ML13205A085

Enclosure 2 - Westinghouse Electric Co. Letter LTR-A&SA-13-14, NP-Attachment, Revision 0, Responses to the U.S. NRC Request for Additional Information Relative to the Monticello Replacement Steam Dryer Acoustic/Structural Analyses Set #5

ML13205A085
Person / Time
Site:	Monticello
Issue date:	07/12/2013
From:	Westinghouse
To:	Office of Nuclear Reactor Regulation
References
L-MT-13-074, TAC MD990
Download: ML13205A085 (163)

Text

L-MT-13-074 ENCLOSURE 2 WESTINGHOUSE LETTER, LTR-A&SA-13-14, N P-ATTACHMENT (NON-PROPRIETARY)

RESPONSES TO THE U.S. NRC REQUEST FOR ADDITIONAL INFORMATION RELATIVE TO THE MONTICELLO REPLACEMENT STEAM DRYER ACOUSTIC/STRUCTURAL ANALYSES SET #5 This Enclosure covers the following NRC Requests for Additional Information.

1) MNGP EPU-EMCB-RSD-RAI-85

2) MNGP EPU-EMCB-RSD-RAI-86

3) MNGP EPU-EMCB-RSD-RAI-87

4) MNGP EPU-EMCB-RSD-RAI-88

5) MNGP EPU-EMCB-RSD-RAI-89

6) MNGP EPU-EMCB-RSD-RAI-90

7) MNGP EPU-EMCB-RSD-RAI-94

8) MNGP EPU-EMCB-RSD-RAI-95

9) MNGP EPU-EMCB-RSD-RAI-99

10) MNGP EPU-EMCB-RSD-RAI-100

11) MNGP EPU-EMCB-RSD-RAI-101

12) MNGP EPU-EMCB-RSD-RAI-105

13) MNGP EPU-EMCB-RSD-RAI-106

14) MNGP EPU-EMCB-RSD-RAI-107

15) MNGP EPU-EMCB-RSD-RAI-108

16) MNGP EPU-EMCB-RSD-RAI-110

17) MNGP EPU-EMCB-RSD-RAI-111

18) MNGP EPU-EMCB-RSD-RAI-112

19) MNGP EPU-EMCB-RSD-RAI-113

20) MNGP EPU-EMCB-RSD-RAI-114

21) MNGP EPU-EMCB-RSD-RAI-116

22) MNGP EPU-EMCB-RSD-RAI-118 155 pages follow Westinghouse Non-Proprietary Class 3 LTR-A&SA-13-14 NP-Attachment Revision 0 LTR-A&SA-13-14 NP-Attachment Revision 0 Responses to the U.S. NRC Request for Additional Information Relative to the Monticello Replacement Steam Dryer Acoustic/Structural Analyses Set #5 July 12, 2013© 2013 Westinghouse Electric Company LLC All Rights Reserved LTR-A&SA-13-14 NP-Attachment Revision 0 Monticello Replacement Steam Dryer RAI Responses for Acoustic/Structural Analyses Set #5 MNGP EPU-EMCB-RSD-RAI-85 WCAP-17252, Rev. 3 (Acoustic Load Definition)

In WCAP 17252, Rev. 3 report, and in other reports, the licensee indicates that dryer analysis for alternating stresses be based on loads induced by pressures emanating from resonances in the main steam line (MSL) valves. The NRC staff notes that the dryer acoustic and hydrodynamic loads are IC Please update the executive summary of WCAP 17252 (and other documents) accordingly.

Note: This RAI is related to the following three RAIs (EPU-EMCB-RSD-RAI 86 through 89).Response The executive summary of WCAP-1 7252-P will be revised to reflect these comments.MNGP EPU-EMCB-RSD-RAI-86 WCAP-17716P, Rev. 0 (Benchmarking of the steam dryer acoustic/structural methodology)

In section 3.0 of WCAP 17716P, it states the following:

a,c LTR-A&SA-13-14 NP-Attachment Revision 0 a,c For validation of the method used IC Response The plots in Figures RAI-86-1 through RAI-86-5 present the []tc The validation of the methodology on the entire frequency range is presented in WCAP- 17716-P, Revision 0,"Benchmarking of the Acoustic Circuit Enhanced Revision 2. 0 for the Monticello Steam Dryer Replacement Project", as well as in the answer to MNGP EPU-EMCB-RSD-RAI-89.

The pressure transducer data [T,,c Inspections of the pressure transducers performed during the 2013 refueling outage identified

[No moisture intrusion was detected on the strain gauge cabling. It is important to note that essentially all strain gauges were still operable at the end of the cycle. Therefore, there is no basis to call into question the viability of the strain gauge data.3 LTR-A&SA-13-14 NP-Attachment Revision 0-a,b,c Figure RAI-86-1 f f for Pressure Transducers I through 4 4 LTR-A&SA-13-14 NP-Attachment Revision 0 Sa,b,c Figure "-86-2 [f for Pressure Transducers 5 through 8 LTR-A&SA-13-14 NP-Attachment Revision 0-a,b,c Figure RAI-86-3 [f for Pressure Transducers 9 through 12 6 LTR-A&SA-13-14 NP-Attachment Revision 0 7 a,b,c Figure RAI-86-4 [f for Pressure Transducers 13 through 16 7 LTR-A&SA-13-14 NP-Attachment Revision 0-a,b,c Figure RAI-86-5 [20 (pressure transducer number 19[A comparison of the measured pressure data [f for Pressure Transducers 17, 18, and D PCo 8 LTR-A&SA-13-14 NP-Attachment Revision 0 a,b,c Figure RAI-86-6 [f MNGP EPU-EMCB-RSD-RAI-87 In WCAP-17716P, Rev. 0, it is also stated that: I Ia,c 9 LTR-A&SA-13-14 NP-Attachment Revision 0 The review of Figure 6-2 and Table 6-1 [IC Response In order to address the qualification of the [TI ACE Revision 2.0. We believe that this approach is sound for the following reasons:[_.o 10 LTR-A&SA-13-14 NP-Attachment Revision 0 The comparison of the [7 a,b,c Figure RAI-87-1 [through 25 using[fC for Pressure Transducers 22 TIC I T, C II LTR-A&SA-13-14 NP-Attachment Revision 0 12 LTR-A&SA-13-14 NP-Attachment Revision 0 Table RAI-87-1 -[]a,c I+- 4 4 4 4 la,b,c The biases and uncertainties listed in Table RAI-87-1 indicate that the predicted acoustic pressure using [f replacement steam dryer at EPU conditions.

For the application of the []T,c Table RAI-87-2 -Ia,c]a,b,c The load definition at EPU conditions for the Monticello RSD is then developed using I]a,c Therefore, the load definition is processed through the structural model to evaluate the minimum stress ratio obtained on the dryer skirt.A comparison with additional pressure transducer data from [.rfc is provided in Figures RAI-87-2 through RAI-87-7.

Note that these figures, as well as those presented in WCAP-17716-P, correspond to frequency based comparisons, i.e., power spectral densities.

13 LTR-A&SA-13-14 NP-Attachment Revision 0 f,c a,b,c Figure RAI-87-2 J 14 LTR-A&SA-13-14 NP-Attachment Revision 0 Ja~c a,b,c Figure RAI-87-3 [15 LTR-A&SA-13-14 NP-Attachment Revision 0 a,b,c]",C Figure RAI-87-4 [16 LTR-A&SA-13-14 NP-Attachment Revision 0 a,b,c f~c Figure RAI-8 7-5 [17 LTR-A&SA-13-14 NP-Attachment Revision 0 a,b,c Figure RAI-87-6 [fJo 18 LTR-A&SA-13-14 NP-Attachment Revision 0 a,b,c Figure RAI-8 7-7 [""IC MNGP EPU-EMCB-RSD-RAI-88 According to Table 4-1 in WCAP-17716P, the licensee has assumed that the ac The licensee is requested to: (1) Explain (a) how the dipoles with]ax to extended power uprate (EPU) conditions and applied to the dryer.(2) Provide specific CLTP to EPU [ ]ax MSL dipole source.19 LTR-A&SA-13-14 NP-Attachment Revision 0 Response (1.a) The calculation of the three-dimensional acoustic field inside the steam dome is[TI,c (1.b) The low frequency pressure loading is []c as described in WCAP-17251-P, Section 5.6.(2) As discussed in 1.b, [, b,c 20 LTR-A&SA-13-14 NP-Attachment Revision 0 MNGP EPU-EMCB-RSD-RAI-89 (Follow-up to MNGP EPU-EMCB-RSD-RAI-43)

The strain gage measurements presented in WCAP 17716, Rev. 0, indicate that outer dryer strain gage signals Ia,c The licensee is requested to: (1) Explain the nature of the [mode shapes, particularly of the skirt.]C, and provide plots of (2) Provide updated bias errors and uncertainties (B&Us) to ensure ACE 2.0 IC (3) Label the plots with power levels, provide the max/min and root mean square (RMS)pressures for each sensor as originally requested, and expand their trending analyses to each sensor.Response (1) Structural Input The mode shapes below 50 Hz for the dryer skirt are shown in the following figures.There are 24 modes below 50 Hz. This RAI is concemed with a [1ac Note that there are [ ]81C The mode shape plots are normalized to the mass matrix. The actual values displayed in the mode shape plot legend represent relative displacement of the structure for a given natural frequency.

The natural frequency of the structural can be thought of like a material property; it is innate to the structure and not a response to a given load.However, these mode shape legend values are not intended to predict relative displacement due to an applied harmonic pressure load over the dryer. The dryer will respond to pressure loads at frequencies other than its natural frequencies.

The structural response is a function of how close the loading frequency is to the natural frequency.

This is known as a magnification factor and is a function of wiwn and the damping, where w is the applied loading frequency and wn is the natural frequency.

21 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-89-1 Monticello Steam Dr'er Skirt Natural Frequencies

[laC[To 22 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-89-2 Monticello Steam Dryer Skirt Mode: [fJC 23 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-89-3 Monticello Steam Dryer Skirt Mode: [fC 24 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-89-4 Monticello Steam Dryer Skirt Mode:f ft 25 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-89-5 Monticello Steam Dryer Skirt Mode: J fJa 26 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-89-6 Monticello Steam Drer Skirt Mode: f Jc 27 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI 7 Monticello Steam Dqer Skirt Mode: [PC 28 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-89-8 Monticello Steam Dryer Skirt Mode: [FJo 29 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-89-9 Monticello Steam Dryer Skirt Mode: [tc 30 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-89-10 Monticello Steam Dyer Skirt Mode: f fJo 31 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-89-11 Monticello Steam Dr.er Skirt Mode: [fIc 32 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-89-12 Monticello Steam Dryer Skirt Mode: [fJc 33 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-89-13 Monticello Steam Dryer Skirt Mode: [fP 34 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-89-14 Monticello Steam Drver Skirt Mode: J fIc 35 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-89-15 Monticello Steam Drver Skirt Mode: [fto 36 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-89-16 Monticello Steam Dryer Skirt Mode: [TIC 37 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-89-17 Monticello Steam Drver Skirt Mode: [fJa 38 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-89-18 Monticello Steam Drer Skirt Mode: I fPo 39 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-89-19 Monticello Steam Dryer Skirt Mode: [JU 40 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-89-20 Monticello Steam Dqer Skirt Mode: [PC 41 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-89-21 Monticello Steam Dryer Skirt Mode: [Jc 42 LTR-A&SA-13-14 NP-Attachmnent Revision 0 b Figure RAI-89-22 Monticello Steam Dryer Skirt Mode: [fJc 43 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-89-23 Monticello Steam Dryer Skirt Mode: [PC 44 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-89-24 Monticello Steam Dryer Skirt Mode: [Ja 45 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-89-25 Monticello Steam Dryer Skirt Mode: [fIU 46 LTR-A&SA-13-14 NP-Attachment Revision 0 (2) The biases and uncertainties computed for ACE Revision 2.0 [(3) The plots in Figures 5-1 through 5-12 in WCAP-17716, Revision 0, contain the []afc 47 LTR-A&SA-13-14 NP-Attachment Revision 0 Table RAI-89-1 -Measured/Predicted Strain Levels [I C 48 LTR-A&SA-13-14 NP-Attachment Revision 0 Table RAI-89-2 -Measured/Predicted Strain Levels [ C 49 LTR-A&SA-13-14 NP-Attachment Revision 0 The trending from [a,b,c Figure RAI-89-26 Predicted and Measured Max/Min Strain Levels [fc 50 LTR-A&SA-13-14 NP-Attachment Revision 0 a,b,c Figure RAI-89-2 7 Predicted and Measured Max/Min Strain Levels [,oc MNGP EPU-EMCB-RSD-RAI-90 WCAP-1 7251, Rev. 1 (Subscale Testing)During the subscale model testing (SMT) described in WCAP-17251, Rev. 1, the pressure signal was recorded for one second starting from a tank pressure of 190 psig. Figure 5-1 of this report indicates that the tank pressure during this measurement period decreases from 190 psig to approximately 130 psig. The resulting decrease in the fluid density at the standpipes of the safety relief valves (SRVs) is expected to reduce the flow energy (i.e. the dynamic head)exciting the SRV resonance.

Please explain how this effect is accounted for in normalizing the pressure spectra obtained over the one second period of measurement.

51 LTR-A&SA-13-14 NP-Attachment Revision 0 Response[]e,c 52 LTR-A&SA-13-14 NP-Attachment Revision 0 MNGP EPU-EMCB-RSD-RAI-94 (Follow-up to MNGP EPU-EMCB-RSD-RAI-42)(a) The licensee's explanation provided in the response to RAI-42 related to the interpolation algorithm is not clear, and the NRC staff does not understand Figure 42-1 and its accompanying description.

This figure appears to be the same as Fig. 9 -1 of the BWRVIP194 report. The figure in BWRVIP194 illustrates the mapping of pressure difference rather than the pressures at both sides of the dryer. The mesh size was also much coarser than those used at Monticello.

The licensee is requested to update Figure 42-1 and provide simple step-by-step calculations for a structural point to better explain how the pressures in the rectangular acoustic grid are mapped onto a generally oriented structural finite element (FE) model surface.(b) The licensee also stated in the response to RAI-42 that actual structural modal testing showed that the structural FE model for the steam dryer simulates natural frequencies within 7.4% of actual modal data for the dryer structure above the support ring.Please submit documentation of this testing and the comparison to the FE model, for both the upper and lower portions of the dryer.Response Overview of the Westinghouse methodology utilizing[

Ia,C The unit acoustic load solutions descrfibed and further illustrated in Figures 3-3 through 3-6 of WCAP- 17540-P are output to pressure data files. []a.c 53 LTR-A&SA-13-14 NP-Attachment Revision 0 Creating the table array files from the acoustic solution output: The Westinghouse methodology includes a special purpose code that [54 LTR-A&SA-13-14 NP-Attachment Revision 0 55 LTR-A&SA-13-14 NP-Attachment Revision 0[, 56 LTR-A&SA-13-14 NP-Attachment Revision 0* I Jr.A sample plot of the NRF of the [Figure RAI-94-1 J To a,c Jc 57 LTR-A&SA-13-14 NP-Attaclmuent Revision 0 a,c Figure RAI-94-2 [58 LTR-A&SA-13-14 NP-Attachment Revision 0 ac Figure RAI-94-3 [I aC 59 LTR-A&SA-13-14 NP-Attachment Revision 0 Figure RAI-94-4 View from Table Arrav file at Node 10814 Location a,c 60 LTR-A&SA-13-14 NP-Attachment Revision 0 fo al~c Table RAI-94-1 [61 LTR-A&SA-13-14 NP-Attachment Revision 0 a,c"i~e Table RAI-94-2 [62 LTR-A&SA-13-14 NP-Attachment Revision 0 a,c Figure RAI-94-5 [TIC MNGP EPU-EMCB-RSD-RAI-95 (Follow-up to MNGP EPU-EMCB-RSD-RAI-44)

In response to RAI-44, MNGP provided plots of the mode shape of a single resonance at 48.1 Hertz (Hz), stating that dryer strain gages are well positioned to measure the response of that mode. The plots (Figures 44-2 & 44-3) are hard to interpret and it is not clear exactly where the gages are located with respect to the mode shape. In particular, the response did not provide the requested information about the dryer response near 18 Hz, in relation to the locations of the gages. Also, other modes likely contributed to dryer alternating stresses, as evidenced by on-dryer strain and acceleration spectra provided in MNGP's response to RAI-44 (c). The licensee is requested to: (a) Provide additional plots of dryer mode shapes which respond strongly under operational loading, and more clearly designate the strain gage and accelerometer locations on the mode shape plots. In particular, the NRC staff is interested in understanding the dominant structural modes for frequencies below 100 Hz.(b) The licensee is requested to: (i) Identify which peak(s) in the strain spectra are associated with the Target Rock safety relief valve (SRV) flow-excited acoustic resonance, and with the recirculation pump tones.63 LTR-A&SA-13-14 NP-Attachment Revision 0 (ii) Provide plant power conditions at which the Target Rock SRV and recirculation pump tones are the strongest?(c) Label the strain gage and accelerometer spectra with their plant power levels (d) Provide a steam dryer sketch(s) identifying the locations of all instruments so that the NRC staff can see the location of the strain gages relative to the pressure sensors. This information is needed to evaluate the changes in the measured pressures and strains as a function of power.Response Figure RAI-95a-1 shows the strain gauge locations on the outer hood in relation to the fundamental mode shape of the [ _r,c The "MX" symbol in Figure RAI-95a-1 represents the location of highest displacement for this mode. The [].,c are all located near high displacement locations with respect to the mode shape.I T, c (a) Additional mode shapes for the skirt were supplied in MNGP EPU-EMCB-RSD-RAI-89.

In addition to the plots shown in response to MNGP EPU-EMCB-RSD-RAI-89, the fundamental modes of the hoods occur at 47.8 Hz for the outer hood, 48.8 Hz for the middle hood and 61.0 Hz for the inner hood. These modes are shown in Figures RAI-95a-4 through RAI-95a-6.

The benchmarking of the ACE Revision 2.0 model was based on purely on[Tc 64 LTR-A&SA-13-14 NP-Attachment Revision 0 Figure RAI-95a-1 Monticello Strain Gauge Locations with Respect to Fundamental Hood Panel Mode/ b 65 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-95a-2 Harmonic Analysis with [J1C Applied to Dryer and Skirt: Skirt Displacement, inches 66 LTR-A&SA-13-14 NP-Attachment Revision 0 Figure RAI-95a-3 Harmonic Analysis with [ f,c Applied to Dryer and Skirt: Outer Hood Displacement, inches b 67 LTR-A&SA-13-14 NP-Attactunent Revision 0 Figure RAI-95a-4 Outer Hood Fundamental Mode: [ pLc b 68 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-95a-5 Middle Hood Fundamental Mode: [TIc 69 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-95a-6 Inner Hood Fundamental Mode: [fJo 70 LTR-A&SA-13-14 NP-Attachment Revision 0 (b) The replacement steam dryer strain gauge data spectra are shown in part C of this RAI.As indicated in WCAP-17548-P, Revision 1, the natural frequency[

[?.fb These values are calculated based on shaft speed, which was recorded at each power level during data collection.

Table RAI-95b-1 Monticello Pump Tones by Power Level b[PCo 71 LTR-A&SA-13-14 NP-Attachment Revision 0 (c) The measured [.r~c 72 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-95c-1 PSDsfor[Ic 73 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-95c-2 PSDsfor [fr 74 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-95c-3 PSDsfor[tc 75 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-95c-4 PSDs for [Jc 76 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-95c-5 PSDsfor [fJo 77 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-95c-6 PSDsfor [tc 78 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-95c-7 PSDsfor[Jo 79 LTR-A&SA-13-14 NP-Aftachment Revision 0 b Figure RAI-95c-8 PSDs for [rf 80 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-95c-9 PSDsfor [fPc 81 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-95c-10 PSDsfor[f.c 82 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-95c-11 PSDs for [TIC 83 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-95c-12 PSDsfor[f[c 84 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-95c-13 PSDsfor [f[c 85 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-95c-14 PSDsfor [f.c 86 LTR-A&SA-13-14 NP-Attachment Revision 0 (d) Figure RAI-95d-1 shows a plane view of the Monticello replacement steam dryer (RSD).The []atc Figure RAI-95d-J Plane View of Monticello RSD Instrumentation b 87 LTR-A&SA-13-14 NP-Attachment Revision 0 The [J.C placement on the [Figure RAI-95d-2

[]ZC is shown in Figure RAI-95d-2.

Jf" RSD Instrumentation b 88 LTR-A&SA-13-14 NP-Attachment Revision 0 Thel f placement on the [f'c is shown in Figure RAI-95d-3.

f.C RSD Instrumentation b Figure RAI-95d-3

[89 LTR-A&SA-13-14 NP-Attachment Revision 0 The []a,c placement on the [Figure RAI-95d-4

[-c is shown in Figure RAI-95d-4.

f"C RSD Instrumentation b 90 LTR-A&SA-13-14 NP-Attachment Revision 0],c is shown in Figure RAI-95d-5.

[The [r'c placement on the [b Figure RAI-95d-5

[f" RSD Instrumentation 91 LTR-A&SA-13-14 NP-Attachment Revision 0 The [.,c placement on the []'.c is shown in Figure RAI-95d-6.

[rc b Figure RAI-95d-6

[f1 RSD Instrumentation 92 LTR-A&SA-13-14 NP-Attachment Revision 0 The [Tc placement on the [TIC f-0 is shown in Figure RAI-95d-7.

[]Oc RSD Instrumentation b Figure RAI-95d- 7 [93 LTR-A&SA-13-14 NP-Attachment Revision 0 MNGP EPU-EMCB-RSD-RAI-99 (Follow-up to MNGP EPU-EMCB-RSD-RAI-54)

As noted in the response to RAI-54, it appears to be reasonable that the failure of noncritical and nonstructural fillet welds will not generate loose parts.Please confirm that the structural welds and components supporting the fillet-welded components of the RSD are strong enough to support the RSD and not generate loose parts, with completely failed fillet welds.Response The table from the response to RAI-54 has been modified and bolded text has been included to address the additional information requested in RAI-99.7 ac 94 LTR-A&SA-13-14 NP-Attachment Revision 0 a,c 95 LTR-A&SA-13-14 NP-Attachment Revision 0 7 ac 96 LTR-A&SA-13-14 NP-Attachment Revision 0 lax 97 LTR-A&SA-13-14 NP-Attachment Revision 0 MNGP EPU-EMCB-RSD-RAI-100 (Follow up to MNGP EPU-EMCB-RSD-RAI-59)

Please provide comparisons of measured and simulated dryer modal frequencies and mode shapes for frequencies up to 250 Hz to show if the +/-10% frequency shifting utilized in the stress analyses is adequate to bound the resonance frequency uncertainty in the FE model.Address the impact on the dryer stress results, of any deviations in frequencies higher than+/- 10%.Also, provide documentation comparing measured and simulated resonance frequencies and mode shapes for selected frequencies up to 250 Hz, along with representative Frequency Response Function (FRF) comparisons for critical regions of the steam dryer.Response]aTc 98 LTR-A&SA-13-14 NP-Attachment Revision 0 Table RAI-] 00-1 Table RAI-100-2 a,c a,c MNGP EPU-EMCB-RSD-RAI-101 (Follow-up to MNGP EPU-EMCB-RSD-RAI-55)

In response to RAI-55, the licensee noted the following,"Westinghouse engineers compared the fabrication drawings prepared by Toshiba to the engineering design drawings.

A further surveillance was conducted after fabrication which compared the fabrication drawings to the as-built drawings of the steam dryer. Any deviations were resolved with the full involvement of Westinghouse engineering." 99 LTR-A&SA-13-14 NP-Attachment Revision 0 Please provide a concise summary of any deviations and the associated resolutions that were found (a) between fabrication drawings and design drawings, and (b) between fabrication drawings and as-built drawings.Response (a) Westinghouse review found no documented deviations between the issued fabrication drawings and the design drawings upon which they were based.(b)[ e,c Iac 100 LTR-A&SA-13-14 NP-Attachment Revision 0 a,c MNGP EPU-EMCB-RSD-RAI-105 (Follow-up to MNGP EPU-EMCB-RSD-RAI-69(e))

The de-noising examples presented in response to RAI-69(e) do not provide sufficient information to confirm that the signals associated with actual dryer loading are not being removed from the MNGP main steam line (MSL) and on-dryer spectra.Please provide frequency spectra of the clean, noisy, and de-noised signals described in the response to RAI-69 (e). Note that longer versions of the signals (longer time records) may be necessary to obtain frequency spectra consistent with those analyzed at the MNGP.Response A new, periodic, test signal was generated to illustrate the effect of[T.b'c Figure RAI-105-1 shows the uncorrupted and corrupted signals in the time domain for a small subset of time, while Figure RA1-105-2 shows the uncorrupted and corrupted signals in the frequency domain from 0-250 Hz. []a,c 101 LTR-A&SA-13-14 NP-Attachment Revision 0 Figure RAI-105-1:

Uncorrupted and Corrupted Test Signals, Time Domain Figure RAI-105-1:

Uncorrupted and Corrupted Test Signals, Frequency Domain 0-250 Hz 102 LTR-A&SA-13-14 NP-Attachment Revision 0[P. bc b Figure RAI-105-3:

[TIC],c Figure RA/-105-5 shows the power spectral density (PSD) of the uncorrupted test signal, corrupted signal, and denoised signal from 0-250 Hz.103 LTR-A&SA-13-14 NP-Attachment Revision 0 Figure RAI-105-4:

Test Signal Denoising, Time Domain Figure RAI-105-5:

PSDs of Test Signal Denoising, 0-250 Hz 104 LTR-A&SA-13-14 NP-Attachment Revision 0 Figure RAI-105-6 shows a close up of the 3 PSDs, [b Figure RAI-105-6:

Zoomed PSDs of Test Signal Denoising, 0-250 Hz MNGP EPU-EMCB-RSD-RAI-106 (Follow-up to MNGP EPU-EMCB-RSD-RAI-71)

In response to RAI-71, sample spectra of the signal attenuation were provided.

The bandwidth of the narrow-band filter used to remove extraneous spectral peaks seems rather excessively wide and possibly resulted in excessive reduction in the strain gage signals.(c) Please provide the characteristics of this narrow-band filter and explain why its bandwidth cannot be reduced to avoid unrealistic attenuation in the strain gage signals.(d) Also, explain whether the notch-filtered frequency band is re-filled to maintain the level of the broadband excitation.

105 LTR-A&SA-13-14 NP-Attachment Revision 0 Response (a) []a-c as indicated in Table 5-5 of WCAP-17548-P, Revision 1, "Signal Processing Performed on Monticello MSL Strain Gauge and RSD Instrumentation Data.".ab,c Figure RAI-106-1 through Figure RAI-106-4 compares the raw unfiltered data, EIC data, and notch-filtered data, and []'c These figures are included in WCAP- 17716-P, Revision 0, "Benchmarking of the Acoustic Circuit Enhanced Revision 2.0 for the Monticello Steam Dryer Replacement Project." b Figure RAI-106-1 Raw and Filtered Data Comparison, MSL A 106 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-106-2 Raw and Filtered Data Comparison, MSL B 107 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-]106-3 Raw and Filtered Data Comparison, MSL C 108 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-106-4 Raw and Filtered Data Comparison, MSL D (b) [fc This is described in WCAP- 17548-P, Revision I and WCAP- 17716-P, Revision 0.[]a,c This is shown in Figure RAI-106-5.

[pb,c 109 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-106-5 MSL Data Notch-Filter Comparisons MNGP EPU-EMCB-RSD-RAI-107 (Follow-up to MNGP EPU-EMCB-RSD-RAI-76)(a) Please provide the maximum alternating stress intensity and its location based on the measured strains at CLTP. Describe how this location compares with the location based on the predicted stress analysis at CLTP.(b) Provide a histogram of the measured strains with the y-axis spanning from 0.0 to 1010 cycles with an increment of 109 cycles.Response (a) Based on the direct steam dryer strain gauge instrumentation data at 100% CL TP, the maximum strain is [110 LTR-A&SA-1 3-14 NP-Attachment Revision 0[.F,c (b) Please see the following Figure RA1- 107-1.ac Figure RAI-107-1 Projected Rain Flow Cycle Counts (40 Years)MNGP EPU-EMCB-RSD-RAI-108 (Follow-up to MNGP EPU-EMCB-RSD-RAI-78)

In RAI-78, the NRC requested that the licensee provide the FE mesh convergence error with respect to the displacement and stresses in the dryer obtained from the dynamic analysis of the RSD. In response, the licensee referred to Rev. 1 of WCAP-17549-P for the results of a mesh density study for a FE model representing a typical portion of the RSD. The results showed that the finest mesh density (4 times smaller) caused stresses [ ]a,c than that used in the final dryer analysis.(a) Please provide stresses as a function of mesh size and trend them to a very small mesh size (e.g. mesh size approaching 0.0). Provide the resulting convergence error when extrapolated to a mesh size of 0.0.(b) Explain how this convergence error is accounted for in estimating the dryer fatigue stresses at EPU conditions.

Response[III LTR-A&SA-13-14 NP-Attachment Revision 0 (a) [fao Table 108-1 [JOa a,c (b) [To MNGP EPU-EMCB-RSD-RAI-1 10 (Follow-up to MNGP EPU-EMCB-RSD-RAI-84)

Please provide the revised MSL limit curves which are based only on CLTP MSL spectra and CLTP minimum alternating stress ratios.Response: I JC 112 LTR-A&SA-13-14 NP-Attachment Revision 0[Pc Figure RAI-110-1:

Monticello Limit Curves, MSL A Figure RAI-1 0-2: Monticello Limit Curves, MSL B 113 LTR-A&SA-13-14 NP-Attachment Revision 0 b Figure RAI-113-4:

Monticello Limit Curves, MSL C b Figure RA4I-1JO-4:

Monticello Limit Curves, MSL D MNGP EPU-EMCB-RSD-RAI-1 11 Based on a review of WCAP-17252-P, Rev. 3, the NRC staff requests the following additional information: (a) Please provide a breakdown of the monopole and dipole contributions to Figures 4-1 to 4-4.(b) Include plots comparing EPU and CLTP pressure spectra.114 LTR-A&SA-13-14 NP-Attachment Revision 0 (c) Provide the CLTP source.]a,c monopole and dipole Response (a) The [ f, presented in Figure 4-1 through 4-4 in WCAP- 1 7252-P, Revision 3, Acoustic Loads Definition for the Monticello Steam Dryer Replacement Project, have been decomposed in their monopole and dipole components.

The [ f' are compared in Figures RAI-1 11-1 through RAI-111-4.

These plots will be included in Revision 4 of WCAP-17252-P.(b) The plots comparing the loads at CLTP and EPU conditions presented in Figures 4-1 through 4-4 of WCAP- 17252-P Revision 3 are provided in Figures RAI- 111-5 through RAP-111-8.

These plots will be included in Revision 4 of WCAP-17252-P.(c) See response to RAI-88 (2).Figure RAI-111-1 Comparison Monopole and Dipole Components of the [f a,b,c 115 LTR-A&SA-13-14 NP-Attachment Revision 0 Figure RAI-111-2 Comparison Monopole and Dipole Components of the[f a,b,c 116 LTR-A&SA-13-14 NP-Attachment Revision 0 Figure RAI-111-3 Comparison Monopole and Dipole Components of the[f a,b,c 117 LTR-A&SA-13-14 NP-Attachment Revision 0 Figure RAI-111-4 Comparison Monopole and Dipole Components of the [f a,b,c 118 LTR-A&SA-13-14 NP-Attachment Revision 0-a,b,c Figure RAI-111-5

[f 119 LTR-A&SA-13-14 NP-Attachment Revision 0 a,b,c Figure RAI-111-6

[f 120 LTR-A&SA-13-14 NP-Attachment Revision 0-7 a.b.c Figure RAI-111- 7 [f 121 LTR-A&SA-13-14 NP-Attachment Revision 0 a,b,c Figure RAI-111-8

[I MNGP EPU-EMCB-RSD-RAI-1 12 In Section 2.1 of WCAP-17252-P, Rev 3, the licensee described the acoustic model as follows, I]aC Please provide examples of the of the simulated dryer load.]a does not challenge the conservatism Response The three-dimensional acoustic model of steam volume defined by the steam dryer structure and the reactor pressure vessel is generated using a high-quality mesh generator with [ _r mesh spacing. The geometry of the [122 LTR-A&SA-13-14 NP-Attachment Revision 0 MNGP EPU-EMCB-RSD-RAI-1 13 Figure 5-2 in WCAP-17251-P, Rev. 1 shows the filtered signal of a pressure transducer during the blow-down transient tests on the 1/6 th subscale model.Please provide additional typical examples of pressure versus time plots for the other transducers and indicate the one second period of time measurements on these plots.Response: Figure RAI 113-1 through Figure RAI 113-8 show signal from the pressure transducers located on four subscale MSLs.]ab a,b Figure RAI-113(1)-I Raw and Filtered Dynamic Pressure Data, MSL A US 123 LTR-A&SA-13-14 NP-Attachment Revision 0 a,b Figure RAI-113(1)-2 Raw and Filtered Dynamic Pressure Data, MSL A, MSL A DS Figure RAI-113(1)-3 Raw and Filtered Dynamic Pressure Data, MSL B US a,b 124 LTR-A&SA-13-14 NP-Attachment Revision 0 a,b Figure RAI-113(1)-4 Raw and Filtered Dynamic Pressure Data, MSL B DS ab Figure RAI-113(1)-5 Raw and Filtered Dynamic Pressure Data, MSL C US 125 LTR-A&SA-13-14 NP-Attachment Revision 0 a,b Figure RAI-113(1)-6 Raw and Filtered Dynamic Pressure Data, MSL C DS a,b Figure RAI-113(1)-7 Raw and Filtered Dynamic Pressure Data, MSL D US 126 LTR-A&SA-13-14 NP-Attachment Revision 0 a,b Figure RAI-113(1)-8 Raw and Filtered Dynamic Pressure Data, MSL D DS The NRC questioned the amplitude of pressure values that occurred after the I second of data taken. An analysis of this additional data is provided in RAI 113-2.MNGP EPU-EMCB-RSD-RAI-113 (2)The NRC staff raised a question on why does the signal increases with time in subscale test data. Provide static pressure as a function of time, and a relation with static pressure and Mach number.Response:[T.127 LTR-A&SA-13-14 NP-Attachment Revision 0 a,b Figure RAI-113(2)-1 Raw and Filtered Depressurization Curve[T, c I ,rc 128 LTR-A&SA-13-14 NP-Attachment Revision 0 a,b Figure RAJ-113(2)-2 Djynamic Pressure PSD, MSL A US 129 LTR-A&SA-13-14 NP-Attachment Revision 0 a,b Figure RAI-113(2)-3 Dynamic Pressure PSD, MSL A DS a,b Figure RAI-113(2)-4 Dynamic Pressure PSD, MSL B US 130 LTR-A&SA-13-14 NP-Attachment Revision 0 a,b Figure RAI-113(2)-5 Dynamic Pressure PSD, MSL B DS a,b Figure RAI-113(2)-6 Dynamic Pressure PSD, MSL C US 131 LTR-A&SA-13-14 NP-Attachment Revision 0 a,b Figure RAI-113(2)-7 Dvnamic Pressure PSD, MSL C DS a,b Figure RAI-113(2)-8 Dynamic Pressure PSD, MSL D US 132 LTR-A&SA-13-14 NP-Attachment Revision 0 a,b Figure RAI-113(2)-9 Dynamic Pressure PSD, MSL D DS MNGP EPU-EMCB-RSD-RAI-1 14 In Section 4 of WCAP-17716-P, the licensee notes that,[However, there are only ac (a) Please list all unknown parameters to be determined for the monopoles and dipoles located at the MSL inlets. Provide the strength, phase and direction associated with each dipole.(b) Explain the number of equations to be used to determine these unknowns.(c) Define and substantiate the assumptions made (e.g. equal dipole strength and angle of 120 degrees).(d) Explain the parameters to be determined from the system of equations and clarify which strain gages are used to determine these parameters.

Response I 133 LTR-A&SA-13-14 NP-Attachment Revision 0 (a) The quantities to be determined by the acoustic model are: [(b) A complete explanation of this process is provided in Section 4 of WCAP- 17716-P, Revision 0, "Benchmarking of the Acoustic Circuit Enhanced Revision 2.0 for the Monticello Steam Dryer Replacement Project".(c) There are no assumptions in the definitions of the [T (d) Response provided in RAI-114 (b).MNGP EPU-EMCB-RSD-RAI-1 16 Based on a review of WCAP-17549-P, Rev. 1, the NRC staff requests the following additional information: (a) Please provide three limiting locations on the dryer, above and below the support ring and (i)provide the corresponding alternating stress ratios, (ii) spectra, and (iii) cumulative stress, as a function of frequency.(b) Also, provide plots of mode shapes with strong peaks in the stress spectra.Response (a) [o.I a..134 LTR-A&SA-1 3-14 NP-Attachment Revision 0 r8,c (b) [].rc I., 135 LTR-A&SA-13-14 NP-Attachment Revision 0 axc Figure RAI-116-1 Locations of Points 1 and 2 on Outer Hood 136 LTR-A&SA-13-14 NP-Attachment Revision 0 Figure RAI-116-2 Location of Point 3 on Drain Channel a,c 137 LTR-A&SA-13-14 NP-Attachment Revision 0 Figure RAI-116-3 ANSYS Stress Result at Point 1 a,c 138 LTR-A&SA-13-14 NP-Attachment Revision 0 Figure RAI-116-4 ANSYS Stress Result at Point 2 a,c 139 LTR-A&SA-13-14 NP-Attachment Revision 0 Figure RAI-116-5 ANSYS Stress Result at Point 3 a,c 140 LTR-A&SA-13-14 NP-Attachment Revision 0 Figure RAI-116-6 PSD and Cumulative Stress Plot for Point 1 a,c 141 LTR-A&SA-13-14 NP-Attachment Revision 0 Figure RA"-116-7 PSD and Cumulative Stress Plot for Point 2 axc 142 LTR-A&SA-13-14 NP-Attachnment Revision 0 Figure RAI-116-8 PSD and Cumulative Stress Plot for Point 3 a,c 143 LTR-A&SA-13-14 NP-Attachment Revision 0 axc Figure RAI-116-9 Mode Shape at [fIc 144 LTR-A&SA-13-14 NP-Attachment Revision 0 a,c Figure RAI-116-10 Mode Shape at [TIC 145 LTR-A&SA-13-14 NP-Attachrment Revision 0 a,c Figure RAJ-116-11 Mode Shape at [f~c 146 LTR-A&SA-13-14 NP-Attachment Revision 0 a,c Figure RAI-116-12 Mode Shape at [fJa 147 LTR-A&SA-13-14 NP-Attachment Revision 0 a,c Figure RAI-11 6-13 Mode Shape at [Jao 148 LTR-A&SA-13-14 NP-Attachment Revision 0 a,c Figure RAI-116-14 Mode Shape at [TIC 149 LTR-A&SA-13-14 NP-Attachment Revision 0 a,c Figure RAI-116-15 Mode Shape at [Jal 150 LTR-A&SA-13-14 NP-Attachment Revision 0 a,c Figure RAI-116-16 Mode Shape at[TIC 151 LTR-A&SA-13-14 NP-Attachment Revision 0 a,c K Figure RAI-116-17 Mode Shape at [fJa 152 LTR-A&SA-13-14 NP-Attachment Revision 0 a,c Figure RAI-116-18 Mode Shape at [flo 153 LTR-A&SA-13-14 NP-Attachment Revision 0 a,c Figure RAI-116-19 Mode Shape at [fJo 154 LTR-A&SA-13-14 NP-Attachment Revision 0 MNGP EPU-EMCB-RSD-RAI-1 18 Section 8.2 of WCAP-1 7549-P, Rev. 1 discusses the application of [Ia~c Response The submodel documented in 8.2.1 is the [_r.C The results of these investigations will be summarized in Revision 2 of WCAP- 17549-P.(d) See the following responses.

i. Confirmed.

ii. As stated in Section 8.1 of WCAP-I 7549-P, Rev. 1, [].,c Revision 2 of WCAP- 17549 will include clarifying text related to this item and the columns in Tables 8-1 and 8-2 will be defined in more detail.A figure will be added to Rev. 2 of WCAP- 17549-P to show[]eac ANSYS and any and all ANSYS, Inc. brand, product, service and feature names, logos and slogans are registered trademarks or trademarks of ANSYS, Inc. or its subsidiaries in the United States or other countries All other brand, product, service and feature names or trademarks are the property of their respective owners.155 L-MT-13-074 ENCLOSURE 3 WESTINGHOUSE AFFIDAVIT FOR WITHHOLDING PROPRIETARY INFORMATION 6 pages follow CAW-13-3762 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF BUTLER: Before me, the undersigned authority, personally appeared James A. Gresham, 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:ýjms A. Gresham, Manager Regulatory Compliance Sworn to and subscribed before me this 16th day of July 2013 Ap4..6 UA&0, Notary Public COMMONWEALTH OF PENNSYLVANIA Noailseal Unft Twp., wemwefand Courty My Cm plMo Bca Aug. 7, 2016 MENSR PENNSYLVANIA ASSOCIATION OF NOTARIES 2 CAW-13-3762 (1) 1 am Manager, Regulatory Compliance, in Engineering, Equipment and Major Projects, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from 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) 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-13-3762 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 4 CAW-13-3762 (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) Tile 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-13-14 P-Attachment, "Responses to the U.S. NRC Request for Additional Information Relative to the Monticello Replacement Steam Dryer Acoustic/Structural Analyses Set #5" (Proprietary), for submittal to the Commission, being transmitted by Xcel Energy -Monticello 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 U.S.NRC request for additional information relative to the Monticello Replacement Steam Dryer Acoustic/Structural Analyses Set #5, and may be used only for that purpose.

5 CAW-13-3762 This information is part of that which will enable Westinghouse to: (a) Provide information to support the acceptance of the Monticello EPU Licensing Amendment Request by the U.S. NRC.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 supporting the power ascension to the Extended Power Uprate condition.(b) Westinghouse can sell support and defense of the information provided in these documents.(c) 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 tile 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 arc 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.