ML14072A022

Peach Bottom Atomic Power Station, Units 2 and 3 - 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)

Text

AwExelon Generation.

PROPRIETARY INFORMATION

-WITHHOLD UNDER 10 CFR 2.39010 CFR 50.9010 CFR 2.390March 10, 2014U. S. Nuclear Regulatory Commission ATTN: Document Control DeskWashington, DC 20555-0001 Peach Bottom Atomic Power Station, Units 2 and 3Renewed Facility Operating License Nos. DPR-44 and DPR-56NRC Docket Nos. 50-277 and 50-278

Subject:

Extended Power Uprate License Amendment Request -Supplement 22Response 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 PowerUprate (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, 2014In 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 BottomAtomic Power Station (PBAPS) Units 2 and 3, respectively (Reference 1). Specifically, the proposed changes would revise the Renewed Operating Licenses to implement anincrease 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 foradditional information.

Reference 2 provided the replacement steam dryer (RSD)Request for Additional Information (RAI). References 3 provided the EGC responses tothose 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 preparedto provide updated analysis results and to address topics discussed during the review ofthe replacement steam dryer. These revised reports supersede those that were originally provided in Reference 1 in Attachments 17 (proprietary) and 15 (non-proprietary);

thespecific Reference 1 attachment numbers are identified below. Proprietary versions ofAttachments 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 22Response to Requests for Additional Information March 10, 2014Page 2the 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 ProgramAtt. 15/ 17.B.2 WCAP-1 7609, Rev 2, Structural Evaluation for High-Cycle Acoustic LoadsAtt. 15 / 17.B.4U2 WCAP-17654, Rev 3, Peach Bottom Unit 2 Power Ascension Program Description for Extended PowerUprateAtt. 15/ 17.B.4U3 WCAP-1 7655, Rev 3, Peach Bottom Unit 3 Power Ascension Program Description for Extended PowerUprateWestinghouse Electric Company (WEC) considers portions of the information providedin 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 with10 CFR 2.390 and in support of this request for withholding, affidavits executed by WECare provided in Attachment 3.EGC has reviewed the information supporting a finding of no significant hazardsconsideration and the environmental consideration provided to the U. S. NuclearRegulatory Commission in Reference

1. The supplemental information provided in thissubmittal 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 anenvironmental impact statement nor an environmental assessment needs to be preparedin 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 ofMaryland of this application by transmitting a copy of this letter along with the non-proprietary attachments to the designated State Officials.

There are no regulatory commitments contained in this letter.

U. S. Nuclear Regulatory Commission EPU LAR Supplement 22Response to Requests for Additional Information March 10, 2014Page 3Should 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 the10"' day of March 2014.Respectfully, Kevin F BortonManager, Licensing

-Power UprateExelon Generation

Company, LLCAttachments:

1. Response to Request for Additional Information

-EMCB-SD -Proprietary

2. Response to Request for Additional Information

-EMCB-SD3. 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 Program9. WCAP-1 7609, Rev 2, Structural Evaluation for High-Cycle Acoustic Loads10. WCAP-1 7654, Rev 3, Peach Bottom Unit 2 Power Ascension Program Description for Extended Power Uprate11. WCAP-1 7655, Rev 3, Peach Bottom Unit 3 Power Ascension Program Description for Extended Power Upratecc: 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 2Peach Bottom Atomic Power Station Units 2 and 3NRC Docket Nos. 50-277 and 50-278Response to Request for Additional Information

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

EPU LAR Supplement 22 Attachment 2Response to RAI -EMCB-SD Page 1 of 1Response 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 themaximum power level from 3514 megawatts thermal (MWt) to 3951 MWt. Therequested change, referred to as an extended power uprate (EPU), represents anincrease of approximately 12.4 percent above the current licensed thermal power level.The NRC staff has reviewed the information supporting the proposed amendment and,by letter dated 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 thecurves on the CLTP (not the projected EPU calculations).

RESPONSEDuring the PBAPS Unit 2 power ascension,

[Ia,c Attachment 3Peach Bottom Atomic Power Station Units 2 and 3NRC Docket Nos. 50-277 and 50-278AFFIDAVITS NoteAttachment 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 theproprietary information has been handled and classified as proprietary, iscustomarily held in confidence, and has been withheld from publicdisclosure.

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

S Westinghouse Westinghouse Electric CompanyEngineering, Equipment and Major Projects1000 Westinghouse DriveCranberry

Township, Pennsylvania 16066USAU.S. Nuclear Regulatory Commission Direct tel: (412) 374-4419Document Control Desk Direct fax: (724) 720-075411555 Rockville Pike e-mail: maurerbf@westinghouse.com Rockville, MD 20852CAW-14-3921 March 7, 2014APPLICATION 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 LicenseAmendment Request -Supplement 22, Response to Request for Additional Information" The proprietary information for which withholding is being requested in the above-referenced report isfurther identified in Affidavit CAW-14-3921 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'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 theaccompanying 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 EngineerPlant Licensing Enclosures CAW-14-3921 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ssCOUNTY OF BUTLER:Before me, the undersigned authority, personally appeared Bradley F. Maurer, who, being by meduly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf ofWestinghouse Electric Company LLC (Westinghouse),

and that the averments of fact set forth in thisAffidavit are true and correct to the best of his knowledge, information, and belief:Bradley F. Maurer, Principal EngineerPlant Licensing Sworn to and subscribed before methis 7h day of March 2014Notary PublicCOMMONWEALTH OF PENNSYLVANIA Notarial SealRenee Glampole, Notaary Public [Penn Twp., Westmoreland County IMy Commission Expires Sept, 25, 2017EMBER, PENNSYLVANLA/

M0ATION OF N TAPJE.S 2CAW-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 publicdisclosure in connection with nuclear power plant licensing and rule making proceedings, and amauthorized 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 theCommission'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, thefollowing 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 inconfidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and notcustomarily disclosed to the public. Westinghouse has a rational basis for determining thetypes of information customarily held in confidence by it and, in that connection, utilizes asystem to determine when and whether to hold certain types of information in confidence.

The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.

Under that system, information is held in confidence if it falls in one or more of severaltypes, the release of which might result in the loss of an existing or potential 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 3CAW-14-3921 competitors without license from Westinghouse constitutes a competitive economicadvantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (orcomponent, structure, tool, method, etc.), the application of which data secures acompetitive economic advantage, e.g., by optimization or improved marketability.

(c) Its use by a competitor would reduce his expenditure of resources or improve hiscompetitive position in the design, manufacture,

shipment, installation, assurance ofquality, or licensing a similar product.(d) It reveals cost or price information, production capacities, budget levels, orcommercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer fundeddevelopment plans and programs of potential commercial value to Westinghouse.

(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 competitive advantage over its competitors.

It is, therefore, withheld from disclosure to protectthe Westinghouse competitive position.

(b) It is information that is marketable in many ways. The extent to which suchinformation is available to competitors diminishes the Westinghouse ability to sellproducts and services involving the use of the information.

(c) Use by our competitor would put Westinghouse at a competitive disadvantage byreducing his expenditure of resources at our expense.

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

Ifcompetitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of acompetitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence ofWestinghouse in the world market, and thereby give a market advantage to thecompetition of those countries.

(f) The Westinghouse capacity to invest corporate assets in research and 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 theprovisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.

(v) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to thebest of our knowledge and belief.(vi) The proprietary information sought to be withheld in this submittal is that which isappropriately marked in Attachment 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 forAdditional Information" for submittal to the Commission, being transmitted by ExelonGeneration letter and Application for Withholding Proprietary Information from PublicDisclosure, to the Document Control Desk. The proprietary information as submitted byWestinghouse is to assist the NRC in their review of the Peach Bottom Atomic Power Station,Units 2 and 3, License Amendment Request for Extended Power Uprate and may be used onlyfor that purpose.

5CAW-14-3921 (a) This information is part of that which will enable Westinghouse to:(i) Assist Exelon Generation in obtaining NRC review of the Peach BottomAtomic Power Station Units 2 and 3 License Amendment Request.(b) Further this information has substantial commercial value as follows:(i) Westinghouse plans to sell the use of this information to its customers forpurposes of plant specific replacement steam dryer analysis for licensing basis applications.

(ii) Its use by a competitor would improve their competitive position in thedesign and licensing of a similar product for BWR steam dryer analysismethodology.

(iii) The information requested to be withheld reveals the distinguishing aspectsof a methodology which was developed by Westinghouse.

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

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

The development of the technology described in part by the information is the result ofapplying the results of many years of experience in an intensive Westinghouse effort and theexpenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having therequisite talent and experience, would have to be expended.

Further the deponent sayeth not.

Proprietary Information NoticeTransmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRCin connection with requests for generic and/or plant-specific review and approval.

In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning theprotection of proprietary information so submitted to the NRC, the information which is proprietary in theproprietary versions is contained within brackets, and where the proprietary information has been deletedin the non-proprietary

versions, only the brackets remain (the information that was contained within thebrackets in the proprietary versions having been deleted).

The justification for claiming the 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 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 foritsinternal 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, copyright protection 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.

• Westinghouse U.S. Nuclear Regulatory Commission Document Control Desk11555 Rockville PikeRockville, MD 20852Westinghouse Electric CompanyEngineering, Equipment and Major Projects1000 Westinghouse DriveCranberry

Township, Pennsylvania 16066USADirect tel: (412) 374-4419Direct fax: (724) 720-0754e-mail: maurerbf@westinghouse.com WEC-PCH-RSD-14-035 CAW-14-3908 March 6, 2014APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

WCAP-! 7635-P -Enclosure 17A, Revision 2, "Peach Bottom Atomic Generating Station Unit2 and Unit 3 Comprehensive Vibration Assessment Program (CVAP)" (Proprietary)

The proprietary information for which withholding is being requested in the above-referenced report isfurther 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 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'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 theaccompanying 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 EngineerPlant Licensing Enclosures CAW-14-3908 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ssCOUNTY OF BUTLER:Before me, the undersigned authority, personally appeared Bradley F. Maurer, who, being by meduly sworn according to law, deposes and says that lie is authorized to execute this Affidavit on behalf ofWestinghouse Electric Company LLC (Westinghouse),

and that the averments of fact set forth in thisAffidavit are true and correct to the best of his knowledge, information, and belief:Bradley F. Maurer, Principal EngineerPlant Licensing Sworn to and subscribed before methis 6th day of March 2014Notary PublicVCOMMONWEALTH OF PENNSYLVANJA Notarial SealAnne M. Stegman, Notary PublicUnity Twp., Westmoreland CountyMy Commission Expires Aug. 7, 2016MEIn"SYLtvAvNS ASSMATION OF NOTAPJES 2CAW-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 publicdisclosure in connection with nuclear power plant licensing and rule making proceedings, and amauthorized to apply for its withholding on behalf of Westinghouse.

(2) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of theCommission's regulations and in conjunction with the Westinghouse Application for 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, thefollowing 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 inconfidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and notcustomarily disclosed to the public. Westinghouse has a rational basis for determining thetypes of information customarily held in confidence by it and, in that connection, utilizes asystem to determine when and whether to hold certain types of information in confidence.

The application of that system and the substance of that system constitute Westinghouse 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 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 3CAW-14-3908 competitors without license from Westinghouse constitutes a competitive economicadvantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (orcomponent, structure, tool, method, etc.), the application of which data secures acompetitive economic advantage, e.g., by optimization or improved marketability.

(c) Its use by a competitor would reduce his expenditure of resources or improve hiscompetitive position in the design, manufacture,

shipment, installation, assurance ofquality, or licensing a similar product.(d) It reveals cost or price information, production capacities, budget levels, orcommercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer fundeddevelopment plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

(iii) There are sound policy reasons behind the Westinghouse system which include thefollowing:

(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors.

It is, therefore, withheld from disclosure to protectthe Westinghouse competitive position.

(b) It is information that is marketable in many ways. The extent to which suchinformation is available to competitors diminishes the Westinghouse ability to sellproducts and services involving the use of the information.

(c) Use by our competitor would put Westinghouse at a competitive disadvantage byreducing his expenditure of resources at our expense.

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

Ifcompetitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of acompetitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence ofWestinghouse in the world market, and thereby give a market advantage to thecompetition of those countries.

(f) The Westinghouse capacity to invest corporate assets in research and 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 theprovisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.

(v) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to thebest of our knowledge and belief.(vi) The proprietary information sought to be withheld in this submittal is that which isappropriately marked in WCAP- 17635-P -Enclosure 17A, Revision 2, "Peach Bottom AtomicGenerating Station Unit 2 and Unit 3 Comprehensive Vibration Assessment Program (CVA.P)"(Proprietary) for submittal to the Commission, being transmitted by Exelon Generation letterand Application for Withholding Proprietary Information from Public Disclosure, to theDocument Control Desk. The proprietary information as submitted by Westinghouse is thatassociated with the review of the Replacement Steam Dryer design and analysis which is a partof the Extended Power Uprate License Amendment Request for Peach Bottom Units 2 and 3,and may be used only for that purpose.

5CAW- 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 BottomAtomic Power Station Units 2 and 3 License Amendment Request.(b) Further this information has substantial commercial value as follows:(i) Westinghouse plans to sell the use of this information to its customers 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 thedesign and licensing of a similar product for BWR steam dryer analysismethodology.

(iii) The information requested to be withheld reveals the distinguishing aspectsof a methodology which was developed by Westinghouse.

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

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

The development of the technology described in part by the information is the result ofapplying the results of many years of experience in an intensive Westinghouse effort and theexpenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having therequisite talent and experience, would have to be expended.

Further the deponent sayeth not.

Proprietary Information NoticeTransmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRCin connection with requests for generic and/or plant-specific review and approval.

In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning theprotection of proprietary information so submitted to the NRC, the information which is proprietary in theproprietary versions is contained within brackets, and where tie 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 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 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, copyright protection 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.

• Westinghouse U.S. Nuclear Regulatory Commission Document Control Desk11555 Rockville PikeRockville, MD 20852Westinghouse Electric CompanyEngineering, Equipment and Major Projects1000 Westinghouse DriveCranberry

Township, Pennsylvania 16066USADirect tel: (412) 374-4419Direct fax: (724) 720-0754e-mail: maurerbf@westinghouse.com WEC-PCH-RSD-14-038CAW- 14-3913March 6, 2014APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

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

The proprietary information for which withholding is being requested in the above-referenced report isfurther 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 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'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 theaccompanying 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 EngineerPlant Licensing Enclosures CAW-14-3913 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ssCOUNTY OF BUTLER:Before me, the undersigned authority, personally appeared Bradley F. Maurer, who, being by meduly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf ofWestinghouse Electric Company LLC (Westinghouse),

and that the averments of fact set forth in thisAffidavit are true and correct to the best of his knowledge, information, and belief:Bradley F. Maurer, Principal EngineerPlant Licensing Sworn to and subscribed before methis 6h day of March 2014Notary PublicCOMMON WE-ALT Hl OFF PENNSYLVANIA Notarial sealAnne M. Stegman, Notary publicunity Twp., Westm~oreland countyMy commission ExpIres Aug. 7, 2016MEMBER. PENNSYLVAN~IA ASSOCIATION OF: 14CTARIES 2CAW-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 publicdisclosure in connection with nuclear power plant licensing and rule making proceedings, and amauthorized to apply for its withholding on behalf of Westinghouse.

(2) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of theCommission's regulations and in conjunction with the Westinghouse Application for 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, thefollowing 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 inconfidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and notcustomarily disclosed to the public. Westinghouse has a rational basis for determining thetypes of information customarily held in confidence by it and, in that connection, utilizes asystem to determine when and whether to hold certain types of information in confidence.

The application of that system and the substance of that system constitute Westinghouse 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 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 3CAW-14-3913 competitors without license from Westinghouse constitutes a competitive economicadvantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (orcomponent, structure, tool, method, etc.), the application of which data secures acompetitive economic advantage, e.g., by optimization or improved marketability.

(c) Its use by a competitor would reduce his expenditure of resources or improve hiscompetitive position in the design, manufacture,

shipment, installation, assurance ofquality, or licensing a similar product.(d) It reveals cost or price information, production capacities, budget levels, orcommercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer fundeddevelopment plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

(iii) There are sound policy reasons behind the Westinghouse system which include thefollowing:

(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors.

It is, therefore, withheld from disclosure to protectthe Westinghouse competitive position.

(b) It is information that is marketable in many ways. The extent to which suchinformation is available to competitors diminishes the Westinghouse ability to sellproducts and services involving the use of the information.

(c) Use by our competitor would put Westinghouse at a competitive disadvantage byreducing his expenditure of resources at our expense.

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

Ifcompetitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of acompetitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence ofWestinghouse in the world market, and thereby give a market advantage to thecompetition of those countries.

(f) The Westinghouse capacity to invest corporate assets in research and 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 theprovisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.

(v) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to thebest of our knowledge and belief.(vi) The proprietary information sought to be withheld in this submittal is that which isappropriately marked in WCAP-17609-P, Revision 2, "Peach Bottom Units 2 and 3Replacement Steam Dryer Structural Evaluation for High-Cycle Acoustic Loads" (Proprietary) for submittal to the Commission, being transmitted by Exelon Generation letter andApplication for Withholding Proprietary Information from Public Disclosure, to the DocumentControl Desk. The proprietary information as submitted by Westinghouse is that associated with the review of the Replacement Steam Dryer design and analysis which is a part of theExtended Power Uprate License Amendment Request for Peach Bottom Units 2 and 3, andmay be used only for that purpose.

5CAW-14-3913 (a) This information is part of that which will enable Westinghouse to:(i) Assist Exelon Generation in obtaining NRC review of the Peach BottomAtomic Power Station Units 2 and 3 License Amendment Request.(b) Further this information has substantial commercial value as follows:(i) Westinghouse plans to sell the use of this information to its customers forpurposes of plant specific replacement steam dryer analysis for licensing basis applications.

(ii) Its use by a competitor would improve their competitive position in thedesign and licensing of a similar product for BWR steam dryer analysismethodology.

(iii) The information requested to be withheld reveals the distinguishing aspectsof a methodology which was developed by Westinghouse.

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

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

The development of the technology described in part by the information is the result ofapplying the results of many years of experience in an intensive Westinghouse effort and theexpenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having therequisite talent and experience, would have to be expended.

Further the deponent sayeth not.

Proprietary Information NoticeTransmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRCin connection with requests for generic and/or plant-specific review and approval.

In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning theprotection of proprietary information so submitted to the NRC, the information which is proprietary in theproprietary versions is contained within brackets, and where the proprietary information has been deletedin the non-proprietary

versions, only the brackets remain (the information that was contained within thebrackets in the proprietary versions having been deleted).

The justification for claiming the 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 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, copyright protection 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.

• Westinghouse U.S. Nuclear Regulatory Commission Document Control Desk11555 Rockville PikeRockville, MD 20852Westinghouse Electric CompanyEngineering, Equipment and Major Projects1000 Westinghouse DriveCranberry

Township, Pennsylvania 16066USADirect tel: (412) 374-4419Direct fax: (724) 720-0754c-mail: maurerbf@westinghouse.com WEC-PCH-RSD-14-036CAW-14-3911 March 6, 2014APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

WCAP-17654-P, Revision 3, "Peach Bottom Unit 2 Replacement Steam Dryer PowerAscension Program for Extended Power Uprate Description" (Proprietary)

The proprietary information for which withholding is being requested in the above-referenced report isfurther identified in Affidavit CAW-14-3911 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'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 theaccompanying Affidavit should reference CAW-14-391 I 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 EngineerPlant Licensing Enclosures CAW-14-3911 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ssCOUNTY OF BUTLER:Before me, the undersigned authority, personally appeared Bradley F. Maurer, who, being by meduly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf ofWestinghouse Electric Company LLC (Westinghouse),

and that the averments of fact set forth in thisAffidavit are true and correct to the best of his knowledge, information, and belief:Bradley F. Maurer, Principal EngineerPlant Licensing Sworn to and subscribed before methis 61h day of March 2014Notary PublicCOMMONWEALTH OF PENNSYLVANIA Notarial SealAnne M. Stegman, Notary PublicUnity Twp., Westmoreland CountyMy Commission Expires Aug. 7, 2016MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES 2CAW-14-3911 (1) 1 am Principal

Engineer, Plant Licensing, in Engineering, Equipment mid 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 publicdisclosure in connection with nuclear power plant licensing and rule making proceedings, and amauthorized to apply for its withholding on behalf of Westinghouse.

(2) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of theCommission's regulations and in conjunction with the Westinghouse Application for 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, thefollowing 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 inconfidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and notcustomarily disclosed to the public. Westinghouse has a rational basis for determining thetypes of information customarily held in confidence by it and, in that connection, utilizes asystem to determine when and whether to hold certain types of information in confidence.

The application of that system and the substance of that system constitute Westinghouse 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 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 3CAW-14-3911 competitors without license from Westinghouse constitutes a competitive economicadvantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (orcomponent, structure, tool, method, etc.), the application of which data secures acompetitive economic advantage, e.g., by optimization or improved marketability.

(c) Its use by a competitor would reduce his expenditure of resources or improve hiscompetitive position in the design, manufacture,

shipment, installation, assurance ofquality, or licensing a similar product.(d) It reveals cost or price information, production capacities, budget levels, orcommercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer fundeddevelopment plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

(iii) There are sound policy reasons behind the Westinghouse system which include thefollowing:

(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors.

It is, therefore, withheld from disclosure to protectthe Westinghouse competitive position.

(b) It is information that is marketable in many ways. The extent to which suchinformation is available to competitors diminishes the Westinghouse ability to sellproducts and services involving the use of the information.

(c) Use by our competitor would put Westinghouse at a competitive disadvantage byreducing his expenditure of resources at our expense.

4CAW-14-3911 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage.

Ifcompetitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of acompetitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence ofWestinghouse in the world market, and thereby give a market advantage to thecompetition of those countries.

(f) The Westinghouse capacity to invest corporate assets in research and 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 theprovisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.

(v) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to thebest of our knowledge and belief.(vi) The proprietary information sought to be withheld in this submittal is that which isappropriately marked in WCAP- I 7654-P, Revision 3, "Peach Bottom Unit 2 Replacement Steam Dryer Power Ascension Program for Extended Power Uprate Description" (Proprietary) for submittal to the Commission, being transmitted by Exelon Generation letter andApplication for Withholding Proprietary Information from Public Disclosure, to the DocumentControl Desk. The proprietary information as submitted by Westinghouse is that associated with the review of the Replacement Steam Dryer design and analysis which is a part of theExtended Power Uprate License Amendment Request for Peach Bottom Units 2 and 3, andmay be used only for that purpose.

5CAW-14-3911 (a) This information is part of that which will enable Westinghouse to:(i) Assist Exelon Generation in obtaining NRC review of the Peach BottomAtomic Power Station Units 2 and 3 License Amendment Request.(b) Further this information has substantial commercial value as follows:(i) Westinghouse plans to sell the use of this information to its customers forpurposes of plant specific replacement steam dryer analysis for licensing basis applications.

(ii) Its use by a competitor would improve their competitive position in thedesign and licensing of a similar product for BWR steam dryer analysismethodology.

(iii) The information requested to be withheld reveals the distinguishing aspectsof a methodology which was developed by Westinghouse.

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

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

The development of the technology described in part by the information is the result ofapplying the results of many years of experience in an intensive Westinghouse effort and theexpenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having therequisite talent and experience, would have to be expended.

Further the deponent sayeth not.

Proprietary Information NoticeTransmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRCin connection with requests for generic and/or plant-specific review and approval.

In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning theprotection of proprietary information so submitted to the NRC, the information which is proprietary in theproprietary versions is contained within brackets, and where the proprietary information has been deletedin the non-proprietary

versions, only the brackets remain (the information that was contained within thebrackets in the proprietary versions having been deleted).

The justification for claiming the 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 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, copyright protection 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.

O Westinghouse U.S. Nuclear Regulatory Commission Document Control Desk11555 Rockville PikeRockville, MD 20852Westinghouse Electric CompanyEngineering, Equipment and Major Projects1000 Westinghouse DriveCranberry

Township, Pennsylvania 16066USADirect tel: (412) 374-4419Dircct fax: (724) 720-0754e-mail: maurerbf@westinghouse.com WEC-PCH-RSD-14-037 CAW-14-3912 March 6, 2014APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

WCAP- ! 7655-P, Revision 3, "Peach Bottom Unit 3 Replacement Steam Dryer PowerAscension Program for Extended Power Uprate Description" (Proprietary)

The proprietary information for which withholding is being requested in the above-referenced report isfurther identified in Affidavit CAW-14-3912 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'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 theaccompanying Affidavit should reference CAW-14-3912 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 EngineerPlant Licensing Enclosures CAW-14-3912 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ssCOUNTY OF BUTLER:Before me, the undersigned authority, personally appeared Bradley F. Maurer, who, being by meduly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf ofWestinghouse Electric Company LLC (Westinghouse),

and that the averments of fact set forth in thisAffidavit are true and correct to the best of his knowledge, information, and belief.Bradley F. Maurer, Principal EngineerPlant Licensing Sworn to and subscribed before methis 6k" day of March 2014Notary PublicCOMMONWEALTH OF PENNSYLVANIA Notarial Seal lI Anne M. Stegman, Notary Public IUnity Twp., westmoreland countyMy Commission Expires Aug. 7, 2016MEMBEM, PENNSYLVANIA ASSO NOTARISS 2CAW-14-3912

(!) [ 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 publicdisclosure in connection with nuclear power plant licensing and rule making proceedings, and amauthorized to apply for its withholding on behalf of Westinghouse.

(2) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of theCommission's regulations and in conjunction with the Westinghouse Application for 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, thefollowing 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 inconfidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and notcustomarily disclosed to the public. Westinghouse has a rational basis for determining thetypes of information customarily held in confidence by it and, in that connection, utilizes asystem to determine when and whether to hold certain types of information in confidence.

The application of that system and the substance of that system constitute Westinghouse 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 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 3CAW-14-3912 competitors without license from Westinghouse constitutes a competitive economicadvantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (orcomponent, structure, tool, method, etc.), the application of which data secures acompetitive economic advantage, e.g., by optimization or improved marketability.

(c) Its use by a competitor would reduce his expenditure of resources or improve hiscompetitive position in the design, manufacture,

shipment, installation, assurance ofquality, or licensing a similar product.(d) It reveals cost or price information, production capacities, budget levels, orcommercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer fundeddevelopment plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

(iii) There are sound policy reasons behind the Westinghouse system which include thefollowing:

(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors.

It is, therefore, withheld from disclosure to protectthe Westinghouse competitive position.

(b) It is information that is marketable in many ways. The extent to which suchinformation is available to competitors diminishes the Westinghouse ability to sellproducts and services involving the use of the information.

(c) Use by our competitor would put Westinghouse at a competitive disadvantage byreducing his expenditure of resources at our expense.

4CAW-14-3912 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage.

Ifcompetitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of acompetitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence ofWestinghouse in the world market, and thereby give a market advantage to thecompetition of those countries.

(f) The Westinghouse capacity to invest corporate assets in research and 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 theprovisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.

(v) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to thebest of our knowledge and belief.(vi) The proprietary information sought to be withheld in this submittal is that which isappropriately marked in WCAP-I 7655-P, Revision 3, "Peach Bottom Unit 3 Replacement Steam Dryer Power Ascension Program for Extended Power Uprate Description" (Proprietary) for submittal to the Commission, being transmitted by Exelon Generation letter andApplication for Withholding Proprietary Information from Public Disclosure, to the DocumentControl Desk. The proprietary information as submitted by Westinghouse is that associated with the review of the Replacement Steam Dryer design and analysis which is a part of theExtended Power Uprate License Amendment Request for Peach Bottom Units 2 and 3, andmay be used only for that purpose.

5CAW-14-3912 (a) This information is part of that which will enable Westinghouse to:(i) Assist Exelon Generation in obtaining NRC review of the Peach BottomAtomic Power Station Units 2 and 3 License Amendment Request.(b) Further this information has substantial commercial value as follows:(i) Westinghouse plans to sell the use of this information to its customers forpurposes of plant specific replacement steam dryer analysis for licensing basis applications.

(ii) Its use by a competitor would improve their competitive position in thedesign and licensing of a similar product for BWR steam dryer analysismethodology.

(iii) The information requested to be withheld reveals the distinguishing aspectsof a methodology which was developed by Westinghouse.

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

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

The development of the technology described in part by the information is the result ofapplying the results of many years of experience in an intensive Westinghouse effort and theexpenditure of a considerable sum of money.In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having therequisite talent and experience, would have to be expended.

Further the deponent sayeth not.

Proprietary Information NoticeTransmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRCin connection with requests for generic and/or plant-specific review and approval.

In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning theprotection of proprietary information so submitted to the NRC, the information which is proprietary in theproprietary versions is contained within brackets, and where the proprietary information has been deletedin the non-proprietary

versions, only the brackets remain (the information that was contained within thebrackets in the proprietary versions having been deleted).

The justification for claiming the 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 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, copyright protection 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.