ML15289A073
| ML15289A073 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 10/12/2015 |
| From: | Gardner P A Northern States Power Co, Xcel Energy |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML15289A082 | List: |
| References | |
| L-MT-15-074, TAC MD9990, TAC MF6730 | |
| Download: ML15289A073 (25) | |
Text
ENCLOSURES 1, 2 AND 3 CONTAIN PROPRIETARY INFORMATION
-WITHHOLD FROM PUBLIC DISCLOSURE IN ACCORDANCE WITH 10 CFR 2.390 Xc el Energy Monticello Nuclear Generating Plant 2807 W County Rd 75 Monticello, MN 55362 October 12, 2015 L-MT-1 5-074 10 CFR 50.4 U.S. Nuclear Regulatory Commission.ATTN: Document Control Desk Washington, DC 20555-0001 Monticello Nuclear Generating Plant Docket No. 50-263 Renewed Facility Operating License No. DPR-22 Monticello Extended Power Uprate: Submittal of Power Ascension Testinq Results for Replacement Steam Dryer (TAC No. MF6730)
References:
1)Letter from T Beltz (NRC) to K Fili (NSPM), "Monticello Nuclear Generating Plant- Issuance of Amendment No. 176 to Renewed Facility Operating License Regarding Extended Power Uprate (TAC No. MD9990)," dated December 9, 2013. (ADAMS Accession No.ML1 3343A006)2) Letter from M Schimmel (NSPM) to Document Control Desk (NRC),"Monticello Extended Power Uprate: Replacement Steam Dryer -Responses to Clarification Questions and Revised Analysis Documentation (TAC MD9990)," L-MT-13-091, dated August 29, 2013. (ADAMS Accession No. ML13248A343)
Pursuant to 10 CFR 50.92, the NRC issued Reference 1, License Amendment No. 176 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. This change to power level is considered an extended power uprate (EPU).Reference 2 provided the Replacement Steam Dryer (RSD) final licensing basis analyses used in part to support the NRC issuance of License Amendment No. 176.Reference 2 contains WCAP-17252-P, Revision 4 and WCAP-17549-P, Revision 2 which are superseded by this letter.i .oo[
Document Control Desk Page 2 This letter provides power ascension testing information in accordance with the following MNGP license conditions associated with License Amendment No. 176: 15(b)2 After reaching 2004 MWt, NSPM shall obtain measurements from the MSL strain gauges and establish the steam dryer flow-induced vibration load fatigue margin for the facility, update the dryer stress report, and re-establish the limit curves with the updated load definition.
This data will be provided to the NRC staff as described in license condition 15(e).15(e) The results of the power ascension testing to verify the continued structural integrity of the steam dryer shall be submitted to the NRC staff in a report that includes a final load definition and stress report of the steam dryer, including the results of a complete re-analysis using the ACE 2.0 and ACE 2.0-.SPM specific bias and uncertainties.
The report will be provided within 90 days of the completion of EPU power ascension testing.The information required by these license conditions is provided in the enclosures to this letter. WCAP-17252-P, Revision 4 and WCAP-17549-P, Revision 2, provided in Reference 2 are impacted by changes in the load definition due to the test results encountered during the power ascension testing. The analyses impacts are incorporated in the enclosures listed below.Enclosure 1 contains Westinghouse Electric Company, LLC (WEC) report WCAP 17252-P, Revision 5, "Acoustic Loads Definition for the Monticello Steam Dryer Replacement Project".
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 update provides additional data and corrections performed on ACE Revision 2.0 and resulted in a revision to the biases and uncertainties for the acoustic load definition.
The updated model is called ACE Revision 2.0.1. This report contains proprietary information.
Enclosure 2 contains WEC report WCAP-17549-P, Revision 3, "Monticello Replacement Steam Dryer Structural Evaluation for High-Cycle Acoustic Loads Using ACE"'. This document provides a high-cycle fatigue evaluation of the MNGP RSD with loads generated using the ACE Revision 2.0.1 model for the upper dryer and ACE 2.0+SPM (skirt protection model) for the lower dryer. Appendix B has been added to this document to update acoustic loads and stresses from data taken at full EPU conditions (2004 MWt). Appendix B indicates that the high-cycle fatigue results have been determined to meet the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code Section IIl, Subsection NG criteria.
This report contains proprietary information.
Enclosure 3 contains WEC report WCAP-1 8064-P, Revision 0, "Monticello EPU Main Steam Line Strain Gauge Data Evaluation Report." This report provides a description of the data obtained from the Main Steam Line (MSL) strain gauges during the EPU power Document Control Desk Page 3 ascension activities.
This report provides the signal processing methods applied to the plant data to support the structural integrity evaluation analysis.
The general signal processing methods applied to the plant data include conversion of measured MSL strain data into MSL alternating pressure signatures, narrow-band filtering, and wavelet denoising.
This report contains proprietary information.
Enclosure 4 contains WEC affidavits executed to support withholding Enclosures 1, 2, and 3 from public disclosure.
The affidavits set forth the basis on which the 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, 2 and 3 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 4 should be addressed to J. A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 3 Suite 310, Cranberry Township, Pennsylvania 16066.Enclosures 5, 6 and 7 contain a nonproprietary version of Enclosures 1, 2, and 3 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.Summary of Commitments This letter makes no new commitments and no revisions to existing commitments.
PeerA " Site Vice-Preside t, ntL icello Nuclear Generating Plant Northern States Power Company-Minnesota Enclosures (7)cc: Administrator, Region Ill, USNRC Project Manager, Monticello Nuclear Generating Plant, USNRC Resident Inspector, Monticello Nuclear Generating Plant, USNRC L.-MT-1 5-074 ENCLOSURE 4 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.Affidavit
- Enclosure number -Document number & Name CAW-15-4299 Enclosure I -WCAP-17252-P, Revision 5, "Acoustic Loads Definition for the Monticello Steam Dryer Replacement Project" (Proprietary)
CAW-15-4301 Enclosure 2 -WCAP-17549-P, Revision 3, "Monticello Replacement Steam Dryer Structural Evaluation for High-Cycle Acoustic Loads Using ACE" (Proprietary)
CAW-15-4300 Enclosure 3 -WCAP-18064-P, Revision 0, "Monticello EPU Main Steam Line Strain Gauge Data Evaluation Report" (Proprietary) 21 pages follow Westinhouseuleetr o C .ompn 1000 Westinghouse Drive U.S. Nuclear Regulatory Commission Direct tel: (412) Document Control Desk Direct fax: (724) 940-8560 11555 Rockville Pike e-mail: greshaja @westinghouse.com Rockville, MD 20852 CAW-15-4299 October 5, 2015 APPLICATION FOR WITHHFOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
WCAP-17252-P, Revision 5, "Acoustic Loads Definition for the Monticello Steam Dryer Replacement Project" (Proprietary)
The Application for Withholding Proprietary Information from Public Disclosure is submitted by Westinghouse Electric Company LLC (Westinghouse), pursuant to the provisions of paragraph (b)(1) of Section 2.390 of the Commission's regulations.
It contains commercial strategic information proprietary to Westinghouse and customarily held in confidence.
The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-15-4299 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The Affidavit, which accompanies this letter, sets forth the 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 Conmmission'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-15-4299, and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company. 1000 Westinghouse Drive, Building 3 Suite 310, Cranberry Township, Pennsylvania 16066./Jmes A. Gresham, Manager Regulatory Compliance CAW-15-4299 October 5, 2015 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
SS COUNTY OF BUTLER: I, James A. Gresham, am authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief.James A. Gresham, Manager Regulatory Compliance 2 2 CAW-15-4299 (1) I am Manager, Regulatory Compliance, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the 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 2.3 90 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 2.3 90 of the Commission' s regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence.
The application of that system and the substance of that system constitute Westinghouse policy and provide the rational basis required.Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows: (a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of 3 3 CAW- 15-4299 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.(f) It contains patentable ideas, for which patent protection may be desirable.(iii) There are sound policy reasons behind the Westinghouse system which include the following: (a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors.
It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.
4 4 CAW-15-4299 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage, If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.(iv) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.(v) The information sought to be protected is. not available in public sources or available information has not been previously emploYed in the same original manner or method to the best of our knowledge and belief.(vi) The proprietary information sought to be withheld in .this submittal is that which is appropriately marked in WCAP-17252-P, Revision 5, "Acoustic Loads Definition for the Monticello Steam Dryer Replacement Project" (Proprietary), dated September 2105, 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 high-cycle fatigue assessment of the replacement steam dryer at Monticello Nuclear Generating Plant.(MNGP) at extended power uprate (EPU) conditions, and may be used only for that purpose.
5 5 CAW-15-4299 (a) This information is part of that which will enable Westinghouse to: (i) Assist Xcel Energy in fulfilling the NRC replacement steam dryer reporting requirements for power, ascension to EPU operating conditions for MINGP.(b) Further this information has substantial commercial value as follows: (i) Westinghouse plans to sell the use of similar information to its customers for the purpose of plant specific replacement steam dryer analysis for licensing basis applications.(ii) Westinghouse can sell support and defense of industry guidelines and acceptance criteria for plant-specific applications.(iii) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.
Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation 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 non-proprietary versions of documents furnished to the NRC associated with the high-cycle fatigue assessment of the replacement steam dryer at extended power uprate (EPU) conditions for the Monticello Nuclear Generating Plant.In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning 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)(t) of the Affidavit accompanying this transmittal pursuant to 10 CFR 2.3 90(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 2.3 90 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.
W estin houseWestinghouse Electric Company 1000 Westinghouse Drive U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk ,Direct fax: (724) 940-8560 11555 Rockville Pike e-mail: greshaja@westinghouse.com Roclkville, MD 20852 CAW-15-4301 October 5, 2015 APPLICATION FOR WITHHFOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
WCAP-17549-P, Revision 3, "Monticello Replacement Steam Dryer Structural Evaluation for High-Cycle Acoustic Loads Using ACE" (Proprietary)
The Application for Withholding Proprietary Information from Public Disclosure is submitted by Westinghouse Electric Company LLC (Westinghouse), pursuant to the provisions of paragraph (b)(l) of Section 2.3 90 of the Commission's regulations.
It contains commercial strategic information proprietary to Westinghouse and customarily held in confidence.
The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-15-4301 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The Affidavit, which accompanies this letter, sets forth the 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 accompanyirng Affidavit by Xcel Energy.Correspondence with respect to the proprietary aspects of the Application for Withholding or the Westinghouse Affidavit should reference CAW-15-4301, and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 3 Suite 310, Cranberry Township, Pennsylvania 16066.6Jaes .Geshaam, Manager Regulatory Compliance CAW-15-4301 October 5, 2015 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
SS COUJNTY OF BUTLER: I, James A. Gresham, am authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief.James A. Gresham, Manager Regulatory Compliance 2 2 CAW-15-4301 (1) I am Manager, Regulatory Compliance, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the 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 2.3 90 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 ftom public disclosure is owned and has been held in confidence by Westinghouse.(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence.
The application of that system and the substance of that system constitute Westinghouse policy and provide the rational basis required.Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows: (a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of 3 3 CAW-15-4301 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 pians and programs of potential commercial value to Westinghouse.(f) It contains patentable ideas, for which patent protection may be desirable.(iii) There are sound policy reasons behind the Westinghouse system which include 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-15-4301 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage, If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.(iv) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.(v) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.(vi) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP-17549-P, Revision 3, "Monticello Replacement Steam Dryer Structural Evaluation for High-Cycle Acoustic Loads Using ACE" (Proprietary), dated October 2015, 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 high-cycle fatigue assessment of the replacement steam dryer at Monticello Nuclear Generating Plant (MNGP) at extended power uprate (EPU) conditions, and may be used only for that purpose.
5 5 CAW-15-4301 (a) This information is part of that which will enable Westinghouse to: (i) Assist Xcel Energy in fulfilling the NRC replacement steam dryer reporting requirements for power ascension to EPU operating conditions for MNGP.(b) Further this information has substantial commercial value as follows: (i) Westinghouse plans to sell the use of similar information to its customers for the purpose of plant specific replacement steam dryer analysis for licensing basis applications.(ii) Westinghouse can sell support and defense of industry guidelines and acceptance criteria for plant-specific applications.(iii) The information requested to be withheld reveals the distinguishing aspects Of a methodology which was developed by Westinghouse.
Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation 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 non-proprietary versions of documents furnished to the NRC associated with the high-cycle fatigue assessment of the replacement steam dryer at extended power uprate (EPU) conditions for the Monticello Nu~lear Generating Plant.In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning 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 2.3 90 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.
W estin houseWestinghouse Electric Company 1000 Westinghouse Drive U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (724) 940-8560 11555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852 CAW-15-4300 October 5, 2015 APPLICATION FOR WiT-HhOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
WCAP-18064-P, Revision 0, "Monticello EPU Main Steam Line Strain Gauge Data Evaluation Report" (Proprietary)
The Application for Withholding Proprietary Information from Public Disclosure is submitted by Westinghouse Electric Company LLC (Westinghouse), pursuant to the provisions of paragraph (b)(1) of Section 2.3 90 of the Commission's regulations.
It contains commercial strategic information proprietary to Westinghouse and customarily held in confidence.
The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW- 15-4300 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The Affidavit, which accompanies this letter, sets forth the 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-15-4300, and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 3 Suite 310, Cranberry Township, Pennsylvania 16066.-t/ames A. Gresham, Manager Regulatory Compliance CAW-15-4300 October 5, 2015 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:
SS COUNTY OlE BUTLER: I, James A. Gresham, am authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief.~James A. Gresham, Manager Regulatory Compliance 2 2 CAW-15-4300 (1) I am Manager, Regulatory Compliance, Westinghouse Electric Company LLC (Westinghouse), and as such, I bave been specifically delegated the function of reviewing the 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 CF~R Section 2.3 90 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.
(3) I have personal knowledge of the criteria-and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial, information.
(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence.
The application of that system and the substance of that system constitute Westinghouse policy and provide the rational basis required.Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive
- advantage, as follows: (a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of 8 3 CAW-15-4300 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.(f) It contains patentable ideas, for which patent protection may be desirable.(iii) There are sound policy reasons behind the Westinghouse system which include the following: (a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors.
It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.
4 4 CAW-I5-4300 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage, If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.(iv) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.(v) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.(vi) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP-18064-P, Revision 0, "Monticello EPU Main Steam Line Strain Gauge Data Evaluation Report" (Proprietary), dated September 2015, 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 high-cycle fatigue assessment of the replacement steam dryer at Monticello Nuclear Generating Plant (MINGP) at extended power uprate (EPU) conditions, and may be used only for that purpose.
5 5 CAW-15-4300 (a) This information is part of that which will enable Westinghouse to: (i) Assist Xcel Energy in fulfilling the NRC replacement steam dryer reporting requirements for power ascension to EPU operating conditions*
for MNGP.(b) Further this information has substantial commercial value as follows: (i) Westinghouse plans to sell the use of similar information to its customers for the purpose of plant specific replacement steam dryer analysis for licensing basis applications.(ii) Westinghouse can sell support and defense of industry guidelines and*acceptance criteria for plant-specific applications.(iii) The information requested to be withheld reveals the distinguishing
- aspects of a methodology which was developed by Westinghouse.
Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation 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 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 non-proprietary versions of documents furnished to the NRC associated with the high-cycle fatigue assessment of the replacement steam dryer at extended power* uprate (EPU) conditions for the Monticello Nuclear Generating Plant.In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning 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.