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Revision as of 04:04, 3 April 2018

Peach Bottom, Units 2 and 3 - Extended Power Uprate License Amendment Request - Supplement 21 Response to Request for Additional Information
ML14070A142
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 02/28/2014
From: Lambert C W
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CAW-14-3909, CAW-14-3910, CAW-14-3914, CAW-14-3915, CAW-14-3920, TAC ME9631, TAC ME9632
Download: ML14070A142 (158)
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A ExeLon Generation.PROPRIETARY INFORMATION -WITHHOLD UNDER 10 CFR 2.39010 CFR 50.9010 CFR 2.390February 28, 2014U. S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001Peach Bottom Atomic Power Station, Units 2 and 3Renewed Facility Operating License Nos. DPR-44 and DPR-56NRC Docket Nos. 50-277 and 50-278Subject:Reference:Extended Power Uprate License Amendment Request -Supplement 21Response to Request for Additional Information1. Exelon letter to the NRC, "License Amendment Request -ExtendedPower Uprate," dated September 28, 2012 (ADAMS Accession No.ML122860201)2. NRC letter to Exelon, "Request for Additional Information RegardingLicense Amendment Request for Extended Power Uprate (TAC Nos.ME9631 and ME9632)," dated October 1, 2013 (ADAMS Accession No.ML13268A263)3. Exelon Letter to NRC, "Extended Power Uprate License AmendmentRequest -Supplement 14, Response to Request for AdditionalInformation," dated October 31, 2013 (ADAMS Accession No.ML13308A331)4. Exelon Letter to NRC, "Extended Power Uprate License AmendmentRequest -Supplement 15, Response to Request for AdditionalInformation," dated December 6, 2013 (ADAMS Accession No.M L13345A687)5. NRC letter to Exelon, "Request for Additional Information RegardingLicense Amendment Request for Extended Power Uprate (TAC Nos.ME9631 and ME9632)," dated January 15, 2014 (ADAMS AccessionNo. ML14002A176)6. Exelon Letter to NRC, "Extended Power Uprate License AmendmentRequest -Supplement 19, Response to Request for AdditionalInformation," dated January 31, 2014 (ADAMS Accession No.ML14035A158)In accordance with 10 CFR 50.90, Exelon Generation Company, LLC (EGC) requestedamendments to the Renewed Facility Operating License Nos. DPR-44 and DPR-56 forPeach Bottom Atomic Power Station (PBAPS) Units 2 and 3, respectively (Reference 1).Specifically, the proposed changes would revise the Renewed Facility Operating Licenses toAttachments 1 and 4 through 7contain Proprietary Information.When separated from these attachments, this document is decontrolled.Acc U. S. Nuclear Regulatory CommissionEPU LAR Supplement 21Response to Requests for Additional InformationFebruary 28, 2014Page 2implement an increase in rated thermal power from 3514 megawatts thermal (MWt) to 3951MWt. During their technical review of the application, the NRC Staff identified the need foradditional information. Reference 2 provided the initial replacement steam dryer (RSD)Request for Additional Information (RAI). References 3 and 4 provided the EGC responsesto those RAIs except EMCB-SD-RAIs-8, 13 and 15.The NRC provided a second round of RSD RAIs in Reference 5. EGC provided a partialresponse in Reference 6. The responses to EMCB-SD-RAIs 8, 13, 15, 16, 17, 30 and 40 areprovided in Attachment 1 to this letter. Responses to the remaining RAIs (i.e., 32 and 41) willbe provided in March 2014.In addition, revisions to the replacement steam dryer topical reports have been prepared toprovide updated analysis results and to address topics which have been discussed during thereview. These revised reports supersede those that were originally provided in Reference 1in Attachments 17 (proprietary) and 15 (non-proprietary); the specific Reference 1 attachmentnumbers are identified below. Proprietary versions of the revised reports identified below areincluded in Attachments 4 through 7:Att. 15 / 17.B.1 WCAP-17590, Rev 2, Acoustic Load DefinitionAtt. 15/ 17.B.3 WCAP-17649, Rev 1, ASME Code Stress ReportAtt. 15 / 17.B.6 WCAP-17626, Rev 1, MSL Strain Gauge Data and Computation ofPredicted EPU SignatureAft. 15/1 7.B.7 WCAP-17639, Rev 3, Instrumentation Description for the Peach BottomUnit 2 Replacement Steam DryerNote that revisions to WCAP-17609, "Evaluation of High-Cycle Acoustic Loads,"WCAP-17635, "Comprehensive Vibration Assessment Program" and WCAPs-17654 and17655, the Power Ascension Program Descriptions for Units 2 and 3, respectively, will betransmitted in March 2014. These documents had been included in Reference 1 asAttachments 17.B.2, 17.A and 17.B4U2 and 17.B4U3. WCAP-1761 1, "Four-Line SubscaleAcoustic Test Data Evaluation and Derivation of CLTP-to-EPU Scaling Spectra" (Reference1, Attachments 15.B.5 and 17.B.5) does not require revision; the version in the original LARremains the current version.Westinghouse Electric Company (WEC) considers portions of the information provided inthe Attachment 1 responses and in the topical reports to be proprietary and, therefore,exempt from public disclosure pursuant to 10 CFR 2.390. In accordance with 10 CFR 2.390and in support of this request for withholding, affidavits executed by WEC are provided inAttachment 3. Non-proprietary versions of the responses and of the topical reports areprovided in Attachment 2 and Attachments 8 through 11.EGC has reviewed the information supporting a finding of no significant hazardsconsideration and the environmental consideration provided to the U. S. Nuclear RegulatoryCommission in Reference 1. The supplemental information provided in this submittal doesnot affect the bases for concluding that the proposed license amendment does not involve asignificant hazards consideration. Further, the additional information provided in thissubmittal does not affect the bases for concluding that neither an environmental impact U. S. Nuclear Regulatory CommissionEPU LAR Supplement 21Response to Requests for Additional InformationFebruary 28, 2014Page 3statement nor an environmental assessment needs to be prepared in connection with theproposed amendment.In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"paragraph (b), EGC is notifying the Commonwealth of Pennsylvania and the State ofMaryland of this application by transmitting a copy of this letter along with the non-proprietary attachments to the designated State Officials.There are no regulatory commitments contained in this letter.Should you have any questions concerning this letter, please contact Mr. David Neff at(610) 765-5631.I declare under penalty of perjury that the foregoing is true and correct. Executed on the28th day of February 2014.Respectfully,Crai L ertVice President, Power UpratesExelon Generation Company, LLCAttachments:1. Response to Request for Additional Information -EMCB-SD -Proprietary2. Response to Request for Additional Information -EMCB-SD3. Affidavits in Support of Request to Withhold Information4. WCAP-17590, Rev 2, Acoustic Load Definition -Proprietary5. WCAP-17649, Rev 1, ASME Code Stress Report -Proprietary6. WCAP-1 7626, Rev 1, MSL Strain Gauge Data and Computation of Predicted EPUSignature -Proprietary7. WCAP-17639, Rev 3, Instrumentation Description for the Peach Bottom Unit 2Replacement Steam Dryer -Proprietary8. WCAP-17590, Rev 2, Acoustic Load Definition9. WCAP-17649, Rev 1, ASME Code Stress Report10. WCAP-1 7626, Rev 1, MSL Strain Gauge Data and Computation of Predicted EPUSignature11. WCAP-1 7639, Rev 3, Instrumentation Description for the Peach Bottom Unit 2Replacement Steam Dryercc: USNRC Region I, Regional Administrator w/attachmentsUSNRC Senior Resident Inspector, PBAPS w/attachmentsUSNRC Project Manager, PBAPS w/attachmentsR. R. Janati, Commonwealth of Pennsylvania w/o proprietary attachmentS. T. Gray, State of Maryland w/o proprietary attachment

Attachment

2Peach Bottom Atomic Power Station Units 2 and 3NRC Docket Nos. 50-277 and 50-278Response to Reauest for Additional Information -EMCB-SDNoteThis attachment includes the non-proprietary version of the response;brackets identify where proprietary information has been redacted.

EPU LAR Supplement 21 Attachment 2Response to RAI -EMCB-SD Page 1 of 118Response to Request for Additional InformationMechanical and Civil Engineering Branch (EMCB) -Steam Dryer (SD),By letter dated September 28, 2012, Exelon Generation Company, LLC (Exelon)submitted a license amendment request for Peach Bottom Atomic Power Station(PBAPS), Units 2 and 3. The proposed amendment would authorize an increase in themaximum power level from 3514 megawatts thermal (MWt) to 3951 MWt. Therequested change, referred to as an extended power uprate (EPU), represents anincrease of approximately 12.4 percent above the current licensed thermal power level.The NRC staff has reviewed the information supporting the proposed amendment and,by letter dated October 1, 2013 (NRC Accession No. ML13268A263), requestedadditional information. Exelon provided responses to EMCB-SD-RAIs 1, 2, 3, 4, 6, 7, 11,12 and 14 (RAIs-5 and 9 were deleted) in a letter dated October 31, 2013 (Supplement14, NRC Accession No. ML13308A331). The response to EMCB-SD-RAI-10 wasprovided in a letter dated December 6, 2013 (Supplement 15, NRC Accession No.ML13345A687). The responses to EMCB-SD-RAI-8, 13 and15 are provided below.In addition, the NRC provided a second round of requests for additional information byletter dated January 15, 2014 (NRC Accession No. ML14002A176). The responses toEMCB-SD-RAIs 19, 21-26, 28-29, 31 and 33-39 (EMCB-SD-RAIs 18, 20 and 27 havebeen deleted) were provided in a letter dated January 31, 2014 (Supplement 19, NRCAccession No. ML14035A158). The responses to EMCB-SD-RAIs 16-17, 30 and 40 areprovided below.Responses to the remaining RAIs (i.e., 32 and 41) will be provided in March 2014.EMCB-SD-RAI-8For PBAPS Units 2 and 3, please provide the following for the 10 lowest alternatingstress ratio locations:a) Frequency spectra for maximum alternating stresses; andb) Stress accumulation plots (root mean square (RMS) stress as a function ofincreasing frequency).Please explain whether any other information (e.g., magnitude of stress as a function offrequency) besides the frequency content of stress may be derived from the plots.Based on the plots, discuss the relative importance of the various forcing functions (e.g.,valve resonances, broad-band acoustic pulsations) on the RSD alternating stresses.RESPONSETable RAI-8-1 lists the ten lowest stress ratio locations for Peach Bottom Atomic PowerStation (PBAPS) Unit 2 with the instrumentation mast from the cumulative results shownin Tables 8-5 and 8-6 of WCAP-17609-P Revision 2. Table RAI-8-2 lists the ten lowest EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 2 of 118stress ratio locations for Unit 3 from the cumulative results shown in Tables 8-3 and 8-4of WCAP-17609-P Revision 2 (Ref 8-1).The plots for the [together at each location for easier comparison and present thefor that location. All shell stress components were []a.c have been pairedIa,c]ac. The predicted natural frequencies of the []a,c are [ ]a,crespectively.The provided plots demonstrate thatinferred.]a,c and that in general, the].'c Since these areshould beREFERENCES:8-1: WCAP-17609-P Revision 2. "Peach Bottom Units 2 and 3 Replacement SteamDryer Structural Evaluation for High-Cycle Acoustic Loads."

EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 3 of 118Table RAI-8-1 Lowest 10 Alternating Stress Ratios for Peach Bottom Unit 2(with Instrumentation Mast)a,c+/-F F F +F F F +F F F +/-

EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 4 of 118Table RAI-8-2 Lowest 10 Alternating Stress Ratios for Peach Bottom Unit 3a,c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 5 of 118a,cFigure RAI-8-1 Peach Bottom Unit 2 with Mast:Lower Drain Channel Belt (non-weld)a,cFigure RAI-8-2 Peach Bottom Unit 2 with Mast:Lower Drain Channel Belt (non-weld)

EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 6 of 118a,cFigure RAI-8-3 Peach Bottom Unit 2 with Mast:Middle Hood to Middle Hood Welda,cFigure RAI-8-4 Peach Bottom Unit 2 with Mast:Middle Hood to Middle Hood Weld EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 7 of 118a,cFigure RAI-8-5 Peach Bottom Unit 2 with Mast:Outer Perforated Plate to Outer Vane Bank Top Step Welda,cFigure RAI-8-6 Peach Bottom Unit 2 with Mast:Outer Perforated Plate to Outer Vane Bank Top Step Weld EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 8 of 118a,cFigure RAI-8-7 Peach Bottom Unit 2 with Mast:Middle Vertical Bank-to-Bank Plate to Middle Vane Bank End Plate Welda,cFigure RAI-8-8 Peach Bottom Unit 2 with Mast:Middle Vertical Bank-to-Bank Plate to Middle Vane Bank End Plate Weld EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 9 of 118a,cFigure RAI-8-9 Peach Bottom Unit 2 with Mast:Lower Slot Belt (non-weld)a,cFigure RAI-8-10 Peach Bottom Unit 2 with Mast:Lower Slot Belt (non-weld)

EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 10 of 118a,cFigure RAI-8-11 Peach Bottom Unit 2 with Mast:Skirt Slot below Water to Skirt Slot Belt Welda,cFigure RAI-8-12 Peach Bottom Unit 2 with Mast:Skirt Slot below Water to Skirt Slot Belt Weld EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 11 of 118a,cFigure RAI-8-13 Peach Bottom Unit 2 with Mast:Mast Front Tube to Mast Front Tube Clamp Welda,cFigure RAI-8-14 Peach Bottom Unit 2 with Mast:Mast Front Tube to Mast Front Tube Clamp Weld EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 12 of 118a,cFigure RAI-8-15 Peach Bottom Unit 2 with Mast:Outer Hood, Curved Portion (non-weld)a,cFigure RAI-8-16 Peach Bottom Unit 2 with Mast:Outer Hood, Curved Portion (non-weld)

EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 13 of 118a,cFigure RAI-8-17 Peach Bottom Unit 2 with Mast:Middle Vertical Bank-to-Bank Plate to Middle Hood Welda,cFigure RAI-8-18 Peach Bottom Unit 2 with Mast:Middle Vertical Bank-to-Bank Plate to Middle Hood Weld EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 14 of 118a,cFigure RAI-8-19 Peach Bottom Unit 2 with Mast:Middle Hood to Outer Trough Welda,cFigure RAI-8-20 Peach Bottom Unit 2 with Mast:Middle Hood to Outer Trough Weld EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 15 of 118a,cFigure RAI-8-21 Peach Bottom Unit 3:Skirt Slot above Water to Support RingFigure RAI-8-22 Peach Bottom Unit 3:Skirt Slot above Water to Support Ringa,c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 16 of 118a,cFigure RAI-8-23 Peach Bottom Unit 3:Lower Drain Channel Belt (non-weld)Figure RAI-8-24 Peach Bottom Unit 3:Lower Drain Channel Belt (non-weld)a,c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 17 of 118a,cFigure RAI-8-25 Peach Bottom Unit 3:Lower Slot Belt (non-weld)Figure RAI-8-26 Peach Bottom Unit 3:Lower Slot Belt (non-weld)a,c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 18 of 118a,cFigure RAI-8-27 Peach Bottom Unit 3:Skirt Slot below Water to Slot Belt WeldFigure RAI-8-28 Peach Bottom Unit 3:Skirt Slot below Water to Slot Belt Welda,c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 19 of 118a,cFigure RAI-8-29 Peach Bottom Unit 3:Skirt above Water to Support Ring WeldFigure RAI-8-30 Peach Bottom Unit 3:Skirt above Water to Support Ring Welda,c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 20 of 118a,cFigure RAI-8-31 Peach Bottom Unit 3:Skirt above Water to Skirt Belt WeldFigure RAI-8-32 Peach Bottom Unit 3:Skirt above Water to Skirt Belt Welda,c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 21 of 118a,cFigure RAI-8-33 Peach Bottom Unit 3:Outer Perforated Plate to Outer Vane Bank Top Step Welda,cFigure RAI-8-34 Peach Bottom Unit 3:Outer Perforated Plate to Outer Vane Bank Top Step Weld EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 22 of 118a,cFigure RAI-8-35 Peach Bottom Unit 3:Middle Hood to Outer Trough WeldFigure RAI-8-36 Peach Bottom Unit 3:Middle Hood to Outer Trough Welda,c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 23 of 118a,cFigure RAI-8-37 Peach Bottom Unit 3:Outer Vane Bank Top Step to Outer Hood Welda,cFigure RAI-8-38 Peach Bottom Unit 3:Outer Vane Bank Top Step to Outer Hood Weld EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 24 of 118a,cFigure RAI-8-39 Peach Bottom Unit 3:Skirt above Water to Skirt Slot above Water Welda,cFigure RAI-8-40 Peach Bottom Unit 3:Skirt above Water to Skirt Slot above Water Weld EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 25 of 118EMCB-SD-RAI-1 3The simulated dryer loading at 102 percent of the EPU power level are presented inTable 3-5 and Figures 3-2 through 3-5 of WCAP-17590-P1, "Peach Bottom Units 2 & 3Replacement Steam Dryer Acoustic Load Definition." These figures and table displayconsiderable differences between PBAPS Units 2 and 3, although these units aresupposed to be identical and have similar specific bias and uncertainties, as listed inTable 3-3. Please explain the sources of these relatively large differences in the totalRMS differential pressure (Table 3-5) and the broadband excitation at low and highfrequencies, especially on the dryer quadrants A and C. Provide contour plots of thedifferential pressures on the dryers of PBAPS 2 and 3 over all four quadrants for: (a) allsignals between 0 and 250 Hz; (b) signals between 0 and 60 Hz; (c) signals spanningthe SRV resonance near 130 Hz; and (d) signals spanning the blind flange resonancenear 220 Hz. These plots should use a common contour color scale so that the plotsmay be easily compared. Also, provide overlays of the PBAPS 2 and 3 raw and filteredMSL spectra for all eight locations (e.g., plot PBAPS 2 versus PBAPS 3 MSL location 1unfiltered, PBAPS 2 versus PBAPS 3 MSL location 1 filtered, PBAPS 2 versus PBAPS 3MSL location 2 unfiltered, etc.). Additionally, overlay the monopole and dipole terms forPBAPS 2 and 3 for each MSL inlet. Interpret this information to explain the differencesin loading between PBAPS 2 and 3.RESPONSEFigures 3-2 through 3-5 and Table 3-5 of WCAP-17590 Revision 0 (Ref. 13-1) representthe [ ]a.c whichwere determined through the [ ]a.c. With theI ]a.c, EGC has selectedloadings. As such,[]a.c for determining the acoustic]a.c to account for the new]a.c. The[ax are summarized in Tables RAI-13-1 and RAI-13-2 for both units.Table RAI-13-1 [ ]acDifferential Pressure Loads Summary Table at EPU*1.02 Conditionsa,c1 WCAP-17590-P, is a proprietary document that was included as Enclosure 17B. 1 of the ExelonEPU LAR dated September 28, 2012. A non-proprietary version is in ADAMS (ML12286A020).

EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 26 of 118Table RAI-13-2 [ ]a,cDifferential Pressure Loads Summary Table at EPU*1.02 Conditions~,: ::'A set of [r-c wereobtained for the]a.c. These plots have been generated for both units and they are shown inFigures RAI-1 3-1 through RAI- 13-8 for [ I]ax, and Figures FRAI-13-9through RAI-1 3-16 for [ ]a~ca,c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 27 of 118a,cFigure RAI-13-1 Peach Bottom Unit 2 RMS Differential Pressure 0-250 Hz(MSL A/B -Left, MSL CID -Right) [ ]axca,cFigure RAI-13-2 Peach Bottom Unit 3 RMS Differential Pressure 0-250 Hz(MSL A/B -Left, MSL C/D -Right) [ ]ac EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 28 of 118a,cFigure RAI-13-3 Peach Bottom Unit 2 RMS Differential Pressure 0-60 Hz(MSL AIB -Left, MSL C/D -Right) [ ]axca,cFigure RAI-13-4 Peach Bottom Unit 3 RMS Differential Pressure 0-60 Hz(MSL A/B -Left, MSL C/D -Right) [ ]axc EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 29 of 118a,cFigure RAI-13-5 Peach Bottom Unit 2 RMS Differential Pressure 128-134 Hz(MSL A/B -Left, MSL C/D -Right) [ ]aCa,cFigure RAI-13-6 Peach Bottom Unit 3 RMS Differential Pressure 128-134 Hz(MSL A/B -Left, MSL C/D -Right) [ ]ax EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 30 of 118a,cFigure RAI-13-7 Peach Bottom Unit 2 RMS Differential Pressure 216-222 Hz(MSL AJB -Left, MSL CID -Right) [ ]aca,cFigure RAI-13-8 Peach Bottom Unit 3 RMS Differential Pressure 216-222 Hz(MSL A/B -Left, MSL C/D -Right) [ I ax EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 31 of 118a,cFigure RAI-13-9 Peach Bottom Unit 2 RMS Differential Pressure 0-250 Hz(MSL A/B -Left, MSL CID -Right) [ ]a,ca,cFigure RAI-13-10 Peach Bottom Unit 3 RMS Differential Pressure 0-250 Hz(MSL A/B -Left, MSL C/D -Right) [ ]a'c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 32 of 118a,cFigure RAI-13-11 Peach Bottom Unit 2 RMS Differential Pressure 0-60 Hz(MSL A/B -Left, MSL CID -Right) [ ]a,cFigure RAI-13-12 Peach Bottom Unit 3 RMS Differential Pressure 0-60 Hz(MSL A/B -Left, MSL C/D -Right) [ ]a'a,c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 33 of 118a,cFigure RAI-13-13 Peach Bottom Unit 2 RMS Differential Pressure 128-134 Hz(MSL A/B -Left, MSL CID -Right) [ ]a,ca,cFigure RAI-13-14 Peach Bottom Unit 3 RMS Differential Pressure 128-134 Hz(MSL A/B -Left, MSL CID -Right) [ ]ax EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 34 of 118a,cFigure RAI-13-15 Peach Bottom Unit 2 RMS Differential Pressure 216-222 Hz(MSL A/B -Left, MSL CID -Right) [ Iaca,cFigure RAI-13-16 Peach Bottom Unit 3 RMS Differential Pressure 216-222 Hz(MSL A/B -Left, MSL C/D -Right) [ ]ax EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 35 of 118Based on the [].,c; moreover, thea,c.]a-c, the load definitions are IFigures RAI-13-17 through RA1-13-20 show anRAI-13-21 through RAI-13-24 show anindicate a []a,c. Figures]a,c. Again, these figuresa,Ca,cFigure RAI-13-17 Peach Bottom Unit 2 and Unit 3 Unfiltered MSL A Pressures EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 36 of 1187 a,cFigure RAI-13-18 Peach Bottom Unit 2 and Unit 3 Unfiltered MSL B Pressuresa,cFigure RAI-13-19 Peach Bottom Unit 2 and Unit 3 Unfiltered MSL C Pressures EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 37 of 118a,cFigure RAI-13-20 Peach Bottom Unit 2 and Unit 3 Unfiltered MSL D Pressuresa,cFigure RAI-13-21 Peach Bottom Unit 2 and Unit 3 Filtered MSL A Pressures EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 38 of 1187 a,cFigure RAI-13-22 Peach Bottom Unit 2 and Unit 3 Filtered MSL B Pressuresa,cFigure RAI-13-23 Peach Bottom Unit 2 and Unit 3 Filtered MSL C Pressures EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 39 of 118a,cFigure RAI-13-24 Peach Bottom Unit 2 and Unit 3 Filtered MSL D PressuresThe [ ]a.c in FiguresRAI-13-25a and RAI-13-25b for both Unit 2, and Figures RAI-13-26a and RAI-13-26b forUnit 3.a,cFigure RAI-13-25a Peach Bottom Unit 2 Monopole Acoustic Sources EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 40 of 118a,cFigure RAI-1 3-25b Peach Bottom Unit 2 Dipole Acoustic SourcesFigure RAI-13-26a Peach Bottom Unit 3 Monopole Acoustic Sourcesa,ca,cFigure RAI-13-26b Peach Bottom Unit 3 Dipole Acoustic Sources EPU LAR Supplement 21 Attachment 2Response to RAI -EMCB-SD Page 41 of 118Since the]a,c. Notethat the Unit 2 and Unit 3 replacement steam dryer major components]ac. Any differences]a,c,REFERENCES:13-1 WCAP-17590-P Revision 0, "Peach Bottom Units 2 & 3 Replacement SteamDryer Acoustic Load Definition."13-2 WCAP-17626-P Revision 1, "Processing of Peach Bottom Unit 2 and Unit 3 MSLStrain Gauge Data and Computation of Predicted EPU Signature."EMCB-SD-RAI-15In Attachment 9 to the licensee's letter dated February 15, 2013, it is noted that the biasand uncertainty associated with the structural finite element dynamic modeling of thedryers is primarily associated with modeling procedures such as the use of shellelements, the element spacing, and coupling of shell and solid modeling sections. It isindicated that you use a procedure similar to that used for the [], c steam dryer model, with the exception of using [ ]a,c instead of shellsembedded within solids to connect different sections. You also cite internal studiesshowing the use of [ ]ac actually reduces uncertainty slightly, but do not take creditfor this in the PBAPS EPU application. You point out that on-dryer measurements areplanned to confirm the "...conservatism in the predicted ACM 4.1 results prior toexceeding CLTP." Based on the above, the NRC staff requests the following informationregarding this subject:Please submit a detailed instrumentation and measurement plan to measure naturalfrequencies and mode shapes, pressures acting on the dryer, and the dryer strains andaccelerations to confirm that the dryer stresses are within acceptable limits. This planshould include how the measurement locations are relevant to the high loading andstress regions in the dryer and a priori predictions of the expected strain and pressurespectra and peaklrms values. You should consider ensuring that both the upper dryer,including the different hood sections, and the lower dryer (skirt) are sufficientlyinstrumented.RESPONSEThe NRC performed an audit of the PBAPS RSD data at the Westinghouse office inRockville, Maryland on August 9, 2013 and September 12, 2013. During that audit, EGCpresented various topics including the on-dryer instrumentation plan for Peach BottomUnit 2. Excerpts from the information presented in those audit meetings are included EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 42 of 118below in our response to this RAI. Our response to this RAI is divided into two parts.The first part describes the on-dryer instrumentation and includes our rationale forlocation and selection of the instruments. The second part discusses our plans for usingthat instrumentation during power ascension. Finally, we summarize how weIa,cPeach Bottom Unit 2: Description of On-Dryer InstrumentationEGC has designed theI].,c A key consideration for locating theIa,cANSYS, ANSYS Workbench, AUTODYN, CFX, FLUENT and any and all ANSYS, Inc.brand, product, service and feature names, logos and slogans are registered trademarksor trademarks of ANSYS, Inc. or its subsidiaries in the United States or other countries.All other brand, product, service and feature names or trademarks are the property oftheir respective owners.The [

EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 43 of 118Ia,c EPU LAR Supplement 21Response to RAI -EMCB-SDPressure Transducers and AccelerometersThe predicted acoustic pressure loads on the steam dryer were calculated byAttachment 2Page 44 of 118a,cBased on the results of the]a,cA total of[Ia,cThe locations of the [Ia,c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 45 of 118Strain GaugesThe location ofI a,cA total of[]a,cThe selected location of the]a,cLa,c EPU LAR Supplement 21Response to RAI -EMCB-SDIt was demonstrated that the [Attachment 2Page 46 of 118Ia,cFor the selected []a,cThe predicted]a,cPeach Bottom Unit 2: Application and Use of Instrumentation during Power AscensionEGC intends to collect and analyze data from the]acThe initial plan is to have a []a,cUpon completion of thea,cDuring power ascension above CLTP, EGC will collect EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 47 of 118Ia,cUpon achieving EPU power level,Ia,cPeach Bottom Unit 3: Use of IlalcThe final]a,cREFERENCES:15-1: EGC letter from K. F. Borton to U.S. Nuclear Regulatory Commission, datedDecember 6, 2013; Subject: Extended Power Uprate License AmendmentRequest -Supplement 15 Response to Request for Additional Information EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 48 of 118a,cFimirp RA1-16-1 rla,cFiaurA RAI-15-1 r lac EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 49 of 1187 a,cFigure RAI-15-2 rla,cFlur RA-1- r a EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 50 of 118a,cFigure RAI-15-3 r EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 51 of 118a,cFigure RAI-15-4 rla,cFiaur RA-1- I EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 52 of 118a,cFinure RA1-15-5 rla,cFioure RAI-15-5 r la.c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 53 of 118a,cFiaure RAI-1s-6 rla,c]a,c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 54 of 118a,cFiaure RAI-15-7 rI axIiIaxc EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 55 of 118a,cFiaure RAI-15-8 rla,cI2~

EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 56 of 118a,cFinure RAI-15-9 rla,cI]a,c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 57 of 118a,cFigure RAI-15-10 I1a~ca,cFiaure RAI-15-11 rlacF Iour ...... .. .. r I EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 58 of 118a,cFiaure RAI-15-12 r1 a,ca,cFiqure RAI-15-13 rIaxc EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 59 of 118a,cFiaure RAI-15-14 Ilaca,cFinure RAI-15-1s rla,cFinurA RAI-15-15 r inc EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 60 of 118a,cFinure RAI-15-16 rla,ca,cFiaure RAI-15-17 rI ,cFioure RAI-15-17 r lac EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 61 of 118a,ca,cFiciure RAI-15-18 rIa,cFinure RAI-lis-19 rla,cFlaure RAI-15-19 r lac EPU LAR Supplement 21Response to RAI -EMCB-SDFiqure RAI-15-20 rAttachment 2Page 62 of 1187 a,cI axa,cFinurp RAI-15-21 rla,cFlaurA RAI-15-21 r lac EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 63 of 118a,cFioure RAI 15-22 ria,cFlaure RA.. 1. -22.r.lI I EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 64 of 118a,cFigure RAI 15-23 rIa,c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 65 of 1187 a,cFiaure RAI-1 5-24 rla,C-l- u rI .. .... .. ...ir l EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 66 of 1187 a,cFinure RAI-15-25 rla,cFlaurA RAI-15-25 r lac EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 67 of 1187 a,cFigure RAI-15-26 ria,cFlur RA-52 r a EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 68 of 1187 a,cFinure RAI-15-27 r1a,cFinur~ RAI-15-27 F lac EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 69 of 1187 a,cFiaure RAI-15-2a rla,cFlaur RAI-15-28... r i' EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 70 of 1187 a,cFigure RAM 6-29 rIla,cFlaure RAI-15-29 r lac EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 71 of 1187 a,cFiqure RAI-15-30 [lac EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 72 of 118a,cFigure RAI-15-31 rlaxFiaure RAI-15-31 I la.c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 73 of 118a,cFiciure RAI-15-32 raxtmiamm RA-1m3 EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 74 of 118a,cFinurp RAI-Is-33 rla,cFlaure RAI-15-33 I lac EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 75 of 118a,cFigure RAI-15-34 rla,c"F iour ....... .. .I Ia EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 76 of 118a,cFiaure RAI-15-35 rIa,ca,cFigure RAI-15-36 [

EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 77 of 118a,cFigure RAI-15-37 raxca,cFigure RAI-15-38 [

EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 78 of 1187 a,cFinure RAI-ls-aq rla,ca,cFigure RAI-15-40 [ ]"'c EPU LAR Supplement 21Response to RAI -EMCB-SDFigure RAI-15-41 [Attachment 2Page 79 of 118a,caa,Ca,c-Figure RAI-15-42 [1a,c EPU LAR Supplement 21Response to RAI -EMCB-SDFiaure RAI-15-43 rAttachment 2Page 80 of 1187 a,cla~ca,cFigure RAI-15-44 [

EPU LAR Supplement 21Response to RAI -EMGCB-SDAttachment 2Page 81 of 118a,cFiqure RAI-15-45 [ ]a,c EPU LAR Supplement 21Response to RAI -EMCB-SD.Attachment 2Page 82 of 1187 a,cFigure RAI-15-46 [ ax,c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 83 of 1187 a,cFigure RAI-15-47 [ Ia,c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 84 of 1187Ka,cFlaure RAI-15-48 r1a,c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 85 of 118a,cFiqure RAI-16-49 r ]aC EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 86 of 118a,cFigure RAI-15-50 r Ia,c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 87 of 118a,c..Fiaure RAI-15-51 r 1 ax EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 88 of 118a,cFiaure RAI-15-52 r Ia'c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 89 of 118a,cFigure RAI-15-53 r ]a,c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 90 of 118a,cFigure RAI-15-54 r ]axc EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 91 of 118a,cFigure RAI-15-55 r lac EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 92 of 118a,cFigure RAI-15-56 r 1.,c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 93 of 118a,cFigure RAI-15-57 r ]a,c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 94 of 118a,cFigure RAI-15-58 r laxc EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 95 of 118a,cFigure RAI-15-59 r ]a,c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 96 of 118a,cFigure RAI-15-60 r Iac EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 97 of 118a,cFigure RAI-15-61 r ]a,c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 98 of 118Fiaure RAI-15-62 r1a.c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 99 of 118a,cFigure RAI-15-63 r ]a,c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 100 of 118a,cFigure RAI-15-64 r ]a,c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 101 of 118a,cFigure RAI-15-65 r ]a,c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 102 of 118a,cFigure RAI-15-66 r Ia'c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 103 of 118Fiaure RAI-15-67 rSac EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 104 of 118Fiaure RAI-15-68 r1 a,c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 105 of 118a,cFigure RAI-15-69 r 1".

EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 106 of 118Table RAI -15-1a [1 axa,ca,cTable RAI-15-1b r Ia"ci +Table RAI-15-2a r-1 a,ci i4 t4 44 i+ 4 EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 107 of 118Table RAI-15-2b I-- a,ci. iI. +I. t EPU LAR Supplement 21 Attachment 2Response to RAI -EMCB-SD Page 108 of 118EMCB-SD-RAI-1 6A Westinghouse octagonal shaped three ring vane bank replacement steam dryer (RSD)was recently installed at the Monticello Nuclear Generating Plant (Monticello) to supportan EPU. Several boiling water reactors (BWRs) in Europe have also installed thisWestinghouse steam dryer. Exelon plans to install the same type RSD at the PBAPS tosupport the proposed EPU, and is using the Monticello data as a benchmark for theirdryer analysis procedure. The NRC staff has noted that the azimuthal orientation of thePBAPS RSD (Figure 2-1 of Reference 1) is [ a'c relative to the orientation ofthe Monticello RSD. [a,c Please providethe following:a) Explain why the PBAPS RSD is oriented [I a,c compared to the Monticello RSD.b) Provide any known operating experience data regarding the BWRs in Europe withWestinghouse steam dryers that are oriented similar to the PBAPS RSDs.c) Since the PBAPS RSD and Monticello dryer orientations are different, the associatedsteam flow velocities, vorticities, and turbulence within the vessels and the dipolesources at the main steam line (MSL) entrances may be different. Therefore, thedipole sources developed based on the Monticello RSD benchmark data may not beapplicable for the analysis of the PBAPS RSD design. Provide any fluid dynamicinformation related to the MSL inlet flow, vorticity, and resulting dipole sources for thePBAPS RSD orientation as compared to the benchmark Monticello orientation.Explain what steps will be taken to ensure that the dipole strengths used for thePBAPS RSD evaluations are conservatived) Please provide a quantitative analysis of the impact of the pressure loads on theouter hoods of the PBAPS RSD for the following two orientations: (1) MonticelloRSD orientation; and (2) proposed PBAPS RSD orientation [ ] a,c.RESPONSEa) Figure 2-1 of WCAP 17590-P Revision 2 (Ref. 16-1) shows the)c.b)[]a,c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 109 of 118c) As part of the design process, the dipole strength valuea,cd) Based on discussions with the NRC following issuance of the RAI, it was agreed thata[]ac. The following analysis is provided toa,cIn order to demonstrate the []a.c This changesummarizes the]a,c This frequency range wasa,c]ac. Table RAI-16-1Table RAI-16-1Comparison of the Maximum RMS Differential Pressure as a Function of theDipole Angle_- I Maximum RMS-DP (psi) ] a,c4 4 4 iTable RAI-1 6-1 demonstrates that the []ac therefore, theac EPU LAR Supplement 21Response to RAI -EMCB-SDIn addition to Table RAI-16-1, Figure RAI-16-1 shows aFigure RAI-16-1 [Attachment 2Page 110 of 118]a,c]a,ca,cFigure RAI-16-1 Maximum Acoustic Differential Pressure Facing MSL A Between0-60 Hz EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 111 of 118a,cFigure RAI-16-2 Acoustic RMS Differential Pressure 0-250 Hz EPU LAR Supplement 21 Attachment 2Response to RAI -EMCB-SD Page 112 of 118The concept ofa,cTo illustrate this, a comparison of the]a,c These comparisons aresummarized in Table RAI-16-2.Table RA1-16-2 .a,cIn conclusion, the]a,c. It should be notedthat the[rc.EMCB-SD-RAI-17In Reference 2, the pressure spectra recorded during the scale model tests (SMTs)show [ I ac at the safety relief valve (SRV) resonancefrequencies. Since the transient conditions [] ac used in the SMTs may affect the bump-up factor results, pleaseprovide the following:a) Perform a sensitivity analysis, using the test samples [] ax Provide the results of this analysisincluding any impacts on resonance amplitude and bump-up factors.b) This RAI question has been deleted.

EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 113 of 118RESPONSETo perform the sensitivity analysis, it]ac. Since the[acThe [Ia,cA sensitivity analysis was performed to assess the]a,c The analysis of the effect of theacAn example of the effect of the]ac. The amplitudes of the]ac This causes the I]a,c for PBAPS Unit 2 andPBAPS Unit 3. The[]a.cTable RAI-17-1 Peach Bottom RMS Ratiosa,c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 114 of 118a,cFigure RAI-17-1 Peach Bottom Unit 2, Scaling Spectra Inputs, MSL D US-- a,cFigure RAI-17-2 Peach Bottom Unit 2, Scaling Spectra Inputs, MSL D DS EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 115 of 118a,cLFigure RAI-17-3 Peach Bottom Unit 3, Scaling Spectra Inputs, MSL D USa,cFigure RAI-17-4 Peach Bottom Unit 3, Scaling Spectra Inputs, MSL D DS EPU LAR Supplement 21 Attachment 2Response to RAI -EMCB-SD Page 116 of 118REFERENCES17-1: WCAP-17611-P, Revision 1, "Peach Bottom Units 2 and 3 Replacement SteamDryer Four-Line Subscale Acoustics Test Data Evaluation and Derivation ofCLTP-to-EPU Scaling Spectra," dated August 2012.EMCB-SD-RAI-30The NRC performed an audit of the PBAPS RSD data at the Westinghouse office inRockville, Maryland on September 12, 2013. Please provide an update to Reference 5which contains all information requested during this audit. Also provide detaileddescriptions of the sensor locations, projected and measured spectra, and thecorrelation of these spectra against the stress regions on the lower and upper dryer,including cumulative strain and pressure plots. Explain what steps will be taken toensure that the integrity of the sensor/wiring connections is maintained to preventmoisture intrusion and corrupted measurements, particularly for the pressure sensors.RESPONSEPlease see response to EMCB-SD-RAI-1 5.EMCB-SD-RAI-40Please describe how the end-to-end bias and uncertainty for ACE and ACE plus the skirtprotection model are determined. Please explain what actions would be taken if thepredicted converged peak stresses after being adjusted for the end-to-end bias anduncertainty do not bound the measured stresses at the installed strain gauges locationson the RSD.RESPONSEWith the change from using]a-c However, the mathematical process to]a~c For the design of the replacement steam dryers,Westinghouse used thea,c.Ia,c EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 117 of 118I a,c]a,cThe bias and uncertainties ofa,c]a,c, the data collected from theIaca,cIThe bias and uncertainties of []a,c In that [

EPU LAR Supplement 21Response to RAI -EMCB-SDAttachment 2Page 118 of 118]a,cOnce the EPU power level is achieved, a [Ia,cREFERENCES:40-1: WCAP-17590-P Revision 0, "Peach Bottom Units 2 & 3 Replacement SteamDryer Acoustic Load Definition."

Attachment

3Peach Bottom Atomic Power Station Units 2 and 3NRC Docket Nos. 50-277 and 50-278AFFIDAVITSNoteAttachments 1 and 4 through 7 contain proprietary information as definedby 10 CFR 2.390. WEC, as the owner of the proprietary information, hasexecuted the enclosed affidavits that identify that the proprietaryinformation has been handled and classified as proprietary, is customarilyheld in confidence, and has been withheld from public disclosure. Theproprietary information has been faithfully reproduced in the attachmentsuch that the affidavits remain applicable.

  • W)estinghouseH ~h esingh useWestinghouse Electric CompanyEngineering, Equipment and Major Projects1000 Westinghouse DriveCranberry Township, Pennsylvania 16066USAU.S. Nuclear Regulatory Commission Direct tel: (412) 374-4419Document Control Desk I)irect fax: (724) 720-075411555 Rockville Pike e-mail: maurerbf@westinghouse.comRockville, MD 20852CAW- 14-3920February 27, 2014APPLICATION FOR WITHHOLDING PROPRIETARYINFORMATION FROM PUBLIC DISCLOSURESubject: Attachment I "Response to Request for Additional Information -EMCB-SD -Proprietary,"attached to Exelon Generation submittal to the NRC "Extended Power Uprate LicenseAmendment Request -Supplement 21, Response to Request for Additional Information"The proprietary information for which withholding is being requested in the above-referenced report isfurther identified in Affidavit CAW-14-3920 signed by the owner of the proprietary information,Westinghouse Electric Company LLC. The Affidavit, which accompanies this letter, sets forth the basison which the information may be withheld from public disclosure by the Commission and addresses withspecificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission'sregulations.Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Exelon Generation.Correspondence with respect to the proprietary aspects of the application for withholding or theaccompanying Affidavit should reference CAW- 14-3920 and should be addressed to James A. Gresham,Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 310, 1000 WestinghouseDrive, Cranberry Township, Pennsylvania 16066.Very truly yours,Bradley F. Maurer, Principal EngineerPlant LicensingEnclosures CAW- 14-3920AFFIDAVITCOMMONWEALTH OF PENNSYLVANIA:ssCOUNTY OF BUTLER:Before me, the undersigned authority, personally appeared Bradley F. Maurer, who, being by meduly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf ofWestinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in thisAffidavit are true and correct to the best of his knowledge, information, and belief:Bradley F. Maurer, Principal EngineerPlant LicensingSworn to and subscribed before methis 27th day of February 2014Notary PublicCOMMONWEALTH OF PENNSYLVANIANotarial SealAnne M. Stegman, Notary PublicutnTwp., Westmoreland countyCommission Expires Aug. 7, 2016MEMBER, PENNSCY'LVANIA ASSCIATION OF NOTARIES 2CAW-14-3920(!) I am Principal Engineer, Plant Licensing, in Engineering, Equipment and Major Projects,Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specificallydelegated the function of reviewing the proprietary information sought to be withheld from publicdisclosure in connection with nuclear power plant licensing and rule making proceedings, and amauthorized to apply for its withholding on behalf of Westinghouse.(2) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of theCommission's regulations and in conjunction with the Westinghouse Application for WithholdingProprietary Information from Public Disclosure accompanying this Affidavit.(3) L have personal knowledge of the criteria and procedures utilized by Westinghouse in designatinginformation 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, thefollowing is furnished for consideration by the Commission in determining whether the informationsought 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 inconfidence by Westinghouse.(ii) The information is of a type customarily held in confidence by Westinghouse and notcustomarily disclosed to the public. Westinghouse has a rational basis for determining thetypes of information customarily held in confidence by it and, in that connection, utilizes asystem 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 Westinghousepolicy and provide the rational basis required.Under that system, information is held in confidence if it falls in one or more of severaltypes, the release of which might result in the loss of an existing or potential competitiveadvantage, 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 3CAW-1.4-3920competitors without license from Westinghouse constitutes a competitive economicadvantage over other companies.(b) It consists of supporting data, including test data, relative to a process (orcomponent, structure, tool, method, etc.), the application of which data secures acompetitive economic advantage, e.g., by optimization or improved marketability.(c) Its use by a competitor would reduce his expenditure of resources or improve hiscompetitive position in the design, manufacture, shipment, installation, assurance ofquality, or licensing a similar product.(d) It reveals cost or price information, production capacities, budget levels, orcommercial strategies of Westinghouse, its customers or suppliers.(e) It reveals aspects of past, present, or future Westinghouse or customer fundeddevelopment 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 thefollowing:(a) The use of such information by Westinghouse gives Westinghouse a competitiveadvantage over its competitors. It is, therefore, withheld from disclosure to protectthe Westinghouse competitive position.(b) It is information that is marketable in many ways. The extent to which suchinformation is available to competitors diminishes the Westinghouse ability to sellproducts and services involving the use of the information.(c) Use by our competitor would put Westinghouse at a competitive disadvantage byreducing his expenditure of resources at our expense.

4CAW- 14-3920(d) Each component of proprietary information pertinent to a particular competitiveadvantage is potentially as valuable as the total competitive advantage. Ifcompetitors acquire components of proprietary information, any one componentmay be the key to the entire puzzle, thereby depriving Westinghouse of acompetitive advantage.(e) Unrestricted disclosure would jeopardize the position of prominence ofWestinghouse in the world market, and thereby give a market advantage to thecompetition of those countries.(f) The Westinghouse capacity to invest corporate assets in research and developmentdepends upon the success in obtaining and maintaining a competitive advantage.(iv) The information is being transmitted to the Commission in confidence and, under theprovisions 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 availableinformation has not been previously employed in the same original manner or method to thebest of our knowledge and belief.(vi) The proprietary information sought to be withheld in this submittal is that which isappropriately marked in Attachment I "Response to Request for Additional Information -ENMCB-SD -Proprietary," attached to Exelon Generation submittal to the NRC "ExtendedPower Uprate License Amendment Request -Supplement 21, Response to Request forAdditional Information" for submittal to the Commission, being transmitted by ExelonGeneration letter and Application for Withholding Proprietary Information from PublicDisclosure, to the Document Control Desk. The proprietary information as submitted byWestinghouse is to assist the NRC in their review of the Peach Bottom Atomic Power Station,Units 2 and 3, License Amendment Request for Extended Power Uprate and may be used onlyfor that purpose.

5CAW-14-3920(a) This information is part of that which will enable Westinghouse to:(i) Assist Exelon Generation in obtaining NRC review of the Peach BottomAtomic Power Station Units 2 and 3 License Amendment Request.(b) Further this infbrmation has substantial commercial value as follows:(i) Westinghouse plans to sell the use of this information to its customers forpurposes of plant specific replacement steam dryer analysis for licensingbasis applications.(ii) Its use by a competitor would improve their competitive position in thedesign and licensing of a similar product for BWR steam dryer analysismethodology.(iii) The information requested to be withheld reveals the distinguishing aspectsof a methodology which was developed by Westinghouse.Public disclosure of this proprietary information is likely to cause substantial harm to thecompetitive position of Westinghouse because it would enhance the ability of competitors toprovide similar technical justifications and licensing defense services for commercial powerreactors without commensurate expenses. Also, public disclosure of the information wouldenable others to use the information to meet NRC requirements for licensing documentationwithout purchasing the right to use the information.The development of the technology described in part by the information is the result ofapplying the results of many years of experience in an intensive Westinghouse effort and theexpenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technicalprograms would have to be performed and a significant manpower effort, having tierequisite talent and experience, would have to be expended.Further the deponent sayeth not.

Proprietary Information NoticeTransmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRCin connection with requests for generic and/or plant-specific review and approval.In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning theprotection of proprietary information so submitted to the NRC, the information which is proprietary in theproprietary versions is contained within brackets, and where the proprietary information has been deletedin the non-proprietary versions, only the brackets remain (the information that was contained within thebrackets in the proprietary versions having been deleted). The justification for claiming the informationso 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 beingidentified as proprietary or in the margin opposite such information. These lower case letters refer to thetypes 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 NoticeThe reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted tomake the number of copies of the information contained in these reports which are necessary for itsinternal 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 publicdisclosure to the extent such information has been identified as proprietary by Westinghouse, copyrightprotection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC ispermitted to make the number of copies beyond those necessary for its internal use which are necessary inorder to have one copy available for public viewing in the appropriate docket files in the public documentroom in Washington, DC and in local public document rooms as may be required by NRC regulations ifthe number of copies submitted is insufficient for this purpose. Copies made by the N.RC must includethe copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

  • WestinghouseWestinghouse Electric CompanyEngineering, Equipment and Major Projects1000 Westinghouse DriveCranberry Township, Pennsylvania 16066USAU.S. Nuclear Regulatory CommissionDocument Control Desk11555 Rockville PikeRockville, MD 20852Direct tel: (412) 374-4419Direct fax: (724) 720-0754e-mail: maurerbf@westinghouise.comWEC-PCH-RSD-14-032CAW- 14-3909February 17, 2014APPLICATION FOR WITHHOLDING PROPRIETARYINFORMATION FROM PUBLIC DISCLOSURESubject: WCAP-17639-P, Revision 3, "Instrumentation Description for the Peach Bottom Unit 2Replacement Steam Dryer" (Proprietary)Tile proprietary information for which withholding is being requested in the above-referenced report isfurther identified in Affidavit CAW-14-3909 signed by the owner of the proprietary information,Westinghouse Electric Company LLC. The Affidavit, which accompanies this letter, sets forth the basison which the information may be withheld from public disclosure by the Commission and addresses withspecificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission'sregulations.Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Exelon Generation.Correspondence with respect to the proprietary aspects of the application for withholding or theaccompanying Affidavit should reference CAW-]4-3909 and should be addressed to James A. Gresham,Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 310, 1000 WestinghouseDrive, Cranberry ToWnship, Pennsylvania 16066.Very truly yours,Bradley F. Maurer, Principal EngineerPlant LicensingEnclosures CAW- 14-3909AFFIDAVITCOMMONWEALTH OF PENNSYLVANIA:ssCOUNTY OF BUTLER:Before me, the undersigned authority, personally appeared Bradley F. Maurer, who, being by meduly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf ofWestinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in thisAffidavit are true and correct to the best of his knowledge, information, and belief:Bradley F. Maurer, Principal EngineerPlant LicensingSworn to and subscribed before methis 17th day of February 2014Notary PublicCOMMONWEALTH OF PENNSYLVANIANotarial SealiAnne M. Stegman, Notary PublicUnity Twp., Westmoreland CountyMy Commission Expires Aug. 7, 2016MEMBER, PENNSYLVANIA OF NOTARIES 2CAW-14-3909(1) 1 am Principal Engineer, Plant Licensing, in Engineering, Equipment and Major Projects,Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specificallydelegated the function of reviewing the proprietary information sought to be withheld from publicdisclosure in connection with nuclear power plant licensing and rule making proceedings, and amauthorized to apply for its withholding on behalf of Westinghouse.(2) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of theCommission's regulations and in conjunction with the Westinghouse Application for WithholdingProprietary Information from Public Disclosure accompanying this Affidavit.(3) 1 have personal knowledge of the criteria and procedures utilized by Westinghouse in designatinginformation 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, thefollowing is furnished for consideration by the Commission in determining whether the informationsought 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 inconfidence by Westinghouse.(ii) The information is of a type customarily held in confidence by Westinghouse and notcustomarily disclosed to the public. Westinghouse has a rational basis for determining thetypes of information customarily held in confidence by it and, in that connection, utilizes asystem to determine when and whether to hold certain types of information in confidence.The application of that system and the substance of that system constitutes Westinghousepolicy and provides the rational basis required.Under that system, information is held in confidence if it falls in one or more of severaltypes, the release of which might result in the loss of an existing or potential competitiveadvantage, 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 3CAW- 14-3909competitors without license from Westinghouse constitutes a competitive economicadvantage over other companies.(b) It consists of supporting data, including test data, relative to a process (orcomponent, structure, tool, method, etc.), the application of which data secures acompetitive economic advantage, e.g., by optimization or improved marketability.(c) Its use by a competitor would reduce his expenditure of resources or improve hiscompetitive position in the design, manufacture, shipment, installation, assurance ofquality, or licensing a similar product.(d) It reveals cost or price information, production capacities, budget levels, orcommercial strategies of Westinghouse, its customers or suppliers.(e) It reveals aspects of past, present, or future Westinghouse or customer fundeddevelopment 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 thefollowing:(a) The use of such information by Westinghouse gives Westinghouse a competitiveadvantage over its competitors. It is, therefore, withheld from disclosure to protectthe Westinghouse competitive position.(b) It is information that is marketable in many ways. The extent to which suchinformation is available to competitors diminishes the Westinghouse ability to sellproducts and services involving the use of the information.(c) Use by our competitor would put Westinghouse at a competitive disadvantage byreducing his expenditure of resources at our expense.

4CAW-14-3909(d) Each component of proprietary information pertinent to a particular competitiveadvantage is potentially as valuable as the total competitive advantage. Ifcompetitors acquire components of proprietary information, any one componentmay be the key to the entire puzzle, thereby depriving Westinghouse of acompetitive advantage.(e) Unrestricted disclosure would jeopardize the position of prominence ofWestinghouse in the world market, and thereby give a market advantage to thecompetition of those countries.(t) The Westinghouse capacity to invest corporate assets in research and developmentdepends upon the success in obtaining and maintaining a competitive advantage.(iv) The information is being transmitted to the Commission in confidence and, under theprovisions 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 availableinformation has not been previously employed in the same original manner or method to thebest of our knowledge and belief.(vi) The proprietary information sought to be withheld in this submittal is that which isappropriately marked in WCAP-17639-P, Revision 3, "Instrumentation Description for thePeach Bottom Unit 2 Replacement Steam Dryer" (Proprietary) for submittal to theCommission, being transmitted by Exelon Generation letter and Application for WithholdingProprietary Information from Public Disclosure, to the Document Control Desk. Theproprietary information as submitted by Westinghouse is that associated with the review of theReplacement Steam Dryer design and analysis which is a part of the Extended Power UprateLicense Amendment Request for Peach Bottom Units 2 and 3, and may be used only for thatpurpose.

5CAW-14-3909(a) This information is part of that which will enable Westinghouse to:(i) Assist Exelon Generation in obtaining NRC review of the Peach BottomAtomic Power Station Units 2 and 3 License Amendment Request.(b) Further this information has substantial commercial value as follows:(i) Westinghouse plans to sell the use of this information to its customers forpurposes of plant specific replacement steam dryer analysis for licensingbasis applications.(ii) Its use by a competitor would improve their competitive position in thedesign and licensing of a similar product for BWR steam dryer analysismethodology.(iii) The information requested to be withheld reveals the distinguishing aspectsof a methodology which was developed by Westinghouse.Public disclosure of this proprietary information is likely to cause substantial harm to thecompetitive position of Westinghouse because it would enhance the ability of competitors toprovide similar technical justifications and licensing defense services for commercial powerreactors without commensurate expenses. Also, public disclosure of the information wouldenable others to use the information to meet NRC requirements for licensing documentationwithout purchasing the right to use the information.The development of the technology described in part by the information is the result ofapplying the results of many years of experience in an intensive Westinghouse effort and theexpenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technicalprograms would have to be performed and a significant manpower effort, having therequisite talent and experience, would have to be expended.Further the deponent sayeth not.

Proprietary Information NoticeTransmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRCin connection with requests for generic and/or plant-specific review and approval.In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning theprotection of proprietary information so submitted to the NRC, the information which is proprietary in theproprietary versions is contained within brackets, and where the proprietary information has been deletedin the non-proprietary versions, only the brackets remain (the information that was contained within thebrackets in the proprietary versions having been deleted). The justification for claiming the informationso 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 beingidentified as proprietary or in the margin opposite such information. These lower case letters refer to thetypes 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 NoticeThe reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted tomake the number of copies of the information contained in these reports which are necessary for itsinternal 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 publicdisclosure to the extent such information has been identified as proprietary by Westinghouse, copyrightprotection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC ispermitted to make the number of copies beyond those necessary for its internal use which are necessary inorder to have one copy available for public viewing in the appropriate docket files in the public documentroom in Washington, DC and in local public document rooms as may be required by NRC regulations ifthe number of copies submitted is insufficient for this purpose. Copies made by the NRC must includethe copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

9 WestinghouseWestinghouse Electric CompanyEngineering, Equipment and Major Projects1000 Westinghouse DriveCranberry Township, Pennsylvania 16066USAU.S. Nuclear Regulatory CommissionDocument Control Desk11555 Rockville PikeRockville, MD 20852Direct tel: (412) 374-4419Direct fax: (724) 720-0754e-mail: maurerbf@westinghouse.comWEC-PCH-RSD-14-033CAW-14-3910February 14, 2014APPLICATION FOR WITHHOLDING PROPRIETARYINFORMATION FROM PUBLIC DISCLOSURESubject: WCAP-1 7626-P, Revision 1, "Processing of Peach Bottom Unit 2 and Unit 3 MSL StrainGauge Data and Computation of Predicted EPU Signature" (Proprietary)The proprietary information for which withholding is being requested in the above-referenced report isfurther identified in Affidavit CAW-14-3910 signed by the owner of the proprietary information,Westinghouse Electric Company LLC. The Affidavit, which accompanies this letter, sets forth the basison which the information may be withheld from public disclosure by the Commission and addresses withspecificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission'sregulations.Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Exelon Generation.Correspondence with respect to the proprietary aspects of the application for withholding or theaccompanying Affidavit should reference CAW-14-3910 and should be addressed to James A. Gresham,Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 310, 1000 WestinghouseDrive, Cranberry Township, Pennsylvania 16066.Very truly yours,Bradley F. Maurer, Principal EngineerPlant LicensingEnclosures CAW-14-3910AFFIDAVITCOMMONWEALTH OF PENNSYLVANIA:ssCOUNTY OF BUTLER:Before me, the undersigned authority, personally appeared Bradley F. Maurer, who, being by meduly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf ofWestinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in thisAffidavit are true and correct to the best of his knowledge, information, and belief:Bradley F. Maurer, Principal EngineerPlant LicensingSworn to and subscribed before methis 14th day of February 2014Nofary PublicCOMMONWEALTH OF PENNSYLVANIANotarial SeatAnne M. Stegman, Notary PublicUnity Twp., Westmoreland CountyMy Commission Expires Aug. 7, 2016MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES 2CAW-14-3910(1) 1 am Principal Engineer, Plant Licensing, in Engineering, Equipment and Major Projects,Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specificallydelegated the function of reviewing the proprietary information sought to be withheld from publicdisclosure in connection with nuclear power plant licensing and rule making proceedings, and amauthorized to apply for its withholding on behalf of Westinghouse.(2) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of theCommission's regulations and in conjunction with the Wcstinghouse Application for WithholdingProprietary Information from Public Disclosure accompanying this Affidavit.(3) 1 have personal knowledge of the criteria and procedures utilized by Westinghouse in designatinginformation 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, thefollowing is furnished for consideration by the Commission in determining whether the informationsought 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 inconfidence by Westinghouse.(ii) The information is of a type customarily held in confidence by Westinghouse and notcustomarily disclosed to the public. Westinghouse has a rational basis for determining thetypes of information customarily held in confidence by it and, in that connection, utilizes asystem to determine when and whether to hold certain types of information in confidence.The application of that system and the substance of that system constitutes Westinghousepolicy and provides the rational basis required.Under that system, information is held in confidence if it falls in one or more of severaltypes, the release of which might result in the loss of an existing or potential competitiveadvantage, 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 3CAW-14-3910competitors without license from Westinghouse constitutes a competitive economicadvantage over other companies.(b) It consists of supporting data, including test data, relative to a process (orcomponent, structure, tool, method, etc.), the application of which data secures acompetitive economic advantage, e.g., by optimization or improved marketability.(c) Its use by a competitor would reduce his expenditure of resources or improve hiscompetitive position in the design, manufacture, shipment, installation, assurance ofquality, or licensing a similar product.(d) It reveals cost or price information, production capacities, budget levels, orcommercial strategies of Westinghouse, its customers or suppliers.(e) It reveals aspects of past, present, or future Westinghouse or customer fundeddevelopment plans and programs of potential commercial value to Westinghouse.(t) It contains patentable ideas, for which patent protection may be desirable.(iii) There are sound policy reasons behind the Westinghouse system which include thefollowing:(a) The use of such information by Westinghouse gives Westinghouse a competitiveadvantage over its competitors. It is, therefore, withheld from disclosure to protectthe Westinghouse competitive position.(b) It is information that is marketable in many ways. The extent to which suchinformation is available to competitors diminishes the Westinghouse ability to sellproducts and services involving the use of the information.(c) Use by our competitor would put Westinghouse at a competitive disadvantage byreducing his expenditure of resources at our expense.

4CAW-14-3910(d) Each component of proprietary information pertinent to a particular competitiveadvantage is potentially as valuable as the total competitive advantage. Ifcompetitors acquire components of proprietary information, any one componentmay be the key to the entire puzzle, thereby depriving Westinghouse of acompetitive advantage.(e) Unrestricted disclosure would jeopardize the position of prominence ofWestinghouse in the world market, and thereby give a market advantage to thecompetition of those countries.(f) The Westinghouse capacity to invest corporate assets in research and developmentdepends upon the success in obtaining and maintaining a competitive advantage,(iv) The information is being transmitted to the Commission in confidence and, under theprovisions 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 availableinformation has not been previously employed in the same original manner or method to thebest of our knowledge and belief.(vi) The proprietary information sought to be withheld in this submittal is that which isappropriately marked in WCAP-17626-P, Revision 1, "Processing of Peach Bottom Unit 2 andUnit 3 MSL Strain Gauge Data and Computation of Predicted EPU Signature" (Proprietary)for submittal to the Commission, being transmitted by Exelon Generation letter andApplication for Withholding Proprietary Information from Public Disclosure, to the DocumentControl Desk. The proprietary information as submitted by Westinghouse is that associatedwith the review of the Replacement Steam Dryer design and analysis which is a part of theExtended Power Uprate License Amendment Request for Peach Bottom Units 2 and 3, andmay be used only for that purpose.

5CAW-14-3910(a) This information is part of that which will enable Westinghouse to:(i) Assist Exelon Generation in obtaining NRC review of the Peach BottomAtomic Power Station Units 2 and 3 License Amendment Request.(b) Further this information has substantial commercial value as follows:(i) Westinghouse plans to sell the use of this information to its customers forpurposes of plant specific replacement steam dryer analysis for licensingbasis applications.(ii) Its use by a competitor would improve their competitive position in thedesign and licensing of a similar product for BWR steam dryer analysismethodology.(iii) The information requested to be withheld reveals the distinguishing aspectsof a methodology which was developed by Westinghouse.Public disclosure of this proprietary information is likely to cause substantial harm to thecompetitive position of Westinghouse because it would enhance the ability of competitors toprovide similar technical justifications and licensing defense services for commercial powerreactors without commensurate expenses. Also, public disclosure of the information wouldenable others to use the information to meet NRC requirements for licensing documentationwithout purchasing the right to use the information.The development of the technology described in part by the information is the result ofapplying the results of many years of cxperience in an intensive Westinghouse effort and theexpenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technicalprograms would have to be performed and a significant manpower effort, having therequisite talent and experience, would have to be expended.Further the deponent sayeth not.

Proprietary Information NoticeTransmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRCin connection with requests for generic and/or plant-specific review and approval.In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning theprotection of proprietary information so submitted to the NRC, the information which is proprietary in theproprietary versions is contained within brackets, and where the proprietary information has been deletedin the non-proprietary versions, only the brackets remain (the information that was contained within thebrackets in the proprietary versions having been deleted). The justification for claiming the informationso 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 beingidentified as proprietary or in the margin opposite such information. These lower case letters refer to thetypes 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 NoticeThe reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted tomake the number of copies of the information contained in these reports which are necessary for itsinternal 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 publicdisclosure to the extent such information has been identified as proprietary by Westinghouse, copyrightprotection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC ispermitted to make the number of copies beyond those necessary for its internal use which are necessary inorder to have one copy available for public viewing in the appropriate docket files in the public documentroom in Washington, DC and in local public document rooms as may be required by NRC regulations ifthe number of copies submitted is insufficient for this purpose. Copies made by the NRC must includethe copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

S WesinghouseU.S. Nuclear Regulatory CommissionDocument Control Desk11555 Rockville PikeRockville, MD 20852Westinghouse Electric CompanyEngineering, Equipment and Major Projects1000 Westinghouse DriveCranberry Township, Pennsylvania 16066USADirect tel: (412) 374-4419Direct fax: (724) 720-0754e-mail: maurerbf@westinghouse.comWEC-PCH-RSD-1 4-039CAW-14-3914February 25, 2014APPLICATION FOR WITHHOLDING PROPRIETARYINFORMATION FROM PUBLIC DISCLOSURESubject: WCAP-.1 7649-P, Revision 1, "Peach Bottom Units 2 and 3 ASME Code Stress Report"(Proprietary)The proprietary information for which withholding is being requested in the above-referenced report isfurther identified in Affidavit CAW- 14-391.4 signed by the owner of the proprietary in formation,Westinghouse Electric Company LLC. The Affidavit, which accompanies this letter, sets forth the basison which the information may be withheld from public disclosure by the Commission and addresses withspecificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission'sregulations.Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Exelon Generation.Correspondence with respect to the proprietary aspects of the application for withholding or theaccompanying Affidavit should reference CAW-14-3914 and should be addressed to James A. Gresham,Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 310, 1000 WestinghouseDrive, Cranberry Township, Pennsylvania 16066.Very truly yours,Bradley F. Maurer, Principal EngineerPlant LicensingEnclosures CAW-14-3914AFFIDAVITCOMMONWEALTH OF PENNSYLVANIA:ssCOUNTY OF BUTLER:Before me, the undersigned authority, personally appeared Bradley F. Maurer, who, being by meduly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf ofWestinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in thisAffidavit are true and correct to the best of his knowledge, information, and belief:Bradley F. Maurer, Principal EngineerPlant LicensingSworn to and subscribed before methis 25"' day of February 2014/ /7Notary PublicCOMMONWEALTH OF PENNSYLVANIANotarial SealAnne M. Stegman, Notary PublicUnity Twp., Westmoreland CountyMy Commission Expires Aug. 7, 2016MEMBER, PENNSyLvANIA ASSOCIATION OF NOTARIES 2CAW-14-3914(I) 1. am Principal Engineer, Plant Licensing, in Engineering, Equipment and Major Projects,Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specificallydelegated the function of reviewing the proprietary information sought to be withheld from publicdisclosure in connection with nuclear power plant licensing and rule making proceedings, and amauthorized to apply for its withholding on behalf of Westinghouse.(2) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of theCommission's regulations and in conjunction with the Westinghouse Application for WithholdingProprietary Information from Public Disclosure accompanying this Affidavit.(3) .1 have personal knowledge of the criteria and procedures utilized by Westinghouse in designatinginformation 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, thefollowing is furnished for consideration by the Commission in determining whether the informationsought 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 inconfidence by Westinghouse.(ii) The information is of a type customarily held in confidence by Westinghouse and notcustomarily disclosed to the public. Westinghouse has a rational basis for determining thetypes of information customarily held in confidence by it and, in that connection, utilizes asystem to determine when and whether to hold certain types of information in confidence.The application, of that system and the substance of that system constitutes Westinghousepolicy and provides the rational basis required.Under that system, information is held in confidence if it falls in one or more of severaltypes, the release of which might result in the loss of an existing or potential competitiveadvantage, 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 3CAW-14-3914competitors without license from Westinghouse constitutes a competitive economicadvantage over other companies.(b) It consists of supporting data, including test data, relative to a process (orcomponent, structure, tool, method, etc.), the application of which data secures acompetitive economic advantage, e.g., by optimization or improved marketability.(c) Its use by a competitor would reduce his expenditure of resources or improve hiscompetitive position in the design, manufacture, shipment, installation, assurance ofquality, or licensing a similar product.(d) It reveals cost or price information, production capacities, budget levels, orcommercial strategies of Westinghouse, its customers or suppliers.(e) It reveals aspects of past, present, or future Westinghouse or customer fundeddevelopment 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 thefollowing:(a) The use of such information by Westinghouse gives Westinghouse a competitiveadvantage over its competitors. It is, therefore, withheld from disclosure to protectthe Westinghouse competitive position.(b) It is information that is marketable in many ways. The extent to which suchinformation is available to competitors diminishes the Westinghouse ability to sellproducts and services involving the use of the information.(c) Use by our competitor would put Westinghouse at a competitive disadvantage byreducing his expenditure of resources at our expense.

4CAW-14-3914(d) Each component of proprietary information pertinent to a particular competitiveadvantage is potentially as valuable as the total competitive advantage. Ifcompetitors acquire components of proprietary information, any one componentmay be the key to the entire puzzle, thereby depriving Westinghouse of acompetitive advantage.(e) Unrestricted disclosure would jeopardize the position of prominence ofWestinghouse in the world market, and thereby give a market advantage to thecompetition of those countries.(f) The Westinghouse capacity to invest corporate assets in research and developmentdepends upon the success in obtaining and maintaining a competitive advantage.(iv) The information is being transmitted to the Commission in confidence and, under theprovisions 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 availableinformation has not been previously employed in the same original manner or method to thebest of our knowledge and belief.(vi) The proprietary information sought to be withheld in this submittal is that which isappropriately marked in WCAP- I 7649-P, Revision 1, "Peach Bottom Units 2 and 3 ASMECode Stress Report" (Proprietary) for submittal to the Commission, being transmitted byExelon Generation letter and Application for Withholding Proprietary Information from PublicDisclosure, to the Document Control Desk. The proprietary information as submitted byWestinghouse is that associated with the review of the Replacement Steam Dryer design andanalysis which is a part of the Extended Power Uprate License Amendment Request for PeachBottom Units 2 and 3, and may be used only for that purpose.

5CAW-14-3914(a) This information is part of that which will enable Westinghouse to:(i) Assist Exelon Generation in obtaining NRC review of the Peach BottomAtomic Power Station Units 2 and 3 License Amendment Request.(b) Further this information has substantial commercial value as follows:(i) Westinghouse plans to sell the use of this information to its customers forpurposes of plant specific replacement steam dryer analysis for licensingbasis applications.(ii) Its use by a competitor would improve their competitive position in thedesign and licensing of a similar product for BWR steam dryer analysismethodology.(iii) The information requested to be withheld reveals the distinguishing aspectsof a methodology which was developed by Westinghouse.Public disclosure of this proprietary information is likely to cause substantial harm to thecompetitive position of Westinghouse because it would enhance the ability of competitors toprovide similar technical justifications and licensing defense services for commercial powerreactors without commensurate expenses. Also, public disclosure of the information wouldenable others to use the information to meet NRC requirements for licensing documentationwithout purchasing the right to use the information.The development of the technology described in part by the information is the result ofapplying the results of many years of experience in an intensive Westinghouse effort and theexpenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technicalprograms would have to be perfonned and a significant manpower effort, having therequisite talent and experience, would have to be expended.Further the deponent sayeth not.

Proprietary Information NoticeTransmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRCin connection with requests for generic and/or plant-specific review and approval.In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning theprotection of proprietary information so submitted to the NRC, the information which is proprietary in theproprietary versions is contained within brackets, and where the proprietary information has been deletedin the non-proprietary versions, only the brackets remain (the information that was contained within thebrackets in the proprietary versions having been deleted), Thejustification for claiming the informationso 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 beingidentified as proprietary or in the margin opposite such information. These lower case letters refer to thetypes 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 NoticeThe reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted tomake the number of copies of the information contained in these reports which are necessary for itsinternal 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 publicdisclosure to the extent such information has been identified as proprietary by Westinghouse, copyrightprotection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC ispermitted to make the number of copies beyond those necessary for its internal use which are necessary inorder to have one copy available for public viewing in the appropriate docket files in the public documentroom in Washington, DC and in local public document rooms as may be required by NRC regulations ifthe number of copies submitted is insufficient for this purpose. Copies made by the NRC must includethe copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

SWestinghouseU.S. Nuclear Regulatory CommissionDocument Control Desk11555 Rockville PikeRockville, MD 20852Westinghouse Electric CompanyEngineering, Equipment and Major Projects1000 Westinghouse DriveCranberry Township, Pennsylvania 16066USADirect tel: (412) 374-4419Direct fax: (724) 720-0754e-mail: maurerbf@westinghouse.comWEC-PCH-RSD-14-034CAW-14-3915February 14, 2014APPLICATION FOR WITHHOLDING PROPRIETARYINFORMATION FROM PUBLIC DISCLOSURESubject: WCAP- 17590-P, Revision 2, "Peach Bottom Units 2 & 3 Replacement Steam Dryer AcousticLoad Definition" (Proprietary)The proprietary information for which withholding is being requested in the above-referenced report isfurther identified in Affidavit CAW-] 4-3915 signed by the owner of the proprietary information,Westinghouse Electric Company LLC. The Affidavit, which accompanies this letter, sets forth the basison which the information may be withheld from public disclosure by the Commission and addresses withspecificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission'sregulations.Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Exelon Generation.Correspondence with respect to the proprietary aspects of the application for withholding or theaccompanying Affidavit should reference CAW-14-3915 and should be addressed to James A. Gresham,Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 310, 1000 WestinghouseDrive, Cranberry Township, Pennsylvania 16066.Very truly yours,Bradley F. Maurer, Principal EngineerPlant LicensingEnclosures CAW-14-3915AFFIDAVITCOMMONWEALTH OF PENNSYLVANIA:ssCOUNTY OF BUTLER:Before me, the undersigned authority, personally appeared Bradley F. Maurer, who, being by meduly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf ofWestinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in thisAffidavit are true and correct to the best of his knowledge, information, and belief:Bradley F. Maurer, Principal EngineerPlant LicensingSworn to and subscribed before methis 14th day of February 2014Notary PublicMS7, 2016MEMER, PENNSYLVANL4 ASSOCIA71ON OF NOTAPJES 2CAW-14-3915(1) I am Principal Engineer, Plant Licensing, in Engineering, Equipment and Major Projects,Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specificallydelegated the function of reviewing the proprietary information sought to be withheld from publicdisclosure in connection with nuclear power plant licensing and rule making proceedings, and amauthorized to apply for its withholding on behalf of Westinghouse.(2) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of theCommission's regulations and in conjunction with the Westinghouse Application for WithholdingProprietary Information from Public Disclosure accompanying this Affidavit.(3) 1 have personal knowledge of the criteria and procedures utilized by Westinghouse in designatinginformation 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, thefollowing is furnished for consideration by the Commission in determining whether the informationsought 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 inconfidence by Westinghouse.(ii) The information is of a type customarily held in confidence by Westinghouse and notcustomarily disclosed to the public. Westinghouse has a rational basis for determining thetypes of information customarily held in confidence by it and, in that connection, utilizes asystem to determine when and whether to hold certain types of information in confidence.The application of that system and the substance of that system constitutes Westinghousepolicy and provides the rational basis required.Under that system, information is held in confidence if it falls in one or more of severaltypes, the release of which might result in the loss of an existing or potential competitiveadvantage, 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 3CAW-14-3915competitors without license from Westinghouse constitutes a competitive economicadvantage over other companies.(b) It consists of supporting data, including test data, relative to a process (orcomponent, structure, tool, method, etc.), the application of which data secures acompetitive economic advantage, e.g., by optimization or improved marketability.(c) Its use by a competitor would reduce his expenditure of resources or improve hiscompetitive position in the design, manufacture, shipment, installation, assurance ofquality, or licensing a similar product.(d) It reveals cost or price information, production capacities, budget levels, orcommercial strategies of Westinghouse, its customers or suppliers.(e) It reveals aspects of past, present, or future Westinghouse or customer fundeddevelopment 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 thefollowing:(a) The use of such information by Westinghouse gives Westinghouse a competitiveadvantage over its competitors. It is, therefore, withheld from disclosure to protectthe Westinghouse competitive position.(b) It is information that is marketable in many ways. The extent to which suchinformation is available to competitors diminishes the Westinghouse ability to sellproducts and services involving the use of the information.(c) Use by our competitor would put Westinghouse at a competitive disadvantage byreducing his expenditure of resources at our expense.

4CAW-14-3915(d) Each component of proprietary information pertinent to a particular competitiveadvantage is potentially as valuable as the total competitive advantage. Ifcompetitors acquire components of proprietary information, any one componentmay be the key to the entire puzzle, thereby depriving Westinghouse of acompetitive advantage.(e) Unrestricted disclosure would jeopardize the position of prominence ofWestinghouse in the world market, and thereby give a market advantage to thecompetition of those countries.(f) The Westinghouse capacity to invest corporate assets in research and developmentdepends upon the success in obtaining and maintaining a competitive advantage.(iv) The information is being transmitted to the Commission in confidence and, under theprovisions 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 availableinformation has not been previously employed in the same original manner or method to thebest of our knowledge and belief.(vi) The proprietary information sought to be withheld in this submittal is that which isappropriately marked in WCAP-1 7590-P, Revision 2, "Peach Bottom Units 2 & 3Replacement Steam Dryer Acoustic Load Definition" (Proprietary) for submittal to theCommission, being transmitted by Exelon Generation letter and Application for WithholdingProprietary Information from Public Disclosure, to the Document Control Desk. Theproprietary information as submitted by Westinghouse is that associated with the review of theReplacement Steam Dryer design and analysis which is a part of the Extended Power UprateLicense Amendment Request for Peach Bottom Units 2 and 3, and may be used only for thatpurpose.

5CAW-14-3915(a) This information is part of that which will enable Westinghouse to:(i) Assist Exelon Generation in obtaining NRC review of the Peach BottomAtomic Power Station Units 2 and 3 License Amendment Request.(b) Further this information has substantial commercial value as follows:(i) Westinghouse plans to sell the use of this information to its customers forpurposes of plant specific replacement steam dryer analysis for licensingbasis applications.(ii) Its use by a competitor would improve their competitive position in thedesign and licensing of a similar product for BWR steam dryer analysismethodology.(iii) The information requested to be withheld reveals the distinguishing aspectsof a methodology which was developed by Westinghouse.Public disclosure of this proprietary information is likely to cause substantial harm to thecompetitive position of Westinghouse because it would enhance the ability of competitors toprovide similar technical justifications and licensing defense services for commercial powerreactors without commensurate expenses. Also, public disclosure of the information wouldenable others to use the information to meet NRC requirements for licensing documentationwithout purchasing the right to use the information.The development of the technology described in part by the information is the result ofapplying the results of many years of experience in an intensive Westinghouse effort and theexpenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technicalprograms would have to be performed and a significant manpower effort, having therequisite talent and experience, would have to be expended.Further the deponent sayeth not.

Proprietary Information NoticeTransmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRCin connection with requests for generic and/or plant-specific review and approval.In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning theprotection of proprietary information so submitted to the NRC, the information which is proprietary in theproprietary versions is contained within brackets, and where the proprietary information has been deletedin the non-proprietary versions, only the brackets remain (the information that was contained within thebrackets in the proprietary versions having been deleted). The justification for claiming the informationso 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 beingidentified as proprietary or in the margin opposite such information. These lower case letters refer to thetypes 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 NoticeThe reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted tomake the number of copies of the information contained in these reports which are necessary for itsinternal 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 publicdisclosure to the extent such information has been identified as proprietary by Westinghouse, copyrightprotection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC ispermitted to make the number of copies beyond those necessary for its internal use which are necessary inorder to have one copy available for public viewing in the appropriate docket files in the public documentroom in Washington, DC and in local public document rooms as may be required by NRC regulations ifthe number of copies submitted is insufficient for this purpose. Copies made by the NRC must includethe copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

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