ML15289A073
| ML15289A073 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 10/12/2015 |
| From: | Gardner P A Northern States Power Co, Xcel Energy |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML15289A082 | List: |
| References | |
| L-MT-15-074, TAC MD9990, TAC MF6730 | |
| Download: ML15289A073 (25) | |
Text
ENCLOSURES 1, 2 AND 3 CONTAIN PROPRIETARY INFORMATION -WITHHOLD FROM PUBLIC DISCLOSURE IN ACCORDANCE WITH 10 CFR 2.390Xc el EnergyMonticello Nuclear Generating Plant2807 W County Rd 75Monticello, MN 55362October 12, 2015L-MT-1 5-07410 CFR 50.4U.S. Nuclear Regulatory Commission.ATTN: Document Control DeskWashington, DC 20555-0001Monticello Nuclear Generating PlantDocket No. 50-263Renewed Facility Operating License No. DPR-22Monticello Extended Power Uprate: Submittal of Power Ascension Testinq Results forReplacement Steam Dryer (TAC No. MF6730)References: 1)Letter from T Beltz (NRC) to K Fili (NSPM), "Monticello NuclearGenerating Plant- Issuance of Amendment No. 176 to RenewedFacility Operating License Regarding Extended Power Uprate (TACNo. MD9990)," dated December 9, 2013. (ADAMS Accession No.ML1 3343A006)2) Letter from M Schimmel (NSPM) to Document Control Desk (NRC),"Monticello Extended Power Uprate: Replacement Steam Dryer -Responses to Clarification Questions and Revised AnalysisDocumentation (TAC MD9990)," L-MT-13-091, dated August 29,2013. (ADAMS Accession No. ML13248A343)Pursuant to 10 CFR 50.92, the NRC issued Reference 1, License Amendment No. 176to the Monticello Nuclear Generating Plant (MNGP) Renewed Operating License (OL)and Technical Specifications (TS) to increase the maximum authorized power level from1775 megawatts thermal (MWt) to 2004 MWt. This change to power level is consideredan extended power uprate (EPU).Reference 2 provided the Replacement Steam Dryer (RSD) final licensing basisanalyses used in part to support the NRC issuance of License Amendment No. 176.Reference 2 contains WCAP-17252-P, Revision 4 and WCAP-17549-P, Revision 2which are superseded by this letter.i .oo[
Document Control DeskPage 2This letter provides power ascension testing information in accordance with thefollowing MNGP license conditions associated with License Amendment No. 176:15(b)2 After reaching 2004 MWt, NSPM shall obtain measurements from the MSLstrain gauges and establish the steam dryer flow-induced vibration loadfatigue margin for the facility, update the dryer stress report, and re-establish the limit curves with the updated load definition. This data will beprovided to the NRC staff as described in license condition 15(e).15(e) The results of the power ascension testing to verify the continued structuralintegrity of the steam dryer shall be submitted to the NRC staff in a reportthat includes a final load definition and stress report of the steam dryer,including the results of a complete re-analysis using the ACE 2.0 and ACE2.0-.SPM specific bias and uncertainties. The report will be provided within90 days of the completion of EPU power ascension testing.The information required by these license conditions is provided in the enclosures tothis letter. WCAP-17252-P, Revision 4 and WCAP-17549-P, Revision 2, provided inReference 2 are impacted by changes in the load definition due to the test resultsencountered during the power ascension testing. The analyses impacts areincorporated in the enclosures listed below.Enclosure 1 contains Westinghouse Electric Company, LLC (WEC) report WCAP17252-P, Revision 5, "Acoustic Loads Definition for the Monticello Steam DryerReplacement Project". This document provides an accurate three-dimensional model ofthe steam dryer and the surrounding fluid to predict the distribution of the pressureloads on the entire structure. This update provides additional data and correctionsperformed on ACE Revision 2.0 and resulted in a revision to the biases anduncertainties for the acoustic load definition. The updated model is called ACE Revision2.0.1. This report contains proprietary information.Enclosure 2 contains WEC report WCAP-17549-P, Revision 3, "Monticello ReplacementSteam Dryer Structural Evaluation for High-Cycle Acoustic Loads Using ACE"'. Thisdocument provides a high-cycle fatigue evaluation of the MNGP RSD with loadsgenerated using the ACE Revision 2.0.1 model for the upper dryer and ACE 2.0+SPM(skirt protection model) for the lower dryer. Appendix B has been added to thisdocument to update acoustic loads and stresses from data taken at full EPU conditions(2004 MWt). Appendix B indicates that the high-cycle fatigue results have beendetermined to meet the American Society of Mechanical Engineers (ASME) Boiler andPressure Vessel (B&PV) Code Section IIl, Subsection NG criteria. This report containsproprietary information.Enclosure 3 contains WEC report WCAP-1 8064-P, Revision 0, "Monticello EPU MainSteam Line Strain Gauge Data Evaluation Report." This report provides a description ofthe data obtained from the Main Steam Line (MSL) strain gauges during the EPU power Document Control DeskPage 3ascension activities. This report provides the signal processing methods applied to theplant data to support the structural integrity evaluation analysis. The general signalprocessing methods applied to the plant data include conversion of measured MSLstrain data into MSL alternating pressure signatures, narrow-band filtering, and waveletdenoising. This report contains proprietary information.Enclosure 4 contains WEC affidavits executed to support withholding Enclosures 1, 2,and 3 from public disclosure. The affidavits set forth the basis on which the informationmay be withheld from public disclosure by the NRC and addresses with specificity theconsiderations listed in 10 CFR 2.390(b)(4). NSPM requests that the proprietaryinformation in Enclosures 1, 2 and 3 be withheld from public disclosure in accordancewith 10 CFR 2.390(a)4, as authorized by 10 CFR 9.17(a)4. Accordingly, it isrespectfully requested that the information which is proprietary to WEC be withheld frompublic disclosure in accordance with 10 CFR 2.390.Correspondence with respect to the copyright or proprietary aspects of WECinformation or the supporting WEC affidavits in Enclosure 4 should be addressed toJ. A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company,1000 Westinghouse Drive, Building 3 Suite 310, Cranberry Township, Pennsylvania16066.Enclosures 5, 6 and 7 contain a nonproprietary version of Enclosures 1, 2, and 3respectively. The nonproprietary reports are being provided based on the NRC'sexpectation that the submitter of the proprietary information should provide, if possible,a nonproprietary version of the document with brackets showing where the proprietaryinformation has been deleted.Summary of CommitmentsThis letter makes no new commitments and no revisions to existing commitments.PeerA " Site Vice-Preside t, ntL icello Nuclear Generating PlantNorthern States Power Company-MinnesotaEnclosures (7)cc: Administrator, Region Ill, USNRCProject Manager, Monticello Nuclear Generating Plant, USNRCResident Inspector, Monticello Nuclear Generating Plant, USNRC L.-MT-1 5-074ENCLOSURE 4AFFIDAVITS FOR WITHHOLDING PROPRIETARY DOCUMENTSThe table below provides an index to the affidavits provided within this enclosure. Theindex correlates the affidavit with the document each affidavit supports.Affidavit # Enclosure number -Document number & NameCAW-15-4299 Enclosure I -WCAP-17252-P, Revision 5, "Acoustic LoadsDefinition for the Monticello Steam Dryer Replacement Project"(Proprietary)CAW-15-4301 Enclosure 2 -WCAP-17549-P, Revision 3, "Monticello ReplacementSteam Dryer Structural Evaluation for High-Cycle Acoustic LoadsUsing ACE" (Proprietary)CAW-15-4300 Enclosure 3 -WCAP-18064-P, Revision 0, "Monticello EPU MainSteam Line Strain Gauge Data Evaluation Report" (Proprietary)21 pages follow Westinhouseuleetr o C .ompn1000 Westinghouse DriveU.S. Nuclear Regulatory Commission Direct tel: (412) Document Control Desk Direct fax: (724) 940-856011555 Rockville Pike e-mail: greshaja @westinghouse.comRockville, MD 20852CAW-15-4299October 5, 2015APPLICATION FOR WITHHFOLDING PROPRIETARYINFORMATION FROM PUBLIC DISCLOSURESubject: WCAP-17252-P, Revision 5, "Acoustic Loads Definition for the Monticello Steam DryerReplacement Project" (Proprietary)The Application for Withholding Proprietary Information from Public Disclosure is submitted byWestinghouse Electric Company LLC (Westinghouse), pursuant to the provisions of paragraph (b)(1) ofSection 2.390 of the Commission's regulations. It contains commercial strategic information proprietaryto Westinghouse and customarily held in confidence.The proprietary information for which withholding is being requested in the above-referenced report isfurther identified in Affidavit CAW-15-4299 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 Conmmission'sregulations.Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Xcel Energy.Correspondence with respect to the proprietary aspects of the Application for Withholding or theWestinghouse Affidavit should reference CAW-15-4299, 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./Jmes A. Gresham, ManagerRegulatory Compliance CAW-15-4299October 5, 2015AFFIDAVITCOMMONWEALTH OF PENNSYLVANIA:SSCOUNTY OF BUTLER:I, James A. Gresham, am authorized to execute this Affidavit on behalf of Westinghouse ElectricCompany LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true andcorrect to the best of my knowledge, information, and belief.James A. Gresham, ManagerRegulatory Compliance 22 CAW-15-4299(1) I am Manager, Regulatory Compliance, Westinghouse Electric Company LLC (Westinghouse),and as such, I have been specifically delegated the function of reviewing the proprietaryinformation sought to be withheld from public disclosure in connection with nuclear power plantlicensing and rule making proceedings, and am authorized to apply for its withholding on behalfof Westinghouse.(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.3 90 of theCommission's regulations and in conjunction with the Westinghouse Application for WithholdingProprietary Information from Public Disclosure accompanying this Affidavit.(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designatinginformation as a trade secret, privileged or as confidential commercial or financial information.(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.3 90 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 determiningthe 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 constituteWestinghouse 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 competitiveadvantage, as follows:(a) The information reveals the distinguishing aspects of a process (or component,structure, tool, method, etc.) where prevention of its use by any of 33 CAW- 15-4299Westinghouse'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, assuranceof 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 competitiveadvantage 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.
44 CAW-15-4299(d) Each component of proprietary information pertinent to a particular competitiveadvantage is potentially as valuable as the total competitive advantage, Ifcompetitors acquire components of proprietary information, any one componentmay be the key to the entire puzzle, thereby depriving Westinghouse of acompetitive advantage.(e) Unrestricted disclosure would jeopardize the position of prominence ofWestinghouse in the world market, and thereby give a market advantage to thecompetition of those countries.(f) The Westinghouse capacity to invest corporate assets in research 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 availableinformation 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 WCAP-17252-P, Revision 5, "Acoustic Loads Definition for theMonticello Steam Dryer Replacement Project" (Proprietary), dated September 2105, forsubmittal to the Commission, being transmitted by Xcel Energy letter and Application forWithholding Proprietary Information from Public Disclosure, to the Document.ControlDesk. The proprietary information as submitted by Westinghouse is that associated withthe high-cycle fatigue assessment of the replacement steam dryer at Monticello NuclearGenerating Plant.(MNGP) at extended power uprate (EPU) conditions, and may be usedonly for that purpose.
55 CAW-15-4299(a) This information is part of that which will enable Westinghouse to:(i) Assist Xcel Energy in fulfilling the NRC replacement steam dryerreporting requirements for power, ascension to EPU operating conditionsfor MINGP.(b) Further this information has substantial commercial value as follows:(i) Westinghouse plans to sell the use of similar information to its customersfor the purpose of plant specific replacement steam dryer analysis forlicensing basis applications.(ii) Westinghouse can sell support and defense of industry guidelines andacceptance criteria for plant-specific applications.(iii) The information requested to be withheld reveals the distinguishingaspects 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 ofcompetitors to provide similar technical evaluation and licensing defense services forcommercial power reactors without commensurate expenses. Also, public disclosure ofthe information would enable others to use the information to meet NRC requirements forlicensing documentation without purchasing the right to use the information.The development of the technology described in part by the information is the result ofapplying the results of many years of experience in an intensive Westinghouse effort andthe expenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technicalprograms would have to be performed and a significant manpower effort, having therequisite talent and experience, would have to be expended.Further the deponent sayeth not.
PROPRIETARY INFORMATION NOTICETransmitted herewith are proprietary and non-proprietary versions of documents furnished to the NRCassociated with the high-cycle fatigue assessment of the replacement steam dryer at extended poweruprate (EPU) conditions for the Monticello Nuclear Generating Plant.In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning theprotection of proprietary information so submitted to the NRC, the information which is proprietary in theproprietary versions is contained within brackets, and where the proprietary information has been deletedin the non-proprietary versions, only the brackets remain (the information that was contained within thebrackets in the proprietary versions having been deleted). The justification for claiming the informationso designated as proprietary is indicated in both versions by means of lower case letters (a) through (f)located as a superscript immediately following the brackets enclosing each item of information beingidentified as proprietary or in the margin opposite such information. These lower case letters refer to thetypes of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a)through (4)(ii)(t) of the Affidavit accompanying this transmittal pursuant to 10 CFR 2.3 90(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 2.3 90 regarding restrictions on publicdisclosure to the extent such information has been identified as proprietary by Westinghouse, copyrightprotection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC ispermitted to make the number of copies beyond those necessary for its internal use which are necessary inorder to have one copy available for public viewing in the appropriate docket files in the public documentroom in Washington, DC and in local public document rooms as may be required by NRC regulations ifthe number of copies submitted is insufficient for this purpose. Copies made by the NRC must includethe copyright notice in all instances and the proprietary notice if the original was identified as proprietary.
W estin houseWestinghouse Electric Company1000 Westinghouse DriveU.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643Document Control Desk ,Direct fax: (724) 940-856011555 Rockville Pike e-mail: greshaja@westinghouse.comRoclkville, MD 20852CAW-15-4301October 5, 2015APPLICATION FOR WITHHFOLDING PROPRIETARYINFORMATION FROM PUBLIC DISCLOSURESubject: WCAP-17549-P, Revision 3, "Monticello Replacement Steam Dryer Structural Evaluation forHigh-Cycle Acoustic Loads Using ACE" (Proprietary)The Application for Withholding Proprietary Information from Public Disclosure is submitted byWestinghouse Electric Company LLC (Westinghouse), pursuant to the provisions of paragraph (b)(l) ofSection 2.3 90 of the Commission's regulations. It contains commercial strategic information proprietaryto Westinghouse and customarily held in confidence.The proprietary information for which withholding is being requested in the above-referenced report isfurther identified in Affidavit CAW-15-4301 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'sregulations.Accordingly, this letter authorizes the utilization of the accompanyirng Affidavit by Xcel Energy.Correspondence with respect to the proprietary aspects of the Application for Withholding or theWestinghouse Affidavit should reference CAW-15-4301, and should be addressed to James A. Gresham,Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive,Building 3 Suite 310, Cranberry Township, Pennsylvania 16066.6Jaes .Geshaam, ManagerRegulatory Compliance CAW-15-4301October 5, 2015AFFIDAVITCOMMONWEALTH OF PENNSYLVANIA:SSCOUJNTY OF BUTLER:I, James A. Gresham, am authorized to execute this Affidavit on behalf of Westinghouse ElectricCompany LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true andcorrect to the best of my knowledge, information, and belief.James A. Gresham, ManagerRegulatory Compliance 22 CAW-15-4301(1) I am Manager, Regulatory Compliance, Westinghouse Electric Company LLC (Westinghouse),and as such, I have been specifically delegated the function of reviewing the proprietaryinformation sought to be withheld from public disclosure in connection with nuclear power plantlicensing and rule making proceedings, and am authorized to apply for its withholding on behalfof Westinghouse.(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.3 90 of theCommission's regulations and in conjunction with the Westinghouse Application for WithholdingProprietary Information from Public Disclosure accompanying this Affidavit.(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designatinginformation as a trade secret, privileged or as confidential commercial or financial information.(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations,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 ftom 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 determiningthe 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 constituteWestinghouse 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 competitiveadvantage, as follows:(a) The information reveals the distinguishing aspects of a process (or component,structure, tool, method, etc.) where prevention of its use by any of 33 CAW-15-4301Westinghouse'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, assuranceof 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 pians 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 competitiveadvantage 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.
44 CAW-15-4301(d) Each component of proprietary information pertinent to a particular competitiveadvantage is potentially as valuable as the total competitive advantage, Ifcompetitors acquire components of proprietary information, any one componentmay be the key to the entire puzzle, thereby depriving Westinghouse of acompetitive advantage.(e) Unrestricted disclosure would jeopardize the position of prominence ofWestinghouse in the world market, and thereby give a market advantage to thecompetition of those countries.(f) The Westinghouse capacity to invest corporate assets in research 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 availableinformation 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 WCAP-17549-P, Revision 3, "Monticello Replacement SteamDryer Structural Evaluation for High-Cycle Acoustic Loads Using ACE" (Proprietary),dated October 2015, for submittal to the Commission, being transmitted by Xcel Energyletter and Application for Withholding Proprietary Information from Public Disclosure,to the Document Control Desk. The proprietary information as submitted byWestinghouse is that associated with the high-cycle fatigue assessment of thereplacement steam dryer at Monticello Nuclear Generating Plant (MNGP) at extendedpower uprate (EPU) conditions, and may be used only for that purpose.
55 CAW-15-4301(a) This information is part of that which will enable Westinghouse to:(i) Assist Xcel Energy in fulfilling the NRC replacement steam dryerreporting requirements for power ascension to EPU operating conditionsfor MNGP.(b) Further this information has substantial commercial value as follows:(i) Westinghouse plans to sell the use of similar information to its customersfor the purpose of plant specific replacement steam dryer analysis forlicensing basis applications.(ii) Westinghouse can sell support and defense of industry guidelines andacceptance criteria for plant-specific applications.(iii) The information requested to be withheld reveals the distinguishingaspects 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 ofcompetitors to provide similar technical evaluation and licensing defense services forcommercial power reactors without commensurate expenses. Also, public disclosure ofthe information would enable others to use the information to meet NRC requirements forlicensing documentation without purchasing the right to use the information.The development of the technology described in part by the information is the result ofapplying the results of many years of experience in an intensive Westinghouse effort andthe expenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technicalprograms would have to be performed and a significant manpower effort, having therequisite talent and experience, would have to be expended.Further the deponent sayeth not.
PROPRIETARY INFORMATION NOTICETransmitted herewith are proprietary and non-proprietary versions of documents furnished to the NRCassociated with the high-cycle fatigue assessment of the replacement steam dryer at extended poweruprate (EPU) conditions for the Monticello Nu~lear Generating Plant.In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning theprotection of proprietary information so submitted to the NRC, the information which is proprietary in theproprietary versions is contained within brackets, and where the proprietary information has been deletedin the non-proprietary versions, only the brackets remain (the information that was contained within thebrackets in the proprietary versions having been deleted). The justification for claiming the informationso designated as proprietary is indicated in both versions by means of lower case letters (a) through (f)located as a superscript immediately following the brackets enclosing each item of information beingidentified as proprietary or in the margin opposite such information. These lower case letters refer to thetypes of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a)through (4)(ii)(f) of the Affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).COPYRIGHT NOTICEThe reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted tomake the number of copies of the information contained in these reports which are necessary for itsinternal use in connection with generic and plant-specific reviews and approvals as well as the issuance,denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license,permit, order, or regulation subject to the requirements of 10 CFR 2.3 90 regarding restrictions on publicdisclosure to the extent such information has been identified as proprietary by Westinghouse, copyrightprotection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC ispermitted to make the number of copies beyond those necessary for its internal use which are necessary inorder to have one copy available for public viewing in the appropriate docket files in the public documentroom in Washington, DC and in local public document rooms as may be required by NRC regulations ifthe number of copies submitted is insufficient for this purpose. Copies made by the NRC must includethe copyright notice in all instances and the proprietary notice if the original was identified as proprietary.
W estin houseWestinghouse Electric Company1000 Westinghouse DriveU.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643Document Control Desk Direct fax: (724) 940-856011555 Rockville Pike e-mail: greshaja@westinghouse.comRockville, MD 20852CAW-15-4300October 5, 2015APPLICATION FOR WiT-HhOLDING PROPRIETARYINFORMATION FROM PUBLIC DISCLOSURESubject: WCAP-18064-P, Revision 0, "Monticello EPU Main Steam Line Strain Gauge Data EvaluationReport" (Proprietary)The Application for Withholding Proprietary Information from Public Disclosure is submitted byWestinghouse Electric Company LLC (Westinghouse), pursuant to the provisions of paragraph (b)(1) ofSection 2.3 90 of the Commission's regulations. It contains commercial strategic information proprietaryto Westinghouse and customarily held in confidence.The proprietary information for which withholding is being requested in the above-referenced report isfurther identified in Affidavit CAW- 15-4300 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'sregulations.Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Xcel Energy.Correspondence with respect to the proprietary aspects of the Application for Withholding or theWestinghouse Affidavit should reference CAW-15-4300, 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.-t/ames A. Gresham, ManagerRegulatory Compliance CAW-15-4300October 5, 2015AFFIDAVITCOMMONWEALTH OF PENNSYLVANIA:SSCOUNTY OlE BUTLER:I, James A. Gresham, am authorized to execute this Affidavit on behalf of Westinghouse ElectricCompany LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true andcorrect to the best of my knowledge, information, and belief.~James A. Gresham, ManagerRegulatory Compliance 22 CAW-15-4300(1) I am Manager, Regulatory Compliance, Westinghouse Electric Company LLC (Westinghouse),and as such, I bave been specifically delegated the function of reviewing the proprietaryinformation sought to be withheld from public disclosure in connection with nuclear power plantlicensing and rule making proceedings, and am authorized to apply for its withholding on behalfof Westinghouse.(2) I am making this Affidavit in conformance with the provisions of 10 CF~R Section 2.3 90 of theCommission's regulations and in conjunction with the Westinghouse Application for WithholdingProprietary Information from Public Disclosure accompanying this Affidavit.(3) I have personal knowledge of the criteria-and procedures utilized by Westinghouse in designatinginformation as a trade secret, privileged or as confidential commercial or financial, information.(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations,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 determiningthe 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 constituteWestinghouse 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 83 CAW-15-4300Westinghouse'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, assuranceof 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 competitiveadvantage 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.
44 CAW-I5-4300(d) Each component of proprietary information pertinent to a particular competitiveadvantage is potentially as valuable as the total competitive advantage, Ifcompetitors acquire components of proprietary information, any one componentmay be the key to the entire puzzle, thereby depriving Westinghouse of acompetitive advantage.(e) Unrestricted disclosure would jeopardize the position of prominence ofWestinghouse in the world market, and thereby give a market advantage to thecompetition of those countries.(f) The Westinghouse capacity to invest corporate assets in research 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 availableinformation 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 WCAP-18064-P, Revision 0, "Monticello EPU Main Steam LineStrain Gauge Data Evaluation Report" (Proprietary), dated September 2015, for submittalto the Commission, being transmitted by Xcel Energy letter and Application forWithholding Proprietary Information from Public Disclosure, to the Document ControlDesk. The proprietary information as submitted by Westinghouse is that associated withthe high-cycle fatigue assessment of the replacement steam dryer at Monticello NuclearGenerating Plant (MINGP) at extended power uprate (EPU) conditions, and may be usedonly for that purpose.
55 CAW-15-4300(a) This information is part of that which will enable Westinghouse to:(i) Assist Xcel Energy in fulfilling the NRC replacement steam dryerreporting requirements for power ascension to EPU operating conditions*for MNGP.(b) Further this information has substantial commercial value as follows:(i) Westinghouse plans to sell the use of similar information to its customersfor the purpose of plant specific replacement steam dryer analysis forlicensing basis applications.(ii) Westinghouse can sell support and defense of industry guidelines and*acceptance criteria for plant-specific applications.(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 ofcompetitors to provide similar technical evaluation and licensing defense services forcommercial power reactors without commensurate expenses. Also, public disclosure ofthe information would enable others to use the information to meet NRC requirements forlicensing documentation without purchasing the right to use the information.The development of the technology described in part by the information is the result ofapplying the results of many years of experience in an intensive Westinghouse effort andthe expenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technicalprograms would have to be performed and a manpower effort, having therequisite talent and experience, would have to be expended.Further the deponent sayeth not.
PROPRIETARY INFORMATION NOTICETransmitted herewith are proprietary and non-proprietary versions of documents furnished to the NRCassociated with the high-cycle fatigue assessment of the replacement steam dryer at extended power* uprate (EPU) conditions for the Monticello Nuclear Generating Plant.In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning theprotection of proprietary information so submitted to the NRC, the information which is proprietary in theproprietary versions is contained within brackets, and where the proprietary information has been deletedin the non-proprietary versions, only the brackets remain (the information that was contained within thebrackets in the proprietary versions having been deleted). The justification for claiming the informationso designated as proprietary is indicated in both versions by means of lower case letters (a) through (f)located as a superscript immediately following the brackets enclosing each item of information beingidentified as proprietary or in the margin opposite such information. These lower case letters refer to thetypes of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a)through (4)(ii)(f) of the Affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).COPYRIGHT NOTICEThe reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted tomake the number of copies of the information contained in these reports which are necessary for itsinternal use in connection with generic and plant-specific reviews and approvals as well as the issuance,denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license,permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on publicdisclosure to the extent such information has been identified as proprietary by Westinghouse, copyrightprotection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC ispermitted to make the number of copies beyond those necessary for its internal use which are necessary inorder to have one copy available for public viewing in the appropriate docket files in the public documentroom in Washington, DC and in local public document rooms as may be required by NRC regulations ifthe number of copies submitted is insufficient for this purpose. Copies made by the NRC must includethe copyright notice in all instances and the proprietary notice if the original was identified as proprietary.