ML15034A573

Peach Bottom Unit 2, Extended Power Uprate: Request for NRC Approval of Revision to Methodology for Establishing Replacement Steam Dryer Strain Limits

ML15034A573
Person / Time
Site:	Peach Bottom
Issue date:	02/03/2015
From:	David Helker Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML15034A570	List: ML15034A573
References
TAC ME9631, TAC ME9632
Download: ML15034A573 (14)

Text

Attachment 1 contains Proprietary Information. When separated from Attachment 1, this document is decontrolled.

10 CFR 50.4 10 CFR 2.390 February 3, 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: Request for NRC Approval of Revision to Methodology for Establishing Replacement Steam Dryer Strain Limits

Reference:

1. Letter from R.B. Ennis (NRC) to M.J. Pacilio (EGC), 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)

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) and Technical Specifications 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).

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.

The purpose of this letter is to request NRC approval of a revision to the methodology contained in Attachment 1, in accordance with the PBAPS Unit 2 FOL license condition 2.C.(15)(d), that establishes the RSD strain limits used to monitor the RSD performance during power ascension above 3514 MWt. Prior to exceeding 3514 MWt, and during re-benchmarking of the acoustic circuit model for PBAPS Unit 2, the on-dryer strain gauge measurements identified strain responses in the low frequency range which were not present in the predicted strains based on main steam line (MSL) acoustic pressure loading. As a result, an approach was developed to quantify the magnitude of the unpredicted loads PROPRIETARY INFORMATION - WITHHOLD UNDER 10 CFR 2.390 U.S. Nuclear Regulatory Commission Replacement Steam Dryer Revised Methodology February 3, 2015 Page2 and integrate the results into the original methodology. The revised methodology described in Attachment 1 was developed that supplements the original methodology. Proprietary and non-proprietary versions of a description of the methodology modifications are provided in Attachments 1 and 2. Westinghouse Electric Company (WEC) considers portions of the information provided in the Attachment 1 responses proprietary and therefore exempt from public disclosure pursuant to 1 O CFR 2.390. In accordance with 1 O 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, David P. Helker Manager, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments: 1. Description of the Revised Methodology -Proprietary 2. Description of the Revised Methodology -Non-Proprietary 3. Affidavit in Support of Request to Withhold Information 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 w/o proprietary attachment w/o proprietary attachment

Attachment 2 Peach Bottom Atomic Power Station Unit 2 NRC Docket No. 50-277 Description of the Revised Methodology Note This attachment includes the non-proprietary version of the response; brackets identify where proprietary information has been redacted.

Replacement Steam Dryer Revised Methodology Attachment 2 Page 1 of 4 1 Background The measured data from the Peach Bottom Unit 2 main steam lines (MSLs) and replacement steam dryer (RSD) taken at 3460 MWt were used to generate an end-to-end benchmark. [

]a,c treated with the acoustic model. Based on these evaluations, the [

]a,c This results in changing the methodology for establishing the RSD strain limits used for the Level 1 and Level 2 performance monitoring. In accordance with the PBAPS Unit 2 license condition 2.C.(15)(d).3, the following description of the proposed methodology change is being presented for NRC approval. Proposed Revision to the Methodology for Establishing the RSD Strain Limits used for Level 1 and Level 2 Performance Monitoring Currently, Level 1 strain limits are defined to be the [ ]a,c Similarly, the current Level 2 strain limits are defined to be [ ]a,c The new Level 1 and Level 2 strain limits at each strain gauge location are proposed to be defined by Equation 1 and Equation 2, respectively. [

]a,c The resulting strain limits, provided in the Brief Stress Summary Report in accordance with the Unit 2 license condition 2.C(15)(a)(1), include [ ]a,c contributions to strain. a,c Replacement Steam Dryer Revised Methodology Attachment 2 Page 2 of 4 2 [

]a,c MSL Acoustic Methodology At 3460 MWt, the measured data from the Peach Bottom Unit 2 MSLs and RSD were used to generate the end-to-end benchmarks of [ ]a,c Based on these evaluations, the original acoustic methodology has been [

]a,c Non-MSL Acoustic A method was developed to both determine the basis for considering these as non-MSL acoustic loads and also then perform a structural evaluation to account for these loadings. In the approach described below, dryer stresses are calculated by [ ]a,c Determination of Non-MSL Acoustic Frequency Ranges A main steam line acoustic excitation would typically be a [

]a,c Replacement Steam Dryer Revised Methodology Attachment 2 Page 3 of 4 3 [

]a,c Structural Evaluation Method for non-MSL Acoustic Frequency Ranges The method used on the Peach Bottom Unit 2 RSD for determining the magnitude of the non-MSL acoustic uses modal analysis to relate the modal strain at a sensor location to the modal stress at the location of interest in the dryer. [

]a,c

a,c Replacement Steam Dryer Revised Methodology Attachment 2 Page 4 of 4 4 [

]a,c A review of data at the different power levels [

]a,c In summary, the original MSL acoustic methodology for establishing the RSD strain limits used for Level 1 and Level 2 performance monitoring is [

]a,c This revised methodology is being presented for NRC approval in accordance with the PBAPS Unit 2 license condition 2.C.(15)(d).3.

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.

@Westinghouse 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 CAW-15-4085 February 2, 2015 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

Attachment 1 "Description of the Revised Methodology -Proprietary," attached to Exelon Generation submittal to the NRC "Extended Power Uprate: Request for NRC Approval of Revision to Methodology for Establishing RSD Strain Limits" The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CA W-15-4085 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-15-4085, 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-15-4085 February 2, 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. ames A. Gresham, Manager Regulatory Compliance 2 CAW-15-4085 (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 CPR 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-15-4085 (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 CA W-15-4085 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 Attachment 1 "Description of the Revised Methodology -Proprietary," attached to Exelon Generation submittal to the NRC "Extended Power Uprate: Request for NRC Approval of Revision to Methodology for Establishing RSD Strain Limits" 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 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. (a) This information is part of that which will enable Westinghouse to: (i) Assist Exelon Generation in obtaining NRC review and approval of a revised methodology for determining RSD strain limits for PBAPS Unit 2.

5 CAW-15-4085 (b) Further this information has substantial commercial value as follows: (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.