View source for CNL-17-062, Response to Request for Additional Information Related to License Amendment Request to Revise Technical Specifications Regarding Ice Condenser Containment Ice Mass Requirements

{{Adams
| number = ML17139C939
| issue date = 05/19/2017
| title = Response to Request for Additional Information Related to License Amendment Request to Revise Technical Specifications Regarding Ice Condenser Containment Ice Mass Requirements
| author name = Shea J
| author affiliation = Tennessee Valley Authority
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000391
| license number = NPF-096
| contact person = 
| case reference number = CAC MF8993, CNL-17-062
| package number = ML17139C937
| document type = Letter type:CNL, Response to Request for Additional Information (RAI)
| page count = 22
| project = CAC:MF8993
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:Proprietary Information Withhold from Public Disclosure Under 10 CFR &sect; 2.390 This letter is decontrolled when separated from Enclosure 1.
Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-17-062 May 19, 2017 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Watts Bar Nuclear Plant, Unit 2 Facility Operating License No. NPF-96 NRC Docket No. 50-391

==Subject:==
Response to Request for Additional Information Related to License Amendment Request to Revise Technical Specifications Regarding Ice Condenser Containment Ice Mass Requirements for Watts Bar Nuclear Plant, Unit 2 (CAC No. MF8993)

==Reference:==
: 1. TVA Letter to NRC, CNL-16-192, Application to Modify the Watts Bar Nuclear Plant Unit 2 Ice Mass Limit in Technical Specification Surveillance Requirements 3.6.11.2 and 3.6.11.3 (WBN-TS-16-026),
dated December 21, 2016 (ML16356A673)
: 2. NRC Electronic Mail to TVA, Watts Bar, Unit 2 - Final Request for Additional Information Concerning Request to Amend Ice Mass Surveillance Requirements (CAC No. MF8993), dated April 7, 2017 (ML17100A107)
In Reference 1, Tennessee Valley Authority (TVA) submitted a request for an amendment to the Watts Bar Nuclear Plant (WBN) Unit 2 Technical Specifications (TS) to revise the WBN Unit 2 ice mass limits in TS Surveillance Requirements (SRs) 3.6.11.2 and 3.6.11.3 to be identical to the ice mass limits in the WBN Unit 1 TS SRs 3.6.11.2 and 3.6.11.3. In Reference 2, the Nuclear Regulatory Commission (NRC) transmitted a request for additional information (RAI). provides the TVA response to the RAI. These responses do not change the no significant hazards considerations determination contained in Reference 1. contains information proprietary to Westinghouse Electric Company and is indicated by bold brackets. Enclosure 2 contains a non-proprietary version of the RAI responses.

U.S. Nuclear Regulatory Commission CNL-17-062 Page 2 May 19, 2017 The proprietary information is supported by an affidavit signed by Westinghouse, the owner of the information (Enclosure 3) . The affidavit sets forth the basis on which the information should be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR 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 2.390 of the Commission 's regulations . Correspondence with respect to the copyright or proprietary aspects of the technical support document or the supporting Westinghouse affidavit should reference CAW-17-4576 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.
There are no new regulatory commitments associated with this submittal. Please address any questions regarding this response to Ed Schrull at 423-751-3850.
I declare under penalty of perjury that the foregoing is true and correct. Executed on this 19th day of May 2017.
4~tv J. W . Shea Vice President, Nuclear Licensing

==Enclosures:==
: 1. Response to Request for Additional Information Related to License Amendment Request to Revise Technical Specifications Regarding Ice Condenser Containment Ice Mass Requirements for Watts Bar Nuclear Plant, Unit 2 (CAC No. MF8993) (Proprietary)
: 2. Response to Request for Additional Information Related to License Amendment Request to Revise Technical Specifications Regarding Ice Condenser Containment Ice Mass Requirements for Watts Bar Nuclear Plant, Unit 2 (CAC No. MF8993) (Non-Proprietary)
: 3. Westinghouse Affidavit CAW-17-4576 Supporting Enclosure 1 cc (Enclosures)
NRC Regional Administrator - Region II NRC Senior Resident Inspector - Watts Bar Nuclear Plant NRR Project Manager - Watts Bar Nuclear Plant

  .Proprietary Information Withhold from Public Disclosure Under 10 CFR &sect; 2.390 Enclosure 1 Response to Request for Additional Information Related to License Amendment Request to Revise Technical Specifications Regarding Ice Condenser Containment Ice Mass Requirements for Watts Bar Nuclear Plant, Unit 2 (CAC No. MF8993)
(Proprietary)
CNL-17-062 Proprietary Information Withhold from Public Disclosure Under 10 CFR &sect; 2.390

Enclosure 2 Response to Request for Additional Information Related to License Amendment Request to Revise Technical Specifications Regarding Ice Condenser Containment Ice Mass Requirements for Watts Bar Nuclear Plant, Unit 2 (CAC No. MF8993)
(Non-Proprietary)
CNL-17-062

Enclosure 2 Response to Request for Additional Information Related to License Amendment Request to Revise Technical Specifications Regarding Ice Condenser Containment Ice Mass Requirements for Watts Bar Nuclear Plant, Unit 2 (CAC No. MF8993)
Nuclear Regulatory Commission (NRC) Introduction By letter dated December 21, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML16356A673), Tennessee Valley Authority (TVA),
the licensee, submitted a License Amendment Request (LAR) for Watts Bar Nuclear Plant (WBN), Unit 2. The proposed change would revise the ice mass limits in Technical Specification (TS) Surveillance Requirements (SRs) as follows:
* Revise SR 3.6.11.2 to change the total weight of stored ice from greater than or equal to
() 2,750,700 pounds (lb) to 2,404,500 lb.
* Revise SR 3.6.11.2 to change the ice limit of each basket from 1,415 lb to 1,237 lb.
* Revise SR 3.6.11.3 to change the average ice weight of the sample baskets from 1,415 lb to 1,237 lb.
After reviewing the LAR, the Reactor Systems Branch (SRXB) staff is requesting responses to the following Requests for Additional Information (RAIs) to complete its review:
NRC Request for Additional Information (RAI) SRXB-RAI 1 WCAP-17721-P-A, Table 4-1, item 7, regarding reactor internals heat transfer, under the heading Sources of Energy, 10 CFR 50, Appendix K, I.A states:
Reactor Internals Heat Transfer - Heat transfer from piping, vessel walls, and non-fuel internal hardware shall be taken into account.
The hot metal in the reactor coolant system consists of the reactor vessel, reactor internals, reactor coolant system piping and all other non-fuel metal hardware. Tables 1 and 2 of the LAR do not provide a comparison of the mass and the material properties of the following parameters for WBN Units 1 and 2 which would affect the mass and energy (M&E) release to the containment: (a) reactor internals, (b) reactor vessel, (c) reactor coolant system (RCS) piping, and (d) RCS fluid. Provide a quantitative comparison of mass and material properties (density, specific heat, and thermal conductivity) of items (a) through (c), and mass of item (d) for WBN Units 1 and 2, and justify that the WBN Unit 1 loss-of-coolant accident (LOCA) containment M&E release from these items is bounding for WBN Unit 2.
TVA Response:
Tables 1 through 4 of this RAI response provide the requested information. Specifically, Table 1 provides the quantitative comparison of mass and material properties of the reactor internals, reactor vessel, and RCS piping. The materials of construction for the reactor internals, reactor vessel, and RCS piping for WBN Units 1 and 2 are identical. As shown in Table 1, these components are made of stainless steel, with the exception of the vessel shell, which is carbon steel. Table 2 provides a comparison of the densities for carbon steel and stainless steel. Tables 3 and 4 provide the comparison of the specific heat (Cp) and CNL-17-062                                   E2-1 of 10

Enclosure 2 thermal conductivity (Tc) for carbon steel and stainless steel, respectively. The following paragraphs provide further information regarding Tables 1 through 4 including the requested mass of the RCS fluid for WBN Units 1 and 2, and the justification that the WBN Unit 1 LOCA containment M&E release from these items is bounding for WBN Unit 2.
Table 1 below provides the requested comparison between WBN Unit 1 and Unit 2 metal mass and fluid volume not including the different steam generator designs. The WBN Unit 1 metal mass and fluid volume column data are the values used in the Unit 1 WCOBRA/TRAC LOCA M&E analysis. The Difference columns provide the delta, if any, when compared to WBN Unit 2. A detailed examination of the data used to build the WCOBRA/TRAC models (e.g., drawings, component databases) showed that the only significant difference in the vessel region was related to the metal mass of the internals. Small design differences in the lower internals, such as instrumentation and energy absorbers, indicate that there is 861 lbm more metal in the WBN Unit 2 vessel internals. However, because the vessel shells are the same, this results in the WBN Unit 2 vessel having 1.72 ft3 less fluid volume.
These differences represent negligible differences compared to the total RCS metal mass of 1.72E+6 lbm and fluid mass of 339,000 lbm (approximately 7850 ft3) not including the steam generators.
Comparisons of as-built data regarding loop piping construction indicate that there is little difference between WBN Unit 1 and Unit 2 and that the pipe diameters and thicknesses are the same. Any difference in metal or fluid volume is typically due to small variations such as allowances for field welds (fractions of an inch). The crossover leg piping comparison did identify piping length differences of up to 1.125 between the two units. These differences are negligible because there is over 280 ft. of RCS piping. The casing and impeller for the reactor coolant pumps (RCPs) were verified to be the same as well, so the metal energy and fluid volume associated with the RCPs are the same between Unit 1 and Unit 2.
Tables 3 and 4 provide thermal conductivity and heat capacity as a function of temperature for the WCOBRA/TRAC structural materials. These values were based on Reference 1.
The heat capacity was calculated based on nominal properties and increased by 10 percent
(%) to account for uncertainty. The thermal conductivity reported in Tables 3 and 4 was increased by 10% to account for uncertainty. The densities in Table 2 were obtained from Table PRD of Reference 1.
In conclusion, the hot metal mass of 1.72E+6 lbm (not including the steam generators, which are different for WBN Units 1 and 2), hot RCS fluid volume of 7850 ft3 (not including the steam generators), and conservative material properties are applicable to both WBN Unit 1 and Unit 2. Therefore, the WBN Unit 1 RSG LOCA M&E calculation is bounding with respect to WBN Unit 2.
CNL-17-062                                    E2-2 of 10

Enclosure 2 Table 1: Summary Table of Differences between WBN Unit 1 and Unit 2 Material      Unit 1 Metal      Difference in      Unit 1 Fluid    Difference in Fluid Component Modelled        Mass (lbm)     Metal Mass (lbm)     Volume (ft&#xb3;)        Volume (ft&#xb3;)
(1)
Vessel Shell        Carbon Steel       686,039            None               4653                -1.72 Stainless                                                    (2)               (1)
Vessel Internals                        544,958             +861             None                None Steel Stainless                                (1)
Hot Leg Piping                           15,625            None                 80               None (1)
Steel Crossover Leg          Stainless 26,269            None (1)            143               None (1)
Piping               Steel Stainless Cold Leg Piping                          23,638            None (1)            108               None (1)
Steel Pressurizer and        Stainless 185,611            None (1)           1,902              None (1)
Surge Line             Steel Stainless Pump                                53,923            None (1)             83               None (1)
Steel Notes:
: 1. Differences are not significant enough to affect the model.
: 2. Vessel Internals are pieces of equipment within the vessel that do not have a fluid volume associated with them. The difference in metal mass is accounted for the reduction in fluid volume identified with the vessel shell. These differences are explained in detail in the RAI response.
Table 2: Densities Material                                       Density (lbm/ft&#xb3;)
Carbon Steel                                              484 Stainless Steel                                            501 CNL-17-062                                        E2-3 of 10

Enclosure 2 Table 3: Carbon Steel Material Properties Cp               TC                               Cp            TC Temperature (&deg;F) (BTU/lbm-&deg;F)   (BTU/hr-ft-&deg;F)  Temperature (&deg;F)   (BTU/lbm-&deg;F) (BTU/hr-ft-&deg;F) 70            0.117            30.0              100            0.121         30.4 150            0.126            30.6              200            0.130         30.6 250            0.134            30.4              300            0.137         30.0 350            0.140            29.6              400            0.142         29.2 450            0.145            28.7              500            0.148         28.3 550            0.151            27.8              600            0.154         27.4 650            0.157            27.0              700            0.161         26.5 Table 4: Stainless Steel Material Properties Cp               TC                               Cp              TC Temperature (&deg;F) (BTU/lbm-&deg;F)   (BTU/hr-ft-&deg;F)  Temperature (&deg;F)   (BTU/lbm-&deg;F)  (BTU/hr-ft-&deg;F) 70            0.129             9.0              100            0.130            9.1 150            0.133             9.5              200            0.134            9.7 250            0.137            10.0              300            0.137           10.2 350            0.138            10.5              400            0.140           10.8 450            0.141            11.0              500            0.142           11.2 550            0.144            11.6              600            0.145           11.8 650            0.146            12.0              700            0.147           12.3 CNL-17-062                                 E2-4 of 10

Enclosure 2 NRC SRXB-RAI 2 Describe the modelling of the main steam isolation valves (MSIVs) for WBN Unit 1 with respect to: (a) the starting time to close after event initiation, and (b) valve-specific time to fully close. In the event that items (a) and (b) differ between WBN Units 1 and 2 due to differences in valve characteristics, different valve manufacturers, or both, provide a comparison of items (a) and (b) for WBN Units 1 and 2, and justify that the WBN Unit 1 M&E release based on these items would be bounding for Unit 2.
TVA Response The MSIVs are assumed to [
              ]   Therefore, the NRC requested information is not applicable. This modeling approach is consistent with the methodology documented in Item 15 of Section 4.1 of WCAP-17721-P-A and reiterated in Section 3.3.1.8 of the NRC Safety Evaluation Report (Reference 2).
NRC SRXB-RAI 3 In its letter to NRC dated September 11, 2015, Notification of Revised Westinghouse Containment Integrity Analysis, (ADAMS Accession No. ML15254A564), Enclosure 1, Section 1, TVA stated that the LOTIC1 ice condenser containment code, documented in WCAP-8354-P-A, was used to calculate the LOCA containment response for WBN Unit 1.
NRC has received the following information in a letter from Westinghouse regarding WCAP-8354-P-A (proprietary) and WCAP-8355-A (non-proprietary), Long Term Ice Condenser Containment Code - LOTIC Code:
A source code inspection revealed that the lower compartment conditions are not included until the end of the depressurization period. It has been determined that the affected portion of the transient is very short, and including the lower compartment conditions in the calculation would have a negligible impact on calculated containment conditions. Code updates regarding this issue would provide no improved transient behavior or influence on the limiting time of the event nor increase in nuclear safety.
CNL-17-062                                      E2-5 of 10

Enclosure 2 The above Westinghouse letter provides the following change in Section 5.2, page 5.2-6 of WCAP-8354-P-A and WCAP-8355-A for the calculation of the containment pressure profile during the phase between the end of blowdown and the establishment of recirculation:
FROM
[1] If the expanding volume is smaller than the lower compartment volume, the system pressure calculation is based on the upper compartment and the ice-filled part of the ice compartment.
[2] If the expanding volume occupies the lower compartment, the pressure calculation then includes the lower compartment conditions.
[3] If the expanding volume fills the lower compartment and the ice-empty part of the ice compartment, this calculation period is terminated.
TO
[1] If the expanding volume is smaller than the lower compartment volume and ice-empty part of the ice compartment, the system pressure calculation is based on the upper compartment and the ice-filled part of the ice compartment.
[2] If the expanding volume occupies the lower compartment, the pressure calculation then includes the lower compartment conditions.
[3] If the expanding volume fills the lower compartment and the ice-empty part of the ice compartment, this calculation period is terminated.
Westinghouse did not provide a quantitative basis for its determination that the changes to correct the discrepancy between the description of the methodology and its implementation in the LOTIC code would have a negligible impact on the calculated containment response.
Therefore, the NRC staff requests the following for Watts Bar Units 1 and 2:
(a) The addition of ice-empty part of the ice compartment in item [1] above appears to be a significant change in the total volume (lower compartment volume + ice-empty volume) which is compared with the expanding volume, because the ice-empty volume varies from zero (or a small volume) to the full volume of the ice-compartment during the depressurization phase. Provide a quantitative impact of this change on the entire pressure response, including the peak pressure, by performing a sensitivity analysis for WBN Unit 1, and provide justification that the results apply to Unit 2.
(b) Describe the impact on the WBN, Units 1 and 2, containment pressure, containment temperature, and sump temperature responses and their peak values due to the deletion of item [2] If the expanding volume occupies the lower compartment, the pressure calculation then includes the lower compartment conditions, and provide quantitative results.
CNL-17-062                                     E2-6 of 10

Enclosure 2 TVA Response A temporary version of the LOTIC1 code was created to model the treatment of the lower compartment volume as it is currently described in WCAP-8354-P-A. The lower compartment conditions were considered in the system pressure calculation of this temporary LOTIC1 code version after the air bubble had expanded to fill the lower compartment. The current WBN Unit 1 containment model input deck for the peak pressure case was used with this temporary LOTIC1 code version to generate a transient pressure response for a sensitivity comparison with the current base case analysis. The following paragraph responds to the information requested in items (a) and (b) of the RAI.
The calculated peak pressure from the base case analysis is 9.36 psig. The calculated peak pressure from the sensitivity case is 9.39 psig, which is only 0.03 psi higher. TVA considers this delta in the peak pressure to be negligible with respect to the entire pressure response. There were no changes to the peak lower compartment and sump temperatures due to the temporary code version. The peak upper compartment air temperature decreased by less than 0.5&deg;F. A comparison of the transient containment pressure, temperature, and sump temperature results for the two cases is shown in Figures 1 through 4 below.
Figure 1 - Containment Pressure Comparison CNL-17-062                                   E2-7 of 10

Enclosure 2 Figure 2 - Upper Compartment Temperature Comparison Figure 3 - Lower Compartment Temperature Comparison CNL-17-062                        E2-8 of 10

Enclosure 2 Figure 4 - Active Sump Temperature Comparison CNL-17-062                      E2-9 of 10

Enclosure 2 References
: 1. 2010 ASME Boiler and Pressure Vessel Code, Section II - Materials, Part D Properties
: 2. NRC Letter to Westinghouse Electric Company, Final Safety Evaluation for Westinghouse Electric Company (Westinghouse) Topical Report (TR) WCAP-17721-P, Revision 0, and WCAP-17721-NP, Revision 0, Westinghouse Containment Analysis Methodology - PWR [Pressurized Water Reactor] LOCA [Loss-of-Coolant Accident]
Mass and Energy Release Calculation Methodology, dated August 24, 2015 (ML15221A005)
CNL-17-062                              E2-10 of 10

Enclosure 3 Westinghouse Affidavit CAW-17-4576 Supporting Enclosure 1 CNL-17-062

Westinghouse Non-Proprietary Class 3
@ Westinghouse                                                                Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission                                Direct tel: (412) 374-4643 Document Control Desk                                            Direct fax: (724) 940-8560 115 55 Rockville Pike                                                e-mail: greshaja@westinghouse.com Rockville, MD 20852 CAW-17-4576 May 4, 2017 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

==Subject:==
L TR-CRA-17-50, Attachment 1, "Response to Request for Additional Information Related to License Amendment Request to Revise Technical Specifications Regarding Ice Condenser Containment Ice Mass Requirements for Watts Bar Nuclear Plant, Unit 2" (CAC No. MF8993)
(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 Nuclear Regulatory Commission's ("Commission's") regulations. It contains commercial strategic information proprietary to Westinghouse and customarily held in confidence.
The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CA W-17-4576 signed by the owner of the proprietary information, Westinghouse. 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 Tennessee Valley Authority (TVA).
Correspondence with respect to the proprietary aspects of the Application for Withholding or the Westinghouse Affidavit should reference CA W-17-4576, 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.
la~~Man:er Regulatory Compliance
                       &#xa9; 2017 Westinghouse Electric Company LLC. All Rights Reserved.

CAW-17-4576 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 declare that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief.
Executed on:  _sf~1'-"'"}_1~7__                          Md. -
                                                       '1aITWsA.. Gresham, Manager Regulatory Compliance

3                                     CAW-17-4576 (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 Nuclear Regulatory Commissions (Commissions) 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 Commissions 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

4                                       CAW-17-4576 Westinghouses 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.

5                                     CAW-17-4576 (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, 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 LTR-CRA-17-50, Revision 0, Attachment, Response to Request for Additional Information Related to License Amendment Request to Revise Technical Specifications Regarding Ice Condenser Containment Ice Mass Requirements for Watts Bar Unit 2 (Proprietary), for submittal to the Commission, being transmitted by TVA letter. The proprietary information as submitted by Westinghouse is that associated with Response to Request for Additional Information Related to License Amendment Request to Revise Technical Specifications Regarding Ice Condenser containment ice mass requirements, and may be used only for that purpose.
(a)      This information is part of that which will enable Westinghouse to protect the proprietary WCOBRA\TRAC application.

6                                    CAW-17-4576 (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 mass and energy release determination.
(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 are proprietary and non-proprietary versions of a document, 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 Commissions 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.}}