ET 15-0002, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 5.6.5, for Large Break Loss-of-Coolant (LOCA) Analysis Methodology

Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 5.6.5, for Large Break Loss-of-Coolant (LOCA) Analysis Methodology

ML15029A198
Person / Time
Site:	Wolf Creek
Issue date:	01/21/2015
From:	Mccoy J Wolf Creek
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML15029A234	List: ET 15-0002, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 5.6.5, for Large Break Loss-of-Coolant (LOCA) Analysis Methodology
References
ET 15-0002
Download: ML15029A198 (27)

Text

WNLF CREEK NUCLEAR OPERATING CORPORATION Jaime H. McCoy January 21, 2015 Vice President Engineering ET 15-0002 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Reference:

1) Letter ET 14-0008, dated February 26, 2014, from J. P. Broschak, WCNOC to USNRC

2) Electronic Mail dated November 20, 2014, from C. F. Lyon, USNRC, to S. G. Wideman, WCNOC

Subject:

Docket No. 50-482: Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 5.6.5, for Large Break Loss-of-Coolant (LOCA) Analysis Methodology Gentlemen:

Reference 1 provided the Wolf Creek Nuclear Operating Corporation (WCNOC) application to revise the Wolf Creek Generating Station (WCGS) Technical Specifications (TS). Specification 5.6.5, "CORE OPERATING LIMITS REPORT (COLR)," is revised to incorporate WCAP-16009-P-A, "Realistic Large-Break LOCA Evaluation Methodology Using the Automated Statistical Treatment of Uncertainty Method (ASTRUM)," to the list of analytical methods used to determine the core operating limits. The Reference 1 application was a plant specific best-estimate large break LOCA analysis that accounted for the effects of fuel thermal conductivity degradation (TCD). Reference 2 provided a request for additional information related to the application. The Attachment provides WCNOC's response to the request for additional information.

The additional information does not expand the scope of the application and does not impact the no significant hazards consideration determination presented in Reference 1.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," a copy of this submittal is being provided to the designated Kansas State official.

/+001 364-8831 P.O. Box 411 / Burlington, KS 66839 / Phone: (620)

An Equal Opportunity Employer M/F/HCNET

ET 15-0002 Page 2 of 3 Enclosure I provides the proprietary Westinghouse Electric Company LLC Attachment 1 to LTR-LIS-1 5-11, Revision 1, "Westinghouse Suggested Response to NRC Request for Additional Information (RAI) Regarding the Wolf Creek (SAP) ASTRUM Analysis - Proprietary." Enclosure II provides the non-proprietary version of Westinghouse Electric Company LLC Attachment 1 to LTR-LIS-15-1 1, Revision 1. Enclosure IV is a CD-ROM containing a spreadsheet version of the data documented in Tables 1 and 2 of Attachment 1 to LTR-LIS-15-11, Revision 1. As Enclosure I and IV contains information proprietary to Westinghouse Electric Company LLC, it is supported by an affidavit signed by Westinghouse Electric Company LLC, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 2.390 of the Commission's regulations. Accordingly, it is respectfully requested that the information, which is proprietary to Westinghouse, be withheld from public disclosure in accordance with 2.390 of the Commission's regulations. This affidavit, along with Westinghouse authorization letter, CAW-15-4077, "Application for Withholding Proprietary Information from Public Disclosure," is contained in Enclosure Ill.

This letter contains no commitments. If you have any questions concerning this matter, please contact me at (620) 364-4156, or Mr. Steven R. Koenig at (620) 364-4041.

Sincerely, Jaime H. McCoyv JHM/rlt Attachment Enclosure I Attachment 1 to LTR-LIS-15-11, Revision 1, "Westinghouse Suggested Response to NRC Request for Additional Information (RAI) Regarding the Wolf Creek (SAP) ASTRUM Analysis - Proprietary" II Attachment 2 to LTR-LIS-15-11, Revision 1, "Westinghouse Suggested Response to NRC Request for Additional Information (RAI) Regarding the Wolf Creek (SAP) ASTRUM Analysis - Non- Proprietary" III CAW-15-4077, "Application for Withholding Proprietary Information from Public Disclosure" IV CD-ROM - Spreadsheet Version of Data Documented in Tables 1 and 2 of Attachment 1 to LTR-LIS-1 5-11, Revision 1 (Proprietary) cc: T. A. Conley (KDHE), w/a, w/e (Enclosure II only)

M. L. Dapas (NRC), w/a, w/e C. F. Lyon (NRC), w/a, w/e N. F. O'Keefe (NRC), w/a, w/e Senior Resident Inspector (NRC), w/a, w/e

ET 15-0002 Page 3 of 3 STATE OF KANSAS )

COUNTY OF COFFEY )

Jaime H. McCoy, of lawful age, being first duly sworn upon oath says that he is Vice President Engineering of Wolf Creek Nuclear Operating Corporation; that he has read the foregoing document and knows the contents thereof; that he has executed the same for and on behalf of said Corporation with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

Jaime H cCoy Vice Psident Engineering SUBSCRIBED and sworn to before me this 2/1 4day of iTOilCr./ f 2015.

I**GAYLE3OHEP.-- T-AP Notarygublic r Nc'iOarfj PullCr - ctf ziz-s cf Expiration Date __ /f5

Attachment to ET 15-0002 Page 1 of 3 Response to Request for Additional Information Reference 1 provided the Wolf Creek Nuclear Operating Corporation (WCNOC) application to revise the Wolf Creek Generating Station (WCGS) Technical Specifications (TS). Specification 5.6.5, "CORE OPERATING LIMITS REPORT (COLR)," is revised to incorporate WCAP-16009-P-A, "Realistic Large-Break LOCA Evaluation Methodology Using the Automated Statistical Treatment of Uncertainty Method (ASTRUM)," to the list of analytical methods used to determine the core operating limits. The Reference 1 application was a plant specific best-estimate large break loss-of-coolant accident (LOCA) analysis that accounted for the effects of fuel thermal conductivity degradation (TCD). Reference 2 provided a request for additional information related to the application. The specific NRC question is provided in italics.

1. Please provide a table of the ASTRUM initial conditions, operating parameters, and results. Please also include PCT, Time of PCT, Fq, FdH, Cycle Bumup, RCS Tavg, Accumulator Temperature, Safety Injection Temperature, and Safety Injection Time. A data file is an acceptable and preferredformat.

Response: Enclosure I provides a table of the ASTRUM initial conditions, operating parameters and results. The table includes peak cladding temperature (PCT), Time of PCT, Fq, FdH, Cycle Burnup, Reactor Coolant System (RCS) Tavg, Accumulator Temperature, Safety Injection Temperature, and Safety Injection Time. Enclosure IV is a CD-ROM of the data.

SUPPLEMENTAL INFORMATION Provided below is supplemental information related to the plant specific best-estimate large break LOCA analysis that has been identified subsequent to the submittal of Reference 1.

Treatment of Burnup Effects

Background

While updating the FULL SPECTRUMTM LOCA (FSLOCATM ) Evaluation Model (Reference 3) analysis methodology to explicitly consider pellet TCD and fuel beyond the first cycle of irradiation, it was discovered that some approximations made in the WCGS plant specific adaptation of the ASTRUM methodology (References 1 and 4) to address TCD could introduce nonconservatisms. As described in Section 3.3 of Enclosure I of Reference 1, the statistically sampled time-in-cycle was translated into rod average burnups consistent with the NRC-approved ASTRUM methodology. For second-cycle fuel, the approach tends to over-estimate the actual rod burnups in the core. Because the peaking factors assumed in the analysis reduce as rod burnup increases (see Table 2 in Enclosure I of Reference 1), the analyzed rod power and local peaking could under-estimate the peaking factors of the rods at the sampled time-in-cycle.

Also, the treatment of gamma energy deposition assumes that the modeled hot assembly is surrounded by assemblies with power consistent with the core-average. However, second-cycle assemblies are often face-adjacent with feed assemblies, which can have power higher than the core-average. This can result in an over-estimation of the energy deposited away from the hot rod and hot assembly.

Attachment to ET 15-0002 Page 2 of 3 Affected Evaluation Model 2004 Westinghouse Realistic Large Break LOCA Evaluation Model Using ASTRUM (plant-specific adaptation for WCGS)

Estimated Effect The as-analyzed peaking factors for the cases in the WCGS analysis were compared to the peaking factors that would realistically bound the rods in the core at the statistically sampled time-in-cycle. It was confirmed that the analysis results remain applicable. Any non-conservatisms associated with the rod burnup and peaking factor approximations and the application of the gamma deposition model are offset by conservatisms in the assumed peaking factors such that the most limiting PCT results are unaffected.

Because the as-analyzed conditions (rod burnup and peaking factors) for the most limiting results in the analysis remain applicable, the estimated peak cladding temperature effect of these closely related issues is 0°F.

Errors in Decay Group Uncertainty Factors Back-ground Errors in the calculation of decay heat were discovered in the WCOBRA/TRAC code. The decay group uncertainty factors for each fissile isotope are provided in Table 8-14 of WCAP-16009-P-A. The uncertainty factors for 239pu were applied to 2 38U, and those for 238U were applied 239 to 239pu. This error causes an over-prediction of the uncertainty in decay power from pu and an under-prediction of the uncertainty in decay power from 23SU. Further, the decay group uncertainty factor for Decay Group 6 of 235U was erroneously coded as 2.5% instead of 2.25%. Correction of these errors impacts the application of the sampled decay heat uncertainty, which may result in small changes to the decay heat power. These issues have been evaluated to estimate the impact on Automated Statistical Treatment of Uncertainty Method (ASTRUM) Best-Estimate (BE) Large-Break Loss-of-Coolant Accident (LBLOCA) analysis results.

Affected Evaluation Model 2004 Westinghouse Realistic Large Break LOCA Evaluation Model Using ASTRUM Estimated Effect The issues described above were evaluated to account for the correction of these errors. The plant-specific sensitivity study resulted in an estimated PCT impact of -10°F for WCGS.

This change results in the following to the Table 1 results on page 3 of Attachment I of Reference 1.

Attachment to ET 15-0002 Page 3 of 3 Table I WCGS Best-Estimate Large Break LOCA Results 10 CFR 50.46 Requirement Value Criteria 95/95 Peak Cladding Temperature (OF) 1890 < 2200 95/95 Maximum Local Oxidation (%) 4.21 < 17 95/95 Core-Wide Oxidation (%) 0.1352 < 1

References:

1. WCNOC letter ET 14-0008, "Application for Amendment to Revise Specification 5.6.6, "CORE OPERATING LIMITS REPORT (COLR)," for Large Break Loss-of-Coolant Accident Analysis Methodology," February 26, 2014. ADAMS Accession No. ML14064A328

2. Electronic mail from C. F. Lyon, USNRC, to S. G. Wideman, WCNOC, "RE: Question on LAR to add ASTRUM to COLR (Wolf Creek TAC No. MF3518)," November 20, 2014.

ADAMS Accession No. ML14324A858

3. WCAP-16996-P, "Realistic LOCA Evaluation Methodology Applied to the Full Spectrum of Break Sizes (FULL SPECTRUM LOCA Methodology)," November 2010.

4. WCAP-16009-P-A, "Realistic Large-Break LOCA Evaluation Methodology Using the Automated Statistical Treatment Of Uncertainty Method (ASTRUM)," January 2005.

Enclosure II to ET 15-0002 to LTR-LIS-15-11, Revision 1, "Westinghouse Suggested Response to NRC Request for Additional Information (RAI) Regarding the Wolf Creek (SAP) ASTRUM Analysis - Non-Proprietary"

Westinghouse Non-Proprietary Class 3 Attachment 2 to LTR-LIS-15-11, Revision 1 Westinghouse Suggested Response to NRC Request for Additional Information (RAI) Regarding the Wolf Creek (SAP) ASTRUM Analysis - Non-Proprietary (11 Pages including Cover Page)

© 2015 Westinghouse Electric Company LLC All Rights Reserved

Westinghouse Non-Proprietary Class 3 to LTR-LIS-15-11, Revision 1 Page 2 of 11

1) Please provide a table of the ASTRUM initial conditions, operating parameters, and results. Please also include PCT, Time of PCT, Fq, FdH, Cycle Burnup, RCS Tavg, Accumulator Temperature, Safety Injection Temperature, and Safety Injection Time. A data file is an acceptable and preferred format [from Reference 1].

Table 1: Wolf Creek (SAP) Cycle 1 ASTRUM Runset Data Run Max HS HS Sl TAVG PRCS PACC VACC TACC TSI FQ FDH PBOT PMID Sampled Hot Rod PCT PCT Time Cycle Burnup Time Burnup

[°F] [s] [s] [*F] [psia] [psia] [ft3] [(F] [°F] [-] [-] [-] [-] [MWD/ [MWD/

MTU] MTU]

a,c

Westinghouse Non-Proprietary Class 3 to LTR-LIS-1 5-11, Revision 1 Page 3 of 11 Run Max HS HS SI TAVG PRCS PACC VACC TACC TSI FQ FDH PBOT PMID Sampled Hot Rod PCT PCT Time Cycle Burnup Time Burnup

[fFl Is] [s] [°F] [psia] [psia] [ft3] [°F] [*F] [-] [-] [-] -] [MWD/ (MWD/

MTU] MTU]

a,c

_ i I _ _ _ J_ _I _ I _ _ I _ I _ _

I- 4 4 F + 4 4 4 4 + 4 F 4 4 I- + 4 4 I 4 4 4 1 4- 4 I 4 1 F 4-- 4 4 4 + 4 4 4 4 + 4 F 4 4

+ 4 4 F + 4 4 4 1 + 4 4 4 F -I- 4 4 F 4 4 4 4 + 4 4 4 4

Westinghouse Non-Proprietary Class 3 to LTR-LIS-15-11, Revision 1 Page 4 of 11 Run Max HS HS SI TAVG PRCS PACC VACC TACC TSI FQ FDH PBOT PMID Sampled Hot Rod PCT PCT Time Cycle Burnup Time Burnup

[°F] [s] Es] ['F] [psia] [psia] [ft3] ['F] ['F] [-] [-] [-] [-] [MWD/ [MWD/

MTU] MTU]

a,c

Westinghouse Non-Proprietary Class 3 to LTR-LIS-15-11, Revision 1 Page 5 of 11 Run Max HS HS Sl TAVG PRCS PACC VACC TACC TSI FQ FDH PBOT PMID Sampled Hot Rod PCT PCT Time Cycle Burnup Time Burnup

[°F] [s] [s] [*F] (psia] [psia] [ft3] ['F] [0F] [-] [-] [-] [-] (MVVD/ [MWD/

MTU] MTU]

a,c

Westinghouse Non-Proprietary Class 3 to LTR-LIS-15-11, Revision 1 Page 6 of 11 Run Max HS HS Sl TAVG PRCS PACC VACC TACC TSI FQ FDH PBOT PMID Sampled Hot Rod PCT PCT Time Cycle Burnup Time Burnup

[*F] [s] [s] [(F] [psia] [psia] [ft3] [°F] [°F] [-] [-] H-] -] [MWD/ [MWD/

MTU] MTU]

a,c Notes:

1. Evaluations that were performed subsequent to the submittal in Reference 2 are not reflected in the tabulated data presented in this table (i.e., the evaluation of the treatment of burnup effects and the errors in decay group uncertainty factors.)

Westinghouse Non-Proprietary Class 3 Attachment 2 to LTR-LIS-1 5-11, Revision 1 Page 7 of 11 Table 2: Wolf Creek (SAP) Cycle 2 ASTRUM Runset Data HS Max HS PCT SI Cycle Hot Rod Run PCT Time Time TAVG PRCS PACC VACC TACC TSI FQ FDH PBOT PMID Burnup Burnup

[°F] Is] Is] [oF] [psia] [psia] fl [°F] ['F] [ - -] [MWD/

MTU] [MWD/

MTU]

[fL3]

a,c

__ __ __ J__ I___ I__ J

__ J

__ I __ It __ I__ I__ I__ I__

Westinghouse Non-Proprietary Class 3 to LTR-LIS-15-11, Revision 1 Page 8 of 11 HS Max HS POT SI Cycle Hot Rod Run PCT Time Time TAVG PRCS PACC VACC TACC TSI FQ FDH PBOT PMID Burnup Burnup

[MWD/ [MWD/

[°]s [] [*F] [psia] [psia] fl °][F - - - - MTU] MTU]

a,c

Westinghouse Non-Proprietary Class 3 to LTR-LIS-15-11, Revision 1 Page 9 of 11 HS Max HS PCT SI Cycle Hot Rod Run PCT Time Time TAVG PRCS PACC VACC TACC TSI FQ FDH PBOT PMID Burnup Burnup

[MWD/ [MWD/

(F] Is] Is] [*FL [psia3 [psia] f [F] [FL [-] MTU] MTU]

a,c

Westinghouse Non-Proprietary Class 3 to LTR-LIS-1 5-11, Revision 1 Page 10 of 11 HS Max HS PCT SI Cycle Hot Rod Run PCT Time Time TAVG PRCS PACC VACC TACC TSI FQ FDH PBOT PMID Burnup Burnup

[MWD/ [MWD/

[*F] Is] Is] [°F] [psia] [psia] [ *t][F] [°F] [-] [-] [-] [-] MTU] MTU]

a,c

Westinghouse Non-Proprietary Class 3 to LTR-LIS-15-11, Revision 1 Page 11 of 11 HS Max HS PCT SI Cycle Hot Rod Run PCT Time Time TAVG PRCS PACC VACC TACC TSl FQ FDH PBOT PMID Burnup Burnup WD/ [M W D /

[*F] Is) Is] ['Fl [psia] [psial _ 3_ _~ i[M[*F]

W- [*F] [-] [-] HL MTU] MTU a,c 4 4 4 4 4 4 + 4 4 4 + 4 4 4 +

1 4 4 4 4 4 4 4 1 4 +/- 4 4 4 4 4 4 4 I. 4 4 4 4 -I- I' 4 -

4 4 4 4 4 4 4 4 4 4 + 4 4 4 +

1 4 4 4 4 4 4 1 1 1 4. 4 4 4 4.

4 4 4 4 I. 4 4 4 4 -I- I- 4 4 4 4 4 4 4 4

• 4 4 4 + 4 4 4 +

Notes:

1. Evaluations that were performed subsequent to the submittal in Reference 2 are not reflected in the tabulated data presented in this table (i.e., the evaluation of the treatment of burnup effects and the errors in decay qroup uncertainty factors.)

References

1. Electronic mail from F. Lyon, USNRC, to S. G. Wideman, WCNOC, "RE: Question on LAR to add ASTRUM to COLR (Wolf Creek TAC No. MF3518),"

November 20, 2014. ADAMS Accession No. ML14324A858.

2. WCNOC letter ET 14-0008, "Application for Amendment to Revise Specification 5.6.5, "CORE OPERATING LIMITS REPORT (COLR)," for Large Break Loss-of-Coolant Accident Analysis Methodology," February 26, 2014. ADAMS Accession No. ML14064A328.

Enclosure III to ET 15-0002 CAW-15-4077, "Application for Withholding Proprietary Information from Public Disclosure" (8 pages)

Westinghouse Westinghouse Electric Company Engineering, Equipment and Major Projects 1000 Westinghouse Drive, Building 3 Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (724) 940-8560 11555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852 Proj letter: SAP-15-4 Rev. I CAW-1 5-4077 January 15, 2015 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE Suibject: LTR-LIS- 15-11, Revision 1, Attachment 1, "Westinghouse Suggested Response to NRC Request for Additional Information (RAI) Regarding the Wolf Creek (SAP) ASTRUM Analysis" (Proprietary) and LTR-LIS-15-11, Revision 1, Attachment 3, "Electronic Data Tables Supporting the Westinghouse Suggested Response to NRC Request for Additional Information (RAI)

Regarding the Wolf Creek (SAP) ASTRUM Analysis" (Proprietary)

The proprietary information for which withholding is being requested in the above-referenced reports is further identified in Affidavit CAW-15-4077 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The Affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Wolf Creek Nuclear Operation Corp (WCNOC).

Correspondence with respect to the proprietary aspects of the Application for Withholding or the Westinghouse Affidavit should reference CAW-1 5-4077, and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 3 Suite 310, Cranberry Township, Pennsylvania 16066.

Very truly yours, james A. Gresham, Manager Regulatory Compliance

CAW-15-4077 January 15, 2015.

AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF BUTLER:

I, James A. Gresham, am authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief.

J/ames A. Gresham, Manager Regulatory Compliance

2 CAW-15-4077 (1) I am Manager, Regulatory Compliance, Westinghouse Electric Company LLC (Westinghouse),

and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

(2) 1am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitute Westinghouse policy and provide the rational basis required.

Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of

3 CAW-15-4077 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d) It reveals cost or price information, production capacities, budget levels,, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

(iii) There are sound policy reasons behind the Westinghouse system which include the following:

(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.

(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

4 CAW-1 5-4077 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.

(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

(iv) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.

(v) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.

(vi) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in LTR-LIS-15-11, Revision 1, Attachment 1, "Westinghouse Suggested Response to NRC Request for Additional Information (RAI) Regarding the Wolf Creek (SAP) ASTRUM Analysis" and LTR-LIS-15-11, Revision 1, Attachment 3, "Electronic Data Tables Supporting the Westinghouse Suggested Response to NRC Request for Additional Information (RAI) Regarding the Wolf Creek (SAP) ASTRUM Analysis" (Proprietary) for submittal to the Commission, being transmitted by Wolf Creek Nuclear Operation Corp. (WCNOC) letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with the results of the Wolf Creek ASTRUM analysis, and may be used only for that purpose.

6 CAW-15-4077 (a) This information is part of that which will enable Westinghouse to:

(i) Provide input to Wolf Creek Nuclear Operation Corp. (WCNOC) to provide to the U.S. Nuclear Regulatory Commission in response to NRC Request for Additional Information related to the Wolf Creek ASTRUM submittal.

(ii) Provide licensing support for customer submittal.

(b) Further this information has substantial commercial value as follows:

(i) Westinghouse plans to sell the use of the information to its customers for the purpose of responding to NRC RAIs.

(ii) Westinghouse can sell support and defense of the technology to its customer in the licensing process.

(iii) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar calculation results and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.

In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.

PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary versions of documents furnished to the NRC associated with the results of the Wolf Creek ASTRUM analysis, and may be used only for that purpose.

In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the Affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).

COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

Enclosure IV to ET 15-0002 CD-ROM - Spreadsheet Version of Data Documented in Tables 1 and 2 of Attachment I to LTR-LIS-15-11 (Proprietary)