ML15350A018

Fort Calhoun, Unit 1 - Transmittal of Response to Remaining Questions from NRC Request for Additional Information (RAI) Regarding Reactor Vessel Internal Component Aging Management Program

ML15350A018
Person / Time
Site:	Fort Calhoun
Issue date:	11/30/2015
From:	Cortopassi L P Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML15350A009	List: LIC-15-0117, Enclosure 8, PWROG-14082-NP, Revision 0, Summary Report for the Fuel Design / Fuel Management Assessments to Demonstrate MRP-227-A Applicability. (Non-Proprietary) ML15350A018 ML15350A019 ML15350A020
References
CAW-15-4212, LIC-15-0117
Download: ML15350A018 (21)

Text

Proprietary- WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390Enclosures 1, 2, and 4, contain Proprietary information.Upon removal of Enclosures 1, 2, and 4, this letter is Decontrolled.inmmmOmaha Public Power District444 South 16th Street MallOmaha, NE 68102-2247LIC-15-01 17November 30, 2015U.S. Nuclear Regulatory CommissionAttn: Document Control DeskWashington, DC 20555-0001Fort Calhoun Station, Unit No. 1Renewed Facility Operating License No. DPR-40NRC Docket No. 50-285

Subject:

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

References:

1. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "Submittal ofReactor Vessel Internal (RVI) Component Aging Management Program (AMP) forFort Calhoun Station (FCS), Unit No.1," dated September 27, 2012 (ML12276A005)(LIC-1 2-0144)2. E-mail from NRC (J. Rankin) to OPPD (M. Edwards I B. Hansher), "Request forAdditional Information -Reactor Vessel Internal Component Aging ManagementProgram (MF341 2)," dated July 8, 2014 (ML14190A211 )3. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "OPPDResponse to NRC Request for Additional Information Regarding Fort Calhoun Station,Unit No.1 Reactor Vessel Internal Component Aging Management Program," datedAugust 22, 2014 (ML1 4234A530) (LIC-1 4-0107)4. Letter from NRC (C. F. Lyon) to OPPD (L. P. Cortopassi), "Fort Calhoun Station, UnitNo. 1 -Request for Additional Information RE: Aging Management Program forReactor Vessel Internals (TAC No. MF341 2)," dated March 3, 2015 (ML15057A015)(NRC-i15-010)5. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "OPPDResponse to NRC Request for Additional Information Regarding Aging ManagementProgram For Reactor Vessel Internals (TAC No. MF341 2," dated April 13, 2015(ML1 51 03A642) (LIC-1 5-0054)This letter responds to the remaining questions from Reference 2 regarding the Fort Calhoun Station(FCS), Reactor Vessel Internal (RV]) Aging Management Program (Reference 1). In Reference 3, theOmaha Public Power District (OPPD) responded to questions 4, 6, 7, 8, and 9. Enclosure 1 respondsto the remaining questions (i.e., 1, 2, 3, and 5). Please note that Enclosures 1, 2 and 4 to this lettercontain information that is proprietary to Westinghouse and should be withheld from public disclosure inaccordance with 10 CFR 2.390.Proprietary- WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390Enclosures 1, 2, and 4, contain Proprietary information.Upon removal of Enclosures 1, 2, and 4, this letter is Decontrolled.Ar IEmployment with Equal Opportunity Proprietary- WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390Enclosures 1, 2, and 4 contain Proprietary information.Upon removal of Enclosures 1, 2, and 4 this letter is Decontrolled.U. S. Nuclear Regulatory CommissionLIC-1 5-0117Page 2The Electric Power Research Institute's Materials Reliability Program (MRP) Report MRP-227-A,"Pressurized Water Reactor Internals Inspection and Evaluation Guidelines," December 2008 (ADAMSAccession No. ML090160205), and its supporting reports were used as technical bases for developingthe Aging Management Program (AMP). In Reference 5, OPPD responded to an NRC request foradditional information (RAI) related to the NRC staffs Action Item 3 addressed in the staffs SafetyEvaluation (SE) for MRP-227-A.The following proprietary Westinghouse documents support the Enclosure 1 response to the Reference2, NRC RAI and are provided to assist the NRC in its review:1. PWROG-15030-P, Rev. 0, "Evaluation of Fort Calhoun Fuel Alignment Plate Fluence for MRP-227-A" (Proprietary) (Enclosure 2).2. PWROG-14082-P, Rev. 0, "Fort Calhoun Station Summary Report for the Fuel Design / FuelManagement Assessments to Demonstrate MRP-227-A Applicability" (Proprietary) (Enclosure4).Enclosures 2 and 4 contain information proprietary to Westinghouse Electric Company LLC, and aresupported by Affidavits in Enclosures 3 and 5 signed by Westinghouse, the owner of the information.Enclosure 1 restates proprietary information from Enclosures 2 and 4 to respond to NRC questions.The Affidavits set forth the basis on which the information may be withheld from public disclosure by theCommission and addresses with specificity the considerations listed in paragraph (b)(4) of Section2.390 of the Commission's regulations.Accordingly, it is respectfully requested that Enclosures 1, 2, and 4, which contain information that isproprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section2.390 of the Commission's regulations.Enclosures 6, 7, and 8 are non-proprietary versions of Enclosures 1, 2, and 4 respectively that aresuitable for public disclosure.Correspondence with respect to the copyright or proprietary aspects of Enclosures 1, 2, and 4 or thesupporting Westinghouse Affidavits should reference CAW-15-4212 and/or CAW-15-4198 and beaddressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company,1000 Westinghouse Drive, Building 3 Suite 310, Cranberry Township, Pennsylvania 16066.This letter contains no regulatory commitments.If you should have any questions regarding this submittal or require additional information, pleasecontact Mr. Bill R. Hansher, Principal Regulatory Engineer, at 402-533-6894.Respectfully,,-Louis P. CortopassiSite Vice President and CNOProprietary-WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390Enclosures 1, 2, and 4 contain Proprietary information.Upon removal of Enclosures 1, 2, and 4 this letter is Decontrolled.

Proprietary- WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390Enclosures 1, 2, and 4 contain Proprietary information.Upon removal of Enclosures 1, 2, and 4 this letter is Decontrolled.U. S. Nuclear Regulatory CommissionLIC-i5-01 17Page 3

Enclosures:

1. OPPD Response to Remaining Questions from NRC Request for AdditionalInformation Regarding Fort Calhoun Station, Reactor Vessel Internal ComponentAging Management Program (Proprietary)2. PWROG-15030-P, Rev. 0, "Evaluation of Fort Calhoun Fuel Alignment Plate Fluencefor MRP-227-A" (Proprietary)3. Westinghouse Application for Withholding Proprietary Information from PublicDisclosure CAW-15-4212, accompanying Affidavit, Proprietary Information Notice,and Copyright Notice dated June 17, 20154. PWROG-14082-P, Rev. 0, "Fort Calhoun Station Summary Report for the FuelDesign / Fuel Management Assessments to Demonstrate MRP-227-A Applicability"(Proprietary)5. Westinghouse Application for Withholding Proprietary Information from PublicDisclosure CAW-15-4198, accompanying Affidavit, Proprietary Information Notice,and Copyright Notice dated June 1, 20156. OPPD Response to Remaining Questions from NRC Request for AdditionalInformation Regarding Fort Calhoun Station, Reactor Vessel Internal ComponentAging Management Program (Non-Proprietary)7. PWROG-15030-NP, Rev. 0, "Evaluation of Fort Calhoun Fuel Alignment PlateFluence for MRP-227-A" (Non-Proprietary)8. PWROG-14082-NP, Rev. 0, "Fort Calhoun Station Summary Report for the FuelDesign / Fuel Management Assessments to Demonstrate MRP-227-A Applicability"(Non-Proprietary)Proprietary- WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390Enclosures 1, 2, and 4 contain Proprietary information.Upon removal of Enclosures 1, 2, and 4 this letter is Decontrolled.

LIC-1 5-0117Enclosure 3Page 1CAW-1 5-4212"Application for Withholding ProprietaryInformation from Public Disclosure"Proprietary- WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390Enclosures I, 2, and 4 contain Proprietary information.Upon removal of Enclosures 1, 2, and 4 this letter is Decontrolled.

Westin hngheo useo ElctioCmpnW estin houseEngineering, Equipment and Major Projects1000 Westinghouse Drive, Building SCranberry Township, Pennsylvania 16066USAU.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643Document Control Desk Direet fax: (724) 940-856011555 Rockville Pike e-mail: greshaja@westinghouse.comRockville, MD 20852CAW-15-421 2June 17, 2015APPLICATION FOR WITHHOLDING PROPRIETARYINFORMATION FROM PUBLIC DISCLOSURE

Subject:

PWROG-15030-P, Rev. 0, "Evaluation of Fort Calhoun Fuel Alignment Plate Fluence forMRP-227-A" (Proprietary)The proprietary information for which withholding is being requested in the above-referenced report isfurther identified in Affidavit CAW-15-4212 signed by the owner of the proprietary information,Westinghouse Electric Company LLC. The Affidavit, which accompanies this letter, sets forth the 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 Pressurized WaterReactor Owners Group (PWROG).Correspondence with respect to the proprietary aspects of the Application for Withholding or theWestinghouse Affidavit should reference CAW-15-4212 and should be addressed to James A. Greshanm,Manager; Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive,Building 3 Suite 310, Cranberry Township, Pennsylvania 16066.Very truly yours,GrshmMaagerRegulatory Compliance CAW- 15-4212June 17, 2015AFFIDAVITCOMMONWEALTH OF PENNSYLVANIA:SSCOUNTY OF BUTLER:I, James A. Gresham, am authorized to execute this Affidavit on behalf of Westinghouse ElectricCompany LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true andcorrect to the best of my knowledge, information, and belief.Jaes-A. Gresham, ManagerRegulatory Compliance 2 CAW-15-421 2(1) I am Manager, Regulatory Compliance, Westinghouse Electric Company LLC (Westinghouse),and as such, I have been specifically delegated the function of reviewing the proprietaryinformation sought to be withheld from public disclosure in connection with nuclear power plantlicensing and rule making proceedings, and am authorized to apply for its withholding on behalfof Westinghouse.(2) I 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) I 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,the following is furnished for consideration by the Commission in determining whether theinformation sought to be withheld from public disclosure should be withheld.(i) The information sought to be withheld from public disclosure is owned and has been heldin confidence 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 determiningthe types of information customarily held in confidence by it and, in that connection,utilizes a system to determine when and whether to hold certain types of information inconfidence. The application of that system and the substance of that system constituteWestinghouse policy 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 33 ~CAW-15-421 2Westinghouse's competitors without license from Westinghouse constitutes acompetitive economic advantage 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 improvedmarketability.(c) Its use by a competitor would reduce his expenditure of resources or improve hiscompetitive position in the design, manufacture, shipment, installation, assuranceof quality, 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 toprotect the 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 tosell products 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.

44 CAW-15-4212(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, th~ereby depriving Westinghouse of acompetitive advantage.Ce) 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 anddevelopment depends upon the success in obtaining and maintaining acompetitive 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 theCommission.(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 tothe best of our knowledge and belief.(vi) The proprietary information sought to be withheld in this submittal is that which isappropriately marked in PWROG-1 503 0-P, Rev. 0, "Evaluation of Fort Calhoun FuelAlignment Plate Fluence for MRP-227-A" (Proprietary), for submittal to the Commission,being transmitted by PWROG letter OG-15-212 and Application for WithholdingProprietary Information from Public Disclosure, to the Document Control Desk. Theproprietary information as submitted by Westinghouse is that associated with the NRCletter, "Request for Additional Information -Reactor Vessel Internal Component AgingManagement Program (MF3412)," ML14190A21 1, July 8, 2014 and may be used only forthat purpose.

55 CAW-15-4212(a) This information is part of that which will enable Westinghouse to:(i) Support reactor vessel internals aging management.(b) Further this information has substantial commercial value as follows:(i) Westinghouse plans to sell the use of similar information to its customersfor the purpose of supporting reactor internals aging management(ii) Westinghouse can sell support and defense of industry guidelines andacceptance criteria for plant-specific applications.(iii) The information requested to be withheld reveals the distinguishingaspects of 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 ofcompetitors to provide similar technical evaluation justifications and licensing defenseservices for commercial power reactors without commensurate expenses. Also, publicdisclosure of the information would enable others to use the information to meet NRCrequirements for licensing documentation without purchasing the right to use theinformation.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 andthe expenditure 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 is the proprietary and/or non-proprietary version of a document furnished to theNRC associated with the NRC Letter, "Request for Additional Information -Reactor Vessel InternalComponent Aging Management Program (MF3412)," ML14190A21 1 July 8, 2014 and may be used onlyfor that purpose.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.

Omaha Public Power DistrictLetter for Transmittal to the NRCThe following paragraphs should be included in your letter to the NRC Document Control Desk:Enclosed are:1. PWROG- 1 5030-P, Rev. 0, "Evaluation of Fort Calhoun Fuel Alignment Plate Fluence forMvIRP-227-A" (Proprietary)2. PWROG-1 5030-NP, Rev. 0, "Evaluation of Fort Calhoun Fuel Alignment Plate Fluence forMRP-227-A" (Non-Proprietary)Also enclosed is the Westinghouse Application for Withholding Proprietary Information from PublicDisclosure CAW.4..417, accompanying Affidavit, Proprietary Information Notice, and CopyrightNotice.As Item 1 contains information proprietary to Westinghouse Electric Company LLC, it is supported by anAffidavit signed by Westinghouse, the owner of the information. The Affidavit sets forth the basis onwhich the information may be withheld from public disclosure by Commission and addresses withspecificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations.Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse bewithheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission'sregulations.Correspondence with respect to the copyright or proprietary aspects of the items listed above or thesupporting Westinghouse Affidavit should reference and should be addressed toJames A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000Westinghouse Drive, Building 3 Suite 310, Cranberry Township, Pennsylvania 16066.

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

~~~Westinghouse Electricu Co mpaoo onyEngineering, Equipment and Major ProjectsUSAU.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643Document Control Desk Direct fax: (724) 940-856011555 Rockville Pike e-mil: greshaja@westinghouse.comRockville, MD 20852CAW- 15-4198June 1, 2015APPLICATION FOR WITHHOLDING PROPRIETARYINFORMATION FROM PUBLIC DISCLOSURE

Subject:

PWROG-14082-P, Rev. 0, "Fort Calhoun Station Summary Report for the Fuel Design I FuelManagement Assessments to Demonstrate MRP-227-A Applicability" (Proprietary)The proprietary information for which withholding is being requested in the above-referenced report isfurther identified in Affidavit CAW- 15-4 198 signed by the owner of the proprietary information,Westinghouse Electric Company LLC. The Affidavit, which accompanies this letter, sets forth the 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 Pressurized WaterReactor Owners Group (PWROG).Correspondence with respect to the proprietary aspects of the Application for Withholding or theWestinghouse Affidavit should reference CAW- 15-4198 and should be addressed to James A. Gresham,Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive,Building 3 Suite 310, Cranberry Township, Pennsylvania 16066.Very truly yours,(/JmesA. resham, ManagerRegulatory Compliance CAW-l 5-4198June 1, 2015AFFIDAVITCOMMONWEALTH OF PENNSYLVANIA:5$COUNTY OF BUTLER:I, James A. Gresham, am authorized to execute this Affidavit on behalf of Westinghouse ElectricCompany LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true andcorrect to the best of my knowledge, information, and belief.41ames A. Gresham, ManagerRegulatory Compliance 22 CAW-I15-4198(1) 1 am Manager, Regulatory Compliance, Westinghouse Electric Company LLC (Westinghouse),and as such, I have been specifically delegated the function of reviewing the proprietaryinformation sought to be withheld from public disclosure in connection with nuclear power plantlicensing and rule making proceedings, and am authorized to apply for its withholding on behalfof Westinghouse.(2) 1 am making this Affidavit in conformance with the provisions of 10 CER Section 2.390 of theCommissions'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,the following is furnished for consideration by the Commission in determining whether theinformation sought to be withheld from public disclosure should be withheld.(i) The information sought to be withheld from public disclosure is owned and has been heldin confidence by Westinghouse.(ii) The information is ofra type customarily held in confidence by Westinghouse and notcustomarily disclosed to the public. Westinghouse has a rational basis for determiningthe types of information customarily held in confidence by it and, in that connection,utilizes a system to determine when and whether to hold certain types of information inconfidence. The application of that system and the substance of that system constituteWestinghouse policy 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 33 CAW-l 5-4198Westinghouse's competitors without license from Westinghouse constitu~tes acompetitive economic advantage 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 improvedmarketability.(c) Its use by a competitor would reduce his expenditure of resources or improve hiscompetitive position in the design, manufacture, shipment, installation, assuranceof quality, 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.(0) 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 toprotect the 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 tosell products 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.

44 CAW-15-4198(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 anddevelopment depends upon the success in obtaining and maintaining acompetitive 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 theCommission.(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 tothe best of our knowledge and belief.(vi) The proprietary information sought to be withheld in this submittal is that which isappropriately marked in PWROG-14082-P, Rev. 0, "Fort Calhoun Station Summary Reportfor the Fuel Design / Fuel Management Assessments to Demonstrate MRP-227-AApplicability" (Proprietary), for submittal to the Commission, being transmitted byPWROG letter OG- 15-212 and Application for Withholding Proprietary Information fromPublic Disclosure, to the Document Control Desk. The proprietary information assubmitted by Westinghouse is that associated with the NRC letter, "Request for AdditionalInformation -Reactor Vessel Internal Component Aging Management Program(MF3412)," ML14190A2 11 July 8, 2014 and may be used only for that purpose.

55 CAW- 15-4I198(a) This information is part of that which will enable Westinghouse to:(i) Support reactor vessel internals aging management.(b) Further this information has substantial commercial value as follows:(i) Westinghouse plans to sell the use of similar information to its customersfor the purpose of supporting reactor internals aging management(ii) Westinghouse can sell support and defense of industry guidelines andacceptance criteria for plant-specific applications.(iii) The information requested to be withheld reveals the distinguishingaspects ofra 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 ofcompetitors to provide similar technical evaluation justifications and licensing defenseservices for commercial power reactors without commensurate expenses. Also, publicdisclosure of the information would enable others to use the information to meet NRCrequirements for licensing documentation without purchasing the right to use theinformation.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 andthe expenditure 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 is the proprietary and non-proprietary versions of a document furnished to the NRCassociated with the NRC letter, "Request for Additional Information -Reactor Vessel InternalComponent Aging Management Program (MF34 12)," ML14190A21 1 July 8, 2014 and may be used onlyfor that purpose.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 vase letters refer to thetypes of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a)through (4Xii)(f) of the Affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).COPYRIGHT 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 ofra 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.

Omaha Public Power DistrictLeotter for Transmittal to the NRCThe following paragraphs should be included in your letter to the NRC Document Control Desk:Enclosed are:1. PWROG-14082-P, Rev. 0, "Fort Calhoun Station Summary Report for the Fuel Design /FuelManagement Assessments to Demonstrate MRP-227-A Applicability" (Proprietary)2. PWROG-14082-NP, Rev. 0, "Fort Calhoun Station Summary Report for the Fuel Design / FuelManagement Assessments to Demonstrate MRP-227-A Applicability" (Non-Proprietary)Also enclosed is the Westinghouse Application for Withholding Proprietary Information from PublicDisclosure CAW-l15-4198, accompanying Affidavit, Proprietary Information Notice, and CopyrightNotice.As Item 1 contains information proprietary to Westinghouse Electric Company LLC, it is supported by anAffidavit signed by Westinghouse, the owner of the information. The Affidavit sets forth the basis onwhich the information may be withheld from public disclosure by the Commission and addresses withspecificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations.Accordingly, it is respectfiully requested that the information which is proprietary to Westinghouse bewithheld from public disclosure in accordance with 1 0 CFR Section 2.390 of the Commission'ssregulations.Correspondence with respect to the copyright or proprietary aspects of the items listed above or thesupporting Westinghouse Affidavit should reference CAW-1 5-4198 and should be addressed toJames A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000Westinghouse Drive, Building 3 Suite 310, Cranberry Township, Pennsylvania 16066.

Proprietary- WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390Enclosures 1, 2, and 4, contain Proprietary information.Upon removal of Enclosures 1, 2, and 4, this letter is Decontrolled.inmmmOmaha Public Power District444 South 16th Street MallOmaha, NE 68102-2247LIC-15-01 17November 30, 2015U.S. Nuclear Regulatory CommissionAttn: Document Control DeskWashington, DC 20555-0001Fort Calhoun Station, Unit No. 1Renewed Facility Operating License No. DPR-40NRC Docket No. 50-285

Subject:

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

References:

1. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "Submittal ofReactor Vessel Internal (RVI) Component Aging Management Program (AMP) forFort Calhoun Station (FCS), Unit No.1," dated September 27, 2012 (ML12276A005)(LIC-1 2-0144)2. E-mail from NRC (J. Rankin) to OPPD (M. Edwards I B. Hansher), "Request forAdditional Information -Reactor Vessel Internal Component Aging ManagementProgram (MF341 2)," dated July 8, 2014 (ML14190A211 )3. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "OPPDResponse to NRC Request for Additional Information Regarding Fort Calhoun Station,Unit No.1 Reactor Vessel Internal Component Aging Management Program," datedAugust 22, 2014 (ML1 4234A530) (LIC-1 4-0107)4. Letter from NRC (C. F. Lyon) to OPPD (L. P. Cortopassi), "Fort Calhoun Station, UnitNo. 1 -Request for Additional Information RE: Aging Management Program forReactor Vessel Internals (TAC No. MF341 2)," dated March 3, 2015 (ML15057A015)(NRC-i15-010)5. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "OPPDResponse to NRC Request for Additional Information Regarding Aging ManagementProgram For Reactor Vessel Internals (TAC No. MF341 2," dated April 13, 2015(ML1 51 03A642) (LIC-1 5-0054)This letter responds to the remaining questions from Reference 2 regarding the Fort Calhoun Station(FCS), Reactor Vessel Internal (RV]) Aging Management Program (Reference 1). In Reference 3, theOmaha Public Power District (OPPD) responded to questions 4, 6, 7, 8, and 9. Enclosure 1 respondsto the remaining questions (i.e., 1, 2, 3, and 5). Please note that Enclosures 1, 2 and 4 to this lettercontain information that is proprietary to Westinghouse and should be withheld from public disclosure inaccordance with 10 CFR 2.390.Proprietary- WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390Enclosures 1, 2, and 4, contain Proprietary information.Upon removal of Enclosures 1, 2, and 4, this letter is Decontrolled.Ar IEmployment with Equal Opportunity Proprietary- WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390Enclosures 1, 2, and 4 contain Proprietary information.Upon removal of Enclosures 1, 2, and 4 this letter is Decontrolled.U. S. Nuclear Regulatory CommissionLIC-1 5-0117Page 2The Electric Power Research Institute's Materials Reliability Program (MRP) Report MRP-227-A,"Pressurized Water Reactor Internals Inspection and Evaluation Guidelines," December 2008 (ADAMSAccession No. ML090160205), and its supporting reports were used as technical bases for developingthe Aging Management Program (AMP). In Reference 5, OPPD responded to an NRC request foradditional information (RAI) related to the NRC staffs Action Item 3 addressed in the staffs SafetyEvaluation (SE) for MRP-227-A.The following proprietary Westinghouse documents support the Enclosure 1 response to the Reference2, NRC RAI and are provided to assist the NRC in its review:1. PWROG-15030-P, Rev. 0, "Evaluation of Fort Calhoun Fuel Alignment Plate Fluence for MRP-227-A" (Proprietary) (Enclosure 2).2. PWROG-14082-P, Rev. 0, "Fort Calhoun Station Summary Report for the Fuel Design / FuelManagement Assessments to Demonstrate MRP-227-A Applicability" (Proprietary) (Enclosure4).Enclosures 2 and 4 contain information proprietary to Westinghouse Electric Company LLC, and aresupported by Affidavits in Enclosures 3 and 5 signed by Westinghouse, the owner of the information.Enclosure 1 restates proprietary information from Enclosures 2 and 4 to respond to NRC questions.The Affidavits set forth the basis on which the information may be withheld from public disclosure by theCommission and addresses with specificity the considerations listed in paragraph (b)(4) of Section2.390 of the Commission's regulations.Accordingly, it is respectfully requested that Enclosures 1, 2, and 4, which contain information that isproprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section2.390 of the Commission's regulations.Enclosures 6, 7, and 8 are non-proprietary versions of Enclosures 1, 2, and 4 respectively that aresuitable for public disclosure.Correspondence with respect to the copyright or proprietary aspects of Enclosures 1, 2, and 4 or thesupporting Westinghouse Affidavits should reference CAW-15-4212 and/or CAW-15-4198 and beaddressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company,1000 Westinghouse Drive, Building 3 Suite 310, Cranberry Township, Pennsylvania 16066.This letter contains no regulatory commitments.If you should have any questions regarding this submittal or require additional information, pleasecontact Mr. Bill R. Hansher, Principal Regulatory Engineer, at 402-533-6894.Respectfully,,-Louis P. CortopassiSite Vice President and CNOProprietary-WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390Enclosures 1, 2, and 4 contain Proprietary information.Upon removal of Enclosures 1, 2, and 4 this letter is Decontrolled.

Proprietary- WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390Enclosures 1, 2, and 4 contain Proprietary information.Upon removal of Enclosures 1, 2, and 4 this letter is Decontrolled.U. S. Nuclear Regulatory CommissionLIC-i5-01 17Page 3

Enclosures:

1. OPPD Response to Remaining Questions from NRC Request for AdditionalInformation Regarding Fort Calhoun Station, Reactor Vessel Internal ComponentAging Management Program (Proprietary)2. PWROG-15030-P, Rev. 0, "Evaluation of Fort Calhoun Fuel Alignment Plate Fluencefor MRP-227-A" (Proprietary)3. Westinghouse Application for Withholding Proprietary Information from PublicDisclosure CAW-15-4212, accompanying Affidavit, Proprietary Information Notice,and Copyright Notice dated June 17, 20154. PWROG-14082-P, Rev. 0, "Fort Calhoun Station Summary Report for the FuelDesign / Fuel Management Assessments to Demonstrate MRP-227-A Applicability"(Proprietary)5. Westinghouse Application for Withholding Proprietary Information from PublicDisclosure CAW-15-4198, accompanying Affidavit, Proprietary Information Notice,and Copyright Notice dated June 1, 20156. OPPD Response to Remaining Questions from NRC Request for AdditionalInformation Regarding Fort Calhoun Station, Reactor Vessel Internal ComponentAging Management Program (Non-Proprietary)7. PWROG-15030-NP, Rev. 0, "Evaluation of Fort Calhoun Fuel Alignment PlateFluence for MRP-227-A" (Non-Proprietary)8. PWROG-14082-NP, Rev. 0, "Fort Calhoun Station Summary Report for the FuelDesign / Fuel Management Assessments to Demonstrate MRP-227-A Applicability"(Non-Proprietary)Proprietary- WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390Enclosures 1, 2, and 4 contain Proprietary information.Upon removal of Enclosures 1, 2, and 4 this letter is Decontrolled.

LIC-1 5-0117Enclosure 3Page 1CAW-1 5-4212"Application for Withholding ProprietaryInformation from Public Disclosure"Proprietary- WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390Enclosures I, 2, and 4 contain Proprietary information.Upon removal of Enclosures 1, 2, and 4 this letter is Decontrolled.

Westin hngheo useo ElctioCmpnW estin houseEngineering, Equipment and Major Projects1000 Westinghouse Drive, Building SCranberry Township, Pennsylvania 16066USAU.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643Document Control Desk Direet fax: (724) 940-856011555 Rockville Pike e-mail: greshaja@westinghouse.comRockville, MD 20852CAW-15-421 2June 17, 2015APPLICATION FOR WITHHOLDING PROPRIETARYINFORMATION FROM PUBLIC DISCLOSURE

Subject:

PWROG-15030-P, Rev. 0, "Evaluation of Fort Calhoun Fuel Alignment Plate Fluence forMRP-227-A" (Proprietary)The proprietary information for which withholding is being requested in the above-referenced report isfurther identified in Affidavit CAW-15-4212 signed by the owner of the proprietary information,Westinghouse Electric Company LLC. The Affidavit, which accompanies this letter, sets forth the 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 Pressurized WaterReactor Owners Group (PWROG).Correspondence with respect to the proprietary aspects of the Application for Withholding or theWestinghouse Affidavit should reference CAW-15-4212 and should be addressed to James A. Greshanm,Manager; Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive,Building 3 Suite 310, Cranberry Township, Pennsylvania 16066.Very truly yours,GrshmMaagerRegulatory Compliance CAW- 15-4212June 17, 2015AFFIDAVITCOMMONWEALTH OF PENNSYLVANIA:SSCOUNTY OF BUTLER:I, James A. Gresham, am authorized to execute this Affidavit on behalf of Westinghouse ElectricCompany LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true andcorrect to the best of my knowledge, information, and belief.Jaes-A. Gresham, ManagerRegulatory Compliance 2 CAW-15-421 2(1) I am Manager, Regulatory Compliance, Westinghouse Electric Company LLC (Westinghouse),and as such, I have been specifically delegated the function of reviewing the proprietaryinformation sought to be withheld from public disclosure in connection with nuclear power plantlicensing and rule making proceedings, and am authorized to apply for its withholding on behalfof Westinghouse.(2) I 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) I 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,the following is furnished for consideration by the Commission in determining whether theinformation sought to be withheld from public disclosure should be withheld.(i) The information sought to be withheld from public disclosure is owned and has been heldin confidence 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 determiningthe types of information customarily held in confidence by it and, in that connection,utilizes a system to determine when and whether to hold certain types of information inconfidence. The application of that system and the substance of that system constituteWestinghouse policy 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 33 ~CAW-15-421 2Westinghouse's competitors without license from Westinghouse constitutes acompetitive economic advantage 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 improvedmarketability.(c) Its use by a competitor would reduce his expenditure of resources or improve hiscompetitive position in the design, manufacture, shipment, installation, assuranceof quality, 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 toprotect the 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 tosell products 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.

44 CAW-15-4212(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, th~ereby depriving Westinghouse of acompetitive advantage.Ce) 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 anddevelopment depends upon the success in obtaining and maintaining acompetitive 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 theCommission.(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 tothe best of our knowledge and belief.(vi) The proprietary information sought to be withheld in this submittal is that which isappropriately marked in PWROG-1 503 0-P, Rev. 0, "Evaluation of Fort Calhoun FuelAlignment Plate Fluence for MRP-227-A" (Proprietary), for submittal to the Commission,being transmitted by PWROG letter OG-15-212 and Application for WithholdingProprietary Information from Public Disclosure, to the Document Control Desk. Theproprietary information as submitted by Westinghouse is that associated with the NRCletter, "Request for Additional Information -Reactor Vessel Internal Component AgingManagement Program (MF3412)," ML14190A21 1, July 8, 2014 and may be used only forthat purpose.

55 CAW-15-4212(a) This information is part of that which will enable Westinghouse to:(i) Support reactor vessel internals aging management.(b) Further this information has substantial commercial value as follows:(i) Westinghouse plans to sell the use of similar information to its customersfor the purpose of supporting reactor internals aging management(ii) Westinghouse can sell support and defense of industry guidelines andacceptance criteria for plant-specific applications.(iii) The information requested to be withheld reveals the distinguishingaspects of 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 ofcompetitors to provide similar technical evaluation justifications and licensing defenseservices for commercial power reactors without commensurate expenses. Also, publicdisclosure of the information would enable others to use the information to meet NRCrequirements for licensing documentation without purchasing the right to use theinformation.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 andthe expenditure 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 is the proprietary and/or non-proprietary version of a document furnished to theNRC associated with the NRC Letter, "Request for Additional Information -Reactor Vessel InternalComponent Aging Management Program (MF3412)," ML14190A21 1 July 8, 2014 and may be used onlyfor that purpose.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.

Omaha Public Power DistrictLetter for Transmittal to the NRCThe following paragraphs should be included in your letter to the NRC Document Control Desk:Enclosed are:1. PWROG- 1 5030-P, Rev. 0, "Evaluation of Fort Calhoun Fuel Alignment Plate Fluence forMvIRP-227-A" (Proprietary)2. PWROG-1 5030-NP, Rev. 0, "Evaluation of Fort Calhoun Fuel Alignment Plate Fluence forMRP-227-A" (Non-Proprietary)Also enclosed is the Westinghouse Application for Withholding Proprietary Information from PublicDisclosure CAW.4..417, accompanying Affidavit, Proprietary Information Notice, and CopyrightNotice.As Item 1 contains information proprietary to Westinghouse Electric Company LLC, it is supported by anAffidavit signed by Westinghouse, the owner of the information. The Affidavit sets forth the basis onwhich the information may be withheld from public disclosure by Commission and addresses withspecificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations.Accordingly, it is respectfully requested that the information which is proprietary to Westinghouse bewithheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission'sregulations.Correspondence with respect to the copyright or proprietary aspects of the items listed above or thesupporting Westinghouse Affidavit should reference and should be addressed toJames A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000Westinghouse Drive, Building 3 Suite 310, Cranberry Township, Pennsylvania 16066.

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

~~~Westinghouse Electricu Co mpaoo onyEngineering, Equipment and Major ProjectsUSAU.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643Document Control Desk Direct fax: (724) 940-856011555 Rockville Pike e-mil: greshaja@westinghouse.comRockville, MD 20852CAW- 15-4198June 1, 2015APPLICATION FOR WITHHOLDING PROPRIETARYINFORMATION FROM PUBLIC DISCLOSURE

Subject:

PWROG-14082-P, Rev. 0, "Fort Calhoun Station Summary Report for the Fuel Design I FuelManagement Assessments to Demonstrate MRP-227-A Applicability" (Proprietary)The proprietary information for which withholding is being requested in the above-referenced report isfurther identified in Affidavit CAW- 15-4 198 signed by the owner of the proprietary information,Westinghouse Electric Company LLC. The Affidavit, which accompanies this letter, sets forth the 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 Pressurized WaterReactor Owners Group (PWROG).Correspondence with respect to the proprietary aspects of the Application for Withholding or theWestinghouse Affidavit should reference CAW- 15-4198 and should be addressed to James A. Gresham,Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive,Building 3 Suite 310, Cranberry Township, Pennsylvania 16066.Very truly yours,(/JmesA. resham, ManagerRegulatory Compliance CAW-l 5-4198June 1, 2015AFFIDAVITCOMMONWEALTH OF PENNSYLVANIA:5$COUNTY OF BUTLER:I, James A. Gresham, am authorized to execute this Affidavit on behalf of Westinghouse ElectricCompany LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true andcorrect to the best of my knowledge, information, and belief.41ames A. Gresham, ManagerRegulatory Compliance 22 CAW-I15-4198(1) 1 am Manager, Regulatory Compliance, Westinghouse Electric Company LLC (Westinghouse),and as such, I have been specifically delegated the function of reviewing the proprietaryinformation sought to be withheld from public disclosure in connection with nuclear power plantlicensing and rule making proceedings, and am authorized to apply for its withholding on behalfof Westinghouse.(2) 1 am making this Affidavit in conformance with the provisions of 10 CER Section 2.390 of theCommissions'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,the following is furnished for consideration by the Commission in determining whether theinformation sought to be withheld from public disclosure should be withheld.(i) The information sought to be withheld from public disclosure is owned and has been heldin confidence by Westinghouse.(ii) The information is ofra type customarily held in confidence by Westinghouse and notcustomarily disclosed to the public. Westinghouse has a rational basis for determiningthe types of information customarily held in confidence by it and, in that connection,utilizes a system to determine when and whether to hold certain types of information inconfidence. The application of that system and the substance of that system constituteWestinghouse policy 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 33 CAW-l 5-4198Westinghouse's competitors without license from Westinghouse constitu~tes acompetitive economic advantage 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 improvedmarketability.(c) Its use by a competitor would reduce his expenditure of resources or improve hiscompetitive position in the design, manufacture, shipment, installation, assuranceof quality, 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.(0) 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 toprotect the 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 tosell products 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.

44 CAW-15-4198(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 anddevelopment depends upon the success in obtaining and maintaining acompetitive 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 theCommission.(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 tothe best of our knowledge and belief.(vi) The proprietary information sought to be withheld in this submittal is that which isappropriately marked in PWROG-14082-P, Rev. 0, "Fort Calhoun Station Summary Reportfor the Fuel Design / Fuel Management Assessments to Demonstrate MRP-227-AApplicability" (Proprietary), for submittal to the Commission, being transmitted byPWROG letter OG- 15-212 and Application for Withholding Proprietary Information fromPublic Disclosure, to the Document Control Desk. The proprietary information assubmitted by Westinghouse is that associated with the NRC letter, "Request for AdditionalInformation -Reactor Vessel Internal Component Aging Management Program(MF3412)," ML14190A2 11 July 8, 2014 and may be used only for that purpose.

55 CAW- 15-4I198(a) This information is part of that which will enable Westinghouse to:(i) Support reactor vessel internals aging management.(b) Further this information has substantial commercial value as follows:(i) Westinghouse plans to sell the use of similar information to its customersfor the purpose of supporting reactor internals aging management(ii) Westinghouse can sell support and defense of industry guidelines andacceptance criteria for plant-specific applications.(iii) The information requested to be withheld reveals the distinguishingaspects ofra 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 ofcompetitors to provide similar technical evaluation justifications and licensing defenseservices for commercial power reactors without commensurate expenses. Also, publicdisclosure of the information would enable others to use the information to meet NRCrequirements for licensing documentation without purchasing the right to use theinformation.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 andthe expenditure 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 is the proprietary and non-proprietary versions of a document furnished to the NRCassociated with the NRC letter, "Request for Additional Information -Reactor Vessel InternalComponent Aging Management Program (MF34 12)," ML14190A21 1 July 8, 2014 and may be used onlyfor that purpose.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 vase letters refer to thetypes of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a)through (4Xii)(f) of the Affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).COPYRIGHT 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 ofra 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.

Omaha Public Power DistrictLeotter for Transmittal to the NRCThe following paragraphs should be included in your letter to the NRC Document Control Desk:Enclosed are:1. PWROG-14082-P, Rev. 0, "Fort Calhoun Station Summary Report for the Fuel Design /FuelManagement Assessments to Demonstrate MRP-227-A Applicability" (Proprietary)2. PWROG-14082-NP, Rev. 0, "Fort Calhoun Station Summary Report for the Fuel Design / FuelManagement Assessments to Demonstrate MRP-227-A Applicability" (Non-Proprietary)Also enclosed is the Westinghouse Application for Withholding Proprietary Information from PublicDisclosure CAW-l15-4198, accompanying Affidavit, Proprietary Information Notice, and CopyrightNotice.As Item 1 contains information proprietary to Westinghouse Electric Company LLC, it is supported by anAffidavit signed by Westinghouse, the owner of the information. The Affidavit sets forth the basis onwhich the information may be withheld from public disclosure by the Commission and addresses withspecificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations.Accordingly, it is respectfiully requested that the information which is proprietary to Westinghouse bewithheld from public disclosure in accordance with 1 0 CFR Section 2.390 of the Commission'ssregulations.Correspondence with respect to the copyright or proprietary aspects of the items listed above or thesupporting Westinghouse Affidavit should reference CAW-1 5-4198 and should be addressed toJames A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000Westinghouse Drive, Building 3 Suite 310, Cranberry Township, Pennsylvania 16066.