HNP-09-007, Supplement to Technical Specifications 5.6.13.a and 5.6.1.3.b - Incorporation of Updated Criticality Analyses to Reflect Removal of Credit for Boraflex in BWR Spent Fuel Spent Storage Racks

Supplement to Technical Specifications 5.6.13.a and 5.6.1.3.b - Incorporation of Updated Criticality Analyses to Reflect Removal of Credit for Boraflex in BWR Spent Fuel Spent Storage Racks

ML090230341
Person / Time
Site:	Harris
Issue date:	01/16/2009
From:	Burton C Progress Energy Carolinas, Progress Energy Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
HNP-09-007
Download: ML090230341 (16)

Text

& Progress Energy Christopher L Burton Vice President Harris Nuclear Plant Progress Energy Carolinas, Inc.

Serial: HNP-09-007 JAN1 6 2009 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 SUPPLEMENT TO TECHNICAL SPECIFICATIONS 5.6.1.3.a AND 5.6.1.3.b -

INCORPORATION OF UPDATED CRITICALITY ANALYSES TO REFLECT REMOVAL OF CREDIT FOR BORAFLEX IN BWR SPENT FUEL POOL STORAGE RACKS

Reference:

1. Letter from C. L. Burton to the Nuclear Regulatory Commission (Serial:

HNP-08-075), "Technical Specifications 5.6.1.3.a and 5.6.1.3.b -

Incorporation of Updated Criticality Analyses Reflect Removal of Credit For Boraflex in BWR Spent Fuel Pool Storage Racks," dated September 29, 2008

2. Email from M. G. Vaaler, Nuclear Regulatory Commission to K. Stacy, "Harris SFP Acceptance Review RI .doc," dated December 3, 2008 (Draft)

Ladies and Gentlemen:

In accordance with the Code of Federal Regulations, Title 10, Part 50.90, "Application for Amendment of License, Construction Permit, or Early Site Permit," Carolina Power & Light Company (CP&L) doing business as Progress Energy Carolinas, Inc. (PEC), submitted the above License Amendment Request for the Harris Nuclear Plant (HNP) (Reference 1). As a result of the NRC Acceptance Review of that request (Reference 2), HNP is submitting additional information via this supplement.

This document contains no regulatory commitments.

Please refer any questions regarding this submittal to D. H. Corlett at (919) 362-3137.

P*. Box 165 New Hill, NC 27562 T> 919.362.2502 Mo!

F> 919.362.2095

Serial: HNP-09-007 Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on JAN 16'2009 Sincerely, Christopher L. Burton Vice President Harris Nuclear Plant CLB/kms

Enclosure:

"Response to Acceptance Review Regarding Amendment to Remove Credit for Boraflex in BWR Spent Fuel Pool Storage Racks" cc:

Mr. J. D. Austin, NRC Sr. Resident Inspector, HNP Ms. B. 0. Hall, N.C. DENR Section Chief Mr. L. A. Reyes, NRC Regional Administrator, Region II Ms. M. G. Vaaler, NRC Project Manager, HINP

Enclosure to SERIAL: HNP-09-007 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 RESPONSE TO ACCEPTANCE REVIEW REGARDING AMENDMENT TO REMOVE CREDIT FOR BORAFLEX IN BWR SPENT FUEL POOL STORAGE RACKS Summary Progress Energy (licensee) submitted a license application to revise the Shearon Harris Nuclear Power Plant, Unit 1 (Harris) licensing basis to reflect the new spent fuel pool (SFP) criticality analysis performed for BWR spent fuel storage racks containing Boraflex. The licensee performed the new analysis removing credit for Boraflex as reactivity suppressor to address the degradation issues.

The staff completed the acceptance review of the application and finds that the information delineated below is necessary for the staff to conduct the detailed technical review.

1. PotentialError in TS Design Features,Figure 5.6-3:

There appearsto be an error in the equation included in Figure 5.6-3 of the TS Design Featuressection. Please correct, if applicable.

Response: The equation displayed on Technical Specification (TS) Figure 5.6-3 was in error and has been corrected. Attachment 3 of this Enclosure contains the corrected Figure 5.6-3 and the other retyped TS pages.

2. PotentialError in Table ] of HI-2043321."

There appears to be an error in Table ] of HI-2043321 for the value of "Maximum Keff' correspondingto the 2% enrichment case. Please correct, if applicable.

Response: This is an editorial error. Table 1 of HI-2043321 has been corrected and is included as page 13 of Attachment 2.

3. Boral MonitoringProgram:

The staff understands that when a BWRfuel assembly does not satisfy the proposed burnup credit requirements, it will be storedin a Boral rack Please describe the requirementsassociatedwith your Boral monitoringprogramand show how you comply with those requirements.

Response: Per the NRC/Progress Energy telephone conversation on December 17, 2008, it is understood that this question will be removed as an Acceptance Review item and presented as an RAI.

Page 1 of 7

Enclosure to SERIAL: HNP-09-007 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 RESPONSE TO ACCEPTANCE REVIEW REGARDING AMENDMENT TO REMOVE CREDIT FOR BORAFLEX IN BWR SPENT FUEL POOL STORAGE RACKS

4. CriticalityModel:

a) Figure 3 ofHI-2043321 shows the calculationalmodel of a "typical" storage cell. Is this model an approximation of the actual configuration? If so, please show the impact of the approximationon the calculatedreactivity.

Response: The storage cells are composed of stainless steel boxes, joined at the comers in an egg-crate structure. The external box side is equipped with a stainless steel sheathing which holds the Boraflex neutron absorber in place. These boxes are then arranged in a checkerboard pattern, where four storage cells form "developed cells" that can also store spent fuel assemblies.

The MCNP model is developed as shown in Figure 3 ofHI-2043321. All material thicknesses (stainless steel and water) are preserved and the Boraflex is completely neglected. Additionally, the storage cell pitch is modeled at 6.22 inches, conservatively reduced from the nominal storage cell pitch of 6.25 inches. These conservatisms would more than offset any small reactivity effect associated with the geometry modeling.

An additional MCNP4a calculation was performed with the storage cell box and stainless steel sheathing modeled explicitly.

Reactivity Effect of Geometr Model Geometry Calculated keff Sigma Figure 3 0.9576 0.0003 Explicit geometry 0.9585 0.0003 The results in the table show that the simplified geometry modeled in the main part of the report provides an accurate representation of the actual geometry. While the explicit geometry provides a slightly larger keff, the small increase would be offset by modeling the storage cell pitch at 6.25 inches.

A plot of the explicit geometry as created in MCNP4a is shown below:

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Enclosure to SERIAL: HNP-09-007 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 RESPONSE TO ACCEPTANCE REVIEW REGARDING AMENDMENT TO REMOVE CREDIT FOR BORAFLEX IN BWR SPENT FUEL POOL STORAGE RACKS Periodic Boundary Conditions 10 (D

0 o

0 0

B:

M rT 0

b) Consider a four assembly configurationwhere each assembly is loadedclosest to the common corner. Please explain how this configuration was modeled with a single cell model.

Response: The analysis presented in HI-2043321 considered a four assembly configuration where each assembly is loaded closest to a common corner. As shown in Figure 3 of HI-2043321, reflective boundary conditions are used on the periphery of the single cell model. This creates an infinite array of storage cells. By moving the assembly in the single storage cell model to the comer of the storage cell, an infinite array of storage cells is created with each cluster of four assemblies being placed closest to a common comer.

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Enclosure to SERIAL: HNP-09-007 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 RESPONSE TO ACCEPTANCE REVIEW REGARDING AMENDMENT TO REMOVE CREDIT FOR BORAFLEX IN BWR SPENT FUEL POOL STORAGE RACKS

5. Reference Fuel Design:

a. Please explain how the reactivity values in Table 7 ofHI-2043321 were calculated Are they based on CASMO or KENO calculations? State the assumed depletion parameters(void history, axial burnup distribution,burnable absorbers,control history) and demonstrate that the assumedparametersbound the actual operating history of these fuel assemblies.

Response: The reactivity values in Table 7 ofHI-2043321 were calculated using the CASMO-4 computer code. The table below provides details of the depletion parameters used in calculating the reactivities in Table 7 of HI-2043321:

Core Operating Parameter for CASMO-4 Depletion Analyses Parameter Analysis Value Reactor Value Reactor Specific Power, MW/MTU 30.0 26.7 max Core Fuel Temp., 'F 1038 818-936 Core Moderator Temp., 'F 548 548-560 In-Core Assembly Pitch, Inches 6.0 6.0 Void History 40% 37-45%

In the case of the reactor specific power and core fuel temperature, the analysis value exceeds the maximum value in the core by more than 10%. The core pitch is modeled in-line with the actual reactor core pitch. Meanwhile, the core moderator temperature and void history are modeled within the range of values within the reactor. The non-conservatism associated with the void history and core moderator temperature would be offset by the conservatism with modeling the reactor specific power and fuel temperature over 10% above their maximum value.

The axial burnup distribution is not considered in the determination of the reference (design basis) assembly, although the MCNP calculations to determine the maximum klff do consider the axial burnup distribution. See also the response to Question 6.

No burnable absorbers are considered in the determination of the reference assembly. The only burnable absorber in BWR fuel is Gadolinium, which is demonstrated in NUREG/CR-6760 to produce a negative reactivity effect when compared to an assembly without the Gadolinium.

Therefore, neglecting the integral burnable absorber is conservative.

No control rods are assumed in the depletion calculations.

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Enclosure to SERIAL: HNP-09-007 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 RESPONSE TO ACCEPTANCE REVIEW REGARDING AMENDMENT TO REMOVE CREDIT FOR BORAFLEX IN BWR SPENT FUEL POOL STORAGE RACKS

b. The application does not provide sufficient information to justify the use of GEl3 as the reference design when GE3 and GE4 show higher reactivity values. Please provide quantitative evidence showing that GE3 and GE4 assemblies residing in the spentfuel pool are bounded by the reference design. Consider the actual enrichments, burnups and cooling times for the GE3 and GE4 assemblies.

c. The application states that an enrichment of 4.6% and burnups between 35,000 and 42,500 MWD/MTU were assumedfor the reactivity calculations in Table 7 ofHI-2043321. Please demonstrate that the bounding design has been identified considering lower enrichments and lower burnup.

Response (5b & 5c): The table below presents calculations similar to those presented in Table 7 ofHI-2043321 for other burnup and enrichment combinations from Table 5 ofHI-2043321 and for longer cooling times.

Bumup GE3 GE3 GE4 GE4 GE7 GE7 GE8 GE9 GE10 GE13

[MWD/MTU] 4 26 4 23 4 12 4 4 4 4 years years years years years years years years years years Enrichment =2.0 wt% 2"sU 8,500 0.9753 0.9643 0.9700 0.9597 0.9676 0.9620 0.9644 0.9633 0.9504 0.9659 10,000 0.9563 0.9415 0.9510 0.9373 0.9482 0.9407 0.9447 0.9436 0.9307 0.9466 23 5 Enrichment = 3.0 wt% U 20,000 0.9710 0.9440 0.9660 0.9409 0.9644 0.9508 0.9623 0.9614 0.9470 0.9638 22,500 0.9427 0.9105 0.9378 0.9080 0.9353 0.9191 0.9326 0.9316 0.9173 0.9348 23 5 Enrichment = 4.0 wt% U 32,500 0.9448 0.9061 0.9402 0.9042 0.9388 0.9191 0.9374 0.9364 0.9213 0.9393 35,000 0.9197 0.8769 0.9152 0.8756 0.9129 0.8910 0.9107 0.9097 0.8947 0.9135 235 Enrichment = 4.6 wt% U 40,000 0.9283 0.8847 0.9241 0.8835 0.9227 0.9003 0.9216 0.9206 0.9167 0.9239 42,500 0.9047 0.8576 0.9008 0.8569 0.8984 0.8741 0.8964 0.8953 0.8912 0.8996 In the determination of the design basis assembly, no credit is taken for the actual burnup and enrichment of the older fuel assembly designs, i.e., GE3, GE4 and GE7. However, these fuel Page 5 of 7

Enclosure to SERIAL: HNP-09-007 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 RESPONSE TO ACCEPTANCE REVIEW REGARDING AMENDMENT TO REMOVE CREDIT FOR BORAFLEX IN BWR SPENT FUEL POOL STORAGE RACKS assemblies have significantly longer cooling times than the assumed four years credited in the analysis (26 years for GE3 assemblies, 23 years for the GE4 assemblies and 12 years for GE7 assemblies). The table above shows the reduction in reactivity associated with crediting the minimum cooling time for the GE3, GE4 and GE7 assemblies, and justifying the use of the GEl3 assembly with 4 years cooling as the design basis assembly.

The table above also shows that for lower enrichments, the GEl3 assembly has the highest reactivity when cooling time is considered for the GE3, GE4 and GE7 assemblies.

6. Axial Burnup Distribution:

a) The applicationstates, "Based on the level of conservatism inherent in choosing the axial burnup distributionin the manner describedabove it is not necessary to confirm that the axial burnup distributionsof individual assemblies are bounded by the assumed axial burnup distribution."

What do you mean by "inherent conservatism?"

Response: The axial bumup distribution is only relevant to calculations that credit an assembly average burnup greater than or equal to 20.5 GWD/MTU. As shown in the table on page 8 of HI-204333 1, a uniform (flat) profile produces bounding results for low bumups.

Therefore, for the low enrichment, low bumup points on the bumup versus enrichment curve, there is an inherent conservatism in the calculations associated with the use of the flat axial burnup distribution.

The axial burnup distribution presented in Table 6 of HI-2043321 is an average of 4 axial bumup distributions from Brunswick BWR assemblies with assembly average burnups between 34.0 GWD/MTU and 40.8 GWD/MTU. These four axial bumup distributions were representative of assemblies with an assembly average bumup near the minimum required bumup specified in Table 5 ofHI-2043321. It is not appropriate to choose axial bumup distributions from assemblies having an assembly average burnup below the burnup versus enrichment curve, as these would be significantly under-exposed assemblies (having experienced only two of their expected three cycles in the core) and not able to be stored in the Harris BWR Boraflex storage racks.

The "inherent conservatism" is in selecting axial burnup profiles from assemblies near the burnup versus enrichment curve and not including profiles from assemblies with much higher exposures. To confirm the "inherent conservatism", an additional calculation was performed using an axial bumup profile from an assembly having an average burnup of 45.88 GWD/MTU.

Both the results of the calculation and a comparison to the result from the axial bumup profile Page 6 of 7

Enclosure to SERIAL: HNP-09-007 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 RESPONSE TO ACCEPTANCE REVIEW REGARDING AMENDMENT TO REMOVE CREDIT FOR BORAFLEX IN BWR SPENT FUEL POOL STORAGE RACKS presented in Table 5 of HI-2043321 are shown in the table below. Both calculations were performed at a burnup of 42.5 GWD/MTU with an enrichment of 4.6 wt%.

Profile Table 5 YJM160 Assembly Burnup 37.51 45.88

[GWD/MTU]

Calculated keff 1 0.9560 0.8957 As can be seen from the table, the axial burnup distribution can have a significant effect on the reactivity of the system. Therefore, the use of the profile shown in Table 5 of HI-2043321 results in a conservative value for the reactivity of the Harris BWR racks.

7. In the application, the licensee is proposingto no longer credit Boraflexfor criticalityin Shearon Harris' BWR Boraflex storage racks in Pools A and B. Currently,the licensee is committed to periodic sampling of the Boraflex in the spent fuel pool as stated in their October 24, 1996 response to Generic Letter (GL) 96-04, "Boraflex Degradationin the Spent Fuel Pool Storage Racks ". However, it is not clear in the submittal whether the licensee is intending to continue the Boraflex MonitoringProgram.

a) Please clarify whether the existing Boraflex MonitoringProgramwill continue to be implemented Response: The Boraflex Monitoring Program will be discontinued upon implementation of the revised criticality analysis, which credits soluble boron instead of Boraflex as a reactivity suppressor.

Attachments:

1. Holtec Affidavit for Withholding of Proprietary Information

2. Holtec Report No. HI-2043321, Revision 5 (Proprietary)

3. Retyped Technical Specification Pages The assembly burnup for the burnup profile in Table 5 is an average of the assembly average burnups from the four assemblies selected to determine the axial burnup profile in Table 5.

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Enclosure to SERIAL: HNP-09-007 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 RESPONSE TO ACCEPTANCE REVIEW REGARDING AMENDMENT TO REMOVE CREDIT FOR BORAFLEX IN BWR SPENT FUEL POOL STORAGE RACKS ATTACHMENT 1 HOLTEC INTERNATIONAL AFFIDAVIT PURSUANT TO 10 CFR 2.390 (5 Pages)

m m m Holtec center,555 Lincoln Drive West, Marlton, NJ 08053 Telephone (856) 797-0900 H O LT EC INTERNATIONAL Fax (856) 797-0909 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk AFFIDAVIT PURSUANT TO 10 CFR 2.390 I, Debabrata Mitra-Majumdar, being duly sworn, depose and state as follows:

(1) I am the Holtec International Project Manager for the Harris Nuclear Plant BWR Racks Criticality Analysis project and have reviewed the information described in paragraph (2) which is sought to be withheld, and am authorized to apply for its withholding.

(2) The information sought to be withheld is Holtec Report HI-2043321 containing Holtec Proprietary information.

(3) In making this application for withholding of proprietary information of which it is the owner, Holtec International relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4) and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10CFR Part 9.17(a)(4), 2.390(a)(4), and 2.390(b)(1) for "trade secrets and commercial or financial information obtained from a person and privileged or confidential" (Exemption 4). The material for which exemption from disclosure is here sought is all "confidential commercial information", and some portions also qualify under the narrower definition of "trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992),

and Public Citizen Health Research Group v. FDA, 704F2d1280 (DC Cir.

1983).

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• * * *Holtec Center; 555 Lincoln Drive West, Marlton, NJ 08053 Telephone (856) 797-0900 H O LTE C INTERNATIONAL Fax (856) 797-0909 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk AFFIDAVIT PURSUANT TO 10 CFR 2.390 (4) Some examples of categories of information which fit into the definition of proprietary information are:

a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by Holtec's competitors without license from Holtec International constitutes a competitive economic advantage over other companies;

b. Information which, if used 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 of a similar product.

c. Information which reveals cost or price information, production, capacities, budget levels, or commercial strategies of Holtec International, its customers, or its suppliers;

d. Information which reveals aspects of past, present, or future Holtec International customer-funded development plans and programs of potential commercial value to Holtec International;

e. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs 4.a and 4.b, above.

(5) The information sought to be withheld is being submitted to the NRC in confidence. The information (including that compiled from many sources) is of 2 of 5

f MEEM Holtec Center, 555 Lincoln Drive West, Marlton, NJ 08053 Telephone (856) 797-0900 INTERNATIONAL' HFax (856) 797-0909 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk AFFIDAVIT PURSUANT TO 10 CFR 2.390 a sort customarily held in confidence by Holtec International, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by Holtec International. No public disclosure has been made, and it is not available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.

(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge.

Access to such documents within Holtec International is limited on a "need to know" basis.

(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his designee), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation.

Disclosures outside Holtec International are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

(8) The information classified as proprietary was developed and compiled by Holtec International at a significant cost to Holtec International. This information is classified as proprietary because it contains detailed descriptions of analytical 3 of 5

• M**M Holtec Center,;555 Lincoln Drive West, Marlton, NJ 08053 HFax Telephone (856) 797-0900 (856) 797-0909 INTERNATIONAL U.S. Nuclear Regulatory Commission ATTN: Document Control Desk AFFIDAVIT PURSUANT TO 10 CFR 2.390 approaches and methodologies not available elsewhere. This information would provide other parties, including competitors, with information from Holtec International's technical database and the results of evaluations performed by Holtec International. A substantial effort has been expended by Holtec International to develop this information. Release of this information would improve a competitor's position because it would enable Holtec's competitor to copy our technology and offer it for sale in competition with our company, causing us financial injury.

(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to Holtec International's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of Holtec International's comprehensive spent fuel storage technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology, and includes development of the expertise to determine and apply the appropriate evaluation process.

The research, development, engineering, and analytical costs comprise a substantial investment of time and money by Holtec International.

The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.

Holtec International's competitive advantage will be lost if its competitors are able to use the results of the Holtec International experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

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fl Holtec Center,'555 Lincoln Drive West, Marlton, NJ 08053 Telephone (856) 797-0900 H O0 L T E C INTERNATIONAL Fax (856) 797-0909 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk AFFIDAVIT PURSUANT TO 10 CFR 2.390 The value of this information to Holtec International would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive Holtec International of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing these very valuable analytical tools.

STATE OF NEW JERSEY )

) ss:

COUNTY OF BURLINGTON)

Dr. Debabrata Mitra-Majumdar, being duly sworn, deposes and says:

That he has read the foregoing affidavit and the matters stated therein are true and correct to the best of his knowledge, information, and belief.

Executed at Marlton, New Jersey, this 1 3 th day of January, 2009.

Deba ra aM umdar Holtec International Subscribed and sworn before me this /3 _ day of ,2009.

MARIA C. MASSI NOTARY PUBLIC OF NEW JERSEY 5 of 5 My Commission Expires April 25, 2010

Enclosure to SERIAL: HNP-09-007 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400/LICENSE NO. NPF-63 RESPONSE TO ACCEPTANCE REVIEW REGARDING AMENDMENT TO REMOVE CREDIT FOR BORAFLEX IN BWR SPENT FUEL POOL STORAGE RACKS ATTACHMENT 2 CRITICALITY SAFETY ANALYSES OF C AND D POOLS FOR BWR FUEL WITHOUT CREDIT FOR BORAFLEX IN THE RACKS AT THE HARRIS NUCLEAR POWER STATION Holtec Report No. HI-2043321 (Proprietary)

(53 Pages)