ML14127A480

Peach Bottom Atomic Power Station, Units 2 and 3 - Extended Power Uprate License Amendment Request - Supplement 26 Response to Request for Additional Information

ML14127A480
Person / Time
Site:	Peach Bottom
Issue date:	05/06/2014
From:	Lambert C W Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML14127A480 (29)

Text

A Exelon Generation PROPRIETARY INFORMATION

-WITHHOLD UNDER 10 CFR 2.39010 CFR 50.9010 CFR 2.390May 6, 2014U. S. Nuclear Regulatory Commission ATTN: Document Control DeskWashington, DC 20555-0001 Peach Bottom Atomic Power Station, Units 2 and 3Renewed Facility Operating License Nos. DPR-44 and DPR-56NRC Docket Nos. 50-277 and 50-278

Subject:

Extended Power Uprate License Amendment Request -Supplement 26Response to Request for Additional Information

Reference:

1. Exelon letter to the NRC, "License Amendment Request -Extended Power Uprate,"

dated September 28, 2012(ADAMS Accession No. ML1 22860201)

In accordance with 10 CFR 50.90, Exelon Generation

Company, LLC (EGC) requested amendments to Renewed Facility Operating License Nos. DPR-44 and DPR-56 forPeach Bottom Atomic Power Station (PBAPS),

Units 2 and 3, respectively (Reference 1).Specifically, the proposed changes would revise the Renewed Operating Licenses toimplement an increase in rated thermal power from 3514 megawatts thermal (MWt) to3951 MWt. During their technical review of the application, the NRC Staff identified theneed for additional information.

The NRC has provided Requests for Additional Information (RAI) related to the replacement steam dryer (RSD). Proprietary and non-proprietary versions of the responses to the outstanding requests (EMCB-SD-RAIs 44and 57) are provided in Attachments 1 and 2.In accordance with discussions with the NRC staff, a new license condition related to thereplacement steam dryer is proposed for each unit in Attachment

3. These licenseconditions are responsive to three RAIs (EMCB-SD-RAIs 41 through 43).Westinghouse Electric Company (WEC) considers portions of the information providedin the Attachment 1 responses proprietary and therefore exempt from public disclosure pursuant to 10 CFR 2.390. In accordance with 10 CFR 2.390 and in support of thisrequest for withholding, an affidavit executed by WEC is provided in Attachment 4.EGC 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 amendment does not involve a significant hazards consideration.

Further, the additional information Attachment I contains Proprietary Information.

When separated from Attachment 1, this document is decontrolled.

ý,A U. S. Nuclear Regulatory Commission EPU LAR Supplement 26Response to Request for Additional Information May 6, 2014Page 2provided 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 the6" day of May 2014.Respectfully, Craig W.. LrertVice Presi ent, Pow ratesExelon Generation

Company, LLCAttachments:

1. Response to Request for Additional Information

-EMCB-SD -Proprietary

2. Response to Request for Additional Information

-EMCB-SD3. Proposed License Conditions related to the Replacement Steam Dryer4. Affidavit in Support of Request to Withhold Information cc: USNRC Region I, Regional Administrator w/attachments USNRC Senior Resident Inspector, PBAPS w/attachments USNRC Project Manager, PBAPS w/attachments R. R. Janati, Commonwealth of Pennsylvania w/o proprietary attachment S. T. Gray, State of Maryland w/o proprietary attachment EPU LAR Supplement 26 Attachment 2Response to RAI -EMCB-SD Page 1 of 6Response to Reauest for Additional Information Mechanical and Civil Engineering Branch (EMCB) -Steam Dryer (SD)By letter dated September 28, 2012, Exelon Generation

Company, LLC (Exelon)submitted a license amendment request for Peach Bottom Atomic Power Station(PBAPS),

Units 2 and 3. The proposed amendment would authorize an increase in themaximum power level from 3514 megawatts thermal (MWt) to 3951 MWt. Therequested change, referred to as an extended power uprate (EPU), represents anincrease of approximately 12.4 percent above the current licensed thermal power level.The NRC staff has reviewed the information supporting the proposed amendment andhas requested additional information.

The responses to EMCB-SD-RAIs 44 and 57 are provided below.EMCB-SD-RAI-44 With regard to the license condition noted in EMCB-SD-RAI-42, Section C(15)(b)(1)

(i.e.,RMS strain),

please provide general criteria for selecting dominant frequency peaks andfrequency ranges in PBAPS Unit 2 and PBAPS Unit 3 dryer maximum stress regionsthat address the following items:a) Apply these criteria to the PBAPS Unit 2 instrumented dryer strain gages, providelist(s) of dominant peaks to be bounded, and propose license condition(s) for howExelon will ensure that measured PBAPS Unit 2 on-dryer strains will be bounded atdominant frequencies by simulations (including application of bias errors anduncertainties (B/Us)).b) Provide a license condition which includes the list of dominant frequencies forPBAPS Unit 3. Following re-benchmarking of the overall dryer stress simulation methodology after data are acquired for PBAPS Unit 2 at the current licensedthermal power (CLTP), reapply the criteria to PBAPS Unit 2 and PBAPS Unit 3 andupdate the list of dominant frequencies that must be bounded.RESPONSEa) At a power level [Ia,c EPU LAR Supplement 26Response to RAI -EMCB-SDAttachment 2Page 2 of 6To provide a consistent approach to [axCA license condition will be provided in response to EMCB-SD-RAI-42 (seeAttachment

3) that will ensure that measured PBAPS Unit 2 on-dryer strains will bebounded at dominant frequencies.

b) For PBAPS Unit 3, [

EPU LAR Supplement 26Response to RAI -EMCB-SDAttachment 2Page 3 of 6]".c The Unit 3 dominant frequencies will besubmitted 90 days prior to the start of the Unit 3 EPU outage, in accordance with theproposed license condition contained in response to EMCB-SD-RAI-43 (seeAttachment 3).]a,b,cFigure RAI-44-1 PBAPS Unit 2 Stress PSD []a'CI a'C EPU LAR Supplement 26Response to RAI -EMC B-SDAttachment 2Page 4 of 6II ab,cFigure RAI-44-2 PBAPS Unit 2 Stress PSD [Ia, EPU LAR Supplement 26 Attachment 2Response to RAI -EMCB-SD Page 5 of 6EMCB-SD-RAI-57 PBAPS steam dryer stresses in WCAP-17609-P, Revision 2 dated March 2014 arebased on Monticello (MNGP) end-to-end benchmark based Bias errors andUncertainties (B/Us) for the upper (hood) portion.

These MNGP based B/Us wereaffected by a recently discovered error in mis-labeling of MNGP MSL-C upper and lowerStrain gage leads to the Data Acquisition System (DAS). Therefore, the NRC staffrequests the following:

(d) Determine the impact of any changes to MNGP B/Us on the PBAPS steam dryerstresses.

(e) Verify and confirm that the PBAPS dryer qualifications are based on proper scalefactor settings in data acquisition and free of any inadvertent errors in labeling ofthe leads.(f) Provide guidance to the data acquisition personnel acquiring data during theupcoming PBAPS Unit 2 specific benchmarking at CLTP and subsequent powerascension from CLTP to EPU regarding DAS scale factor settings andverification of labeling of the various leads to the DAS.RESPONSEa) WCAP-17590-P Rev. 2, "Peach Bottom Units 2&3 Replacement Steam DryerAcoustic Load Definition" provided the []B.C The [acThe new [a,c EPU LAR Supplement 26Response to RAI -EMCB-SDAttachment 2Page 6 of 6Table RAI-57-1

[a, ,cThe []a,cb) The labeling and verification of the PBAPS MSL strain gauge leads to the DAS wasperformed in accordance with the Exelon configuration control process.

The PBAPSDAS scale factor measurement range was not adjusted, and a review of the baselinedata documentation confirmed the data was taken at the appropriate range and gainsettings.

In addition, a review of the PBAPS Units 2 and 3 plant data was performed which indicates a consistency between the upper strain gauge locations for all fourmain steam lines and between the lower strain gauge locations for all four mainsteam lines. The above controls and verifications confirm the data acquisition wasbased on the proper scale factor settings and free of inadvertent errors in labelingthe leads.c) Industry Operating Experience (OPEX) regarding recent data acquisition errors willbe included in the PBAPS replacement steam dryer instrumentation cabling / DASinstallation and data acquisition personnel briefings.

In addition, installation and dataacquisition procedures and guidance documents will continue to include verifications regarding proper settings and labeling of MSL instrumentation, replacement steamdryer instrumentation, and DAS equipment in accordance with PBAPS configuration control practices.

Finally, the DAS measurement range setting will be verified byDAS operators prior to acquisition of each data set during power ascension.

I a,c Attachment 3Peach Bottom Atomic Power Station Units 2 and 3NRC Docket Nos. 50-277 and 50-278PROPOSED LICENSE CONDITIONS RELATED TOTHE REPLACEMENT STEAM DRYER EPU LAR Supplement 26 Attachment 3Proposed License Conditions Related to the Replacement Steam Dryer Page 1 of 12PROPOSED LICENSE CONDITIONS RELATED TOTHE REPLACEMENT STEAM DRYERNew license condition for PBAPS Unit 2 Renewed License No. DPR-44A new License Condition Section 2.C(15) to the PBAPS Unit 2 Renewed Operating License is proposed below. The license condition is responsive to EMCB-SD-RAIs 41and 42.(15) Potential Adverse Flow EffectsIn conjunction with the license amendment to revise paragraph 2.C(1) ofRenewed Facility Operating License No. DPR-44, for Peach BottomUnit 2, to reflect the new maximum licensed reactor core power level of3951 megawatts thermal (MWt), the license is also amended to add thefollowing license condition.

This license condition provides for monitoring, evaluating, and taking prompt action in response to potential adverse floweffects as a result of power uprate operation on plant structures, systems,and components (including verifying the continued structural integrity ofthe steam dryer). This license condition is applicable to the initial powerascension from 3514 MWt to the extended power uprate (EPU) powerlevel of 3951 MWt:(a) The following requirements are placed on the initialoperation of the facility, above the thermal power level of3514 MWt, for the power ascension to 3951 MWt. Theseconditions are applicable until the first time full EPUconditions (3951 MWt) are achieved.

If the number ofactive main steam line (MSL) strain gauges is less thantwo strain gauges (180 degrees apart) at any of the eightMSL locations, Exelon Generation Company will stoppower ascension and repair/replace the damaged straingauges and only then resume power ascension.

Inaddition, sufficient on-dryer strain gauges must remain inworking order to monitor all dryer peak stress locations with a minimum alternating stress ratio (MASR) less than1.5. In the event there are no working on-dryer straingauges, with coherence of greater than 0.5 with any peakstress location, Exelon Generation Company will: (1) stoppower ascension; (2) evaluate the dryer MASR at thecurrent power level and at the projected EPU power level;and (3) provide the results to the NRC Project Manager viae-mail. Exelon Generation Company shall not resumepower ascension for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the NRCProject Manager confirms receipt of the MASR resultsunless, prior to the expiration of the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, theNRC Project Manager advises that the NRC staff has noobjections to the continuation of power ascension.

EPU LAR Supplement 26 Attachment 3Proposed License Conditions Related to the Replacement Steam Dryer Page 2 of 12Furthermore, power ascension may only resume if ExelonGeneration Company determines that the dryer MASR willremain greater than 1.0.1. Exelon Generation Company shall provide a briefstress summary report for the replacement steam dryer(RSD) based on MSL strain gauge and on-dryerinstrument data collected at or near 3514 MWt for NRCreview before increasing power above 3514 MWt.Exelon Generation Company shall also provide a briefvibration summary report for piping and valve vibration data collected at or near 3514 MWt for NRC reviewbefore increasing power above 3514 MWt. Bothsummary reports shall be provided by e-mail to theNRC Project Manager.

Exelon Generation Companyshall not increase power above 3514 MWt for at least240 hours after the NRC Project Manager confirmsreceipt of the reports unless, prior to expiration of the240 hour period, the NRC Project Manager advisesthat the NRC staff has no objections to the continuation of power ascension.

The stress summary report shallinclude the information in items a through f, and thevibration summary report shall include the information in items g through i, as follows:a. A comparison of predicted and measured pressurespectra plots on the RSD.b. A comparison of predicted and measured rootmean square (RMS) strains and spectra plots onthe RSD.c. End-to-end bias errors and uncertainties (B/Us) forRSD strains, along with a demonstration that theapplication of these B/Us leads to RSD strainsimulations that bound the measured spectra atdominant frequencies and RMS strains at all activestrain gauge locations.

d. RSD strain gauge limits based on benchmarking performed near 3514 MWt. This will include thepredicted RSD strains at each measured locationand the corresponding updated MASR near 3514MWt.e. Predicted (extrapolated) strains at the active RSDstrain gauge locations at 104% of 3514 MWt andan evaluation against acceptance limits.f. Predicted RSD stresses and MASRs at EPU.

EPU LAR Supplement 26 Attachment 3Proposed License Conditions Related to the Replacement Steam Dryer Page 3 of 12g. Vibration data for piping and valve locations deemed prone to vibration and vibration monitoring locations identified in Attachment 13 to the EPUapplication dated September 28, 2012, including the following locations:

MSLs (including those inthe drywell, turbine building and in the steamtunnel),

Feedwater Lines (including those in thedrywell and turbine building),

Safety Relief Valves(SRVs) and Main Steam Isolation Valves in thedrywell.h. An evaluation of the measured vibration datacollected in item 1.g above compared againstacceptance limits.i. Predicted vibration values and associated acceptance limits at approximately 104 percent,108 percent and 112.4 percent of 3514 MWt usingthe data collected in item g above.2. Exelon Generation Company shall monitor the RSDstrain gauges during power ascension above 3514MWt for increasing strain fluctuations.

Upon the initialincrease of power above 3514 MWt until reaching 3951MWt, Exelon Generation Company shall collect datafrom the RSD strain gauges at nominal 2 percentthermal power increments and evaluate steam dryerstress ratios based on these data. Summaries of theresults shall be provided via e-mail to the NRC ProjectManager at approximately 104 percent and 108percent of 3514 MWt.3. Exelon Generation Company shall monitor the MSLstrain gauges during power ascension above 3514MWt for increasing pressure fluctuations in the mainsteam lines. Upon the initial increase of power above3514 MWt until reaching 3951 MWt, Exelon Generation Company shall collect data from the MSL strain gaugesand on-dryer instruments at nominal 2 percent thermalpower increments.

4. Exelon Generation Company shall hold the facility atapproximately 104 percent and 108 percent of 3514MWt to perform the following:

a. Collect strain data from the MSL strain gauges andcollect data from on-dryer instruments (accelerometers, strain gauges, and pressuretransducers).

EPU LAR Supplement 26 Attachment 3Proposed License Conditions Related to the Replacement Steam Dryer Page 4 of 12b. Collect vibration data for the locations included inthe vibration summary report discussed above.c. Evaluate steam dryer performance based on RSDstrain gauge data.d. Evaluate the measured vibration data (collected initem 4.b above) at that power level, data projected to EPU conditions, trends, and comparison with theacceptance limits.e. Provide the steam dryer evaluation and thevibration evaluation, including the data collected, via e-mail to the NRC Project Manager, uponcompletion of the evaluation for each of the twohold points.f. Exelon Generation Company shall submit acomparison of predicted and measured pressures and strains (RMS and spectra) on the RSD at104% of 3514 MWt and 108% of 3514 MWt duringpower ascension.

g. Exelon Generation Company shall not increasepower above each hold point until 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> afterthe NRC Project Manager confirms receipt of theevaluations unless, prior to the expiration of the 96hour period, the NRC Project Manager advises thatthe NRC staff has no objections to the continuation of power ascension.

5. If any RMS level measured by the active RSD straingauges exceeds allowable Level 1 limits, ExelonGeneration Company shall return the facility to a powerlevel at which the limit(s) is not exceeded.

ExelonGeneration Company shall resolve the discrepancy, evaluate and document the continued structural integrity of the steam dryer, and provide thatdocumentation to the NRC Project Manager via e-mailprior to further increases in reactor power. If a revisedstress analysis is performed and new RSD strain limitsare developed, then Exelon Generation Company shallnot further increase power above each hold point until96 hours after the NRC Project Manager confirmsreceipt of the documentation or until the NRC ProjectManager advises that the NRC staff has no objections to the continuation of power ascension, whichever comes first. Additional detail is provided in paragraph (b)l below.

EPU LAR Supplement 26 Attachment 3Proposed License Conditions Related to the Replacement Steam Dryer Page 5 of 12(b) Exelon Generation Company shall implement the following actions for the initial power ascension from 3514 MWt to3951 MWt condition:

1. In the event that RMS strain levels for active RSDstrain gauges are identified to-exceed the allowable Level 1 limits during power ascension above 3514MWt, Exelon Generation Company shall re-evaluate dryer loads and stresses, and re-establish updatedMASRs and RSD strain gauge RMS limits. In theevent that stress analyses are re-performed based onnew strain gauge data to address paragraph (a)5above, the revised load definition, stress analysis, andlimits shall include:a. Determination of end-to-end B/Us and theirapplication in determining maximum alternating stress intensities.

b. Use of bump-up factors associated with all of theSRV acoustic resonances, as determined from thescale model test results or in-plant data acquiredduring power ascension.

2. After reaching 3951 MWt, Exelon Generation Companyshall obtain measurements from the MSL strain gaugesand establish the steam dryer flow-induced vibration load fatigue margin for the facility, update the dryerstress report, and re-establish the RSD strain gaugelimits based on the updated load definition.

These datawill be provided to the NRC staff as described below inparagraph (e).(c) Exelon Generation Company shall prepare the EPU powerascension test procedure to include:1. The stress limits and the corresponding RSD strainlimits to be applied for evaluating steam dryerperformance.

2. Specific hold points and their durations during EPUpower ascension.

3. Activities to be accomplished during the hold points.4. Plant parameters to be monitored.

EPU LAR Supplement 26 Attachment 3Proposed License Conditions Related to the Replacement Steam Dryer Page 6 of 125. Inspections and walkdowns to be conducted for steam,feedwater, and condensate systems and components during the hold points.6. Methods to be used to trend plant parameters.

7. Acceptance criteria for monitoring and trending plantparameters, and conducting the walkdowns andinspections.

8. Actions to be taken if acceptance criteria are notsatisfied.

9. Verification of the completion of commitments andplanned actions specified in the application and allsupplements to the application in support of the EPUlicense amendment request pertaining to the steamdryer prior to power increase above 3514 MWt. ExelonGeneration Company shall provide the related EPUstartup test procedure sections to the NRC ProjectManager via e-mail prior to increasing power above3514 MWt.(d) The following key attributes of the program for verifying thecontinued structural integrity of the steam dryer shall notbe made less restrictive without prior NRC approval:

1. During initial power ascension testing above 3514MWt, each of the two hold points shall be at increments of 4 percent of 3514 MWt.2. Level 1 performance criteria.

3. The methodology for establishing the RSD strain limitsused for the Level 1 and Level 2 performance.

(e) The results of the power ascension testing to verify thecontinued structural integrity of the steam dryer shall besubmitted to the NRC staff in a report in accordance with10 CFR 50.4. The report shall include a final loaddefinition and stress report of the steam dryer, including the results of a complete re-analysis using the end-to-end B/Us determined at EPU conditions and a comparison ofpredicted and measured pressures and strains (RMSlevels and spectra) on the RSD. The report shall besubmitted within 90 days of the completion of EPU powerascension testing for Peach Bottom Unit 2.(f) During the first two scheduled refueling outages afterreaching EPU conditions, a visual inspection shall be EPU LAR Supplement 26 Attachment 3Proposed License Conditions Related to the Replacement Steam Dryer Page 7 of 12conducted of the steam dryer as described in theinspection guidelines contained in WCAP-17635-P.

(g) The results of the visual inspections of the steam dryershall be submitted to the NRC staff in a report inaccordance with 10 CFR 50.4. The report shall besubmitted within 90 days following startup from each of thefirst two respective refueling outages.(h) Within 6 months following completion of the secondrefueling outage, after the implementation of the EPU, thelicensee shall submit a long-term steam dryer inspection plan based on industry operating experience along with thebaseline inspection results.The license condition described above shall expire: (1) upon satisfaction of the requirements in paragraphs (f) and (g), provided that a visualinspection of the steam dryer does not reveal any new unacceptable flaw(s) or unacceptable flaw growth that is due to fatigue, and; (2) uponsatisfaction of the requirements specified in paragraph (h).New license condition for PBAPS Unit 3 Renewed License No. DPR-56A new License Condition Section 2.C(15) to the PBAPS Unit 3 Renewed Operating License is proposed below. The license condition is responsive to EMCB-SD-RAI 43.(15) Potential Adverse Flow EffectsIn conjunction with the license amendment to revise paragraph 2.C(1) ofRenewed Facility Operating License No. DPR-56, for Peach BottomUnit 3, to reflect the new maximum licensed reactor core power level of3951 megawatts thermal (MIVt), the license is also amended to add thefollowing license condition.

This license condition provides for monitoring, evaluating, and taking prompt action in response to potential adverse floweffects as a result of power uprate operation on plant structures, systems,and components (including verifying the continued structural integrity ofthe steam dryer). This license condition is applicable to the initial powerascension from 3514 MWt to the extended power uprate (EPU) powerlevel of 3951 MWt:(a) The following requirements are placed on the initialoperation of the facility, above the thermal power level of3514 MWt, for the power ascension to 3951 MWt. Theseconditions are applicable until the first time full EPUconditions (3951 MWt) are achieved.

If the number ofactive main steam line (MSL) strain gauges is less thantwo strain gauges (180 degrees apart) at any of the eightMSL locations, Exelon Generation Company will stop EPU LAR Supplement 26 Attachment 3Proposed License Conditions Related to the Replacement Steam Dryer Page 8 of 12power ascension and repair/replace the damaged straingauges and only then resume power ascension.

1. At least 90 days prior to the start of the Peach BottomUnit 3 EPU outage, Exelon Generation Company shallrevise the Peach Bottom Unit 3 replacement steamdryer (RSD) analysis utilizing the Unit 2 on-dryer straingauge based end-to-end Bias errors and Uncertainties (B/Us) at EPU conditions, and submit the information including the updated limit curves and a list ofdominant frequencies for Unit 3, to the NRC as a reportin accordance with 10 CFR 50.4.2. Exelon Generation Company shall evaluate the Unit 3limit curves prepared in 15(a)1 above based on newMSL strain gauge data collected following the Unit 3EPU outage at or near 3514 MWt. If the limit curveschange, the new post-EPU outage limit curves shall beprovided by e-mail to the NRC Project Manager.Exelon Generation Company shall not increase powerabove 3514 MWt for at least 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> after the NRCProject Manager confirms receipt of the report unless,prior to expiration of the 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> period, the NRCProject Manager advises that the NRC staff has noobjections to the continuation of power ascension.

3. Exelon Generation Company shall provide a briefvibration summary report, for piping and valvesvibration data collected at or near 3514 MWt, for NRCreview before increasing power above 3514 MWt. Thesummary report shall be provided by e-mail to the NRCProject Manager.

Exelon Generation Company shallnot increase power above 3514 MWt for at least 96hours after the NRC Project Manager confirms receiptof the report unless, prior to expiration of the 96 hourperiod, the NRC Project Manager advises that the NRCstaff has no objections to the continuation of powerascension.

The vibration summary report shall includethe information in items a through c, as follows:a. Vibration data for piping and valve locations deemed prone to vibration and vibration monitoring locations identified in Attachment 13 to the EPUapplication dated September 28, 2012, including the following locations:

MSLs (including those inthe drywell, turbine building and in the steamtunnel),

Feedwater Lines (including those in thedrywell and turbine building),

Safety Relief Valves(SRVs) and the Main Steam Isolation Valves in thedrywell.

EPU LAR Supplement 26 Attachment 3Proposed License Conditions Related to the Replacement Steam Dryer Page 9 of 12b. An evaluation of the measured vibration datacollected in item a above compared againstacceptance limits.c. Predicted vibration values and associated acceptance limits at approximately 104 percentT108 and 112.4 percent of 3514 MWt using the datacollected in item a, above.4. Exelon Generation Company shall monitor the MSLstrain gauges during power ascension above 3514MWt for increasing pressure fluctuations in the steamlines. Upon the initial increase of power above 3514MWt until reaching 3951 MWt, Exelon Generation Company shall collect data from the MSL strain gaugesat nominal 2 percent thermal power increments andevaluate steam dryer performance based on this data.5. During power ascension at each nominal 2 percentpower level above 3514 MWt, Exelon Generation Company shall compare the MSL data to the approvedlimit curves based on end-to-end B/Us from the PeachBottom Unit 2 benchmarking at EPU conditions anddetermine the minimum alternating stress ratio(MASR). A summary of the results shall be providedfor NRC review at approximately 104 percent and 108percent of 3514 MWt. The summary report shall beprovided to the NRC Project Manager via e-mail.6. Exelon Generation Company shall hold the facility atapproximately 104 percent and 108 percent of 3514MWt to perform the following:

a. Collect strain data from the MSL strain gauges.b. Collect vibration data for the locations included inthe vibration summary report discussed above.c. Evaluate steam dryer performance based on MSLstrain gauge data.d. Evaluate the measured vibration data (collected initem 6.b above) at that power level, data projected to EPU conditions, trends, and comparison with theacceptance limits.e. Provide the steam dryer evaluation and thevibration evaluation, including the data collected, via e-mail to the NRC Project Manager, upon EPU LAR Supplement 26 Attachment 3Proposed License Conditions Related to the Replacement Steam Dryer Page 10 of 12completion of the evaluation for each of the holdpoints.f. Exelon Generation Company shall not increasepower above each hold point until 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> afterthe NRC Project Manager confirms receipt of theevaluations unless, prior to the expiration of the 96hour period, the NRC Project Manager advises thatthe NRC staff has no objections to the continuation of power ascension.

7. If any frequency peak from the MSL strain gauge dataexceeds the Level 1 limit curves, Exelon Generation Company shall return the facility to a power level atwhich the limit curve is not exceeded.

ExelonGeneration Company shall resolve the discrepancy, evaluate and document the continued structural integrity of the steam dryer, and provide thatdocumentation to the NRC Project Manager via e-mailprior to further increases in reactor power. If a revisedstress analysis is performed and new limit curves aredeveloped, then Exelon Generation Company shall notfurther increase power above each hold point until 96hours after the NRC Project Manager confirms receiptof the documentation or until the NRC Project Manageradvises that the NRC staff has no objections to thecontinuation of power ascension, whichever comesfirst. Additional detail is provided in paragraph (b)lbelow.(b) Exelon Generation Company shall implement the following actions for the initial power ascension from 3514 MWt to3951 MWt condition:

1. In the event that acoustic signals (in MSL strain gaugesignals) are identified that exceed the Level 1 limitcurves during power ascension above 3514 MWt,Exelon Generation Company shall re-evaluate dryerloads and stresses, and re-establish the limit curves.In the event that stress analyses are re-performed based on new strain gauge data to address paragraph (a)7 above, the revised load definition, stress analysis, and limit curves shall include:a. Application of end-to-end B/Us as determined fromPeach Bottom Unit 2 EPU measurements.

b. Use of bump-up factors associated with all of theSRV acoustic resonances as determined from the EPU LAR Supplement 26 Attachment 3Proposed License Conditions Related to the Replacement Steam Dryer Page 11 of 12scale model test results or in-plant data acquiredduring power ascension.

2. After reaching 3951 MWt. Exelon Generation Companyshall obtain measurements from the MSL strain gaugesand establish the steam dryer flow-induced vibration load fatigue margin for the facility, update the dryerstress report, and re-establish the limit curves with theupdated load definition.

These data will be provided tothe NRC staff as described below in paragraph (e).(c) Exelon Generation Company shall prepare the EPU powerascension test procedure to include:1. The MSL strain gage limit curves to be applied forevaluating steam dryer performance, based on end-to-end B/Us from Peach Bottom Unit 2 benchmarking atEPU conditions

2. Specific hold points and their durations during EPUpower ascension.

3. Activities to be accomplished during the hold points.4. Plant parameters to be monitored.

5. Inspections and walkdowns to be conducted for steam,feedwater, and condensate systems and components during the hold points.6. Methods to be used to trend plant parameters.

7. Acceptance criteria for monitoring and trending plantparameters, and conducting the walkdowns andinspections.

8. Actions to be taken if acceptance criteria are notsatisfied.

9. Verification of the completion of commitments andplanned actions specified in the application and allsupplements to the application in support of the EPUlicense amendment request pertaining to the steamdryer prior to power increase above 3514 MWt. ExelonGeneration Company shall provide the related EPUstartup test procedure sections to the NRC ProjectManager via e-mail prior to increasing power above3514 MWt.

EPU LAR Supplement 26 Attachment 3Proposed License Conditions Related to the Replacement Steam Dryer Page 12 of 12(d) The following key attributes of the program for verifying thecontinued structural integrity of the steam dryer shall notbe made less restrictive without prior NRC approval:

1. During initial power ascension testing above 3514MWt, each of the two hold points shall be at increments of approximately 4 percent of 3514 MWt.2. Level 1 performance criteria.

3. The methodology for establishing the limit curves usedfor the Level 1 and Level 2 performance.

(e) The results of the power ascension testing to verify thecontinued structural integrity of the steam dryer shall besubmitted to the NRC staff in a report in accordance with10 CFR 50.4. The report shall include a final loaddefinition and stress report of the steam dryer, including the results of a complete re-analysis using the end-to-end B/Us from Peach Bottom Unit 2 benchmarking at EPUconditions.

The report shall be submitted within 90 days ofthe completion of EPU power ascension testing for PeachBottom Unit 3.(f) During the first two scheduled refueling outages afterreaching EPU conditions, a visual inspection shall beconducted of the steam dryer as described in theinspection guidelines contained in WCAP-17635-P.

(g) The results of the visual inspections of the steam dryershall be submitted to the NRC staff in a report inaccordance with 10 CFR 50.4. The report shall besubmitted within 90 days following startup from each of thefirst two respective refueling outages.(h) Within 6 months following completion of the secondrefueling outage, after the implementation of the EPU, thelicensee shall submit a long-term steam dryer inspection plan based on industry operating experience along with thebaseline inspection results.The license condition described above shall expire: (1) upon satisfaction of the requirements in paragraphs (f) and (g), provided that a visualinspection of the steam dryer does not reveal any new unacceptable flaw(s) or unacceptable flaw growth that is due to fatigue, and; (2) uponsatisfaction of the requirements specified in paragraph (h).

Attachment 4Peach Bottom Atomic Power Station Units 2 and 3NRC Docket Nos. 50-277 and 50-278AFFIDAVIT NoteAttachment 1 contains proprietary information as defined by 10 CFR 2.390.WEC, as the owner of the proprietary information, has executed theenclosed affidavit, which identifies that the proprietary information has beenhandled and classified as proprietary, is customarily held in confidence, andhas been withheld from public disclosure.

The proprietary information hasbeen faithfully reproduced in the attachment such that the affidavit remainsapplicable.

Westinghouse Electric CompanyEngineering, Equipment and Major Projects1000 Westinghouse Drive, Building 3Cranberry

Township, Pennsylvania 16066USAU.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643Document Control Desk Direct fax: (724) 940-856011555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852CAW-14-3953 May 5, 2014APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

Attachment I "Response to Request for Additional Information

-EMCB-SD-Proprietary,"

attached to Exelon Generation submittal to the NRC "Extended Power Uprate LicenseAmendment Request -Supplement 26, Response to Request for Additional Information" The proprietary information for which withholding is being requested in the above-referenced report isfurther identified in Affidavit CAW-14-3953 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The Affidavit, which accompanies this letter, sets forth the basison which the information may be withheld from public disclosure by the Commission and addresses withspecificity 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 theWestinghouse Affidavit should reference CAW-14-3953 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,James A. Gresham, ManagerRegulatory Compliance Enclosures CAW-14-3953 AFFIDAVIT COMMONWEALTH 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 Licensing Sworn towad subscribed before methis __day of i21.. 2014Notary(blic

N seai Nl ReneiG ampole, Notary ptblicI Penn TWP._Wtmorelart couty* .. m = l o F x r e s s p .2 5 , 2 0 1 7 2CAW-14-3953 (1) 1 am Principal

Engineer, Plant Licensing, in Engineering, Equipment and Major Projects, 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 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 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 theinformation 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 heldin confidence 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 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 inconfidence.

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 severaltypes, 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 3CAW-14-3953 Westinghouse's competitors without license from Westinghouse constitutes acompetitive economic advantage 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 improvedmarketability.

(c) Its use by a competitor would reduce his expenditure of resources or improve hiscompetitive 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, orcommercial 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, for which 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 competitive advantage over its competitors.

It is, therefore, withheld from disclosure toprotect the 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 tosell products 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-14-3953 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage.

Ifcompetitors acquire components of proprietary information, any one component may 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 anddevelopment depends upon the success in obtaining and maintaining acompetitive 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 theCommission.

(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 tothe best of our knowledge and belief.(vi) The proprietary information sought to be withheld in this submittal is that which isappropriately marked in Attachment 1 "Response to Request for Additional Information

-EMCB-SD -Proprietary,"

attached to Exelon Generation submittal to the NRC "Extended Power Uprate License Amendment Request -Supplement 26, 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 that associated with the review of the Replacement Steam Dryer designand analysis which is a part of the Extended Power Uprate License Amendment Requestfor Peach Bottom Units 2 and 3, and may be used only for that purpose.

5CAW-14-3953 (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 licensing basis 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 aspects of 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 documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applyingthe 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 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 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 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, copyright protection 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.