Revision as of 21:14, 7 February 2019

Text

Extended Power Uprate License Amendment Request - Supplement 22 Response to Request for Additional Information
	ML14072A022
Person / Time
Site:	Peach Bottom
Issue date:	03/10/2014
From:	Borton K F; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML14072A016	List: ML14072A022; ML14072A023; ML14072A024; ML14072A025; ML14072A026;
References
	Download: ML14072A022 (41)
	v • d • e

AwExelon Generation.

PROPRIETARY INFORMATION

-WITHHOLD UNDER 10 CFR 2.390 10 CFR 50.90 10 CFR 2.390 March 10, 2014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278

Subject:

Extended Power Uprate License Amendment Request -Supplement 22 Response to Request for Additional Information

1. Exelon letter to the NRC, "License Amendment Request -Extended Power Uprate," dated September 28, 2012 (ADAMS Accession No. ML1 22860201)

Reference:

2. NRC letter to Exelon, "Request for Additional Information Regarding License Amendment Request for Extended Power Uprate (TAC Nos. ME9631 and ME9632)," dated January 15, 2014 (ADAMS Accession No. ML14002A176)

3. Exelon Letter to NRC, "Extended Power Uprate License Amendment Request- Supplement 21, Response to Request for Additional Information," dated February 28, 2014 In accordance with 10 CFR 50.90, Exelon Generation Company, LLC (EGC) requested amendments to Facility Operating License Nos. DPR-44 and DPR-56 for Peach Bottom Atomic Power Station (PBAPS) Units 2 and 3, respectively (Reference 1). Specifically, the proposed changes would revise the Renewed Operating Licenses to implement an increase in rated thermal power from 3514 megawatts thermal (MWt) to 3951 MWt.During their technical review of the application, the NRC Staff identified the need for additional information.

Reference 2 provided the replacement steam dryer (RSD)Request for Additional Information (RAI). References 3 provided the EGC responses to those RAIs except EMCB-SD-RAIs-32 and 41. The Exelon response to EMCB-SD-RAI 32 is provided in Attachment 1 of this letter.In addition, revisions to the replacement steam dryer topical reports have been prepared to provide updated analysis results and to address topics discussed during the review of the replacement steam dryer. These revised reports supersede those that were originally provided in Reference 1 in Attachments 17 (proprietary) and 15 (non-proprietary);

the specific Reference 1 attachment numbers are identified below. Proprietary versions of Attachments 1 and 4 through 7 contain Proprietary Information.

When separated from these attachments, this document is decontrolled.

A4w\

U. S. Nuclear Regulatory Commission EPU LAR Supplement 22 Response to Requests for Additional Information March 10, 2014 Page 2 the WCAPs identified below are included in Attachments 4 through 7 and non-proprietary versions are provided in Attachments 8 through 11.The revised topical reports are: Att. 15 / 17.A WCAP-1 7635, Rev 2, Comprehensive Vibration Assessment Program Att. 15/ 17.B.2 WCAP-1 7609, Rev 2, Structural Evaluation for High-Cycle Acoustic Loads Att. 15 / 17.B.4U2 WCAP-17654, Rev 3, Peach Bottom Unit 2 Power Ascension Program Description for Extended Power Uprate Att. 15/ 17.B.4U3 WCAP-1 7655, Rev 3, Peach Bottom Unit 3 Power Ascension Program Description for Extended Power Uprate Westinghouse Electric Company (WEC) considers portions of the information provided in the Attachment 1 response 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 2.390 and in support of this request for withholding, affidavits executed by WEC are provided in Attachment 3.EGC has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration provided to the U. S. Nuclear Regulatory Commission in Reference

1. The supplemental information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration.

Further, the additional information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed 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 of Maryland 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.

U. S. Nuclear Regulatory Commission EPU LAR Supplement 22 Response to Requests for Additional Information March 10, 2014 Page 3 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 the 10"' day of March 2014.Respectfully, Kevin F Borton Manager, Licensing

-Power Uprate Exelon Generation Company, LLC Attachments:

1. Response to Request for Additional Information

-EMCB-SD -Proprietary

2. Response to Request for Additional Information

-EMCB-SD 3. Affidavits in Support of Request to Withhold Information

4. WCAP-17635, Rev 2, Comprehensive Vibration Assessment Program -Proprietary

5. WCAP-17609, Rev 2, Structural Evaluation for High-Cycle Acoustic Loads -Proprietary

6. WCAP-17654, Rev 3, Peach Bottom Unit 2 Power Ascension Program Description for Extended Power Uprate -Proprietary

7. WCAP-17655, Rev 3, Peach Bottom Unit 3 Power Ascension Program Description for Extended Power Uprate -Proprietary

8. WCAP-17635, Rev 2, Comprehensive Vibration Assessment Program 9. WCAP-1 7609, Rev 2, Structural Evaluation for High-Cycle Acoustic Loads 10. WCAP-1 7654, Rev 3, Peach Bottom Unit 2 Power Ascension Program Description for Extended Power Uprate 11. WCAP-1 7655, Rev 3, Peach Bottom Unit 3 Power Ascension Program Description for Extended Power Uprate cc: USNRC Region I, Regional Administrator w/attachments USNRC Senior Resident Inspector, PBAPS w/attachments USNRC Project Manager, PBAPS w/attachments R. R. Janati, Commonwealth of Pennsylvania w/o proprietary attachment S. T. Gray, State of Maryland w/o proprietary attachment Attachment 2 Peach Bottom Atomic Power Station Units 2 and 3 NRC Docket Nos. 50-277 and 50-278 Response to Request for Additional Information

-EMCB-SD Note This attachment includes the non-proprietary version of the response;brackets identify where proprietary information has been redacted.

EPU LAR Supplement 22 Attachment 2 Response to RAI -EMCB-SD Page 1 of 1 Response to Request for Additional Information Mechanical 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 the maximum power level from 3514 megawatts thermal (MWt) to 3951 MWt. The requested change, referred to as an extended power uprate (EPU), represents an increase 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 January 15, 2014 (NRC Accession No. ML14002A176), requested additional information.

The Exelon response to EMCB-SD-RAI 32 is provided below.EMCB-SD-RAI-32 Please provide the limit curves for the on-dryer strain gages for PBAPS Unit 2. Base the curves on the CLTP (not the projected EPU calculations).

RESPONSE During the PBAPS Unit 2 power ascension, [Ia,c Attachment 3 Peach Bottom Atomic Power Station Units 2 and 3 NRC Docket Nos. 50-277 and 50-278 AFFIDAVITS Note Attachment 1 and Attachment 4 through 7 contain proprietary information as defined by 10 CFR 2.390. WEC, as the owner of the proprietary information, has executed the enclosed affidavits, which identify that the proprietary information has been handled and classified as proprietary, is customarily held in confidence, and has been withheld from public disclosure.

The proprietary information has been faithfully reproduced in the attachment such that the affidavit remains applicable.

S Westinghouse Westinghouse Electric Company Engineering, Equipment and Major Projects 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4419 Document Control Desk Direct fax: (724) 720-0754 11555 Rockville Pike e-mail: maurerbf@westinghouse.com Rockville, MD 20852 CAW-14-3921 March 7, 2014 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

Attachment 1 "Response to Request for Additional Information

-EMCB-SD -Proprietary," attached to Exelon Generation submittal to the NRC "Extended Power Uprate License Amendment Request -Supplement 22, Response to Request for Additional Information" The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-14-3921 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The Affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Exelon Generation.

Correspondence with respect to the proprietary aspects of the application for withholding or the accompanying Affidavit should reference CAW- 14-3921 and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 310, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.Very truly yours, Bradley F. Maurer, Principal Engineer Plant Licensing Enclosures CAW-14-3921 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF BUTLER: Before me, the undersigned authority, personally appeared Bradley F. Maurer, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief: Bradley F. Maurer, Principal Engineer Plant Licensing Sworn to and subscribed before me this 7h day of March 2014 Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Renee Glampole, Notaary Public [Penn Twp., Westmoreland County I My Commission Expires Sept, 25, 2017 EMBER, PENNSYLVANLA/

M0ATION OF N TAPJE.S 2 CAW-14-3921 (1) 1 am Principal Engineer, Plant Licensing, in Engineering, Equipment and Major Projects, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence.

The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows: (a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's 3 CAW-14-3921 competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(0 It contains patentable ideas, for which patent protection may be desirable.(iii) There are sound policy reasons behind the Westinghouse system which include the following: (a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors.

It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

4 CAW-14-3921 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage.

If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.(iv) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.(v) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.(vi) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in Attachment 1 "Response to Request for Additional Information

-EMCB-SD -Proprietary," attached to Exelon Generation submittal to the NRC "Extended Power Uprate License Amendment Request -Supplement 22, Response to Request for Additional Information" for submittal to the Commission, being transmitted by Exelon Generation letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse 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 only for that purpose.

5 CAW-14-3921 (a) This information is part of that which will enable Westinghouse to: (i) Assist Exelon Generation in obtaining NRC review of the Peach Bottom Atomic 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 for purposes of plant specific replacement steam dryer analysis for licensing basis applications.(ii) Its use by a competitor would improve their competitive position in the design and licensing of a similar product for BWR steam dryer analysis methodology.(iii) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical justifications and licensing defense services for commercial power reactors without commensurate expenses.

Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.Further the deponent sayeth not.

Proprietary Information Notice Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted).

The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f)located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information.

These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the Affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).

Copyright Notice The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary forits internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding.

With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

Westinghouse U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Westinghouse Electric Company Engineering, Equipment and Major Projects 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA Direct tel: (412) 374-4419 Direct fax: (724) 720-0754 e-mail: maurerbf@westinghouse.com WEC-PCH-RSD-14-035 CAW-14-3908 March 6, 2014 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

WCAP-! 7635-P -Enclosure 17A, Revision 2, "Peach Bottom Atomic Generating Station Unit 2 and Unit 3 Comprehensive Vibration Assessment Program (CVAP)" (Proprietary)

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-14-3908 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The Affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Exelon Generation.

Correspondence with respect to the proprietary aspects of the application for withholding or the accompanying Affidavit should reference CAW-14-3908 and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 310, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.Very truly yours, Bradley F. Maurer, Principal Engineer Plant Licensing Enclosures CAW-14-3908 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF BUTLER: Before me, the undersigned authority, personally appeared Bradley F. Maurer, who, being by me duly sworn according to law, deposes and says that lie is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief: Bradley F. Maurer, Principal Engineer Plant Licensing Sworn to and subscribed before me this 6th day of March 2014 Notary PublicV COMMONWEALTH OF PENNSYLVANJA Notarial Seal Anne M. Stegman, Notary Public Unity Twp., Westmoreland County My Commission Expires Aug. 7, 2016 MEIn"SYLtvAvNS ASSMATION OF NOTAPJES 2 CAW-14-3908 (1) 1 am Principal Engineer, Plant Licensing, in Engineering, Equipment and Major Projects, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

(2) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

(3) 1 have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence.

The application of that system and the substance of that system constitute Westinghouse policy and provide the rational basis required.Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows: (a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's 3 CAW-14-3908 competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.(f) It contains patentable ideas, for which patent protection may be desirable.(iii) There are sound policy reasons behind the Westinghouse system which include the following: (a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors.

It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

4 CAW-1 4-3908 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage.

If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.(iv) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.(v) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.(vi) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP- 17635-P -Enclosure 17A, Revision 2, "Peach Bottom Atomic Generating Station Unit 2 and Unit 3 Comprehensive Vibration Assessment Program (CVA.P)" (Proprietary) for submittal to the Commission, being transmitted by Exelon Generation letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with the review of the Replacement Steam Dryer design and analysis which is a part of the Extended Power Uprate License Amendment Request for Peach Bottom Units 2 and 3, and may be used only for that purpose.

5 CAW- 14-3908 (a) This information is part of that which will enable Westinghouse to: (i) Assist Exelon Generation in obtaining NRC review of the Peach Bottom Atomic 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 for'purposes of plant specific replacement steam dryer analysis for licensing basis applications.(ii) Its use by a competitor would improve their competitive position in the design and licensing of a similar product for BWR steam dryer analysis methodology.(iii) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical justifications and licensing defense services for commercial power reactors without commensurate expenses.

Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.Further the deponent sayeth not.

Proprietary Information Notice Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where tie proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted).

The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f)located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information.

These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the Affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).

Copyright Notice The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding.

With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

Westinghouse U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Westinghouse Electric Company Engineering, Equipment and Major Projects 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA Direct tel: (412) 374-4419 Direct fax: (724) 720-0754 e-mail: maurerbf@westinghouse.com WEC-PCH-RSD-14-038 CAW- 14-3913 March 6, 2014 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

WCAP-17609-P, Revision 2, "Peach Bottom Units 2 and 3 Replacement Steam Dryer Structural Evaluation for High-Cycle Acoustic Loads" (Proprietary)

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-14-3913 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The Affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CFR Section 2.390 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Exelon Generation.

Correspondence with respect to the proprietary aspects of the application for withholding or the accompanying Affidavit should reference CAW- 14-3913 and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, Suite 310, 1000 Westinghouse Drive, Cranberry Township, Pennsylvania 16066.Very truly yours, Bradley F. Maurer, Principal Engineer Plant Licensing Enclosures CAW-14-3913 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF BUTLER: Before me, the undersigned authority, personally appeared Bradley F. Maurer, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC (Westinghouse), and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief: Bradley F. Maurer, Principal Engineer Plant Licensing Sworn to and subscribed before me this 6h day of March 2014 Notary Public COMMON WE-ALT Hl OFF PENNSYLVANIA Notarial seal Anne M. Stegman, Notary public unity Twp., Westm~oreland county My commission ExpIres Aug. 7, 2016 MEMBER. PENNSYLVAN~IA ASSOCIATION OF: 14CTARIES 2 CAW-14-3913 (1) 1 am Principal Engineer, Plant Licensing, in Engineering, Equipment and Major Projects, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

(2) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

(3) 1 have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence.

The application of that system and the substance of that system constitute Westinghouse policy and provide the rational basis required.Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows: (a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's 3 CAW-14-3913 competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.(f) It contains patentable ideas, for which patent protection may be desirable.(iii) There are sound policy reasons behind the Westinghouse system which include the following: (a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors.

It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

4 CAW-14-3913 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage.

If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.(iv) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.(v) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.(vi) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP-17609-P, Revision 2, "Peach Bottom Units 2 and 3 Replacement Steam Dryer Structural Evaluation for High-Cycle Acoustic Loads" (Proprietary) for submittal to the Commission, being transmitted by Exelon Generation letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by Westinghouse is that associated with the review of the Replacement Steam Dryer design and analysis which is a part of the Extended Power Uprate License Amendment Request for Peach Bottom Units 2 and 3, and may be used only for that purpose.

5 CAW-14-3913 (a) This information is part of that which will enable Westinghouse to: (i) Assist Exelon Generation in obtaining NRC review of the Peach Bottom Atomic 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 for purposes of plant specific replacement steam dryer analysis for licensing basis applications.(ii) Its use by a competitor would improve their competitive position in the design and licensing of a similar product for BWR steam dryer analysis methodology.(iii) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.