L-PI-08-096, Response to Request for Additional Information Regarding License Amendment Request for Technical Specifications Changes to Allow Use of Westinghouse. 0.422- Inch OD 14x14 Vantage + Fuel

Response to Request for Additional Information Regarding License Amendment Request for Technical Specifications Changes to Allow Use of Westinghouse. 0.422- Inch OD 14x14 Vantage + Fuel

ML083190820
Person / Time
Site:	Prairie Island
Issue date:	11/14/2008
From:	Wadley M Northern States Power Co, Xcel Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML083190818	List: L-PI-08-096, Response to Request for Additional Information Regarding License Amendment Request for Technical Specifications Changes to Allow Use of Westinghouse. 0.422- Inch OD 14x14 Vantage + Fuel
References
CAW-08-2496, L-PI-08-096, NSP-08-73, TAC MD9142, TAC MD9143
Download: ML083190820 (19)

Text

WITHHOLD FROM PUBLIC DISCLOSURE PER 10 CFR 2.390 Prairie lsland Nuclear Generating Plant 1717 Wakonade Drive East Welch. MN 55089 L-PI-08-096 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Prairie lsland Nuclear Generating Plant, Units 1 and 2 Docket Nos. 50-282 and 50-306 License Nos. DPR-42 and DPR-60 Response To Request For Additional lnformation Regardinq License Amendment Request For Technical Specifications Changes To Allow Use Of Westinghouse 0.422-Inch OD 14x14 Vantage+ Fuel (TAC Nos. MD9142 and MD9143)

References:

1) Letter from M. Wadley (NMC) to Document Control Desk (NRC),

L-PI-08-047, "License Amendment Request for Technical Specifications Changes to Allow Use of Westinghouse 0.422-inch OD 14x14 VANTAGE+ Fuel," dated June 26,2008 (ML081820137)

2) Letter from T. Wengert (NRC) to M. Wadley (NSPM), Prairie lsland Nuclear Generating Plant, Units 1 and 2 Request For Additional lnformation Related to License Amendment Request For Technical Specifications Changes to Allow Use of Westinghouse 0.422-Inch OD 14x14 Vantage+ Fuel (TAC Nos. MD9142 and MD9143), dated October 17,2008 (ML082810645)

By letter dated June 26,2008 (Reference I), Nuclear Management Company, LLC, (now Northern States Power, a Minnesota corporation (NSPM)) requested approval of amendments to the Operating Licenses and associated Technical Specifications (TS) for Prairie lsland Nuclear Generating Plant (PINGP), Units 1 and 2, as well as certain supporting analyses, in support of the transition from Westinghouse 0.400-inch outer diameter (OD) VANTAGE+ (hereinafter referred to as 400V+) fuel to 0.422-inch OD VANTAGE+ (hereafter referred to as 422V+) fuel.

On October 17, 2008, the NRC staff notified NSPM (ML082810645) that additional information was necessary for the staff to complete its review. NSPM's response includes information which is held proprietary by Westinghouse Electric Company, LLC (Westinghouse), as supported by an affidavit signed by Westinghouse, the owner of the information (Enclosure 2).

L When separated from Enclosure 3, this letter may be made publicly available.

Document Control Desk Page 2 Accordingly, it is requested that the information which is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR 2.390. Enclosure 1 provides a non-proprietary version of the responses while Enclosure 3 provides the proprietary response to be withheld.

The supplemental information provided in this letter does not impact the conclusions of the Determination of No Significant Hazards Consideration and Environmental Assessment presented in the June 26, 2008 submittal.

In accordance with 10 CFR 50.91, NSPM is notifying the State of Minnesota of this License Amendment Request supplement by transmitting a copy of this letter and non-proprietary enclosures to the designated State Official.

Summary of Commitments This letter makes no new commitments and no revisions to existing commitments.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on:

Michael D. Wadley Site Vice-President u

Prairie Island Nuclear Generating Plant Northern States Power Company-Minnesota Enclosures (3) cc: Administrator, Region Ill, USNRC Project Manager, Prairie Island, USNRC Resident Inspector, Prairie Island, USNRC State of Minnesota (wlo Enclosures 2 and 3)

ENCLOSURE 1 Non-Proprietary Responses to Requests for Additional Information License Amendment Request for Technical Specifications Changes to Allow Use of Westinghouse 422V+ Fuel By letter dated June 26,2008 (ML081820137), Nuclear Management Company, LLC, (now Northern States Power, a Minnesota corporation (NSPM)) requested approval of amendments to the Operating Licenses and associated Technical Specifications (TS) for Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2, as well as certain supporting analyses, in support of the transition from Westinghouse 0.400-inch outer diameter (OD) VANTAGE+ (hereinafter referred to as 400V+) fuel to 0.422-inch OD VANTAGE+ (hereafter referred to as 422V+)

fuel. On October 17, 2008 (ML082810645), the NRC staff notified NSPM that additional information was necessary for the staff to complete its review. NRC requests for additional information (RAI) are repeated below with the NMC response following each M I :

1. Page 1-7, Table 1-1 of the PINGP 422V+ Reload Licensing Report states, "The power uncertainty was reduced to account for installation of a more accurate flow measurement system used in the power measurement. The [Revised Thermal Design Procedure (RTDP)] analyses completed within this report were thus completed at a bounding high power level to confirm acceptable operation at any power level, including measurement uncertainties of 0.5 percent or more, up to 1,683 [megawatts thermal (MWt)]." Please justify the uncertainty reduction:

NSPM Response:

The referenced statement in Table 1-1 was intended to clarify that the analyses completed using WCAP-11397-P-A, Reactor Thermal ~ e s i Procedure

~n (RTDP) bound operation at the existing licensed power level of 1650 MWt and a power uncertainty of 2%. However, the RTDP analyses were completed assuming a power of 1677 MWt and a power uncertainty of 0.5%. This assumed power uncertainty of 0.5% bounds the anticipated power uncertainty for the proposed measurement uncertainty recapture (MUR) uprate Leading Edge Flowmeter as described in the following paragraph. While the MUR uprate is not part of this License Amendment Request, the combination of assumed power and uncertainty in the RTDP analyses bound operation at the present licensed power level as discussed further in the response to question #2.

The methodology used to calculate the Caldon LEFM Checkplus System uncertainties is consistent with ASME Pressure Test Code (PTC) 19.1 and ISA 67.04.02 as described in Caldon Topical Reports ER-80P and 157P as referenced in the response to question Ib. This methodology is also consistent with the Prairie Island setpoint methodology that was used to determine calorimetric power calculation error with the existing equipment. The overall thermal power calorimetric uncertainty calculated for both units using the LEFM system is 0.36% which is less than the analyzed value of 0.5%.

Page 1 of 9

ENCLOSURE 1 Non-Proprietary Responses to Requests for Additional Information License Amendment Request for Technical Specifications Changes to Allow Use of Westinghouse 422V+ Fuel As requested, additional information on the proposed MUR flow measurement system follows:

a. Explain what flow measurement system was installed.

NSPM Response:

A A Cameron formally Caldon) Leading Edge Flow Meter (LEFM) checkplusT System is being installed in PINGP Units 1 and 2. There is an individual LEFM metering spool piece on each unit's two feedwater lines whose output signals feed into a separate CPU Electronics Cabinet for each unit.

b. Provide reference to applicable supporting documentation, such as topical reports describing the flow measurement system.

NSPM Response:

The referenced topical reports applicable to the proposed MUR flow measurement equipment are as follows:

1. Caldon Inc. Engineering Report-(ER) 80P, "Improving Thermal Power Accuracy and Plant Safety While Increasing Operating Power Level Using the LEFM?~System," Revision 0, March 1997.

The NRC approved Caldon Topical Report 80P Rev 0 by NRC safety evaluation (SE) dated March 8, 1999 (ADAMS Accession No. 9903190065 (legacy library)).

2. Caldon Inc. Engineering Report-157P, "Supplement to Topical Report ER-BOP: Basis for a Power Uprate with the L E F M ? ~Check or checkplusTMSystem," Revision 0, October 2001. The NRC approved Caldon Topical Report 157P Rev 5 by NRC SE dated December 20,2001 (ML013540256).

3. In addition, the NRC staff completed a re-evaluation of the Caldon LEFM ultrasonic flow meters (UFMs) as part of the generic assessment of the hydraulic aspects of UFM application to increase licensed thermal power and issued NRC SE "Evaluation of The Hydraulic Aspects of the Caldon Leading Edge Flow Measurement (LEFM) Check and checkplusTMUltrasonic Flow Meters Caldon, Inc. (ML061700222). As described in that SE the NRC found that the Caldon Check and Checkplus UFMs' performance is consistent with the Caldon TRs ER-80P, Revision 0, and ER-157P, Revision 5, previously approved by the NRC staff.

Page 2 of 9

ENCLOSURE 1 Non-Proprietary Responses to Requests for Additional Information License Amendment Request for Technical Specifications Changes to Allow Use of Westinghouse 422V+ Fuel

c. Briefly describe the flow measurement system installation and calibration process.

NSPM Response:

The Unit 1 and Unit 2 LEFM Checkplus Systems are each comprised of two metering section spool pieces and an Electronics Unit Cabinet. The Unit 1 spool pieces are being installed in the Loop A and B feedwater lines downstream of the existing feedwater flow venturis. The Unit 2 spool pieces are being installed in the Loop A and B feedwater lines upstream of the existing feedwater flow venturis. The Unit 1 LEFM Electronics Unit Cabinet is being installed in the Train A Event Monitoring Room and the Unit 2 LEFM Electronics Unit Cabinet is being installed in the Train B Event Monitoring Room. The Train A and B Event Monitoring Rooms are temperature controlled, mild environment locations.

Calibration of the Unit 1 and Unit 2 LEFM spool pieces was performed by Cameron at Alden Labs in their unit specific piping configuration to determine the individual meter factor and individual path normalized velocities. During final commissioning following installation and startup, the actual in-plant data is determined to be consistent with the data obtained at Alden Labs and that the individual system components are operating as designed within pre-established limits. This ensures that as-installed measurement uncertainties are within the bounding values used in the analysis. During operation, internal monitoring and checking systems generate alarms in the event system parameters exceed pre-established limits.

2. The information contained in Table 1-1, discussed in RAI Iabove, appears slightly inconsistent with the information contained i n Table 4-1, on Page 4-8, of the licensing report, which states, "A power level of 1,677 MWt has been used for all RTDP thermal-hydraulic design analyses. For analyses explicitly modeling parameter uncertainties, a power level of 1,683 MWt was used." Please provide additional information about the analytic incorporation of power uncertainty to bring these two statements into clearer alignment.

NSPM Response:

With the RTDP methodology (WCAP-11397-P-A), uncertainties in plant operating parameters, nuclear and thermal parameters, fuel fabrication parameters, computer codes, and departure from nucleate boiling (DNB) correlation predictions are considered statistically to obtain the overall DNB uncertainty factor. The DNB correlation limit is then increased by the total uncertainty factor and the nominal values of the parameters are input to the departure from nucleate boiling ratio (DNBR) calculations.

Page 3 of 9

ENCLOSURE 1 Non-Proprietary Responses to Requests for Additional Information License Amendment Request for Technical Specifications Changes to Allow Use of Westinghouse 422V+ Fuel With the Standard Thermal Design Procedure (STDP), the DNBR calculations are performed by incorporating the parameter uncertainties directly into the DNBR calculation. STDP is used in the DNB analysis of accidents initiated at the hot zero power condition where the power measurement uncertainty is not applicable.

The fuel transition DNBR calculations were performed at a nominal power level of 1677 MWt with a power uncertainty of 0.5% for RTDP analyses and at 1683 MWt for STDP analyses. The analysis at these conditions bounds operation at the current licensed power level of 1650 MWt with a 2.0% power uncertainty.

Page 4-4 of the licensing report states "There is a maximum 9.0-percent transition core [departure from nucleate boiling ratio (DNBR)] penalty for the 400V+ fuel which will be offset by a 6.0-percent [FdH] reduction i n burned 400V+ fuel based on a conservative 1.5-percent DNBR: I-percent [FdH] sensitivity." This treatment of DNBR margin trade-off is presented as axiomatic; however, the NRC staff is unfamiliar with this sensitivity. Please provide a basis for this statement.

a. Reference an appropriate licensing topical report where this sensitivity is described.

NSPM Response:

This DNBR sensitivity is discussed in WCAP-11397-P-A where a sample value is provided. Plant specific DNBR sensitivity calculations were performed as part of the RTDP analysis for the fuel transition and a conservatively bounding sensitivity was used for determining the peaking factor restriction in a mixed core.

b. If the sensitivity is not discussed i n a licensing topical report, please provide a phenomenological discussion of the peaking behavior of previously irradiated fuel and explain how the changes i n peaking behavior result in increased DNBR margin.

NSPM Response:

The peaking factor restriction is on the burned 400V+ fuel. At increasing burnups (second and third resident cycle in the core), the build-up of fission products and the depletion of fissile material results in the burned fuel assemblies no longer being able to maintain a high peaking factor.

The peaking factor reduction in the burned 400V+ fuel necessary to offset the transition core DNBR penalty on the 400V+ fuel is conservatively Page 4 of 9

ENCLOSURE 1 Non-Proprietary Responses to Requests for Additional Information License Amendment Request for Technical Specifications Changes to Allow Use of Westinghouse 422V+ Fuel calculated using the stated sensitivity factor and is then confirmed during the reload core design for each transition cycle.

c. Presumably, the steady-state peaking effects of previously irradiated fuel that result in a DNBR margin increase are propagated through DNBR transient analyses. Is the margin increase observed above based on a steady-state or transient power shape?

NSPM Response:

The peaking factor of the previously irradiated fuel discussed above is based on steady state neutronics calculations, consistent with the calculation of the peaking factor for the core as the initial conditions for the DNBR transient analyses. The initial conditions are selected using a conservative combination of axial and radial peaking factors that bound any change in the core power distribution anticipated to occur during the transients. Accident specific evaluations for the hot zero power accidents were also performed to confirm that sufficient DNBR margin exists to offset the transition core penalty.

4. Table 4-3 on Page 4-10 of the licensing report lists a 15 psi increase in RTDP pressure uncertainty; however, the NRC staff was unable to locate a discussion of this increase i n the licensing report. Please explain.

NSPM Response:

Table 4-3 lists the uncertainties assumed in the RTDP based DNBR analyses. These uncertainties are used to determine the DNBR limit as described in WCAP 11397-P-A, "Revised Thermal Design Procedure" (RTDP), as delineated in Prairie Island Technical Specifications Section 5.6.5 reference 15. The 15 psi increase in assumed pressurizer pressure uncertainty was initiated to align the analyzed pressurizer pressure uncertainty with other more recent existing analyses (such as the recent LBLOCA ASTRUM analyses documented in Accession # ML061880026 where +I- 60 psi was utilized). There were no physical changes associated with this analysis input assumption change. Increasing the assumed pressurizer uncertainty for RTDP based analyses will effectively result in a lower analyzed initial RCS pressure via a higher DNBR limit which is a conservative analysis assumption for DNB analyses. Since an increase in pressurizer pressure uncertainty (without any changes to actual plant configuration) is a penalty in DNBR analyses, this is considered a conservative RTDP analysis input assumption.

Page 5 of 9

ENCLOSURE I Non-Proprietary Responses to Requests for Additional Information License Amendment Request for Technical Specifications Changes to Allow Use of Westinghouse 422V+ Fuel

5. Section 5.1 of the licensing report discusses the Rod Withdrawal Accident from a Subcritical Condition. An isothermal temperature coefficient of +5 pcml°F is assumed, and the accident initiates at 547°F. As a part of the justification for these assumptions, the licensing report states, "...after the initial neutron flux peak, the isothermal temperature coefficient can affect the succeeding rate of power increase." Regarding the selection of parameters affecting heat transfer, the analysis is designed so that it "yields a larger peak heat flux."

a. Confirm whether the assumed isothermal temperature coefficient is bounding of that at lower assumed temperatures.

NSPM Response:

The analysis of the Rod Withdrawal from a Subcritical Condition event, as described in Section 5.1 . I , bounds the same event at lower temperatures.

[ ] The contribution of moderator temperature to isothermal temperature coefficient (ITC) is negligible during the initial part of the transient because the heat transfer time constant between the fuel and moderator is much longer than the neutron flux response time constant.

The assumed most positive initial ITC value of +5 pcmI0Fis consistent with the maximum allowable ITC specified in Technical Specifications LC0 3.1.3.a.

It should also be noted that there is significant margin to the appropriate limit values for the Section 5.1 .Ianalysis. The minimum DNBR calculated is [ ] a'C The peak fuel centerline temperature calculated is [ ] a'C

b. Explain how the effect of selecting input conditions to maximize heat flux results in a conservative hot rod fuel temperature, or how other input assumptions correct or compensate for the maximized heat flux.

NSPM Response:

For the Rod Withdrawal from a Subcritical Condition analysis, [ ]

6. The introduction of larger fuel assemblies will reduce the volume of water in the core. Thus, a chemical and volume control system malfunction could dilute the core more rapidly. Confirm that the assumed reactivity insertion rate associated with a boron dilution is bounding for the 422V+ core, which will have a reduced volume.

NSPM Response:

The change in the volume due to the larger fuel rods is extremely small cornparedto the total volume of the system. [ ] "lC This change in the Page 6 of 9

ENCLOSURE I Non-Proprietary Responses to Requests for Additional Information License Amendment Request for Technical Specifications Changes to Allow Use of Westinghouse 422V+ Fuel volume results in essentially no change in the reactivity insertion rate used in the analysis.

7. The reactor coolant pump locked rotorlshaft break analysis presents hot spot cladding inner temperature as a function of time. This result is attained based on standard Westinghouse analytic assumptions used to maximize fuel energy delivery to the cladding.

a. Why is fuel centerline temperature not an acceptance criterion for this postulated accident scenario?

b. How is the fuel centerline temperature affected by the assumptions discussed above?

c. What is the predicted peak fuel centerline temperature for this accident?

NSPM Response:

High fuel centerline temperatures [ ] a'C The fuel cladding temperature increase for the Locked Rotor event is primarily due to [ ] To maximize the fuel centerline temperature, [ ]

8. Page 5-72 of the licensing report discusses the triviality of differences arising from postulating a LOCA in a transition core as opposed to the analyzed equilibrium 422V+ core. It is stated, "Even for larger [small-break loss-of-coolant accidents (SBLOCAs)], the thermal-hydraulic response is quasi-one dimensional..." This statement is offered to assess the significance of the potential for flow redistribution between the 400V+ and the 422V+ fuel assemblies. Presumably, the quasi-one dimensionality of transition cores has been assessed. Please provide a summary of this assessment to help substantiate the quasi-one dimensionality claim.

NSPM Response:

Small break LOCA transients are characterized by gradual top-down draining of the reactor coolant system with low flow rates in the core relative to those occurring at steady-state or for large break LOCA transients. Additionally, hydraulic losses in the core due to frictional drag, form loss, and acceleration are small and reasonable variations in flow resistance are expected to have negligible effect on small break LOCA transient results. For these reasons, it is reasonable to conclude that the thermal-hydraulic response will be quasi-one dimensional and multiple core channels are not required to accurately reflect SBLOCA transient characteristics. Note that per the safety evaluation report for Reference 1, Page 7 of 9

ENCLOSURE 1 Non-Proprietary Responses to Requests for Additional Information License Amendment Request for Technical Specifications Changes to Allow Use of Westinghouse 422V+ Fuel the single core flow channel of the 1985 Westinghouse Small Break LOCA Evaluation Model (NOTRUMP-EM) was deemed acceptable and judged to meet the requirements of 10 CFR 50 Appendix K because cross-flow is not important for small break LOCAs.

Moreover, in the event that that cross-flow occurs during a small break LOCA, the fuel assembly loss coefficient is smaller for the 422V+ fuel assemblies and therefore, flow would be favored towards these fuel assemblies. As discussed in Section 3 of the Reload Transition Licensing Report (Enclosure 1, Attachment 4 of Reference 2), the 400V+ fuel assemblies used in the representative transition cores have been burned for at least one fuel cycle and operate at lower power and with lower local peaking factors; any minor penalizing effect of reduced flow to the 400V+

fuel assemblies would be more than offset by the reduced peaking factors.

References:

1) WCAP-10054-P-A, "Westinghouse Small Break ECCS Evaluation Model Using the NOTRUMP Code," August 1985.

2) ADAMS Accession Number ML081820137, "Prairie Island, Units 1 and 2 - License Amendment Request for Technical Specification Changes to Allow Use of Westinghouse 0.422-inch OD 14x14 VANTAGE+ Fuel, June 26,2008.

9. In consideration of the Westinghouse position on loop seal plugging, the licensing report discusses the effects that gaps between the core barrel upper plenum nozzles and the vessel may have on the effectiveness of vapor relief. Please provide an assessment of this statement in terms of the figures of merit discussed in the 1997 report, NSD-NRC-97-5092, "Core Uncovery Due to Loop Seal Re-Plugging During Post-LOCA Recovery." Particularly, consider some of the stable or unstable core uncovery envelopes, and evaluate the effects of a change in KIA* would have on the core uncovery envelopes.

NSPM Response:

The effects of changes in vessel bypass resistance (i.e. WA*) were specifically considered as part of the referenced report (NSD-NRC 5092). Figures 5 and 6 therein display the effect of variations of vessel bypass resistance for several classes of plants under single phase conditions. Those being:

Upper head temperature at approximately the hot leg temperature (i.e. That plants),

Upper head temperature at approximately the cold leg temperature (i.e. Tcoldplants)

Page 8 of 9

ENCLOSURE 1 Non-Proprietary Responses to Requests for Additional Information License Amendment Request for Technical Specifications Changes to Allow Use of Westinghouse 422V+ Fuel Upper head temperature for Upper Head Injection configuration plants (i.e. UHI plants).

These represent a rather broad range of possible vessel bypass resistance conditions. Under two-phase conditions, the effect of variations in bypass resistances can be observed in Figures 11A through 12B respectively for the reference plant as discussed in Section 5.2 of the reference report. As can be seen, increasing the vessel bypass resistance reduces the stable uncovery window. For the reference plant of the report, with a single train of safety injection (SI), a vessel bypass resistance of approximately I 0 0 W~ would prevent stable uncovery whereas with two trains of SI, a vessel bypass resistance of approximately 25 ff4 would accomplish this. For the Prairie Island Units, the vessel resistances range from approximately [ la-' for the vessel spray nozzles only to approximately [ IaqCfor the combined spray nozzle and vessel baffle nozzle bypass flow paths.

Page 9 of 9

ENCLOSURE 2 AFFIDAVIT REQUEST TO WITHHOLD PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE 7 pages follow

Westinghouse ElectricCompany Nuclear Services P.O. Box 35 5 Pittsburgh, Pennsylvania 15230-0355 USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (412) 374-3846 Washington, DC 20555-0001 e-mail: greshaja@westinghouse.com Proj letter ref NSp-08-73 Our ref: CAW-08-2496 November 05,2008 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

"Prairie Island 422V+ Fuel Transition Program RAI Responses," (Proprietary)

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-08-2496 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 (bX4) of 10 CFR Section 2.390 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Xcel Energy.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse &davit should reference this letter, CAW-08-2496 and should be addressed to J. A.

Gresham, Manager, Regulatoly Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, Pennsylvania 15230-0355.

very truly YOpys, YJ.A.- res sham, Manager Regulatory Compliance and Plant Licensing cc: G. Bacuta (NRC OWFN 12E-1)

Enclosures

AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

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 M d a v i t 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:

41.A. Gresham, Manager Regulatory Compliance and Plant Licensing Sworn to and subscribed before me this 5' day of November, 2008 Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sharon L Madde, Notary Public MonroevilleBoro,Allegheny County My Commission W r e s Jan. 29,2011

(1) I am Manager, Regulatory Compliance and Plant Licensing, in Nuclear Services, Westinghouse Electric Company LLC (Westinghouse), and as such, 1have 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" accompanying this Affidavit.

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

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

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

(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence.

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

Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of Westinghouse's

competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

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

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer finded 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 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 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.

(0 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.

(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in "Prairie Island 422V+ Fuel Transition Program RAI Responses,"

(Proprietary) for submittal to the Commission, being transmitted by Xcel Energy 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 Xcel Energy's responses to the NRC's Request for Additional Information (re: Prairie Island Units 1 and 2 transition to the Westinghouse 0.422-Inch OD 14x14 VANTAGE+ Fuel).

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

(a) Obtain NRC approval of Westinghouse 0.422-Inch OD 14x14 VANTAGE+ Fuel for Prairie Island Units 1 and 2.

(b) Respond to NRC Request for Additional Information in support of the transition to Westinghouse 0.422-Inch OD 14x14 VANTAGE+ Fuel for Prairie Island Units 1 and 2.

Further this information has substantial commercial value as follows:

(a) Westinghouse plans to sell the use of this information to its customers for purposes of enhancing fuel performance.

(b) The information requested to be withheld reveals the distinguishing aspects of a fuel design 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 calculations and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.

In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.

Further the deponent sayeth not.

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

In order to conform to the requirements of 10 CFR 2.390 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(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.