ML15322A089

E.I. Hatch, Units 1 and 2 - Response to Request for Additional Information Regarding Application for Amendment to Technical Specifications for Relocation of Pressure and Temperature (P-T) Curves to the Pressure and Temperature Limits Report

ML15322A089
Person / Time
Site:	Hatch
Issue date:	11/12/2015
From:	Pierce C R Southern Co, Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML15322A088	List: ML15322A089 ML15322A090 ML15322A091 ML15322A092 NL-15-2034, Calculation No. 1001527.303, Revision 0, Feedwater, Water Level Instrument, and Core Dp Nozzle Fracture Mechanics Evaluation for Hatch, Unit 1 and Unit 2 Pressure-Temperature Limit Curve Development NL-15-2034, Calculation No. 1001527.304, Revision 2, Hatch Unit 1, P-T Curve Calculation for 38 and 49.3 EFPY NL-15-2034, Calculation No. 1001527.305, Revision 2, Hatch Unit 2 P-T Curve Calculation for 37 and 50.1 EFPY NL-15-2034, E.I. Hatch, Units 1 and 2 - Enclosure 4, Non-Proprietary Version of the Epri/Bwrvip Information Requested in RAI 1 NL-15-2034, E.I. Hatch, Units 1 and 2 - Response to Request for Additional Information Regarding Application for Amendment to Technical Specifications for Relocation of Pressure and Temperature (P-T) Curves to the Pressure and Temperature Limits Repo
References
MF6063, MF6064, NL-15-2034
Download: ML15322A089 (17)

Text

Charles R. PierceRegulatory Affairs DirectorSouthern NuclearOperating Company, Inc.40 Inverness Center ParkwayPost Office Box 1295Birmingham, AL 35242Tel 205.992.7872Fax 205.992.7601Proprietary Information -Withhold Under 10 CFR 2.390 ISOUTHERNNUCLEARA SOUTHERzN COMPANYNovember 12, 2015Docket Nos.: 50-32150-366NL-1 5-2034U. S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, D. C. 20555-0001Edwin I. Hatch Nuclear PlantResponse to Request for Additional Information Regarding Application forAmendment to Technical Specifications for Relocation of Pressure andTemperature (P-T) Curves to the Pressure and Temperature Limits Report(PTLR) Consistent with TSTF-41 9-ALadies and Gentlemen:By letter dated April 2, 2015 (Agencywide Documents Access and ManagementSystem (ADAMS) Accession No. ML15092A856), Southern Nuclear OperatingCompany (SNC) submitted a license amendment request for the Edwin I. HatchNuclear Plant (HNP). This request would modify the Unit 1 and Unit 2 TechnicalSpecifications (TS) Section 1.0 ("Definitions"), Limiting Conditions for Operationand Surveillance Requirement Applicability Section 3.4.9 ("RCS Pressure andTemperature (PIT) Limits"'), and Section 5.0 ("Administrative Controls") to deletereference to the pressure and temperature curves, and to include reference to thePressure and Temperature Limits Report (PTLR). By letter dated October 13,2015, the Nuclear Regulatory Commission (NRC) staff issued a request foradditional information (RAI).Enclosure 1 provides the SNC response to the NRC RAI. Enclosure 2 providesthe supporting affidavit from Electric Power Research Institute (EPRI), the ownerof the proprietary information in the Enclosure 3 response, requesting withholdingof proprietary information. This affidavit sets forth the basis on which theinformation in Enclosure 3 may be withheld from public disclosure by theCommission and addresses with specificity the considerations listed in paragraph(b)(4) of 10 CFR 2.390 of the Commission's regulations. Accordingly, it isrespectfully requested that the information, which is proprietary to EPRI, bewithheld from public disclosure in accordance with 2.390 of the Commission'sr~gulations. Enclosure 3 provides the proprietary version of the EPRI informationrequested in RAI 1, while Enclosure 4 provides the corresponding non-proprietaryversion of this EPRI information. Enclosure 5 provides the requested StructuralIntegrity Associates (SIA) calculations requested in RAI 1 and RAI 5. SIAcalculation 1001527.303 contains information that is proprietary to GeneralEnergy Hitachi. This information has been redacted from the SIA calculationA~6~

U. S. Nuclear Regulatory CommissionNL-1 5-2034Page 2included in Enclosure 5 but can be provided to the NRC upon request. Enclosure6 provides the TransWare fluence evaluation reports requested in RAI 1. Pleasenote that the TransWare reports state "Southern Nuclear Proprietary Information"at the top header. SNC considers the reports to be intellectual property belongingto SNC, but does not consider these reports proprietary. As such, SNC does notrequest withholding of this information under 10 CFR 2.390. Enclosure 7provides the corrected Table 3 to the Unit 1 PTLR that was provided in. Enclosure5 to the April 2, 2015 letter.This letter contains no NRC commitments. If you have any questions, pleasecontact Ken McElroy at (205) 992-7369.Mr. C. R. Pierce states he is Regulatory Affairs Director of Southern NuclearOperating Company, is authorized to execute this oath on behalf of SouthernNuclear Operating Company and, to the best of his knowledge and belief, thefacts set forth in this letter are true.Respectfullysubm i~d,,C. R. Pierce Regulatory Affairs DirectorCRP/RMJme this ofjj ,2015.My commission expires: //6 ) -_z l "I

Enclosures:

1. SNC Response to NRC RAI2. Electric Power Research Institute (EPRI) affidavit requestingwithholding of proprietary information3. Proprietary Version of the EPRI Information Requested in RAI 14. Non-Proprietary Version of the EPRI Information Requested inRAI 15. Structural Integrity Associates (SIA) Calculations Requested inRAI 1 and RAI 56. TransWare Fluence Evaluation Reports Requested in RAI 17. Corrected Table 3 to the Unit 1 PTLR U. S. Nuclear Regulatory CommissionNL-1 5-2034Page 3cc: Southern Nuclear Operatincq CompanyMr. S. E. Kuczynski, Chairman, President & CEOMr. D. G. Bost, Executive Vice President & Chief Nuclear OfficerMr. D. R. Vineyard, Vice President -HatchMr. M. D. Meier, Vice President -Regulatory AffairsMr. D. R. Madison, Vice President -Fleet OperationsMr. B. J. Adams, Vice President -EngineeringMr. G. L. Johnson, Regulatory Affairs Manager -HatchRTYPE: CHA02.004U. S. Nuclear Re qulatory CommissionMr. L. D. Wert, Regional Administrator (Acting)Mr. R. E. Martin, NRR Senior Project Manager -HatchMr. D. H. Hardage, Senior Resident Inspector -HatchState of GeorqiaMr. J. H. Turner, Environmental Director Protection Division Edwin I. Hatch Nuclear PlantResponse to Request for Additional Information Regarding Application forAmendment to Technical Specifications for Relocation of Pressure andTemperature (P-T) Curves to the Pressure and Temperature Limits Report(PTLR) Consistent with TSTF-41 9-AEnclosure 1SNC Response to NRC RA! to NL-15-2034SNC Response to NRC RAI

References:

1. Letter from Mr. Bob Martin (U.S. NRC) to Mr. C. R. Pierce (SNOC),

Subject:

Edwin I. Hatch Nuclear Plant, Units 1 and 2 -Request forAdditional Information (TAO NOS. MF6063 and MF6064), October 13,2015, ADAMS Accession Number: ML15271A336.2. Sommerville, D.V., "Pressure-Temperature Limits Report Methodology forBoiling Water Reactors," SIR-05-044, Rev. 1-A, June 2013.3. Structural Integrity Associates Calculation No. 1001527.304, Revision 2,"Hatch Unit 1 P-T Curve Calculation for 38 and 49.3 EFPY", September2014.4. Structural Integrity Associates Calculation No. 1001527.305, Revision 2,"Hatch Unit 2 P-T Curve Calculation for 37 and 50.1 EFPY", September2014.5. BWRVIP-135, Revision 2: BWR Vessel and Internals Project, IntegratedSurveillance Program (ISP) Data Source Book and Plant Evaluations.EPRI, Palo Alto, CA: 2009. 1020231.6. Combustion Engineering Report No. CE NPSD-1 119, Revision 01,"Updated Analysis for Combustion Engineering Fabricated Reactor VesselWelds Best Estimate Copper and Nickel Content," July 1998. SI File No.1001527.207.NRC RAI 1Provide the following references from Enclosures 5 and 6 of the April 2, 2015,submittal to afford the NRC staff supporting information regarding the data andmethodology necessary for determining best estimate chemistries, materialchemistry factors, and neutron fluence:i. Enclosure 5, Reference 7: Structural Integrity-Associates Calculation No.1001527.301, Revision 1, "Hatch Unit 1 RPV Material Summary and ARTCalculation," July 2014.ii. Enclosure 5, Reference 12: Hatch 1 specific portions of EPRI Report No.1020231, "BWRVIP-1 35, Revision 2: BWR Vessel and Internals Project,Integrated Surveillance Program (ISP) Data Source Book and PlantEvaluations," Palo Alto, CA, 2009, and any related follow-on documentscontaining data specific to Hatch 1.iii. Enclosure 6, Reference 7: Structural Integrity-Associates Calculation No.1001527.302, Revision 1, "RPV Material Summary and ART Calculation,"July 2014.iv. Enclosure 6, Reference 12: Hatch 2 specific portions of EPRI Report No.1020231, "BWRVIP-135, Revision 2: BWR Vessel and Internals Project,Integrated Surveillance Program (ISP) Data Source Book and PlantEvaluations," Palo Alto, CA, 2009, and any related follow-on documentscontaining data specific to Hatch 2.v. Enclosure 5, Reference 5: Transware Enterprises Inc. Report No. SNC-HA1-002-R-001 Revision 0, "Edwin I. Hatch Unit 1 Fluence Evaluation atEnd of Cycle 25 and 49.3 EFPY."vi. Enclosure 6, Reference 5: Transware Enterprises Inc. Report No. SNC-HA2-001-R-001 Revision 0, "Edwin I. Hatch Unit 2 Fluence Evaluation atEnd of Cycle 22 and 50.1 EFPY."El-i to NL-15-2034SNC Response to NRC RAISNC Response to NRC RAI 1The requested additional Structural Integrity Associates references (i., iii.,) areincluded in Enclosure 5. The requested Hatch-specific portions from BWRVIP-135 (ii., iv.,) are included in Enclosures 3 and 4 representing a proprietary andnon-proprietary version of the information extracted as attested in the enclosedaffidavit from the Electric Power Research Institute (Enclosure 2). The requestedTransWare references (v., vi.) are included as Enclosure 6.NRC RAI 2Page 11 of Enclosure 5 of SNC's April 2, 2015 submittal states the following:The following summarizes the development of the thermal and pressurestress intensity factors for the [core delta-pressure] CDP nozzle [14]:*The KIT term is calculated using the ASME Xl, Non-mandatory AppendixG, Paragraph G-22 14.3 [17] methodology for a heat-up/cool-down rate of100 °F/hr as described in Reference [14].Paragraph G-2214.3 of Section Xl, Appendix G, contains methods for calculatingthe thermal stress intensity factor, KIT, for beltline shell regions of the reactorpressure vessel (RPV) due to radial thermal gradients. Normally, discontinuities(such as the CDP nozzle) would be evaluated based on Paragraph G-2220 ofSection XI, Appendix G, "Nozzles, Flanges, and shell Regions near GeometricDiscontinuities." However, the NRC staff notes that on page 2-19 of NRCapproved Topical Report (TR) BWROG-TP-1 1-022-A, Revision 1, "Pressure-Temperature Limits Report Methodology for Boiling Water Reactors," June 2013(ADAMS Accession No. ML13277A557), the following is stated:A conservative alternative to using Equation 2.5.3-3a or2.5.3-3b is to use theASME Code,Section XI, Nonmanda tory Appendix G [5] method forcalculating a thermal stress intensity factor for an edge cracked plate given inEquation 2.5.1-8, above, where the section thickness is taken as the length Ofthe diagonal path through the nozzle blend radius shown in Figure 2-7.Equation 2.5.1-8 of TR BWROG-TP-1 1-022-A, Revision 1 is as follows:KIT = 0.953 X 103 (CR) (t2"5)Where CR is the cooldown rate in °F/hr and t is the RPV wall thickness in inches.This equation is identical to the equation in Paragraph G-221 4.3 of Section Xl,Appendix G for the maximum KIT produced by a radial thermal gradient for apostulated axial or circumferential inside surface defect in a shell region.However, there are also several other equations contained in Paragraph G-221 4.3 of Section Xl, Appendix G for computing KIT.Confirm that Equation 2.5.1-8 of TR BWROG-TP-1 1-022-A, Revision 1 was usedto calculate KIT for the COP nozzle.El1-2 Enciosure 1 to NL-15-2034SNO Response to NRC RAISNC Response to NRC RAI 2Equation 2.5.1-8 of TR BWROG-TP-1 1-022-A, Revision 1 was used to calculateKIT for the CDP nozzle.NRC RAI 3Page 8 of Enclosure 5 of SNC's April 2, 2015, submittal briefly addresses thewater level instrument (WLI) nozzle for Hatch 1. Pages 9 through 11 of Enclosure5 address the feedwater nozzle for Hatch Nuclear Plant Unit 1 (Hatch 1). Page 11of Enclosure 5 addresses the CDP nozzle for Hatch 1. A summary of the thermalstress intensity factors, KIT, for all three nozzles is provided in Table 9 ofEnclosure 5.Similar discussions for the WLI and feedwater nozzles for Hatch Nuclear PlantUnit 2 (Hatch 2) are contained on pages 8 through 11 of Enclosure 6; however,discussion of the CDP nozzle is not included in Enclosure 6 for Hatch 2, nor is theCDP nozzle included in the summary of nozzle stress intensity factors for Hatch 2in Table 9 of Enclosure 6. Iftis also not clear from the discussion or the Table 9KIT values contained in either Enclosures 5 or 6 which nozzles are controlling withrespect to any of the pressure-temperature (P-T) limit curves shown in Figures 1through 6 of both enclosures.Provide the following:a. Explain why the CDP nozzle was addressed for Hatch 1 and not for Hatch2.b. Explain whether any of the evaluated nozzles control any portions of theP-T limit curves shown in Figures 1 through 6 of both Enclosures 5 and 6and, if so, identify which nozzles are limiting and describe the portions ofthe P-T curves that they control.SNC Response to NRC RAI 3:a. The CDP nozzle is specifically addressed for Hatch 1 because the CDPnozzle in Hatch 1 is located in the thinner shell section of the bottomhead; whereas, for Hatch 2 the CDP nozzle is in the thicker shell sectionof the bottom head. This situation is addressed in SI Calculation Package1001527.303, Rev. 1, pg. 4 of 29:The SI P-T Curve L TR [1] addresses the bottom head penetrations byconservatively applying a stress concentration factor (SCF) of 3.0 for ahole in a flat plate to the pressure induced membrane stress in thebottom head shell and using the thermal stress intensity factor solutiongiven in ASME Xl, Non-mandatory Appendix G, Paragraph G-22 14.3[8], discussed below. Review of the Hatch Unit 1 general assemblydrawing [30] shows that the Core DP nozzle exists in the thinnestsection of the bottom head. Based on prior experience from a similarbottom head design, application of the conservative SCF=3. 0methodology to the Core DP nozzle penetration will result in a bottomhead P-T curve which controls the entire RPV. Consequently, aE1-3 to NL-15-2034SNC Response to NRC RAIdetailed evaluation of the Core DP nozzle is performed to removeexcess conservatism.Where the references cited in the above excerpt are:1. Sommerville, D.V., "Pressure-Temperature Limits Report Methodologyfor Boiling Water Reactors," SIR-05-044, Rev. 1-A, June 2013.8. American Society of Mechanical Engineers, Boiler and PressureVessel Code, Section Xl, Rules for Inservice Inspection of NuclearPower Plant Components, Non-mandatory Appendix G, "FractureToughness Criteria for Protection Against Failure," 2001 Ed. through2003 Addenda.30. Core DP Nozzle Drawings:a. SNOC Dwg. S-15227A, Combustion Engineering Drawing 234-244-5, Nozzle Details for 218" l.D. BWR, SI File No. 1001527.208.b. SNOC Sketch 1-BE-2, Rev. 1, "N10 Standby Liquid Control & CoreDifferential Pressure Nozzle Detail," SI File No. 1001527.208.c. SNOC Dwg. Si15523, Combustion Engineering Drawing 234-270,Rev. 3, "General Arrangement Elevation for 218" ID BWR," SI FileNo. 1001527.208.The CDP nozzle in Hatch 2 is inherently addressed by applying thebottom head methodology documented in the Reference [2] licensingtopical report (LTR). Consequently, it is not specifically discussed in amanner similar to the Hatch 1 CDP nozzle. Similarly, none of the bottomhead penetrations are specifically identified and discussed when theconservative methodology of Reference [2] is applied for the bottom headpenetrations.b. For Hatch 1 the following situation exists:a. Curve Ai. 38 EFPY:ii. 49.3 EFPY:b. Curve Bi. 38 EFPY:ii. 49.3 EFPY:c. Curve Ci. 38 EFPY:ii. 49.3 EFPY:Water Level Instrument (WLI) nozzle controls from-450 psig onwardWLI nozzle controls from -400 psig onwardWLI nozzle controls from -150 psig onwardWLI nozzle controls from -125 psig onwardFW nozzle controls from -100 --120 psig, then WLInozzle controls beyond this point, with the exceptionof the closure flange "notch".FW nozzle controls at ~100 psig, then WLI nozzlecontrols beyond this point, with the 'exception of theclosure flange "notch".For Hatch 2 the following situation exists:a. Curve Ai. 37 EFPY:,Water Level Instrument (WLI) nozzle controls from-700 psig onwardEl1-4 to NL-15-2034SNC Response to NRC RAIii. 50.1 EFPY: WLI nozzle controls from -650 psig onwardb. Curve Bi. 37 EFPY: WLI nozzle controls from -250 psig onward, with theexception of the closure flange "notch"ii. 50.1 EFPY: WLI nozzle controls from -240 psig onward, with theexception of the closure flange "notch"c. Curve Ci. 37 EFPY: WLI nozzle controls from -150 psig onward, with theexception of the closure flange "notch"ii. 50.1 EFPY: WLI nozzle controls from -125 psig onward, with theexception of the closure flange "notch"Individual curves for all nozzles considered are clearly shown in AppendixB of References [3, 4].NRC RAI 4:Pages 2-5 and 2-6 of Licensing Topical Report BWROG-TP-1 1-022-A, Rev. 1state, in part, the following:The following in formation should be included In the PTLR with respect to theART calculations:a. The IRTNDT for all RPV materials and the method of determining theRTNDT (i. e., ASME Code, Generic Communication, Branch TechnicalPosition MTEB 5-2 in Standard Review Plan 5.3.2 in NUREG-0800, orother NRG-approved methodologies).c. Identify whether "Procedure 1" or "Procedure 2" from Appendix A wasutilized to evaluate the surveillance data. If surveillance data wasutilized, provide the surveillance data and the analysis of thesurveillance data that was used to determine the ART values. Ifsurveillance data was not utilized, state why it was not utilized.Provide the following information in the PTLRs:a. The method used to compute the initial RTND-T values for both Hatch units.b. Identify whether "Procedure 1" or "Procedure 2" was utilized to evaluatethe surveillance data for both Hatch units.SNC Response to NRC RAI 4:a. The initial RTNDT values are taken from surveillance materials test reports,NEDC-30997 and SASR 90-104 for Hatch 1 and Hatch 2 respectively.As indicated in those reports, :the values were derived using the GE RTNDTEstimation Method submitted by the BWROG as NEDC-32399-P andassessed in a December 16, "1994 letter from Brian Sheron to R. A.Pinelli. Specifically, Section 3.2.4 in each report provides the initialestimation details.b. Procedure 1 was used to evaluate surveillance data for Hatch 1 for thesurveillance plate material, procedure 2 for the weld material.Procedure 2 was used to evaluate surveillance data for Hatch 2 weld andplate material since credible surveillance data was not available.El-5 to NL-1 5-2034SNC Response to NRC RAINRC RAI 5:The NRC staff is unable to reproduce the P-T limits in the Hatch, Unit 1 and 2,PTLRs within reasonable accuracy. However,. many of the inputs needed todetermine the P-T limits are not included in the PTLRs.Provide the necessary P-T limits inputs for both Hatch units similar to therecommendations made in the NRC presentation, "Recommendations for InputsRelated to Pressure-Temperature (P-T) Limits Submittals" (ADAMS AccessionNo. ML 151558464) presented at the lndustry/NRG Materials ProgramsTechnical Information Exchange Meeting that was held at NRC Headquarters onJune 2 -4, 2015. Alternatively, if the inputs are clearly defined in References 8and 14 of each PTLR, provide copies of those three documents.SNC Response to NRC RAI 5:References 8 and 14 of each PTLR are provided as Enclosure 5. SIA calculation1001527.303 Rev. 0 (Hatch 1 and Hatch 2 PLTR Reference 14) containsinformation that is proprietary to General Energy Hitachi. This information hasbeen redacted from the SIA calculation included in Enclosure 5 but can beprovided to the NRC upon request.NRC RAI 6:The Non-Beitline curve in Figure 3, "HNP-1 P-T Curve C (Normal Operation -Core Critical) for 38 EFPY," of the Hatch, Unit 1, PTLR indicates a temperature of-201 °F for pressures greater than 312.6 psig. On the other hand, the tabularvalues for this curve in Table 3, "HNP-1 P-T Curve C (Normal Operation -CoreCritical) for 38 EFPY," of the Hatch, Unit 1, PTLR indicate a temperature of 2170F for pressures greater than 312.6 psig. The NRC staff could not verify either ofthese temperature values as appropriate for Curve C for Hatch, Unit 1, using theminimum temperature requirements of Table 1 of Title 10 of the Code of FederalRegulations, Part 50 (10 CFR 50), Appendix G, "Fracture ToughnessRequirements."Furthermore, since the Non-Beltline region is unaffected by fluence, the NRCstaff expected Curve C for the Non-Beltline region for 38 EFPY to be identical toCurve C for the Non-Beitline region for 49.3 EFPY. The values reflected in Figure3 and Table 3 of the Hatch, Unit 1, PTLR for 38 EFPY, and Figure 6 and Table 6of the Hatch, Unit 1, PTLR for 49.3 EFPY do not reflect this expectation.The NRC staff was able to confirm the Curve C Non-Beltline region temperaturevalues indicated in the Hatch, Unit 2, PTLR for pressures greater than 312.6 psigusing the minimum temperature requirements of Table 1 of 10 CFR 50, AppendixG.Provide the following:a. Identify the correct temperature values for Curve C for the Non-Beltlineregion for Hatch, Unit 1, for pressures greater than 312.6 psig for 38 and49.3 EFPY,El1-6 to NL-15-2034SNC Response to NRC RAIb. Provide the basis for the temperature values for Curve C for the Non-Beitline region for Hatch, Unit 1, for pressures greater than 312.6 psig for38 and 49.3 EFPY.c. Explain any discrepancies with the temperature values for Curve C for theNon-Beltline region for Hatch, Unit 1, for pressures greater than 312.6psig and the temperature values in Figures 3 and 6 and Tables 3 and 6 ofthe Hatch, Unit 1, PTLR for 38 and 49.3 EFPY.SNC Response to NRC RAI 6:a. The correct Hatch 1, non-beltline region, Curve C temperatures are 1970F for 38 EFPY, for which 202 0F was conservatively used, and 210 °F for49.3 EFPY, for which 217 °F was, conservatively used.b. The basis forthe temperatures used is the minimum temperaturerequirement from 10CFR50 Appendix G, Table 1 Operating Condition 2.d,"Core Critical" for pressures greater than 20% of the preservice hydrotestpressure. For this condition the minimum temperature is the larger of:i. The minimum permissible temperature for the inservice systemhydrotest, which is taken as 1250 psig for the Hatch P-T curves, orii. The highest reference temperature of the material in the closureflange that is highly stressed by the bolt preload + 160 °F.For the Hatch 1 P-T curves the minimum permissible temperature for theinservice hydrotest becomes the limiting temperature condition. Since thebeltline region (WLI~nozzle) controls the inservice hydrotest temperature,TIHST varies with EFPY. For Hatch 2 this condition was not the limitingcondition; hence, the difficulty in matching the temperature for the Hatch 1P-T curves but not the Hatch 2 P-T curves.c. The values in Table 3 should list a temperature of 202 °F for pressuresgreater than 312.6 psig. Table 3 currently lists a temperature of 217 °F,which is Conservative; however, it is inconsistent with the correspondingFigure. A revised Table 3 is provided as Enclosure 7.NRC RAI 7:In the LAR, the PTLRs contain new P-T Curves for Hydrostatic Pressure andLeak Test (Curve A), Normal Operation Core Not Critical (Curve B), and NormalOperation -Core Critical (Curve C) for Unit 1 at 38 EFPY and 49.3 EFPY, and forUnit 2 at 37 EFPY and 50.1 EFPY. The PTLR P-T curves are different than thedeleted P-T curves in the current Technical Specifications. Explain the factorsthat lead to the differences observed between the PTLR P-T curves and the TSP-T curves.SNC Response to NRC RAI 7:The previous P-T curves were based on an earlier set of P-T curves developedusing a methodology consistent with the methodology used by the GeneralElectric company. The current methodology, used to develop the curves in theEl1-7 to NL-15-2034SNC Response to NRC RAIPTLR, is based on Reference [1] which includes some notable differences fromthe prior methodology:1. Water Level Instrument nozzle and Feedwater nozzle curves aredeveloped from plant specific nozzle finite element analysis and BoundaryIntegral Equation / Influence Function linear elastic fracture mechanics(LEFM) nozzle solutions.2. The bottom head is treated by applying a conservative SCF =3.0.Additional factors listed below may cause differences in the resulting P-T limitcurves:1. The fluence used in the current analysis is higher than the previousfluence and is based on a more recent evaluation.2. The Adjusted Reference Temperature (ART) calculation in the currentanalysis uses the latest information in BWRVIP-135, Rev. 2 [5], as well asthe Combustion Engineering Owner's Group (CEOG) best estimatechemistry results [6]El1-8 Edwin I. Hatch Nuclear PlantResponse to Request for Additional Information Regarding Application forAmendment to Technical Specifications for Relocation of Pressure andTemperature (P-T) Curves to the Pressure and Temperature Limits Report(PTLR) Consistent with TSTF-41 9-AEnclosure 2Electric Power Research Institute (EPRI) affidavit requesting withholding ofproprietary information

~ELECT,,C POWERKURT EDSINGERDirector, PWR & BWR MaterialsRet. EPRI Project Number 669November 11, 2015Document Control DeskOffice of Nuclear Reactor RegulationU.S. Nuclear Regulatory CommissionWashington, DC 20555-0001

Subject:

...Request for Withholding of the following Proprietary Information Included in:Edwin I, Hatch Nuclear P[ant, Response to Request for Additional Information Regarding Application forAmendment to Technical Specifications for Relocation of Pressure and Temperature (P-T) Curves to thePressure and Temperature Limits Report (PTLR) Consistent with TSTF-419-A, Enclosure 3To Whom It May Concern:This is a request under 10 C.F.R. §2,390(a)(4) that the U.S. Nuclear Regulatory Commission ("NRC")withhold from public disclosure the report identified in the enclosed Affidavit consisting of the proprietaryinformation owned by Electric Power Research Institute, [nc. ("EPRr") identified in the attached report.Proprietary and non-proprietary versions of the Reor and the Affidavit in support of this request areenclosed.EPRI desires to disclose the Proprietary Information in confidence to assist the NRC review of the enclosedsubmittal to the NRC by Southern Nuclear. The Proprietary Information is not to be divulged to anyoneoutside of the NRC or to any of its contractors, nor shall any copies be made of the Proprietary lnformationprovided herein. EPRI welcomes any discussions and/or questions relating to the information enclosed.If you have, any questions about the legal aspects of this request for withholding, please do not hesitate tocontact me at (650) 855-2271. Questions on the content of the Report should be directed to AndyMcGehee of EPRI at (704) 502-6440.Sincerely,Together ...Shaping the Fbture of ElectricityPALO ALTO OFFICE:3420 Hi~lview Avenue, Polo Alto, CA 94304-1338 USA

• 650.855.2000

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• www.epri.com AFF[DAVITRE: Request for Withholding of the Following Proprietary Information Included In:Edwin I, Hatch Nuclear Plant, Response to Request for Additional Information Regarding Application forAmendment to Technical Specifications for Relocation of Pressure and Temperature (P-T) Curves to thePressure and Temperature Limits Report (PTLR) Consistent with TSTF-41 9-A, Enclosure 3I, Kurt Edsinger, being duly sworn, depose and state as follows:I am the Director of PWR and BWR Materials at Electric Power Research Institute, Inc, whose principaloffice is located at 3420 Hillview Avenue, Palo Alto, CA ('EPRI") and ] have been specifically delegatedresponsibility for the above-listed report that contains EPRI Proprietary Information that is sought under thisAffidavit to be withheld "Proprietary Information". I am authorized to apply to the U.S. Nuclear RegulatoryCommission"("NRC") for the withholding of the Proprietary Information on behalf of EPRI,EPRI Proprietary Information is identified in the above referenced report by double brackets. An exampleof such identification is as follows:{{This sentence is an exarnpla.{EI}}}Tables containing EPRI Proprietary Information are identified with double brackets before and after theObject. In each case, the superscript notation tE] refers to this affidavit as the basis for the proprietarydetermination.EPRI requests that the Proprietary Information be withheld from the public on the following bases:Withholdingq Based Upon Privilegled And Confidential Trade Secrets Or Commercial Or FinancialInformation (see e.g., 10 C.F.R. § 2.390(a)(4)l:a. The Proprietary Information is owned by EPRI and has been held in confidence byEPRI. All entities accepting copies of the Proprietary Information do so subject to written agreements imposingan obligation upon the recipient to maintain the confidentiality of the Proprietary Information. The ProprietaryInformationi is, disclosed only to parties who agree, in writing, to preserve the confidentiality thereof,b. EPRI considers the Proprietary Information contained therein to constitute trade secretsof EPRI. As such, EPRI holds the Information in confidence and disclosure thereof is strictly limited to individualsand entities who have agreed, in writing,, to maintain the confidentiality of the Information.c. The information sought to be withheld is considered to be proprietary for the followingreasons. EPRI made a substantial economic investment to develop the Proprietary Information and, by prohibitingpublic disclosure, EPRI derives an economic benefit in the form of licensing royalties and other additional feesfrom the confidential nature of the Proprietary Information. If the Proprietary Information were publicly available to consultants and/or other businesses providing services in the electric and/or nuclear power industry, they wouldbe able to use the Proprietary Information for their own commercial benefit and profit and without expending thesubstantial economic resources required of EPR1 to develop the Proprietary Information.d. EPRI's classification of the Proprietary Information as trade secrets is justified by theUniform Trade Secrets Act which California adopted in 1984 and a version of which has been adopted by overforty states. The California Uniform Trade Secrets Act, California Civil Code §§3426 -3425.11, defines a "tradesecret" as follows:"'Trade secret' means information, including a formula, pattern, compilation,program device, method, technique, or process, that:(1) Derives independent economic value, actual or potential, from not beinggenerally known to the public or to other persons who can obtain economicvalue from its disclosure or use; and-"(2) Is the subject of efforts that are reasonable under the circumstances tomaintain its secrecy."e. The Proprietary Information contained therein are not generally known or available tothe public. EPRI developed the Information only after making a determination that the Proprietary Informationwas not available from public sources. EPRI made a substantial investment of both money and employee hoursin the development of the Proprietary Information. EPRI was required to devote these resources and effort toderive the Proprietary Information. As a result of such effort and cost, both in terms of dollars spent and dedicatedemployee time, the Proprietary Information is highly valuable to EPRI.f. A public disclosure of the Proprietary Information would be highly likely to causesubstantial harm to EPRI's competitive position and the ability of EPRI to license the Proprietary Information bothdomestically and internationally. The Proprietary Information can only be acquired and/or duplicated by othersusing an equivalent investment of time and effort.I have read the foregoing* and the matters stated herein are true and correct to the best of my knowledge,information and belief, I make this affidavit under penalty of perjury under the laws of the United States of Americaand under the laws of the State of North Carolina.Executed at 1300 W WT Harris Blvd being the premises and place of business of Electric Power ResearchInstitute, Inc.'Kurt Edsitnger (State of North Carolina)(County of Mecklenburg)Subscr~ibed and sworn to (or affirmed) before me on. this __.t-yof '- 20L by/_,ff ( proved to me on the basis of satisfactory evidence to bethe person(s) who a Ieared before me.Signature 7.'.. 4 c&Z (Seal)My Commission Expires A"i'day of ____,201.__,.ii; ,.. ' ., ! ;

Charles R. PierceRegulatory Affairs DirectorSouthern NuclearOperating Company, Inc.40 Inverness Center ParkwayPost Office Box 1295Birmingham, AL 35242Tel 205.992.7872Fax 205.992.7601Proprietary Information -Withhold Under 10 CFR 2.390 ISOUTHERNNUCLEARA SOUTHERzN COMPANYNovember 12, 2015Docket Nos.: 50-32150-366NL-1 5-2034U. S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, D. C. 20555-0001Edwin I. Hatch Nuclear PlantResponse to Request for Additional Information Regarding Application forAmendment to Technical Specifications for Relocation of Pressure andTemperature (P-T) Curves to the Pressure and Temperature Limits Report(PTLR) Consistent with TSTF-41 9-ALadies and Gentlemen:By letter dated April 2, 2015 (Agencywide Documents Access and ManagementSystem (ADAMS) Accession No. ML15092A856), Southern Nuclear OperatingCompany (SNC) submitted a license amendment request for the Edwin I. HatchNuclear Plant (HNP). This request would modify the Unit 1 and Unit 2 TechnicalSpecifications (TS) Section 1.0 ("Definitions"), Limiting Conditions for Operationand Surveillance Requirement Applicability Section 3.4.9 ("RCS Pressure andTemperature (PIT) Limits"'), and Section 5.0 ("Administrative Controls") to deletereference to the pressure and temperature curves, and to include reference to thePressure and Temperature Limits Report (PTLR). By letter dated October 13,2015, the Nuclear Regulatory Commission (NRC) staff issued a request foradditional information (RAI).Enclosure 1 provides the SNC response to the NRC RAI. Enclosure 2 providesthe supporting affidavit from Electric Power Research Institute (EPRI), the ownerof the proprietary information in the Enclosure 3 response, requesting withholdingof proprietary information. This affidavit sets forth the basis on which theinformation in Enclosure 3 may be withheld from public disclosure by theCommission and addresses with specificity the considerations listed in paragraph(b)(4) of 10 CFR 2.390 of the Commission's regulations. Accordingly, it isrespectfully requested that the information, which is proprietary to EPRI, bewithheld from public disclosure in accordance with 2.390 of the Commission'sr~gulations. Enclosure 3 provides the proprietary version of the EPRI informationrequested in RAI 1, while Enclosure 4 provides the corresponding non-proprietaryversion of this EPRI information. Enclosure 5 provides the requested StructuralIntegrity Associates (SIA) calculations requested in RAI 1 and RAI 5. SIAcalculation 1001527.303 contains information that is proprietary to GeneralEnergy Hitachi. This information has been redacted from the SIA calculationA~6~

U. S. Nuclear Regulatory CommissionNL-1 5-2034Page 2included in Enclosure 5 but can be provided to the NRC upon request. Enclosure6 provides the TransWare fluence evaluation reports requested in RAI 1. Pleasenote that the TransWare reports state "Southern Nuclear Proprietary Information"at the top header. SNC considers the reports to be intellectual property belongingto SNC, but does not consider these reports proprietary. As such, SNC does notrequest withholding of this information under 10 CFR 2.390. Enclosure 7provides the corrected Table 3 to the Unit 1 PTLR that was provided in. Enclosure5 to the April 2, 2015 letter.This letter contains no NRC commitments. If you have any questions, pleasecontact Ken McElroy at (205) 992-7369.Mr. C. R. Pierce states he is Regulatory Affairs Director of Southern NuclearOperating Company, is authorized to execute this oath on behalf of SouthernNuclear Operating Company and, to the best of his knowledge and belief, thefacts set forth in this letter are true.Respectfullysubm i~d,,C. R. Pierce Regulatory Affairs DirectorCRP/RMJme this ofjj ,2015.My commission expires: //6 ) -_z l "I

Enclosures:

1. SNC Response to NRC RAI2. Electric Power Research Institute (EPRI) affidavit requestingwithholding of proprietary information3. Proprietary Version of the EPRI Information Requested in RAI 14. Non-Proprietary Version of the EPRI Information Requested inRAI 15. Structural Integrity Associates (SIA) Calculations Requested inRAI 1 and RAI 56. TransWare Fluence Evaluation Reports Requested in RAI 17. Corrected Table 3 to the Unit 1 PTLR U. S. Nuclear Regulatory CommissionNL-1 5-2034Page 3cc: Southern Nuclear Operatincq CompanyMr. S. E. Kuczynski, Chairman, President & CEOMr. D. G. Bost, Executive Vice President & Chief Nuclear OfficerMr. D. R. Vineyard, Vice President -HatchMr. M. D. Meier, Vice President -Regulatory AffairsMr. D. R. Madison, Vice President -Fleet OperationsMr. B. J. Adams, Vice President -EngineeringMr. G. L. Johnson, Regulatory Affairs Manager -HatchRTYPE: CHA02.004U. S. Nuclear Re qulatory CommissionMr. L. D. Wert, Regional Administrator (Acting)Mr. R. E. Martin, NRR Senior Project Manager -HatchMr. D. H. Hardage, Senior Resident Inspector -HatchState of GeorqiaMr. J. H. Turner, Environmental Director Protection Division Edwin I. Hatch Nuclear PlantResponse to Request for Additional Information Regarding Application forAmendment to Technical Specifications for Relocation of Pressure andTemperature (P-T) Curves to the Pressure and Temperature Limits Report(PTLR) Consistent with TSTF-41 9-AEnclosure 1SNC Response to NRC RA! to NL-15-2034SNC Response to NRC RAI

References:

1. Letter from Mr. Bob Martin (U.S. NRC) to Mr. C. R. Pierce (SNOC),

Subject:

Edwin I. Hatch Nuclear Plant, Units 1 and 2 -Request forAdditional Information (TAO NOS. MF6063 and MF6064), October 13,2015, ADAMS Accession Number: ML15271A336.2. Sommerville, D.V., "Pressure-Temperature Limits Report Methodology forBoiling Water Reactors," SIR-05-044, Rev. 1-A, June 2013.3. Structural Integrity Associates Calculation No. 1001527.304, Revision 2,"Hatch Unit 1 P-T Curve Calculation for 38 and 49.3 EFPY", September2014.4. Structural Integrity Associates Calculation No. 1001527.305, Revision 2,"Hatch Unit 2 P-T Curve Calculation for 37 and 50.1 EFPY", September2014.5. BWRVIP-135, Revision 2: BWR Vessel and Internals Project, IntegratedSurveillance Program (ISP) Data Source Book and Plant Evaluations.EPRI, Palo Alto, CA: 2009. 1020231.6. Combustion Engineering Report No. CE NPSD-1 119, Revision 01,"Updated Analysis for Combustion Engineering Fabricated Reactor VesselWelds Best Estimate Copper and Nickel Content," July 1998. SI File No.1001527.207.NRC RAI 1Provide the following references from Enclosures 5 and 6 of the April 2, 2015,submittal to afford the NRC staff supporting information regarding the data andmethodology necessary for determining best estimate chemistries, materialchemistry factors, and neutron fluence:i. Enclosure 5, Reference 7: Structural Integrity-Associates Calculation No.1001527.301, Revision 1, "Hatch Unit 1 RPV Material Summary and ARTCalculation," July 2014.ii. Enclosure 5, Reference 12: Hatch 1 specific portions of EPRI Report No.1020231, "BWRVIP-1 35, Revision 2: BWR Vessel and Internals Project,Integrated Surveillance Program (ISP) Data Source Book and PlantEvaluations," Palo Alto, CA, 2009, and any related follow-on documentscontaining data specific to Hatch 1.iii. Enclosure 6, Reference 7: Structural Integrity-Associates Calculation No.1001527.302, Revision 1, "RPV Material Summary and ART Calculation,"July 2014.iv. Enclosure 6, Reference 12: Hatch 2 specific portions of EPRI Report No.1020231, "BWRVIP-135, Revision 2: BWR Vessel and Internals Project,Integrated Surveillance Program (ISP) Data Source Book and PlantEvaluations," Palo Alto, CA, 2009, and any related follow-on documentscontaining data specific to Hatch 2.v. Enclosure 5, Reference 5: Transware Enterprises Inc. Report No. SNC-HA1-002-R-001 Revision 0, "Edwin I. Hatch Unit 1 Fluence Evaluation atEnd of Cycle 25 and 49.3 EFPY."vi. Enclosure 6, Reference 5: Transware Enterprises Inc. Report No. SNC-HA2-001-R-001 Revision 0, "Edwin I. Hatch Unit 2 Fluence Evaluation atEnd of Cycle 22 and 50.1 EFPY."El-i to NL-15-2034SNC Response to NRC RAISNC Response to NRC RAI 1The requested additional Structural Integrity Associates references (i., iii.,) areincluded in Enclosure 5. The requested Hatch-specific portions from BWRVIP-135 (ii., iv.,) are included in Enclosures 3 and 4 representing a proprietary andnon-proprietary version of the information extracted as attested in the enclosedaffidavit from the Electric Power Research Institute (Enclosure 2). The requestedTransWare references (v., vi.) are included as Enclosure 6.NRC RAI 2Page 11 of Enclosure 5 of SNC's April 2, 2015 submittal states the following:The following summarizes the development of the thermal and pressurestress intensity factors for the [core delta-pressure] CDP nozzle [14]:*The KIT term is calculated using the ASME Xl, Non-mandatory AppendixG, Paragraph G-22 14.3 [17] methodology for a heat-up/cool-down rate of100 °F/hr as described in Reference [14].Paragraph G-2214.3 of Section Xl, Appendix G, contains methods for calculatingthe thermal stress intensity factor, KIT, for beltline shell regions of the reactorpressure vessel (RPV) due to radial thermal gradients. Normally, discontinuities(such as the CDP nozzle) would be evaluated based on Paragraph G-2220 ofSection XI, Appendix G, "Nozzles, Flanges, and shell Regions near GeometricDiscontinuities." However, the NRC staff notes that on page 2-19 of NRCapproved Topical Report (TR) BWROG-TP-1 1-022-A, Revision 1, "Pressure-Temperature Limits Report Methodology for Boiling Water Reactors," June 2013(ADAMS Accession No. ML13277A557), the following is stated:A conservative alternative to using Equation 2.5.3-3a or2.5.3-3b is to use theASME Code,Section XI, Nonmanda tory Appendix G [5] method forcalculating a thermal stress intensity factor for an edge cracked plate given inEquation 2.5.1-8, above, where the section thickness is taken as the length Ofthe diagonal path through the nozzle blend radius shown in Figure 2-7.Equation 2.5.1-8 of TR BWROG-TP-1 1-022-A, Revision 1 is as follows:KIT = 0.953 X 103 (CR) (t2"5)Where CR is the cooldown rate in °F/hr and t is the RPV wall thickness in inches.This equation is identical to the equation in Paragraph G-221 4.3 of Section Xl,Appendix G for the maximum KIT produced by a radial thermal gradient for apostulated axial or circumferential inside surface defect in a shell region.However, there are also several other equations contained in Paragraph G-221 4.3 of Section Xl, Appendix G for computing KIT.Confirm that Equation 2.5.1-8 of TR BWROG-TP-1 1-022-A, Revision 1 was usedto calculate KIT for the COP nozzle.El1-2 Enciosure 1 to NL-15-2034SNO Response to NRC RAISNC Response to NRC RAI 2Equation 2.5.1-8 of TR BWROG-TP-1 1-022-A, Revision 1 was used to calculateKIT for the CDP nozzle.NRC RAI 3Page 8 of Enclosure 5 of SNC's April 2, 2015, submittal briefly addresses thewater level instrument (WLI) nozzle for Hatch 1. Pages 9 through 11 of Enclosure5 address the feedwater nozzle for Hatch Nuclear Plant Unit 1 (Hatch 1). Page 11of Enclosure 5 addresses the CDP nozzle for Hatch 1. A summary of the thermalstress intensity factors, KIT, for all three nozzles is provided in Table 9 ofEnclosure 5.Similar discussions for the WLI and feedwater nozzles for Hatch Nuclear PlantUnit 2 (Hatch 2) are contained on pages 8 through 11 of Enclosure 6; however,discussion of the CDP nozzle is not included in Enclosure 6 for Hatch 2, nor is theCDP nozzle included in the summary of nozzle stress intensity factors for Hatch 2in Table 9 of Enclosure 6. Iftis also not clear from the discussion or the Table 9KIT values contained in either Enclosures 5 or 6 which nozzles are controlling withrespect to any of the pressure-temperature (P-T) limit curves shown in Figures 1through 6 of both enclosures.Provide the following:a. Explain why the CDP nozzle was addressed for Hatch 1 and not for Hatch2.b. Explain whether any of the evaluated nozzles control any portions of theP-T limit curves shown in Figures 1 through 6 of both Enclosures 5 and 6and, if so, identify which nozzles are limiting and describe the portions ofthe P-T curves that they control.SNC Response to NRC RAI 3:a. The CDP nozzle is specifically addressed for Hatch 1 because the CDPnozzle in Hatch 1 is located in the thinner shell section of the bottomhead; whereas, for Hatch 2 the CDP nozzle is in the thicker shell sectionof the bottom head. This situation is addressed in SI Calculation Package1001527.303, Rev. 1, pg. 4 of 29:The SI P-T Curve L TR [1] addresses the bottom head penetrations byconservatively applying a stress concentration factor (SCF) of 3.0 for ahole in a flat plate to the pressure induced membrane stress in thebottom head shell and using the thermal stress intensity factor solutiongiven in ASME Xl, Non-mandatory Appendix G, Paragraph G-22 14.3[8], discussed below. Review of the Hatch Unit 1 general assemblydrawing [30] shows that the Core DP nozzle exists in the thinnestsection of the bottom head. Based on prior experience from a similarbottom head design, application of the conservative SCF=3. 0methodology to the Core DP nozzle penetration will result in a bottomhead P-T curve which controls the entire RPV. Consequently, aE1-3 to NL-15-2034SNC Response to NRC RAIdetailed evaluation of the Core DP nozzle is performed to removeexcess conservatism.Where the references cited in the above excerpt are:1. Sommerville, D.V., "Pressure-Temperature Limits Report Methodologyfor Boiling Water Reactors," SIR-05-044, Rev. 1-A, June 2013.8. American Society of Mechanical Engineers, Boiler and PressureVessel Code, Section Xl, Rules for Inservice Inspection of NuclearPower Plant Components, Non-mandatory Appendix G, "FractureToughness Criteria for Protection Against Failure," 2001 Ed. through2003 Addenda.30. Core DP Nozzle Drawings:a. SNOC Dwg. S-15227A, Combustion Engineering Drawing 234-244-5, Nozzle Details for 218" l.D. BWR, SI File No. 1001527.208.b. SNOC Sketch 1-BE-2, Rev. 1, "N10 Standby Liquid Control & CoreDifferential Pressure Nozzle Detail," SI File No. 1001527.208.c. SNOC Dwg. Si15523, Combustion Engineering Drawing 234-270,Rev. 3, "General Arrangement Elevation for 218" ID BWR," SI FileNo. 1001527.208.The CDP nozzle in Hatch 2 is inherently addressed by applying thebottom head methodology documented in the Reference [2] licensingtopical report (LTR). Consequently, it is not specifically discussed in amanner similar to the Hatch 1 CDP nozzle. Similarly, none of the bottomhead penetrations are specifically identified and discussed when theconservative methodology of Reference [2] is applied for the bottom headpenetrations.b. For Hatch 1 the following situation exists:a. Curve Ai. 38 EFPY:ii. 49.3 EFPY:b. Curve Bi. 38 EFPY:ii. 49.3 EFPY:c. Curve Ci. 38 EFPY:ii. 49.3 EFPY:Water Level Instrument (WLI) nozzle controls from-450 psig onwardWLI nozzle controls from -400 psig onwardWLI nozzle controls from -150 psig onwardWLI nozzle controls from -125 psig onwardFW nozzle controls from -100 --120 psig, then WLInozzle controls beyond this point, with the exceptionof the closure flange "notch".FW nozzle controls at ~100 psig, then WLI nozzlecontrols beyond this point, with the 'exception of theclosure flange "notch".For Hatch 2 the following situation exists:a. Curve Ai. 37 EFPY:,Water Level Instrument (WLI) nozzle controls from-700 psig onwardEl1-4 to NL-15-2034SNC Response to NRC RAIii. 50.1 EFPY: WLI nozzle controls from -650 psig onwardb. Curve Bi. 37 EFPY: WLI nozzle controls from -250 psig onward, with theexception of the closure flange "notch"ii. 50.1 EFPY: WLI nozzle controls from -240 psig onward, with theexception of the closure flange "notch"c. Curve Ci. 37 EFPY: WLI nozzle controls from -150 psig onward, with theexception of the closure flange "notch"ii. 50.1 EFPY: WLI nozzle controls from -125 psig onward, with theexception of the closure flange "notch"Individual curves for all nozzles considered are clearly shown in AppendixB of References [3, 4].NRC RAI 4:Pages 2-5 and 2-6 of Licensing Topical Report BWROG-TP-1 1-022-A, Rev. 1state, in part, the following:The following in formation should be included In the PTLR with respect to theART calculations:a. The IRTNDT for all RPV materials and the method of determining theRTNDT (i. e., ASME Code, Generic Communication, Branch TechnicalPosition MTEB 5-2 in Standard Review Plan 5.3.2 in NUREG-0800, orother NRG-approved methodologies).c. Identify whether "Procedure 1" or "Procedure 2" from Appendix A wasutilized to evaluate the surveillance data. If surveillance data wasutilized, provide the surveillance data and the analysis of thesurveillance data that was used to determine the ART values. Ifsurveillance data was not utilized, state why it was not utilized.Provide the following information in the PTLRs:a. The method used to compute the initial RTND-T values for both Hatch units.b. Identify whether "Procedure 1" or "Procedure 2" was utilized to evaluatethe surveillance data for both Hatch units.SNC Response to NRC RAI 4:a. The initial RTNDT values are taken from surveillance materials test reports,NEDC-30997 and SASR 90-104 for Hatch 1 and Hatch 2 respectively.As indicated in those reports, :the values were derived using the GE RTNDTEstimation Method submitted by the BWROG as NEDC-32399-P andassessed in a December 16, "1994 letter from Brian Sheron to R. A.Pinelli. Specifically, Section 3.2.4 in each report provides the initialestimation details.b. Procedure 1 was used to evaluate surveillance data for Hatch 1 for thesurveillance plate material, procedure 2 for the weld material.Procedure 2 was used to evaluate surveillance data for Hatch 2 weld andplate material since credible surveillance data was not available.El-5 to NL-1 5-2034SNC Response to NRC RAINRC RAI 5:The NRC staff is unable to reproduce the P-T limits in the Hatch, Unit 1 and 2,PTLRs within reasonable accuracy. However,. many of the inputs needed todetermine the P-T limits are not included in the PTLRs.Provide the necessary P-T limits inputs for both Hatch units similar to therecommendations made in the NRC presentation, "Recommendations for InputsRelated to Pressure-Temperature (P-T) Limits Submittals" (ADAMS AccessionNo. ML 151558464) presented at the lndustry/NRG Materials ProgramsTechnical Information Exchange Meeting that was held at NRC Headquarters onJune 2 -4, 2015. Alternatively, if the inputs are clearly defined in References 8and 14 of each PTLR, provide copies of those three documents.SNC Response to NRC RAI 5:References 8 and 14 of each PTLR are provided as Enclosure 5. SIA calculation1001527.303 Rev. 0 (Hatch 1 and Hatch 2 PLTR Reference 14) containsinformation that is proprietary to General Energy Hitachi. This information hasbeen redacted from the SIA calculation included in Enclosure 5 but can beprovided to the NRC upon request.NRC RAI 6:The Non-Beitline curve in Figure 3, "HNP-1 P-T Curve C (Normal Operation -Core Critical) for 38 EFPY," of the Hatch, Unit 1, PTLR indicates a temperature of-201 °F for pressures greater than 312.6 psig. On the other hand, the tabularvalues for this curve in Table 3, "HNP-1 P-T Curve C (Normal Operation -CoreCritical) for 38 EFPY," of the Hatch, Unit 1, PTLR indicate a temperature of 2170F for pressures greater than 312.6 psig. The NRC staff could not verify either ofthese temperature values as appropriate for Curve C for Hatch, Unit 1, using theminimum temperature requirements of Table 1 of Title 10 of the Code of FederalRegulations, Part 50 (10 CFR 50), Appendix G, "Fracture ToughnessRequirements."Furthermore, since the Non-Beltline region is unaffected by fluence, the NRCstaff expected Curve C for the Non-Beltline region for 38 EFPY to be identical toCurve C for the Non-Beitline region for 49.3 EFPY. The values reflected in Figure3 and Table 3 of the Hatch, Unit 1, PTLR for 38 EFPY, and Figure 6 and Table 6of the Hatch, Unit 1, PTLR for 49.3 EFPY do not reflect this expectation.The NRC staff was able to confirm the Curve C Non-Beltline region temperaturevalues indicated in the Hatch, Unit 2, PTLR for pressures greater than 312.6 psigusing the minimum temperature requirements of Table 1 of 10 CFR 50, AppendixG.Provide the following:a. Identify the correct temperature values for Curve C for the Non-Beltlineregion for Hatch, Unit 1, for pressures greater than 312.6 psig for 38 and49.3 EFPY,El1-6 to NL-15-2034SNC Response to NRC RAIb. Provide the basis for the temperature values for Curve C for the Non-Beitline region for Hatch, Unit 1, for pressures greater than 312.6 psig for38 and 49.3 EFPY.c. Explain any discrepancies with the temperature values for Curve C for theNon-Beltline region for Hatch, Unit 1, for pressures greater than 312.6psig and the temperature values in Figures 3 and 6 and Tables 3 and 6 ofthe Hatch, Unit 1, PTLR for 38 and 49.3 EFPY.SNC Response to NRC RAI 6:a. The correct Hatch 1, non-beltline region, Curve C temperatures are 1970F for 38 EFPY, for which 202 0F was conservatively used, and 210 °F for49.3 EFPY, for which 217 °F was, conservatively used.b. The basis forthe temperatures used is the minimum temperaturerequirement from 10CFR50 Appendix G, Table 1 Operating Condition 2.d,"Core Critical" for pressures greater than 20% of the preservice hydrotestpressure. For this condition the minimum temperature is the larger of:i. The minimum permissible temperature for the inservice systemhydrotest, which is taken as 1250 psig for the Hatch P-T curves, orii. The highest reference temperature of the material in the closureflange that is highly stressed by the bolt preload + 160 °F.For the Hatch 1 P-T curves the minimum permissible temperature for theinservice hydrotest becomes the limiting temperature condition. Since thebeltline region (WLI~nozzle) controls the inservice hydrotest temperature,TIHST varies with EFPY. For Hatch 2 this condition was not the limitingcondition; hence, the difficulty in matching the temperature for the Hatch 1P-T curves but not the Hatch 2 P-T curves.c. The values in Table 3 should list a temperature of 202 °F for pressuresgreater than 312.6 psig. Table 3 currently lists a temperature of 217 °F,which is Conservative; however, it is inconsistent with the correspondingFigure. A revised Table 3 is provided as Enclosure 7.NRC RAI 7:In the LAR, the PTLRs contain new P-T Curves for Hydrostatic Pressure andLeak Test (Curve A), Normal Operation Core Not Critical (Curve B), and NormalOperation -Core Critical (Curve C) for Unit 1 at 38 EFPY and 49.3 EFPY, and forUnit 2 at 37 EFPY and 50.1 EFPY. The PTLR P-T curves are different than thedeleted P-T curves in the current Technical Specifications. Explain the factorsthat lead to the differences observed between the PTLR P-T curves and the TSP-T curves.SNC Response to NRC RAI 7:The previous P-T curves were based on an earlier set of P-T curves developedusing a methodology consistent with the methodology used by the GeneralElectric company. The current methodology, used to develop the curves in theEl1-7 to NL-15-2034SNC Response to NRC RAIPTLR, is based on Reference [1] which includes some notable differences fromthe prior methodology:1. Water Level Instrument nozzle and Feedwater nozzle curves aredeveloped from plant specific nozzle finite element analysis and BoundaryIntegral Equation / Influence Function linear elastic fracture mechanics(LEFM) nozzle solutions.2. The bottom head is treated by applying a conservative SCF =3.0.Additional factors listed below may cause differences in the resulting P-T limitcurves:1. The fluence used in the current analysis is higher than the previousfluence and is based on a more recent evaluation.2. The Adjusted Reference Temperature (ART) calculation in the currentanalysis uses the latest information in BWRVIP-135, Rev. 2 [5], as well asthe Combustion Engineering Owner's Group (CEOG) best estimatechemistry results [6]El1-8 Edwin I. Hatch Nuclear PlantResponse to Request for Additional Information Regarding Application forAmendment to Technical Specifications for Relocation of Pressure andTemperature (P-T) Curves to the Pressure and Temperature Limits Report(PTLR) Consistent with TSTF-41 9-AEnclosure 2Electric Power Research Institute (EPRI) affidavit requesting withholding ofproprietary information

~ELECT,,C POWERKURT EDSINGERDirector, PWR & BWR MaterialsRet. EPRI Project Number 669November 11, 2015Document Control DeskOffice of Nuclear Reactor RegulationU.S. Nuclear Regulatory CommissionWashington, DC 20555-0001

Subject:

...Request for Withholding of the following Proprietary Information Included in:Edwin I, Hatch Nuclear P[ant, Response to Request for Additional Information Regarding Application forAmendment to Technical Specifications for Relocation of Pressure and Temperature (P-T) Curves to thePressure and Temperature Limits Report (PTLR) Consistent with TSTF-419-A, Enclosure 3To Whom It May Concern:This is a request under 10 C.F.R. §2,390(a)(4) that the U.S. Nuclear Regulatory Commission ("NRC")withhold from public disclosure the report identified in the enclosed Affidavit consisting of the proprietaryinformation owned by Electric Power Research Institute, [nc. ("EPRr") identified in the attached report.Proprietary and non-proprietary versions of the Reor and the Affidavit in support of this request areenclosed.EPRI desires to disclose the Proprietary Information in confidence to assist the NRC review of the enclosedsubmittal to the NRC by Southern Nuclear. The Proprietary Information is not to be divulged to anyoneoutside of the NRC or to any of its contractors, nor shall any copies be made of the Proprietary lnformationprovided herein. EPRI welcomes any discussions and/or questions relating to the information enclosed.If you have, any questions about the legal aspects of this request for withholding, please do not hesitate tocontact me at (650) 855-2271. Questions on the content of the Report should be directed to AndyMcGehee of EPRI at (704) 502-6440.Sincerely,Together ...Shaping the Fbture of ElectricityPALO ALTO OFFICE:3420 Hi~lview Avenue, Polo Alto, CA 94304-1338 USA

• 650.855.2000

• Customer Service 800.31 3.3774

• www.epri.com AFF[DAVITRE: Request for Withholding of the Following Proprietary Information Included In:Edwin I, Hatch Nuclear Plant, Response to Request for Additional Information Regarding Application forAmendment to Technical Specifications for Relocation of Pressure and Temperature (P-T) Curves to thePressure and Temperature Limits Report (PTLR) Consistent with TSTF-41 9-A, Enclosure 3I, Kurt Edsinger, being duly sworn, depose and state as follows:I am the Director of PWR and BWR Materials at Electric Power Research Institute, Inc, whose principaloffice is located at 3420 Hillview Avenue, Palo Alto, CA ('EPRI") and ] have been specifically delegatedresponsibility for the above-listed report that contains EPRI Proprietary Information that is sought under thisAffidavit to be withheld "Proprietary Information". I am authorized to apply to the U.S. Nuclear RegulatoryCommission"("NRC") for the withholding of the Proprietary Information on behalf of EPRI,EPRI Proprietary Information is identified in the above referenced report by double brackets. An exampleof such identification is as follows:{{This sentence is an exarnpla.{EI}}}Tables containing EPRI Proprietary Information are identified with double brackets before and after theObject. In each case, the superscript notation tE] refers to this affidavit as the basis for the proprietarydetermination.EPRI requests that the Proprietary Information be withheld from the public on the following bases:Withholdingq Based Upon Privilegled And Confidential Trade Secrets Or Commercial Or FinancialInformation (see e.g., 10 C.F.R. § 2.390(a)(4)l:a. The Proprietary Information is owned by EPRI and has been held in confidence byEPRI. All entities accepting copies of the Proprietary Information do so subject to written agreements imposingan obligation upon the recipient to maintain the confidentiality of the Proprietary Information. The ProprietaryInformationi is, disclosed only to parties who agree, in writing, to preserve the confidentiality thereof,b. EPRI considers the Proprietary Information contained therein to constitute trade secretsof EPRI. As such, EPRI holds the Information in confidence and disclosure thereof is strictly limited to individualsand entities who have agreed, in writing,, to maintain the confidentiality of the Information.c. The information sought to be withheld is considered to be proprietary for the followingreasons. EPRI made a substantial economic investment to develop the Proprietary Information and, by prohibitingpublic disclosure, EPRI derives an economic benefit in the form of licensing royalties and other additional feesfrom the confidential nature of the Proprietary Information. If the Proprietary Information were publicly available to consultants and/or other businesses providing services in the electric and/or nuclear power industry, they wouldbe able to use the Proprietary Information for their own commercial benefit and profit and without expending thesubstantial economic resources required of EPR1 to develop the Proprietary Information.d. EPRI's classification of the Proprietary Information as trade secrets is justified by theUniform Trade Secrets Act which California adopted in 1984 and a version of which has been adopted by overforty states. The California Uniform Trade Secrets Act, California Civil Code §§3426 -3425.11, defines a "tradesecret" as follows:"'Trade secret' means information, including a formula, pattern, compilation,program device, method, technique, or process, that:(1) Derives independent economic value, actual or potential, from not beinggenerally known to the public or to other persons who can obtain economicvalue from its disclosure or use; and-"(2) Is the subject of efforts that are reasonable under the circumstances tomaintain its secrecy."e. The Proprietary Information contained therein are not generally known or available tothe public. EPRI developed the Information only after making a determination that the Proprietary Informationwas not available from public sources. EPRI made a substantial investment of both money and employee hoursin the development of the Proprietary Information. EPRI was required to devote these resources and effort toderive the Proprietary Information. As a result of such effort and cost, both in terms of dollars spent and dedicatedemployee time, the Proprietary Information is highly valuable to EPRI.f. A public disclosure of the Proprietary Information would be highly likely to causesubstantial harm to EPRI's competitive position and the ability of EPRI to license the Proprietary Information bothdomestically and internationally. The Proprietary Information can only be acquired and/or duplicated by othersusing an equivalent investment of time and effort.I have read the foregoing* and the matters stated herein are true and correct to the best of my knowledge,information and belief, I make this affidavit under penalty of perjury under the laws of the United States of Americaand under the laws of the State of North Carolina.Executed at 1300 W WT Harris Blvd being the premises and place of business of Electric Power ResearchInstitute, Inc.'Kurt Edsitnger (State of North Carolina)(County of Mecklenburg)Subscr~ibed and sworn to (or affirmed) before me on. this __.t-yof '- 20L by/_,ff ( proved to me on the basis of satisfactory evidence to bethe person(s) who a Ieared before me.Signature 7.'.. 4 c&Z (Seal)My Commission Expires A"i'day of ____,201.__,.ii; ,.. ' ., ! ;