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MONTHYEARML15118A7172015-04-28028 April 2015 Response to Request for Additional Information on Mellla+ License Amendment Request - Supplement 3 Project stage: Supplement ML15187A3912015-07-0606 July 2015 Supplement 4 - Response to Request for Additional Information on Mellla+ License Amendment Request, Attachments; 2, 3 and 4 Project stage: Supplement ML15247A0882015-09-0404 September 2015 Attachment 2, EPU and Mellla+ Combined Rsd Masrs (Non-Proprietary) and Attachment 3, Affidavit Project stage: Request ML15274A4672015-10-0101 October 2015 MELLLA License Amendment Request - Supplement 6 Response to Request for Additional Information Project stage: Supplement ML15299A0842015-10-26026 October 2015 PBAPS MELLLA License Amendment Request - Supplement 7 Revision Regarding Proposed Technical Specifications Project stage: Supplement ML15302A2372015-11-0909 November 2015 Transmittal of Draft Safety Evaluation for Proposed Maximum Extended Load Limit Plus Amendment Project stage: Draft Approval ML15278A0462016-02-0505 February 2016 Request for Withholding Information from Public Disclosure for Peach Bottom Atomic Power Station, Units 2 and 3 Project stage: Withholding Request Acceptance ML16034A3722016-03-21021 March 2016 Issuance of Amendments Maximum Extended Load Line Limit Analysis Plus Project stage: Approval ML16099A2022016-04-0808 April 2016 Mellla+ License Amendment Issuance - Request for Corrections to Approved License Amendment Safety Evaluation Project stage: Request 2015-07-06
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Category:Legal-Affidavit
MONTHYEARML24121A1852024-04-25025 April 2024 Attachment 2: Curtiss-Wrights Affidavit Withholding Portions of Material Presented to the NRC on May 14, 2024 ML23317A1192023-11-10010 November 2023 Constellation Energy Generation, LLC - 2023 Annual Report - Guarantees of Payment of Deferred Premiums ML22320A5592022-11-16016 November 2022 2022 Annual Report - Guarantees of Payment of Deferred Premiums ML22301A1742022-10-28028 October 2022 Global Nuclear Fuel Americas, LLC (GNF) - Part 21 60-Day Interim Report Notification: GNF3 Raised Water Rod (SC-22-04 Rt) ML22145A0852022-05-25025 May 2022 Response to Request for Additional Information - Proposed Relief Request Associated with Reactor Pressure Vessel N-16A Nozzle Repair ML22003A0022021-12-20020 December 2021 Proposed Relief Request Associated with Reactor Pressure Vessel N-16A Nozzle Repair ML21307A0542021-11-0202 November 2021 Annual Report - Guarantees of Payment of Deferred Premiums ML21272A2772021-09-29029 September 2021 Update to Application for Order Approving License Transfers and Proposed Conforming License Amendments ML21057A2732021-02-25025 February 2021 Application for Order Approving License Transfers and Proposed Conforming License Amendments NMP1L3371, Summary of Changes, Quality Assurance Topical Report, NO-AA-10 & Decommissioning Quality Assurance Program, NO-DC-102021-02-10010 February 2021 Summary of Changes, Quality Assurance Topical Report, NO-AA-10 & Decommissioning Quality Assurance Program, NO-DC-10 ML20329A3452020-11-24024 November 2020 Relief Request Associated with N-16A Reactor Pressure Vessel Instrument Nozzle Repairs - Submittal of Analyses ML20310A1152020-11-0404 November 2020 Annual Report - Guarantees of Payment of Deferred Premiums ML19318G1702019-11-14014 November 2019 2019 Annual Report - Guarantees of Payment of Deferred Premiums ML18316A0032018-11-0707 November 2018 Submittal of 2018 Annual Report - Guarantees of Payment of Deferred Premiums ML18205A3112018-07-24024 July 2018 Application for Subsequent Renewed Operating Licenses - Update Per 10 CFR 2.390 ML18150A3872018-05-30030 May 2018 License Amendment Request - Revised Technical Specifications to Allow Two Safety Relief Valves / Safety Values to Be Out-of-Service with Increased Reactor Pressure Safety Limit ML17243A0112017-08-30030 August 2017 Measurement Uncertainty Recapture License Amendment Request - Supplement 4 Response to Request for Additional Information ML16048A4412016-02-17017 February 2016 Transmittal of Extended Power Uprate: Results of Replacement Steam Dryer Power Ascension Testing ML16049A2582016-02-11011 February 2016 Transmittal of Exelon Nuclear Radiological Emergency Plan Revision ML16028A1712016-01-14014 January 2016 Transmittal of Exelon Nuclear Radiological Emergency Plan Revision ML15274A4672015-10-0101 October 2015 MELLLA License Amendment Request - Supplement 6 Response to Request for Additional Information ML15247A0882015-09-0404 September 2015 Attachment 2, EPU and Mellla+ Combined Rsd Masrs (Non-Proprietary) and Attachment 3, Affidavit ML15233A0952015-08-20020 August 2015 Revision 0 to LTR-BWR-ENG-15-076-NP, Replacement Steam Dryer Report at Predicted EPU Conditions ML15196A6372015-07-15015 July 2015 Error Identified in Letter from Exelon to NRC Re Predicted Strain Ratios Provided in Response to Request for Additional Information (RAI-11) ML15187A3912015-07-0606 July 2015 Supplement 4 - Response to Request for Additional Information on Mellla+ License Amendment Request, Attachments; 2, 3 and 4 ML15096A0082015-04-0505 April 2015 Extended Power Uprate: Response to Replacement Steam Dryer Requests for Additional Information ML14321A7052014-11-14014 November 2014 2014 Annual Report - Guarantees of Payment of Deferred Premiums ML14247A5032014-09-0404 September 2014 License Amendment Request - Maximum Extended Load Line Limit Analysis Plus ML14204A7092014-07-23023 July 2014 Enclosure 3, Affidavit of Peter M. Yandow RS-14-160, Co. - Submission of Standard Practice Procedure Plans and Foreign Ownership Control or Influence Package2014-07-0202 July 2014 Co. - Submission of Standard Practice Procedure Plans and Foreign Ownership Control or Influence Package ML14105A3842014-04-11011 April 2014 Extended Power Uprate License Amendment Request - Supplement 24 Response to Request for Additional Information ML14035A1582014-01-31031 January 2014 Extended Power Uprate License Amendment Request - Supplement 19 Response to Request for Additional Information ML13240A0022013-08-22022 August 2013 Extended Power Uprate License Amendment Request - Supplement 9 Response to Request for Additional Information ML13109A0522013-04-18018 April 2013 Revised Gnf Response to NRC RAI 44 for License Amendment Request for Use of Neutron Absorbing Spent Fuel Pool Rack Inserts, Attachment 3, Enclosures 2, 3 and 4 RS-12-227, Exelongeneration, Submission of Standard Practice Procedure Plans and Updated Foreign Ownership Control or Influence Package2012-12-19019 December 2012 Exelongeneration, Submission of Standard Practice Procedure Plans and Updated Foreign Ownership Control or Influence Package ML11325A3882011-11-18018 November 2011 Issuance of the Core Operating Limits Report for Reload 18, Cycle 19, Revision 7 ML1127000682011-09-26026 September 2011 Enclosure 3, Mfn 10-245 R4, Affidavit ML1031904262010-11-0808 November 2010 Corp. - 2010 Annual Report - Guarantees of Payment of Deferred Premiums ML1008301582010-03-23023 March 2010 Enclosure 2 to Mfn 10-124, Affidavit of James F. Harrison Response to NRC Request for Information Regarding Appeal of Denial of Request for Withholding Certain Information: Reference 1 Letter from J. Hughey (NRC) to J. Head (GEH) February 2 ML0520003282005-07-14014 July 2005 Surveillance Program for Channel-Control Blade Interference ML0508101932005-03-18018 March 2005 Renewed Facility Operating License No. DPR-56, Incorporation of Lead Use Assemblies 2024-04-25
[Table view] Category:Letter
MONTHYEARML24240A1692024-09-18018 September 2024 Cy 2023 Summary of Decommissioning Trust Fund Status ML24255A8642024-09-0606 September 2024 Rscc Wire & Cable LLC Dba Marmon Industrial Energy & Infrastructure - Part 21 Retraction of Final Notification ML24221A2582024-09-0606 September 2024 Response to Request for Re-Engagement Regarding the Subsequent License Renewal Environmental Review for Peach Bottom Atomic Power Station, Units 2 and 3 05000277/LER-2024-003, (Pbaps), Unit 2, Automatic Reactor Scram Following Main Turbine Trip Due to Degraded Condenser Vacuum2024-09-0505 September 2024 (Pbaps), Unit 2, Automatic Reactor Scram Following Main Turbine Trip Due to Degraded Condenser Vacuum IR 05000277/20240022024-09-0404 September 2024 Reissued Integrated Inspection Report 05000277/2024002 and 05000278/2024002 IR 05000277/20240052024-08-29029 August 2024 Updated Inspection Plan for Peach Bottom Atomic Power Station, Units 2 and 3 (Report 05000277/2024005 and 05000278/2024005) IR 05000277/20240102024-08-23023 August 2024 Fire Protection Team Inspection Report 05000277/2024010 and 05000278/2024010 ML24235A0342024-08-23023 August 2024 U.S. Nuclear Regulatory Commission’S Analysis of Constellation Energy Generation’S Decommissioning Funding Status Report ML24239A3972024-08-23023 August 2024 Rssc Wire & Cable LLC Dba Marmon - Part 21 Final Notification - 57243-EN 57243 IR 05000482/20240052024-08-14014 August 2024 Updated Inspection Plan for Wolf Creek Generating Station (Report 05000482/2024005) ML24227A5492024-08-14014 August 2024 Integrated Inspection Report 05000277/2024002 and 05000278/2024002 ML24225A1692024-08-12012 August 2024 10 CFR 50.46 Annual Report ML24222A6772024-08-0909 August 2024 Response to Request for Additional Information for Application to Revise Technical Specifications to Adopt TSTF-591-A, Revise Risk Informed Completion Time (RICT) Program Revision 0 and Revise 10 CFR 50.69 License Condition ML24214A3232024-08-0101 August 2024 Response to Request for Additional Information - Request for Alternative Schedule to Complete Decommissioning Beyond 60 Years of Permanent Cessation of Operations ML24208A0962024-07-25025 July 2024 57243-EN 57243 - Rssc Wire & Cable LLC, Dba Marmon - Part 21 Notification ML24206A1252024-07-24024 July 2024 Revision of Three Procedures and Two Forms That Implement the Radiological Emergency Response Plan (RERP) ML24191A0612024-07-0606 July 2024 Independent Spent Fuel Storage Installation (ISFSI) - Annual Radioactive Effluent Release Report ML24178A4142024-06-26026 June 2024 Revision of One Procedure and One Form That Implement the Radiological Emergency Response Plan (RERP) ML24178A3672024-06-26026 June 2024 Correction to 2023 Annual Radioactive Effluent Release Report – Report 47 ML24177A1512024-06-24024 June 2024 Post Accident Monitoring Instrumentation Report ML24166A1172024-06-20020 June 2024 Regulatory Audit Summary Regarding Proposed Alternative Schedule to Complete Decommissioning Beyond 60 Years RS-24-061, Constellation Energy Generation, LLC, Response to NRC Regulatory Issue Summary 2024-01, Preparation and Scheduling of Operator Licensing Examinations2024-06-14014 June 2024 Constellation Energy Generation, LLC, Response to NRC Regulatory Issue Summary 2024-01, Preparation and Scheduling of Operator Licensing Examinations IR 05000277/20243012024-06-13013 June 2024 Initial Operator Licensing Examination Report 05000277/2024301 and 05000278/2024301 RS-24-058, Regarding Subsequent License Renewal Environmental Review2024-06-0505 June 2024 Regarding Subsequent License Renewal Environmental Review ML24151A6482024-06-0303 June 2024 Changes in Reactor Decommissioning Branch Project Management Assignments for Some Decommissioning Facilities ML24150A2722024-05-29029 May 2024 Annual Radiological Environmental Operating Report 81, January 1, 2023 Through December 31, 2023 ML24150A0032024-05-28028 May 2024 Request for Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) and Proposed Amendment to the Decommissioning Trust Agreement ML24079A0762024-05-23023 May 2024 Issuance of Amendments to Adopt TSTF 264 RS-24-055, 2023 Corporate Regulatory Commitment Change Summary Report2024-05-17017 May 2024 2023 Corporate Regulatory Commitment Change Summary Report ML24134A1792024-05-13013 May 2024 Supplemental Information in Support of Request for Alternative Schedule to Complete Decommissioning Beyond 60 Years of Permanent Cessation of Operations IR 05000277/20240012024-05-13013 May 2024 Integrated Inspection Report 05000277/2024001 and 05000278/2024001 IR 05000277/20245012024-05-0808 May 2024 Emergency Preparedness Biennial Exercise Inspection Report 05000277/2024501 and 05000278/2024501 RS-24-041, Alternative Request to Utilize Code Case OMN-32, Alternative Requirements for Range and Accuracy of Pressure, Flow, and Differential Pressure Instruments Used in Pump Tests2024-04-30030 April 2024 Alternative Request to Utilize Code Case OMN-32, Alternative Requirements for Range and Accuracy of Pressure, Flow, and Differential Pressure Instruments Used in Pump Tests ML24121A1832024-04-30030 April 2024 Pre-Submittal Meeting Presentation Material Peach Bottom ECCS Compensated Level System Replacement Project ML24118A0032024-04-27027 April 2024 2023 Annual Radioactive Effluent Release Report - Report 47 ML24120A2762024-04-23023 April 2024 Independent Spent Fuel Storage Installation (ISFSI) Facility - Annual Radioactive Effluent Release Report 66 January 1, 2023 Through December 31, 2023 CNL-24-033, Central Emergency Control Center Emergency Plan Implementing Procedure Revisions2024-04-17017 April 2024 Central Emergency Control Center Emergency Plan Implementing Procedure Revisions ML24107A2462024-04-15015 April 2024 Submittal of Changes to Technical Specifications Bases ML24103A2042024-04-12012 April 2024 Constellation Energy Generation, LLC, Application to Revise Technical Specifications to Adopt TSTF-591-A, Revise Risk Informed Completion Time (RICT) Program Revision 0 and Revise 10 CFR 50.69 License Condition ML24102A0472024-04-11011 April 2024 Operator Licensing Examination Approval ML24099A0012024-04-0808 April 2024 (PBAPS) Units 2 and 3, Uncoordinated DC Circuits Cause Unanalyzed Condition RS-24-002, Constellation Energy Generation, LLC - Annual Property Insurance Status Report2024-04-0101 April 2024 Constellation Energy Generation, LLC - Annual Property Insurance Status Report RS-24-023, Report on Status of Decommissioning Funding.2024-03-22022 March 2024 Report on Status of Decommissioning Funding. 05000277/LER-2024-001, Submittal of LER 2024-001-00 for Peach Bottom Atomic Power Station (PBAPS) Unit 2, Automatic Reactor Scram Due to an Invalid Generator Lockout2024-03-21021 March 2024 Submittal of LER 2024-001-00 for Peach Bottom Atomic Power Station (PBAPS) Unit 2, Automatic Reactor Scram Due to an Invalid Generator Lockout IR 05000277/20244022024-03-12012 March 2024 Cybersecurity Inspection Report 05000277/2024402 and 05000278/2024402 (Cover Letter Only) ML24061A2642024-03-0101 March 2024 Revision of Two Procedures That Implement the Radiological Emergency Response Plan (RERP) for Wolf Creek Generating Station (WCGS) Commissioners ML24060A1192024-02-29029 February 2024 Notification of Conduct of a Fire Protection Team Inspection IR 05000277/20230062024-02-28028 February 2024 Annual Assessment Letter for Peach Bottom Atomic Power Station, Units 2 and 3 (Reports 05000277/2023006 and 05000278/2023006) IR 05000171/20230012024-02-20020 February 2024 Constellation Energy Generation, LLC - Peach Bottom Atomic Power Station, Unit 1 - NRC Inspection Report No. 05000171/2023001 ML24050A0012024-02-19019 February 2024 (Wcgs), Revision of One Form That Implements the Radiological Emergency Response Plan (RERP) 2024-09-06
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U.S. Nuclear Regulatory Commission MELLLA+ LAR Supplement 4 Response to Request for Additional Information July 6, 2015 Page 2 related to MELLLA+ operating training. EGC proposes minor editorial and administrative changes to that text; Attachment 3 provides the revised text for the license condition. This letter also modifies the PBAPS plans for implementation of the MELLLA+ amendments. In the cover letter of the amendment request (Reference 1 ), EGC described plans for implementation of the MELLLA+ amendment. The following statement amends this original implementation plan: Once approved, the amendment will be implemented on Unit 2 within 90 days following the completion of the Unit 3 outage (P3R20), and will be implemented on Unit 3 within 90 days following the completion of the Unit 3 P3R20 EPU full power ascension. 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 the referenced LAR. 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 attachments to the designated State Officials. There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Mr. David Neff at (610) 765-5631. I declare under penalty of perjury that the foregoing is true and correct. Executed on the 61h day of July 2015. Respectfully, Kevin F. Borton Manager, Licensing -Power Uprate Exelon Generation Company, LLC Attachments: 1. Response to Mechanical and Civil Engineering Branch Request for Additional Information -Proprietary 2. Response to Mechanical and Civil Engineering Branch Request for Additional Information -Non-Proprietary 3. Revised Proposed License Condition 2.C (17) 4. Affidavit in Support of Request to Withhold Information
in ouse U.S. Nuclear Regulatory Commission Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA Direct tel: (412) 374-4643 Direct fax: (724) 940-8560 e-mail: greshaj a@westinghouse.com CAW-15-4226 July 1, 2015 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE
Subject:
LTR-BWR-ENG-15-067-P "Response to Support the U.S. NRC Requests for Additional Information Relative to the Impacts of MELLLA+ on the Peach Bottom Replacement Steam Dryer," and Attachment 1 to Exelon Generation submittal to the NRC containing the response to EMCB-RAI-3, "Responses to Mechanical and Civil Engineering Branch Request for Additional Information -Proprietary" The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CA W-15-4226 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 Westinghouse Affidavit should reference CAW-15-4226, and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 3 Suite 310, Cranberry Township, Pennsylvania 16066. 4-James A. Gresham, Manager Regulatory Compliance Enclosures COMMONWEALTH OF PENNSYLVANIA: COUNTY OF BUTLER: AFFIDAVIT SS CAW-15-4226 July 1, 2015 I, Henry A. Sepp, am 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 my knowledge, information, and belief. CRE-Systems and Components Engineering 2 CAW-15-4226 (1) I am Director, CRE-Systems and Components Engineering, 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 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 competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.
3 CAW-15-4226 (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. ( 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 CAW-15-4226 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 "LTR-BWR-ENG-15-067-P, "Response to Support the U.S. NRC Requests for Additional Information Relative to the Impacts of MELLLA+ on the Peach Bottom Replacement Steam Dryer," and Attachment 1 to Exelon Generation submittal to the NRC containing the response to EMCB-RAI-3, "Responses to Mechanical and Civil Engineering Branch Request for Additional Information - 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 NRC's further review of the RSD analysis for EPU and MELLLA+ operating conditions for PBAPS Units 2 and 3, and may be used only for that purpose.
CAW-15-4226 (a) This information is part of that which will enable Westinghouse to: (i)Assist Exelon Generation in obtaining NRC review and approval of the RSD analysis for EPU and MELLLA+ operating conditions for PBAPS Units 2 and 3. (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 evaluation 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 non-proprietary versions of documents furnished to the NRC associated with the NRC' s request for additional information with regards to the Impacts of MELLLA + on the Peach Bottom Replacement Steam Dryer, and may be used only for that purpose. In order to conform to the requirements of 10 CPR 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 that Westinghouse customarily holds in confidence is identified in Sections (4)(ii)(a) through (4)(ii)(f) of the Affidavit accompanying this transmittal pursuant to 10 CPR 2.390(b)(l). 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.