ML15135A402
| ML15135A402 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 05/15/2015 |
| From: | Borton K F Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML15135A401 | List: |
| References | |
| Download: ML15135A402 (29) | |
Text
Attachment 1 contains Proprietary Information. When separated from Attachment 1, this document is decontrolled.
10 CFR 50.4 10 CFR 2.390 May 15, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Unit 2 Renewed Facility Operating License No. DPR-44 NRC Docket No. 50-277
Subject:
Extended Power Uprate
- Response to Replacement Steam Dryer Request for Additional Information
Reference:
- 1. NRC Letter to Exelon, "Peach Bottom Atomic Power Station, Units 2 and 3 - Issuance of Amendments Re: Extended Power Uprate (TAC Nos. ME9631 and ME9632)", dated August 25, 2014 (ADAMS Accession No. ML14133A046) 2.Exelon letter to the NRC, "Extended Power Uprate
- Request for NRCApproval of Revision to Methodology for Establishing Replacement Steam Dryer Strain Limits", dated February 3, 2015 (ADAMS Accession No. ML1503 4A573)3.Exelon letter to the NRC, "Extended Power Uprate: Response to Replacement Steam Dryer Requests for Additional Information", dated
March 24, 2015 (ADAMS Accession No. ML150 83A559)4.Exelon letter to the NRC, "Extended Power Uprate: Response toReplacement Steam Dryer Requests for Additional Information", dated April 5, 2015 (ADAMS Accession No. ML15096A008)5.Email from R. Ennis, NRC, to K. Ainger, Exelon, "Peach Bottom Unit 2Power Ascension - Draft RAI-11", dated April 25, 2015 (ADAMS Accession No. ML15127A518).In accordance with 10 CFR 50.92, the NRC issued Reference 1, License Amendment Nos.
293 and 296 to the Peach Bottom Atomic Power Station (PBAPS) Renewed Facility Operating Licenses (FOLs) to increase the authorized maximum power level from 3514 megawatts thermal (MWt) to 3951 MWt. This change to power level is considered an extended power uprate (EPU). PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390
U.S. Nuclear Regulatory Commission Response to Replacement Steam Dryer RAI May 15, 2015 Page 2 The amended FOLs contain specific license conditions that control the monitoring, evaluating, and taking prompt action in response to potential adverse flow effects as a result of the EPU on plant structures, systems, and components (including verifying the continued structural integrity of the replacement steam dryer (RSD)) during initial EPU power ascension.
As described in Exelon Generation Company, LLC (EGC) letter dated February 3, 2015, (Reference 2), data collected at near the previously licensed thermal power level identified low frequency loads on the RSD that were not previously predicted.
The NRC staff reviewed the information regarding the revised methodology and provided requests for additional information (RAI). The EGC responses to those requests were submitted on March 24, 2015, (Reference
- 3) and April 5, 2015, (Reference 4). The NRC Staff also requested additional information to support further review of the RSD methodology (Reference 5). This letter provides the response to that RAI. Westinghouse Electric Company (WEC) considers portions of the information provided in the Attachment 1 response proprietary and, therefore, exempt from public disclosure pursuant to 10 CFR 2.390. In accordance with 10 CFR 2.390 and in support of this request for withholding, an affidavit executed by WEC is provided in Attachment
- 3. There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Mr. Ken Ainger at (630) 657-3330. Respectfully, Kevin F. Borton Manager, Power Uprate Licensing Exelon Generation Company, LLC Attachments:
- 1. Response to Request for Additional Information
-Proprietary, Westinghouse Electric Company LLC L TR-BWR-ENG-15-054-P
- 2. Response to Request for Additional Information
-Non-Proprietary, Westinghouse Electric Company LLC LTR-BWR-ENG-15-054-NP
- 3. Affidavit cc: USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, PBAPS USNRC Project Manager, PBAPS R. R. Janati , Commonwealth of Pennsylvania S. T. Gray, State of Maryland w/attachments w/attachments
w/attachments wlo proprietary attachment wlo proprietary attachment
Attachment 2 Peach Bottom Atomic Power Station Unit 2 NRC Docket No. 50-277 Response to Request for Additional Information - Non-Proprietary Westinghouse Electric Company LLC LTR-BWR-ENG-15-054-NP The Nuclear Regulatory Commission (NRC) issued Amendment Nos. 293 and 296 to Renewed Facility Operating License Nos. DPR-44 and DPR-56 for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3 (ADAMS Accession No. ML14133A046).
These amendments authorized an increase in the maximum licensed thermal power level for PBAPS, Units 2 and 3, from 3514 megawatts thermal (MWt) to 3951 MWt, which is an increase of approximately 12.4 percent.
In accordance with PBAPS Unit 2 License Condition 2.C(15)(d)3, EGC requested NRC approval for a revision to the methodology for establishing the RSD strain limits and provided additional information in letters dated February 3, 2015 (ADAMS Accession No.
ML15034A573), March 24, 2015 (ADAMS Accession No. ML15083A559) and April 5, 2015 (ADAMS Accession No. ML15096A008). The NRC staff has reviewed that information, approved further power ascension, and requested additional information on April 25, 2015 (ADAMS Accession No. ML15127A518). The response to that request is provided in this attachment.
Westinghouse Non-Proprietary Class 3 Westinghouse Electric Company LLC 1000 Westinghouse Drive Cranberry Township, PA 16066 USA © 2015 Westinghouse Electric Company LLC All Rights Reserved LTR-BWR-ENG-15-054-NP
Response to the U.S. NRC Requests for Additional Information Relative to the Peach Bottom Replacement Steam Dryer Acoustic/Structural Analyses Set May 15, 2015
Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-054-NP 1 RAI-11 As described below and detailed in the proprietary attachments to this RAI (Excel and Power Point files), the non-main steam line acoustic (NMSLA) portion of Exelon's evaluation at 108% of 3514 MWt, based on the proposed methodology change, may be under-estimating the dryer stress because the licensee's approach for implementation of steps 2 and 3 of the methodology needs to be corrected. [[
]]. Since the dryer minimum alternating stress ratio (MASR) at the projected extended
power uprate (EPU) conditions is 1.09 with a very small margin, the NRC requests the licensee to re-compute the dryer MASRs and demonstrate the structural integrity of the PBAPS Unit 2 replacement steam dryer (RSD) based on the following information.
The results from the methodology submitted on April 22, 2015, are not reasonable. While the updated methodology is improved in that it considers [[
]].
Using [[ ]] could lead to significant stress under-predictions, [[
]].
The licensee is therefore requested to provide an updated stress estimate, [[
]]
Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-054-NP 2 [[
]]
Figure 1. [[
]]
Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-054-NP 3
Figure 2. [[ ]]
Figure 3. [[ ]]
Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-054-NP 4
Figure 4. [[ ]]
Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-054-NP 5 Response An overview of the steps performed to implement [
]
a,c Implementation of Amended Method Discussed in RAI 11
[
]a,c Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-054-NP 6
Figure RAI-11-1: Example FEM Modal Strain Vector Data in the [ ]
a,c
[
]
a,c
a,c Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-054-NP 7
Figure RAI-11-2: [ ]
a,c [
]
a,c
Figure RAI-11-3: [ ]
a,c
[
]
a,c a,c a,c Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-054-NP 8
EquationRAI 11 1
[
]
a,c
a,c Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-054-NP 9 Figure RAI-11-4: [ ]a,c
[
]
a,c a,c Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-054-NP 10
Figure RAI-11-5: [ ]
a,c
Figure RAI-11-6: [ ]
a,c a,c a,c Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-054-NP 11 [
]
a,c Table RAI-11-1: [
]a,c
[
]a,c
a,c Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-054-NP 12 Strain Validation and Bias Development
[
]a,c Bias Example:
[
]a,c Table RAI-11-2: [ ]a,c
a,c Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-054-NP 13 Table RAI-11-3: [ ]
a,c
Strain Calculations Table RAI-11-4 provides a comparison of the [ ]
a,c listed in Table RAI-11-5. [
]a,c Table RAI-11-6 contains the [
]
a,c a,c Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-054-NP 14 Table RAI-11-4: [ ]
a,c
a,c Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-054-NP 15 Table RAI-11-5: [ ]
a,c
a,c Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-054-NP 16 Table RAI-11-6: [ ]
a,c
a,c Westinghouse Non-Proprietary Class 3 LTR-BWR-ENG-15-054-NP 17 Stress Calculation Table RAI-11-7 summarizes the five most limiting locations for both the upper and lower dryer [ ]
a,c Table RAI-11-7 [ ]
a,c
Conclusions
[
]
a,c a,c
Attachment 3 Peach Bottom Atomic Power Station Unit 2 NRC Docket No. 50-277 AFFIDAVIT
Note Attachment 1 contains proprietary information as defined by 10 CFR 2.390. WEC, as the owner of the proprietary information, has executed the enclosed affidavit, which identifies that the proprietary information has been handled and classified as proprietary, is customarily held in confidence, and has been withheld from public disclosure. The proprietary information has been faithfully reproduced in the attachment such that the affidavit remains applicable.
e in ouse U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Westinghouse Electric Company Engineering, Equipment and Major Projects 1000 Westinghouse Drive, Building 3 Cranberry Township, Pennsylvania 16066 USA Direct tel: (412) 374-4643 Direct fax: (724) 940-8560 e-mail: greshaja@westinghouse.com WEC-PCH-RSD-15-097 CAW-15-4187 May 15, 2015 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
LTR-BWR-ENG-15-054-P, "Response to the U.S. NRC Requests for Additional Information Relative to the Peach Bottom Replacement Steam Dryer Acoustic/Structural Analyses Set" The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CA W-15-4187 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The Affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.
Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Exelon Generation.
Correspondence with respect to the proprietary aspects of the Application for Withholding or the Westinghouse Affidavit should reference CAW-15-4187, and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 3 Suite 310, Cranberry Township, Pennsylvania 16066. Very truly yours, Regulatory Compliance Enclosures COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF BUTLER: AFFIDAVIT SS CAW-15-4187 May 15, 2015 I, James A. Gresham, am authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief. Regulatory Compliance 2 CAW-15-4187 (1) I am Manager, Regulatory Compliance, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized 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 the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.
(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information 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, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld. (i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse. (ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence.
The application of that system and the substance of that system constitute Westinghouse policy and provide the rational basis required.
Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, 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 competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.
3 CAW-15-4187 (b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability. ( c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product. ( d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers. ( e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse. (f) It contains patentable ideas, for which patent protection may be desirable. (iii) There are sound policy reasons behind the Westinghouse system which include the following: (a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors.
It is, therefore, withheld from disclosure to protect the Westinghouse competitive position. (b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information. (c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense. (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage.
If competitors acquire components of proprietary information, any one component 4 CAW-15-4187 may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage. ( e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries. (f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage. (iv) The information is being transmitted to the Commission in confidence and, under the provisions 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 available information has not been previously employed in the same original manner or method to the best of our knowledge and belief. (vi) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in LTR-BWR-ENG-15-054-P, "Response to the U.S. NRC Requests for Additional Information Relative to the Peach Bottom Replacement Steam Dryer Acoustic/Structural Analyses Set" (Proprietary), for submittal to the Commission, being transmitted by Exelon Generation letter and Application for Withholding Proprietary Information from Public Disclosure to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with the NRC's further review of RSD methodology for PBAPS Unit 2, and may be used only for that purpose. (a) This information is part of that which will enable Westinghouse to: (i) Assist Exelon Generation in obtaining NRC review and approval of RSD methodology for PBAPS Unit 2. (b) Further this information has substantial commercial value as follows:
5 CAW-15-4187 (i) Westinghouse plans to sell the use of this information to its customers for purposes of plant specific replacement steam dryer analysis for licensing basis applications. (ii) Its use by a competitor would improve their competitive position in the design and licensing of a similar product for BWR steam dryer analysis methodology. (iii) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.
Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation and licensing defense services.for commercial power reactors without commensurate expenses.
Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.
The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money. In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.
Further the deponent sayeth not.
PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and non-proprietary versions of documents furnished to the NRC associated with the NRC' s review of a revised methodology for determining RSD strain limits with regard to RSD analysis benchmarking for PBAPS Unit 2, and may be used only for that purpose. In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted).
The justification for claiming the information so 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 being identified as proprietary or in the margin opposite such information.
These lower case letters refer to the types 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 NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal 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 public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding.
With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.