ML14035A158

Peach Bottom, Units 2 and 3, Extended Power Uprate License Amendment Request - Supplement 19 Response to Request for Additional Information

ML14035A158
Person / Time
Site:	Peach Bottom
Issue date:	01/31/2014
From:	Borton K F Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME9631, TAC ME9632
Download: ML14035A158 (26)

Text

{{#Wiki_filter:200 Exelon WayExe!on Generation& Kennett Square, PA 19348www.exeloncorp.comPROPRIETARY INFORMATION -WITHHOLD UNDER 10 CFR 2.39010 CFR 50.9010 CFR 2.390January 31, 2014U. S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001Peach Bottom Atomic Power Station, Units 2 and 3Renewed Facility Operating License Nos. DPR-44 and DPR-56NRC Docket Nos. 50-277 and 50-278Subject: Extended Power Uprate License Amendment Request -Supplement 19Response to Request for Additional InformationReferences: 1. Exelon letter to the NRC, "License Amendment Request -ExtendedPower Uprate," dated September 28, 2012 (ADAMS Accession No.ML122860201)2. NRC letter to Exelon, "Request for Additional Information RegardingLicense Amendment Request for Extended Power Uprate (TAC Nos.ME9631 and ME9632)," dated January 15, 2014 (ADAMS AccessionNo. ML14002A176)In accordance with 10 CFR 50.90, Exelon Generation Company, LLC (EGC) requestedamendments to Facility Operating License Nos. DPR-44 and DPR-56 for Peach BottomAtomic Power Station (PBAPS) Units 2 and 3, respectively (Reference 1). Specifically, theproposed changes would revise the Renewed Operating Licenses to implement an increasein rated thermal power from 3514 megawatts thermal (MWt) to 3951 MWt. During theirtechnical review of the application, the NRC Staff identified the need for additionalinformation.The NRC provided a second round of requests for additional information in Reference 2.The response to EMCB-SD-RAIs 19, 21-26, 28-29, 31 and 33-39 are provided in this letter(EMCB-SD-RAIs 18, 20 and 27 have been deleted). The response to EMCB-SD-RAIs 16-17, 30, 32, 40 and 41 will be provided by February 28, 2014.Attachment 1 contains the response to EMCB-SD-RAIs-19, 21-26, 28-29, 31 and 33-39.Westinghouse Electric Company (WEC) considers portions of the information provided inthe response to be proprietary and therefore exempt from public disclosure pursuant to 10CFR 2.390. In accordance with 10 CFR 2.390 and in support of this request forwithholding, affidavits executed by the respective parties are provided in Attachment 3. Anon-proprietary version of the responses is provided in Attachment 2.Attachment 1 contains Proprietary Information.When separated from Attachment 1, this document is decontrolled. U. S. Nuclear Regulatory CommissionEPU LAR Supplement 19Response to Requests for Additional InformationJanuary 31, 2014Page 2EGC has reviewed the information supporting a finding of no significant hazardsconsideration and the environmental consideration provided to the U. S. NuclearRegulatory Commission in Reference 1. The supplemental information provided in thissubmittal does not affect the bases for concluding that the proposed license amendmentdoes not involve a significant hazards consideration. Further, the additional informationprovided in this submittal does not affect the bases for concluding that neither anenvironmental impact statement nor an environmental assessment needs to be preparedin connection with the proposed amendment.In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"paragraph (b), EGC is notifying the Commonwealth of Pennsylvania and the State ofMaryland of this application by transmitting a copy of this letter along with the non-proprietary attachments to the designated State Officials.There are no regulatory commitments contained in this letter.Should you have any questions concerning this letter, please contact Mr. David Neff at(610) 765-5631.I declare under penalty of perjury that the foregoing is true and correct. Executed on the31st day of January 2014.RepctfullyKevin F. BortonManager, Licensing -Power UprateExelon Generation Company, LLCAttachments:1. Response to Request for Additional Information -EMCB-SD -Proprietary2. Response to Request for Additional Information -EMCB-SD3. Affidavits in Support of Request to Withhold Informationcc: USNRC Region I, Regional Administrator w/attachmentsUSNRC Senior Resident Inspector, PBAPS w/attachmentsUSNRC Project Manager, PBAPS w/attachmentsR. R. Janati, Commonwealth of Pennsylvania w/o proprietary attachmentS. T. Gray, State of Maryland w/o proprietary attachment Attachment 3Peach Bottom Atomic Power Station Units 2 and 3NRC Docket Nos. 50-277 and 50-278AFFIDAVITNoteAttachment 1 contains proprietary information as defined by10 CFR 2.390. WEC, as the owner of the proprietary information, hasexecuted the enclosed affidavit, which identifies that the proprietaryinformation has been handled and classified as proprietary, is customarilyheld in confidence, and has been withheld from public disclosure. Theproprietary information has been faithfully reproduced in the attachmentsuch that the affidavit remains applicable. CAW-14-3892AFFIDAVITCOMMONWEALTH OF PENNSYLVANIA:ssCOUNTY OF BUTLER:Before me, the undersigned authority, personally appeared Bradley F. Maurer, who, being by meduly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf ofWestinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in thisAffidavit .are true and correct to the best of his knowledge, information, and belief:Bradley F. Maurer, Principal EngineerPlant LicensingSworn to and subscribed before methis 30th day of January 2014U UVNotary PublicCOMMONWEALTH OF PENNSYLVANIANotarial Seal IRenee Giampole, Notary PublicPenn Twp., Westmoreland CountyMy Commission Expires Sept. 25, 2017MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES 2 CAW-14-3892(1) I am Principal Engineer, Plant Licensing, in Engineering, Equipment and Major Projects,Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specificallydelegated the function of reviewing the proprietary information sought to be withheld from publicdisclosure in connection with nuclear power plant licensing and rule making proceedings, and amauthorized to apply for its withholding on behalf of Westinghouse.(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of theCommission's regulations and in conjunction with the Westinghouse Application for WithholdingProprietary Information from Public Disclosure accompanying this Affidavit.(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designatinginformation as a trade secret, privileged or as confidential commercial or financial information.(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, thefollowing is furnished for consideration by the Commission in determining whether the informationsought to be withheld from public disclosure should be withheld.(i) The information sought to be withheld from public disclosure is owned andhas been held inconfidence by Westinghouse.(ii) The information is of a type customarily held in confidence by Westinghouse and notcustomarily disclosed to the public. Westinghouse has a rational basis for determining thetypes of information customarily held in confidence by it and, in that connection, utilizes asystem to determine when and whether to hold certain types of information in confidence.The application of that system and the substance of that system constitutes Westinghousepolicy and provides the rational basis required.Under that system, information is held in confidence if it falls in one or more of severaltypes, the release of which might result in the loss of an existing or potential competitiveadvantage, as follows:(a) The information reveals the distinguishing aspects of a process (or component,structure, tool, method, etc.) where prevention of its use by any of Westinghouse's 3CAW-14-3892competitors without license from Westinghouse constitutes a competitive economicadvantage over other companies.(b) It consists of supporting data, including test data, relative to a process (orcomponent, structure, tool, method, etc.), the application of which data secures acompetitive economic advantage, e.g., by optimization or improved marketability.(c) Its use by a competitor would reduce his expenditure of resources or improve hiscompetitive position in the design, manufacture, shipment, installation, assurance ofquality, or licensing a similar product.(d) It reveals cost or price information, production capacities, budget levels, orcormnercial strategies of Westinghouse, its customers or suppliers.(e) It reveals aspects of past, present, or future Westinghouse or customer fundeddevelopment plans and programs of potential commercial value to Westinghouse.(f) It contains patentable ideas, forwhich patent protection may be desirable.(iii) There are sound policy reasons behind the Westinghouse system which include thefollowing:(a) The use of such information by Westinghouse gives Westinghouse a competitiveadvantage over its competitors. It is, therefore, withheld from disclosure to protectthe Westinghouse competitive position.(b) It is information that is marketable in many ways. The extent to which suchinformation is available to competitors diminishes the Westinghouse ability to sellproducts and services involving the use of the information.(c) Use by our competitor would put Westinghouse at a competitive disadvantage byreducing his expenditure of resources at our expense. 4CAW-14-3892(d) Each component of proprietary information pertinent to a particular competitiveadvantage is potentially as valuable as the total competitive advantage. Ifcompetitors acquire components of proprietary information, any one componentmay be the key to the entire puzzle, thereby depriving Westinghouse of acompetitive advantage.(e) Unrestricted disclosure would jeopardize the position of prominence ofWestinghouse in the world market, and thereby give a market advantage to thecompetition of those countries.(f) The Westinghouse capacity to invest corporate assets in research and developmentdepends upon the success in obtaining and maintaining a competitive advantage.(iv) The information is being transmitted to the Commission in confidence and, under theprovisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.(v) The information sought to be protected is not available in public sources or availableinformation has not been previously employed in the same original manner or method to thebest of our knowledge and belief.(vi) The proprietary information sought to be withheld in this submittal is that which isappropriately marked in Attachment I "Response to Request for Additional Information -EMCB-SD -Proprietary," attached to Exelon Generation submittal to the NRC "ExtendedPower Uprate License Amendment Request -Supplement 19, Response to Request forAdditional Information" for submittal to the Commission, being transmitted by ExelonGeneration letter and Application for Withholding Proprietary Information from PublicDisclosure, to the Document Control Desk. The proprietary information as submitted byWestinghouse is to assist the NRC in their review of the Peach Bottom Atomic Power Station,Units 2 and 3, License Amendment Request for Extended Power Uprate and may be used onlyfor that purpose. 5CAW-14-3892(a) This information is part of that which will enable Westinghouse to:(i) Assist Exelon Generation in obtaining NRC review of the Peach BottomAtomic Power Station Units 2 and 3 License Amendment Request.(b) Further this information has substantial commercial value as follows:(i) Westinghouse plans to sell the use of this information to its customers forpurposes of plant specific replacement steam dryer analysis for licensingbasis applications.(ii) Its use by a competitor would improve their competitive position in thedesign and licensing of a similar product for BWR steam dryer analysismethodology.(iii) The information requested to be withheld reveals the distinguishing aspectsof a methodology which was developed by Westinghouse.Public disclosure of this proprietary information is likely to cause substantial harm to thecompetitive position of Westinghouse because it would enhance the ability of competitors toprovide similar technical justifications and licensing defense services for commercial powerreactors without commensurate expenses. Also, public disclosure of the information wouldenable others to use the information to meet NRC requirements for licensing documentationwithout purchasing the right to use the information.The development of the technology described in part by the information is the result ofapplying the results of many years of experience in an intensive Westinghouse effort and theexpenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technicalprograms would have to be performed and a significant manpower effort, having therequisite talent and experience, would have to be expended.Further the deponent sayeth not. Proprietary Information NoticeTransmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRCin connection with requests for generic and/or plant-specific review and approval.In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning theprotection of proprietary information so submitted to the NRC, the information which is proprietary in theproprietary versions is contained within brackets, and where the proprietary information has been deletedin the non-proprietary versions, only the brackets remain (the information that was contained within thebrackets in the proprietary versions having been deleted). The justification for claiming the informationso designated as proprietary is indicated in both versions by means of lower case letters (a) through (f)located as a superscript immediately following the brackets enclosing each item of information beingidentified as proprietary or in the margin opposite such information. These lower case letters refer to thetypes of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a)through (4)(ii)(f) of the Affidavit accompanying this transmittal pursuant to 10 CFR 2,390(b)(1).Copyright NoticeThe reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted tomake the number of copies of the information contained in these reports which are necessary for itsinternal use in connection with generic and plant-specific reviews and approvals as well as the issuance,denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license,permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on publicdisclosure to the extent such information has been identified as proprietary by Westinghouse, copyrightprotection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC ispermitted to make the number of copies beyond those necessary for its internal use which are necessary inorder to have one copy available for public viewing in the appropriate docket files in the public documentroom in Washington, DC and in local public document rooms as may be required by NRC regulations ifthe number of copies submitted is insufficient for this purpose. Copies made by the NRC must includethe copyright notice in all instances and the proprietary notice if the original was identified as proprietary. Attachment 2Peach Bottom Atomic Power Station Units 2 and 3NRC Docket Nos. 50-277 and 50-278Response to Request for Additional Information -EMCB-SDNoteThis attachment includes the non-proprietary version of the response;brackets identify where proprietary information has been redacted. EPU LAR Supplement 19 Attachment 2Response to RAI -EMCB-SD Page 1 of 16Response to Request for Additional InformationMechanical and Civil Engineering Branch (EMCB) -Steam Dryer (SD)By letter dated September 28, 2012, Exelon Generation Company, LLC (EGC) submitted alicense amendment request for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3.The proposed amendment would authorize an increase in the maximum power level from 3514megawatts thermal (MWt) to 3951 MWt. The requested change, referred to as an extendedpower uprate (EPU), represents an increase of approximately 12.4 percent above the currentlicensed thermal power level.The NRC staff has reviewed the information supporting the proposed amendment and, by letterdated January 15, 2014 (NRC Accession No. ML1 4002A1 76), requested additional information.The response to EMCB-SD-RAIs 19, 21-26, 28-29, 31 and 33-39 is provided in this letter(EMCB-SD-RAIs 18, 20 and 27 have been deleted). The response to EMCB-SD-RAIs 16-17,30, 32, 40 and 41 will be provided by February 28, 2014.EMCB-SD-RAI-18This RAI question has been deleted.EMCB-SD-RAI-19Reference 2 notes that one of the blind-flanged standpipes on the dead-ended leg of MSL C willbe replaced with a Dresser SRV. Please provide the standpipe dimensions for the new DresserSRV in comparison to the existing SRV standpipes.RESPONSEIt should be noted that the additional valve location in each unit is not in the active steam flowregion of the MSL and is therefore not susceptible to flow induced resonance during normalplant operation.Dimensionally, the existing standpipe for the new Steam Safety Valve (SSV) is similar to theother existing SSV standpipes. The standpipes utilize dimensionally identical Bonny ForgeSweepolets connected to 6" schedule 160 pipe provided with identical flanges. The length ofthe pipes vary slightly (by less than an inch) to compensate for the MSL pipe slope. TheDresser SSVs are mounted on the flanges.EMCB-SD-RAI-20This RAI question has been deleted. EPU LAR Supplement 19Response to RAI -EMCB-SDAttachment 2Page 2 of 16EMCB-SD-RAI-21In Section 5.3 of Reference 3, it appears that some peaks other than those caused by thea,c were filtered. Please provide information about any peaks, other than those due to a,c which have been filtered fromthe signals of the MSL strain gages.RESPONSEAC electrical motor drive, electrical supply, low frequency bias (0-2 Hz) and vane passingfrequency peaks were filtered as discussed in Tables 5-3 through 5-6 of Section 5.3 ofReference 3. No additional peaks were filtered from the raw data.EMCB-SD-RAI-22Figures 3-2 to 3-5 of Reference 1 show [[]]ac Please provide the following:a) The averaging of pressure spectra over large dryer areas (e.g., quadrants) does not providean accurate description of the load distribution on the dryer. Explain whether these pressurespectra are averaged over the respective quadrants or they represent local spectra atselected points on the quadrants.b) Explain the nature of the EPU load on the RSD for PBAPS Unit 3.'ax which appears in the estimatedRESPONSEa) Figures 3-2 through 3-5 of Reference 1 show PSDs corresponding to the locations of[[:b) Figures 3-2 through 3-5 of Reference 1 will be revised as a result of the updated analysesbeing performed using ACE. [[EMCB-SD-RAI 23Explain how the acoustic pressure field in the [[] a,c as presented in Reference 1, is mapped to the curved continuous structuralsurfaces of the PBAPS RSD structural finite element model mesh. Discuss any bias errorsassociated with this mapping and how are they accounted for in the dryer stress analyses. EPU LAR Supplement 19Response to RAI -EMCB-SDAttachment 2Page 3 of 16RESPONSEThe acoustic field determined from the Helmholtz analysis is [[EMCB-SD-RAI-24The dryer skirt is partially submerged in boiling or saturated water, which imparts randomfluctuating pressure pulsations to the bottom of the structure. These loads were not accountedfor in the Acoustic Circuit Model (ACM), or in the Quad Cities Unit 2 based bias errors anduncertainties. Please provide details on how you will account for the effects of these loads in:(a) the dryer stress analysis prior to EPU approval; and (b) the instrumented dryer test plan.RESPONSEConsistent with [[ EPU LAR Supplement 19 Attachment 2Response to RAI -EMCB-SD Page 4 of 16]a,oEMCB-SD-RAI-25The NRC staff experience indicates that minor changes in vessel conditions (static pressure,core flow, and MSL inlet flow rates) can lead to modest (>10%) changes in dryer alternatingstresses. Please provide the allowable range of operating conditions at EPU power for theremaining life of the PBAPS Units 2 and 3 (including the historical plant data at CLTP, themethodology for determining the worst-case alternating stresses for all dryer regions over theseoperating conditions, and the effects of these operating conditions on the remaining fatigue life).RESPONSEPlant procedures currently allow for operation of PBAPS Units 2 and 3 at pressures which rangefrom 1015 psig to 1035 psig at rated conditions. This pressure range will not change due toEPU implementation.Between 90-100% CLTP, EGC will vary reactor dome pressure by approximately 6 psi as partof the EPU power ascension testing. Observed variance in loads upon the dryer attributed tothe pressure change will be extrapolated to the limiting pressure conditions. This additionalloading will be incorporated into the acoustic/structural model benchmarking developed between90-100% CLTP and used in determination of minimum stress ratios.EMCB-SD-RAI-26Tables 5-3 and 5-4 of Reference 3 show [[the PBAPS Unit 2 reactor recirculation pump drivea,c However, Table 5-5 of Reference3 shows [['Cwhereas Table 5-6 of Reference 3 shows [[]] ax Please provide the frequencies of the [[ ]ax in both PBAPS Units. Also provide the motor and pump design specifications, along with anyformulas explaining how the [[ a]' are computed based on the pump andmotor design parameters.RESPONSEThe PBAPS recirculation systems in each unit operate through the use of a pair of variablespeed A/C motor driven pumps. The pumps utilize five vane impellers so that the VPF is fivetimes the pump rotational frequency. The pumps are driven by 3-phase, 4-pole motors. Themotors are driven by motor/generator sets which supply variable frequency power.A wide range of pump speeds and VPFs are possible. At rated CLTP conditions (3514 MWt),the pump speed range is limited by the licensed core flow range of 83% to 110% of rated flow(rated flow is 102.5 Mlb/hr). At EPU conditions (3951 MWt), minimum core flow will be limited to99% of rated with a maximum core flow of 110% of rated. EPU LAR Supplement 19Response to RAI -EMCB-SDAttachment 2Page 5 of 16Three phase motor drive frequency is derived from the following formula assuming 1% driveslippage:fdrive = rpm*poles/1 18.8Pump motor rpm is derived empirically from curves fitted to plant data. Both PBAPS unitsoperate similarly with respect to pump speeds for a given core flow. The table below presentsthe range of typical values for motor and pump speeds as they relate to reactor corerecirculation flow.CLTP CLTP EPU EPULow High Low HighPercent Rated Core Flow 83 110 99 110Motor Drive Frequency (Hz)* 43.4 56.2 51.5 56.2Pump Motor RPM 1290 1668 1530 1668Pump Frequency (Hz) 21.5 27.8 25.5 27.8Pump VPF (Hz) 109 139 128 139* Assumes 1 percent slippage per the motor design specificationThe following table supplies the additional information requested as calculated from Tables 5-5and 5-6 of Reference 3. Note that in Tables 5-5 and 5-6 only the filtered signals were listed. Inthe case of Table 5-5, VPF effects were not significant and as such were not considered forfiltering. As can be seen in the table below, VPFs corresponding to Table 5-5 motor drivefrequencies are 94.0 Hz and 101.3 Hz. In the case of Table 5-6, Motor Drive AC signal effectswere not significant enough to adversely impact the strain gage signals and as such were notfiltered. The Motor Drive AC frequencies corresponding to Table 5-6 VPFs are 47.8 Hz and48.0 Hz.It can also be noted that the two recirculation loops were operating at slightly different speeds,resulting in the two separate motor drive frequency and VPF tones.Table 5-5 Table 5-5 Table 5-6 Table 5-61st Row 2nd Row 2nd Row 3rd RowMotor Drive Frequency (Hz)* 38.0 41.0 47.8 48.0Pump Motor RPM 1128 1215 1419 1427Pump Frequency (Hz) 18.8 20.3 23.7 23.8Pump VPF (Hz) 94.0 101.3 118.3 118.9* Assumes 1 percent slippage per the motor design specification EPU LAR Supplement 19Response to RAI -EMCB-SDAttachment 2Page 6 of 16EMCB-SD-RAI-27This RAI question has been deleted.EMCB-SD-RAI-28Attachment 9 of Reference 4 contains estimates of the PBAPS RSD alternating stressesinduced by [[ ]] a,c Please include these stresscomponents in your proposed revision of Reference 4. Also, include the consideration of peak[[ ]] a,c stresses in this forthcoming submission, describing on-dryer instrumentationlocations, such that you ensure that a few of the on-dryer strain gages will measure the 1 ,c Provide the spectra of the motor bearing vibration measurements referred to inReference 4 and discuss the impact on the dryer stresses of any [[ ]] a,c frequencypeaks which may be present in the data contained in Reference 4, Attachment 9.RESPONSEThe updated high cycle fatigue analysis (WCAP-17609) will include [[]] axEMCB-SD-RAI-29Provide the bias errors and uncertainties for all on-dryer instrumentation, including the effects ofcabling and data acquisition systems.RESPONSEBased upon discussions with Staff reviewers during the audit of December 16, 2013, [[]° ac EPU LAR Supplement 19Response to RAI -EMCB-SDAttachment 2Page 7 of 16EMCB-SD-RAI-31Explain how end-to-end benchmarking will be performed using the on-dryer upper and lowerstrain gages on PBAPS Unit 2.RESPONSEThe Peach Bottom Unit 2 replacement steam dryer will be instrumented with [[fl".C Details of strain gages locations are provided in response toEMCB-SD-RAI-15, which will be provided by February 28, 2014.EGC will perform [[] a,xEMCB-SD-RAI-33Please provide details on how you will project dryer minimum alternating stress ratios at higherpower levels during power ascension. Also, provide details of how you will address projectionsthat reveal stresses that violate acceptable limits.RESPONSEFor power ascension above CLTP, the Limit Curve method described in Enclosure B.4U2 of theoriginal submittal (Ref. 7) will be utilized. Two levels of limit curves will be used as describedbelow:0 HIIa EPU LAR Supplement 19Response to RAI -EMCB-SDAttachment 2Page 8 of 16The following situations may occur depending upon the magnitude of the pressure load:Condition ActionPressure Load < Level 2 Increase power to the next level[rLevel 2 < Pressure Load < Level 1Pressure Load > Level 1A second method will also be utilized [[] ]D a ,cEMCB-SD-RAI-34Provide comparisons of the MSL spectra in PBAPS Unit 2 with those from Quad Cities Unit 2 atcomparable EPU power levels. This information should be provided for MSLs with resonances(not all MSLs).RESPONSEThe following table compares the velocities from Quad Cities Unit 2 to PBAPS [[The spectra of MSL data is provided below in Figures 34-1 and 34-2 for PBAPS Units 2 and 3and Quad Cities Unit 2. The EPU conditions are presented for Quad Cities Unit 2 and predictedEPU conditions for the two PBAPS units.Figures 34-1 and 34-2 present [[ EPU LAR Supplement 19Response to RAI -EMCB-SDAttachment 2Page 9 of 16[[Figure 34-1 -Spectrum for MSL A Data at the Upper Strain Gage Location EPU LAR Supplement 19Response to RAI -EMCB-SDAttachment 2Page 10 of 16[[Figure 34-2 -Spectrum for MSL D Data at the Upper Strain Gage LocationEMCB-SD-RAI-35The PBAPS RSDs [[ a,c With respect to the fatigueassessment, please provide information showing whether the section properties of the filletwelds are as good as or better than the section properties of the plates being welded. If the filletweld properties are not equal to or better than that of the plates, provide the followinginformation:a) Identify which fillet welds are one-sided and which are two-sided.b) Provide sketches of the different types of fillet welds along with the dimensions.c) Explain what steps will be taken to estimate the fatigue stress. EPU LAR Supplement 19Response to RAI -EMCB-SDAttachment 2Page 11 of 16RESPONSEThe replacement steam dryers at Peach Bottom will utilize [[]] a,oFigure RAI-35-1: Fillet Weld W 13 joining the Perforated Plate to the Vane Bank Top Plate. EPU LAR Supplement 19Response to RAI -EMCB-SDAttachment 2Page 12 of 16[[]I a,cFigure RAI-35-2: Fillet Weld W 14 joining the Perforated Plate to the Vane Bank Side Plateu Fa ,nFigure RAI-35-3: Fillet Weld W 16 joining the Perforated Plate to the Vane Bank Trough. EPU LAR Supplement 19Response to RAI -EMCB-SDAttachment 2Page 13 of 16c) The stress resultant [[], aocEMCB-SD-RAI-36Since stress convergence errors depend upon the mesh density, the stress gradient, and thelocal geometry of the RSDs, the stress convergence errors will be different at various locationsin the RSDs. According to Section 3 of Reference 6, the finite element model for the PBAPSRSDs [[ ]] a,c Therefore, the stress convergence errors at differentlocations are likely to be different. Please provide the stress convergence errors for thefollowing locations on the RSDs: (1) locations having high stress gradients; (2) locations havinghigh stresses at EPU power levels; and (3) at the on-dryer strain gage and accelerometerlocations. Additionally, please explain how the stress convergence errors will be accounted forin estimating the stresses in the RSDs at EPU power levels.RESPONSEStress convergence errors are addressed [[]1 ac EPU LAR Supplement 19 Attachment 2Response to RAI -EMCB-SD Page 14 of 16EMCB-SD-RAI-37Please explain whether the speed of the reactor recirculation pumps for PBAPS Units 2 and 3would change when power is increased from CLTP to the EPU power level during powerascension. Please provide the speeds of the reactor recirculation pumps at CLTP and EPU foreach of the PBAPS Units.RESPONSEAdjustment of reactor recirculation (RR) pump speed is a tool utilized by operations to finelyvary reactor power throughout the operating cycle. During power ascension from CLTP to EPU,RR pump speed will be varied to adjust reactor power. However, control rod pattern changesduring power ascension will determine at what power levels and to what degree RR pumpspeed will vary as power is increased. As shown in the table in the response to EMCB-SD-RAI-26, at 100% CLTP the pump speed ranges from 1290 rpm to 1668 rpm. At 100% EPU, with itssmaller flow window, the pump speed range is from 1530 to 1668 rpm.EMCB-SD-RAI-38Please identify if any of the PBAPS RSD WCAP documents will be revised if you switch fromusing the Acoustic Circuit Model (ACM) 4.1 Version to the Acoustic Circuit Model Enhanced(ACE) 2.0 Version in the PBAPS RSD load evaluations.RESPONSEWith the change in acoustic analysis methodology from ACM 4.1 to ACE and ACE+SPM, thefollowing WCAPs will be revised:1ax°All WCAPs will be provided by the end of February 2014.EMCB-SD-RAI-39Please provide the weights for the PBAPS original equipment manufacturer (OEM) steam dryerand the RSD. Also, address the impact of any increase in weight of the RSD compared to theOEM steam dryer on the reactor pressure vessel (RPV) lugs supporting the RSD and the RPVsupports. EPU LAR Supplement 19Response to RAI -EMCB-SDAttachment 2Page 15 of 16RESPONSEThe weight of the original steam dryer at PBAPS is approximately [[Replacement Steam Dryer will weigh approximately [[ ]]a,c tons.]]a,, tons. TheThe increased loading from the RSD upon the RPV dryer support lugs has been evaluated. Thedryer support lugs continue to meet American Society of Mechanical Engineers (ASME)standards.EGC has evaluated the increased loading from the RSD upon the RPV support skirt anddetermined that the current evaluation continues to bound the case with a Replacement SteamDryer. EPU LAR Supplement 19 Attachment 2Response to RAI -EMCB-SD Page 16 of 16REFERENCES1) Attachment 17, Enclosure B.1 to Exelon letter to NRC dated September 28, 2012,Westinghouse Report WCAP-1 7590-P, Revision 0, "Peach Bottom Units 2 & 3Replacement Steam Dryer Acoustic Load Definition," dated August 2012.2) Attachment 17, Enclosure B.5 to Exelon letter to NRC dated September 28, 2012,Westinghouse Report WCAP-1 7611 -P, Revision 1, "Peach Bottom Units 2 and 3Replacement Steam Dryer Four-Line Subscale Acoustics Test Data Evaluation andDerivation of CLTP-to-EPU Scaling Spectra," dated August 2012.3) Attachment 17, Enclosure B.6 to Exelon letter to NRC dated September 28, 2012,Westinghouse Report WCAP-1 7626-P, Revision 0, "Peach Bottom Units 2 & 3 MSLStrain Gage Data and Computation of Predicted EPU Signature," dated August 2012.4) Attachment 9 to Exelon letter to NRC dated February 15, 2013, "Response to Requestfor Supplement Information, Issue 2, Steam Dryer Analysis."5) Attachment 17, Enclosure B.7 to Exelon letter to NRC dated September 28, 2012,Westinghouse Report WCAP-1 7639-P, Revision 2, "Instrumentation Description for thePeach Bottom Unit 2 Replacement Steam Dryer," dated September 2012.6) Attachment 17, Enclosure B.2 to Exelon letter dated to NRC dated September 28, 2012,Westinghouse Report WCAP-17609-P, Revision.1, "Peach Bottom Units 2 and 3Replacement Steam Dryer Structural Evaluation for High-Cycle Acoustic Loads," datedSeptember 2012.7) Attachment 17, Enclosure B.4U2 to Exelon letter dated to NRC dated September 28,2012, Westinghouse Report No. WCAP-17654-P (Revision 2), "Peach Bottom Unit 2Replacement Steam Dryer Power Ascension Program Description for Extended PowerUprate." Dennis, R. 2012.8) BWR Vessel and Internals Project Report BWRVIP-1 82-A, "Guidance for Demonstrationof Steam Dryer Integrity for Power Uprate." Electric Power Research Institute, Palo Alto,CA: May 2010. }}