2CAN040703, License Amendment Request to Allow the Use of Optimized Zirlo Fuel Rod Cladding

License Amendment Request to Allow the Use of Optimized Zirlo Fuel Rod Cladding

ML071220267
Person / Time
Site:	Arkansas Nuclear
Issue date:	04/24/2007
From:	Mitchell T Entergy Operations
To:	Document Control Desk, NRC/NRR/ADRO
References
2CAN040703, CENPD-404-P-A, WCAP-12610-P-A
Download: ML071220267 (19)

Text

SEntergy Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 Timothy G. Mitchell Vice President Operations ANO 2CAN040703 Apri124, 2007 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

License Amendment Request To Allow the Use of Optimized ZIRLOTM Fuel Rod Cladding Arkansas Nuclear One, Unit 2 Docket No. 50-368 License No. NPF-6

REFERENCES:

1. Westinghouse Topical Reports WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A, Optimized ZIRLOTM

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Entergy Operations, Inc. (Entergy) hereby requests the following amendment for Arkansas Nuclear One, Unit 2 (ANO-2). Technical Specification (TS) 5.2.1, Fuel Assemblies, identifies, in part, Zircaloy or ZIRLOTM fuel rod claddin%as the allowable fuel rod cladding material. The proposed change will add Optimized ZIRLO'T as an acceptable fuel rod cladding material.

Topical report WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A "Optimized ZIRLOTM,"

prepared by Westinghouse Electric Company, LLC (Westinghouse), addresses Optimized ZIRLOTM and demonstrates that Optimized ZIRLOTM has essentially the same properties as currently licensed ZIRLOTM. The topical report has been approved by the U.S. Nuclear Regulatory Commission (NRC).

The proposed change to the TS has been evaluated in accordance with 10 CFR 50.91(a)(1) using criteria in 10 CFR 50.92(c) and it has been determined that this change involves no significant hazards consideration. The bases for these determinations are included in Attachment 1. A markup of the affected TS pages is included in Attachment 2.

To support the change and pursuant to 10 CFR 50.12, Entergy is also requesting an exemption from certain requirements of 10 CFR 50.46, "Acceptance Criteria for Emergency Core Cooling Systems for Light -Water Nuclear Power Reactors," and Appendix K to 10 CFR

ýoc)(

2CAN040703 Page 2 of 3 Part 50, MECCS Evaluation Models" for ANO-2. The exemption request relates solely to the specific types of cladding material specified in these regulations for use in light water reactors.

As written, the regulations presume the use of either Zircaloy or ZlRLOTM fuel rod cladding.

The exemption request is required since Optimized ZIRLO'rM has a slightly different composition than Zircaloy or ZIRLOTM. The exemption request is included as Attachment 3.

In July 2004, the NRC approved a similar exemption request for Waterford Steam Electric Station, Unit 3 to allow the use of Optimized ZIRLOTM fuel rod cladding in four lead test assemblies.

The proposed change includes new commitments as summarized in Attachment 4.

Enterguylans to Introduce fuel assemblies containing fuel rods fabricated with Optimized ZIRLO cladding In future core reload applications starting in the spring of 2008. Entergy requests approval of the proposed amendment by January 31, 2008. Once approved, the amendment shall be implemented within 60 days. Although this request is neither exigent nor emergency, your prompt review Is requested.

If you have any questions or require additional information, please contact Dana Millar at 601-368-5445.

I declare under penalty of perjury that the foregoing Is true and correct. Executed on April 24, 2007.

Sincerely, TGM/DM Attachments:

1. Analysis of Proposed Technical Specification Change

2. Proposed Technical Specification Changes (mark-up)

3. Request for Exemption to the Cladding Material Specified in 10 CFR 50.46 and 10 CFR Part 50, Appendix K to Allow Use of Optimized ZIRLOTM in Core Reload Applications

4. List of Regulatory Commitments

2CAN040703 Page 3 of 3 cc: Dr. Bruce S. Mallert Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Arkansas Nuclear One P. O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Ms. Farldeh Saba MS 0-8 B1 Washington, DC 20555-0001 Mr. Bernard R. Bevill Director Division of Radiation Control and Emergency Management Arkansas Department of Health & Human Services P.O. Box 1437 Slot H-30 Little Rock, AR 72203-1437

Attachment I 2CAN040703 Analysis of Proposed Technical Specification Change

Attachment I to 2CAN040703 Page 1 of 7

1.0 DESCRIPTION

This letter is a request to amend Operating License NPF-6 for Arkansas Nuclear One, Unit 2 (ANO-2).

The proposed change will revise the Operating License to allow the use of Optimized ZIRLOTM fuel rod cladding material. Acceptable fuel rod cladding material is identified in ANO-2 Technical Specification (TS) 5.2.1, Fuel Assemblies. The proposed change will add Optimized ZIRLOTM fuel rod cladding material as an acceptable material.

An exemption from certain requirements of 10 CFR 50.46, "Acceptance Criteria for Emergency Core Cooling Systems for Light -Water Nuclear Power Reactors," and Appendix K to 10 CFR Part 50, "ECCS Evaluation Models" Is required to support this change.

The exemption request is Included as Attachment 3 of this letter.

2.0 PROPOSED CHANGE

The proposed change will revise ANO-2 TS 5.2.1 by adding Optimized ZIRLOTM fuel rod cladding material as an acceptable material.

3.0 BACKGROUND

As the nuclear Industry pursues longer operating cycles with Increased fuel discharge bumup and fuel duty, the corrosion performance requirements for the nuclear fuel cladding become more demanding. Optimized ZIRLOTM was developed to meet these needs and provides a reduced corrosion rate while maintaining the benefits of mechanical strength and resistance to accelerated corrosion from abnormal chemistry conditions.

Optimized ZIRLOTm is described In WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A "Optimized ZIRLOT," prepared by Westinghouse Electric Company, LLC (Westinghouse).

The topical report has been reviewed and approved by the NRC by letter dated June 10, 2005.

By regulatory definition, Optimized ZIRLOTm Is a nioblum-tin-iron (Nb-Sn-Fe) zirconium (Zr) based alloy with a microstructure comprised of a body-centered cubic ZrNb phase and a close-packed hexagonal ZrNbFe phase homogeneously distributed throughout the zirconium matrix.

Optimized ZIRLOTM fuel cladding Is different from standard ZIRLOTM in two respects: 1) the tin content Is lower; and 2) the mlcrostructure Is different. This difference in tin content and microstructure can lead to differences In some mateda4 ,properties. Most of the material properties of standard ZIRLOTM and Optimized ZIRLO are the same within the uncertainty of the data and therefore use of standard ZIRLO~rm properties for safety analyses is acceptable. However, the NRC Safety Evaluation for Optimized ZIRLOTM suggests that the computer codes used to perform fuel design safety analyses Incorporate the material properties of Optimized ZIRLOTM.

to 2CAN040703 Page 2 of 7 The NRC staff approved Optimized ZIRLOTM fuel cladding based on: 1) similarities with standard ZIRLO'm; 2) demonstrated material performance; and 3) a commitment to provide irradiated data and validate fuel performance models ahead of burnups achieved in batch application. The NRC Safety Evaluation included ten conditions and limitations, to which Entergy's response is provided below. The conditions and limitations specifically address the commitment requirement stated above.

4.0 TECHNICAL ANALYSIS

The Final Safety Evaluation for Addendum I to Topical Report WCAP-1 261 0-P-A and CENPD-404-P-A, Optimized ZIRLOTM prepared by the NRC includes ten conditions and limitations. The reload process for ANO-2 will ensure these conditions and limitations are met when a batch of Optimized ZIRLOT is implemented. ANO-2 will comply with these conditions and limitations as follows:

1. Until rulemaking to 10 CFR Pail50 addressingOptimized ZIRLOTM has been completed, implementation of Optimized ZIRLOTM fuel clad requiresan exemption from 10 CFR 50.46 and 10 CFR Part50 Appendix K.

An exemption request is included as Attachment 3 to this letter.

2. The fuel rod burnup limit for this approvalremains at currently establishedlimits:

62 GWd/MTU for Westinghouse fuel designs and 60 GWd/MTU for CE fuel designs.

The fuel rod burnup limit Is Included in the ANO-2 Operating License. The License condition 2.C.(9) states that "Entergy Operations is authorized to operate the facility with an individual rod average bumup (burnup average over the length of a fuel rod) not to exceed 60 megawatt-days/kilogram of uranium." Therefore, until a new fuel bumup limit is approved for use by the NRC, ANO-2 is limited to 60 megawatt-days/kilogram of uranium which is equivalent to 60 GWd/MTU.

3. The maximum fuel rod waterside corrosion, as predictedby the best-estimatemodel, will

[proprietary limits included In topical report and proprietary version of safety evaluation] of hydrides for all locations of the fuel rod.

Using the best-estimate model, the maximum fuel rod waterside corrosion at ANO-2 will be confirmed to be less than the corrosion limit specified in the topical report for all locations of the fuel rod.

4. All conditions listed in previous NRC SE approvalsfor methodologies used for standard ZIRLOTM and Zircaloy-4 fuel analysis will continue to be met, except that the use of Optimized ZIRLOTM cladding in addition to standardZIRLOTM and Zircaloy-4 cladding is now approved.

The fuel analysis of Optimized ZIRLOTM fuel rod cladding will continue to meet all conditions associated with methods approved for ANO-2.

N to 2CAN040703 Page 3 of 7

5. All methodologies will be used only with the range for which ZIRLOTM and Optimized ZIRLOTM data were acceptable and for which the verification discussed in Addendum 1 and response to RAIs were performed.

The application of ZIRLOTM and Optimized ZIRLOTM In approved methodologies will be made consistent with the approach accepted in WCAP-12610-P-A Addendum 1-A.

6. The licensee is requiredto ensure that Westinghouse has fulfilled the following commitment: Westinghouse shall provide the NRC staff with a letter(s) containing the following information (Based on the schedule describedin response to RAI #3

[Reference 3)):

a. Optimized ZIRLOTM LTA data from Byron, Calvert Cliffs, Catawba, and Millstone.

I. Visual ii. Oxidation of fuel rods iii. Profilometry iv. Fuel rod length

v. Fuelassembly length

b. Using the standardand Optimized ZIRLOM database including the most recent LTA data, confirm applicabilitywith currently approved fuel performance models (e.g.,

measured vs. predicted).

Confirmationof the approved models' applicabilityup through the projected end of cycle bumup for the Optimized ZIRLO'M fuel rods must be completed priorto their initialbatch loading and priorto the startup of subsequent cycles. Forexample, prior to the first batch applicationof Optimized ZIRLOTM, sufficient LTA data may only be available to confirm the models' applicabilityup through 45 GWd/MTU. In this example, the licensee would need to confirm the models up through the end of the initialcycle. Subsequently, the licensee would need to confirm the models, based upon the latest LTA data, priorto re-insertingthe Optimized ZIRLO TM fuel rods in future cycles. Based upon the LTA schedule, it Is expected that this issue may only be applicable to the first few batch implementations since sufficient LTA data up through the bumup limit should be available within a few years.

Information confirming acceptability of the approved models for the first cycle has been provided by letter dated January 4, 2007 from J. A. Gresham (Westinghouse) to the NRC, uSER Compliance with WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A "Optimized ZIRLOTM," (Proprietary I Non-proprietary), LTR-NRC-07-1. Entergy will confirm that Westinghouse will provide additional confirmatory data prior to subsequent cycles.

7. The licensee is requiredto ensure that Westinghouse has fulfilled the following commitment: Westinghouse shall provide the NRC staff with a lettercontainingthe following information (Based on the schedule describedin response to RAI #11

[Reference 3)):

a. Vogtle growth and creep data summary reports.

Attachment I to 2CAN040703 Page 4 of 7

b. Using the standardZIRLOTM and Optimized ZIRLOT databaseincluding the most recent Vogtle data, confirm applicabilitywith currently approved fuel performance models (e.g., level of conservatism in W rod pressureanalysis, measure vs. predicted, predictedminus measured vs. tensile and compressive stress).

Confirmation of the approved models' applicabilityup through the projected end of cycle bumup for the Optimized ZIRLOTM fuel rods must be completed priorto their initialbatch loading andpriorto the startup of subsequent cycles. Forexample, prior to the first batch applicationof Optimized ZIRLOTM, sufficient L TA data may only be available to confirm the models' applicabilityup through 45 GWd/MTU. In this example, the licensee would need to confirm the models up through the end of the initialcycle. Subsequently, the licensee would need to confirm the models, based upon the latest LTA data, priorto re-insertingthe Optimized ZIRLOTM fuel rods in future cycles. Based upon the LTA schedule, it is expected that this issue may only be applicable to the first few batch implementations since sufficient LTA data up through the bumup limit should be available within a few years.

Information confirming acceptability of the approved models for the first cycle has been provided by letter dated January 4, 2007 from J. A. Gresham (Westinghouse) to the NRC, "SER Compliance with WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A uOptimized ZIRLOTM, (Proprietary I Non-proprietary), LTR-NRC-07-1. Entergy will confirm that Westinghouse will provide additional confirmatory data prior to subsequent cycles.

8. The licensee shall account for the relative differences in unirradiatedstrength (YS and UTS) between Optimized ZIRLOTM and standardZIRLOTM in cladding and structural analyses until irradiateddata for Optimized ZIRLOTM have been collected and provided to the NRC staff.

a. Forthe Westinghouse fuel design analyses:

i. The measured,unirradiatedOptimized ZIRLOTM strengths shall be used for BOL analyses.

ii. Between BOL up to a radiationfluence of 3.0 x 1021 n/cm2 (E>IMeV), pseudo-irradiatedOptimized ZIRLOTM strength set equalto linearinterpolationbetween the following two strength level points: At zero fluence, strength of Optimized ZIRLO equal to measuredstrength of Optimized ZIRLOTM and at a fluence of 3 x 1021 n/cm 2 (E>IMeV) minus 3 ksi.

iii. During subsequentirradiationfrom 3 x 1021 n/cm2 up to 12 x 1021 nlcm2, the differences in strength (the difference at a fiuence of 3 x 1021 n/cm2 due to tin content)shallbe decreasedlinearlysuch that the pseudo-irradiatedOptimized ZIRLO strengths will saturateat the same propertiesas standardZIRLOTM at 12 x 1021 n/cm .

b. Forthe CE fuel design analyses, the measured, unirradiatedOptimized ZIRLOTM strengths shall be used for all fluence levels (consistentwith previously approved methods).

Attachment I to 2CAN040703 Page 5 of 7 The fuel analysis of Optimized ZIRLOTM for ANO-2 (CE fuel design) will use measured, unirradiated Optimized ZIRLOTM strengths for all fluence levels.

9. As discussed in response to RAI #21 (Reference 3), for plants introducing Optimized ZIRLOTM that are licensed with LOCBART or STRIKIN-Il and have a limiting PCT that occurs during blowdown or early reflood, the limiting LOCBART or STRIKIN-Il calculation will be rerun using the specified Optimized ZIRLOTM materialproperties. Although not a condition of approval,the NRC staff strongly recommends that, for future evaluations, Westinghouse update all computer models with Optimized ZIRLOTM specific material properties.

ANO-2's ECCS performance analyses were performed using the STRIKIN-II computer code.

The specified Optimized ZIRLOTM material properties have been implemented in the STRIKIN-II code.

10. Due to the absence of high temperatureoxidation data for Optimized ZIRLOTM, the Westinghouse coolabilitylimit on PCT during the locked rotorevent shall be [a proprietary value listed in the topical report].

This condition is for Westinghouse fuel designs and is not applicable to ANO-2.

5.0 REGULATORY ANALYSIS

5.1 Applicable Regulatory Requirements/Criteria The proposed changes have been evaluated to determine whether applicable regulations and requirements continue to be met. Entergy has determined that the proposed change to allow the use of Optimized ZIRLOTM fuel rod cladding material requires exemptions from 10 CFR 50.46, Acceptance criteriafor emergency core cooling systems for light-water nuclear power reactors and 10 CFR 50, Appendix K, ECCS Evaluation Models. Attachment 3 provides the basis and justification for relief from these regulations.

The proposed change does not require relief from any other regulatory requirements and does not affect conformance with any General Design Criterion (GDC) differently than described in the Safety Analysis Report (SAR).

5.2 No Significant Hazards Consideration A change is proposed to the Design Features section of the Arkansas Nuclear One, Unit 2 (ANO-2) Technical Specifications (TSs) to include the allowance to use Optimized ZIRLOTM as a fuel rod cladding material.

Entergy Operations, Inc. has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, missuance of amendment," as discussed below:

to 2CAN040703 Page 6 of 7

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The NRC approved topical report WCAP-1 2610-P-A and CENPD-404-P-A, Addendum 1-A "Optimized ZIRLO' M," prepared by Westin house Electric Company, LLC (Westinghouse), addresses Optimized ZIRLO and demonstrates that O.mized ZIRLO'6 has essentially the same properties as currently licensed ZIRLO . The fuel cladding itself is not an accident initiator and does not affect accident probability. Use of Optimized ZIRLOTM fuel cladding has been shown to meet all 10 CFR 50.46 design criteria and, therefore, will not increase the consequences of an accident.

Therefore, the proposed change does not involve a significant increase In the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

Use of Optimized ZIRLOTM clad fuel will not result in changes in the operation or configuration of the facility. Topical report WCAP-12610-P-A and CENPD-404-P-A demonstrated that the material properties of Optimized ZIRLOTM are similar to those of standard ZIRLOTM. Therefore, Optimized ZIRLOTM fuel rod cladding will perform similarly to those fabricated from standard ZIRLOTM, thus precluding the possibility of the fuel becoming an accident initiator and causing a new or different type of accident.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change will not involve a significant reduction in the margin of safety because It has been demonstrated that the material properties of the Optimized ZIRLOM are not significantly different from those of standard ZIRLOTM. Optimized ZIRLOTM is expected to perform similarly to standard ZIRLOTM for all normal operating and accident scenarios, Including both loss of coolant accident (LOCA) and non-LOCA scenarios. For LOCA scenarios, where the slight difference In Optimized ZIRLOTM material properties relative to standard ZIRLO' M could have some Impact on the overall accident scenario, plant-specific LOCA analyses using Optimized ZIRLOTM properties will be performed pirior to the use of fuel assemblies with fuel rods containing Optimized ZIRLO' M . These LOCA analyses will demonstrate that the acceptance criteria of 10 CFR 50.46 will be satisfied when Optimized ZlRLOTM fuel rod cladding Is implemented.

to 2CAN040703 Page 7 of 7 Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, Entergy concludes that the proposed amendment(s) present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

5.3 Environmental Considerations The proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change In the types or significant increase In the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

Attachment 2 2CAN040703 Proposed Technical Specification Changes (mark-up)

5.0 DESIGN FEATURES 5.1 Site Location The site for Arkansas Nuclear One is located in Pope County, Arkansas on the north bank of the Dardanelle Reservoir (Arkansas River), approximately 6 miles west-northwest of Russellville, AR. The exclusion area boundary shall have a radius of 0.65 statute miles from the center of the reactor.

5.2 Reactor Core 5.2.1 Fuel Assemblies The reactor shall contain 177 fuel assemblies. Each assembl shall consist of a matrix of zircaloy or ZIRLO or Optimized ZIRLO clad fuel rods with an initial composition of natural or slightly enriched uranium dioxide (UO2) as fuel material. Limited substitutions of zirconium alloy or stainless steel filler rods for fuel rods, in accordance with approved applications of fuel rod configurations, may be used. Fuel assemblies shall be limited to those fuel designs that have been analyzed with applicable NRC staff approved codes and methods and shown by tests or analyses to comply with all fuel safety design bases. A limited number of lead test assemblies that have not completed representative testing may be placed in non- limiting core regions. Other cladding material may be used with an approved exemption.

5.2.2 Control Element Assemblies The reactor core shall contain 81 control element assemblies. The control material shall be boron carbide and silver-indium-cadmium as approved by the NRC.

ARKANSAS - UNIT 2 5-1 Amendment No. 205,

Attachment 3 2CAN040703 Request for Exemption to the Cladding Material Specified In 10 CFR 50.46 and 10 CFR Part 50, Appendix K to Allow Use of Optimized ZIRLOTm In Core Reload Applications to 2CAN040703 Page 1 of 3 Purpose Arkansas Nuclear One, Unit 2 (ANO-2) requests an exemption to 10 CFR 50.46, "Acceptance criteria for emergency core cooling systems for light-water nuclear power reactors," and Appendix K to 10 CFR Part 50, "ECCS Evaluation Models" to allow the use of Optimized ZIRLOTM fuel rod cladding in future core reload applications. The regulation in 10 CFR 50.46 contains acceptance criteria for the emergency core cooling system (ECCS) for reactors that have fuel rods fabricated either with Zircaloy or ZIRLOTM. Appendix K to 10 CFR Part 50, paragraph I.A.5, requires the Baker-Just equation to be used to predict the rates of energy release, hydrogen concentration, and cladding oxidation for the metal-water reaction. The Baker-Just equation assumed the use of a zirconium alloy different than Optimized ZIRLOTM.

Therefore, an exemption to 10 CFR 50.46 and 10 CFR Part 50, Appendix K is required to support the use of Optimized ZIRLOTM fuel rod cladding. The exemption request relates solely to the specific cladding material specified in these regulations (i.e., fuel rods clad with Zircaloy or ZIRLOTM). This request will provide for the application of the acceptance criteria of 10 CFR 50.46 to fuel assembly designs utilizing Optimized ZIRLOTM fuel cladding.

Background

As the nuclear Industry pursues longer operating cycles with increased fuel discharge burnup and fuel duty, the corrosion performance requirements for the nuclear fuel cladding become more demanding. Optimized ZIRLOTM was developed to meet these needs and provides a reduced corrosion rate while maintaining the benefits of mechanical strength and resistance to accelerated corrosion from abnormal chemistry conditions.

Starting in the spring of 2008 the reloads for ANO-2 will contain fuel rods clad with Optimized ZIRLOTM.

Technical Justification of Acceptability Westinghouse Electric Company, LLC (Westinghouse) topical report WCAP-1 261 0-P-A and CENPD-404-P-A, Addendum 1-A =Optimized ZIRLOTM" (Reference 1), provides the details and results of material testing of Optimized ZIRLOTM compared to standard ZIRLOTM as well as the material properties to be used in various models and methodologies when analyzing Optimized ZIRLOTM. The NRC Safety Evaluation (SE) (Reference 2) for the topical report contains ten conditions and limitations. The first condition requires an exemption from 10 CFR 50.46 and 10 CFR Part 50, Appendix K. The remaining conditions and limitations are addressed in of this letter.

The reload evaluation will ensure that acceptance criteria are met for the insertion of assemblies with fuel rods clad with Optimized ZIRLOTM. These assemblies will be evaluated using NRC approved methods and models to address the use of Optimized ZIRLOTM.

to 2CAN040703 Page 2 of 3 Justification of Exemption 10 CFR 50.12, "Specific exemptions," states that the NRC may grant exemptions from the requirements of the regulations of this part provided three conditions are met. The three conditions are: 1) the exemption is authorized by law; 2) the exemption will not present an undue risk to the health and safety of the public; and 3) the exemption is consistent with the common defense and security.

The requested exemption to allow the use of Optimized ZIRLOTM fuel rod cladding material rather than Zircaloy or ZIRLOTM for core reload applications at ANO-2 satisfies these criteria as described below.

1. This exemption Is authorized by law As required by 10 CFR 50.12 (a)(1), this requested exemption is "authorized by law." The selection of a specified cladding material in 10 CFR 50.46 and implied In 10 CFR Part 50, Appendix K, was adopted at the discretion of the Commission consistent with its statutory authority. No statute required the NRC to adopt this specification. Additionally, the NRC has the authority under Section 50.12 to grant exemptions from the requirements of Part 50 upon showing proper justification. Further, it should be noted that, by submitting this exemption request, ANO-2 does not seek an exemption from the acceptance and analytical criteria of 10 CFR 50.46 and 10 CFR Part 50, Appendix K. The Intent of the request Is solely to allow the use of criteria set forth in these regulations for application to the Optimized ZIRLOTm fuel rod cladding material.

2. This exemption will not present an undue risk to public health and safety The reload evaluations will ensure that acceptance criteria are met for the insertion of assemblies with fuel rods clad with Optimized ZIRLOTM. Fuel assemblies using Optimized ZIRLOT' fuel rod cladding will be evaluated using NRC approved analytical methods and plant specific models to address the changes In the cladding material properties. The safety analysis for ANO-2 is supported by site specific TSs. Reload cores are required to be operated In accordance with the operating limits specified In the TSs. Thus, the granting of this exemption request will not pose an undue risk to public health and safety.

3. This exemption is consistent with common defense and secudty As noted above, the exemption request is only to allow the application of the aforementioned regulations to an Improved fuel rod cladding material. All the requirements and acceptance criteria will be maintained. The special nuclear material in these assemblies is required to be handled and controlled in accordance with approved procedures. Use of full regions of Optimized ZIRLOTM fuel rod cladding in the ANO-2 core will not affect plant operations and Is consistent with common defense and security.

Special circumstances support the Issuance of an exemption 10 CFR 50.12(a)(2) states that the NRC will not consider granting an exemption to the regulations unless special circumstances are present. The requested exemption meets the special circumstances of 10 CFR 50.12(a)(2)(ii) which states that, "Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not to 2CAN040703 Page 3 of 3 necessary to achieve the underlying purpose of the rule." In this particular circumstance, application of the subject regulations is not necessary to achieve the underlying purpose of the rule.

10 CFR 50.46 Identifies acceptance criteria for ECCS performance at nuclear power plants.

Due to the similarities In the material properties of the Optimized ZIRLOTM and standard ZIRLOTM, the current ECCS analysis approach remains applicable. Westinghouse will perform evaluations of the ANO-2 core using approved LOCA methods to ensure that assemblies with Optimized ZIRLOTM fuel rod cladding material meet all LOCA safety criteria.

The intent of 10 CFR Part 50, Appendix K, paragraph I.A.5 is to apply an equation for rates of energy release, hydrogen generation, and cladding oxidation from a metal-water reaction that conservatively bounds all post-LOCA scenarios (i.e., the Baker-Just equation). Application of the Baker-Just equation has been demonstrated to be appropriate for the Optimized ZIRLOTM alloy (Reference 1). Due to the similarities in the composition of the Optimized ZIRLOTM and standard ZIRLOTM fuel rod cladding materials, the application of the Baker-Just equation will continue to conservatively bound all post-LOCA scenarios.

Conclusion The acceptance criteria and requirements of 10 CFR 50.46 and 10 CFR Part 50, Appendix K currently are limited in applicability to the use of fuel rods clad with Zircaloy or ZIRLOTM.

10 CFR 50.46 and 10 CFR Part 50, Appendix K do not appq to the proposed use of Optimized ZIRLOTM fuel rod cladding material since Optimized ZIRLO has a slightly different composition than Zircaloy or ZIRLOTm. With the approval of this exemption request, these regulations will be applied to Optimized ZIRLOWm.

In order to support the use of Optimized ZIRLOTM fuel rod cladding material, an exemption from the requirements of 10 CFR 50.46 and 10 CFR Part 50, Appendix K is requested. As required by 10 CFR 50.12, the requested exemption is authorized by law, does not present undue risk to public health and safety, and is consistent with common defense and security. Approval of this exemption request does not violate the underlying purpose of the rule. In addition, special circumstances do exist to justify the approval of an exemption from the subject requirements.

References

1. WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A "Optimized ZIRLOTM," July 2006

2. Letter dated June 10, 2005 from U.S. Nuclear Regulatory Commission to Mr. James A.

Gresham (Westinghouse), NFinal Safety Evaluation for Addendum 1 to Topical Report WCAP-1261 0-P-A and CENPD-404-P-A, "Optimized ZIRLOTm," (TAC No. M18041)

3. Letter dated January 4, 2007 from J. A. Gresham (Westinghouse) to U. S Nuclear Regulatory Commission, "SER Compliance with WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A "Optimized ZIRLOm," (Proprietary I Non-proprietary), LTR-NRC-07-1

Attachment 4 2CAN040703 List of Regulatory Commitments to 2CAN040703 Page 1 of I List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE (Check one) SCHEDULED ONE- CONTINUING COMPLETION COMMITMENT TIME COMPLIANCE DATE (If ACTION Required)

The reload process for ANO-2 will ensure the conditions and limitations of the NRC SER for Optimized ZIRLOTM as addressed In Attachment 1 x are met when a batch of Optimized ZIRLOTMA is implemented.

Entergy will confirm that Westinghouse will provide Confirmation additional confirmatory data associated with LTA will continue programs at other facilities prior to subseorent until average cycles of operation with Optimized ZIRLO fuel rod assembly cladding. bumup for the LTA programs at the other x facilities reach the licensed average fuel rod burnup limit for ANO-2 (60 GWDIMTU).