Westinghouse Non-Proprietary Class 3

WCAP-16498-NP-A,Revision 0

17x17 Next Generation Fuel(17x17 NGF)Reference Core Report

Westinghouse

WESTINGHOUSE NON-PROPRIETARY CLASS 3

WCAP-16498-NP-A,Revision 0

17x17 Next Generation Fuel (17x1 7 NGF)Reference Core Report

May 2011

Authors:

J. A. Barsic

A. M. Everhard

D. S. Huegel

E. M. Monahan

M. E. Nissley

R. R. Schoff

Y. X. Sung

M. E. Conner

J. L. Grover

K. E. Keiser

K. B. Neubert

D. H. Risher

J. R. Secker

Prepared by:*N. T. Brichacek, Licensing Engineer

Fuel Engineering Licensing

Approved by:*K. W. Cummings, Manager

Fuel Engineering Licensing

* Electronically Approved Records Are Authenticated in the Electronic Document Management System

Westinghouse Electric Company LLC1000 Westinghouse Drive

Cranberry Township, PA 16066

© 2011 Westinghouse Electric Company LLCAll Rights Reserved

WCAP-16498-NP-A

This page intentionally left blank

WCAP-16498-NP-A

TABLE OF CONTENTS

Section Description

Final Safety Evaluation

A Letter from T. B. Blount (USNRC) to J. A. Gresham (Westinghouse), "Final Safety Evaluation forWestinghouse Electric Company Topical Report WCAP-16498-P/WCAP-16498-NP, '17x17 NextGeneration Fuel (1 7x 17 NGF) Reference Core Report' (TAC No. MD8540)" dated March 16, 2011.

Submittal

B Letter from J. A. Gresham (Westinghouse) to USNRC, "Submittal ofWCAP- 1 6498-P/WCAP 16498-NP, 'I 7x 17 Next Generation Fuel (1 7x 17 NGF) Reference CoreReport,' (Proprietary/Non-Proprietary)" dated April 3, 2008.

Correspondences

C Letter from J. A. Gresham (Westinghouse) to USNRC, "Response to the NRC's Request forAdditional Information By the Office of Nuclear Reactor Regulation For Westinghouse ElectricCompany Topical Report WCAP- 16498-P '1 7x 17 Next Generation Fuel Reference Core Report'(TAC No. MD8540) (Proprietary/Non-Proprietary)" dated February 9, 2010.

WCAP-16498-NP-A

Section A

OFFICIAL USE ONLYPOifE RYFOtTOWCAP-16498-NP-A

March 16, 2011

Mr. James A. Gresham, ManagerRegulatory Compliance and Plant LicensingWestinghouse Electric Company1000 Westinghouse DriveCranberry Township, PA 16066

SUBJECT: FINAL SAFETY EVALUATION FOR WESTINGHOUSE ELECTRIC COMPANYTOPICAL REPORT WCAP-1 6498-P/WCAP-1 6498-NP, "1 7Xl 7 NEXTGENERATION FUEL (17X17 NGF) REFERENCE CORE REPORT"(TAC NO. MD8540)

Dear Mr. Gresham:

By letter dated April 3, 2008 (Agencywide Documents Access and Management System(ADAMS) Accession No. ML081010602), Westinghouse Electric Company (Westinghouse)submitted Topical Report (TR) WCAP-16498-P/WCAP-16498-NP, "17x17 Next Generation Fuel(17x17 NGF) Reference Core Report," to the U.S. Nuclear Regulatory Commission (NRC) staff.By letter dated December 7, 2010, an NRC draft safety evaluation (SE) regarding our approvalof TR WCAP-16498-P/WCAP-16498-NP was provided for your review and comments. By letterdated January 20, 2011, Westinghouse commented on the draft SE. The NRC staffsdisposition of Westinghouse's comments on the draft SE are discussed in the attachment to thefinal SE enclosed with this letter.

The NRC staff has found that TR WCAP-16498-P/WCAP-16498-NP is acceptable forreferencing in licensing applications for reactors that incorporate 17x17 NGF fuel assemblydesign to the extent specified, and under the limitations delineated in the enclosed final SE.The final SE defines the basis for our acceptance of the TR.

Our acceptance applies only to material provided in the subject TR. We do not intend to repeatour review of the acceptable material described in the TR. When the TR appears as areference in license applications, our review will ensure that the material presented applies tothe specific plant involved. License amendment requests that deviate from this TR will besubject to aplant-specific review in accordance with applicable review standards.

In accordance with the guidance provided on the NRC website, we request that Westinghousepublish accepted proprietary and non-proprietary versions of this TR within three months ofreceipt of this letter. The accepted versions shall incorporate this letter and the enclosed finalSE after the title page. Also, they must contain historical review information, including NRCrequests for additional information (RAIs) and your responses. The accepted versions shallinclude an "-A" (designating accepted) following the TR identification symbol.

NOTICE: Enclosure 2 transmitted herewith contains proprietary information. Whenseparated from Enclosure 2, this document is decontrolled.

/OF1F1IC'I A ITSEI O•NLTY PROPRIT1T ARD INFOR-DMlA TION~l.

OFFICTIA1TAL USE ONLY PROPRIETARV INFOR•MATIO"N WCAP-16498-NP-A

J. Gresham -2-

As an alternative to including the RAIs and RAI responses behind the title page, if changes tothe TR were provided to the NRC staff to support the resolution of RAI responses, and the NRCstaff reviewed and approved those changes as described in the RAI responses, there are twoways that the accepted version can capture the RAIs:

1. The RAIs and RAI responses can be included as an Appendix to the accepted version.2. The RAIs and RAI responses can be captured in the form of a table (inserted after the finalSE) which summarizes the changes as shown in the approved version of the TR. The tableshould reference the specific RAIs and RAI responses which resulted in any changes, as shownin the accepted version of the TR.

If future changes to the NRC's regulatory requirements affect the acceptability of this TR,Westinghouse and/or licensees referencing it will be expected to revise the TR appropriately, orjustify its continued applicability for subsequent referencing.

Sincerely,

/RA/

Thomas B. Blount, Deputy DirectorDivision of Policy and RulemakingOffice of Nuclear Reactor Regulation

Project No. 700

Enclosures: 1. Final SE (non-proprietary version)2. Final SE (proprietary version)3. Resolution of comments

cc w/encls 1 and 3 only:

Mr. Kris Cummings, ManagerNuclear Fuel Engineering LicensingWestinghouse Electric CompanyP.O. Box 355Pittsburgh, PA 15230-0355cumminkwcDwestinqhouse.com

OFFICIAL USE ONLY OFCAUEOLPROPRIETARY NINFORMAT-ION

OFF'ICIAL USE ONLY PROPRIETAAR- INFORMATION WCAP-16498-NP-A

J. Gresham -2-

As an alternative to including the RAIs and RAI responses behind the title page, if changes tothe TR were provided to the NRC staff to support the resolution of RAI responses, and the NRCstaff reviewed and approved those changes as described in the RAI responses, there are twoways that the accepted version can capture the RAls:

1. The RAIs and RAI responses can be included as an Appendix to the accepted version.2. The RAls and RAI responses can be captured in the form of a table (inserted after the finalSE) which summarizes the changes as shown in the approved version of the TR. The tableshould reference the specific RAIs and RAI responses which resulted in any changes, as shownin the accepted version of the TR.

If future changes to the NRC's regulatory requirements affect the acceptability of this TR,Westinghouse and/or licensees referencing it will be expected to revise the TR appropriately, orjustify its continued applicability for subsequent referencing.

Sincerely,

IRA/

Thomas B. Blount, Deputy DirectorDivision of Policy and RulemakingOffice of Nuclear Reactor Regulation

Project No. 700

Enclosures: 1. Final SE (non-proprietary version)2. Final SE (proprietary version)3. Resolution of comments (non-proprietary version)

cc w/encls 1 and 3 only:

Mr. Kris Cummings, ManagerNuclear Fuel Engineering LicensingWestinghouse Electric CompanyP.O. Box 355Pittsburgh, PA 15230-0355cumminkw(awestinghouse.com

DISTRIBUTION:RidsNrrDprPIpb RidsNrrPMELenning RidsNrrLADBaxleyRidsOgcMailCenter RidsAcrsAcnwMailCenter RidsNrrDssSpnbAMendiola YOrechwa PLPB Reading FileRidsNrrDpr RidsNroDsraSrsb

PACKAGE ADAMS ACCESSION NO. ML110610254

*No major changes to SE input. NRR-043

OFFICE PLPB/PM PLPB/LA SNPB/BC* PLPB/PM PLPB/BC DPR/DDNAME ELenning DBaxley AMendiola HCruz JJolicoeur TBIountDATE 3/10/11 3/10/11 11/2/10 3/10/11 3/11/11 3/16/11

OFFICIAL RECORD COPY

OFFICIT•lA ll TUSE /lIl ONV PROPRDDIET ARY INa'•FORlATT"ION

WCAP-16498-NP-A

FINAL SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION

WCAP-16498-P/WCAP-16498-NP, "17X17 NEXT GENERATION FUEL (17X17 NGF)

REFERENCE CORE REPORT"

WESTINGHOUSE ELECTRIC COMPANY

PROJECT NO. 700

1.0 INTRODUCTION AND BACKGROUND

By letter dated April 3, 2008 (Reference 1), the Westinghouse Electric Company(Westinghouse) submitted Topical Report (TR) WCAP-16498-P/WCAP-16498-NP, "17X17 NextGeneration Fuel (17X17 NGF) Reference Core Report," to the U.S. Nuclear RegulatoryCommission (NRC) for review and approval. The 17x17 NGF fuel design is an evolutionarydesign of NRC approved 17x17 fuel designs in general and the 17x17 Robust Fuel Assembly(RFA) design in particular. Thus, most of the design features of the 17x17 NGF fuel areidentical to those of the NRC accepted 17x17 RFA fuel. To assure that the Nuclear SteamSupply System (NSSS) conditions applied in the previous approvals of 17x17 fuel do notinvalidate or change the analysis methodology for 17x17 NGF fuel, a scoping analysis wasperformed of the NSSS conditions of the various 17x1 7 fueled plants. This TR presents genericinformation with regard to the performance of the improved fuel design features associated withthe transition from 17x17 RFA to 17x17 NGF fuel. The key feature in that transition isassociated with the design of the grids. The mixing vane design has been modified to improveheat transfer performance during normal operation. Furthermore, the number of IntermediateFlow Mixing (IFM) grids has been increased from three to five so as to provide additionalturbulent mixing in the upper spans of the fuel assembly, and, thereby, allow more thermalmargin in the design and in the support of plant uprates.

2.0 REGULATORY EVALUATION

Topical Report WCAP-16498-PIWCAP-16498-NP presents the 17X17 NGF design evaluationthat provides, through demonstrated conformance to the guidance given in the Section 4.2,Revision 2, "Fuel System Design" of NUREG-0800, "Standard Review Plan [(SRP)] for theReview of Safety Analysis Reports for Nuclear Power Plants," (Reference 2), assurance that:

(a) The fuel system is not damaged as a result of normal operation and anticipated operationaloccurrences.

(b) Fuel system damage is never so severe as to prevent control rod insertion when it isrequired.

(c) The number of fuel rod failures is not underestimated for postulated accidents.

(d) Coolability is always maintained.

ENCLOSURE 1

_9_WCAP-16498-NP-A

These objectives implement General Design Criteria 10, 27, and 35. All fuel damage criteriarelevant to these requirements are described in SRP 4.2; those stated in terms that involve thedeparture from nucleate boiling ratio (DNBR) or the critical power ratio (CPR) limits, that arerelevant specific thermal-hydraulic criteria, are given in the Section 4.4, Revision 2, "Thermaland Hydraulic Design" of NUREG-0800, "Standard Review Plan for the Review of SafetyAnalysis Reports for Nuclear Power Plants" (SRP 4.4) (Reference 3). The specific coolabilityrequirements for the loss-of-coolant accident (LOCA) and for the dose analysis in postulatedaccidents are given respectively by 10 CFR 50.46 and 10 CFR Part 100.

3.0 TECHNICAL EVALUATION

The 17x17 NGF fuel assembly is designed as a follow-on to the 17x17 RFA design. The keydifferences in the two designs are given in the following table.1

Key Differences of 17x17 RFA and 17x17 NGF Fuel DesignRFA NGF

Fuel AssemblyWeight, lbs. [ ] [ ]

GridsMid-grids Five grids, modified horizontal Five grids, wide horizontal

dimple, diagonal spring, and dimple, new "I-spring", andmodified V5H vane modified RFA vane

Mid-grid Height, in.IFM - Grids Three Five

IFM - Grid Height, in.

NozzleTop Nozzle Machine and/or cast, Cast, reconstitutable, integral

reconstitutable spring padTop Nozzle Weight, lbs. I I

Bottom Nozzle Debris filter Debris filter with improved AP

Guide ThimbleGuide Thimble Dashpot Swaged Tube-in-tube

Design

Joints and ConnectionsTop-Grid Joint One Bulge to guide thimble Two Bulges to guide thimble

Restraint Bulge Zero Two

Fuel RodClad Material ZIRLOTM Optimized ZIRLOTM

Axial Blankets [

1 Note: All dimensions are in inches and are listed as reference values as would be done in a plant's Final SafetyEvaluation Report.

- 3- WCAP-16498-NP-A

The 17x17 NGF fuel assembly is designed to be mechanically compatible with the 17x17 RFAdesign for operation with mixed fuel cores. Moreover, most of the new features of the 17x17NGF design, relative to the 17x17 RFA design, have a licensing pedigree as indicated by thereferences in the table.

Therefore, given that most of the 17x17 NGF design is identical to that of previously NRCapproved 17xl 7 fuel designs, TR WCAP-1 6498-PMWCAP-1 6498-NP presents the 17x1 7 NGFdesign evaluation in line with the structure of the SRP 4.2 (Reference 2) supplemented with theappropriate references to any materials already approved by the NRC. As such, the evaluationis organized along functional lines: Mechanical Design, Nuclear Design, Thermal and HydraulicDesign, Accident Analysis, Reactor Vessel and Internals Evaluation, and RadiologicalAssessment.

The NRC staffs Requests for Additional Information (RAIs) that addressed a one-to-onecomparison between methodologies, computer codes, and specific performance characteristicsas they relate to the fuel performance analysis of the NRC approved 17x1 7 RFA fuel design andthe 17x17 NGF fuel design in the context of the same reference core (Reference 4). In addition,the calculation notes for fuel rod design, thermal-hydraulic design, and core design were madeavailable at request for audit purposes.

Based on the generic information presented by Westinghouse in TR WCAP-1 6498-P/WCAP-16498-NP in regard to the design evaluation of the 17x17 NGF fuel design, and theresponse to the NRC staffs RAIs, the following performance characteristics are confirmed bythe NRC (Reference 5).

3.1 Mechanical Design

* The 17x17 NGF fuel assembly design is mechanically compatible with the 17x17 RFAdesign.

* The design bases for fuel assembly structural components are satisfied." The design bases and limits for the 17x17 NGF fuel assembly and fuel rod performance

are satisfied for lead rod average burnups of 62,000 MWD/MTU." The grid impact force for seismic and LOCA events was determined to be within the

allowable limits as determined by grid crush tests.* Hydraulic flow testing of the 17x1 7 NGF fuel assembly with the 17x1 7 RFA fuel design

confirms that fuel rod wear is within the Westinghouse established guidelines andprovides additional margin relative to current 17x17 designs.

3.2 Nuclear Design

" Standard nuclear design analytical models and methods accurately describe theneutronic behavior of the 17x1 7 NGF fuel design.

* The 17x17 NGF nuclear design bases are satisfied.* Safety limit characteristics of the 17x17 RFA fuel design apply to the 17x17NGF fuel

design with no loss of margin to those limits.

3.3 Thermal and Hydraulic Design

• With the implementation of the five IFM grids, the thermal margins are increased.

- 4- WCAP-16498-NP-A

* A new departure from nucleate boiling (DNB) correlation WNG-1 has been developedthrough testing of the 17x17 NGF fuel assembly. The application of this correlation tomeet the DNB design basis of SRP 4.2 and SRP 4.4 (Reference 2, Reference 3), thatthere will be at least a 95 percent probability at a 95 percent confidence level that DNBwill not occur on the limiting fuel rods during Conditions I and II events for the 17x17NGF fuel, is based on the NRC-approved TR WCAP-16766-P-A/WCAP-16766-NP-A(Reference 8).

* Hydraulic flow tests of the 17x1 7 NGF fuel assembly indicate a [ ]increase in the core pressure drop compared to 17x17 RFA fuel.

* No rod bow DNBR penalty is required in the IFM-grid spans as the additional grids in the17x17 NGF fuel assembly eliminate rod bow issues.

3.4 Accident Analyses and Evaluations

* For the non-LOCA accidents, the currently-approved methods and computer codes usedin the Final Safety Analysis Report non-LOCA Chapter 15 analyses are applicable for17x17 NGF fueled core accident evaluations for demonstrating that acceptance criteriaare met.

* For the LOCA analyses, the currently-approved realistic Large Break LOCA anddeterministic Small Break LOCA methods are applicable for 17x17 NGF fueled coreaccident evaluations for demonstrating that acceptance criteria are met.

3.5 Reactor Vessel and Internals Evaluation

3.5.1 Reactor Internals System Thermal-Hydraulic Performance

* The thermal-hydraulic analysis methodology used by Westinghouse of the reactorinternals in pressurized water reactors implementing changes in fuel remains valid forWestinghouse PWRs implementing 17x17 NGF fuel.

3.5.2 Reactor internals System Structural Response to Seismic and LOCA Conditions

* The Westinghouse finite element modeling associated with LOCA and seismic analysesof the reactor vessel, reactor internals, and fuel remains valid in the analysis of aWestinghouse PWR implementing the 17x17 NGF fuel design. (Reference 7)

3.5.3 Reactor Control Cluster Assembly (RCCA) Scram Performance

* The Westinghouse RCCA scram time methodology remains valid for use in the analysisof Westinghouse PWRs implementing the 17x17 NGF fuel design. RCCA scram timeevaluations have been performed for several plants with 17x17 NGF fuel and indicate aslight increase in the scram time. Thus, plant-specific RCCA scram time analysis will bedone by Westinghouse to confirm that the RCCA scram time limit is not violated.

3.5.4 Reactor Internal Components Structural Performance

* With a change in fuel design there is a possibility of increased gamma heating on theinternal components surrounding the core. The model and methodology used byWestinghouse in analyzing increased gamma heating on the reactor internalcomponents is unaffected by the 17x17 NGF design.

- 5- WCAP-16498-NP-A

3.5.5 Reactor Internal Components Interface with the Fuel

The Westinghouse methodology used in evaluating the impact of the introduction of17x17 NGF fuel does not have an effect on the interface between the fuel and thereactor internal components.

3.6 Radiological Assessment

The design changes for the 17x17 NGF fuel do not include changes to the fuel pellets,nor to the enrichment or burnup limits. Thus, there is no direct impact on the coresource term and no projected impact on the potential releases of radioactivity from theoperating plant under normal operation or under accident conditions.

4.0 LIMITATIONS AND CONDITIONS

Licensees that reference TR WCAP-16498-PIWCAP-16498-NP must ensure compliance withthe following conditions and limitations:

1. Where plant-specific analyses are required, these analyses will be documented for thatapplication with appropriate reference to the material in TR WCAP-16498-P/WCAP-16498-NP.

2. Plant-specific analyses/evaluations will be done for each initial application of the 17x1 7NGF fuel assembly design. These analyses/evaluations are to address the transitioncore effects from the existing 17x17 fuel product to a full core of 17x17 NGF fuel.

3. The transition core DNBR penalty on the 17x17 NGF fuel assembly during the transitionfrom 17x17 fuel is to be evaluated using the current evaluation methodology with thenew DNB correlation WNG-1 that has been developed through testing of the 17x17 NGFfuel assembly. The application of this correlation to meet the DNB design basis of SRP4.2 and SRP 4.4 that there will be at least a 95 percent probability at a 95 percentconfidence level, that DNB will not occur on the limiting fuel rods during Conditions I andII events for 17x17 NGF fuel, is based on NRC approved TR WCAP-16766-P-A/WCAP-16766-NP-A (Reference 6).

4. The Westinghouse RCCA scram time methodology remains valid for use in the analysisof Westinghouse PWRs implementing the 17x17 NGF fuel design. RCCA scram timeevaluations have been performed for several plants with 17x17 NGF fuel and indicate aslight increase in the scram time. Thus, plant-specific RCCA scram time analysis will bedone by Westinghouse to confirm that the Technical Specification RCCA scram timelimit is not violated.

5. The reference fuel assembly design, 17x17 NGF, its fuel mechanical designmethodology and design criteria, are approved up to a peak rod average burnup of62 GWd/MTU.

All of the limitations and conditions listed in previous NRC safety evaluations' approvals formethodologies used for 17x17 NGF, including those listed for Optimized ZIRLOTM (Reference 8)will continue to be met.

-6- WCAP-16498-NP-A

5.0 CONCLUSION

The NRC staff has reviewed the reference 17x1 7 NGF fuel design presented by Westinghousein the TR WCAP-16498-P-P/WCAP-NP and determined that it meets design and regulatoryrequirements. Plant-specific and cycle-specific evaluations are required to ensure thatallowable variances of this fuel assembly design continue to satisfy all criteria.

Based upon its review of TR WCAP-16498-P-P/WCAP-NP, and RAI responses, the NRC stafffinds that the Westinghouse 17x17 NGF fuel assembly design, fuel design criteria, andsupporting fuel mechanical and reload design methodology is acceptable subject to theconditions and limitations listed in Section 4.0.

6.0 REFERENCES

1. Letter from Gresham, J. A. (Westinghouse) to U.S. Nuclear Regulatory Commission,"Submittal of WCAP-116498-P/ WCAP-1 6498-NP, '1 7Xl 7 Next Generation Fuel (1 7Xl 7NGF) Reference Core Report'," April 3, 2008 (ADAMS Accession No. ML0810106020).

2. NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports forNuclear Power Plants," Section 4.2, "Fuel System Design", U.S. NRC, March 2007.

3. NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports forNuclear Power Plants," Section 4.4, Revision 2, "Thermal and Hydraulic Design", U.S.NRC, July 1981.

4. Letter from U.S. Nuclear Regulatory Commission to Gresham, J. A. (Westinghouse),"Westinghouse Electric Company Request for Additional Information Re: Topical ReportWCAP-16498-P, 'Next Generation Fuel Reference Core Report' (TAC No. MD8540),"July 1, 2009 (ADAMS Accession No. ML091740088).

5. Letter from Gresham, J. A. (Westinghouse) to U.S. Nuclear Regulatory Commission,"Response to the NRC's Request for Additional Information by the Office of NuclearReactor Regulation for the Westinghouse Electric Company Topical ReportWCAP-16498-P '17x17 Next Generation Fuel Reference Core Report," February 9, 2010(ADAMS Accession No. ML100480892).

6. Letter from Gresham, J. A. (Westinghouse) to U. S. Nuclear Regulatory Commission,"Submittal of Approved Version of WCAP-16766-P-A/WCAP-16766-NP-A,'Westinghouse Next Generation Correlation (WNG-1) for Predicting Critical Heat Flux inRob Bundles with Split Vane Mixing Grids'," March 2, 2010 (ADAMS Accession No.ML100850530).

7. WCAP-9401 -P-A, "Verification Testing and Analyses of the 17x17 Optimized FuelAssembly," September 1981.

- 7- WCAP-16498-NP-A

8. WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A (Proprietary)/WCAP-14342-A &CENPD-404-NP-A, Addendum 1-A (Non-Proprietary), "Optimized ZIRLOTM,'' July 10,2006 (ADAMS Accession No. ML062080563).

Principal Contributor: Yuri Orechwa

Date: March 16, 2011

WCAP-16498-NP-A

Section B

WCAP-16498-NP-A

* Westinghouse Westinghouse Electric CompanyNuclear ServicesP.O. Box 355Pittsburgh, Pennsylvania 15230-0355USA

Direct tel: (412) 374-4643Direct fax: (412) 374-4011

e-mail: greshaja@westinghouse.comOur ref: LTR-NRC-08-15

April 3, 2008

U.S. Nuclear Regulatory CommissionDocument Control DeskWashington, DC 20555-0001

Subject: Submittal of WCAP-16498-P/WCAP-16498-NP, "17x17 Next Generation Fuel (17x17 NGF)Reference Core Report," (Proprietary/Non-proprietary)

Enclosed are Proprietary and Non-Proprietary copies of WCAP-16498-P/WCAP-16498-NP, "17x17 Next GenerationFuel (I 7x1 7 NGF) Reference Core Report," submitted to the NRC for review and approval. It is requested that theabove topicals be approved by April 2009. It is also requested that the NRC provide an estimate on the man-powerresources required for the review and a tentative date for the acceptance meeting. Based on Westinghouse's discussionwith the NRC Staff at our recent Fuel Performance Update meeting, this topical would be classified as "easy".

Also enclosed is:

1. One (1) copy of the Application for Withholding, AW-08-2406 (Non-proprietary) with ProprietaryInformation Notice.

2. One (1) copy of Affidavit (Non-proprietary).

This submittal contains proprietary information of Westinghouse Electric Company, LLC. In conformance with therequirements of 10 CFR Section 2.390, as amended, of the Commission's regulations, we are enclosing with thissubmittal an Application for Withholding from Public Disclosure and an affidavit. The affidavit sets forth the basis onwhich the information identified as proprietary may be withheld from public disclosure by the Commission.

Correspondence with respect to the affidavit or Application for Withholding should reference AW-08-2406 andshould be addressed to J. A. Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse ElectricCompany LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.

Very truly yours,

A4. A. Gresham, ManagerRegulatory Compliance and Plant Licensing

Enclosurescc: A. Mendiola, NRR

J. Thompson, NRR

WCAP-16498-NP-A

* Westinghouse Westinghouse Electric CompanyNuclear ServicesP.O. Box 355Pittsburgh, Pennsylvania 15230-0355USA

U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555

Direct tel:Direct fax:

e-mail:Our ref:

412/374-4643412/374-4011greshaja@westinghouse.comAW-08-2406April 3, 2008

APPLICATION FOR WITHHOLDING PROPRIETARYINFORMATION FROM PUBLIC DISCLOSURE

Subject: Submittal of WCAP-16498-P/WCAP-16498-NP, "17x17 Next Generation Fuel (17x17 NGF) ReferenceCore Report," (Proprietary)

Reference: Letter from J. A. Gresham to Document Control Desk, LTR-NRC-08-15, dated April 3, 2008

The application for withholding is submitted by Westinghouse Electric Company LLC (Westinghouse) pursuant to theprovisions of paragraph (b)(l) of Section 2.390 of the Commission's regulations. It contains commercial strategicinformation proprietary to Westinghouse and customarily held in confidence.

The proprietary material for which withholding is being requested is identified in the proprietary version of the subjectreport. In conformance with 10 CFR Section 2.390, Affidavit AW-08-2406 accompanies this application for withholding,setting forth the basis on which the identified proprietary information may be withheld from public disclosure.

Accordingly, it is respectfully requested that the subject information which is proprietary to Westinghouse be withheldfrom public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.

Correspondence with respect to this application for withholding or the accompanying affidavit should reference AW-08-2406 and should be addressed to J. A. Gresham, Manager of Regulatory Compliance and Plant Licensing, Westinghouse

Electric Company LLC, P. 0. Box 355, Pittsburgh, Pennsylvania 15230-0355.

Very truly yo, rs,

1J. A. Gresham, ManagerRegulatory Compliance and Plant Licensing

Cc: A. Mendiola, NRRJ. Thompson, NRR

WCAP-16498-NP-A

AW-08-2406

AFFIDAVIT

COMMONWEALTH OF PENNSYLVANIA:

ss

COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally appeared J. A. Gresham, who, being by me duly sworn according

to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC

(Westinghouse) and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge,

information, and belief:

;/J. A. Gresham, Manager

Regulatory Compliance and Plant Licensing

Sworn to and subscribed

before me this day

of ,2008.

Notary Public

COMMONWEALTH OF PENNSYLVANIANotarial Seal

Sharon L. Madde. Notary PublicMonroeville Boro, Allegheny County

MY Commission Expires Jan. 29,2011Member, Pennsylvania Association of Notaries

WCAP-16498-NP-A

-2- AW-08-2406

(1) 1 am Manager, Regulatory Compliance and Plant Licensing, in Nuclear Services, 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 rulemaking proceedings, and am authorized to apply for its withholding on behalf of

Westinghouse.

(2) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Commission's

regulations and in conjunction with the Westinghouse "Application for Withholding" accompanying this

Affidavit.

(3) 1 have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information

as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following

is furnished for consideration by the Commission in determining whether the information sought to be

withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in

confidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily

disclosed to the public. Westinghouse has a rational basis for determining the types of information

customarily held in confidence by it and, in that connection, utilizes a system to determine when and

whether to hold certain types of information in confidence. The application of that system and the

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

Under that system, information is held in confidence if it falls in one or more of several types, the

release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure,

tool, method, etc.) where prevention of its use by any of Westinghouse's competitors

without license from Westinghouse constitutes a competitive economic advantage over

other companies.

(b) It consists of supporting data, including test data, relative to a process (or component,

structure, tool, method, etc.), the application of which data secures a competitive

economic advantage., e.g., by optimization or improved marketability.

(c) Its use by a competitor would reduce his expenditure of resources or improve his

competitive position in the design, manufacture, shipment, installation, assurance of

quality, or licensing a similar product.

WCAP-16498-NP-A

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(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.

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 which 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 byreducing 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 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.

(iii) 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.

(iv) 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.

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(v) The proprietary information sought to be withheld in this submittal is that which is appropriately

marked "Submittal of WCAP- 16498-P/WCAP- 16498-NP, "1 7x 17 Next Generation Fuel (I 7x 17

NGF) Reference Core Report," (Proprietary), for submittal to the Commission, being transmitted

by Westinghouse letter (LTR-NRC-08-15) and Application for Withholding Proprietary Information

from Public Disclosure, to the Document Control Desk. The proprietary information as submitted by

Westinghouse Electric Company is for NRC review and approval.

This information is part of that which will enable Westinghouse to:

(a) Obtain generic NRC licensed approval for the Westinghouse 17xl7 Next Generation

Fuel (17xl 7 NGF) design.

(b) Assist customers in improving their fuel performance (zero defects).

Further this information has substantial commercial value as follows:

(a) Westinghouse can use this Reference Core Report to further enhance their licensing

position over their competitors.

(b) Assist customers to obtain license changes.

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 justifications and licensing defense services for commercial power reactors

without commensurate expenses. Also, public disclosure of the information would enable others to

use the information to meet NRC requirements for licensing documentation without purchasing the

right to use the information.

The development of the technology described in part by the information is the result of applying the

results of many years of experience in an intensive Westinghouse effort and the expenditure of a

considerable sum of money.

In order for competitors of Westinghouse to duplicate this information, similar technical programs

would have to be performed and a significant manpower effort, having the requisite talent and

experience, would have to be expended for developing the enclosed improved core thermal

performance methodology.

Further the deponent sayeth not.