Text

Transmittal of Response to Remaining Questions from NRC Request for Additional Information (RAI) Regarding Reactor Vessel Internal Component Aging Management Program
	ML15350A018
Person / Time
Site:	Fort Calhoun
Issue date:	11/30/2015
From:	Cortopassi L P; Omaha Public Power District
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML15350A009	List: LIC-15-0117, Enclosure 8, PWROG-14082-NP, Revision 0, Summary Report for the Fuel Design / Fuel Management Assessments to Demonstrate MRP-227-A Applicability. (Non-Proprietary); ML15350A018; ML15350A019; ML15350A020;
References
	CAW-15-4212, LIC-15-0117
	Download: ML15350A018 (21)
	v • d • e

Proprietary-WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 Enclosures 1, 2, and 4, contain Proprietary information.

Upon removal of Enclosures 1, 2, and 4, this letter is Decontrolled.

inmmm Omaha Public Power District 444 South 1 6 th Street Mall Omaha, NE 68102-2247 LIC-15-01 17 November 30, 2015 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285

Subject:

OPPD Response to Remaining Questions from NRC Request for Additional Information (RAI)Regarding Fort Calhoun Station, Reactor Vessel Internal Component Aging Management Program

References:

1. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "Submittal of Reactor Vessel Internal (RVI) Component Aging Management Program (AMP) for Fort Calhoun Station (FCS), Unit No.1," dated September 27, 2012 (ML12276A005)(LIC-1 2-0144)2. E-mail from NRC (J. Rankin) to OPPD (M. Edwards I B. Hansher), "Request for Additional Information

-Reactor Vessel Internal Component Aging Management Program (MF341 2)," dated July 8, 2014 (ML14190A211

)3. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "OPPD Response to NRC Request for Additional Information Regarding Fort Calhoun Station, Unit No.1 Reactor Vessel Internal Component Aging Management Program," dated August 22, 2014 (ML1 4234A530) (LIC-1 4-0107)4. Letter from NRC (C. F. Lyon) to OPPD (L. P. Cortopassi), "Fort Calhoun Station, Unit No. 1 -Request for Additional Information RE: Aging Management Program for Reactor Vessel Internals (TAC No. MF341 2)," dated March 3, 2015 (ML15057A015)(NRC-i15-010)

5. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "OPPD Response to NRC Request for Additional Information Regarding Aging Management Program For Reactor Vessel Internals (TAC No. MF341 2," dated April 13, 2015 (ML1 51 03A642) (LIC-1 5-0054)This letter responds to the remaining questions from Reference 2 regarding the Fort Calhoun Station (FCS), Reactor Vessel Internal (RV]) Aging Management Program (Reference 1). In Reference 3, the Omaha Public Power District (OPPD) responded to questions 4, 6, 7, 8, and 9. Enclosure 1 responds to the remaining questions (i.e., 1, 2, 3, and 5). Please note that Enclosures 1, 2 and 4 to this letter contain information that is proprietary to Westinghouse and should be withheld from public disclosure in accordance with 10 CFR 2.390.Proprietary-WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 Enclosures 1, 2, and 4, contain Proprietary information.

Upon removal of Enclosures 1, 2, and 4, this letter is Decontrolled.

Ar I Employment with Equal Opportunity Proprietary-WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 Enclosures 1, 2, and 4 contain Proprietary information.

Upon removal of Enclosures 1, 2, and 4 this letter is Decontrolled.

U. S. Nuclear Regulatory Commission LIC-1 5-0117 Page 2 The Electric Power Research Institute's Materials Reliability Program (MRP) Report MRP-227-A,"Pressurized Water Reactor Internals Inspection and Evaluation Guidelines," December 2008 (ADAMS Accession No. ML090160205), and its supporting reports were used as technical bases for developing the Aging Management Program (AMP). In Reference 5, OPPD responded to an NRC request for additional information (RAI) related to the NRC staffs Action Item 3 addressed in the staffs Safety Evaluation (SE) for MRP-227-A.

The following proprietary Westinghouse documents support the Enclosure 1 response to the Reference 2, NRC RAI and are provided to assist the NRC in its review: 1. PWROG-15030-P, Rev. 0, "Evaluation of Fort Calhoun Fuel Alignment Plate Fluence for MRP-227-A" (Proprietary) (Enclosure 2).2. PWROG-14082-P, Rev. 0, "Fort Calhoun Station Summary Report for the Fuel Design / Fuel Management Assessments to Demonstrate MRP-227-A Applicability" (Proprietary) (Enclosure 4).Enclosures 2 and 4 contain information proprietary to Westinghouse Electric Company LLC, and are supported by Affidavits in Enclosures 3 and 5 signed by Westinghouse, the owner of the information.

Enclosure 1 restates proprietary information from Enclosures 2 and 4 to respond to NRC questions.

The Affidavits set 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 2.390 of the Commission's regulations.

Accordingly, it is respectfully requested that Enclosures 1, 2, and 4, which contain information that is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.

Enclosures 6, 7, and 8 are non-proprietary versions of Enclosures 1, 2, and 4 respectively that are suitable for public disclosure.

Correspondence with respect to the copyright or proprietary aspects of Enclosures 1, 2, and 4 or the supporting Westinghouse Affidavits should reference CAW-15-4212 and/or CAW-15-4198 and be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 3 Suite 310, Cranberry Township, Pennsylvania 16066.This letter contains no regulatory commitments.

If you should have any questions regarding this submittal or require additional information, please contact Mr. Bill R. Hansher, Principal Regulatory Engineer, at 402-533-6894.

Respectfully,,-

Louis P. Cortopassi Site Vice President and CNO Proprietary-WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 Enclosures 1, 2, and 4 contain Proprietary information.

Upon removal of Enclosures 1, 2, and 4 this letter is Decontrolled.

Proprietary-WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 Enclosures 1, 2, and 4 contain Proprietary information.

Upon removal of Enclosures 1, 2, and 4 this letter is Decontrolled.

U. S. Nuclear Regulatory Commission LIC-i5-01 17 Page 3

Enclosures:

1. OPPD Response to Remaining Questions from NRC Request for Additional Information Regarding Fort Calhoun Station, Reactor Vessel Internal Component Aging Management Program (Proprietary)

2. PWROG-15030-P, Rev. 0, "Evaluation of Fort Calhoun Fuel Alignment Plate Fluence for MRP-227-A" (Proprietary)

3. Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-15-4212, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice dated June 17, 2015 4. PWROG-14082-P, Rev. 0, "Fort Calhoun Station Summary Report for the Fuel Design / Fuel Management Assessments to Demonstrate MRP-227-A Applicability" (Proprietary)

5. Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-15-4198, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice dated June 1, 2015 6. OPPD Response to Remaining Questions from NRC Request for Additional Information Regarding Fort Calhoun Station, Reactor Vessel Internal Component Aging Management Program (Non-Proprietary)

7. PWROG-15030-NP, Rev. 0, "Evaluation of Fort Calhoun Fuel Alignment Plate Fluence for MRP-227-A" (Non-Proprietary)

8. PWROG-14082-NP, Rev. 0, "Fort Calhoun Station Summary Report for the Fuel Design / Fuel Management Assessments to Demonstrate MRP-227-A Applicability" (Non-Proprietary)

Proprietary-WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 Enclosures 1, 2, and 4 contain Proprietary information.

Upon removal of Enclosures 1, 2, and 4 this letter is Decontrolled.

LIC-1 5-0117 Enclosure 3 Page 1 CAW-1 5-4212"Application for Withholding Proprietary Information from Public Disclosure" Proprietary-WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 Enclosures I, 2, and 4 contain Proprietary information.

Upon removal of Enclosures 1, 2, and 4 this letter is Decontrolled.

Westin hngheo useo ElctioCmpn W estin houseEngineering, Equipment and Major Projects 1000 Westinghouse Drive, Building S Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direet fax: (724) 940-8560 11555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852 CAW-15-421 2 June 17, 2015 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

PWROG-15030-P, Rev. 0, "Evaluation of Fort Calhoun Fuel Alignment Plate Fluence for MRP-227-A" (Proprietary)

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-15-4212 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 Pressurized Water Reactor Owners Group (PWROG).Correspondence with respect to the proprietary aspects of the Application for Withholding or the Westinghouse Affidavit should reference CAW-15-4212 and should be addressed to James A. Greshanm, Manager; Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 3 Suite 310, Cranberry Township, Pennsylvania 16066.Very truly yours, GrshmMaager Regulatory Compliance CAW- 15-4212 June 17, 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.Jaes-A. Gresham, Manager Regulatory Compliance 2 CAW-15-421 2 (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 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

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

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence.

The application of that system and the substance of that system constitute Westinghouse policy and provide the rational basis required.Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows: (a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of 3 3 ~CAW-15-421 2 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-15-4212 (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, th~ereby depriving Westinghouse of a competitive advantage.

Ce) 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 PWROG-1 503 0-P, Rev. 0, "Evaluation of Fort Calhoun Fuel Alignment Plate Fluence for MRP-227-A" (Proprietary), for submittal to the Commission, being transmitted by PWROG letter OG-15-212 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 NRC letter, "Request for Additional Information

-Reactor Vessel Internal Component Aging Management Program (MF3412)," ML14190A21 1, July 8, 2014 and may be used only for that purpose.

5 5 CAW-15-4212 (a) This information is part of that which will enable Westinghouse to: (i) Support reactor vessel internals aging management.(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 supporting reactor internals aging management (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 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 is the proprietary and/or non-proprietary version of a document furnished to the NRC associated with the NRC Letter, "Request for Additional Information

-Reactor Vessel Internal Component Aging Management Program (MF3412)," ML14190A21 1 July 8, 2014 and may be used only for that purpose.In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted).

The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f)located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information.

These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the Affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).

COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding.

With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

Omaha Public Power District Letter for Transmittal to the NRC The following paragraphs should be included in your letter to the NRC Document Control Desk: Enclosed are: 1. PWROG- 1 5030-P, Rev. 0, "Evaluation of Fort Calhoun Fuel Alignment Plate Fluence for MvIRP-227-A" (Proprietary)

2. PWROG-1 5030-NP, Rev. 0, "Evaluation of Fort Calhoun Fuel Alignment Plate Fluence for MRP-227-A" (Non-Proprietary)

Also enclosed is the Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW.4..417, 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 Commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations.

Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 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 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.

LIC-15-01 17 Enclosure 5 Page 1 CAW-1 5-4198"Application for Withholding Proprietary Information from Public Disclosure"

~~~Westinghouse Electricu Co mpaoo ony Engineering, Equipment and Major Projects USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (724) 940-8560 11555 Rockville Pike e-mil: greshaja@westinghouse.com Rockville, MD 20852 CAW- 15-4198 June 1, 2015 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

PWROG-14082-P, Rev. 0, "Fort Calhoun Station Summary Report for the Fuel Design I Fuel Management Assessments to Demonstrate MRP-227-A Applicability" (Proprietary)

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW- 15-4 198 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 Pressurized Water Reactor Owners Group (PWROG).Correspondence with respect to the proprietary aspects of the Application for Withholding or the Westinghouse Affidavit should reference CAW- 15-4198 and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 3 Suite 310, Cranberry Township, Pennsylvania 16066.Very truly yours, (/JmesA. resham, Manager Regulatory Compliance CAW-l 5-4198 June 1, 2015 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

5$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.4 1 ames A. Gresham, Manager Regulatory Compliance 2 2 CAW-I15-4198 (1) 1 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) 1 am making this Affidavit in conformance with the provisions of 10 CER Section 2.390 of the Commissions'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 ofra 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-l 5-4198 Westinghouse's competitors without license from Westinghouse constitu~tes 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.

(0) 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-15-4198 (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 PWROG-14082-P, Rev. 0, "Fort Calhoun Station Summary Report for the Fuel Design / Fuel Management Assessments to Demonstrate MRP-227-A Applicability" (Proprietary), for submittal to the Commission, being transmitted by PWROG letter OG- 15-212 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 NRC letter, "Request for Additional Information

-Reactor Vessel Internal Component Aging Management Program (MF3412)," ML14190A2 11 July 8, 2014 and may be used only for that purpose.

5 5 CAW- 15-4I198 (a) This information is part of that which will enable Westinghouse to: (i) Support reactor vessel internals aging management.(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 supporting reactor internals aging management (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 ofra methodology which was developed by Westinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications and licensing defense services for commercial power reactors without commensurate expenses.

Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.Further the deponent sayeth not.

PROPRIETARY INFORMATION NOTICE Transmitted herewith is the proprietary and non-proprietary versions of a document furnished to the NRC associated with the NRC letter, "Request for Additional Information

-Reactor Vessel Internal Component Aging Management Program (MF34 12)," ML14190A21 1 July 8, 2014 and may be used only for that purpose.In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted).

The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f)located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information.

These lower vase letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4Xii)(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 ofra 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.

Omaha Public Power District Leotter for Transmittal to the NRC The following paragraphs should be included in your letter to the NRC Document Control Desk: Enclosed are: 1. PWROG-14082-P, Rev. 0, "Fort Calhoun Station Summary Report for the Fuel Design /Fuel Management Assessments to Demonstrate MRP-227-A Applicability" (Proprietary)

2. PWROG-14082-NP, Rev. 0, "Fort Calhoun Station Summary Report for the Fuel Design / Fuel Management Assessments to Demonstrate MRP-227-A Applicability" (Non-Proprietary)

Also enclosed is the Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-l15-4198, 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 2.390 of the Commission's regulations.

Accordingly, it is respectfiully requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 1 0 CFR Section 2.390 of the Commission'ss regulations.

Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse Affidavit should reference CAW-1 5-4198 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.