ML13092A348

Extended Power Uprate: Replacement Steam Dryer - Responses to Requests for Additional Information and Analysis Documentation

ML13092A348
Person / Time
Site:	Monticello
Issue date:	03/29/2013
From:	Schimmel M A Northern States Power Co, Xcel Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-MT-13-029, TAC MD9990
Download: ML13092A348 (80)

Text

{{#Wiki_filter:ENCLOSURES 1, 2, 3,4,5,6 AND 7 CONTAIN PROPRIETARY INFORMATION -WITHHOLD FROM PUBLIC DISCLOSURE IN ACCORDANCE WITH 10 CFR 2.390 IXcelEner/y Monticello Nuclear Generating Plant 2807 W County Rd 75 Monticello, MN 55362 March 29, 2013 L-MT-13-029 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Monticello Nuclear Generating Plant Docket 50-263 Renewed License No. DPR-22 Monticello Extended Power Uprate: Replacement Steam Dryer -Responses to Requests for Additional Information and Analysis Documentation (TAC MD9990)

References:

1) Letter from T J O'Connor (NSPM) to Document Control Desk (NRC),"License Amendment Request: Extended Power Uprate (TAC MD9990)," L-MT-08-052, dated November 5, 2008. (ADAMS Accession No. ML083230111)

2) Letter from T J O'Connor (NSPM) to Document Control Desk (NRC),"Monticello Extended Power Uprate: Replacement Steam Dryer Supplement (TAC MD9990)," L-MT-10-046, dated June 30, 2010.(ADAMS Accession No. ML102010462)

3) Letter from T J O'Connor (NSPM) to Document Control Desk (NRC),"Monticello Extended Power Uprate: Updates to Docketed Information (TAC MD9990)," L-MT-10-072, dated December 21, 2010. (ADAMS Accession No. ML103570026)

4) Letter from M A Schimmel (NSPM) to Document Control Desk (NRC),"Monticello Extended Power Uprate: Supplement to Revise Technical Specification Setpoint for the Automatic Depressurization System Bypass Timer (TAC MD9990)," L-MT-12-091, dated October 30, 2012.(ADAMS Accession No. ML12307A036)

5) Email from T Beltz (NRC) to J Fields (NSPM), "Monticello Nuclear Generating Plant -Draft Requests for Additional Information re: Extended Power Uprate Steam Dryer Review (TAC MD9990)," [RAIs 42 -53] dated November 8, 2012.

Document Control Desk Page 2 6) Email from T Beltz (NRC) to J Fields (NSPM), "Monticello Nuclear Generating Plant -Draft Requests for Additional Information re: Extended Power Uprate Steam Dryer Review (TAC MD9990)," [RAIs 54 -67] dated December 13, 2012.7) Email from K Feintuch (NRC) to J Fields (NSPM), "Monticello Nuclear Generating Plant -Draft Requests for Additional Information re: Extended Power Uprate Steam Dryer Review (TAC MD9990)," [RAI 67e] dated December 17, 2012. (ADAMS Accession No.ML12353A053)

8) Email from T Beltz (NRC) to J Fields (NSPM), "Monticello Nuclear Generating Plant -Draft Requests for Additional Information re: Extended Power Uprate Steam Dryer Review (TAC MD9990)," [RAIs 68 -80] dated January 4, 2013.9) Letter from T Beltz (NRC) to J Fields (NSPM), "Monticello Nuclear Generating Plant -Draft Requests for Additional Information re: Extended Power Uprate Steam Dryer Review (TAC MD9990)," [RAIs 81 -84] dated January 16, 2013.Pursuant to 10 CFR 50.90, the Northern States Power Company, a Minnesota corporation (NSPM), doing business as Xcel Energy, requested in Reference 1 an amendment to the Monticello Nuclear Generating Plant (MNGP) Renewed Operating License (OL) and Technical Specifications (TS) to increase the maximum authorized power level from 1775 megawatts thermal (MWt) to 2004 MWt.In Reference 2 NSPM provided a supplement to Reference 1 to provide detailed design and analysis results for a replacement steam dryer (RSD) for MNGP. Reference 3 was provided to correct reactor internal pressure differential information provided in Reference 2.In References 5, 6, 7, 8 and 9 the NRC provided NSPM draft requests for additional information (RAIs). Conference calls regarding these draft RAIs were held on December 4, 2012, January 18, 2013 and February 19, 2013.The purpose of this letter is to provide the NRC with the final RAI responses and to provide the detailed analysis documentation referenced in the RAI responses.

This is the fourth and final letter in a series of letters that provided responses to all the NRC RAIs included in References 5 through 9.Enclosure 1 contains Westinghouse Electric Company, LLC (WEC) letter LTR-A&SA-13-7, P-Attachment, Revision 1, "Monticello Replacement Steam Dryer RAI Responses for Acoustic/Structural Analyses Set #4," dated March 27, 2013. Enclosure 1 provides responses to RAIs 44(c), 69, 70, 72(b), 72(c), 76, 82, 83 and 84. Also, included is Document Control Desk Page 3 supplemental information concerning the MNGP RSD. Enclosure 1 contains proprietary information. Enclosure 2 contains Westinghouse Electric Company, LLC (WEC) WCAP-17548-P, Revision 1, "Signal Processing Performed on Monticello MSL Strain Gauge and RSD Instrumentation Data," dated March 2013. This document provides details concerning the signal processing methods applied to the plant data to support the benchmarking of the structural integrity evaluation methods. This revision supersedes the document previously sent to the NRC. This document contains proprietary information. Enclosure 3 contains WEC WCAP-17251-P, Revision 1, "Monticello Replacement Steam Dryer Four-Line Acoustic Subscale Testing Report," dated March 2013. This document provides the results of subscale testing performed on the RSD and the original equipment manufacturer steam dryer. This revision supersedes the document previously sent to the NRC. This document contains proprietary information. Enclosure 4 contains WEC WCAP-17252-P, Revision 3, "Acoustic Loads Definition for the Monticello Steam Dryer Replacement Project," dated March 2013. This document provides an accurate three-dimensional model of the steam dryer and the surrounding fluid to predict the distribution of the pressure loads on the entire structure. This revision supersedes the document previously sent to the NRC. This document contains proprietary information. Enclosure 5 contains WEC WCAP-17549-P, Revision 1, "Monticello Replacement Steam Dryer Structural Evaluation for High-Cycle Acoustic Loads Using ACE," dated March 2013. This document provides a high-cycle fatigue evaluation of the MNGP RSD with loads generated using the Acoustic Circuit Enhanced (ACE) Revision 2.0 methodology. Acoustic loads and stresses for extended power uprate (EPU) conditions have been evaluated for high-cycle fatigue and have been determined to meet the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV)Code Section III, Subsection NG criteria. This revision supersedes the document previously sent to the NRC. This document contains proprietary information. Enclosure 6 contains WEC WCAP-17716, Revision 0, "Benchmarking of the Steam Dryer Acoustic/Structural Methodology," dated March 2013. This document provides the basis for the development of ACE Revision 2.0 and its application to the MNGP RSD. This document provides complete "end-to-end" benchmark of the MNGP RSD using only MNGP plant-specific direct dryer data. This document contains proprietary information. Enclosure 7 contains WEC letter LTR-A&SA-09-32, Revision 6, P- Attachment (Proprietary), "Limit Curves for Monticello Power Ascension," dated March 20, 2013.This revision supersedes the document previously sent to the NRC. This document contains proprietary information. Document Control Desk Page 4 Enclosure 8 contains WEC affidavits executed to support withholding Enclosures 1, 2, 3, 4, 5, 6 and 7 from public disclosure. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the NRC and addresses with specificity the considerations listed in 10 CFR 2.390(b)(4). NSPM requests that the proprietary information in Enclosures 1 -7 be withheld from public disclosure in accordance with 10 CFR 2.390(a)4, as authorized by 10 CFR 9.17(a)4. Accordingly, it is respectfully requested that the information which is proprietary to WEC be withheld from public disclosure in accordance with 10 CFR 2.390.Correspondence with respect to the copyright or proprietary aspects of WEC information or the supporting WEC affidavits in Enclosure 8 should be addressed to J.A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company LLC, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.Enclosures 9, 10, 11, 12, 13, 14 and 15 contain nonproprietary versions of Enclosures 1, 2, 3, 4, 5, 6 and 7 respectively. The nonproprietary reports are being provided based on the NRC's expectation that the submitter of the proprietary information should provide, if possible, a nonproprietary version of the document with brackets showing where the proprietary information has been deleted.The RAI responses and analysis documentation provided herein do not change the conclusions of the No Significant Hazards Consideration and the Environmental Consideration evaluations provided in Reference 1 as revised by References 3 and 4.In accordance with 10 CFR 50.91(b), a copy of this application supplement, without enclosures is being provided to the designated Minnesota Official. Document Control Desk Page 5 Summary of Commitments This letter makes no new commitments and no revisions to existing commitments. I declare under penalty of perjury that the foregoing is true and correct.Executed on: March z9, 2013 Mark A. Schimmel Site Vice-President Monticello Nuclear Generating Plant Northern States Power Company-Minnesota Enclosures (15)cc: Administrator, Region Ill, USNRC (w/o enclosures) Project Manager, Monticello Nuclear Generating Plant, USNRC Resident Inspector, Monticello Nuclear Generating Plant, USNRC (w/o enclosures) Minnesota Department of Commerce (w/o enclosures) L-MT-1 3-029 ENCLOSURE 8 AFFIDAVITS FOR WITHHOLDING PROPRIETARY DOCUMENTS 50 pages follow L-MT-13-029 Enclosure 8 Affidavits for Withholding Proprietary Documents The table below provides an index to the affidavits provided within this enclosure. The index correlates the affidavit with the document each affidavit supports.Letter and Affidavit

1. Enclosure number -Document number & Name LTR-EP-13-012, Revision 1 Enclosure 1 -LTR-A&SA-13-7, P-Attachment, Affidavit CAW-1 3-3679 Revision 1, "Monticello Replacement Steam Dryer RAI Responses for Acoustic/Structural Analyses Set#4," dated March 27, 2013 LTR-EP-13-014 Enclosure 2- WCAP-17548-P, Revision 1, "Signal Affidavit CAW-13-3646 Processing Performed on Monticello MSL Strain Gauge and RSD Instrumentation Data" LTR-EP-13-015 Enclosure 3 -WCAP-17251 -P, Revision 1, "Monticello Affidavit CAW-13-3665 Replacement Steam Dryer Four-Line Acoustic Subscale Testing Report" LTR-EP-13-017 Enclosure 4 -WCAP-17252-P, Revision 3, "Acoustic Affidavit CAW-1 3-3666 Loads Definition for the Monticello Steam Dryer Replacement Project" LTR-EP-13-019 Enclosure 5 -WCAP-17549-P, Revision 1, "Monticello Affidavit CAW-13-3668 Replacement Steam Dryer Structural Evaluation for High-Cycle Acoustic Loads Using ACE" LTR-EP-13-018 Enclosure 6 -WCAP-1 7716, Revision 0, Affidavit CAW-1 3-3667 "Benchmarking of the Steam Dryer Acoustic/Structural Methodology" LTR-EP-13-020 Enclosure 7 -LTR-A&SA-09-32, Revision 6, P-Affidavit CAW-13-3671 Attachment, "Limit Curves for Monticello Power Ascension," dated March 20, 2013

• Westinghouse U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Westinghouse Electric Company Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA (412) 374-4419 (724) 720-0857 maurerbf@westinghouse.com LTR-EP- 13-012, Revision I Direct tel: Direct fax: e-mail: Proj letter: CAW-13-3679 March 27, 2013 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

LTR-A&SA-13-7, Revision 1, P-Attachment, "Monticello Replacement Steam Dryer RAI Responses for Acoustic/Structural Analyses Set #4" (Proprietary) The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-13-3679 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 Xcel Energy.Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference CAW-13-3679, and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.Very truly yours, Bradley F. Maurer, Manager ABWR Licensing Enclosures CAW- 13-3679 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA: ss COUNTY OF BUTLER: Before me, the undersigned authority, personally appeared Bradley F. Maurer, who, being by me duly sworn according to law, deposes and says that he is 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 his knowledge, information, and belief: Bradley F. Maurer, Manager ABWR Licensing Sworn to and subscribed before me this 27th day of March 2013 Notary Public COMMONWEALTH OF PENNSYLVANIA Notarlal Seal Anne M. Stegman, Notary Public Unity Twp., Westmoreland County My Commission Expires Aug. 7, 2016 MENBER PENNSYLVANIA ASSOCIATION OF NOTARIES 2 CAW-13-3679 (1) I am Manager, ABWR Licensing, in Nuclear Services, 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) 1 am 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 constitutes Westinghouse policy and provides 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-13-3679 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. 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-13-3679 (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.(iii) 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.(iv) 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.(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in LTR-A&SA-13-7, Revision 1, P-Attachment, "Monticello Replacement Steam Dryer RAI Responses for Acoustic/Structural Analyses Set #4" (Proprietary) for submittal to the Commission, being transmitted by Xcel Energy 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 Monticello Replacement Steam Dryer Project, and may be used only for that purpose. 5 CAW-13-3679 This information is part of that which will enable Westinghouse to: (a) Respond to NRC RAIs regarding the Monticello replacement steam dryer analysis.Further this information has substantial commercial value as follows: (a) Westinghouse plans to sell the use of the information to its customers for the purpose of replacement steam dryer qualification.(b) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse. Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information. The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.Further the deponent sayeth not. PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning 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.

• Westinghouse U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Westinghouse Electric Company Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA Direct tel: Direct fax: e-mail: Proj letter: (412) 374-4643 (724) 720-0754 greshaja@westinghouse.com LTR-EP- 13-014 CAW-13-3646 March 19, 2013 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

WCAP-17548-P, Revision 1, "Signal Processing Performed on Monticello MSL Strain Gauge and RSD Instrumentation Data" (Proprietary) The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-13-3646 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 Xcel Energy.Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference CAW-13-3646, and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.Very truly yours, Bradley F. Maurer, Manager ABWR Licensing Enclosures CAW-13-3643 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA: $s COUNTY OF BUTLER: Before me, the undersigned authority, personally appeared Bradley F. Maurer, who, being by me duly sworn according to law, deposes and says that he is 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 his knowledge, information, and belief: Bradley F. Maurer, Manager ABWR Licensing Sworn to and subscribed before me this 19th day of March 2013 Notary Public-COMMONWEALTH OF PENNSYLVANIA I Notadal Seal Anne M. Stegman, Notary Pubhlc Unity Twp., Westmoreland County My Commission Expires Aug. 7, 2016 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES 2 CAW-13-3617 (1) 1 am Manager, ABWR Licensing, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse. (2) I am making this Affidavit in conformance with the provisions of 10 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) 1 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 constitutes Westinghouse policy and provides 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-13-3617 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. 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-13-3617 (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.(iii) 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.(iv) 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.(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP- 17548-P, Revision 1, "Signal Processing Performed on Monticello MSL Strain Gauge and RSD Instrumentation Data" (Proprietary), dated March 5, 2013, for submittal to the Commission, being transmitted by Xcel Energy 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 Monticello Replacement Steam Dryer Project, and may be used only for that purpose. 5 CAW-13-3617 This information is part of that which will enable Westinghouse to: (a) Apply signal processing methodology to MSL and RSD data to support future EPU operation. Further this information has substantial commercial value as follows: (a) Westinghouse plans to sell the use of the information to its customers for the purpose of the Monticello Replacement Steam Dryer Project.(b) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse. Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information. The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.Further the deponent sayeth not. PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning 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.

• Westinghouse U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD 20852.Westing house Electric Company Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA Direct tel: Direct fax: e-mail: Proj letter: (412) 374-4643 (724) 720-0754 greshaja@westinghouse.com LTR-EP-1 3-015 CAW-13-3665 March 20, 2013 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

WCAP-17251-P, Revision 1, "Monticello Replacement Steam Dryer Four-Line Acoustic Subscale Testing Report" (Proprietary) The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-13-3665 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 Xcel Energy.Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference CAW-13-3 665, and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.Very truly yours, Bradley F. Maurer, Manager ABWR Licensing Enclosures CAW-13-3665 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA: ss COUNTY OF BUTLER: Before me, the undersigned authority, personally appeared Bradley F. Maurer, who, being by me duly sworn according to law, deposes and says that he is 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 his knowledge, information, and belief: Bradley F. Maurer, Manager ABWR Licensing Sworn to and subscribed before me this 20th day of March 2013ýJoqw~Notary Public L -O~VAT -OF PKNAGAYVARMtL NOWrtaI Sees 3dyce A. S.Ip,, Noary A b th M C"" Membmr POM"'118 AMM of ftg. 2 CAW-13-3665 (1) 1 am Manager, ABWR Licensing, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse. (2) I am making this Affidavit in conformance with the provisions of 10 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 constitutes Westinghouse policy and provides 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-13-3665 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. 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-13-3665 (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.(iii) 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.(iv) 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.(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP-1725 I-P, Revision 1, "Monticello Replacement Steam Dryer Four-Line Acoustic Subscale Testing Report" (Proprietary), for submittal to the Commission, being transmitted by Xcel Energy 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 Monticello Replacement Steam Dryer Project, and may be used only for that purpose.This information is part of that which will enable Westinghouse to: (a) Provide four-line subscale test data used in the acoustic analysis program to support NRC review of the Monticello RSD. 5 CAW-13-3665 Further this information has substantial commercial value as follows: (a) Westinghouse plans to sell the use of the information to its customers for the purpose of the Monticello Replacement Steam Dryer Project.(b) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse. Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information. The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.Further the deponent sayeth not. PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning 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. L_W estinghouse Westinghouse Electric Company Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4419 Document Control Desk Direct fax: (724) 720-0857 11555 Rockville Pike e-mail: maurerbf@westinghouse.com Rockville, MD 20852 Proj letter: LTR-EP-13-017 CAW-13-3666 March 21, 2013 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

WCAP-17252-P, Revision 3, "Acoustic Loads Definition for the Monticello Steam Dryer Replacement Project" (Proprietary) The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-13-3666 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 2.3 90 of the Commission's regulations. 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 the Westinghouse affidavit should reference CAW-13-3666, and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.Very truly yours, Bradley F. Maurer, Manager ABWR Licensing Enclosures CAW-13-3666 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA: ss COUNTY OF BUTLER: Before me, the undersigned authority, personally appeared Bradley F. Maurer, who, being by me duly sworn according to law, deposes and says that he is 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 his knowledge, information, and belief: Bradley F. Maurer, Manager ABWR Licensing Sworn to and subscribed before me this 21 st day of March 2013 Notary Public COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Renee Glampole, Notary Public Penn Township, Westmoreland County My Commission Expires September 25, 2013 2 CAW-13-3666 L (1) I am Manager, ABWR Licensing, in Nuclear Services, Westinghouse Electric Company LLC L (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) 1 am 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 constitutes Westinghouse policy and provides 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 L CAW-13-3666 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. 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. L 4 CAW-13-3666 (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.(iii) 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.(iv) 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.(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP- 1 7252-P, Revision 3, "Acoustic Loads Definition for the Monticello Steam Dryer Replacement Project" (Proprietary) for submittal to the Commission, being transmitted by Xcel Energy 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 Monticello Replacement Steam Dryer Project, and may be used only for that purpose.This information is part of that which will enable Westinghouse to: (a) Provide the acoustic load definitions for the Monticello RSD to assist in the NRC review of the Xcel Energy EPU application. 5 CAW-13-3666 Further this information has substantial commercial value as follows: (a) Westinghouse plans to sell the use of the information to its customers for the purpose of replacement steam dryer qualification..(b) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse. Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information. The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.Further the deponent sayeth not. PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in theV 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.

• Westinghouse Westinghouse Electric Company Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Direct tel: Direct fax: e-mail: Proj letter: (412) 374-4643 (724) 720-0754 greshaja@westinghouse.com LTR-EP-13-019 CAW-13-3668 March 20, 2013 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

WCAP-17549-P, Revision 1, "Monticello Replacement Steam Dryer Structural Evaluation for High-Cycle Acoustic Loads Using ACE" (Proprietary) The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-13-3668 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 2.3 90 of the Commission's regulations. 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 the Westinghouse affidavit should reference CAW-13-3668, and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.Very truly yours, Bradley F. Maurer, Manager ABWR Licensing Enclosures CAW-13-3668 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA: ss COUNTY OF BUTLER: Before me, the undersigned authority, personally appeared Bradley F. Maurer, who, being by me duly sworn according to law, deposes and says that he is 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 his knowledge, information, and belief: Bradley F. Maurer, Manager ABWR Licensing Sworn to and subscribed before me this 20th day of March 2013\S1'4c aOjL G5t Notary Public.PZMVtMWEAL~TH OF PENSYVMM I WWc A. SiePMsY, Not"r Pubc ItftT".. kmwow anty~ 2 CAW-13-3668 (1) I am Manager, ABWR Licensing, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse. (2) I am making this Affidavit in conformance with the provisions of 10 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 constitutes Westinghouse policy and provides 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-13-3668 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. 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-13-3668 (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.(iii) 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.(iv) 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.(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP-17549-P, Revision 1, "Monticello Replacement Steam Dryer Structural Evaluation for High-Cycle Acoustic Loads Using ACE" (Proprietary) for submittal to the Commission, being transmitted by Xcel Energy 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 Monticello Replacement Steam Dryer Project, and may be used only for that purpose. 5 CAW-13-3668 This information is part of that which will enable Westinghouse to: (a) Provide the structural evaluation for high-cycle acoustic loads for the Monticello Replacement Steam Dryer to support the NRC review of the Xcel Energy EPU application. Further this information has substantial commercial value as follows: (a) Westinghouse plans to sell the use of the information to its customers for the purpose of the Monticello Replacement Steam Dryer Project.(b) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse. Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information. The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.Further the deponent sayeth not. PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning 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.

• Westinghouse U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Westinghouse Electric Company Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA (412) 374-4419 (724) 720-0857 maurerbf@westinghouse.com LTR-EP- 13-018 Direct tel: Direct fax: e-mail: Proj letter: CAW-13-3667 March 25, 2013 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

WCAP-17716-P, Revision 0, "Benchmarking of the Acoustic Circuit Enhanced Revision 2.0 for the Monticello Steam Dryer Replacement Project" (Proprietary) The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-1 3-3667 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 Xcel Energy.Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference CAW-13-3667, and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.Very truly yours, Bradley F. Maurer, Manager ABWR Licensing Enclosures CAW-13-3667 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA: ss COUNTY OF BUTLER: Before me, the undersigned authority, personally appeared Bradley F. Maurer, who, being by me duly sworn according to law, deposes and says that he is 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 his knowledge, information, and belief: Bradley F. Maurer, Manager ABWR Licensing Sworn to and subscribed before me this 25th day of March 2013 Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Cynthia Olesky, Notary Public Manor Boro, Westmoreland County My Commission Expires July 16, 2014 Member, Association of Nota ies 2 CAW-13-3667 (1) I am Manager, ABWR Licensing, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse. (2) I am making this Affidavit in conformance with the provisions of 10 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) 1 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 constitutes Westinghouse policy and provides 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-13-3667 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. 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-13-3667 (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.(iii) 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.(iv) 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.(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP-1 7716-P, Revision 0, "Benchmarking of the Acoustic Circuit Enhanced Revision 2.0 for the Monticello Steam Dryer Replacement Project" (Proprietary) for submittal to the Commission, being transmitted by Xcel Energy 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 Monticello Replacement Steam Dryer Project, and may be used only for that purpose. 5 CAW-13-3667 This information is part of that which will enable Westinghouse to: (a) Provide information describing the benchmarking of the Acoustic Circuit Enhanced Revision 2.0 methodology for the Monticello RSD to support the NRC review of the Xcel Energy EPU application. Further this information has substantial commercial value as follows: (a) Westinghouse plans to sell the use of the information to its customers for the purpose of replacement steam dryer qualification.(b) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse. Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information. The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.Further the deponent sayeth not. PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning 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. ()Westinghouse U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Westinghouse Electric Company Nuclear Services 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA Directtel: (412) 374-4419 Direct fax: (724) 720-0857 e-mail: maurerbf@westinghouse.com Proj letter: LTR-EP-13-020 CAW-13-3671 March 21, 2013 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

LTR-A&SA-09-32 P-Attachment, Rev. 6, "Limit Curves for Monticello Power Ascension" (Proprietary) The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-13-3671 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 Xcel Energy.Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference CAW-13-3671, and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 428, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.Very truly yours, Bradley F. Maurer, Manager ABWR Licensing Enclosures CAW-13-3671 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA: ss COUNTY OF BUTLER: Before me, the undersigned authority, personally appeared Bradley F. Maurer, who, being by me duly sworn according to law, deposes and says that he is 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 his knowledge, information, and belief: Bradley F. Maurer, Manager ABWR Licensing Sworn to and subscribed before me this 21st day of March 2013 Notu ubi COMMONWEALTH OF PENNSYLVANIA I .NOTARIAL SEAL Renee Giampole, Notary Public lPenn Township. Westmoreland County My Commission Expires September 28, 2013 2 CAW-13-3671 (1) I am Manager, ABWR Licensing, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse. (2) I am making this Affidavit in conformance with the provisions of 10 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) Pursuantto 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 constitutes Westinghouse policy and provides 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-13-3671 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. 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. CAW-13-3671 (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.(iii) 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.(iv) 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.(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in LTR-A&SA-09-32 P-Attachment, Rev. 6, "Limit Curves for Monticello Power Ascension" (Proprietary), for submittal to the Commission, being transmitted by Xcel Energy 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 Monticello Replacement Steam Dryer Project, and may be used only for that purpose.This information is part of that which will enable Westinghouse to: (a) Provide the limit curves for Monticello power ascension to support the NRC review of the Xcel Energy EPU application. 5 CAW-13-3671 V Further this information has substantial commercial value as follows: (a) Westinghouse plans to sell the use of the information to its customers for the purpose of the Monticello Replacement Steam Dryer Project. 1 r.(b) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse. Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information. The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.Further the deponent sayeth not. 7 PROPRIETARY INFORMATION NOTICE L Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC -in connection with requests for generic and/or plant-specific review and approval.In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning 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. L-MT-13-029 ENCLOSURE 9 WESTINGHOUSE LETTER, LTR-A&SA-13-7, NP-ATTACHMENT, REVISION 1 MONTICELLO REPLACEMENT STEAM DRYER RAI RESPONSES FOR ACOUSTIC/STRUCTURAL ANALYSES SET #4 This Enclosure covers the following NRC Requests for Additional Information:

1) MNGP EPU-EMCB-RSD-44(c)

2) MNGP EPU-EMCB-RSD-69

3) MNGP EPU-EMCB-RSD-70

4) MNGP EPU-EMCB-RSD-72(b)

5) MNGP EPU-EMCB-RSD-72(c)

6) MNGP EPU-EMCB-RSD-76

7) MNGP EPU-EMCB-RSD-82

8) MNGP EPU-EMCB-RSD-83

9) MNGP EPU-EMCB-RSD-84 23 pages follow Westinghouse Non-Proprietary Class 3 LTR-A&SA-13-7 NP-Attachment, Revision 1 Monticello Replacement Steam Dryer RAI Responses for Acoustic/Structural Analyses Set 44 March 27, 2013 Westinghouse Electric Company LLC 1000 Westinghouse Drive Cranberry Township, PA 16066 USA© 2013 Westinghouse Electric Company, LLC All Rights Reserved LTR-A&SA-13-7 NP-Attachment Revision I I Monticello Replacement Steam Dryer RAI Responses for Acoustic/Structural Analyses Set #4 MNGP EPU-EMCB-RSD-RAI-44 (c)The licensee is requested to provide the following: (c) Provide the measured dryer strains and accelerations for on-dryer sensors over all frequencies as a function of power.Response LTR-A&SA-13-1 states that the "measured strain and accelerations for on-dryer sensors over all frequencies as a function of power will be provided."[

]a~c a,b Figure RAI-44-1 PSDs for RSD Strain Gauge Channel S01, All Power Levels 2 LTR-A&SA-13-7 NP-Attachment Revision I a,b Figure RAI-44-2 PSDs for RSD Strain Gauge Channel S02, All Power Levels a,b Figure RAI-44-3 PSDs for RSD Strain Gauge Channel S03, All Power Levels 3 LTR-A&SA-13-7 NP-Attachment Revision II a,b Figure RAI-44-4 PSDs for RSD Strain Gauge Channel S04, All Power Levels a,b Figure RAI-44-5 PSDs for RSD Strain Gauge Channel S05, All Power Levels 4 LTR-A&SA-13-7 NP-Attachment Revision I a,b Figure RAI-44-6 PSDs for RSD Strain Gauge Channel S06, All Power Levels a,b Figure RAI-44-7 PSDs for RSD Strain Gauge Channel S07, All Power Levels 5 LTR-A&SA-1 3-7 NP-Attachment Revision I I a,b Figure RAI-44-8 PSDs for RSD Strain Gauge Channel S08, All Power Levels Figure RAI-44-9 PSDs for RSD Strain Gauge Channel S09, All Power Levels a,b 6 LTR-A&SA-13-7 NP-Attachment Revision I I a,b Figure RAI-44-10 PSDs for RSD Strain Gauge Channel SI1, All Power Levels a,b Figure RAI.44-11 PSDs for RSD Strain Gauge Channel SlI, All Power Levels 7 LTR-A&SA-13-7 NP-Attachment Revision II a,b a,b Figure RAI-44-12 PSDs for RSD Strain Gauge Channel S12, All Power Levels Figure RAI-44-13 PSDs for RSD Accelerometer Channel 1, All Power Levels 8 LTR-A&SA-13-7 NP-Attachment Revision II a,b Figure RAI-44-14 PSDs for RSD Accelerometer Channel 2, All Power Levels 9 LTR-A&SA-13-7 NP-Attachment Revision I I MNGP EPU-EMCB-RSD-RAI-69 (a, b, c, d, e)Wavelet Denoising Please provide the following additional information regarding]a, c (a)Response Ia, c a, c (b) Explain further how [Ia, c Response I Je I0 LTR-A&SA-13-7 NP-Attachment Revision I I I r, C (c) Describe if the[Response I a,c[Io (d) Describe the implications of Response a, c[],a (e) Provide simple numerical examples of a, c Response I T. I I1I LTR-A&SA-13-7 NP-Attachment Revision II a, b Figure RAI-69-1 "Bumps" Pure Test Signal and Noisy Test Signal (Top), "Heavy Sine" Pure Test Signal and Noisy Test Signal (Bottom)12 LTR-A&SA-13-7 NP-Attachment Revision I I la,c a, b Figure RAI-69-2 Autocorrelation of Noisy Bumps (Top), Autocorrelation of Noisy Heavy Sine (Bottom)13 LTR-A&SA-13-7 NP-Attachment Revision I I[[a, b Figure RAI-69-3 Detail Coefficients of the Bumps Signal[r.C 14 LTR-A&SA-13-7 NP-Attachment Revision I I a, b Figure RAI-69-4 Detail Coefficients of the Heavy Sine Signal]r~c 15 LTR-A&SA-13-7 NP-Attachment Revision I I a, b Figure RAI-69-5 Bumps Benchmark Signal Denoising (Top), Heavy Sine Signal Denoising (Bottom)16 LTR-A&SA-13-7 NP-Attachment Revision I I MNGP EPU-EMCB-RSD-RAI-70 Recirculation Pump Vane Passing Frequencies (VPF)I I a. c Response I_a.MNGP EPU-EMCB-RSD-RAI-72 (b, c)Hybrid Approach Using ACE and ACM 4.1 In the Executive Summary and Section 3.3 of WCAP-17540-P, it is mentioned that ACM 4.1 is used for 0-60 Hz range and ACE is used for 60-250 Hz range.Please provide the following information: (b) Describe how the resultant worst-case time segments are chosen for dryer stress analysis.(c) Describe the length of the time segments used to compute dryer stresses.Response[17 LTR-A&SA-13-7 NP-Attachment Revision II MNGP EPU-EMCB-RSD-RAI-76 (a, b)Histogram of Strain Cycles Based On-Dryer Strain Gage Measurement a, C (a) Maximum measured strain range at each strain gage location at 98% CLTP.Response[a, b (b)a, c Response[]a~c 18 LTR-A&SA-13-7 NP-Attachment Revision II a, b Figure RAI-76-1 [I a, C MNGP EPU-EMCB-RSD-RAI-82 Impact of Pressure Regulator Setting RPV and Dome Pressure on Dryer Dynamic Loads ca,c Response[1 9 19 LTR-A&SA-13-7 NP-Attachment Revision I1[]a.c MNGP EPU-EMCB-RSD-RAI-83 Scale Model Test (SMT)-Derived Scale Factors Please provide the frequency-dependent and location-dependent SMT-derived scale factors applied to the CLTP data to emulate EPU conditions. Response[, C MNGP EPU-EMCB-RSD-RAI-84 Limit Curves Generation I]a, c Response[]a, 20 LTR-A&SA-13-7 NP-Attachment Revision I I a, b c)ac 1) [ ]aC 2)[]a~c 3)[ ]a~c]a3c Supplemental Information

1) Comparison to Quad Cities 2 Steam Dryer Data[]a~c 21 LTR-A&SA-13-7 NP-Attachment Revision I 2) Evaluation of Impact of Recirculation Pump Vane Passing Frequencies on Steam Dryer[J2 2 22 LTR-A&SA-13-7 NP-Attachment Revision I I 3) Revision to WCAP-17540-P In responses to MNGP EPU-EMCB-RSD-RAI-43 (a), MNGP EPU-EMCB-RSD-RAI-48, and MNGP EPU-EMCB-RSD-RAI-64 (b), it was stated that a revision to WCAP-1 7540-P would be created. With the incorporation of the ACE Revision 2.0 methodology, WCAP-17716-P and WCAP- 17252-P provide supplemental information to WCAP- 17540-P. As a result, WCAP-I 7540-P will not be revised since [23}}