ML16321A002

Response to RAI, Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis - Revised Technical Specifications and Bases and WCAP-18030, Revision 1

ML16321A002
Person / Time
Site:	Palo Verde
Issue date:	11/09/2016
From:	Lacal M Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML16321A001	List: ML16321A002 ML16321A003
References
102-07360-MLL/MDD, WCAP-18030, Rev 1
Download: ML16321A002 (35)

Text

{{#Wiki_filter:,. Attachment 6 of the Enclosure contains PROPRIETARY information to be withheld under 10 CFR 2.390 10 CFR 50.90 t)aps Maria L. Lacal Senior Vice President, Nuclear Regulatory & Oversight Palo Verde Nuclear Generating Station 102-07360-MLL/MDD P.O. Box 52034 November 9, 2016 Phoenix, AZ 85072 Mail Station 7605 Tel 623.393.6491 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk

*Washington, DC 20555-0001

References:

1. Arizona Public Service Company (APS) letter number 102-07149, License Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis, dated November 25, 2015, [Agencywide Documents Access and Management System (ADAMS) Accession Number ML15336A251]

2. NRC document Palo Verde 1, 2, and 3 - Official RAis from SNPB for LAR that Requested Revision of TSs to Incorporate Updated Criticality Safety Analysis, dated July 14, 2016 (ADAMS Accession Number ML16197A006)

3. APS letter number 102-07342, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis, dated October 6, 2016 (ADAMS Accession Number ML16286A240)

Subject:

Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2, and 3 Docket Nos. STN 50-528, 50-529, and 50-530 Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis - Revised Technical Specifications and Bases and WCAP-18030, Revision 1 In Reference 1, Arizona Public Service Company (APS) submitted a license amendment request (LAR) to revise the PVNGS Technical Specifications (TS) for Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2, and 3. The proposed amendment would modify TS requirements to incorporate the results of an updated criticality safety analysis for both new and spent fuel storage. In Reference 2, the NRC staff requested additional information to support the review of the LAR. The APS response to the NRC staff request for additional information (RAI) was provided in Reference 3, which indicated that the affected TS and TS

*Bases pages, as well as the necessary revision to WCAP-18030, Criticality Safety Analysis for Palo Verde Nuclear Generating Station Units 1, 2, and 3, would be submitted separately.

The enclosure to this letter includes the TS pages (Attachments 1 and 2) and TS Bases markup pages (Attachment 3) and the non-proprietary and proprietary versions of the revised WCAP-18030 (Attachments 5 and 6, respectively). Attachment 4 of the enclosure is the Westinghouse affidavit signed by Westinghouse Electric Company LLC that sets forth the basis on which the proprietary information in Attachment 6 "D l A member of the STARS (Strategic Teaming and Resource Sharing) Alliance ~V

                     .      Callaway

• Diablo Canyon
• Palo Verde
• Wolf Creek . ~( ~ ~

Attachment 6 transmitted herewith contains PROPRIETARY information. fV When separated from Attachment 6, this transmittal document is decontrolled.

102-07 360-M LL/MDD ATIN: Document Control Desk U. S. Nuclear Regulatory Commission Response to RAI Regarding LAR to Revise TS to Incorporate Updated Criticality Safety Analysis - Revised Technical Specifications and Bases and WCAP-18030, Revision 1 Page 2 of the enclosure may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in 10 CFR 2.390(b)(4). Correspondence with respect to the proprietary aspects of Attachment 6 of the enclosure or the supporting Westinghouse affidavit should reference Westinghouse letter number CAW-16-4498 and be addressed to.James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 3 Suite 310, Cranberry Township, Pennsylvania 16066. The APS response does not affect the conclusion of the no significant hazards consideration determination [10 CFR 50.91(a)] provided in the original LAR, as supplemented by APS letter 102-07181, dated January 29, 2016 (ADAMS Accession Number ML16043A361). This submittal does not contain new regulatory commitments as defined by NEI 99-04, Guidelines for Managing NRC Commitment Changes, Revision 0. The original target date for this response was extended to November 11, 2016, based upon communications with the PVNGS NRC Project Manager; Mr. Siva Lingam, on September 7, 2016. The rieed to extend the date for the response was due to an emergent Westinghouse issue that irrypacted available resources. In accordance with the PVNGS Quality Assurance Program, the Plant Review Board and the Offsite Safety Review Committee have reviewed and concurred with the LAR changes proposed herein. By copy of this letter, this submittal is being forwarded to the Arizona Radiation Regulatory Agency (ARRA) pursuant to 10 CFR 50.91(b)(1). Should you have any 'questions concerning the content of this letter, please contact Michael D. Dilorenzo, Licensing Section Leader, at (623) 393-3495. I declare under penalty of perjury that the foregoing is true and correct. Executed on: November 9. 2016 (Date) Sincerely, MLL/MDD/CJS/af

Enclosure:

Response to Request for Additional Information (RAI) Regarding License Amendment Request (LAR) to Revise Technical Specifications (TS) to Incorporate Updated Criticality Safety Analysis - Nuclear Performance and Code Review Branch (SNPB) - Revised Technical Specifications and Bases and WCAP-18030, Revision 1 cc: K. M. Kennedy NRC Region IV Regional Administrator S. P. Lingam NRC NRR Project Manager for PVNGS M. M. Watford NRC NRR Project Manager

c. A. Peabody NRC Senior Resident Inspector for PVNGS T. Morales Arizona Radiation Regulatory Agency (ARRA)

Enclosure Response to Request for Additional Information {RAI) Regarding License Amendment Request {LAR) to Revise Technical Specifications {TS) to Incorporate Updated Criticality Safety Analysis- Nuclear Performance and Code Review Branch {SNPB) Revised Technical Specifications and Bases and WCAP-18030, Revision 1

Enclosure Response to RAI Regarding LAR to Revise TS to Incorporate Updated Criticality Safety Analysis- Nuclear Performance and Code Review Branch (SNPB) Revised Technical Specifications and Bases and WCAP-18030, Revision 1 Ta hie of Contents Enclosure - Response to Request for Additional Information (RAI) Regarding License Amendment Request (LAR) to Revise Technical Specifications (TS) to Incorporate Updated Criticality Safety Analysis- Nuclear Performance and Code Review Branch (SNPB) - Revised Technical Specifications and Bases and WCAP-18030, Revision 1 Attachment 1 - Technical Specifications Markup Pages Attachment 2 - Technical Specifications Clean Pages Attachment 3 - Technical Specifications Bases Markup Pages Attachment 4 - Westinghouse Application for Withholding Proprietary Information from Public Disclosure, CAW-16-4498, October 27, 2016 Attachment 5 - Westinghouse Electric Company - WCAP-18030-NP, Revision 1, Criticality Safety Analysis for Palo Verde Nuclear Generating Station Units 1, 2, and 3 (Non-proprietary), dated October 2016

• Attachment 6 - Westinghouse Electric Company - WCAP-18030-P, Revision 1, Criticality Safety Analysis for Palo Verde Nuclear Generating Station Units 1, 2, and 3 (Proprietary), dated October 2016 1

Enclosure Response to RAI Regarding LAR to Revise TS to Incorporate Updated Criticality Safety Analysis- Nuclear Performance and Code Review Branch (SNPB) Revised Technical Specifications and Bases and WCAP-18030, Revision 1 Introduction -By letter dated November 25, 2015 [Agencywide Documents Access and Management System (ADAMS) Accession Number ML15336A087] (Reference 1), as supplemented by letters dated January 29 (Reference 2) and June 30, 2016 (Reference 3) (ADAMS Accession Numbers ML16043A361 and ML16182A519, respectively), Arizona Public Service Company (APS) submitted a license amendment request (LAR) to amend Facility Operating License Numbers NPF-41, NPF-51, and NPF-74, and revise the Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2, and 3, Technical Specifications (TSs). The LAR proposes to install NETCO-SNAP-IN neutron absorbing rack inserts into some spent fuel pool (SFP) storage rack cells coupled with six classifications of fuel (i.e., regions) by initial enrichment, burnup, and decay time in six storage configurations (i.e., arrays) for criticality control. Approval of the license amendment will establish the new licensing basis for how APS meets the effective neutron multiplication factor (keffective or keff) criticality control requirements. The U.S. Nuclear Regulatory Commission (NRC) Nuclear Performance and Code Review Branch (SNPB) provided an official request for additional information (RAI) by Reference 4. The APS response to each of the NRC staff information requests of Reference 4 was provided by APS letter number 102-07342, dated October 6, 2016 (Reference 5). The APS response to the NRC staff RAI (Reference 5) indicated that the affected TS and TS Bases pages, as well as the necessary revision to WCAP-18030, Criticality Safety Analysis for Palo Verde Nuclear Generating Station Units 1, 2, and 3, would be submitted separately. Attachment 1 of this enclosure provides the markup TS pages and Attachment 2 provides the clean (re-typed) TS pages. The TS Bases markup pages are provided for information as Attachment 3 of this enclosure. Attachment 4 of this enclosure is the Westinghouse affidavit signed by Westinghouse Electric Company LLC that sets forth the basis on which the proprietary information in Attachment 6 of this enclosure may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in 10 CFR2.390(b)(4). The non-proprietary and proprietary versions of WCAP-18030, Revision 1, are provided as Attachments 5 and 6 of this enclosure, respectively. Proposed Changes to the Technical Specifications The following additional specific TS changes are proposed as part ofthe updated criticality safety analysis resulting from Reference 5 and supported by Attachments 5 and 6 of this enclosure. The remaining TS changes previously submitted in the LAR dated November 25, 2015 (Reference 1), as supplemented by APS letter dated January 29, 2016 (Reference 2), are not affected and remain applicable.

*TS 3.7.17, Spent Fuel Assembly Storage

• Update Tables 3.7.17-2 through 3.7.17-5 to define the Fuel Regions
• Update Figure 3.7.17-1 to clarify Note 2 for blocking devices Need for Proposed Changes The NRC SNPB provided an RAI by Reference 4. The APS response to each of the NRC staff information requests of Reference 4 was provided by Reference 5. The Attachments to this enclosure provide the updated TS markup and clean pages and TS Bases markup pages for 2

Enclosure Response to RAI Regarding LAR to Revise TS to Incorporate Updated Criticality Safety Analysis- Nuclear Performance and Code Review Branch (SNPB) Revised Technical Specifications and Bases and WCAP-18030, Revision 1 information, as well as the revision to WCAP-18030 resulting from the RAI, as indicated in Reference 5. Specifically, the APS response to RAI-8 and RAI-12 resulted in changes to the TS pages that had been previously submitted to the NRC as part of the LAR, as supplemented by Reference 2. The response to RAI-8 specifically addresses increases in the burnup requirements for all enrichments due to issues such as grid growth, migration of volatile isotopes and criticality code bias and uncertainty. The coefficient values, therefore, are changed for TS Tables 3.7.17-2 through 3.7.17-5. In addition, Note 2 to Table 3.7.17-2 was altered to reflect the updated analysis such that it now reflects the decrease in initial enrichment from 2.55% to 2.50% uranium-235. Finally, Note 2 of Figure 3.7.17-1 has the phrase, and only water in the active fuel region, removed from the description of the cell blocking devices, consistent with the APS response to RAI-12 in Reference 5. Markups of the changes to the TS Bases for Section 3.7.15 and 3.7.17, resulting from RAI-7, are provided in Attachment 3 of this enclosure. The changes address the updated criticality analysis required minimum boron concentration for the postulated multiple mislead event. The TS required minimum boron concentration is not changing (greater than or equal to 2150 ppm), but the minimum value in the analysis is updated from 1460 ppm to 1600 ppm. No Significant Hazards Consideration The APS response does not affect the conclusion of the no significant hazards consideration determination [10 CFR 50.91(a)] provided in the original LAR (Reference 1), as supplemented by Reference 2. Conclusion APS concludes that operation of the facility in accordance with the proposed amendment, as supplemented, does not involve a significant hazards consideration and, accordingly, a finding of "no significant hazards consideration" is justified. Based on the considerations discu_ssed above and in the referenced APS supplemental responses, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or the health and safety of the public. References

1. APS letter number 102-07149, License Amendment Request to Revise Technical Spedfications to Incorporate Updated Criticality Safety Analysis, dated November 25, 2015, (ADAMS Accession Numbers ML15336A251 and ML15336A087)

2. APS letter number 102-07181, Supplemental Information Regarding License Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis, dated January 29, 2016 (ADAMS Accession Number ML16043A361)

3. APS letter number 102-07275, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis, dated June 30, 2016 (ADAMS Accession Number ML16182A519) 3

Enclosure Response to RAI Regarding LAR to Revise TS to Incorporate Updated Criticality Safety Analysis- Nuclear Performance and Code Review Branch (SNPB) Revised Technical Specifications and Bases and WCAP-18030, Revision 1

4. NRC document Palo Verde 1, 2, and 3 - Official RAis from SNPB for LAR that Requested Revision of TSs to Incorporate Updated Criticality Safety Analysis, dated July 14, 2016 (ADAMS Accession Number ML16197A006)

5. APS letter number 102-07342, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis, dated October 6, 2016 (ADAMS Accession Number ML16286A240) 4

Endosure Response to RAI Regarding LAR to Revise TS to Incorporate Updated Criticality Safety Analysis- Nuclear Performance and Code Review Branch (SNPB) Revised Technical Specifications and Bases and WCAP-18030, Revision 1 Attachment 1 Technical Specifications Markup Pages Revised inserts for Tables 3.7.17-2through 3.7.17-5 Figure 3.7.17-1

After SFP transition !Insert Revised Table 3.7.17-2 here I Spent Fuel Assembly Storage 3.7 .17 Coefficients Decay Time (yr . ) A4 0 24 .1121 5 18 .3369 10 12. 6854 10 .4694 9.1487 -17.9045

1. Relevant uncertainties are explicitly included in the criticality analysis. For instance. no additional allowance for burnup uncertainty or enrichment uncertainty is required. For a fuel assembly to meet the requirements of a Fuel Reg ion. the assembly burnup must exceed t he '" min imum burnup" (GWd/ MTU) gi ven by the curve fit for the assembly '"decay ti me" and "i nit i al enrichment.** The specific mini mum bu rnup (BU) requ ired for each fuel assembl y is ca l cu l at ed f rom the following equation:

BU = A1

• En 3 + Az
• En 2 + A3
• En + A4 En. is the maxi mum radial average 235 U enrichment . Any En value between 235 U and 4. 65 wt% 235 U may be used. Burn up credit is not requ i red for an En be low t% 235 U.

3. It is acceptab le to l inear ly interpol ate between calculated BU limits based on decay time.

4. The 20-year coefficients must be used to calculate the minimum BU for an assembly with a decay time of greater than 20 years.

PALO VERDE UNITS 1. 2.3 3.7 .17-3 AMENDMENT NO. ~

After SFP transition Insert Revised Table 3.7.17-3 here Spent Fuel Assembly Storage 3.7.17 Fuel Region 4: Burnup Requirement Coefficients Coefficients 0 5 -46 .1161 10 -51. 5889 15 -7. 3777 20 -7.3897

1. Relevant uncertainties are explicitly included in the criticality analysis. For instance. no additional allowance for burnup uncertainty or enrichment uncertainty is required. For a fuel assembly to meet the requirements of a Fuel Region. the assembly burnup must exceed the "minimum burnup" CGWd/MTU) given by the curve fit for the assembly "decay time" and "initial enrichment." The specific minimum burnup (BU) required for each fuel assembly is calculated from the following equation:

BU = A1

• En 3 + A2
• En 2 + A3
• En + A4

2. Initial enrichment . En. is the maximum radial average 235 U enrichment. Any En value between 1. 75 wt% 235 U and 4. 65 wt% 235 U may be used. Burn up credit is not required for an En below 1. 75 wt% 235 U.

3. It is acceptable to linearly interpolate between calculated BU limits based on decay time.

4. The 20 -year coefficients must be used to calculate the minimum BU for an assembly with a decay time of greater than 20 years.

PALO VERDE UNITS 1.2.3 3.7.17-4 AMENDMENT NO. ~

Insert Revised Table 3.7.17-4 here After SFP transition Spent Fuel Assembly Storage 3.7.17 Fuel Region 5: Burnup Requirement Coefficients Coefficients 0 -32.8551 5 -32.6068 10 -30.0042

                                                 -0.4523
                                                 -0 .8152

1. Relevant uncertainties are explicitly included in the critical ity analysis. For instance. no additional allowance for burnup uncertainty or enrichment uncertainty is required. For a fuel assembly to meet the requirements of a Fuel Region. the assembly burnup must exceed the '"minimum burnup" (GWd/MTU) given by the curve fit for the assembly "decay time" and "i nitial enrichment." The speci fic minimum burnup (BU) required for each fuel assembly i s calculated from the following equation:

BU = A1

• En 3 + Az
• En 2 + A3
• En + A4

2. Initial enrichment. En . is the maximum radial average 235 U enrichment. Any En value between 1. 65 wt% 235 U and 4. 65 wt% 235 U may be used. Burn up credit is not required for an En below 1. 65 wt% 235 U.

3. It is acceptable to linearly interpolate between ca lculated BU limits based on decay time.

4. The 20 -year coeffic ients must be used to calculate the minimum BU for an assembly with a decay time of greater than 20 years.

PALO VERDE UNITS 1.2.3 3.7.17-5 AMENDMENT NO.

Insert Revised Table 3.7.17-5 here After SFP transition Spent Fuel Assembly Storage 3.7.17 Coefficients

                                                                                    -54 .6847
                                                                                    -49.7282
                                                                                    -44.9348 28.8269

1. Relevant uncertainties are explicitly included in the criticality analysis. For instance. no additional allowance for burnup uncertainty or enrichment uncertainty i s required. For a fuel assembly to meet the requirements of a Fuel Region . the assembly burnup must exceed the "minimum burnup" (GWd/MTU) given by the curve fit for the assembly "decay time" and "initial enrichment." The specific minimum burnup (BU) required for each fuel assembly is calculated from the following equation:

BU = A1

• En 3 + Az
• En 2 + A3
• En + A4

2. Initial enrichment. En . is the maximum radial average 235 U enrichment. Any En value between 1. 45 wt% 235 U and 4. 65 wt%235 U may be used. Burn up credit is not required for an En below 1. 45 wt% 235 U.

3. It is acceptable to linearly interpolate between calculated BU limits based on decay time .

4. The 20-year coefficients must be used to calculate the minimum BU for an assembly with a decay time of greater than 20 years.

PALO VERDE UNITS 1.2.3 3.7.17-6 AMENDMENT NO .

Revised Tables 3.7.17-2 and 3.7.17- 3 Tabl e 3.7.17-2 Fuel Region 3: Burnu p Requirement Coefficients Decay Time Coefficients (yr.) A1 0 -0.8100 6 .5551 -2.9050 -21.0499 t i 5 -0.9373 7 .6381 -6.0246 -18.0299 10 -0.8706 6 .8181 -3.1913 -21.0299 15 -0.7646 5 .6311 0.7657 -25.1599 20 -0.7233 5 .1651 2.3084 -26.7499 Tabl e 3.7.17-3 Fuel Region 4: Burnu p Requirement Coefficients Decay Time Coefficients (yr.) A1 0 0.0333 -2 .1141 27.4985 -41.8258 5 -0.2105 0 .2472 19.7919 -34.2641 10 0.0542 -2 .5298 28.0953 -41.7092 15 0.3010 -5 .0718 35.6966 -48.5494 20 0.4829 -6 .9436 41.3118 -53.6182

Revised Tables 3.7.17-4 and 3.7.17-5 Table 3.7.17-4 Fuel Region 5: Burnup Requirement Coefficients Decay Time Coefficients (yr.) A1 A2 Aa ~ 0 0.1586 -3.0177 28.7074 . -39.8636 5 -0.2756 1.3433 14.5578 -26.4388 10 -0.2897 1.3218 14.6176 -26.4160 15 -0.0736 -0.9107 21.2118 -32.1887 20 0.1078 -2.7684 26.6911 -36.9873 Table 3.7.17-5 Fuel Region 6: Burnup Requirement Coefficients Decay Time Coefficients (yr.) A, A2 A3 ~ 0 0.4890 -6.7447 42.7619 -49.3143 5 0.5360 -6.9115 41.1003 -46.6977 10 0.4779 -6.1841 37.6389 -43.0309 15 0.4575 -5.8844 35.8656 -41.0274 20 0.3426 -4.7050 31.8126 -37.2800

After SFP transition Spent Fuel Assembly Storage 3.7.17 Figure 3.7.17-1 Allowable Storage Arrays .I. . . , Array A . >f.)'. x Two Region 1 assemblies Cl) checkerboarded with two blocked cells CX). The Region 1 assemblies are each in a cell with a stainless steel L-insert. No NETCO-SNAP-IN inserts are credited. - x Array B TC Two Region 1 assemblies (1) checkerboarded with two cells containing . .. " . trash cans (TC). The Region 1 assemblies are each in a cell with a stainless steel L-insert. Every cell without a stainless steel L- TC :.:'J.** insert must contain a NETCO-SNAP-IN insert. ,\,.* *.* Array C Two Region 2 assemblies (2) checkerboarded with one Region 3 assembly (3) and one blocked cell (X). The Region 2 assemblies are each in a cell with a stainless steel L-insert. The Region 3 assembly is in a cell containing a NETCO-SNAP-IN insert. .* ..

• Array D One Region 2 assembly (2) checkerboarded with three Region 4 4 assemblies (4). The Region 2 assembly and the diagonally located Region 4 assembly are each in a storage cell with a stainless steel L-insert. The two storage cells without a stainless steel L-insert 4

                                                                                                                  ****'.:~~-;r.-". ~.

contain a NETCO-SNAP-IN insert. Array E 5 Four Region 5 assemblies (5). Two storage cells contain a stainless steel L-insert. One cell contains a NETCO-SNAP-IN insert. One 5 .*** storage cell contains no insert. >-'*' :< Array F . 6 .. 6 Four Region 6 assemblies (6). Two storage cells contain a stainless steel L-insert. The other two cells contain no inserts. Notes:

1. The shaded locations indicate cells which contain a stainless steel L-insert.

2. A blocked cell CX) contains a blocking device a19d e19ly 'ilateP il9 tl9e aeti*te ftlel Pe§iefl. -

3. NETCO-SNAP-IN inserts must be oriented in the same direction as the stainless steel L-inserts.

4. NETCO-SNAP-IN inserts are only located in cells without a stainless steel L-insert.

5. Any cell containing a fuel assembly or a TC may instead be an empty Cwater-f1lled) cell in all storage arrays.

6. Any storage array location designated for a fuel assembly may be replaced with non-fissile material.

7. Interface requirements: Each cell is part of up to four 2x2 arrays and each cell must simultaneously meet the requirements of all those arrays of which it is a part.

PALO VERDE UNITS 1.2.3 3.7.17-7 AMENDMENT NO.

Enclosure Response to RA! Regarding LAR to Revise TS to Incorporate Updated Criticality Safety Analysis- Nuclear Performance and Code Review Branch (SNPB) Revised Technical Specifications and Bases and WCAP-18030, Revision 1 Attachment 2 Technical Specifications Clean Pages Tables 3.7.17-2 through 3.7.17-5 Figure 3.7.17-1

After SFP transition Spent Fuel Assembly Storage 3.7.17 Table 3.7.17-2 Fuel Region 3: Burnup Requirement Coefficients Decay Coefficients Time (yr.) Ai AJ A4 A2 0 -0.8100 6.5551 -2.9050 -21. 0499 5 -0.9373 7. 6381 -6.0246 -18. 0299 10 -0.8706 6. 8181 -3.1913 -21.0299 15 -0.7646 5. 6311 0.7657 -25.1599 20 -0.7233 5.1651 2.3084 -26.7499 Notes:

1. Relevant uncertainties are explicitly included in the criticality analysis. For instance. no additional allowance for burnup uncertainty or enrichment uncertainty is required. For a fuel assembly to meet the requirements of a Fuel Region. the assembly burnup must exceed the "minimum burnup" (GWd/MTU) given by the curve fit for the assembly "decay time" and "initial enrichment." The specific minimum burnup (BU) required for each fuel assembly is calculated from the following equation:

BU : A1

• En 3 + Az
• En 2 + A3
• En + A4

2. Initial enrichment, En. is the maximum radial average 235U enrichment. Any En -

value be tween 2. 50 wt% 235 U and 4. 65 wt% 235 U may be used . Burnup credit is not required for an En below 2. 50 wU 235 U.

3. It is acceptable to linearly interpolate between calculated BU limits based on decay time.

4. The 20-year coefficients must be used to calculate the minimum BU for an assembly with a decay time of greater than 20 years.

PALO VERDE UNITS 1,2,3 3.7.17-3 AMENDMENT NO. ~

After SFP transition Spent Fuel Assembly Storage 3.7.17 Table 3.7.17-3 Fuel Region 4: Burnup Requirement Coefficients Decay Coefficients

   . Time Cyr.)                Ai                     A2                     A3               A4 0               0.0333                -2.1141                 27.4985         -41.8258 5               -0.2105                 0.2472                 19.7919         -34.2641 10               0.0542                -2.5298                 28.0953         -41.7092 15               0.3010                -5. 0718                35.6966         -48.5494 20                0.4829                -6.9436                 41. 3118        -53.6182 Notes:

1. Relevant uncertainties are explicitly included in the criticality analysis. For instance. no additional allowance for burnup uncertainty or enrichment uncertainty is required. For a fuel assembly to meet the requirements of a Fuel Region. the assembly burnup must exceed the "minimum burnup" CGWd/MTU) given by the curve fit for the assembly "decay time" and "initial enrichment." The specific minimum burnup (BU) required for each fuel assembly is calculated from the following equation:

BU = A1

• En3 + A2
• En 2 + /'iJ
• En + A4

2. Initial enrichment. En. is the maximum radial average 235 U enrichment. Any En val ue between 1. 75 wt% 235 U and 4 . 65 wt% 235U may be used . Burnup credit is not required for an En below 1. 75 wt% 235 U.

3. It is acceptable to linearly interpolate between calculated BU limits based on decay time.

4. The 20-year coefficients must be used to calculate the minimum BU for an assembly with a decay time of greater than 20 years.

PALO VERDE UNITS 1.2,3 3.7.17-4 AMENDMENT NO. +/-29

After SFP transition Spent Fuel Assembly Storage 3.7.17 Table 3.7.17-4 Fuel Region 5: Burnup Requirement Coefficients Decay Coefficients Time Cyr.) A1 A2 AJ A4 0 0.1586 -3.0177 28.7074 -39.8636 5 -0.2756 1. 3433 14.5578 -26.4388 10 -0.2897 1. 3218 14.6176 -26.4160 15 -0.0736 -0.9107 21. 2118 -32.1887 20 0.1078 -2.7684 26.6911 -36.9873 Notes:

1. Relevant uncertainties are explicitly included in the criticality analysis. For instance. no additional allowance for burnup uncertainty or enrichment uncertainty is required. For a fuel assembly to meet the requirements of a Fuel Region. the assembly burnup must exceed the "minimum burnup" (GWd/MTU) given by the curve fit for the assembly "decay time" and "initial enrichment." The specific minimum burnup {BU) required for each fuel assembly is calculated from the following equation:

BU = A1

• En 3 + Ai
• En 2 + A3
• En + A4

2. Initial enrichment. En. is the maximum radial average 235 U enrichment. Any En value between 1. 65 wU 235U and 4. 65 wt% 235 U may be used. Burnup credit is not required for an En below 1.65 wu; 235 U.

3. It is acceptable to linearly interpolate between calculated BU limits based on decay time.

4. The 20-year coefficients must be used to calculate the minimum BU for an assembly with a decay time of greater than 20 years.

PALO VERDE UNITS 1.2.3 3.7.17-5 AMENDMENT NO.

After SFP transition Spent Fuel Assembly Storage 3.7.17 Table 3.7.17-5 Fuel Region 6: Burnup Requirement Coefficients Decay Coefficients Time (yr.) Ai Ai AJ A4 0 0.4890 -6.7447 42.7619 -49.3143 5 0.5360 -6. 9115 41.1003 -46.6977 10 0.4779 -6.1841 37.6389 -43.0309 15 0.4575 -5.8844 35.8656 -41.0274 20 0.3426 -4.7050 31.8126 -37.2800 Notes:

1. Relevant uncertainties are explicitly included in the criticality analysis. For instance. no additional allowance for burnup uncertainty or enrichment uncertainty is required. For a fuel assembly to meet the requirements of a Fuel Region. the assembly burnup must exceed the minimum burnup" CGWd/MTU) given by the curve fit for the assembly "decay time" and "initial enrichment." The specific minimum burnup CBU) required for each fuel assembly is calculated from the following equation:

BU = At

• En 3 + A2
• En 2 + AJ
• En + AA

2. Initial enrichment. En, is the maximum radial average 235 U enrichment. Any En value between 1. 45 wU 235U and 4 .65 wU 235 U may be used. Burnup credit is not re qui red for an En below 1. 45 wU 235 U.

3. It is acceptable to linearly interpolate between calculated BU limits based on decay time.

4. The 20-year coefficients must be used to calculate the minimum BU for an assembly with a decay time of greater than 20 years.

PALO VERDE UNITS 1.2.3 3.7.17-6 AMENDMENT NO.

After SFP transition Spent Fuel Assembly Storage

3. 7 .17 Figure 3.7.17-1 Allowable Storage Arrays Array A 1 x Two Region 1 assemblies Cl) checkerboarded with two blocked cells CX).

The Region 1 assemblies are each in a cell with a stainless steel x 1 L-insert. No NETCO-SNAP-IN inserts are credited. Array B 1 TC Two Region 1 assemblies Cl) checkerboarded with two cells conta~ning trash cans (TC). The Region 1 assemblies are each in a cell with a stainless steel L-insert. Every cell without a stainless steel L- TC 1 insert must contain a NETCO-SNAP-IN insert. Array c Two Region 2 assemblies (2) checkerboarded with one Region 3 assembly 2 x (3) and one blocked cell CX). The Region 2 assemblies are each in a cell with a stainless steel L-insert. The Region 3 assembly is in a 3 2 cell containing a NETCO-SNAP-IN insert. Array D One Region 2 assembly (2) checkerboarded with three Region 4 2 4 assemblies (4). The Region 2 assembly and the diagonally located Region 4 assembly are each in a storage cell with a stainless steel L-insert. The two storage cells without a stainless steel L-insert 4 4 contain a NETCO-SNAP-IN insert. Array E 5 5 Four Region 5 assemblies (5). Two storage cells contain a stainless steel L-insert. One cell contains a NETCO-SNAP-IN insert. One 5 5 storage cell contains no insert. Array F 6 6 Four Region 6 assemblies (6). Two storage cells contain a stainless steel L-insert. The other two cells contain no inserts. 6 6 Notes:

1. The shaded locations indicate cells which contain a stainless steel L-insert.

2. A blocked cell CX) contains a blocking device.

3. NETCO-SN.AP-IN inserts must be oriented in the same direction as the stainless steel L-inserts.

4. NETCO-SN.AP-IN inserts are only located in cells without a stainless steel L-insert.

5. "1ly cell containing a fuel assembly or a TC may instead be an empty (water-filled) cell in all storage arrays.

6. Puly storage array location designated for a fuel assembly may be replaced with non-fissile material.

7. Interface requirements: Each cell is part of up to four 2x2 arrays and each cell must simultaneously meet the requirements of all those arrays of which it is a part.

PALO VERDE UNITS 1.2,3 3.7.17-7 AMENDMENT NO.

l Enclosure Response to RAI Regarding LAR to Revise TS to Incorporate Updated Criticality Safety Analysis- Nuclear Performance and Code Review Branch (SNPB) Revised Technical Specifications and Bases and WCAP-18030, Revision 1 Attachment 3 Technical Specifications Bases Markup Pages Revised inserts for TS Bases Sections 3.7.15 and 3.7.17

                                                                      !After SFP transition I Fuel Storage Pool Boron Concentration B 3.7.15 B 3.7 PLANT SYSTEMS B 3.7 .15 Fuel Storage Pool Boron Concentration
                        , and decay BASES                   ___

time . BACKGROUND As described in CO 3. 7.17, "Spent Fue 1 Assembly Star ge." fuel assemblies re stored in the spent fuel racks i accordance with iteria based on initial enrichment ilAG discharge burnup. Altl=lo t:J~h t l=le ~Jater in the spent fblel pool is norma ll y borated t o ~ 215Q ppm. the criteria that limit

~:s:!~::i~e~ ~e!~i!P:~s:Tt~1:J : t:ei~~f!;e~::kf!:cb!!::~ is 0

In order to maintain the spent ft:Jel pool kett < 1. Q. a

       ~soluble boron concentration of                              is required to            ,--fi6ffifl maintain the spent fue 1 poo 1 ketf ~ 0.             ming the most     Y,,, -

limiting single fuel mishandling accident . APPLICABLE A fuel assembly could be inadvertently loaded into a spent SAFETY ANALYSES fuel rack location not allowed by LCO 3.7.17 (e.g .. an unirradi at ed fuel assembly or an insufficiently depleted fuel assembly) Another type of postulated accident is There could also be associated

• a fuel assembly that is dropped onto the a misload of fully 1 ed fuel pool storage rack or between a rack and multiple fuel the ol walls. These incidents could have a positive assemblies into fuel activity effect. decreasing the margin to critical ity.

rack locations not However. the negative reactivity effect of the soluble boron compensates for the increased reactivity caused by these allowed by LCO postulated accident scenarios. 3.7.17. The concentration of dissolved boron in the fuel pool satisfies Criterion 2 of 10 CFR 50 .36 (c)(2)(ii) . LCO The specified concentration of dissolved boron in the fuel pool preserves the assumptions used in the analyses of the potential accident scenarios described above. This concentration of dissolved boron is the minimum required concentration for fuel assembly storage and movement within the fuel pool. AP PLI CAB IL ITY This LCO applies whenever any fuel assembly is stored in the spent fuel pool in order to comply with the TS 4.3.1.1.c design requirement that keff s 0.95 . (continued) PALO VERDE UNITS 1,2,3 B 3.7.15-1 REVISION ~

                                                                 !After SFP transition I Fuel Storage Pool Boron Concentration B 3.7.15 BASES (continued)

ACTIONS A. l andA.2 The Required Actions are modified by a Note indicating that LCO 3.0.3 does not apply. When the concentration of boron in the spent fuel pool is less than requi red, immediate action must be taken to preclude an accident from happening or to mitigate the consequences of an accident in progress. This is most efficiently achieved by immediately suspending the movement of fuel assemblies. This does not preclude the movement of fuel assemblies to a safe posi t ion . In addition. action must be immediately ini tiated to restore boron concentration to within limit. If moving fuel assemblies while in MODE 5 or 6. LCO 3.0.3 would not specify any action. If moving fuel assemblies while in MODE 1, 2, 3. or 4. the fuel movement is independent of reactor operation. Therefore. inability to suspend movement of fuel assemblies is not sufficient reason to require a reactor shutdown. SURVEILLANCE SR 3.7.15 .l REQUIREMENTS This SR verifies that the concentration of boron in the spent fuel poo 1 is within the required 1imit. As 1ong as this SR is met. the analyzed incidents are fully addressed . The Surveillance Frequency is controlled under the Surveil lance Frequency Control Program. REFERENCES 1. UFSAR. Section 9.1.2. 2.

            "Criticality Safety Analysis for Palo Verde Nuclear Generating Station Units 1, 2, and 3" (Proprietary), WCAP-18030-P, Rev ision 0, REVISION   ea Revision 1, October 2016

lAtter SFP transition I Spent Fuel Assembly Storage B 3.7 .17

                                       . The design basis of the spent fuel pool cooling system is to 8 3.7 PLANT SYSTEMS                provide adequate cooling to the spent fuel pool during all operating conditions (including full core offload) for up to 1205 B 3.7 .17 Spent Fuel Assembl       fuel assemblies (UFSAR Section 9.1.3).

BASES pool BACKGROUND The spent fuel is designed o sto (nonirradiated) Rblclear fuel asse lies. (irradiated) fuel assemblies in vertical configuration underwater . The storage pool s originally designed to store up to 1329 fuel assemblies * . Tl:le c1:i1rrent storage confi9blration, 1t1 Rich allows credit to be 1

                   !:~~nn!~rr:~:i:ec~:~i:!:a!~::rb~~;n{~or:~fe~~c:!o;!::*c:::.

provides for a maximum storafje of 12Q9 ft:Jel assemblies in a fo1:i1r region confi§blration. The design basis of the spent fblel coolin9 system, ho*n*ever, is to praviae aEle('.!blate caaling to the spent fuel dblring all operating conaitions (inclblding fblll core offloacl) for only 12Q9 fl:lel assem/:Jl ies CUfSAR section 9 . 1.~). Therefore. an ad9itianal foblr spaces are mechanically blocked to limit the maxim1:i1m nt:Jmber sf f1:i1el assemblies that may be stored in the spent f1:i1ol storage pool to 12Q6. Region 1 is coR!pri sed of t1t.*o 9xQ storage racks and oi:ie 12xB storage rack. Gell 131 ocki ng devices are p1aced in every other storage cel 1 1ocati on in Region 1 to !Hai Rtai n a t1t:o 01::1t of four checkersoard coAfi gblrati OR. n1ese eel l blocking devi cos prevent inadvertent insertion of a f~el asselHbly into a cell that is Rot allm. .*ed to coRtain a f1:i1el asseRlbly . Region ~ is comprised of tRree 9xQ storage racks and one 9x9 storage rack in Units 2 and a. RegioR dis comprises of four 9xg storage racks and one 9x9 storage rack in Unit 1. ~ fuel assemblies may se stores in every Region 3 cell 1ocati on, no cell blocking devices are installed in RegioR 3. Regions 2 and 4 are mixed and are comprised of seven gxg storage racks and three 12x8 storage racks in Uni ts 2 and 3. Regions 2 and 4 are mixed aRd are comprised of six 9xg stora§e racks and three 12xQ storage racks iR Unit 1. RegioRs 2 and 4 are mixed iR a repeating 3x4 storage patterR in ~\lhich ti.*m out of tv:el ve cell 1ocati ons are desi gnateEI Region 2 and ten ottt of twelve cell locations are designateEI Region 4 (see UFSAR fig1::1res 9.1 7 aRd 9.1 7A). Since fuel assomslies may be stored in every Region 2 and Region 4 cell location. no cell blocking devices are installed in Regisn 2 and Region 4. !Insert 1 ) (contin1:i1ed) PALO VERDE UNITS 1,2,3 B 3.7 .17 -1 REVISION fil

Insert 1 for TS Bases 3.7.17 page B 3.7.17*1 t1600 The spent fuel storage cells are installed in parallel rows with a nominal center-to-center spacing of 9.5 inches. This spacing, a minimum soluble boron concentration of 14eG- ppm, the use of neutron-absorbing panels, and the storage of fuel in the appropriate region based on fuel assembly initial enrichment, discharge burnup, and decay time in accordance with TS Tables 3.7.17-1 through 3.7.17-5 is sufficient to maintain ke1t s 0.95 for fuel of initial maximum radially averaged enrichment of up to 4.65 wt%. Disused CEAs, in-core instruments, and other material is stored in trash cans. A trash can may be stored in any location that is approved to store a fuel assembly. No special nuclear material (SNM) may be stored in a trash can.

                                                               .    !After SFP transition I Spent Fuel Assembly Storage B 3.7.17 BASES SURI/ EI LL'\~IGE

• that a fuel assembly that does not meet the burn1:1p REQU I REM01l£ requirement for Region 2 must be stored in Region 1.

(GOAtimied)

• that any fuel assembly may be stored in Region 1.
• t hat any f1:1el assembly may be stored in a l o't:er numbered region than U1e region for which it q1:1alifies becat1se bt1rnt1p reqt1irements decrease as region numbers decrease (refer also to Tech Spec 4.3 .1.1).
• and that comparing actual burnup to tRe burnup requirement for zero decay time wi 11 ah ays be correct 1

or conservative. REFERENCES 1. UFSAR. Sections 9.1.2 and 9.1 .3. 2. 13 N OQl 19QO 1221 1. "Palo Verde Spent Fuel Pool Criticality /\nalysis," ABB calculation A PV FE 0109. revision 03 , dated Janblary Hi . 1999 . Westinghouse letter ~IF /\PS 10 19. "Cr itical icy Safety Evaluation of the Spent Fuel Pool Map wi th a Proposed Region 3 Increase." dated Febr1:Jary 25 . 2010 .

                 "Criticality Safety Analysis for Palo Verde Nuclear Generating Station Units 1, 2, and 3" (Proprietary), WCAP- 18030-P, Revision 1, October 2016 PALO VERDE UNITS 1.2.3                    B 3.7 .17 -6                       REVISION   ~

Enclosure Response to RAI Regarding LAR to Revise TS to Incorporate Updated Criticality Safety Analysis- Nuclear Performance and Code Review Branch (SNPB) Revised Technical Specifications and Bases and WCAP-18030, Revision 1 ATTACHMENT 4 Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-16-4498, October 27, 2016

Westinghouse Non-Proprietary Class 3 @Westinghouse Westinghouse Elec~ric Company 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066. USA U.S. Nuclear Regulatory Commission Direct tel: (412) 374-4643 Document Control Desk Direct fax: (724) 940-8560

• 11555 Rockville Pike e-mail: greshaja@westinghouse.com Rockville, MD 20852 CAW-16-4498 October 27, 2016 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

WCAP-18030-P, Revision 1, "Criticality Safety Analysis for Palo Verde Nuclear Generating Station Units 1, 2, and 3" (Proprietary)

• The Application for Withholding Proprietary Information from Public Disclosure is submitted by Westinghouse Electric Company LLC ("Westinghouse"), pursuant to the provisions of paragraph (b)(l) of Section 2.390 of the Commission's regulations. It contains commercial strategic information proprietary to Westinghouse and customarily held in confidence.

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-16-4498 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 Arizona Public Service Company. Correspondence with respect to the proprietary aspects of the Application for Withholding or the Westinghouse Affidavit should reference CAW-16-4498 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~ fames A. Gresham, Manager Regulatory Compliance

                      © 2016 Westinghouse Electric Company LLC. All Rights Reserved.

CAW-16-4498 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF BUTLER: I, James A. Gresham, 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.

                           ~--

Date: --1-f9-=--1<-U7'-'-"--{J

2 CAW-16-4498 (1) I am Manager, Regulatory Compliance, 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 ofa 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

3 CA W-16-4498 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 ofresources 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 sucl:i information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information. (c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

4 CAW-16-4498 (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 ofa 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 I 0 CFR Section 2.390, is to be received in confidence by the Commission. (v) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief. (vi). The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP-18030-P, Revision I, "Criticality Safety Analysis for Palo Verde Nuclear Generating Station Units I, 2, and 3" (Proprietary), dated October 2016, for submittal to the Commission, being transmitted by Arizona Public Service Company 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 Westinghouse's request for NRC approval of WCAP-18030, and may be used only for that purpose.

5 CA W-16-4498 (a) This information is part of that which will enable Westinghouse to obtain NRC approval of WCAP-18030, Revision 1, "Criticality Safety Analysis for Palo Verde Nuclear Generating Station Units 1, 2, and 3." (b) Further, this information has substantial commercial value as follows: (i) Westinghouse plans to sell the use of similar information to its customers for the purpose of demonstrating the sub-criticality of the spent fuel pool. (ii) Westinghouse can sell support and defense of industry guidelines and acceptance criteria for plant-specific applications. (iii) The information requested to be withheld reveals the distinguishing aspects ofa 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 justifications and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information. The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money. In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended. Further the deponent sayeth not.

PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and non-proprietary versions of a document, 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 nec*essary 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 ifthe original was identified as proprietary.}}