View source for PY-CEI-NRR-2420, Application for Amend to License NPF-58,increasing Present 100% Authorized Rated Thermal Power Level of 3579 Megawatts Thermal to 3758 Megawatts Thermal.Proprietary SAR Encl. Proprietary SAR Withheld,Per 10CFR2.790(a)(4)

{{Adams
| number = ML20211P282
| issue date = 09/09/1999
| title = Application for Amend to License NPF-58,increasing Present 100% Authorized Rated Thermal Power Level of 3579 Megawatts Thermal to 3758 Megawatts Thermal.Proprietary SAR Encl. Proprietary SAR Withheld,Per 10CFR2.790(a)(4)
| author name = Wood J
| author affiliation = CENTERIOR ENERGY
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000440
| license number = 
| contact person = 
| document report number = PY-CEI-NRR-2420, NUDOCS 9909130176
| package number = ML20138D182
| document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS &amp; PERMITS
| page count = 14
| project = 
| stage = Request
}}

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I ame=wa==-mam wcav v' C                                                                              Perry Nudear Power Plant p ,        44 John K. Wood Vee Premdent, Nudear                                                                                           440-280-5224 Fax:440-280-8029 September 9,1999 PY-CEl/NRR-2420L United States Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Perry Nuclear Power Plant Docket No. 50-440 License Amendment Request Pursuant to 10 CFR 50.90: Implementation of Power Uprate Ladies and Gentlemen:
Nuclear Regulatory Commission review and approval of a license amendment for the Perry Nuclear Power Plant (PNPP) is requested. The proposed amendment would increase the present 100% authorized rated thermal power level of 3579 megawatts thermal to 3758 megawatts thermal. This represents a power levelincrease of 5% for the PNPP.
The analysis performed for this license amendment supports implementation of the power uprate at PNPP anytime during Cycle 8 operation. Implementation of the proposed increase in power level is planned for the middle of Cycle 8. Therefore, in order to support the increased demand for electric power in the summer months, it is requested that the proposed license amendment be approved no later than May 1, 2000.
The power uprate project is an ongoing program. Presently the changes required by power uprate to the Updated Safety Analyses are being reviewed and evaluated.
Although not expected, there is a slight possibility that these reviews could result in a future submittal (s) to the NRC staff for their review. If such a possibility arises, the submittal (s) will be made in a timely fashion to permit the NRC sufficient review time.
Attachment 1 provides the " Safety Analysis Report For Perry 5% Thermal Power Uprate," NEDC-32907P, prepared by General Electric for the FirstEnergy Nuclear Operating Company. The description of the proposed changes necessary for power uprate operation and the technical bases for the changes are contained within gpg Attachment 1. Also within Attachment 1 is an environmental consequences evaluation                       \\
and information supporting the determination that the proposed changes do not involve a significant hazards consideration.
Attachment 2 provides the annotated Technical Specification pages reflecting the proposed change.
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PY-CEl/NRR-2420L September 9,1999 Page 2 of 2 Some of the power related numbers in the Technical Specifications are not being changed by this license amendment. As part of the power uprate analysis it was determined that power uprate does not influence the numbers involved. A list of these items, along with a brief explanation, is given in Attachment 3. provides the annotated Technical Specifications Bases pages for information. Since the Technical Specifications Bases are not part of the Technical Specifications, this attachment is only provided for information. contains material that General Electric considers proprietary information as described in 10 CFR 2.790(a)(4) for which an affidavit is provided. Hence,  provides a request from GE that information provided in Attachment 1 is withheld from disclosure. Stand-alone GE proprietary information is contained in this attachment and is illustrated by side bars in the right hand margin next to the text, figures and tables containing the proprietary information. contains a list of commitments identified from Attachment 1.
If you have questions or require additionalinformation, please contact Mr. Henry L. Hegrat, Manager - Regulatory Affairs, at (440) 280-5606.
I Very t ly youra, 4v f r John .W      d Attachments Attachment 1 contains 2.790(a)(4)
                                                          #    '"'*"""''*"'Id*"
cc:     NRC Project Manager NRC Resident inspector by sidebars. Upon remwal M NRC Region 111 Proprietary Information from State of Ohio                         Attachment 1, the remainder of Attachment 1 may be disclosed.

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l I, Howard W. Bergendahl, hereby affirm that (1) I am Director, Perry Nuclear Services      j Department of the FirstEnergy Nuclear Operating Company, (2) I am duly authorized to       l execute and file this certification on behalf of The Cleveland Electric Illuminating       ;
Company and Toledo Edison Company, and as the duly authorized agent for Duquesne           !
Light Company, Ohio Edison Company, and Pennsylvania Power Company, and (3) the            i statements set forth herein are true and correct to the best of my knowledge, information  j and belief.
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                                                           / "Hofard W. Bergendahl 1
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Subscribed to and affirmed before me, the             day of       ag&* lu~          . /9W
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                                                                    ' JANE E. MOTT My co% Pub'ie.ShesW%
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l                                Att:chmsnt 5 PY-CEl/NRR-2420L Page 1 of 6 1
GENERAL ELECTRIC COMPANY l   REQUEST FOR PROPRIATARY INFORMATION TO BE 1
WITHHELD FOR DISCLOSURE (AFFIDAVIT) l l

<                                                                     Att: chm:nt 5 PY-CEl/NRR-2420L Page 2 of 6 General Electric Company AFFIDAVIT I, David J. Robare, being duly swom, depose and state as follows:
(1) I am Technical Account Manager, Technical Services, General Electric Company
("GE") and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld, and have been authorized to apply for its withholding.
(2) The information sought to be withheld is contained in the GE proprietary report NEDC-32907P, DRF A22-00084-53, Safety Analysis Reportfor Perry 5% Thermal Power Uprate, Class III (GE Proprietary Information), dated September 1999. This document, taken as a whole, constitutes a proprietary compilation of information, some of it also independently proprietary, prepared by the General Electric Company. The independently proprietary elements are identified by bars marked in the margin adjacent to the specific material.
(3) In making this application for withholding of proprietary information of w' ich it is the owner, GE relies upon the exemption from disclosure set forth in the F a iom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets As t,18 USC Sec.1905, and NRC regulations 10 CFR 9.17(a)(4), 2.790(a)(4), ud 2.790(d)(1) for " trade secrets and commercial or finodal information obtained from a person and privileged or confidential" (Exemption 4). The material for which exemption from disclosure is here sought is all " confidential commercial information", and some portions also qualify under the narrower definition of " trade             i secret", within the meanings assigned to those terms for purposes of FOIA                         I Exemption 4 in, respectively, Critical Mass Energy Proiect v. Nuclear Reculatory                  l Commission. 975F2d871 (DC Cir.1992), and Public Citizen H_ealth Research Group
: v. FDA,704F2dl280 (DC Cir.1983).
(4) Some examples of categories of information which fit into the definition of proprietary information are:
: a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention ofits use by General Electric's competitors without license from General Electric constitutes a competitive economic advantage over other companies; Affidavit Page 1 s

Attachmsnt 5 PY-CEl/NRR-2420L Page 3 of 6
: b.      Information which, if used by a competitor, would reduce his expenditure of l               resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product; l'      c.      Information which reveals cost or price information, production capacities, l
budget levels, or commercial strategies of General Electric, its customers, or its suppliers; l       d.     .Information which reveals aspects of past, present, or future General Electric l               customer-funded development plans and programs, of potential commercial value to General Electric;
: e.      Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.
Both the compilation as a whole and the marked independently proprietary elements                      !
incorporated in that compilation are considered proprietary for the reason described                    I in items (4)a. and (4)b., above.
(5) The information sought to be withheld is being submitted to NRC in confidence.
That information (both the entire body of information in the form compiled in this                      l document, and the marked individual proprietary elements) is of a sort customarily held in confidence by GE, and has, to the best of my knowledge, consistently been held in confidence by GE, has not been publicly disclosed, and is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be 'made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent                     l steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.
(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to such documents within GE is limited on a "need to know" basis.
(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside GE are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the infonnation, and then only in accordance with appropriate regulatory provisions or proprietary agreements.
Affidavit Page 2

Attichm:nt 5 PY-CEl/NRR-2420L Page 4 of 6 (8) The information identified by bars in the margin is classified as proprietary because it contains detailed results and conclusions from these evaluations, utilizing analytical models and methods, including computer codes, which GE has developed, obtained NRC approval of, and applied to perform evaluations of transient and accident events in the GE Boiling Water Reactor ("BWR"). The development and approval of these system, component, and thermal hydraulic models and computer codes was achieved at a significant cost to GE, on the order of several million dollars.
;     . The remainder of the information identified in paragraph (2), above, is classified as proprietary because it constitutes a confidential compilation of information, including detailed results of analytical models, methods, and processes, including computer codes, and conclusions from these applications, which represent, as a
       .whole, an integrated process or approach which GE has developed, obtained NRC approval of, and applied to perform evaluations of the safety-significant changes necessary to demonstrate the regulatory acceptability of a given increase in licensed power output for a GE BWR. The development and approval of this overall approach was achieved at a significant additional cost to GE, in excess of a million dollars, over and above the very large cost of developing the underlying individual proprietary analyses.
To effect a change to the licensing basis of a plant requires a thorough evaluation of the impact of the change on all postulated accident and transient events, and all other regulatory requirements and commitments included in the plant's FSAR. The analytical process to perform and document these evaluations for a proposed power uprate was developed at a substantial investment in GE resources and expertise. The results from these evaluations identify those BWR systems and components, and those postulated events, which are impacted by the changes required to accommodate operation at increased power levels, and, just as importantly, those which are nat so impacted, and the technical justification for not considering the latter in changing the licensing basis. The scope thus determined forms the basis for GE's offerings to support utilities in both performing analyses and providing licensing consulting services. Clearly, the scope and magnitude of effort of any attempt by a competitor to effect a similar licensing change can be narrowed considerably based upon these results. Having invested in the initial evaluations and developed the solution strategy and process described in the subject document GE derives an important competitive advantage in selling and performing these services.
However, the mere knowledge of the impact on each system and component reveals                  i the process, and provides a guide to the solution strategy.
(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GE's competitive position and foreclose or reduce the availability of profit-making opportunities. The infomiation is past of GE's comprehensive l
BWR technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive AfEdavit Page 3

Attachment 5 PY-CEl/NRR-2420L Page 5 of 6 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, including justifications for not including certain analyses in applications to change the licensing basis.
GE's competitive advantage will be lost ifits competitors are able to use the results of the GE experience to avoid fruitless avenues, or to normalize or verify their own process, or to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions. In particular, the specific areas addressed by any document and submittal to support a change in the safety or licensing bases of the plant will clearly reveal those areas where detailed evaluations must be performed and specific analyses revised, and also, by omission, reveal those areas pm so affected.
While some of the underlying analyses, and some of the gross structure of the                     j process, may at various times have been publicly revealed, enough of both the                     '
analyses and the detailed structural framework of the process have been held in confidence that this information, in this compiled form, continues to have great competitive value to GE. This value would be lost if the information as a whole, in the context and level of detail provided in the subject GE document, were to be disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources, including that required to determine the areas that are no_t affected by a power uprate and are therefore blind alleys, would unfairly provide competitors with a windfall, and deprive GE of the opportunity to exercise its competitive advantage to seek an adequate retum on its large investment in developing its analytical process.
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Affidavit Page 4

g Att chm:nt 5 PY-CEl/NRR-2420L Page 6 of 6 STATE OF CALIFORNIA                   )                                                                     l
                                        )       ss:                                                          i COUNTY OF SANTA CLARA                 )
David J. Robare, being duly sworn, deposes an;d says:
That he has read the foregoing aflidavP. and the matters stated therein are true and correct               i to the best of his knowledge, informe. ion, and belief.                                                    l Executed at San Jose, California, this 8       day of 59Tep18at               1999.                        ;
David J. Robare General Electric Company                             I i
l Subscribed and sworn before me this 8 day of             M                   1999.
Notary Public, State of California ANNA HANUN           y Commission # 1184507 j            Notcy Public-CoEfomia . l Santa Clara County    ?
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Affidavit Page 5 l

I Att chm:nt 6 PY-CEl/NRR-2420L Page 1 of 4 COMMITMENTS IDENTIFIED FROM THE SAFETY ANALYSIS REPORT (ATTACHMENT 1) i

p Attrchmtnt 6 l                                                                           PY-CEl/NRR-2420L Page 2 of 4 l
L COMMITMENTS WITHIN THIS LETTER The Safety Analysis Report (Attachment 1) was prepared by General Electric to support l- this amendment request for the Perry Nuclear Power Plant. The following list identifies those actions from the Safety Analysis Report, which are considered to be regulatory commitments by the Perry Nuclear Power Plant Staff. Any other actions discussed in the Safety Analysis Report represent intended or planned actions, are described for the NRC's information, and are not regulatory commitments. Please notify the Manager -
Regulatory Affairs at the Perry Nuclear Power Plant of any questions regarding this document or any associated regulatory commitments.
Commitments l   1. Perry is implementing long term stability Option Ill. The Option lli solution monitors l       Oscillation Power Range Monitor (OPRM) signals to determine when a reactor
:      scram is required. The OPRM signal is evaluated by the Option ill stability algorithms to determine when the signal is becoming st?iciently periodic and large
;       to warrant a reactor scram to disrupt the oscillation. The OPRM system may only l
cause a scram when plant operation is in the Option ill Armed Region. The Armed Region will be defined in plant procedures and will be added to the Perry power / flow operating map (Figure 2-1). The Armed Region will be modifed for power uprate operation to maintain the pre-uprate absolute power and flow
.      - coordinates. The stability based Minimum Critical Power Ratio (MCPR) l       calculations show no significant changes from the pre-uprate conditions.
: 2. Any erosion / corrosion attribute changes related to power uprate will be encompassed by the on-going monitoring program. Appropriate changes to predictive modeling and resulting changes to piping inspection frequency will be
       - implemented to ensure adequate margin exists for those systems with changing process conditions.
: 3. The supports of the systems with the most significant loading increases (Main Steam, Feedwater, and Feedwater influenced branch lines) were reviewed to determine if there is sufficient margin to Code acceptance criteria to accommodate the increased loadings. This review showed that, in most cases, pipe supports affected by power uprate conditions are in compliance with appropriate Code criteria. For those supports that are not within the code acceptance criteria, additional rigorous detailed calculations will be done to justify compliance to code requirements. If necessary, minor support modifications may be needed to accommodate the increased loadings d.e to power uprate. All acceptance justification analysis and/or remedial modifications, if necessary, will be completed prior to exceeding the current licensed power.

r Attachmtnt 6 PY-CEl/NRR-2420L Page 3 of 4 Commitments 1
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: 4. Speedic Electrohydraulic Control (EHC) and Steam Bypass Pressure Control System (SBPCS) tests will be performed during the 105% power ascension phase. These
       . tests are summarized in Section 10.4 of the Safety Analysis Report (SAR).
l  S. The Feedwater Control System (FWCS) is adequate to support uprated power as l       will be demonstrated by the power ascension testing performed during the 105%
l'      power uprated startup. The span of the feedwater flow instrumentation is capable of measuring in excess of 105% of the power uprated steam and feedwater flow rates. The FWCS will be recalibrated, rescaled and retuned as necessary to provide stable and responsive operation up to the uprated condition. FWCS " fine tuning" will be done during the 105% power uprate power ascension test phase.
: 6. The analyticallimit for power uprate remains at 140% of the rated steam flow. The
!       instrumentation will be recalibrated for the higher steam flow condition, and the setpoint will be adjusted appropriately as identified in Table 5-1. The adjustment ensures that sufficient pressure margin to the trip setpoint exists to allow for normal plant testing of the main steam isolation valves (MSIVs) and the turbine stop and control valves.
: 7. . Compared to the initial startup program, and consistent with the NRC-approved
!       generic power uprate guidelines in Reference 1, power uprate requires only a limited       i subset of the original startup test program. As applicable to this plant's design, testing j l       for power uprate will be consistent with the descriptions in Section 5.11.9 and            l
,       Appendix L, Section L2 of Reference 1. Specifically, the following testing will be         l l       performed prior to or at the time of implementation of power uprate, depending on plant alignment. This philosophy will accommodate power uprate during Cycle 8.
: a. Surveillance testing will be performed on the instrumentation that requires recalibration for power uprate in addition to the testing performed according to the plant Technical Specifications schedule.                                        l
: b. Steady-state data will be taken at points from 90% up to the previous rated thermal power, so that system performance parameters can be projected for l
uprated power before the previous power rating is exceeded
!          c. ~ Power increases beyond the previous rating will be made along an established flow control / rod line in increments of 5 3% power. Steady-state operating data, including fuel thermal margins will be taken and evaluated at each step.
: d. Control system tests will be performed for the feedwater/ reactor water level controls and pressure controls. These operational tests will be made at the appropriate plant conditions for that test, and at each power increment above the previous rated power condition, to show acceptable adjustments and operational capability.
The same performance criteria will be used as in the original power ascension tests, unless they have been replaced by updated criteria since the initial test program.
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Attachm:nt 6        i PY-CEl/NRR-2420L Page 4 of 4 Commitments
: 8. A summary report of the power uprate program will be submitted after the completion of the uprate test program as required by Section 7.6.1.1 of the Operational           ;
Requirements Manual. This report willinclude descriptions of the quantitative results, any corrective actions that were required, and brief discussions as to why it was not necessary to repeat specific tests listed la USAR Section 14.2.12.2 during the power uprate test program. When applicable, the results from the uprate test program will be used to revise the operator training program to more accurately reflect the effects of the power uprate.
: 9. Safety Evaluations (SE) for work in progress and SEs completed but not yet included in the Updated Safety Analysis Report (USAR) were reviewed for required changes due to uprated conditions. SEs which were identified as affected by power uprate will be revised as necessary to include uprated conditions.
: 10. Temporary Modifications that would be in effect after power uprate will be reviewed and rtrvised, if necessary, to include uprated conditions.
: 11. The Plant Emergency instructions (PEls) will be reviewed for any effects due to power uprate and updated as necessary. This review will be based on Section 2.3 of Reference 1, which includes a list of operator action levels which are sensitive to power uprate.
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