NRC 2021-0003, Refueling 39 (U1 R39) Reactor Coolant Pump Analytical Evaluation Report

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Refueling 39 (U1 R39) Reactor Coolant Pump Analytical Evaluation Report
ML21021A102
Person / Time
Site: Point Beach 
Issue date: 01/21/2021
From: Schultz E
Point Beach
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML21021A101 List:
References
NRC 2021-0003 LTR-SDA-20-079-NP, Rev 0
Download: ML21021A102 (20)
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Text

Proprietary Information - Withhold from Public Disclosure Under 10 CFR 2.390 January 21, 2021 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Point Beach Nuclear Plant Unit 1 Docket 50-266 Renewed License No. DPR-24 NEXTera ENERGY&

~*

BEACH NRC 2021-0003 10 CFR 50.55a Unit 1 Refueling 39 (U1 R39) Reactor Coolant Pump Analytical Evaluation Report During the recent U1 R39 outage that concluded October 28, 2020, examinations were performed that resulted in an American Society of Mechanical Engineers (ASME)Section XI Code rejectable indication. The indication was found to be acceptable for further service without repair using the acceptance criteria of ASME Section XI, Paragraph IWB-3600.

In accordance with the requirements of the 2007 Edition through the 2008 Addenda of Section XI of the ASME Code, the enclosed analytical evaluation report is being submitted in accordance with Subarticle IWB-3134(b) for the identified Reactor Coolant Pump indication. contains one copy of L TR-SDA-20-079-P, Revision 0, dated October 2020, "Point Beach Unit 1 Reactor Coolant Pump Flaw Assessment for As-Found Linear Indications During Fall 2020 Refueling Outage" (Proprietary). Withhold from public disclosure under 1 O CFR 2.390. Upon removal of Attachment 1, this letter is uncontrolled. contains information proprietary to Westinghouse Electric Company LLC

("Westinghouse"), which is supported by an Affidavit (Attachment 3) 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 Nuclear Regulatory Commission ("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.

Proprietary Information - Withhold Under 10 CFR 2.390. Contains Proprietary Information, Upon Separation of Attachment 1 this letter is Nonproprietary.

NextEra Energy Point Beach, LLC 6610 Nuclear Road, Two Rivers, WI 54241

Proprietary Information - Withhold from Public Disclosure Under 10 CFR 2.390 Document Control Desk Page 2 contains one copy of L TR-SDA-20-079-NP, Revision 0, dated January 2021, "Point Beach Unit 1 Reactor Coolant Pump Flaw Assessment for As-Found Linear Indications During Fall 2020 Refueling Outage" (Non-Proprietary).

As stated, Attachment 3 contains the Westinghouse Affidavit supporting the withholding of from public disclosure pursuant to 10 CFR 2.390. Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse Affidavit should reference CAW-21-5139 and should be addressed to Korey L. Hosack, Manager, Licensing, Analysis, & Testing, Westinghouse Electric Company, 1000 Westinghouse Drive, Suite 165, Cranberry Township, Pennsylvania 16066.

This letter contains no new Regulatory Commitments or revisions to existing Regulatory Commitments.

If you have questions regarding this submittal, please contact me at 920-755-7854.

Sincerely yours, Eric Schultz Licensing Manager NextEra Energy Point Beach, LLC Attachments cc:

Regional Administrator, Region Ill, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC Proprietary Information - Withhold Under 10 CFR 2.390. Contains Proprietary Information, Upon Separation of Attachment 1 this letter is Nonproprietary.

Proprietary Information - Withhold from Public Disclosure Under 10 CFR 2.390 Westinghouse L TR-SDA-20-079-P, Revision 0, dated October 2020, "Point Beach Unit 1 Reactor Coolant Pump Flaw Assessment for As-Found Linear Indications During Fall 2020 Refueling Outage" (Proprietary)

(12 pages follow)

Proprietary Information - Withhold Under 10 CFR 2.390. Contains Proprietary Information, Upon Separation of Attachment 1 this letter is Nonproprietary.

Westinghouse L TR-SDA-20-079-NP, Revision 0, dated January 2021, "Point Beach Unit 1 Reactor Coolant Pump Flaw Assessment for As-Found Linear Indications During Fall 2020 Refueling Outage "

(Non-Proprietary)

(12 pages follow)

WESTINGHOUSE NON-PROPRIETARY CLASS 3 LTR-SDA-20-079-NP Revision 0 Point Beach Unit 1 Reactor Coolant Pump Flaw Assessment for As-Found Linear Indications During Fall 2020 Refueling Outage January 2021 Author: Anees U dyawar*, RV /CV Design & Analysis Verifier: Alexandria Carolan*, RV /CV Design & Analysis Approved: Lynn A. Patterson*, Manager, RV /CV Design & Analysis

  • Electronically Approved Records are Authenticated in the Electronic Document Management System

© 2021 Westinghouse Electric Company LLC All Rights Reserved

@Westinghouse

      • This record was final approved on 1/7/2021 12:50:45 PM. (This statement was added by the PRIME system upon its validation)

Rev Date 0

January 2021 WESTINGHOUSE NON-PROPRIETARY CLASS 3 Record of Revisions Revision Description Original Issue Page 2of12 LTR-SDA-20-079-NP Revision 0

      • This record was final approved on 1/7/2021 12:50:45 PM. (This statement was added by the PRIME system upon its validation)

WESTINGHOUSE NON-PROPRIETARY CLASS 3 FOREWORD LTR-SDA-20-079-NP Revision 0 This letter contains Westinghouse Electric Company LLC proprietary information and data which has been identified by brackets. Coding (a,c,e) associated with the brackets sets forth the basis on which the information is considered proprietary.

The proprietary information and data contained in this letter were obtained at considerable Westinghouse expense and its release could seriously affect our competitive position. This information is to be withheld from public disclosure in accordance with the Rules of Practice 1 OCFR2.390 and the information presented herein is to be safeguarded in accordance with 10CFR2.390. Withholding of this information does not adversely affect the public interest.

This information has been provided for your internal use only and should not be released to persons or organizations outside the Directorate of Regulation and the ACRS without the express written approval of Westinghouse Electric Company LLC. Should it become necessary to release this information to such persons as paii of the review procedure, please contact Westinghouse Electric Company LLC, which will make the necessary arrangements required to protect the Company's proprietary interests.

Page 3of12

      • This record was final approved on 1/7/2021 12:50:45 PM. (This statement was added by the PRIME system upon its validation)

WESTINGHOUSE NON-PROPRIETARY CLASS 3 1

INTRODUCTION LTR-SDA-20-079-NP Revision 0 During the Fall 2020 refueling outage at Point Beach Unit 1, two linear surface indications (Figures 1, 2,

& 3) were detected based on liquid penetrant (PT) examination at the reactor coolant cool pump (RCP) "A" near the integrally welded attachment (Reference 1 ). This integrally welded attachment was being examined as part of the Inservice Inspection (ISI) Program per ASME Section XI, Table IWB-2500-1, Exam Category B-K, IWB-3516 acceptance criteria (Reference 2).

Indication #1 is a linear indication measuring approximately 1 inch in length, located on the RCP casing between the 2 and 3 o'clock position relative to the attachment lug. This indication has a branch component to it which makes its width approximately 112" wide. Indication #2 is also a linear indication measuring approximately 1-7/8 inches in length and approximately 3/8" wide, located on the RCP casing at approximately the 7 o'clock position.

These indications were rejectable based on the acceptance flaw standards in IWB-3516 (Reference 2). The acceptance standard in IWB-3516 (Reference 2) references the acceptance standards for the applicable supported pressure retaining component to which the attachment is welded, which is the reactor coolant pump with criteria described in IWB-3519. Based on the acceptance criteria per IWB-3519, the two linear indication are rejectable.

The two as-found indications are similar in characteristics and location to the numerous linear indications that were found back in 1989 for the same RCP "A" (attributed to surface shrinkage of casting process) at Point Beach Unit 1 per NPC-47876 (Reference 3). The linear indications from 1989 were localized to the outside surface and had the appearance of surface shrinkage. Based on the Point Beach site review of the flaws, the two as-found linear indication discovered in Fall 2020 are in the same vicinity as the previous indications and are also indicative of casting shrinkage flaws that occur during solidification.

As a result, the two linear indications found in Fall 2020 will be assessed similarly to the flaw evaluation performed in 1989 as reported in NPC-47876 (Reference 3) and WCAP-12286 (Reference 4). This letter report herein will discuss the applicability of the fracture mechanics evaluations from References 3 and 4 to the two as-found linear indications. The conclusion of this report will demonstrate that the linear indications are acceptable for the life of the plant and can be left as-is with no repair needed.

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      • This record was final approved on 1/7/2021 12:50:45 PM. (This statement was added by the PRIME system upon its validation)

WESTINGHOUSE NON-PROPRIETARY CLASS 3 LTR-SDA-20-079-NP Revision 0 Figure 1: RCP As-found Indications Detected during Fall 2020 Outage Page 5of12

      • This record was final approved on 1/7/2021 12:50:45 PM. (This statement was added by the PRIME system upon its validation)

WESTINGHOUSE NON-PROPRIETARY CLASS 3 Figure 2: As-Found Indication 1 Figure 3: As-Found Indication 2 Page 6of12 LTR-SDA-20-079-NP Revision 0

      • This record was final approved on 1/7/2021 12:50:45 PM. (This statement was added by the PRIME system upon its validation)

WESTINGHOUSE NON-PROPRIETARY CLASS 3 2

FLAW CHARACTERISTICS LTR-SDA-20-079-NP Revision 0 The as-found linear indications discovered in Fall 2020 were based on surface examination (i.e. PT);

therefore, only flaw surface length and width information is available as follows:

Indication #1: Flaw length x width= 1.0" x 0.5

Indication #2: Flaw length x width= 1.875" x 0.375" These two indications were discovered in the same region ofRCP "A" as the indications discovered in 1989 (Reference 3); furthermore, the 1989 indications appeared to be caused by surface shrinkage during solidification of the pump casting.

The indications discovered back in 1989 were located in groups, and the flaw length ranged from 0.2" to 1.8". The random orientations of the flaws indicated that service conditions due to normal operating plant stresses did not cause the flaws, instead the appearance of the flaws were similar to that resulting from casting process. In 1989, flaw depth measurements were taken by Southwest Research Institute using ultrasonic tip diffraction methods, which provided reasonable size information in the outside surface region (1/16" to 1/2") of the stainless steel casting. Eddy current techniques with capabilities to find flaws 1/8" deep were also used by Cramer & Lindell Engineering, Inc to size the surface flaws detected in 1989. Based on the ultrasonic and eddy current testing, the majority of the flaw depths from 1989 were in the range of 0.1" to 0.2", with the largest flaw depth measured at 0.24" (Reference 3).

Therefore, based on the Point Beach personnel review, the two as-found linear indications which were detected by PT in Fall 2020 are assumed to be small surface indications, similar to the 1989 indications; and, caused by surface shrinkage based on the flaw appearance. Furthermore, these two indications, though not measured by volumetric inspection, are likely to have flaw depths no larger than 0.24", similar to the largest indication detected in 1989.

The indications in 1989 were evaluated based on a detailed finite element stress analysis and fracture mechanics in WCAP-12286 (Reference 4) and [

]a,c,*. Based on the similarities between the 1989 and 2020 flaws, the 1989 fracture mechanics evaluation can be used to provide a flaw assessment of the as-found linear indications from Fall 2020.

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WESTINGHOUSE NON-PROPRIETARY CLASS 3 3

FRACTURE MECHANICS ASSESSMENT LTR-SDA-20-079-NP Revision 0 The fracture mechanics evaluations performed in WCAP-122S6 (Reference 4) with the accompanying detailed pump specific transient stress analysis [

]a,c,e can be utilized to assess the two linear indications detected in Fall 2020. The fracture mechanics evaluation in Reference 4 considered the transient, piping loads, and welding residual stresses analyses as inputs to determine the largest permissible flaw size that is acceptable for continued operation with consideration of fatigue crack growth mechanism. The final results in WCAP-122S6 demonstrated that a 50% through wall flaw would be acceptable and meet the criteria of ASME Section XI for continued operation for a 40-year period. The fracture mechanics evaluation in Reference 4 considered the appropriate ASME Section XI safety margins, stress intensity factor and fatigue crack growth methodologies, along with plant specific fracture toughness, pipe loadings, and transient definition at the time of analysis. This section of the letter report will justify that these inputs and methodologies are still appropriate to evaluate the current as found indications.

Fracture Toughness The as-found flaws are all located in the pump casing, which is fabricated from cast austenitic stainless steel (CASS) material made from SA-351 CFS.

In general, cast stainless product forms exhibit exceptionally high toughness in the as-built condition. However, this material is also susceptible to thermal aging embrittlement due to long-term operation at elevated reactor coolant loop temperatures. Therefore, pump casing made of CASS materials are always part of time limited aging management programs at nuclear power plants.

The fracture mechanics evaluation performed in WCAP-122S6 considered plant specific certified material test reports to determine the lower bound fracture toughness values [

]a,c,e for the material of interest. As discussed previously, pump casings are part of aging management programs; therefore, Point Beach Units 1 and 2 pump casings were recently assessed in LTR-SDA-20-020 (Reference

6) for subsequent license renewal (SLR) application (SO years life). Based on Reference 6, the SA-351 CFS material was reassessed per the latest industry methodology for fracture toughness determination per NUREG/CR-4513, Rev. 1and2 (References 7 & S). Per Table 3 of Reference 6, the J1c and Tmat calculated per the latest methodologies in References 7 and S resulted in higher (better) fracture toughness than the values [

]a,c,e used in WCAP-122S6; therefore, the lower bound fracture toughness used in the fracture mechanics evaluation in Reference 4 are conservative and appropriate for the flaw assessment herein. No additional analysis is necessary to reconcile the fracture toughness properties.

Piping Loads In performing the fracture mechanics analysis for the pump casing, the piping loads and forces imposed on the pump nozzles are considered in the finite element analysis. [

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WESTINGHOUSE NON-PROPRIETARY CLASS 3 LTR-SDA-20-079-NP Revision 0

]a,c,e Therefore, the WCAP-12286 normal and faulted loading at the pump inlet and outlet nozzle are still appropriate and conservative for the assessment of the as-found flaws.

Transients For the fracture and fatigue crack growth analyses, the complete set of design transients and cycles for Point Beach was used as shown in Table 3-1 ofWCAP-12286 (Reference 4). The thermal transient loads, along with thermal and deadweight piping loads, and residual stresses are used in fatigue crack growth evaluations. The latest design transients for the Point Beach 80-year pump casing evaluation are provided in Table 6 ofLTR-SDA-20-020 (Reference 6). The 80 year design transient and cycles from Reference 6 are generally consistent with the transients and cycles used in Table 3-1 of WCAP-12286 (Reference 4 ),

and any minor differences in the cycles will have a negligible impact on the fatigue crack growth results due to the low stresses at the region of concern. Thus, the design transient inputs used in WCAP-12286 are still appropriate for the as-found flaw assessment.

General Fracture Mechanics Methodology ASME Section XI contains evaluation procedures and acceptance criteria for indications in stainless steel piping, but no specific requirements are stated for pump casing. In developing the evaluation for the pump casing in WCAP-12286 (Reference 4), the pipe flaw evaluation procedures ofIWB-3640 for piping were followed with the inclusion of appropriate safety margins for normal and faulted conditions. The margins were applied to the governing normal and faulted conditions stresses where the indications were discovered.

The general fracture mechanics principles of IWB-3640 used in WCAP-12286 for evaluating flaws in stainless steel piping is still consistent with the latest edition of ASME Section XI.

]a,c,e Page 9of12

      • This record was final approved on 1/7/2021 12:50:45 PM. (This statement was added by the PRIME system upon its validation)

WESTINGHOUSE NON-PROPRIETARY CLASS 3 LTR-SDA-20-079-NP Revision 0 The stress intensity factor used in WCAP-12286 was based on industry accepted solutions which are still widely used today; therefore, the methodology for the crack driving force as calculated in Reference 4 is still applicable for the current assessment of flaws.

The general fatigue crack growth correlations used in Section 5 of WCAP-12286 (Reference 4) is for stainless steel material exposed to air environment, and this crack growth rate is still consistent with the latest edition of ASME Section XI (Reference 2). Therefore, the transients, loadings, and methodology used in the fatigue crack growth analysis in WCAP-12286 are still appropriate for use in the evaluation of the current as found flaws in the Fall 2020 outage.

The conclusions from WCAP-12286 stated that a postulated flaw with a depth that is 50% through the wall thickness (with an aspect ratio of20:1, flaw length/flaw depth), will be acceptable for more than 40 years of plant life. Per LTR-SDA-20-020 (Reference 6), the transient definitions and cycles for 60 years and 80 years are still consistent with the original 40 year design transients, in WCAP-12286, with consideration of uprates. Therefore, the fatigue crack growth results from WCAP-12286 are applicable for the current license of 60 years and for any future extension to 80 year of plant life. [

]a,c,e Also per LTR-SDA-20-020 (Reference 6), a separate fracture mechanics evaluation was performed to assess the thermal aging embrittlement of pump casings for Point Beach. The analysis in Reference 6 postulated 25% through-wall flaws (with aspect ratio of 6:1) [

]a,c,e were concluded to be acceptable for 80 years of total service life.

The two linear indications from Fall 2020 have as-measured flaw lengths of 1.0 and 1.875", along with an assumed flaw depth of no more than 0.24" (based on the largest flaw depth sized in 1989). The as-found flaws are in a region of the pump casing [

]a,c,e and is much less than the 50% and 25% through-wall flaws postulated in WCAP-12286 and LTR-SDA-20-020.

As a result, the as-found linear indications found by PT during Fall 2020 outage will be acceptable, without any need for repair, for the current plant life of 60 years (and also for 80 year life if granted second license renewal). Please note that this location should follow the requirements of successive examinations per IWB-2420(b ), which requires that the areas containing flaws or relevant conditions shall be reexamined during the next three inspection periods listed in the schedule of the Inspection Program.

Lastly, based on WCAP-12286, it was also concluded that the flaw evaluation methodology used in that report is also applicable to the other reactor coolant pump casings in Unit 1 and to all the casings in Unit 2, should similar indications be found in the same region.

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      • This record was final approved on 1/7/2021 12:50:45 PM. (This statement was added by the PRIME system upon its validation)

WESTINGHOUSE NON-PROPRIETARY CLASS 3 4

SUMMARY

AND CONCLUSION LTR-SDA-20-079-NP Revision 0 During the Fall 2020 inservice inspection of the pump casing integrally welded attachment (ASME Section XI B-K category), two linear indication were discovered based on PT examination. These indications were unacceptable based on the Section XI IWB-3 516 and IWB-3519 acceptance standards. Therefore, an ASME Section XI IWB-3600 fracture mechanics assessment, based on previous bounding analyses (References 3

& 4), was considered in this repo1i to justify leaving the indications as-is without repair.

The linear indications have a maximum flaw length of 1.875"; however, no flaw depth was available since a volumetric examination was not performed. However, these indications were similar in appearance and within the same vicinity as compared to the linear indications found this pump in 1989 (Reference 3). Thus, the depths of the flaws detected in Fall 2020 are likely to be no greater than 0.24" based on the indications detected and sized in 1989. It should be noted that both the 1989 and the Fall 2020 flaw orientation are indicative of surface shrinkage due to the casting process, based on the Point Beach site review.

A previous flaw evaluation of as-found flaws at Point Beach Unit 1 RCP "A" had been performed in early 1990 in WCAP-12286 (Reference 4) which demonstrated acceptability of flaws up to 50% through-wall.

Furthermore, a more recent thermal aging embrittlement fracture mechanics evaluation was performed in LTR-SDA-20-020 (Reference 6) this year to support the subsequent license renewal program for Point Beach Units 1 and 2 RCP casing. The evaluation in LTR-SDA-20-020 demonstrated acceptance of 25%

through-wall flaws. Both the WCAP-12286 and LTR-SDA-20-020 reports demonstrate the acceptability of the current as-found indications detected during fall 2020 outage. Based on the fracture mechanics results in WCAP-12286, it was concluded that a postulated flaw depth of 50% of the wall thickness is acceptable for 40 years of plant life. The current as-found flaws are likely to have flaw depth of no greater than approximately [

y.c,e based on sizing data from the flaws detected in 1989 and are much shallower than the 50% and 25%

postulated through-wall flaws evaluated in WCAP-12286 and LTR-SDA-20-020. Thus, the as-found linear indications are acceptable for the current 60 year life of the plant (and for 80 years per second license renewal) per an ASME Section XI fracture mechanics assessment. Thus, no repair of the indication is needed at this time. These indications should follow the requirements of successive examinations per IWB-2420(b ), which requires that the areas containing flaws or relevant conditions shall be reexamined during the next three inspection periods listed in the schedule of the Inspection Program.

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      • This record was final approved on 1/7/2021 12:50:45 PM. (This statement was added by the PRIME system upon its validation)

WESTINGHOUSE NON-PROPRIETARY CLASS 3 5

REFERENCES LTR-SDA-20-079-NP Revision 0

1. Point Beach Report, RCP-A-1-IWA, "Point Beach Nuclear Plant Visible Liquid Penetrant Examination Record, Integrally Welded Attachment," Work Order Number: 40667619-01, Sheet Number: ABM450.1. October 15, 2020.
2. ASME Boiler and Pressure Vessel Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," 2007 Edition with 2008 Addendum.
3. Point Beach Report, NPC-47876, "Report of Unit 1 Reactor Coolant Pump A Flaw Evaluations."

Kohlwey, J.F., and Sherwood, G.R.

4. WCAP-12286, "Evaluation of Indications found in the Pump Casing of Point Beach Unit 1,"

January 1990. Bamford, W. H., Witt, F. J. (Westinghouse Class 2 Proprietary).

5.

]a,c,e

6. LTR-SDA-20-020-NP, Revision 1, "Point Beach Units 1 and 2 Reactor Coolant Pump Casings ASME Code Case N-481 Analysis for 80-year Subsequent License Renewal (SLR)," July 2020.
7. NUREG/CR-4513 ANL-93/22, Rev. 1, "Estimation of Fracture Toughness of Cast Stainless Steels During Thermal Aging in LWR Systems," August, 1994.
8. NUREG/CR-4513 ANL-15/08, Rev. 2, "Estimation ofFracture Toughness of Cast Stainless Steels During Thermal Aging in L WR Systems," May, 2016.

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      • This record was final approved on 1n12021 12:50:45 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Affidavit (3 pages follow)

Westinghouse Non-Proprietary Class 3 COMMONWEALTH OF PENNSYL VANlA:

COUNTY OF BUTLER:

CA W-21-5139 Page 1 of3 (1)

I, Korey L. Hosack, have been specifically delegated and authorized to apply for withholding and execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse).

(2)

I am requesting the proprietary portions ofLTR-SDA-20-079-P be withheld from public disclosure under 10 CFR 2.390.

(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 10 CFR 2.390, 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 and is not customarily disclosed to the public.

(ii)

The information sought to be withheld is being transmitted to the Commission in confidence and, to Westinghouse's knowledge, is not available in public sources.

(iii)

Westinghouse notes that a showing of substantial harm is no longer an applicable criterion for analyzing whether a document should be withheld from public disclosure. Nevertheless, 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

Westinghouse Non-Proprietary Class 3 CA W-21-5139 Page 2 of3 others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

(5)

Westinghouse has policies in place to identify proprietary information. 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 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.

Westinghouse Non-Proprietary Class 3 CA W-21-5139 Page 3 of3 (6)

The attached documents are bracketed and marked to indicate the bases for withholding. The justification for withholding is indicated in both versions by means oflower-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 (5)(a) through (f) of this Affidavit.

I declare that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on: 2021 01 07 Korey L. Hosack, Manager Licensing, Analysis, & Testing

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