial plate to bottom head dollar plate.
There is also a thickness discontinuity between the top head dollar plate and torus; the P-T limits for the top head are determined considering this continuity in order to ensure that the vessel is adequately protected, or bounded.
An evaluation was performed for the vessel wall thickness transition discontinuities identified above. The CGS P-T curves bound the requirements due to the beltline thickness discontinuities discussed in this Section.
3.8           Pressure-Temperature (P-T) Curves The CGS P-T curves presented in this PTLR are based upon the GEH methodology accepted by the NRC in Reference 2. Selected explanations are presented below, and Appendix D includes sample calculations demonstrating P-T curve methodology.
The pressure head for the beltline hydrostatic test curve (Curve A) for CGS is ((` ` ` ` ` ` ` ` ` `
                        ` ` ` )). This is determined using the height of the vessel and the elevation of the bottom of active fuel. The full vessel pressure head is ((` ` ` ` ` ` ` ` ` ` ` )). The pressure combining the internal pressure and pressure head is used for determining KI for the bottom head curve as discussed in Sections 4.3.2.1.1 and 4.3.2.1.2 of Reference 2.
In Reference 2, the P-T curves for the non-beltline region were developed for a ((` ` ` ` ` ` ` ` `
                        ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )) vessel with a nominal inside diameter of ((` ` ` ` `
                        ` ` ` ` ` ` ` ` ` )). Because the CGS RPV bottom head geometry is different from a ((` ` ` ` ` ` ` ` `
                        )), it is necessary to confirm that the generic analysis of the ((` ` ` ` ` ` ` ` ` )) applies to CGS.
The applicability of generic analysis data to CGS is shown as follows.
The P-T curve is dependent on the calculated KI value which is proportional to the stress ()
and the crack depth (a) as shown below:
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NEDO-33929 Revision 0 Non - Proprietary Information K   a                                                                           (2)
The stress is proportional to R/t (R = bottom head radius and t = bottom head thickness) and, for the P-T curves, crack depth, a, is t/4. Thus, KI is proportional to R/t. The generic curve value of R/t, based on the generic BWR/6 bottom head dimensions, is:
Generic:          ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ))
The CGS-specific bottom head dimensions are R = 130.25 inches and t = 7.3125 inches minimum, resulting in:
CGS-specific: R/t  130.25/ 7.3125  48in Because the generic value of R/t is ((` ` ` ` ` ` ` ` ` ` )), the generic P-T curve ((` ` ` ` ` ` ` ` ` ` ` ` ` `
                        ` ` ` ` ` )) when applied to the CGS bottom head.
The P-T curves for the heatup and cooldown operating conditions at a given EFPY apply for both the 1/4T and 3/4T locations. When combining pressure and thermal stresses, it is usually necessary to evaluate stresses at the 1/4T location (inside surface flaw) and the 3/4T location (outside surface flaw). This is because the thermal gradient tensile stress of interest is in the inner wall during cooldown and the outer wall during heatup. However, as a conservative simplification, the thermal gradient stress at the 1/4T location is assumed to be tensile for both heatup and cooldown. This results in the approach of applying the maximum tensile stress at the 1/4T location. This approach is conservative because irradiation effects cause the allowable toughness, KIr, at 1/4T to be less than at 3/4T for a given metal temperature. This approach causes no operational difficulties, because the BWR is at steam saturation conditions during normal operation, well above the heatup/cooldown temperature curve limits.
For the core not critical curve (Curve B) and the core critical curve (Curve C), the P-T curves specify a coolant heatup and cooldown temperature rate of  100&deg;F/hr for which the curves are applicable. However, the core not critical and the core critical curves were also developed to bound transients defined on the RPV thermal cycle diagram and the nozzle thermal cycle diagrams. The P-T limits and corresponding heatup/cooldown rates of either Curve A or Curve B may be applied while achieving or recovering from hydrostatic pressure and leak test conditions. Curve A may be used for the hydrostatic pressure and leak test if a coolant heatup and cooldown rate of  20&deg;F/hr is maintained. Otherwise, the limits of Curve B apply when performing the hydrostatic pressure and leak test.
The CGS P-T curves are based upon an initial RTNDT of ((` ` ` ` ` ` ` ` )) for the bottom head,
((` ` ` ` ` ` ` ` )) for the upper vessel, an ART of ((` ` ` ` ` ` ` ` )) for the plates and welds, ((` ` ` ` ` ` `
                        ` ` ` )) for the N6 LPCI nozzle, and ((` ` ` ` ` ` ` ` ` ` )) for the N12 WLI nozzle. For Curve B, the N6 LPCI and N12 WLI nozzle requirements ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )) by the beltline limited curves.
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NEDO-33929 Revision 0 Non - Proprietary Information For CGS, the lower shell (Shell #1) plate (Heat C1272-1) is ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ))
for the beltline region for 54 EFPY. Both the N6 LPCI nozzle and the N12 WLI nozzle are also within the beltline region and are considered in the development of the P-T curves.
Using the fluence discussed earlier, the P-T curves are ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` `
                        ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )) at all pressures for Curve A and Curve B.
In order to ensure that the limiting vessel discontinuity has been considered in the development of the P-T curves, the methods in Sections 4.3.2.1 and 4.3.2.2 of Reference 2 for the non-beltline and beltline regions, respectively, are applied.
In order to determine how much to shift the baseline non-beltline P-T curves, an evaluation is performed using Tables 4-4a and 4-5a from Reference 2. These tables define ((` ` ` ` ` ` ` `
                        `````````````````````````````````````````````````````````````````````````````````````````
                        ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )). Each component listed in these tables is evaluated using its plant-specific initial RTNDT. The required temperature is then determined by ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )), thereby resulting in the required T for the curve. As the upper vessel curve is initially based on the non-shifted
((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )), all resulting T values are compared to the ((` ` ` ` ` ` ` `
                        ` ` ` ` ` ` ` )). The difference between the maximum T and ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )) is used to shift the ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )). The same method is applied for the ((` ` ` ` ` ` ` `
                        ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )). In this manner, it is assured that each curve bounds the maximum discontinuity that is represented.
For the CGS upper vessel curve, the maximum T value for pressure equal to ((` ` ` ` ` ` ` ` ` ` ` `
                        ` )) from the method described above is ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )).
The initial required T-RTNDT for the ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )); this is then adjusted by the CGS specific maximum FW nozzle initial RTNDT of ((` ` ` ` ` ` ` )), resulting in ((` ` ` ` ` ` ` ` ` )). Comparing this to the other components bounded by the upper vessel curve, the limiting value is for the ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )). The required T-RTNDT for the
((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )), which is added to the limiting ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` `
                        ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )). It is seen that the resulting T required for the ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` `
                        ` ` ` ` ` ` ` ` ` ` ` )). As ((` ` ` ` ` ` ` ` ` ))is limiting, the CGS upper vessel curve is based on an RTNDT of ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )). As noted above, this calculation was performed for each component shown in Table 4-4a of the Reference 2; only the limiting cases are discussed here.
For the CGS bottom head or CRD hydrotest and core critical curves (Curves A and C, respectively), the maximum T value from the method described above is ((` ` ` ` ` ` ` ` ` ` ` ` ` ` `
                        ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )). The required T-RTNDT for the ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` `
                        ` ` ` ` ` ` ` ` ` ` ` )); this is adjusted by the CGS specific maximum ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` `
                        ` ` ` ` ` ` ` ` ` ` ` ` ` ` )), resulting in ((` ` ` ` ` ` ` ` ` )). Comparing this to the remaining components represented by the bottom head curve, the required T-RTNDT is 8
                                                                                                      

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NEDO-33929 Revision 0 Non - Proprietary Information
((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )), which is added to the ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` `
                        ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )). It is seen that the resulting T required for the ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` `
                        ` ` ` ` ` ` ` ` ` ` ` )). As ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )), the CGS bottom head (CRD) curve is based on an ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )). As noted above, this calculation was performed for each component shown in Table 4-5a of Reference 2; only the limiting case is presented here.
Appendix H of Reference 2 contains the details of an analysis performed to determine the baseline requirement (non-shifted) for the ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` `
                        ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )). It can be seen in Section H.5 of Appendix H of Reference 2 that the stresses developed in this finite element analysis demonstrated that the ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` `
                        ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )), resulting in a baseline non-shifted required T-RTNDT of
((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` `
                        ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )). Therefore, considering the determination of the required shift from the paragraph above for ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )), calculations for all components listed in Table 4-5a of Reference 2 were compared to the CRD T, which is ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` `
                        ` ` ` ` ` ` )) (where ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` `
                        ` ` ` ` ` ` ` ` ` ` ` )) materials). Therefore, the shift for the bottom head ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` `
                        `````````````````````````````````````````````````````````````````````````````````````````
                        `````````````````````````````````````````````````````````````````````````````````````````
                        ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ))
The ART of the limiting beltline material is used to adjust the beltline P-T curves to account for the effects of irradiation. RG 1.99 provides the methods for determining the ART.
Appendix J of Reference 2 provides detailed results of an analysis performed for the WLI nozzle that provides the required stresses for the drill hole in the shell plate. These stresses were used to generate a specific curve applicable for the WLI nozzle to ensure that this location is bounded in the P-T curves. For CGS, the N12 WLI nozzle is the ((` ` ` ` ` ` ` ` ` ` ` `
                        ` ` ` ` ` ` ` ` ` ` ` ` ` )) for the beltline region for 54 EFPY.
The CGS N12 WLI nozzle is a partial penetration design similar to that shown in Figure 1 in Appendix J of Reference 2, fabricated with a ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )). Therefore, the evaluation is performed, consistent with the statement in Appendix J, by using the material properties and ART of the limiting forging material.
3.9            Reactor Coolant Pressure Boundary (RCPB)
ASME Code Section III, NB-2332(b) states:
Pressure retaining material, other than bolting, with nominal wall thickness over 2-1/2 in. for piping (pipe and tubes) and material for pumps, valves, and fittings with any pipe connections of nominal wall thickness greater than 2-1/2 in. shall meet the requirements of NB-2331. The lowest service temperature shall not be lower than 9
                                                                                                     

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NEDO-33929 Revision 0 Non - Proprietary Information RTNDT + 100&deg;F unless a lower temperature is justified by following methods similar to those contained in Appendix G.
All CGS ferritic reactor coolant pressure boundary (RCPB) piping have wall thicknesses less than 2.5 inches. The lowest service temperature may be less than RTNDT + 100&deg;F, however the methods of Appendix G have been followed to justify lower temperatures.
Therefore, the requirements of NB-2332 have been met, and there are no ferritic RCPB piping components that require consideration in the CGS P-T curves.
With respect to the concern regarding irradiation effects on RCPB piping, the N6 LPCI and N12 WLI beltline nozzles were assessed. As can be seen in Table B-5, the LPCI and WLI nozzles exceed 1.0e17 n/cm2 at the 1/4T location. It is further noted that the WLI piping have a thickness less than 2.5 inches and are fabricated from ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )).
Therefore, this piping meets the conditions identified in ASME NB-2332(b) and does not require evaluation for fracture toughness.
3.10     Future Changes Changes to the curves, limits, or parameters within this PTLR, based upon new irradiation fluence data of the RPV, or other plant design assumptions in the Updated Final Safety Analysis Report (UFSAR), can be made pursuant to 10 CFR 50.59, provided the above methodologies are utilized. The revised PTLR shall be submitted to the NRC upon issuance (Reference 2).
4.0        Operating Limits The pressure-temperature (P-T) curves provided in this PTLR represent steam dome pressure versus minimum vessel metal temperature and incorporate the appropriate non-beltline limits and irradiation embrittlement effects in the beltline region. Note that the P-T curves were developed without allowance or margin for instrument uncertainty or errors.
The operating limits for pressure and temperature are required for three categories of operation:
: 1.       Curve A: Pressure Test (Hydrostatic Pressure Tests and Leak Tests)
Curve A may be used during pressure tests at times when the coolant temperature heatup or cooldown rate is  20&deg;F/hr during a hydrotest and when the core is not critical.
: 2.       Curve B: Non-Nuclear Heatup/Cooldown Curve B must be used whenever Curve A or Curve C do not apply. In other words, this curve must be followed during times when the coolant heatup or cooldown rate is greater than 20&deg;F/hr during a pressure test and when the core is not critical.
Additionally, when performing low-power physics testing, Curve B must be 10
                                                                     

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NEDO-33929 Revision 0 Non - Proprietary Information followed. The heatup and cooldown rate is limited to  100&deg;F/hr when using Curve B.
: 3.       Curve C: Core Critical Operation This curve must be used when the core is critical with the exception as noted in Item 2 above, during low-power physics testing activities. The heatup and cooldown rate is limited to  100&deg;F/hr when using Curve C.
Complete P-T curves were developed for 54 EFPY. The P-T curves are provided in Figures 1 through 3, and a tabulation of the curves is included in Table 1.
Other temperature limits applicable to the RPV and controlled by the Technical Specification are:
x    Heatup and Cooldown rate limit during Hydrostatic and Class 1 Leak Testing:
d 20qF/hour.
x    Normal Operating Heatup and Cooldown rate limit: d 100 qF/hour.
x    RPV bottom head coolant temperature to RPV coolant temperature 'T limit during Recirculation Pump startup: d 145 qF.
x    Recirculation loop coolant temperature to RPV coolant temperature 'T limit during Recirculation Pump startup: d 50 qF.
x    RPV flange and adjacent shell temperature limit: t 80 qF.
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NEDO-33929 Revision 0 Non - Proprietary Information 5.0        Discussion The procedures described in References 1 and 2 were used in the development of the P-T curves for CGS.
The method for determining the initial Reference Temperature of Nil-Ductility Transition (RTNDT) for all vessel materials is defined in Section 4.1.2 of Reference 2. Initial RTNDT values for all vessel materials considered are presented in tables in Appendix B.
For CGS, the surveillance materials, weld heat 5P6756 and 5P6214B, were considered using Procedure 1 as defined in Appendix I of Reference 2. This procedure was used because the target vessel material and the surveillance material are identical heats.
However, from Table B-5, the limiting material is a lower shell plate whose ART is ((` ` ` `
                        ` ` ` ` )). This ART was used for the generation of P-T curves.
The ART of the limiting beltline material is used to adjust the beltline P-T curves to account for irradiation effects. Regulatory Guide 1.99, Revision 2 (RG 1.99) provides the methods for determining the ART.
The P-T curves for the non-beltline region were conservatively developed for ((` ` ` ` ` ` ` ` ` `
                        ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )) vessel with nominal inside diameter of ((` ` ` ` ` `
                        ` ` ` ` ` ` ` ` )). The analysis is considered appropriate for CGS because the plant-specific geometric values ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )) by the generic analysis for the large ((` ` ` ` ` ` ` ` ` )). The generic value ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )) to the conditions at CGS using plant-specific RTNDT values for the reactor pressure vessel.
For CGS, the Shell #1 plate (Heat C1272-1) material is the limiting material for the beltline region for 54 EFPY whose initial RTNDT and ART are 28&deg;F and ((` ` ` ` ` ` ` ` )), respectively.
The generic pressure test P-T curve is applied to the CGS beltline curve by shifting the P vs. (T - RTNDT) values to reflect the ART value of ((` ` ` ` ` ` ` ` )) for 54 EFPY. Using the fluence discussed above, the P-T curves are ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` `
                        ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )) for Curves A, B, and C.
In order to ensure that the limiting vessel discontinuity has been considered in the development of the P-T curves, the methods in Sections 4.3.2.1 and 4.3.2.2 of Reference 2 for the non-beltline and beltline regions, respectively, are applied.
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NEDO-33929 Revision 0 Non - Proprietary Information 6.0        References
: 1. Final Safety Evaluation Regarding Removal of Methodology Limitations for NEDC-32983P-A, General Electric Methodology for Reactor Pressure Vessel Fast Neutron Flux Evaluation (TAC NO. MC3788), November 17, 2005.
: 2. Final Safety Evaluation for Boiling Water Reactors Owners Group Licensing Topical Report NEDC-33178P, General Electric Methodology for Development of Reactor Pressure Vessel Pressure-Temperature Curves (TAC NO. MD2693),
April 27, 2009.
: 3. BWR Vessel and Internals Project Integrated Surveillance Program (ISP) Data Source Book and Plant Evaluations, BWRVIP-135, Revision 3, EPRI, Palo Alto, CA: December 2014, 3002003144. (EPRI Proprietary)
: 4. BWR Vessel and Internals Project, Updated BWR Integrated Surveillance Program (ISP) Implementation Plan, BWRVIP-86, Revision 1-A, EPRI, Palo Alto, CA:
October 2012, 1025144. (EPRI Proprietary)
: 5. Not used.
: 6. Not used.
: 7. Not used.
: 8. PVRC Recommendations on Toughness Requirements for Ferritic Materials, Welding Research Council Bulletin 175, August 1972.
: 9. Mehta, H.S., Stevens, G.L., Sommerville, D.V., Benson, M., Kirk, M., Griesbach, T.J., and Kusnick, J., Treatment of Stresses Exceeding Material Yield Strength in ASME Code Section XI Appendix G Fracture Toughness Evaluations, 2014 ASME Pressure Vessels and Piping Conference, PVP2014-28397, July 2014.
: 10. Radiation Embrittlement of Reactor Vessel Materials, USNRC Regulatory Guide 1.99, Revision 2, May 1988.
: 11. Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence, USNRC Regulatory Guide 1.190, March 2001.
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NEDO-33929 Revision 0 Non - Proprietary Information 1400                                                                                                                I I
I I
I I
1300                                                                                                                                                         INITIAL RTNDT VALUES ARE I
I I                                                      28&deg;F FOR BELTLINE, I
I                                                       -20&deg;F FOR WATER LEVEL 1200                                                                                               I INSTRUMENTATION (WLI),
I I                                                              34&deg;F FOR UPPER VESSEL, J
I I
34&deg;F FOR BOTTOM HEAD
                                                                                                                                                                                            /I I
I 1100 1035 PSIG 88.6&deg;F                         Ii                                                                           1035 PSIG l
PRESSURE LIMIT IN REACTOR VESSEL TOP HEAD (psig)
I                                                     117.1&deg;F I
1000 I
I I
I I
I I              I I
I 910 PSIG                         BELTLINE CURVES 900                                        I I
I     110&deg;F    I                    ADJUSTED AS SHOWN:
I EFPY SHIFT (&deg;F) 800 PSIG   I /                                                                                                                                     54      42.1 800                68&deg;F     I                                                                                                                                        54    55 (WLI) 700 HEATUP/COOLDOWN 600                                                                                                                                                                  RATE OF COOLANT
                                                                                                                                                                                                                                              -< 20&deg;F/HR I                         I 500              BOTTOM HEAD 68&deg;F 400 300                          --,
I312 PSIGI 200                                                                                                                                  FLANGE
                                                                                                                                                                                                                                          -         UPPER VESSEL AND BELTLINE
                                                                                                                                        -                                                                 REGION                                    LIMITS 80&deg;F                          -------   BOTTOM HEAD 100                                                                                                                                                                            CURVE 0
0     25       50            75                                              100                                     125           150        175   200 MINIMUM REACTOR VESSEL METAL TEMPERATURE (&deg;F)
Figure 1 - CGS Composite Curve A (Pressure Test P-T Curves) Effective for up to 54 EFPY
             
                                                                                                                                                                                                                                                
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NEDO-33929 Revision 0 Non - Proprietary Information 1400 I
I I
I I
I I
I 1300                                                                                                                                                      I I
I I                                              INITIAL RTNDT VALUES I
I I                                                          ARE 1200                                                                                                                                               I I
28&deg;F FOR BELTLINE, I
I I
                                                                                                                                                                                                                                                                          -20&deg;F FOR WATER LEVEL I
I I
INSTRUMENTATION (WLI),
1100                                                                                                                                 I I
34&deg;F FOR UPPER l:                                                                                   l I
VESSEL, I                                                                                                                                                   I 148.1&deg;F 1035 PSIG                                                                                                                                        1035 PSIG 48.6&deg;F FOR BOTTOM PRESSURE LIMIT IN REACTOR VESSEL TOP HEAD (psig) 123.9&deg;F                                                                                           I I
1000                                                                                                                          I HEAD I
I I
I I
I 900                                                                                                           I I
I BELTLINE CURVES I
I I
ADJUSTED AS SHOWN:
I 800                                                                                     ;                                                                                                                   EFPY SHIFT (&deg;F)
I I
I 790 PSIG                               54     42.1 I
140&deg;F                                54    55 (WLI)
I 700                                                                     I I
I I
I I
I I
600                                     I I
I HEATUP/COOLDOWN H
I RATE OF COOLANT 520 PSIG 500            68&deg;F                                                                                                                                                                                              -< 100&deg;F/HR I                             I 400 BOTTOM HEAD                                                                                                                                                    I312 PSIGI 300            68&deg;F                                                                 ,-
200                                         z J                                                                                                                                                         -         UPPER VESSEL AND BELTLINE I 170 PSIG I                                                                                                                                                        LIMITS FLANGE 100                                                     _.
REGION 80&deg;F
                                                                                                                                                                                                                                                                                  -------   BOTTOM HEAD L.-                                                                                                                                                                         CURVE 0
0    25   50         75                                      100                                                 125                                      150         175     200     225   250 MINIMUM REACTOR VESSEL METAL TEMPERATURE (&deg;F)
                                                                                                                                                                                                                                                                                                               
Figure 2 - CGS Composite Curve B (Core Not Critical P-T Curves) Effective for up to 54 EFPY
             
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NEDO-33929 Revision 0 Non - Proprietary Information 1400 INITIAL RTNDT VALUES ARE 1300                                                                               28&deg;F FOR BELTLINE.
                                                                                                                                                  -20&deg;F FOR WATER LEVEL INSTRUMENTATION (WLI),
1200                                                                                 34&deg;F FOR UPPER VESSEL, 34&deg;F FOR BOTTOM HEAD 1100 1035 PSIG I
PRESSURE LIMIT IN REACTOR VESSEL TOP HEAD (psig) 188.1&deg;F 1000                                                                                 BELTLINE CURVE ADJUSTED AS SHOWN:
EFPY SHIFT (&deg;F) 900                                                                                   54       42.1 54      55 (WLI)
I 800                                                           790 PSIG 180&deg;F HEATUP/COOLDOWN 700                                                                                 RATE OF COOLANT
                                                                                                                                                         -< 100&deg;F/HR I                      I 600 500 400 I 312 PSIG I
300
                                                                                                      /                                          1-200 BELTLINE AND NON-BELTLINE 100 60 PSIG                       Minimum Vessel                           LIMITS I
I~                  Temperature 80&deg;F 0
0   25     50      75       100 125 150 175 200 225 250 275 MINIMUM REACTOR VESSEL METAL TEMPERATURE (&deg;F)
                                                                                                                                                                            
Figure 3 - CGS Limiting Curve C (Core Critical P-T Curve) Effective for up to 54 EFPY
                                                                                                 
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NEDO-33929 Revision 0 Non - Proprietary Information Table 1       CGS Tabulation of Curves - 54 EFPY BOTTOM         UPPER RPV &       BOTTOM     UPPER RPV &
HEAD          BELTLINE AT       HEAD      BELTLINE AT LIMITING 54 EFPY                     54 EFPY   54 EFPY PRESSURE        CURVE A           CURVE A        CURVE B      CURVE B   CURVE C (PSIG)           (&deg;F)             (&deg;F)           (&deg;F)         (&deg;F)       (&deg;F) 0            68.0              80.0           68.0         80.0       80.0 10            68.0              80.0           68.0         80.0       80.0 20            68.0              80.0           68.0         80.0       80.0 30            68.0              80.0           68.0         80.0       80.0 40            68.0              80.0           68.0         80.0       80.0 50            68.0              80.0           68.0         80.0       80.0 60            68.0              80.0           68.0         80.0       80.0 70            68.0              80.0           68.0         80.0       81.2 80            68.0              80.0           68.0         80.0       87.2 90            68.0              80.0           68.0         80.0       92.3 100           68.0              80.0           68.0         80.0       96.8 110           68.0              80.0           68.0         80.0      100.9 120           68.0              80.0           68.0         80.0      104.7 130           68.0              80.0           68.0         80.0      108.2 140           68.0              80.0           68.0         80.0      111.4 150           68.0              80.0           68.0         80.0      114.2 160           68.0              80.0           68.0         80.0      116.9 170           68.0              80.0           68.0         80.0      119.5 180           68.0              80.0           68.0         81.9      121.9 190           68.0              80.0           68.0         84.2      124.2 17
                                                                    

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NEDO-33929 Revision 0 Non - Proprietary Information BOTTOM         UPPER RPV &       BOTTOM     UPPER RPV &
HEAD          BELTLINE AT       HEAD      BELTLINE AT LIMITING 54 EFPY                     54 EFPY   54 EFPY PRESSURE        CURVE A           CURVE A        CURVE B      CURVE B   CURVE C (PSIG)           (&deg;F)             (&deg;F)           (&deg;F)         (&deg;F)       (&deg;F) 200           68.0              80.0           68.0         86.3      126.3 210           68.0              80.0           68.0         88.3      128.3 220           68.0              80.0           68.0         90.3      130.3 230           68.0              80.0           68.0         92.1      132.1 240           68.0              80.0           68.0         93.9      133.9 250           68.0              80.0           68.0         95.6      135.6 260           68.0              80.0           68.0         97.2      137.2 270           68.0              80.0           68.0         98.8      138.8 280           68.0              80.0           68.0        100.3      140.3 290           68.0              80.0           68.0        101.8      141.8 300           68.0              80.0           68.0        103.2      143.2 310           68.0              80.0           68.0        104.5      144.5 312.5           68.0              80.0           68.0        104.9      144.9 312.5           68.0             110.0           68.0        140.0      180.0 320           68.0             110.0           68.0        140.0      180.0 330           68.0             110.0           68.0        140.0      180.0 340           68.0             110.0           68.0        140.0      180.0 350           68.0             110.0           68.0        140.0      180.0 360           68.0             110.0           68.0        140.0      180.0 370           68.0             110.0           68.0        140.0      180.0 380           68.0             110.0           68.0        140.0      180.0 18
                                                                    

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NEDO-33929 Revision 0 Non - Proprietary Information BOTTOM         UPPER RPV &       BOTTOM     UPPER RPV &
HEAD          BELTLINE AT       HEAD      BELTLINE AT LIMITING 54 EFPY                     54 EFPY   54 EFPY PRESSURE        CURVE A           CURVE A        CURVE B      CURVE B   CURVE C (PSIG)           (&deg;F)             (&deg;F)           (&deg;F)         (&deg;F)       (&deg;F) 390           68.0             110.0           68.0        140.0      180.0 400           68.0             110.0           68.0        140.0      180.0 410           68.0             110.0           68.0        140.0      180.0 420           68.0             110.0           68.0        140.0      180.0 430           68.0             110.0           68.0        140.0      180.0 440           68.0             110.0           68.0        140.0      180.0 450           68.0             110.0           68.0        140.0      180.0 460           68.0             110.0           68.0        140.0      180.0 470           68.0             110.0           68.0        140.0      180.0 480           68.0             110.0           68.0        140.0      180.0 490           68.0             110.0           68.0        140.0      180.0 500           68.0             110.0           68.0        140.0      180.0 510           68.0             110.0           68.0        140.0      180.0 520           68.0             110.0           68.0        140.0      180.0 530           68.0             110.0           69.8        140.0      180.0 540           68.0             110.0           71.7        140.0      180.0 550           68.0             110.0           73.5        140.0      180.0 560           68.0             110.0           75.3        140.0      180.0 570           68.0             110.0           77.0        140.0      180.0 580           68.0             110.0           78.6        140.0      180.0 590           68.0             110.0           80.2        140.0      180.0 19
                                                                    

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NEDO-33929 Revision 0 Non - Proprietary Information BOTTOM         UPPER RPV &       BOTTOM     UPPER RPV &
HEAD          BELTLINE AT       HEAD      BELTLINE AT LIMITING 54 EFPY                     54 EFPY   54 EFPY PRESSURE        CURVE A           CURVE A        CURVE B      CURVE B   CURVE C (PSIG)           (&deg;F)             (&deg;F)           (&deg;F)         (&deg;F)       (&deg;F) 600           68.0             110.0           81.8        140.0      180.0 610           68.0             110.0           83.3        140.0      180.0 620           68.0             110.0           84.7        140.0      180.0 630           68.0             110.0           86.1        140.0      180.0 640           68.0             110.0           87.5        140.0      180.0 650           68.0             110.0           88.8        140.0      180.0 660           68.0             110.0           90.1        140.0      180.0 670           68.0             110.0           91.4        140.0      180.0 680           68.0             110.0           92.7        140.0      180.0 690           68.0             110.0           93.9        140.0      180.0 700           68.0             110.0           95.0        140.0      180.0 710           68.0             110.0           96.2        140.0      180.0 720           68.0             110.0           97.3        140.0      180.0 730           68.0             110.0           98.4        140.0      180.0 740           68.0             110.0           99.5        140.0      180.0 750           68.0             110.0          100.6        140.0      180.0 760           68.0             110.0          101.6        140.0      180.0 770           68.0             110.0          102.6        140.0      180.0 780           68.0             110.0          103.6        140.0      180.0 790           68.0             110.0          104.6        140.0      180.0 800           68.0             110.0          105.5        140.1      180.1 20
                                                                    

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NEDO-33929 Revision 0 Non - Proprietary Information BOTTOM         UPPER RPV &       BOTTOM     UPPER RPV &
HEAD          BELTLINE AT       HEAD      BELTLINE AT LIMITING 54 EFPY                     54 EFPY   54 EFPY PRESSURE        CURVE A           CURVE A        CURVE B      CURVE B   CURVE C (PSIG)           (&deg;F)             (&deg;F)           (&deg;F)         (&deg;F)       (&deg;F) 810           68.3             110.0          106.5        140.5      180.5 820           69.4             110.0          107.4        140.9      180.9 830           70.5             110.0          108.3        141.2      181.2 840           71.5             110.0          109.2        141.6      181.6 850           72.6             110.0          110.0        141.9      181.9 860           73.6             110.0          110.9        142.3      182.3 870           74.6             110.0          111.7        142.6      182.6 880           75.5             110.0          112.6        143.0      183.0 890           76.5             110.0          113.4        143.3      183.3 900           77.4             110.0          114.2        143.7      183.7 910           78.4             110.0          115.0        144.0      184.0 920           79.3             110.2          115.7        144.4      184.4 930           80.1             110.9          116.5        144.7      184.7 940           81.0             111.5          117.3        145.0      185.0 950           81.9             112.1          118.0        145.4      185.4 960           82.7             112.7          118.7        145.7      185.7 970           83.6             113.3          119.5        146.0      186.0 980           84.4             113.9          120.2        146.4      186.4 990           85.2             114.5          120.9        146.7      186.7 1000           86.0             115.1          121.6        147.0      187.0 1010           86.7             115.7          122.2        147.3      187.3 21
                                                                    

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NEDO-33929 Revision 0 Non - Proprietary Information BOTTOM         UPPER RPV &       BOTTOM     UPPER RPV &
HEAD          BELTLINE AT       HEAD      BELTLINE AT LIMITING 54 EFPY                     54 EFPY   54 EFPY PRESSURE        CURVE A           CURVE A        CURVE B      CURVE B   CURVE C (PSIG)           (&deg;F)             (&deg;F)           (&deg;F)         (&deg;F)       (&deg;F) 1020           87.5             116.2          122.9        147.6      187.6 1030           88.3             116.8          123.6        148.0      188.0 1035           88.6             117.1          123.9        148.1      188.1 1040           89.0             117.4          124.2        148.3      188.3 1050           89.7             117.9          124.9        148.6      188.6 1055           90.1             118.2          125.2        148.7      188.7 1060           90.4             118.5          125.5        148.9      188.9 1070           91.2             119.0          126.1        149.2      189.2 1080           91.9             119.5          126.8        149.5      189.5 1090           92.6             120.1          127.4        149.8      189.8 1100           93.2             120.6          128.0        150.1      190.1 1105           93.6             120.8          128.3        150.3      190.3 1110           93.9             121.1          128.6        150.4      190.4 1120           94.6             121.6          129.2        150.7      190.7 1130           95.2             122.1          129.8        151.0      191.0 1140           95.9             122.6          130.3        151.3      191.3 1150           96.5             123.1          130.9        151.6      191.6 1160           97.1             123.6          131.5        151.9      191.9 1170           97.8             124.1          132.0        152.2      192.2 1180           98.4             124.6          132.6        152.5      192.5 1190           99.0             125.1          133.1        152.7      192.7 22
                                                                    

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NEDO-33929 Revision 0 Non - Proprietary Information BOTTOM         UPPER RPV &       BOTTOM     UPPER RPV &
HEAD          BELTLINE AT       HEAD      BELTLINE AT LIMITING 54 EFPY                     54 EFPY   54 EFPY PRESSURE        CURVE A           CURVE A        CURVE B      CURVE B   CURVE C (PSIG)           (&deg;F)             (&deg;F)           (&deg;F)         (&deg;F)       (&deg;F) 1200            99.6            125.5          133.7        153.0      193.0 1210           100.2            126.0          134.2        153.3      193.3 1220           100.8            126.5          134.8        153.6      193.6 1230           101.3            126.9          135.3        153.9      193.9 1240           101.9            127.4          135.8        154.2      194.2 1250           102.5            127.8          136.3        154.4      194.4 1260           103.0            128.3          136.8        154.7      194.7 1270           103.6            128.7          137.3        155.0      195.0 1280           104.1            129.2          137.8        155.2      195.2 1290           104.7            129.6          138.3        155.5      195.5 1300           105.2            130.0          138.8        155.8      195.8 1310           105.7            130.5          139.3        156.1      196.1 1320           106.3            130.9          139.8        156.3      196.3 1330           106.8            131.3          140.2        156.6      196.6 1340           107.3            131.7          140.7        156.8      196.8 1350           107.8            132.1          141.2        157.1      197.1 1360           108.3            132.6          141.6        157.4      197.4 1370           108.8            133.0          142.1        157.6      197.6 1380           109.3            133.4          142.5        157.9      197.9 1390           109.8            133.8          143.0        158.1      198.1 1400           110.3            134.2          143.4        158.4      198.4 23
                                                                    

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NEDO-33929 Revision 0 Non - Proprietary Information Appendix A        Reactor Vessel Material Surveillance Program In accordance with 10 CFR 50, Appendix H, Reactor Vessel Material Surveillance Program Requirements, the first surveillance capsule was removed from the CGS reactor vessel after 7.2 EFPY, during refueling outage R11 in 1996. This capsule was tested, reconstituted, and returned to the reactor vessel in R12 (1997). The same specimen holder was subsequently found failed in R23 (2017) and removed from the vessel. The surveillance capsule contained flux wires for neutron fluence measurement, Charpy V-Notch impact test specimens and uniaxial tensile test specimens fabricated using materials from the vessel materials within the core beltline region.
As described in the CGS Updated Final Safety Analysis Report (UFSAR) Section 5.3.1.6, Material Surveillance, the BWR Vessel and Internals Project (BWRVIP) Integrated Surveillance Program (ISP) will determine the removal schedule for the remaining CGS surveillance capsules. The CGS material surveillance program is administered in accordance with the BWRVIP ISP. The ISP combines the US BWR surveillance programs into a single integrated program. This program uses similar heats of materials in the surveillance programs of BWRs to represent the limiting materials in other vessels. It also adds data from the ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )).
Per the BWRVIP ISP, CGS ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )); all surveillance capsules are classified as Deferred.
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NEDO-33929 Revision 0 Non - Proprietary Information
             
Appendix B                CGS Reactor Pressure Vessel P-T Curve Supporting Plant-Specific Information
             
             
             
                                                 
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NEDO-33929 Revision 0 Non - Proprietary Information
             
TOP HEAD FLANGE SHELL FLANGE
                                                                                         /    SHELL COURSE #4
                                                                                         /   SHELL COURSE #3 LPCI NOZZLE
                                          ~
* BOUNDING TOP OF                 ~ZZ2~2Z2Z2Z2Z:ZZ;z;z:;cl?ZL22Z2ZW:ZZ~
ACTIVE FUEL                     Y.;\                             ~ SHELL COURSE #2 (TAF) 366.3" - ----1         ~     /    AXIAL WELDS         /
GIRTH WELD
                                                                   /
BOTTOM OF ACTIVE FUEL (BAF) 216.3"  - ----1                                        r   SHELL COURSE #1 C
                                                                                        ~    BOTTOM HEAD
                                                                                                              
             
             
Figure B Schematic of the CGS RPV Showing Arrangement of Vessel Plates and Welds 26
                                                                       

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NEDO-33929 Revision 0 Non - Proprietary Information Table B-1         CGS Initial RTNDT Values for RPV Plate and Flange Materials
             
Drop Test Heat or Heat / Flux        Charpy Energy (T50T-60) Weight RTNDT Component                                       Temp
                                                              / Lot                   (ft-lb)     (&deg;F)     NDT    (&deg;F)
(&deg;F)
(&deg;F)
Top Head & Flange Shell Closure Flange - MK 26 26-1                                      2V2243 BSD451         10   90  116    110  -20       10    10 Top Head Flange - MK 30 30-1                                      4P4740 BAS452         10  194 160     144  -20       10    10 Top Head Dollar - MK 32 32-2                                          C1256-3           10  58    50     41   -2       10    10 Top Head Side Plates - MK 32 32-1-1/3                                      A0141-1           10  55    65    52   -20       10    10 32-1-4/6                                      A0203-1           10  35    62    72    10       10    10 Shell Courses Upper Shell Plates - MK 24 Shell #4 24-1-1                                        C1308-2           10   40   64     60    0       10    10 24-1-2                                        C1307-2           10  30    33    36    20      10     20 24-1-3                                        C1873-2           10  45    69    70   -10       10    10 Upper Int. Plates - MK 23 Shell #3 23-1-1                                        C1307-1           10  60    50     60  -20       10    10 23-1-2                                        C1308-1           10  57    46    42    -4       10    10 23-1-3                                        C1302-1           10  34    42    50    12      10     12 Low-Int. Plates - MK 22 Shell #2 22-1-1                                        B5301-1           10  52    52    55   -20      -30   -20 22-1-2                                        C1336-1           10   60   44     66   -8      -30    -8 22-1-3                                        C1337-1           10  70    72     55  -20      -30   -20 22-1-4                                        C1337-2           10  62    72     82  -20      -50   -20 Lower Shell Plates - MK21 Shell #1 21-1-1                                        C1272-1           10   26   34     30   28      -10    28 21-1-2                                        C1273-1           10  30    34    35    20      -20    20 21-1-3                                        C1273-2           10  38    48    55     4      -30     4 21-1-4                                        C1272-2           10  40    42    44     0      -30     0 Bottom Head Bottom Head Dollar - MK 13 13-1                                          B5432-1           10  74    64    60   -20       10    10 13-2-1                                        B5130-1           10  35    40    31    18       10    18 13-2-2                                        B5130-2           10  32    33    30    20       10    20 Bottom Head Side Plates - MK 13 13-4-1,2,3                                    C1578-1           10  96    96    80   -20      10     10 13-4-4,5,6                                    A0081-1           10  95    84    90   -20       10    10 Note: Minimum Charpy values are provided for all materials.
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NEDO-33929 Revision 0 Non - Proprietary Information Table B-2                  CGS Initial RTNDT Values for RPV Nozzle Materials Test Heat or Heat / Flux             Charpy Energy     (T 50T-60) Drop Weight RT NDT Component                                               Temp
                                                                                  / Lot                      (ft-lb)          (&deg;F)     NDT (&deg;F)    (&deg;F)
(&deg;F)
N1 Recirculation Outlet Nozzle 46-1-1                                                      Q2Q55W 327S-1          10   45        41      41      -2         10       10 46-1-2                                                      Q2Q49W 327S-2          10   25        28      25      30         10       30 N2 Recirculation Inlet Nozzle 49-1-1                                                      210527 53003-01        10   39        34      25      30         10       30 49-1-2                                                      210527 53003-01        10   60        26      31      28         10       28 49-1-3                                                      210527 53003-01        10   26        25      32      30         10       30 49-1-4                                                      210527 53003-01        10   30        50      50      20         10       20 49-1-5                                                      211319 53003-1A        10   37        30      35      20         10       20 49-1-6                                                      211319 53003-1A        10   39        28      41      24         10       24 49-1-7                                                     211319 53003-1R         10  104        80      76     -20         10       10 49-1-8                                                     211319 53003-1R         10   70        44      42      -4         10       10 49-1-9                                                     211319 53003-1R         10   53        50      68     -20         10       10 49-1-10                                                    211319 53003-1R         10   70       64      91      -20         10       10 N3 Steam Outlet Nozzle 53-1-1                                                      Q2Q54W 328S-1          10   49        42      36       8         10       10 53-1-2                                                      Q2Q54W 328S-2          10   32        46      25      30         10       30 53-1-3                                                      Q2Q63W R328S           10   54        29      44      22         10       22 53-1-4                                                      Q2Q57W 328S-4          10   33        35      39      14         10       14 N4 Feedwater Nozzle 56-1-1                                                      Q2Q55W      786S-1    -20   58        31      61     -12        -20      -12 56-1-2                                                      Q2Q55W      786S-2    -20   64        52      37     -24        -20      -20 56-1-3                                                      Q2Q55W      786S-3    -20   25        65      57       0        -20        0 56-1-4                                                      Q2Q55W      786S-4    -20   48        58      46     -42        -20      -20 56-1-5                                                      Q2Q55W      786S-5    -20   78        75      53     -50        -20      -20 56-1-6                                                      Q2Q55W      786S-6    -20   55        55      43     -36        -20      -20 N5 Core Spray Nozzle (Low Pressure) 60-1                                                         Q2Q55W 787S          -20   72        43      55     -36        -20      -20 N6 Residual Heat Removal / Low Pressure Core Isolation 64-1-1                                                      Q2Q55W 790S-1         -20   73        55      74     -50        -20      -20 64-1-2                                                      Q2Q55W 790S-2         -20   48        64      45     -40        -20      -20 64-1-3                                                      Q2Q55W 790S-3         -20   66        56      48     -46        -20      -20 N7 Head Spray Nozzle 68-2                                                         Q2Q55W 173T          -20   30        50      65     -10        -20      -10 N8 Vent Nozzle 70-1                                                         Q2Q30W 171T           10   48        67      74     -16         10       10 N9 Jet Pump Instrumentation Nozzle 72-1-1                                                         210527 Lot 1        10   66       50       46     -12         10       10 72-1-2                                                         210527 Lot 1        10   35       41       80      10         10       10 (1)
N10 Control Rod Drive Hyd System Return Nozzle 75-1                                                         Q2Q34W 789S          -20   61        29      68      -8        -20       -8 N11 Core Differential Pressure & Liquid Control Nozzle           Alloy 600 79-1                                                          NX4256 6212 N12 Instrumentation Nozzle 82-1-1,2,3                                                     219972 Lot 1       -20   60       90      230     -50        -20      -20 82-1-7                                                        718259 65363        -20  240       240     240     -50        -20      -20 N13 Instrumentation Nozzle 82-1-5,6                                                       219972 Lot 1       -20   60       90      230     -50        -20      -20 N14 Instrumentation Nozzle 85-1-1/4                                                       219972 Lot 1       -20  120       240     240     -50        -20      -20 N15 Drain Nozzle MK 87-1                                                        B12W 295T          -20   33        20      30      10        -20       10 N16 Core Spray High Pressure (2) 88-1                                                         Q2Q55W 788S                                                     40       40 N17 Seal Leak Detector                                           Alloy 600 26-3                                                          NX4104 6242 N18 Top Head Spare Nozzle 92-2                                                         Q2Q59W 172T           10   31        36      71      18         10       18   
Notes:
: 1. Minimum Charpy values are provided for all materials.
: 2. The N10 nozzle has been capped off.
: 3. CMTR information was not available for the N16 nozzle; thus the Purchase Specification requirement was used for the evaluation of this component.
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NEDO-33929 Revision 0 Non - Proprietary Information Table B-3            CGS Initial RTNDT Values for RPV Weld Materials Drop Test Heat or             Heat /     Welds where Heat is                                Charpy Energy  (T50T-60) Weight   RTNDT Weld Type      Temp Flux / Lot                   Present                                          (ft-lb)      (&deg;F)     NDT      (&deg;F)
(&deg;F)
(&deg;F)
Beltline Welds 492L4871 / A422B27AF                   AB                     (SMAW)         -20 78    81    82    -80       -       -50 04T931 / A423B27AG                    AB                     (SMAW)         -20 61    63    84    -80       -       -50 5P6756 / 0342 - 3447                  AB                Single Wire (SAW)    10 72    76    77    -50      -60      -50 5P6756 / 0342 - 3447                  AB               Tandem Wire (SAW)     10 72    76    77    -50      -50      -50 3P4955 / 0342 - 3443                  AB                Single Wire (SAW)    10 33    37    45    -16      -40      -16 3P4955 / 0342 - 3443[2]                AB               Tandem Wire (SAW)     10 47    49    49    -44      -20      -20 04P046 / D217A27A            BA, BB, BD, BF, BH             (SMAW)         -20 34    36    39    -48       -       -48 07L669 / K004A27A                  BA, BB                   (SMAW)          10 50    50    54    -50       -       -50 3P4966 / 1214 - 3482            BA, BB, BC,BD           Single Wire (SAW)    10 40    59    63    -30       -       -30 3P4966 / 1214 - 3482            BA, BB, BC,BD          Tandem Wire (SAW)     10 49    65    67    -48       -       -48 C3L46C / J020A27A                BB, BC, BD                 (SMAW)          10 35    39    40    -20       -       -20 08M365 / G128A27A                    BB                     (SMAW)          10 49    50    51    -48       -       -48 09L853 / A111A27A                    BC                     (SMAW)          10 78    78    79    -50       -       -50 3P4966 / 1214 - 3481 [2]         BE, BF, BG, BH          Single Wire (SAW)    10 38    38    39    -26      -20      -20 3P4966 / 1214 - 3481            BE, BF, BG, BH         Tandem Wire (SAW)     10 28    63    75     -6      -20       -6 05P018 / D211A27A                    BF                     (SMAW)         -20 29    30    31    -38       -       -38 624063 / C228A27A                    BG                     (SMAW)         -20 37    40    51    -54       -       -50 624039 / D224A27A                    BG                     (SMAW)         -20 28    33    34    -36       -       -36 624039 / D205A27A                    BH                     (SMAW)         -20 41    44    49    -62       -       -50 Nonbeltline Welds See note 1.                                                                                                    10 Weld Identification Table AB                              Shell 1 to Shell 2 Girth Weld BA, BB, BC, BD                  Shell 1 Vertical Welds BE, BF, BG, BH                  Shell 2 Vertical Welds Notes:
: 1. CMTRs for the non-beltline welds are not available. The Purchase Specification requirement is used as the limiting RTNDT.
: 2. Drop weight information was obtained and considered, resulting in a change to the initial RTNDT for these materials.
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NEDO-33929 Revision 0 Non - Proprietary Information Table B-4          CGS Initial RTNDT Values for RPV Appurtenance and Bolting Materials
             
Drop Test Heat or       Heat          Charpy Energy    (T50T-60)  Weight RTNDT Component                                    Temp
                                                             / Flux / Lot                 (ft-lb)         (&deg;F)     NDT    (&deg;F)
(&deg;F)
(&deg;F)
Misc Appurtenances:
Skirt Knuckle 9-1-1/4                                        C9285-2A          10  56      54     61     -20       10     10 Shroud Support 17 1/4                                      Alloy 600 20-1-1& 2, 20-1-3&4, 20-2 Refueling Bellows Ring - MK 43 43-1-1/6                                        R0543-1          40  57      50     61     -20       -20   -20 Refueling Bellows Bar 26-2, 4, 5                                    C2924-14B          10  28      24     23      34       10     34 Stabilizer Bracket 95-1-1/8                                       A1322-2B          50  67      50     51     -10       -20   -10 Guide Rod Bracket Stainless Steel 98-1-1/2                                         651542 Steam Dryer Support Bracket Inconel 100-1-1/4                                      NX4055-G Steam Dryer Hold Down Bracket 102-1-1/4                                       A0141-1          10  55      65     52     -20       10     10 Feedwater Sparger Brackets Stainless Steel 104-1-1/12                                       131146 Core Spray Brackets Stainless Steel 108-1-1/8                                         61587 Surveillance Bracket 106-1-1/3,                                  Stainless Steel 106-2-1/3                                        150368 CRD Penetrations 14                                               Inconel Thermocouple Clamping Pad and End Pad 44-1, 44-2                                     A8879-1B          40  30      30     33      50       40     50 Lifting Lugs 40-1-1/4                                        C1256-3          10  58      50     41      -2       10     10 Jet Pump Riser Support Pads                  Stainless Steel Test Charpy Energy   Min Lat Exp  LST Component                         Heat       Temp (ft-lb)        (mils)    (&deg;F)
(&deg;F)
STUDS:
Closure 35-1                                              81741          10  46      45     49      27       10 35-1                                              81646          10  47      49     45      26       10 NUTS:
Closure 36-1                                              61056          10  47      47     45      26       10 BUSHINGS:
Stud Bushings 94-1                                              61056          10  47      47     45      26       10 WASHERS:
36-2                                              61056          10  47      47     45      26       10         
Note: These are minimum Charpy values.
             
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NEDO-33929 Revision 0 Non - Proprietary Information Table B-5     CGS Adjusted Reference Temperatures for up to 54 EFPY Lower Shell (Shell #1) Axial Welds Thickness in inches = 9.5000                                             54 EFPY Peak I.D. fluence = 2.97E+17 n/cm2 54 EFPY Peak 1/4 T fluence = 1.68E+17 n/cm2 Lower-Intermediate Shell (Shell #2) Axial Welds Thickness in inches = 6.1875                                             54 EFPY Peak I.D. fluence = 7.73E+17 n/cm2 54 EFPY Peak 1/4 T fluence = 5.33E+17 n/cm2 Lower Shell Plates Thickness in inches = 9.5000                                             54 EFPY Peak I.D. fluence = 4.20E+17 n/cm2 54 EFPY Peak 1/4 T fluence = 2.38E+17 n/cm2
                                                                                                                                                  $% !
                                                                                                                                                     
                                                                                                                                                                                
Lower-Intermediate Shell Plates Thickness in inches = 6.1875                                             54 EFPY Peak I.D. fluence = 1.28E+18 n/cm2 54 EFPY Peak 1/4 T fluence = 8.83E+17 n/cm2 Shell #1 to #2 Girth Weld Thickness in inches = 6.1875                                             54 EFPY Peak I.D. fluence = 4.20E+17 n/cm2 54 EFPY Peak 1/4 T fluence = 2.90E+17 n/cm2 Bottom of N6 LPCI Nozzle Thickness in inches = 6.1875                                             54 EFPY Peak I.D. fluence = 5.81E+17 n/cm2 54 EFPY Peak 1/4 T fluence = 4.01E+17 n/cm2 Bottom of N12 WLI Nozzle Thickness in inches = 6.1875                                             54 EFPY Peak I.D. fluence = 3.72E+17 n/cm2 54 EFPY Peak 1/4 T fluence = 2.57E+17 n/cm2 31
                                                                                     

                        
NEDO-33929 Revision 0 Non - Proprietary Information Table B-5         CGS Adjusted Reference Temperatures for up to 54 EFPY (continued)
COMPONENT                     HEAT OR               %Cu      %Ni     CF      Adjusted        Initial    1/4 T     54 EFPY   I      Margin    54     54 EFPY HEAT/LOT [1]                            &deg;F       CF &deg;F         RTNDT &deg;F   Fluence    RTNDT    &deg;F   &deg;F    &deg;F      EFPY    ART &deg;F n/cm2        &deg;F                        Shift
                                                                                                                                                            &deg;F PLATES:
Lower Shell Mk 21-1-1                C1272-1                     0.15    0.60    110                       28      2.38E+17     21       0   11     21      42       70 Mk 21-1-2                C1273-1                     0.14    0.60    100                       20      2.38E+17     19       0   10     19      38       58 Mk 21-1-3                C1273-2                     0.14    0.60    100                       4       2.38E+17     19       0   10     19      38       42 Mk 21-1-4                C1272-2                     0.15    0.60    110                       0       2.38E+17     21       0   11     21      42       42 Lower-Intermediate
                                                                                                                                                                              $% !
                                                                                                                                                                                 
                                                                                                                                                                                                            
Shell Mk 22-1-1 [2]            B5301-1                     0.13    0.50    88                       -20      8.83E+17     35       0   17     34      69       49 Mk 22-1-2                C1336-1 C1337-1             0.13    0.50    88                        -8      8.83E+17     35       0   17     34      69       61 Mk 22-1-3                C1337-2                     0.15    0.51    105                      -20      8.83E+17     41       0   17     34      75       55 Mk 22-1-4                                            0.15    0.51    105                      -20      8.83E+17     41       0   17     34      75       55 WELDS:
Lower Shell Axial BA, BB, BD               04P046 / D217A27A           0.06    0.90    82                       -48      1.68E+17     13       0    6     13      25       -23 BA, BB                   07L669 / K004A27A           0.03    1.02    41                       -50      1.68E+17      6       0    3     6       13       -37 BA, BB, BC, BD [7]       3P4966 / 1214 - 3482 (S)    0.025   0.913   34                       -30      1.68E+17      5       0    3     5       10       -20 BA, BB, BC, BD [7]       3P4966 / 1214 - 3482 (T)    0.025   0.913   34                       -48      1.68E+17      5       0    3     5       10       -38 BB, BC, BD               C3L46C / J020A27A           0.02    0.87    27                       -20      1.68E+17      4       0    2     4        8       -12 BB                       08M365 / G128A27A           0.02    1.10    27                       -48      1.68E+17      4       0    2     4        8       -40 BC                       09L853 / A111A27A           0.03    0.86    41                       -50      1.68E+17      6       0    3     6       13       -37 32
                                                                                               

                      
NEDO-33929 Revision 0 Non - Proprietary Information Table B-5           CGS Adjusted Reference Temperatures for up to 54 EFPY (continued)
COMPONENT                   HEAT OR               %Cu      %Ni     CF      Adjusted          Initial     1/4 T    54 EFPY   I      Margin    54     54 EFPY HEAT/LOT [1]                            &deg;F       CF &deg;F           RTNDT &deg;F    Fluence   RTNDT    &deg;F   &deg;F    &deg;F      EFPY    ART &deg;F n/cm2       &deg;F                        Shift
                                                                                                                                                            &deg;F Lower-Intermediate Shell Axial BE, BF, BG, BH [7]     3P4966 / 1214 - 3481 (S)    0.025   0.913   34                        -20       5.33E+17    10       0    5     10      21        1 BE, BF, BG, BH [7]     3P4966 / 1214 - 3481 (T)    0.025   0.913   34                         -6       5.33E+17    10       0    5     10      21       15 BF, BH                 04P046 / D217A27A           0.06    0.90    82                        -48       5.33E+17    25       0    12    25      50        2 BF                     05P018 / D211A27A           0.09    0.90    122                       -38       5.33E+17    37       0    18    37      74       36 BG                     624063 / C228A27A           0.03    1.00    41                        -50       5.33E+17    12       0    6     12      25       -25 BG                     624039 / D224A27A           0.07    1.01    95                        -36       5.33E+17    29       0    14    29      58       22
                                                                                                                                                                              $% !
                                                                                                                                                                                 
                                                                                                                                                                                                            
BH                     624039 / D205A27A           0.10    0.92    134                       -50       5.33E+17    41       0    20    41      81       31 Lower to Lower-Intermediate Girth AB                     492L4871 / A422B27AF        0.03    0.98    41                        -50       2.90E+17     9       0    4     9       18       -32 AB                     04T931 / A423B27AG          0.03    1.00    41                        -50       2.90E+17     9       0    4     9       18       -32 AB [6,7,9]             5P6756 / 0342-3447 (S)      0.08    0.936   108       154             -50       2.90E+17    33       0    14    28      61       11 AB [6,7,9]             5P6756 / 0342-3447 (T)      0.08    0.936   108       154             -50       2.90E+17    33       0    14    28      61       11 AB [7]                 3P4955 / 0342-3443 (S)      0.027   0.921   37                        -16       2.90E+17     8       0    4     8       16        0 AB [7]                 3P4955 / 0342-3443 (T)      0.027   0.921   37                        -20       2.90E+17     8       0    4     8       16        -4 33
                                                                                               

                        
NEDO-33929 Revision 0 Non - Proprietary Information Table B-5          CGS Adjusted Reference Temperatures for up to 54 EFPY (continued)
COMPONENT                      HEAT OR              %Cu      %Ni     CF      Adjusted          Initial    1/4 T     54 EFPY   I      Margin    54     54 EFPY HEAT/LOT [1]                           &deg;F       CF &deg;F           RTNDT &deg;F   Fluence    RTNDT    &deg;F   &deg;F    &deg;F      EFPY    ART &deg;F n/cm2        &deg;F                        Shift
                                                                                                                                                              &deg;F NOZZLES:
N6 (LPCI)
Nozzle [8]                Q2Q55W / 790S              0.11    0.76    76                         -20      4.01E+17     20       0   10     20      40       20 Weld [3,4,7,9]            5P6214B / 0331 (S)         0.019   0.828   27         58              -50      4.01E+17     15       0    8     15      30       -20 Weld [3,4,7,9]            5P6214B / 0331 (T)         0.019   0.828   27         58              -24      4.01E+17     15       0    8     15      30        6 N12 (WLI)
Nozzle [5,8]              219972 / 1                 0.272   0.214   136                        -20      2.57E+17     27       0   14     27      55       35
                                                                                                                                                                                $% !
                                                                                                                                                                                   
                                                                                                                                                                                                              
Nozzle [5,8]              718259 / 65363             0.25    0.24    130                        -20      2.57E+17     26       0   13     26      52       32 Weld                      Inco 82/182
: 1. For weld materials, S = single wire, T = tandem wire.
: 2. B5301-1 is the surveillance plate material; this chemistry represents the average of the Columbia Surveillance Capsule Report chemistry test results averaged with the baseline CMTR.
: 3. Adjusted CF is based on best estimate chemistry data.
: 4. CF is adjusted per BWRVIP-135 Revision 3 to be: 43.28*(27/20) = 58.43, where 43.28 is the fitted CF listed in the BWRVIP and 20 is the CF from the surveillance weld.
: 5. Material = 508 Class 1.
: 6. CF is adjusted per BWRVIP-135 Revision 3 to be: 116.9 * (108/82) = 153.97, where 116.9 is the fitted CF listed in the BWRVIP and 82 is the CF from the surveillance weld.
: 7. Best estimate chemistry data was considered from BWRVIP-135 Revision 3.
: 8. Nozzles are considered as plates versus welds.
: 9. Credible data so 1/2 margin term for  per BWRVIP-135 Revision 3 was considered.
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NEDO-33929 Revision 0 Non - Proprietary Information Table B-6         CGS RPV Beltline P-T Curve Input Values for 54 EFPY A = ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )) (limiting value for ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )))
A = ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )) (limiting value Adjusted RTNDT = Initial RTNDT + Shift                  for ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )))
A = ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )) (limiting value for ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )))
Vessel Height                                           H = 870.5 inches Bottom of Active Fuel Height                            B = 216.313 inches Vessel Radius (to base metal)                           R = 126.6875 inches Minimum Vessel Thickness (without clad)                 t = 6.1875 inches
             
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NEDO-33929 Revision 0 Non - Proprietary Information Table B-7         CGS Definition of RPV Beltline Region (1)
Component                                    Elevation (inches from RPV 0)
Shell # 2 - Top of Active Fuel (TAF)                                            366.3 Shell # 1 - Bottom of Active Fuel (BAF)                                         216.3 Shell # 2 - Top of Extended Beltline Region                                     382.5 Shell # 1 - Bottom of Extended Beltline Region                                  208.2 Circumferential Weld Between Shell #1 and Shell #2                              230.0 Circumferential Weld Between Shell #2 and Shell #3                              405.0 Centerline of Recirculation Outlet Nozzle N1 in Shell # 1                       172.5 Top of Recirculation Outlet Nozzle N1 in Shell # 1                              193.5 Centerline of Recirculation Inlet Nozzle N2 in Shell # 1                        181.0 Top of Recirculation Inlet Nozzle N2 in Shell # 1                               195.9 Centerline of LPCI Nozzle N6 in Shell # 2                                       372.5 Bottom of LPCI Nozzle N6 in Shell # 2                                           355.0 Centerline of Water Level Instrumentation Nozzle N12 in Shell # 2               366.0 Bottom of Water Level Instrumentation Nozzle N12 in Shell # 2                   364.8
: 1. The extended beltline region is defined as any location where the peak neutron fluence is expected to exceed or equal 1.0e17 n/cm2.
             
Based on the above, it is concluded that none of the CGS reactor vessel plates, nozzles, or welds, other than those included in the Adjusted Reference Temperature Table (Table B-5), are in the beltline region.
             
             
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NEDO-33929 Revision 0 Non - Proprietary Information
                                                                      
             
Appendix C                CGS Reactor Pressure Vessel P-T Curve Checklist Table C-1 provides a checklist that defines pertinent points of interest regarding the methods and information used in developing the CGS Pressure-Temperature Limits Report. This table demonstrates that all important parameters have been addressed in accordance with the P-T curve Licensing Topical Report (LTR) (Reference 2), and includes comments, resolutions, and clarifications as necessary.
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NEDO-33929 Revision 0 Non - Proprietary Information Table C-1       CGS Checklist Parameter                           Completed        Comments/Resolutions/Clarifications Initial RTNDT Initial RTNDT has been determined for CGS for             ~        The N12 water level instrumentation nozzle all vessel materials including plates, flanges,                    is considered within the beltline region. This forgings, studs, nuts, bolts, welds.                               forging was fabricated from ((` ` ` ` ` ` ` ` ` ` ` ` ` `
Include           explanation            (including                ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )). The initial RTNDT of the methods/sources) of any exceptions, resolution                     WLI nozzle forging materials (N12, N13, of discrepant data (e.g., deviation from                           and N14 with heat 219972 Lot 1) have been originally reported values).                                       updated to -20&deg;F according to the design basis documents.                       Additional details regarding this material and its properties are provided in Section 3.0 of this PTLR.
All other information remains unchanged from previous submittals.
Appendix B contains tables of all Initial RTNDT           ~
values for CGS.
Has any non-CGS initial RTNDT information                 ~        Plate heat B0673-1 information was obtained (e.g., ISP, comparison to other plant) been used?                  from the ISP database. This material is not the identical heat to the target vessel plate material and, in accordance with the ISP guidance; this data was not used in determining the limiting ART.
If deviation from the P-T curve LTR process               ~        Details regarding the determination of the occurred, sufficient supporting information has                    initial RTNDT of the N12 nozzle are provided been included (e.g., Charpy V-Notch data used                      in Section 3.0 of this PTLR.
to determine an Initial RTNDT).                                    No other deviations from the P-T curve LTR process.
All previously published Initial RTNDT values             ~        RVID was reviewed for the beltline from sources such as the GL88-01, Reactor                          materials; all initial RTNDT values agree; no Vessel Integrity Database (RVID), UFSAR,                           further review was performed.
etc., have been reviewed.
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NEDO-33929 Revision 0 Non - Proprietary Information Table C-1: CGS Checklist (continued)
Parameter                          Completed      Comments/Resolutions/Clarifications Adjusted Reference Temperature (ART)
Sigma I (I, standard deviation for Initial RTNDT)        ~        Sigma I is equal to 0 for all materials.
is 0&deg;F unless the RTNDT was obtained from a source other than CMTRs. If I is not equal to 0, reference/basis has been provided.
Sigma  (, standard deviation for RTNDT) is            ~
determined per RG 1.99, Revision 2.
Chemistry has been determined for all vessel              ~        Sufficient information was not available to beltline materials including plates, forgings (if                  determine the chemistry content for the N12 applicable), and welds for CGS.                                    water       level      instrumentation                       nozzle materials. ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` `
Include explanation (including methods/sources)
                                                                                  ````````````````````````````````````````````
of any exceptions, resolution of discrepant data
                                                                                  ` ` ` ` )). More information is provided in (e.g., deviation from originally reported values).
Section 3.0.
No deviations from previously reported values.
Non-CGS chemistry information (e.g., ISP,                 ~        Weld heats 5P6756, 3P4955, 3P4966, and comparison to other plant) used has been                           5P6214B have been evaluated using best adequately defined and described.                                  estimate chemistry from the ISP.
For any deviation from the P-T curve LTR                  ~        No deviations from the P-T curve LTR process, sufficient information has been                           process.
included.
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NEDO-33929 Revision 0 Non - Proprietary Information Table C-1: CGS Checklist (continued)
Parameter                          Completed      Comments/Resolutions/Clarifications All previously published chemistry values from            ~        RVID was reviewed; all initial RTNDT values sources such as the GL88-01, Reactor Vessel                        agree; no further review was performed Integrity Database (RVID), UFSAR, etc., have been reviewed.
The fluence used for determination of ART and             ~        One (1) NRC-approved methodology any extended beltline region was obtained using                    (Reference 1) was used for the entire plant an NRC-approved methodology.                                       license.
The fluence calculation provides an axial                 ~
distribution to allow determination of the vessel elevations that experience fluence of 1.0e17 n/cm2 both above and below active fuel.
The fluence calculation provides an axial                 ~
distribution to allow determination of the fluence for intermediate locations such as the beltline girth weld (if applicable) or for any nozzles within the beltline region.
All materials within the elevation range where            ~
the vessel experiences a fluence 1.0e17 n/cm2 have been included in the ART calculation. All initial RTNDT and chemistry information is available or explained.
Discontinuities The discontinuity comparison has been                     ~        There are no deviations.
performed as described in Section 4.3.2.1 of the P-T curve LTR. Any deviations have been explained.
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NEDO-33929 Revision 0 Non - Proprietary Information Table C-1: CGS Checklist (continued)
Parameter                           Completed        Comments/Resolutions/Clarifications Discontinuities requiring additional                       ~
components (such as nozzles) to be considered part of the beltline have been adequately described. It is clear which curve is used to bound each discontinuity.
Appendix G of the P-T curve LTR describes                  ~        The thickness discontinuity evaluation the process for considering a thickness                             demonstrated that ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` `
discontinuity, both beltline and non-beltline. If                   ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )); the curves ((` ` ` ` ` ` ` ` ` ))
there is a discontinuity in the CGS vessel that                     the discontinuity stresses.
requires such an evaluation, the evaluation was performed. The affected curve was adjusted to bound the discontinuity, if required.
Appendix H of the P-T curve LTR defines the                ~
basis for the CRD Penetration curve discontinuity and the appropriate transient application. The CGS evaluation bounds the requirements of Appendix H.
Appendix J of the P-T curve defines the basis              ~
for the Water Level Instrumentation Nozzle curve discontinuity and the appropriate transient application. The CGS evaluation bounds the requirements of Appendix J.
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NEDO-33929 Revision 0 Non - Proprietary Information
             
Appendix D                                   Sample P-T Curve Calculations Beltline Water Level Instrumentation Nozzle Pressure Test (Curve A) for 54 EFPY KI for the discontinuity is determined considering the KI obtained from Table 7 of Appendix J of Reference 2 (for hydrotest). For 1050 psig, this KI is scaled by pressure as follows:
((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ))
T-RTNDT is calculated in the following manner:
((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ))
The ART is added to T-RTNDT to obtain the required T:
((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ))
This temperature is not found from Table 1 as it ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )) the temperature requirements for ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )).
Core Not Critical (Curve B) for 54 EFPY KI for the discontinuity is determined considering the KI obtained from Table 5 of Appendix J of Reference 2.
KI(pressure)                 =              ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ))
KI(thermal)                  =              ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ))
The transient used for the WLI nozzle, defined in Appendix J, is used in determination of KI.
The total KI is therefore:
((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` `
             ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ))
T-RTNDT is calculated in the following manner:
((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ))
The ART is added to T-RTNDT to obtain the required T:
((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ))
This temperature is not found from Table 1 as it ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )) the temperature requirements for ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )).
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NEDO-33929 Revision 0 Non - Proprietary Information Correction Factor The total stress for the WLI nozzle exceeds the yield stress; therefore, the correction factor, R, is calculated to consider the nonlinear effects in the plastic region. The R factor adjustment for the WLI nozzle is based on the assumptions and recommendation of Welding Research Council (WRC)
Bulletin 175 (Reference 8) that provides the technical background for Appendix G (Fracture Toughness Criteria for Protection Against Failure) of ASME Boiler & Pressure Vessel Code Section XI. WRC Bulletin 175 proposes the methodology how to estimate the stresses when the secondary and peak stresses calculated on an elastic basis exceed the yield stress. This is to consider the nonlinear effects in the local plastic region. However, for the application to WLI nozzle, ((` ` ` ` ` ` ` ` ` `
             ```````````````````````````````````````````````````````````````````````````````````````````````````
             ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )) The technical detail for this method is described in Section 5.C.3 of WRC Bulletin 175. The applicability of this procedure to pressure vessel was studied in a Pressure Vessels & Piping (PVP) Conference paper (Reference 9). For example, the R factor under the pressure of 1050 psig is calculated below in accordance with the Equation 4-7 of Reference 2.
R              =              [ys - pm + ((total - ys)/30)]/(total - pm)
Applied to the WLI nozzle:
((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` `
                            ` ` ` ` ` ` ` ` ` ` ` ))
R factor values for WLI nozzle over the entire pressure range are shown as follows.
Pressure (psig)                    ys (ksi)             pm (ksi)             total (ksi)              R Factor [1]
((`                        ````                ````                     `````                       `````
                                                 ```                        ````                ````                     `````                       `````
                                                 ```                        ````                ````                     `````                       `````
                                                 ```                        ````                ````                     `````                       `````
                                                 ```                        ````                ````                     `````                       `````
                                                 ```                        ````                `````                    `````                       `````
                                                 ```                        ````                `````                    `````                       `````
                                                 ```                        ````                `````                    `````                       `````
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NEDO-33929 Revision 0 Non - Proprietary Information Pressure (psig)                    ys (ksi)             pm (ksi)                 total (ksi)    R Factor [1]
                                                ```                   ````             `````               `````    `````
                                                ```                   ````             `````               `````    `````
                                               ````                  ````             `````               `````    `````
                                               ````                  ````             `````               `````    `````
                                               ````                  ````             `````               `````    `````
                                               ````                  ````             `````               `````    `````
                                               ````                  ````             `````               `````    `````
                                                               
             ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ))
             
Beltline Calculations Excluding Nozzles Pressure Test (Curve A) at 1020 psig for 54 EFPY A sample calculation for the beltline material, not including the N12 WLI nozzle, for Curve A is provided for 1020 psig as follows.
The ART applied to the beltline P-T curves is ((` ` ` ` ` ` ` ` )), for ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )).
Pressure is calculated to include hydrostatic pressure for a full vessel:
P              =             1020 psig + (H - B)
* 0.0361 psi/inch (H = vessel height; B = elevation of bottom of active fuel)
                            =             1020 + (870.5 - 216.313)
* 0.0361
                            =             1044 psig Pressure Stress:
                           =             PR/t (P = pressure; R = vessel radius; t = vessel thickness)
                            =             1.044
* 126.6875 / 6.1875
                            =             21.37 ksi 44
                                                                                                           

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NEDO-33929 Revision 0 Non - Proprietary Information Mm             =             0.926
* t                    (for 2  t  3.464)
                            =             0.926
* 6.1875
                            =             2.30 The stress intensity factor, KIt, is calculated as described in Section 4.3.2.2.4 of Reference 2, except that G is 20&deg;F/hr instead of 100&deg;F/hr.
Mt             =             0.2914, from ASME Appendix G, Figure G-2214-1 T             =             GC2 / 2 G = coolant heatup/cooldown rate of 20&deg;F/hr C = minimum vessel thickness including clad = 6.3125 = 0.526 ft
                                           = thermal diffusivity at 550&deg;F = 0.354 ft2/hr
                            =             (20 * (0.526)2) / (2
* 0.354)
                            =             7.816&deg;F KIt            =             Mt
* T
                            =             0.2914
* 7.816
                            =             2.28 KIm            =
* Mm
                            =             21.37
* 2.30
                            =             49.15 T-RTNDT                      =              ln[(1.5
* KIm + KIt - 33.2) / 20.734] / 0.02
                                          =              ln[(1.5
* 49.15 + 2.28 - 33.2) / 20.734] / 0.02
                                          =              36.2&deg;F T is calculated by adding the ART:
T              =             ((` ` ` ` ` ` ` ` ` ` ` ` ` ))
                            =             ((` ` ` ` ` ` ` ` ` ` ` ))                             for P = 1020 psig at 54 EFPY This temperature is not obvious from the P-T curves as it ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` `
             ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )).
Core Not Critical (Curve B) at 1020 psig for 54 EFPY As discussed above and shown in Table B-5, the ART applied to the beltline Curve B is ((` ` ` ` ` ` ` `
             )) for ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )).
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NEDO-33929 Revision 0 Non - Proprietary Information The T term is calculated as shown above for the Pressure Test case, but the temperature rate change is 100&deg;F/hr instead of 20&deg;F/hr. Therefore, T equals 39&deg;F.
P              =             1020 psig + (H - B)
* 0.0361 psi/inch (H = vessel height; B = elevation of bottom of active fuel)
                            =             1020 + (870.5 - 216.313)
* 0.0361
                            =             1044 psig Pressure Stress:
                           =             PR/t (P = pressure; R = vessel radius; t = vessel thickness)
                            =             1.044
* 126.6875 / 6.1875
                            =             21.37 ksi KIm            =
* Mm
                            =             21.37
* 2.30
                            =             49.15 KIt            =             Mt
* T (for the 100&deg;F/hr case)
                            =             0.2914
* 39
                            =             11.36 T-RTNDT                      =              ln [(2.0
* KIm + KIt - 33.2) / 20.734] / 0.02
                                          =              ln [(2.0
* 49.15 + 11.36 - 33.2) / 20.734] / 0.02
                                          =              65.2&deg;F T is calculated by adding the ART:
T              =             ((` ` ` ` ` ` ` ` ` ` ` ` ` ))
                            =             ((` ` ` ` ` ` ` ` ` ` ` ))                     for P = 1020 psig at 54 EFPY This temperature is not obvious from the P-T curves as it ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` `
             ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )).
             
             
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NEDO-33929 Revision 0 Non - Proprietary Information Feedwater Nozzle Calculations An evaluation was performed for the feedwater nozzle as described in Section 4.3.2.1.3 of the Reference 2. The first part of the evaluation is as described earlier, where it is assured that the limiting component that is represented by the upper vessel curve is bounded by the ((shell discontinuities {3})). A second evaluation was performed using the CGS-specific feedwater nozzle dimensions; this evaluation is shown below to demonstrate that the baseline curve is applicable to CGS:
Vessel radius to base metal, Rv                                                                                        ((` ` ` ` ` ` ` ` ` ` ` `
Vessel thickness, tv                                                                                                   `````````````
Vessel pressure, Pv                                                                                                    `````````
Pressure stress = PR/t = ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ))` ` ` ` ` ` ` ` ` ` `
Dead Weight + Thermal Restricted Free End stress                                                                       `````````
Total Stress = ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ))                                                          ` ` ` ` ` ` ` ` ` ` ` ` ` ))
The factor F(a/rn) from Figure A5-1 of PVRC Recommendations on Toughness Requirements for Ferritic Materials, WRC-175 is determined where:
a = 1/4 * (tn2 + tv2) 1/2                                                                                                    ((` ` ` ` ` ` ` ` ` ` `
tn = thickness of nozzle                                                                                                 ````````````
tv = thickness of vessel                                                                                                 `````````````
rn = apparent radius of nozzle = ri + 0.29*rc                                                                            ````````````
ri = actual inner radius of nozzle                                                                                       ``````````
rc = nozzle radius (nozzle corner radius)                                                                                ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ))
Therefore, a/rn = ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )). The value F(a/rn), taken from Figure A5-1 of WRC-175 for an ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )). Including the safety factor of 1.5, the stress intensity factor, KI, is 1.5  (a)1/2
* F(a/rn):
CGS Plant-Specific Nominal KI = 1.5 * ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ))
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NEDO-33929 Revision 0 Non - Proprietary Information A detailed upper vessel example calculation for core not critical conditions is provided in Section 4.3.2.1.4 of the Reference 2. Section 4.3.2.1.3 of the Reference 2 defines the baseline nominal KI to be ((` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` ` )) for the FW nozzle evaluation upon which the baseline non-shifted upper vessel P-T curve is based. It can be seen that the nominal KI from this CGS evaluation is ((` ` ` ` ` `
             ` ` ` ` ` ` ` ` ` ` ` ` ` ` )). Therefore, it has been shown that the nominal KI for the CGS-specific FW nozzle is less than the baseline KI, demonstrating applicability of the FW nozzle curve for CGS.
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GO2-21-016 Enclosure 6 GEH and EPRI Affidavits Requesting Withholding of GEH Report NEDC-33929P, Revision 0

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GE-Hitachi Nuclear Energy Americas LLC AFFIDAVIT I, Michelle P. Catts, state as follows:
(1) I am the Senior Vice President Nuclear Programs, GE-Hitachi Nuclear Energy Americas LLC (GEH), 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 GEH proprietary report NEDC-33929P, Energy Northwest Columbia Generating Station Pressure and Temperature Limits Report (PTLR) up to 54 Effective Full-Power Years, Revision 0, dated November 2020. GEH proprietary information in NEDC-33929P Revision 0 is identified by a dotted underline inside double square brackets. ((This sentence is an example.{3})). GEH proprietary information in figures and large objects is identified by 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 or licensee, GEH relies upon the exemption from disclosure set forth in the Freedom of Information Act (FOIA), 5 U.S.C. &sect;552(b)(4), and the Trade Secrets Act, 18 U.S.C.
                    &sect;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 qualifies 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, 975 F.2d 871 (D.C. Cir. 1992), and Public Citizen Health Research Group v. FDA, 704 F.2d 1280 (D.C. Cir. 1983).
(4) The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a and (4)b. Some examples of categories of information that 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 GEH's competitors without a license from GEH constitutes a competitive economic advantage over other companies;
: b. Information that, if used by a competitor, would reduce its expenditure of resources or improve its competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;
: c. Information that reveals aspects of past, present, or future GEH customer-funded development plans and programs, resulting in potential products to GEH;
: d. Information that discloses trade secret or potentially patentable subject matter for which it may be desirable to obtain patent protection.
NEDC-33929P Revision 0                                                              Affidavit Page 1 of 3

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GE-Hitachi Nuclear Energy Americas LLC (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 GEH, 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 GEH, not been disclosed publicly, and not been made available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions for proprietary or confidentiality agreements or both that provide for maintaining the information in confidence. The initial designation of this information as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in the following paragraphs (6) and (7).
(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, who is the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or who is the person most likely to be subject to the terms under which it was licensed to GEH.
(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 for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GEH 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 and/or confidentiality agreements.
(8) The information identified in paragraph (2) is classified as proprietary because it contains the detailed GEH methodology for pressure-temperature curve analysis for the GEH Boiling Water Reactor (BWR). These methods, techniques, and data along with their application to the design, modification, and analyses associated with the pressure-temperature curves were achieved at a significant cost to GEH.
The development of the evaluation processes along with the interpretation and application of the analytical results is derived from the extensive experience databases that constitute a major GEH asset.
(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GEH's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GEH'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.
NEDC-33929P Revision 0                                                           Affidavit Page 2 of 3

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GE-Hitachi Nuclear Energy Americas LLC The research, development, engineering, analytical and NRC review costs comprise a substantial investment of time and money by GEH. 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. GEH's competitive advantage will be lost if its competitors are able to use the results of the GEH 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 GEH would be lost if the information were disclosed to the public. Making such information available to competitors without there having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall and deprive GEH of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable analytical tools.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on this 16th day of November 2020.
l               r
                                                                                 -6 Michelle P. Catts Senior Vice President Nuclear Programs GE-Hitachi Nuclear Energy Americas, LLC 3901 Castle Hayne Road Wilmington, NC 28401 michelle.catts@ge.com NEDC-33929P Revision 0                                                            Affidavit Page 3 of 3

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EP121 I                ELECTRIC POWER RESEARCH INSTITUTE 2020-098                                                            BWR Vessel & Internals Project (BWRVIP)
November 16, 2020 Rick Garcia Energy Northwest rmgarcia@energy-northwest.com

==Subject:==
Transmittal of EPRI Proprietary Affidavit to Energy Northwest

==Dear Mr. Garcia:==

The purpose of this letter is to transmit the EPRI proprietary affidavit for transmittal of the following document to the NRC:
Energy Northwest/Columbia Generating Station Pressure and Temperature Limits Report (PTLR) up to 54 Effective Full Power Years, NEDC-33929P, Revision 0 Please note that the document referenced above contains EPRI proprietary information. A letter requesting that the report be withheld from public disclosure and an affidavit describing the basis for withholding this information are provided as Attachment 1.
If you have any questions on this subject, please contact me by telephone at 724-288-4043 or by e-mail at npalm@epri.com.
Sincerely, Nathan Palm EPRI, BWRVIP Program Manager Together ... Shaping the Future of Electricity CHARLOTTE OFFICE 1300 West W.T. Harris Boulevard, Charlotte, NC 28262-8550 USA
* 704.595 .2000
* Customer Service 800.313 .377 4
* www.epri .com

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1 ELECTRIC POWER RESEARCH INSTITUTE AFFIDAVIT RE:      Request for Withholding of the Following Proprietary Information Included In:
Energy NorthwesUColumbia Generating Station Pressure and Temperature Limits Report (PTLR) up to 54 Effective Full Power Years, NEDC-33929P, Revision 0 I, Steve Chengelis, being duly sworn, depose and state as follows:
I am the Director of Plant Support at Electric Power Research Institute, Inc. whose principal office is located at 3420 Hillview Avenue, Palo Alto, California ("EPRI") and I have been specifically delegated responsibility for the above-listed Report which 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 with text underlined inside double square brackets. Examples of such identification is as follows:
f[This sentence is an example{El]l Tables containing EPRI Proprietary Information are identified with double square brackets before and after the object. In each case the superscript notation {El refers to this affidavit and all the bases included below, which provide the reasons for the proprietary determination.
EPRI requests that the Proprietary Information be withheld from the public on the following bases:
Withholding Based Upon Privileged And Confidential Trade Secrets Or Commercial Or Financial Information (see e.g. 10 C.F.R. &sect;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.

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: 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.          EPRl'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 &sect;&sect;3426 - 3426.11, 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) Is 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 Propretary 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 EPRl's competitive position and the ability of EPRI to license the Proprietary Information both domestically and internationally. The Proprietary Information and Report 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, Charlotte, NC being the premises and place of business of Electric Power Research Institute, Inc.
Stev'e "Chengeif

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(State of North Carolina)
(County of Mecklenburg)}}