View source for CNL-23-044, Transmittal of Revision 3 to WCAP-18774-P and WCAP-18774-NP, Addendum to the Rotterdam Dockyard Company Final Stress Report for 173 P.W.R. Vessels TVA III & IV (Report No. 30749-B-030, Rev. 3) - Evaluation of One Closure Stud Out

{{Adams
| number = ML23152A150
| issue date = 06/01/2023
| title = Transmittal of Revision 3 to WCAP-18774-P and WCAP-18774-NP, Addendum to the Rotterdam Dockyard Company Final Stress Report for 173 P.W.R. Vessels TVA III & IV (Report No. 30749-B-030, Rev. 3) - Evaluation of One Closure Stud Out
| author name = Hulvey K
| author affiliation = Tennessee Valley Authority
| addressee name = 
| addressee affiliation = NRC/NRR, NRC/Document Control Desk
| docket = 05000390
| license number = 
| contact person = 
| case reference number = CNL-23-044, EPID L-2023-LLA-0064)
| document report number = WCAP-18774-P, Rev 3
| package number = ML23152A149
| document type = Legal-Affidavit, Letter type:CNL, Topical Report
| page count = 1
| project = EPID:L-2023-LLA-0064
| stage = Request
}}

=Text=
{{#Wiki_filter:Proprietary Information - Withhold Under 10 CFR &sect; 2.390 This letter is decontrolled when separated from Enclosure 1 1101 Market Street, Chattanooga, Tennessee 37402 CNL-23-044 June 1, 2023 10 CFR 50.4 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 0001 Watts Bar Nuclear Plant, Unit 1 Facility Operating License No. NPF-90 NRC Docket No. 50-390

==Subject:==
Transmittal of Revision 3 to WCAP-18774-P and WCAP-18774-NP, Addendum to the Rotterdam Dockyard Company Final Stress Report for 173" P.W.R. Vessels TVA III & IV (Report No. 30749-B-030, Rev. 3) -
Evaluation of One Closure Stud Out of Service for 40 Years for Watts Bar Units 1 and 2 (EPID L-2023-LLA-0064)

==References:==
: 1. TVA letter to NRC, CNL-23-043, Watts Bar Nuclear Plant, Unit 1 -
Emergency License Amendment Request to Relax the Required Number of Fully Tensioned Reactor Pressure Vessel Head Closure Studs in Technical Specification Table 1.1-1, MODES (WBN-TS-23-09), dated May 4, 2023 (ML23124A403 and ML23124A404)
: 2. NRC letter to TVA, Watts Bar Nuclear Plant, Unit 1 - Issuance of Amendment No. 161 Regarding a One-Time Use Change to Footnotes Applicable to Technical Specification Table 1.1-1 Modes (Emergency Circumstances) (EPID L-2023-LLA-0064), dated May 5, 2023 (ML23125A220)
In Reference 1, Tennessee Valley Authority (TVA) submitted a request for a one-time emergency license amendment request (LAR) to Facility Operating License No. NPF-90 for the Watts Bar Nuclear Plant (WBN), Unit 1, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.91(a)(5). Reference 1 was approved by the Nuclear Regulatory Commission (NRC) in Reference 2. to Reference 1 contained Westinghouse Electric Company LLC (Westinghouse)
WCAP-18774-P, Revision 1, Addendum to the Rotterdam Dockyard Company Final Stress Report for 173" P.W.R. Vessels TVA III & IV (Report No. 30749-B-030, Rev. 3) - Evaluation of One Closure Stud Out of Service for 40 Years for Watts Bar Units 1 and 2. Due to the emergent nature of the Reference 1 LAR, Enclosure 2 to Reference 1 was submitted as a proprietary document in its entirety. However, as noted in Reference 1, TVA stated it would Proprietary Information - Withhold Under 10 CFR &sect; 2.390 This letter is decontrolled when separated from Enclosure 1

Proprietary Information - Withhold Under 10 CFR &sect; 2.390 This letter is decontrolled when separated from Enclosure 1 U.S. Nuclear Regulatory Commission CNL-23-044 Page 2 June 1, 2023 submit a revision of WCAP-18774-P with revised proprietary markings and an associated non-proprietary version within 30 days following NRC approval of the Reference 1 LAR.
Accordingly, Enclosure 1 to this submittal contains WCAP-18774-P, Revision 3, Addendum to the Rotterdam Dockyard Company Final Stress Report for 173" P.W.R. Vessels TVA III
& IV (Report No. 30749-B-030, Rev. 3) - Evaluation of One Closure Stud Out of Service for 40 Years for Watts Bar Units 1 and 2. Enclosure 1 contains information that Westinghouse considers to be proprietary in nature pursuant to 10 CFR 2.390, "Public inspections, exemptions, requests for withholding," paragraph (a)(4). Enclosure 2 contains a non-proprietary version of Enclosure 1. provides the Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-23-019 affidavit supporting this proprietary withholding request.
The affidavit sets forth the basis on which the information may be withheld from public disclosure by the NRC and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390. Accordingly, TVA requests that the information, which is proprietary to Westinghouse, be withheld from public disclosure in accordance with 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-23-019 and should be addressed to Camille T. Zozula, Manager, Regulatory Compliance &
Corporate Licensing.
There are no new regulatory commitments contained in this letter. Please address any questions regarding this submittal to Stuart L. Rymer, Senior Manager, Fleet Licensing, at slrymer@tva.gov.
Respectfully, Digitally signed by Edmondson, Carla Date: 2023.06.01 11:47:42 -04'00' Kimberly D. Hulvey Director, Nuclear Regulatory Affairs

==Enclosures:==
: 1.      WCAP-18774-P, Revision 3 (Proprietary)
: 2.      WCAP-18774-NP, Revision 3 (Non-Proprietary)
: 3.      Westinghouse Electric Company LLC Application for Withholding Proprietary Information from Public Disclosure (Affidavit CAW-23-019) cc: See Page 3 Proprietary Information - Withhold Under 10 CFR &sect; 2.390 This letter is decontrolled when separated from Enclosure 1

Proprietary Information - Withhold Under 10 CFR &sect; 2.390 This letter is decontrolled when separated from Enclosure 1 U.S. Nuclear Regulatory Commission CNL-23-044 Page 3 June 1, 2023 cc (Enclosures):
NRC Regional Administrator - Region II NRC Senior Resident Inspector - Watts Bar Nuclear Plant NRC Project Manager - Watts Bar Nuclear Plant Director, Division of Radiological Health - Tennessee State Department of Environment and Conservation Proprietary Information - Withhold Under 10 CFR &sect; 2.390 This letter is decontrolled when separated from Enclosure 1

Proprietary Information - Withhold Under 10 CFR &sect; 2.390 Enclosure 1 WCAP-18774-P, Revision 3 (Proprietary)
CNL-23-044 Proprietary Information - Withhold Under 10 CFR &sect; 2.390

Enclosure 2 WCAP-18774-NP, Revision 3 (Non-Proprietary)
CNL-23-044

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*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
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*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
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*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
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*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
*** This record was final approved on 5/31/2023, 11:14:41 AM. (This statement was added by the PRIME system upon its validation)
Enclosure 3 Westinghouse Electric Company LLC Application for Withholding Proprietary Information from Public Disclosure (Affidavit CAW-23-019)
CNL-23-044

Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-23-019 Page 1 of 3 Commonwealth of Pennsylvania:
County of Butler:
(1)        I, Zachary Harper, Manager, Licensing Engineering, 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 of WCAP-18774-P, Revision 3, Addendum to the Rotterdam Dockyard Company Final Stress Report for 173" P.W.R. Vessels TVA III & IV (Report No. 30749-B-030, Rev. 3) - Evaluation of One Closure Stud Out of Service for 40 Years for Watts Bar Units 1 and 2, 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 Westinghouses 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 others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.
 *** This record was final approved on 5/31/2023, 1:16:59 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-23-019 Page 2 of 3 (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.
(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 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 (5)(a) through (f) of this Affidavit.
 *** This record was final approved on 5/31/2023, 1:16:59 PM. (This statement was added by the PRIME system upon its validation)

Westinghouse Non-Proprietary Class 3 AFFIDAVIT CAW-23-019 Page 3 of 3 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: 5/31/2023                                      _____________________________
Signed electronically by Zachary Harper
 *** This record was final approved on 5/31/2023, 1:16:59 PM. (This statement was added by the PRIME system upon its validation)}}