RS-15-294, Response to Request for Additional Information Regarding Request for a License Amendment to Technical Specification 3.7.9, Ultimate Heat Sink.
| ML15313A254 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 11/09/2015 |
| From: | Gullott D Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RS-15-294 | |
| Download: ML15313A254 (17) | |
Text
Proprietary Information - Withhold From Public Disclosure Under 10 CFR 2.390 4300 Winfield Road Warrenville, IL 60555 Awnw- ExeLon G 630 657 2000 Office RS-1 5-294 10 CFR 50.90 November 9, 2015 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. 50-456 and 50-457
Subject:
Response to Request for Additional Information Regarding Request for a License Amendment to Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, "Ultimate Heat Sink"
References:
- 1) Letter from D. M. Gullott (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "Request for a License Amendment to Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, 'Ultimate Heat Sink,"
dated August 19, 2014 (ML14231A902)
- 2) Letter from D. M. Gullott (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "Response to Request for Additional Information Regarding Request for a License Amendment to Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, "Ultimate Heat Sink," dated April 30, 2015 (ML15120A396)
- 3) Email from J. Wiebe (NRC) to J. Krejcie (Exelon Generation Company, LLC)
Additional RAI Regarding Containment Analysis for Braidwood UHS LAR (MF4671 and MF4672), dated July 22, 2015
- 4) Email from J. Wiebe (NRC) to J. Krejcie (Exelon Generation Company, LLC)
Need Clarification Conference Call Regarding Your April 30, 2015 Response to SCVB-RAI-1(a), dated August 12, 2015 (ML1522413548)
- 5) Email from J. Wiebe (NRC) to J. Krejcie (Exelon Generation Company, LLC)
Additional RAls Regarding Braidwood Ultimate Heat Sink Temperature Amendment, dated September 29, 2015
- 6) Letter from D. M. Gullott (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "Response to Request for Additional Information Regarding Request for a License Amendment to Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, 'Ultimate Heat Sink," dated October 9, 2015
November 9, 2015 U.S. Nuclear Regulatory Commission Page 2
- 7) Letter D. M. Gullott (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "Response to Request for Additional Information Regarding Request for a License Amendment to Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, 'Ultimate Heat Sink," dated October 30, 2015 In Reference 1, Exelon Generation Company, LLC, (EGC) requested an amendment to the Technical Specifications (IS) of Facility Operating License Nos. NPF-72 and NPF-77 for Braidwood Station, Units 1 and 2. The proposed amendment would modify TS 3.7.9, "Ultimate Heat Sink (UHS)," by changing the maximum allowable temperature of the UHS from 100 OF to a maximum UHS temperature of 102°F. The U. S. Nuclear Regulatory Commission (NRC) requested additional information related to its review of Reference 1 and additional information was provided in Reference 2.
Subsequent to submittal of Reference 2, the NRC requested additional information to support the review of the subject License Amendment Request (i.e., Reference 1) in References 3 and
- 4. Reference 6 provided the response to the Reference 3 and 4 requested information but indicated that the response to Reference 3 SCVB-RAI-1 1 would be provided at a later date.
Just prior to issuance of the EGC response in Reference 6, the NRC requested additional information in Reference 5 with two additional questions. Recently submitted (i.e., October 30, 2015) Reference 7 contained the response to Reference 5. A teleconference with NRC staff was held on November 2, 2015 to discuss the response to the Reference 3 outstanding RAI (i.e., SCVB-RAI-1 1). At the request of the NRC during the teleconference, includes the response to SCVB-RAI-1 1.
Portions of Attachment 1 contain proprietary information as defined by 10 CFR 2.390, "Public inspection, exemption, requests for withholding." Westinghouse Electric Company, LLC, (Westinghouse), as the owner of the proprietary information has executed the enclosed affidavit, which identifies that the enclosed proprietary information has been handled and classified as proprietary, is customarily held in confidence, and has been withheld from public disclosure.
The portions of Attachment 1 that are considered proprietary are shown with brackets surrounding the proprietary information. The proprietary information was provided to EGC by Westinghouse as referenced by the affidavit. The proprietary information has been faithfully reproduced in the attached information such that the affidavit remains applicable. Westinghouse hereby requests that the attached proprietary information be withheld, in its entirety, from public disclosure in accordance with the provisions of 10 CFR 2.390 and 10 CFR 9.17. Attachment 2 contains a nonproprietary version of Reference 1 with brackets showing where the proprietary information has been deleted. The affidavit supporting the proprietary nature of the information is contained in Attachment 3.
EGC has reviewed the information supporting a finding of no significant hazards consideration that was previously provided to the NRC in Attachment 1 of Reference 1. The information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration.
In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b), a copy of this letter and its attachment is being provided to the designated State of Illinois official.
November 9, 2015 U.S. Nuclear Regulatory Commission Page 3 Should you have any questions concerning this letter, please contact Ms. Jessica Krejcie at (630) 657-2816.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 9th day of November 2015.
Respectfully, David M. Gulloft Manager Licensing Exelon Generation Company, LLC : Response to Request for Additional Information (Proprietary) : Response to Request for Additional Information (Non-Proprietary) : Westinghouse Electric Company, LLC Affidavit for Report LTR-CRA-15-174 cc: NRC Regional Administrator, Region III NRC Senior Resident Inspector, Braidwood Station Illinois Emergency Management Agency Division of Nuclear Safety
ATTACHMENT 2 Response to Request for Additional Information (Non-Proprietary)
ATTACHMENT 2 Response to Request for Additional Information (Non-Proprietary)
In Reference 1, Exelon Generation Company, LLC, (EGC) requested an amendment to the Technical Specifications (TS) of Facility Operating License Nos. NPF-72 and NPF-77 for Braidwood Station, Units 1 and 2. The proposed amendment would modify TS 3.7.9, "Ultimate Heat Sink (UHS)," by changing the maximum allowable temperature of the UHS from 100 OF to a maximum UHS temperature of 102°F. The U. S. Nuclear Regulatory Commission (NRC) requested additional information related to its review of Reference 1 and additional information was provided in Reference 2.
Subsequent to submittal of Reference 2, the NRC requested additional information to support the review of the subject License Amendment Request (i.e., Reference 1) in References 3 and
- 4. Reference 6 provided the response to the Reference 3 and 4 requested information but indicated that the response to Reference 3 SCVB-RAI-1 1 would beprovided at a later date.
Just prior to issuance of the EGC response in Reference 6, the NRC requested additional information in Reference 5 with two additional questions. Recently submitted (i.e., October 30, 2015) Reference 7 contained the response to Reference 5. A teleconference with NRC staff was held on November 2, 2015 to discuss the response to the Reference 3 outstanding RAI (i.e., SCVB-RAI-1 1). At the request of the NRC during the teleconference, this attachment includes the response to SCVB-RAI-1 1.
SCVB-RAI-1 1 (from Reference 3)
The NRC staff is aware of Westinghouse's InfoGram IG-14-1, dated November 5, 2014, which states that the loss-of-coolant accident (LOCA) containment mass and energy (M&E) release analysis methodology was found to use the reactor coolant system (RCS) stainless steel volumetric heat capacity value lower than the ASME values. The staff has received information which indicates that the impact on the LOCA peak containment pressure in the current licensing basis would be significant if the analysis would use ASME values for the RCS metal volumetric heat capacity. Provide an update to your application dated August 19, 2014 (ADAMS Accession Number ML14231A902), that contains the results of the containment pressure, containment temperature, sump temperature responses and net positive suction head (NPSH) analysis using the ASME published volumetric heat capacity for the RCS metal. In your supplement dated April 30, 2015 (ADAMS Accession No. ML15128A186) you stated that, "All issues related to the subject Nuclear Safety Advisory Letters (NSALs) (NSAL-06-6, NSAL-1 1-5, and NSAL-14-2) were explicitly addressed (and subsequent corrections in the loss-of-coolant (LOCA) mass and energy (M&E) release analysis were made) in support of the Ultimate Heat Sink (UHS) analysis." Confirm, in your update, that these NSALs continue to be addressed in the requested updated analysis.
SCVB-RAI-1 1 Response:
As noted in the supplement dated April 30, 2015 (Reference 2), Nuclear Safety Advisory Letters (NSALs) NSAL-06-6, NSAL-1 1-5 and NSAL-14-2 were all explicitly addressed with subsequent corrections to the loss-of-coolant accident (LOCA) mass and energy (M&E) release analysis made in support of the revised Ultimate Heat Sink (UHS) analysis for increased initial UHS temperature to support the Reference 1 Technical Specification change request.
Page 1 of 4
ATTACHMENT 2 Response to Request for Additional Information (Non-Proprietary)
Exelon has reviewed Westinghouse's InfoGram (IG) 14-1 (Reference 8) and concurs with the InfoGram conclusion indicating that the current Westinghouse LOCA M&E release methodology provides a conservative calculation of the energy release rate for input to the containment calculations. The methodology has been proven to be overall conservative for containment integrity and downstream analyses, including Equipment Qualification (EQ), and as such, no further action on part of the utility was noted or required in response to the IG 14-1 issuance.
Specifically, EGC has reviewed IG-14-1 and concurs with the determination that the stainless steel volumetric heat capacity value used in the methodology for the revised analysis does not match the latest uppermost bound of the ASME data, however the value used is representative of published material property data (i.e., the standard available at the time of development of the Westinghoue LOCA M&E release methodology) and is considered to be representtivO Of the various published values.
To better address the NRC's request, EGC contacted Westinghouse to perform a qualitative evaluation to understand the potential impact of incorporating the ASME values for RCS metal volumetric heat capacity for Braidwood Station. Portions of the information below are marked as proprietary as indicated with brackets [] as described in References 9 and 10.
The qualitative evaluation is based on generic LOCA M&E release and containment response analyses that Westinghouse had performed to address the issue related to the stainless steel volumetric heat capacity. A plant with a large dry containment design, similar to the Braidwood units, was the basis for one of the generic LOCA M&E release and containment response models. The generic models included the necessary input changes to address the issues previously identified in NSAL-06-6, NSAL-11-5, and NSAL-14-2.
Based on the results of the sensitivity cases with these generic models, if the RCS metal volumetric heat capacity input value was increased to be consistent with more recent data (i.e.,
ASME values), then the following effects on the calculated containment peak pressure results could be expected:
- Plants that have a blowdown pressure peak that is substantially higher than the post-reflood pressure peak would not be affected by the increase in stored metal energy because the amount of metal energy that is released during the blowdown phase is not significant when compared to the fluid energy release. This includes plants with the sub-atmospheric containment design and some plants with the large dry containment design that have very good containment heat removal systems. Plants with a second pressure peak during the post-reflood phase that is only slightly lower than the blowdown peak
[ ] may become second peak limited.
- Plants that are limited by a post-reflood pressure peak could expect an increase in the calculated peak pressure [ ]. This includes plants with the passive containment design and plants with the large dry containment design that have less effective containment heat removal systems.
- For an increase in the post-reflood peak pressure [ ], the change in the peak vapor temperature and peak sump temperature would be [ I.
The Braidwood Station units have the large dry containment design. The calculated containment peak pressure for Unit 1 occurs during the blowdown phase of a double-ended hot leg (DEHL)
ATTACHMENT 2 Response to Request for Additional Information (Non-Proprietary)
LOCA. The DEHL blowdown peak is 42.1 psig and is very close to the second peak in the double-ended pump suction (DEPS) LOCA event. The calculated containment peak pressure for Unit 2 occurs during the post-reflood phase of a DEPS LOCA and is 38.37 psig. The containment design pressure for both units is 50 psig.
Based on the results from a similar generic model with the large dry containment design, the estimated containment peak pressure increase for both Braidwood units would be approximately [ ]. For Unit 1, the time of peak pressure is expected to switch from the end of blowdown in the DEHL LOCA case to the post-reflood phase in the DEPS LOCA case. For Unit 2, the time of peak pressure is expected to remain during the post-reflood phase of the DEPS LOCA case. For both units, the estimated containment peak pressure [ ] is still significantly less than the containrneiitdesign pressure of 50'psig.
In contrast, plants with the ice condenser design could expect a significant increase in the calculated peak pressure [ ]. The additional stored metal energy release during the first hour would cause the ice to melt faster and reduce the time for the ice to be an effective heat sink. After all of the ice melted, the heat load to containment would be higher and this would cause the calculated pressure and temperature to increase until the active containment heat removal systems could match the heat release rate. Therefore, plants with the ice condenser design would be more significantly impacted by the lG-14-1 described ASME values for RCS stainless steel volumetric heat capacity.
The results of the Braidwood Station evaluation showed that with corrections made to address NSAL-06-6, NSAL-1 1-5, and NSAL-14-2 and with consideration of the ASME value for RCS stainless steel volumetric heat capacity, the peak containment pressure results do not increase significantly and would remain below the containment design pressure with a margin of over
[ }. Additional conservatisms within the existing model are described within lG-14-1.
EGC does not plan on revising the Braidwood Station UHS analysis to address lG-14-1 at this time. Since the results of the Braidwood Station evaluation of IG-14-1 demonstrate that consideration of the ASME stainless steel volumetric heat capacity value do not significantly impact the calculated peak pressure and do not challenge the containment design pressure, EGC requests that the NRC continue their review of the Reference 1 submittal and analysis with the current approved LOCA M&E release methodology. Additional actions and analyses to address IG-14-1 should be addressed by an industry effort in conjunction with the NRC.
Page 3 of 4
ATTACHMENT 2 Response to Request for Additional Information (Non-Proprietary)
REFERENCES:
- 1) Letter from D. M. Gullott (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "Request for a License Amendment to Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, 'Ultimate Heat Sink," dated August 19, 2014 (ML14231A902)
- 2) Letter from D. M. Gullott (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "Response to Request for Additional Information Regarding Request for a License Amendment to Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, "Ultimate Heat Sink," dated April 30, 2015 (ML15120A396)
- 3) Email from J. Wiebe (NRC) to J. Krejcie (Exelon Generation Company, LLC) Additional RAI Regarding Containment Analysis for Braidwood UHS LAR (MF4671 and MF4672),
dated July 22, 2015
- 4) Email from J. Wiebe (NRC) to J. Krejcie (Exelon Generation Company,LLC) Need Clarification Conference Call Regarding Your April 30, 2015 Response to SCVB-RAI-1(a), dated August 12, 2015
- 5) Email from J. Wiebe (NRC) to J. Krejcie (Exelon Generation Company, LLC) Additional RAIs Regarding Braidwood Ultimate Heat Sink Temperature Amendment, dated September 29, 2015
- 6) Letter from D. M. Gullott (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "Response to Request for Additional Information Regarding Request for a License Amendment to Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, 'Ultimate Heat Sink," dated October 9, 2015
- 7) Letter D. M. Gullott (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "Response to Request for Additional Information Regarding Request for a License Amendment to Braidwood Station, Units 1 and 2, Technical Specification 3.7.9,
'Ultimate Heat Sink," dated October 30, 2015
- 8) Westinghouse InfoGram 14-1, "Materials Properties for Loss-of Coolant Accident Mass and Energy Release Analyses," dated November 5, 2014
- 9) Westinghouse Letter CCE-15-56, "Transmittal of Application for Withholding Proprietary
- Information form Public Disclosure for the Qualitative Assessment of lG-14-1 Applicable to Braidwood Station Units 1 and 2," dated October 23, 2015 10)Westinghouse Letter CCE-15-53, "Qualitative Assessment of IG-14-1 Applicable to Braidwood Units 1 and 2," dated October 20, 2015 Page 4 of 4
ATTACHMENT 3 Westinghouse Electric Company, LLC Affidavit for Report LTR-CRA-15-174
Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township Pennsylvania 16088 USA U.S. Nuclear Regulatory Commission Direct Document Control Desk 11555 Rockville Pike .Ilri 4Ij L L t. .!.ji Rockville, MD 20852 October 23, 2015 A
W
Subject:
LIR-CRA-15-174,, Attachment 1.'~Qualitative Evaluation to Support BraidwoodUHS RAI Response Concerning IG-14-1" (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 m Affidavit CAW-15-4317 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 2390 of the Commission's regulations.
Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Exelon Generation Co, LLC.
AV James A. Gresham, Manager
CAW-15-4317 October 23, 2015 ss lJ'LS)I$4 I, Henry A. Sepp, 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.
- AI-I L44/
H=y A.(Sepp,&ectol 74
CAW-15-4317 (1) I am Director, CRE-Systems and Components Engineering, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.
(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.
(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.
(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.
(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.
(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system 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
CAW-15-4317 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.
(b) ft consism of supporting daia,, including tea data, relative to a process (or componeK structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved (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 capacifies,, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.
development plans and programs of potential commercial value to Westinghouse.
(iii) There are sound policy reasons behind the Westinghouse system which include the (a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position (b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.
(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.
CAW-15-4317 (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 2390, 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 i!TLI)I![
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 L11-CRA-15-174 Attachment 1, "Qualitative Evaluation to Support Braidwood UIIS RAI Response Concerning IG-14-l" (Proprietary), for submittal to the Commission, being transmitted by Exelon Generation Company 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 a qualitative evaluation of the estimate effect of 1G-14-1 on the Braidwood Ultimate Heat Sink analysis, and may be used only for that purpose.
(a) This information is part of that which will enable Westinghouse to:
(i) Provide input to Exelon Generation Co, LLC to provide to the U.S.
Nuclear Regulatory Commission in response to NRC Request for Additional Information (RAI) related to the Braidwood Ultimate Heat Sink (UHS) submittal.
(b) Further this information has substantial commercial value as follows:
Westinghouse plans to sell the use of similair information to its cuslomi for the purpose of responding to NRC RAls.
(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 evaluations 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
ZJ L)J TI )i 411114VI ($)IiaI Transmitted herewith are proprietary and/or non-proprietary versions of docwnents 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 (I) 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)(uXa) through (4X"Xf) of the Affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).
sj a 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.
Exelon Generation Company, LLC Letter for Transmittal to the NRC The following paragraphs should be included in your letter to the NRC Document Control Desk:
Enclosed are:
- 1. One copy of LTR-CRA-15-174, Attachment 1, "Qualitative Evaluation to Support Braidwood UHS RA! Response Concerning IG-14-1" (Proprietary)
- 2. One copy of LTR-CRA-15-174, Attachment 2, "Qualitative Evaluation to Support Braidwood UHS RAI Response Concerning 10-14-1" (Non-Proprietary)
Also enclosed is the Westinghouse Application for Withholding Proprietary information from Public Disclosure CAW-15-4317, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice.
As Item 1 contains information proprietary to Westinghouse Electric Company LLC, it is supported by an Affidavit signed by Westinghouse, the owner of the information The Affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2390 of the Commission's regulations Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.
Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse Affidavit should reference CAW-15-43i7 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