Text

Turkey Point, Units 3 and 4 - Fuel Storage Criticality Analysis
	ML102220022
Person / Time
Site:	Turkey Point
Issue date:	08/05/2010
From:	Kiley M; Florida Power & Light Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	L-2010-169, LAR 207
	Download: ML102220022 (44)
	v • d • e

0:PL. L-2010-169 POWERING TODAY. 10 CFR 50.90 EMPOWERING TOMORROW.*

August 5, 2010 U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, D.C. 20555-0001 Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 License Amendment Request No. 207 Fuel Storage Criticality Analysis

Reference:

(1) Brenda L. Mozafari (NRC) to J. A. Stall (FPL), "Issuance of Amendments Regarding Spent Fuel Pool Boraflex Remedy (TAC Nos. MC9740 and MC974 1)," July 17, 2007 In accordance with the provisions of 10 CFR 50.90, Florida Power and Light Company (FPL)requests that Appendix A of Renewed Facility Operating Licenses DPR-31 and DPR-41 for Turkey Point Units 3 and 4 be amended to incorporate the enclosed Technical Specification (TS)revisions.

The proposed amendments would revise TS 5.5.1 Fuel Storage -Criticality, to include new spent fuel storage patterns that account for both the increase in fuel maximum enrichment from 4.5 wt% U-235 to 5.0 wt% U-235 and the impact on the fuel of higher power operation proposed under the Extended Power Uprate (EPU) project. Although the fuel storage has been analyzed at the higher fuel enrichment in the new criticality analysis, the fuel enrichment limit of 4.5 wt% U-235 specified in TS 5.5.1 will not be changed under this license amendment request.The proposed TS changes and a new supporting criticality analysis are being submitted to revise the current licensing basis analysis for both new fuel and spent fuel pool storage.The proposed TS changes are based on the results of a new criticality analysis provided in Attachment 4, "Turkey Point Units 3 and 4 New Fuel Storage Rack and Spent Fuel Pool Criticality Analysis," WCAP- 1 7094-P, Rev 2, dated July 2010, that was performed, in part, to support the proposed EPU for Turkey Point Units 3 and 4. The analysis addresses the depletion of EPU fuel, which is more reactive at the same burnup than the fuel depleted under current operating conditions, as well as conservatively revising the uncertainty assumptions used in the evaluation methodology.

The Spent Fuel Pool Boraflex Remedy approved under Amendments 234 and 229 for Units 3 and 4, respectively, as described in Reference 1, is in the process of being implemented for both units and is assumed to be implemented in this analysis.The Enclosure to this letter contains a description of the proposed changes and their supporting justifications including a no significant hazards determination and environmental considerations.

The Attachments to the Enclosure are as follows: Attachment 1 contains the approved Amendment 234 and 229 TS pages marked-up to show the proposed changes.an FPL Group company Turkey Point Nuclear Plant L-2010-169 License Amendment Request No. 207 Page 2 of 3 Enclosure" Attachment 2 contains the non-proprietary version of the Westinghouse Topical Report, WCAP-17094-NP, Rev 2, Turkey Point Units 3 and 4 New Fuel Storage Rack and Spent Fuel Pool Criticality Analysis, dated July 2010.* Attachment 3 contains the application for withholding the proprietary information contained in the WCAP-17094-P, Rev 2, Attachment 4, from public disclosure." Attachment 4 contains the proprietary version of the Westinghouse Topical Report, WCAP-17094-P, Rev 2, Turkey Point Units 3 and 4 New Fuel Storage Rack and Spent Fuel Pool Criticality Analysis, dated July 2010.As Attachment 4 contains information proprietary to Westinghouse Electric Company, LLC (Westinghouse), it is supported by the Attachment 3 affidavit signed by Westinghouse, the owner of the information.

The affidavit sets forth the basis for which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b) (4) of § 2.390 of the Commission's' regulations.

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

Correspondence with respect to the copyright or proprietary aspects of the items provided in Attachment 4 of this letter in WCAP-17094-P, Rev 2 or the supporting Westinghouse affidavit should reference CAW-10-2895 and should be addressed to J. A. Gresham, Manager, Regulatory Compliance and Plant Licensing, Westinghouse Electric Company LLC, P.O. Box 355, Pittsburgh, PA 15230-0355.

The Turkey Point Plant Nuclear Safety Committee (PNSC) has reviewed the proposed license amendments.

In accordance with 10 CFR 50.91(b)(1), a copy of this letter is being forwarded to the State Designee of Florida.The proposed TS changes have been evaluated in accordance with 10 CFR 50.91(a)(1), using the criteria in 10 CFR 50.92(c).

FPL has determined that the proposed TS changes do not involve a significant hazards consideration.

The proposed license amendments change requirements with respect to the use of a facility component located within the restricted area as defined in 10 CFR Part 20. FPL has determined that the proposed amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and no significant increase in individual or cumulative occupational radiation exposure.

Therefore, FPL has concluded that the proposed amendments meet the criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and, pursuant to 10 CFR 51.22(b), an environmental impact statement or environmental assessment need not be prepared in connection with issuance of the amendments.

Turkey Point Nuclear Plant L-2010-169 License Amendment Request No. 207 Page 3 of 3 Enclosure This letter contains no new commitments and no revisions to existing commitments.

It is requested that issuance of this requested amendment be no later than December 31, 2011 prior to the Unit 3 Spring and Unit 4 Fall 2012 outages.Should you have any questions regarding this submittal, please contact Mr. Robert J. Tomonto, Licensing Manager, at (305) 246-7327.I declare under penalty of perjury that the foregoing is true and correct.Executed on August S4, 2010.Very truly yours, Michael Kiley Site Vice President Turkey Point Nuclear Plant Enclosure cc: USNRC Regional Administrator, Region II USNRC Project Manager, Turkey Point Nuclear Plant USNRC Senior Resident Inspector, Turkey Point Nuclear Plant Mr. W. A. Passetti, Florida Department of Health (w/o Attachment

4)

Turkey Point Nuclear Plant License Amendment Request No. 207 Enclosure L-2010-169 Page 1 of 17 Enclosure Turkey Point Units 3 and 4 License Amendment Request No. 207 Fuel Storage Criticality Analysis Turkey Point Nuclear Plant License Amendment Request No. 207 Enclosure L-2010-169 Page 2 of 17 1.0 2.0 3.0 4.0 5.0 6.0 7.0 8.0 9.0 10.0 TABLE OF CONTENTS LICENSE AMENDMENT REQUEST FUEL STORAGE CRITICALITY ANALYSIS SECTION TITLE Cover Sheet Table of Contents Purpose and Scope Background Information Description of Proposed Changes Basis/Justification of Proposed Changes List of Commitments Conclusion No Significant Hazards Determination Environmental Consideration Summary of Results References Technical Specification Marked Up Pages WCAP-17094-NP, Rev 2, Turkey Point Units 3 and 4 New Fuel Storage Rack and Spent Fuel Pool Criticality Analysis Westinghouse Affidavit WCAP- 1 7094-P, Rev 2, Turkey Point Units 3 and 4 New Fuel Storage Rack and Spent Fuel Pool Criticality Analysis PAGE 1 2 3 3 4 6 10 10 10 15 17 17 Attachment 1 Attachment 2 Attachment 3 Attachment 4 24 pages 135 pages 9 pages 135 pages Turkey Point Nuclear Plant L-2010-169 License Amendment Request No. 207 Page 3 of 17 Enclosure 1.0 Purpose and Scope Florida Power and Light Company (FPL) proposes to revise the Turkey Point (PTN)Units 3 and 4 licensing basis for spent fuel pools by amending Appendix A of Renewed Facility Operating Licenses DPR-31 and DPR-41 for Turkey Point Units 3 and 4 to incorporate the enclosed Technical Specification (TS) revisions.

The proposed TS changes and a new supporting criticality analysis are being submitted to revise the current licensing basis analysis for both new fuel and spent fuel pool storage.The proposed amendments will revise TS 5.5.1 Fuel Storage -Criticality, to include new spent fuel pool storage patterns that account for both the increase in fuel maximum enrichment from 4.5 wt% U-235 to 5.0 wt% U-235 and the impact on the fuel of the higher power operation proposed under the Extended Power Uprate (EPU) project.Although the fuel storage has been analyzed at the higher fuel enrichment in the new criticality analysis, the fuel enrichment limit of 4.5 wt% U-235 specified in TS 5.5.1 will not be changed under this license amendment request. The licensing basis for the spent fuel pools will reflect the new criticality analysis performed by Westinghouse, WCAP-17094-P, Rev 2, Turkey Point Units 3 and 4 New Fuel Storage Rack and Spent Fuel Pool Criticality Analysis, July 2010.2.0 Background Information As described in Section 9.5.2 of the Updated Final Safety Analysis Report (UFSAR), spent fuel storage is provided by a spent fuel pool for each unit located at opposite ends of the Auxiliary Building.

Each spent fuel pool is designed for underwater storage of up to 1535 spent fuel assemblies (approximately 9 full cores) and miscellaneous fuel handling tools. The spent fuel pool is designed to store both fresh and burned fuel. The spent fuel pool uses a Distinct Zone Two Region rack design. Region I can accommodate 286 fresh fuel assemblies and Region II can store 1118 fuel assemblies.

In addition, a removable cask area rack can store 131 fuel assemblies with a maximum fuel enrichment of 4.5 wt%U-235. Criticality of fuel assemblies in the fuel storage racks is prevented by the design of the racks which limits fuel assembly interaction.

This is done by fixing the minimum separation between fuel assemblies and/or placing absorber panels between storage cells.The spent fuel storage racks are free-standing, seismically qualified components composed of individual storage cells made of stainless steel that are wrapped with a neutron absorbing material.The spent fuel storage racks are designed to maintain subcritical conditions with a k~ff of less than 1.0 with unborated water in the spent fuel pit or with a keff of less than or equal to 0.95 with a specified level of soluble boron. The process of fuel handling and storage in the spent fuel pool is controlled administratively by procedure.

However, as the possibility of spent fuel mislocation or misorientation exists, criticality analyses have Turkey Point Nuclear Plant L-2010-169 License Amendment Request No. 207 Page 4 of 17 Enclosure been conducted for the most limiting cases to assure that any consequences are accommodated by the design.License Amendment Request No. 178, Spent Fuel Pool Boraflex Remedy, was submitted to the NRC on January 27, 2006 in order to eliminate the need to credit BoraflexTM neutron absorbing material for reactivity control in the spent fuel pools through use of analyzed new spent fuel storage patterns and Metamic Mrack inserts [Reference 1]. The MetamicTM inserts are manufactured in the shape of an "L" and, when inserted, blanket two of the four walls of the host storage cell. MetamicTM neutron absorber material is a metal matrix composite consisting of a matrix of 6061 aluminum alloy reinforced with Type 1 ASTN C-750 boron carbide. The MetamicTM inserts are being installed into selected spent fuel pit rack cells and establish allowed spent fuel storage configurations based on assembly initial enrichment, burnup and post-irradiation cooling times. License Amendments 234 and 229 were issued by the NRC on July 17, 2007 and will affect TS Section 3/4 9.1, "Boron Concentration," Section 3/4 9.14, "Spent Fuel Storage," and Section 3/4 5.5.1, "Fuel Storage Criticality" [Reference 2]. The reactivity control function credited to the BoraflexTM neutron absorbers, in the Unit 3 and 4 spent fuel pool storage racks, will be performed by a combination of rod cluster control assemblies (RCCAs), MetamicTM rack inserts, and administrative controls that require mixing higher reactivity fuel with lower-reactivity fuel. Implementation of this Boraflex Remedy is in progress and expected to be fully implemented by the end of 2010.3.0 Description of Proposed Changes The proposed TS changes are based on the attached Westinghouse Spent Fuel Pool Criticality Analysis that was completed to support the proposed EPU for Turkey Point Units 3 and 4. See Attachment 4, WCAP-17094-P, Rev 2, Turkey Point Units 3 and 4 New Fuel Storage Rack and Spent Fuel Pool Criticality Analysis, dated July 2010. The analysis accounts for the increase in the fuel maximum enrichment from 4.5 wt% U-235 to 5.0 wt% U-235 and the impact on the fuel of higher power operation at EPU conditions, e.g., the depletion of fuel at higher EPU conditions that results in the fuel being more reactive at the same burnup than the fuel depleted under current operating conditions, that are proposed under the EPU project. Although the fuel storage has been analyzed at the higher fuel enrichment in the new criticality analysis, the fuel enrichment limit of 4.5 wt% U-235 specified in TS 5.5.1 will not be changed under this license amendment request. The analysis also conservatively revises the uncertainty assumptions used in the evaluation methodology The Spent Fuel Pool Boraflex Remedy approved under Amendments 234 and 229, as described in Reference 1, is in the process of being implemented for both units and is assumed to be implemented in this new analysis.As indicated in Section 2.0 above, each unit's Spent Fuel Pool consists of the permanent Region I and Region II racks and the removable cask area rack. The existing Region I and II racks have been evaluated for the placement of fuel with new allowable storage Turkey Point Nuclear Plant L-2010-169 License Amendment Request No. 207 Page 5 of 17 Enclosure configurations.

Consistent with the storage patterns in License Amendment No. 234 (Unit 3) and No. 229 (Unit 4), the evaluation credits neutron absorber inserts placed into the Region II racks to partially offset an assumed full loss of the Boraflex.

In the analysis, credit is taken for the negative reactivity associated with burnup and post-irradiation cooling time. Additionally, credit is taken for the presence of soluble boron in the spent fuel pool and for the presence of full-length RCCAs placed in selected fuel assemblies.

The presence of Integrated Fuel Burnable Absorber (IFBA) rods is also credited for certain fresh fuel evaluations.

The analysis considered fuel placement under both normal and all postulated accident conditions.

The following changes to the current licensing basis, i.e., differences between the Spent Fuel Pool Boraflex Remedy Analysis and WCAP- 1 7094-P, are provided here:* Assumes storage of fuel assemblies with a maximum enrichment of 5.0 wt % U-235* Assumes fuel burnup under EPU operating conditions (2644 MWt)* Addresses issues raised by NRC on industry LARs up to time of analysis, including: " Depletion uncertainty in unborated calculations" Benchmark statistical analysis follows NUREG/CR-6361 and NUREG/CR-6698" Code benchmark includes HTC experiments" Target keff values reduced by 0.005 Ak Accordingly, the following is a summary of the changes that are proposed to the PTN TS.Justification for these proposed changes is provided in Section 4.2. See Attachment 1 for marked-up TS pages of these changes.5.5.1.1 Design Features -(Spent) Fuel Storage -Criticality.

The minimum boron concentration in the spent fuel pool required to maintain keff for all permissible fuel storage arrangements less than or equal to 0.95 under normal conditions is reduced from 650 ppm to 500 ppm.5.5.1.3 Design Features -(Spent) Fuel Storage -Criticality.

Storage requirements are defined for EPU fuel that consider the higher allowable fuel assembly enrichment and the higher reactivity of the fuel operated at EPU conditions.

Table 5.5-1 Tables completely revised and reduced to two pages.Table 5.5-2 Tables completely revised and reduced to two pages.Table 5.5-3 Table completely revised.Figure 5.5-1 Figure completely revised.Figure 5.5-2 Figure completely revised and expanded to two pages.Figure 5.5-3 Figure completely revised.

Turkey Point Nuclear Plant L-2010-169 License Amendment Request No. 207 Page 6 of 17 Enclosure Figure 5.5-4 Figure completely revised.To provide more specific description of the proposed changes, TS mark-ups are provided in Attachment

1. An item-by-item description is provided below along with a brief justification for each change.4.0 Basis/Justification for the Proposed Changes 4.1 Methodology/Assumption Changes Between Boraflex Remedy and WCAP Analyses The new WCAP- 17094-P criticality analysis was conducted to support the proposed EPU which has two major impacts on the criticality analysis:

(1) The fuel maximum enrichment will be increased from 4.5 wt% U-235 to 5.0 wt% U-235 and (2) the depletion of fuel at the EPU conditions results in the fuel being more reactive at the same burnup than fuel depleted under current conditions.

This is due to the higher fuel and moderator temperatures that result in a harder neutron spectrum, resulting in more plutonium production.

The analysis also revises several aspects of the current licensing basis method of analysis including the benchmark statistical methodology, the depletion uncertainty for the unborated calculations, and benchmarking of the analysis including the Haut Taux de Combustion (HTC) experiments.

In all cases, the maximum klff calculated was less than 0.995 for margin to the 1.0 limit. For cases that include soluble boron, the maximum keff calculated is less than 0.945 for margin to the 0.95 limit.4.2 Changes to the PTN Operating Licenses and Technical Specifications 4.2.1 Technical Specification 5.5.1 Fuel Storage -Criticality Approved TS 5.5.1.1 The spent fuel storage racks are designed and shall be maintained with: b. A keff less than or equal to 0.95 when flooded with water borated to 650 ppm, which includes an allowance for biases and uncertainties as described in UFSAR Chapter 9.c. A nominal 10.6 inch center-to-center distance for Region I and 9.0 inch center-to-center distance for Region II for the two region spent fuel pool storage racks. A nominal 10.1 inch center-to-center distance in the east-west direction and a nominal 10.7 inch center-to-center distance in the north-south direction for the Region I cask area storage rack.f. Fresh or irradiated fuel assemblies not stored in the cask area storage rack shall be stored in accordance with Specification 5.5.1.3 or configurations that have been shown to comply with Specification 5.5.1.1 a and 5.5.1.1 b using the NRC approved methodology in UFSAR Chapter 9.

Turkey Point Nuclear Plant L-2010-169 License Amendment Request No. 207 Page 7 of 17 Enclosure Proposed TS 5.5.1.1 The spent fuel storage racks are designed and shall be maintained with: b. A klff less than or equal to 0.95 when flooded with water borated to 500 ppm, which includes an allowance for biases and uncertainties as described in UFSAR Chapter 9.c. A nominal 10.6 inch center-to-center distance for Region I and 9.0 inch center-to-center distance for Region II for the two region spent fuel pool storage racks. A nominal 10.1 inch center-to-center distance in the east-west direction and a nominal 10.7 inch center-to-center distance in the north-south direction for the cask area storage rack.f. Fresh or irradiated fuel assemblies not stored in the cask area storage rack shall be stored in accordance with Specification 5.5.1.3 or configurations that have been shown to comply with Specification 5.5.1.1 a and 5.5.1.1 b using NRC approved methodology in UFSAR Chapter 9.Basis for the Change: Technical Specification 5.5.1.1 .b is updated to reflect analyses showing that kaf for all permissible fuel storage arrangements is less than or equal to 0.95 under normal and accident conditions when the storage racks are assumed to be flooded with borated water of a minimum boron concentration of 500 ppm. Technical Specification 5.5.1.1 .c is modified to remove the characterization of the cask area storage rack as a Region I rack. Analyses demonstrate that the interface requirements between Region I and Region II are not applicable to the cask area storage rack.

Turkey Point Nuclear Plant L-2010-169 License Amendment Request No. 207 Page 8 of 17 Enclosure 4.2.2 Technical Specification 5.5.1 Fuel Storage -Criticality (continued)

Approved TS 5.5.1.3 Credit for burnup and cooling time is taken in determining acceptable placement locations for spent fuel in the two-region spent fuel racks. Fresh or irradiated fuel assemblies shall be stored in compliance with the following:

a. Any 2x2 array of Region I storage cells containing fuel shall comply with the storage patterns in Figure 5.5-1 and the requirements of Table 5.5-1 and 5.5-2, as applicable.

The reactivity rank of fuel assemblies in the 2x2 array (rank determined using Table 5.5-3) shall be equal to or less than that shown for the 2x2 array.b. Any 2x2 array of Region II storage cells containing fuel shall: i. Comply with the storage patterns in Figure 5.5-2 and the requirements of Table 5.5-1 and 5.5-2, as applicable.

The reactivity rank of fuel assemblies in the 2x2 array (rank determined using Table 5.5-3) shall be equal to or less than that shown for the 2x2 array.c. Any 2x2 array of Region II storage cells that interface with Region I shall comply with the rules of Figure 5.5-3. Arrays II-E and II-F may interface with Region I without special restriction.

d. Any 2x2 array of Region II storage cells may adjoin a row of assemblies with a reactivity rank of 11-2 (or lower) that is located in the outer row adjacent to the spent fuel pit wall. The outer row of reactivity rank 11-2 (or lower) fuel assemblies need not contain any Metamic inserts or full length RCCAs, as long as the following additional requirements are met: i. Fuel is loaded to comply with the allowable storage patterns defined in Figure 5.5-4, and ii Arrays II-E and II-F are loaded without any additional restriction on that 2x2 array. Arrays II-E and II-F do not have empty cells, Metamic inserts, or RCCAs that restrict the interface with the adjoining reactivity rank 11-2 (or lower) fuel assemblies.

Turkey Point Nuclear Plant L-2010-169 License Amendment Request No. 207 Page 9 of 17 Enclosure Proposed TS 5.5.1.3 Credit for burnup and cooling time is taken in determining acceptable placement locations for spent fuel in the two-region spent fuel racks. Fresh or irradiated fuel assemblies shall be stored in compliance with the following:

a. Any 2x2 array of Region I storage cells containing fuel shall comply with the storage patterns in Figure 5.5-1 and the requirements of Table 5.5-1 and 5.5-2, as applicable.

The reactivity rank of fuel assemblies in the 2x2 array (rank determined using Table 5.5-3) shall be equal to or less reactive than that shown for the 2x2 array.b. Any 2x2 array of Region II storage cells containing fuel shall: i. Comply with the storage patterns in Figure 5.5-2 and the requirements of Table 5.5-1 and 5.5-2, as applicable.

The reactivity rank of fuel assemblies in the 2x2 array (rank determined using Table 5.5-3) shall be equal to or less reactive than that shown for the 2x2 array.c. Any 2x2 array of Region II storage cells that interface with Region I storage cells shall comply with the rules of Figure 5.5-3. Arrays II-E and II-F may interface with Region I without special restriction.

d. Any 2x2 array of Region II storage cells may adjoin a row of assemblies with a reactivity category of II-2b (or lower reactivity) that is located in the outer row adjacent to the spent fuel pit wall. The outer row of reactivity category II-2b (or lower reactivity) fuel assemblies need not contain any Metamic inserts or full length RCCAs, as long as the fuel is loaded to comply with the allowable storage patterns defined in Figure 5.5-4.Table 5.5-1 Tables completely revised and reduced to two pages.Table 5.5-2 Tables completely revised and reduced to two pages.Table 5.5-3 Table completely revised.Figure 5.5-1 Figure completely revised.Figure 5.5-2 Figure completely revised and expanded to two pages.Figure 5.5-3 Figure completely revised.Figure 5.5-4 Figure completely revised.Basis for the Change: Technical Specification 5.5.1.3.d is updated to reflect analysis results that revise the reactivity categorization of new and spent fuel assemblies, where former category 11-2 is further divided into categories II-2a, IT-Turkey Point Nuclear Plant L-2010-169 License Amendment Request No. 207 Page 10 of 17 Enclosure 2b, and II-2c. In addition, where Region II storage arrays are permitted to contain higher reactivity fuel assemblies adjacent to the spent fuel pit wall (taking advantage of neutron leakage at the wall boundary), additional requirements have been imposed via Figure 5.5-4 that consider the effect of adjacent interior arrays that further limit the reactivity category of the storage cells adjacent to the wall.4.3 Disposition of Recent SFP Submittals RAIs A review of NRC Requests for Additional Information (RAIs) received concerning the recent SFP submittals was performed.

The subjects of the RAIs that could be applicable to PTN Units 3 & 4 have been reviewed and incorporated in this LAR, as appropriate.

5.0 List of Commitments None 6.0 Conclusion The criticality analysis evaluated the different 2x2 storage arrays that are designed to accommodate both fresh fuel and spent discharged fuel. The analysis confirmed the acceptability of each storage array in the spent fuel pool and the appropriate limitations to be placed on the use of each array noting that fuel of lower reactivity, i.e., greater burnup, than the maximum allowable may be placed in an array. The analysis demonstrated that the effective neutron multiplication factor (keff) of all permissible fuel storage arrangements is less than 0.95 when the storage racks are assumed to be flooded with borated water. The analysis also demonstrated that the keff is less than 0.95 under all postulated accident conditions.

Finally, the analysis demonstrated that the keff of each fuel storage arrangement remains less than 1.0 when the pool is assumed to be flooded with unborated water.Although allowable fuel enrichment remains unchanged by this submittal, the analysis shows that fresh fuel of up to 5.0 wt% U-235 could be stored in the cask area rack under fully flooded conditions and meet the applicable acceptance criteria.

The analysis also confirms that fresh fuel assemblies up to 4.7 wt% U-235 or up to 5.0 wt% U-235 with 16 or more IFBA rods or an equivalent amount of other burnable absorber could be placed anywhere in the new fuel storage rack.The analysis also demonstrated that a fuel rod basket can be placed in any fuel storage cell and in any region without restrictions.

7.0 No Significant Hazards Determination The Commission has provided standards in 10 CFR 50.92(c) for determining whether a significant hazards consideration exists. A proposed amendment to an operating license Turkey Point Nuclear Plant L-2010-169 License Amendment Request No. 207 Page 11 of 17 Enclosure for a facility involves no significant hazard if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.The proposed license amendments to Renewed Facility Operating Licenses DPR-31 for Turkey Point Unit 3 and DPR-41 for Turkey Point Unit 4 will revise the Technical Specifications to eliminate the current spent fuel pool storage patterns and replace them with new spent fuel pool storage patterns.

The new patterns use a combination of rod control cluster assemblies, borated aluminum (Metamic) rack inserts, and administrative controls that require dispersing higher reactivity fuel to achieve acceptable neutron multiplication.

The supporting WCAP criticality analysis addresses the safe storage of new and spent fuel with a maximum fuel enrichment of up to 5.0 wt% U-235. The radiological dose consequences associated with fuel enrichment at this level have been addressed in LAR 196 on Alternative Source Term implementation at EPU conditions (Reference 3). However, the maximum fuel enrichment for both new and spent fuel storage currently allowed by Technical Specifications will not be changed by this LAR.The introduction of Metamic rack inserts into the spent fuel pool and the increased fuel handling required to achieve new fuel storage configurations using these inserts were previously addressed in the Boraflex Remedy LAR (Reference 1). The design and operational considerations upon which the previous evaluation was based are reiterated below and the conclusions have not changed as a result of the proposed amendment.

FPL has reviewed this proposed license amendment for FPL's Turkey Point Units 3 and 4 and determined that its adoption would not involve a significant hazards consideration.

The bases for this determination are: The proposed amendment does not involve a significant hazards consideration for the following reasons: 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

No. The proposed amendments do not change or modify the fuel, fuel handling processes, fuel storage racks, number of fuel assemblies that may be stored in the spent fuel pool (SFP), decay heat generation rate, or the spent fuel pool cooling and cleanup system. The proposed amendment was evaluated for impact on the following previously evaluated events and accidents:

a. A fuel handling accident (FHA), b. A cask drop accident, Turkey Point Nuclear Plant L-2010-169 License Amendment Request No. 207 Page 12 of 17 Enclosure c. A fuel mispositioning event, d. A spent fuel pool boron dilution event, e. A seismic event, and f. A loss of spent fuel pool cooling event Although the proposed amendment will required increased handling of the fuel, the probability of a FHA is not significantly increased because the implementation of the proposed amendment will employ the same equipment and process to handle fuel assemblies that is currently used. Also, tests have confirmed that the Metamic inserts can be installed and removed without damaging the host fuel assemblies.

The FHA radiological dose consequences associated with fuel enrichment at this level were addressed in LAR 196 on Alternative Source Term implementation at EPU conditions (Reference

3) and remain unchanged.

Therefore, the proposed amendments do not significantly increase the probability or consequences of a FHA.The proposed amendments do not increase the probability of dropping a fuel transfer cask because they do not introduce any new heavy loads to the SFP and do not affect heavy load handling processes.

Also, the insertion of Metamic rack inserts does not increase the consequences of the cask drop accident because the radiological source term of that accident is developed from a non-mechanistically derived quantity of damaged fuel stored in the spent fuel pool. Therefore, the proposed amendments do not significantly increase the probability or consequences of a cask drop accident.Operation in accordance with the proposed amendment will not change the probability of a fuel mispositioning event because fuel movement will continue to be controlled by approved fuel handling procedures.

These procedures continue to require identification of the initial and target locations for each fuel assembly that is moved. The consequences of a fuel mispositioning event are not changed because the reactivity analysis demonstrates that the same subcriticality criteria and requirements continue to be met for the worst-case fuel mispositioning event. (See Attachment 4)Operation in accordance with the proposed amendment will not change the probability of a boron dilution event because the systems and events that could affect spent fuel pool soluble boron are unchanged.

The consequences of a boron dilution event are unchanged because the proposed amendment reduces the soluble boron requirement below the currently required value and the maximum possible water volume displaced by the inserts is an insignificant fraction of the total spent fuel pool water volume.Operation in accordance with the proposed amendment will not change the probability of a seismic event. The consequences of a seismic event are not significantly increased because the forcing functions for seismic excitation are not increased and because the mass of storage racks with Metamic inserts is not Turkey Point Nuclear Plant L-2010-169 License Amendment Request No. 207 Page 13 of 17 Enclosure appreciably increased.

Seismic analyses demonstrate adequate stress levels in the storage racks when inserts are installed.

Operation in accordance with the proposed amendment will not change the probability of a loss of SFP cooling event because the systems and events that could affect SFP cooling are unchanged.

The consequences are not significantly increased because there are no changes in the SFP heat load or SFP cooling systems, structures or components.

Furthermore, conservative analyses indicate that the current design requirements and criteria continue to be met with the Metamic inserts installed.

Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

No. The proposed amendments do not change or modify the fuel, fuel handling processes, fuel racks, number of fuel assemblies that may be stored in the pool, decay heat generation rate, or the spent fuel pool cooling and cleanup system. The effects of operating with the proposed amendment are listed below. The proposed amendments were evaluated for the potential of each effect to create the possibility of a new or different kind of accident: a. addition of inserts to the fuel storage racks, b. new storage patterns, c. additional weight from the inserts, d. insert movement above fuel, and e. displacement of fuel pool water by the inserts, Each insert will be placed between a fuel assembly and the storage cell wall, taking up some of the space available on two sides of the fuel assembly.

Tests confirm that the insert can be installed and removed without damaging the fuel assembly.Analyses demonstrate that the presence of the inserts does not adversely affect spent fuel cooling, seismic capability, or subcriticality.

The aluminum (alloy 6061) and boron carbide materials of construction have been shown to be compatible with nuclear fuel, storage racks and spent fuel pool environments, and generate no adverse material interactions.

Therefore, placing the inserts into the spent fuel pool storage racks cannot cause a new or different kind of accident.Operation with the proposed fuel storage patterns will not create a new or different kind of accident because fuel movement will continue to be controlled by approved fuel handling procedures.

These procedures continue to require identification of the initial and target locations for each fuel assembly that is moved. There are no Turkey Point Nuclear Plant L-2010-169 License Amendment Request No. 207 Page 14 of 17 Enclosure changes in the criteria or design requirements pertaining to fuel storage safety, including subcriticality requirements, and analyses demonstrate that the proposed storage patterns meet these requirements and criteria with adequate margins.Therefore, the proposed storage patterns cannot cause a new or different kind of accident.Operation with the added weight of the Metamic inserts will not create a new or different accident.

The net effect of the adding the maximum number of inserts is to add less than one percent to the weight of the loaded racks. Furthermore, the analyses of the racks with Metamic inserts installed demonstrate that the stress levels in the rack modules continue to be considerably less than allowable stress limits. Therefore, the added weight from the inserts cannot cause a new or different kind of accident.Operation with insert movement above stored fuel will not create a new or different kind of accident.

The insert with its handling tool weighs considerably less than the weight of a single fuel assembly.

Single fuel assemblies are routinely moved safely over fuel assemblies and the same level of safety in design and operation will be maintained when moving the inserts. Furthermore, the effect of a dropped insert to block the top of a storage cell has been evaluated in thermal-hydraulic analyses.Therefore, the movement of inserts cannot cause a new or different kind of accident.Whereas the installed rack inserts will displace a very small fraction of the fuel pool water volume and impose a very small reduction in operator response time to previously-evaluated SFP accidents, the reduction will not promote a new or different kind of accident.

Also, displacement of water along two sides of a stored fuel assembly may have some local reduction in the peripheral cooling flow; however, this effect would be small compared to the flow induced through the fuel assembly and would in no way promote a new or different kind of accident.The accidents and events previously analyzed and presented in the Boraflex Remedy and Alternative Source Term LARs remain bounding.

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

3. Does the proposed amendment involve a significant reduction in the margin of safety?No. The proposed change was evaluated for its effect on current margins of safety as they relate to criticality, structural integrity, and spent fuel heat removal capability.

The margin of safety for subcriticality required by 10 CFR 50.68 (b) (4) is unchanged.

New criticality analysis confirms that operation in accordance with the proposed amendment continues to meet the required subcriticality margins.

Turkey Point Nuclear Plant L-2010-169 License Amendment Request No. 207 Page 15 of 17 Enclosure The structural evaluations for the racks and spent fuel pool with Metamic inserts installed show that the rack and spent fuel pool are unimpaired by loading combinations during seismic motion, and there is no adverse seismic-induced interaction between the rack and Metamic inserts.The proposed change does not affect spent fuel heat generation or the spent fuel pool cooling systems. A conservative analysis indicates that the design basis requirements and criteria for spent fuel cooling continue to be met with the Metamic inserts in place, and displacing coolant. Thermal hydraulic analysis of the local effects of an installed rack insert blocking peripheral flow show a small increase in local water and fuel clad temperatures, but will remain within acceptable limits including no departure from nucleate boiling.Therefore, the proposed changes do not involve a significant reduction in the margin of safety.Based on the above discussion, FPL has determined that the proposed change does not involve a significant hazards consideration.

8.0 Environmental Consideration 10 CFR 51.22(c)(9) provides criteria for and identification of licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment.

A proposed amendment of an operating license for a facility requires no environmental assessment, if the operation of the facility in accordance with the proposed amendment does not: (1) involve a significant hazards consideration, (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, and (3) result in a significant increase in individual or cumulative occupational radiation exposure.

FPL has reviewed this LAR and determined that the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of this amendment.

The basis for this determination follows.Basis This change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) for the following reasons: 1. As demonstrated in the 10 CFR 50.92 evaluation, the proposed amendment does not.involve a significant hazards consideration.

2. The proposed amendment does not result in a significant change in the types or increase in the amounts of any effluents that may be released offsite. Implementation Turkey Point Nuclear Plant L-2010-169 License Amendment Request No. 207 Page 16 of 17 Enclosure of the proposed project involves two activities that could produce some form of radiological effluent:

(1) spent fuel handling, and (2) insertion and removal of rack inserts. As many as several hundred spent fuel assemblies may be handled using established procedures, and several hundred Metamic rack inserts may also be installed at each unit. A modicum of solid low-level radioactive waste will be generated from the normal radiological waste generated from wipe-down of the above-water sections of the handling equipment during each fuel move, and protective clothing worn by personnel handling fuel. However, this quantity of waste is expected to be very small compared to that generated by a typical refueling outage.Otherwise, performing the fuel movement campaign and installing Metamic inserts is not expected to generate any gaseous or liquid effluent that would not otherwise be generated in the course of routine spent fuel pool operations over its lifetime.

For example, some waste filters may be generated as a result of vacuuming several hundred fuel assemblies to verify identification numbers; however, that waste and those operations would have to transpire sometime in the future anyhow. Installation and use of Metamic inserts is not expected to generate a significant amount of radwaste.

The installation may dislodge some crud/silt; however, the amount is expected to be no more than that created by a typical refueling.

The necessity for resin replacement of spent fuel pool purification media is determined primarily by the requirement for water clarity, which is not affected by the Metamic inserts. There is no mechanistic means to increase the volume of solid radioactive wastes due to the addition of Metamic inserts.3. The proposed amendment does not result in a significant increase in individual or cumulative occupational radiation exposure.

Implementation of the proposed amendments for each PTN unit will involve a several-month campaign of fuel movements and insert installations with personnel in the respective fuel handling building.

Aside from the modicum of individual and cumulative occupational radiation exposure resulting from that campaign, the proposed amendments will not result in any permanent effects that would increase occupational exposure.

The proposed fuel storage configurations and inserts do not fundamentally change the inventory or radiological source term of the spent fuel. In addition, based on FPL's experience with routine fuel movement campaigns during refueling outages and the fuel movement campaigns experienced during implementation of the Boraflex Remedy at St. Lucie, the cumulative exposure from the proposed activities is expected to be minimal.9.0 Summary of Results The criticality analysis evaluated the different 2x2 storage arrays that are designed to accommodate both fresh fuel and spent discharged fuel. The analysis confirmed the acceptability of each storage array in the spent fuel pool and the appropriate limitations to Turkey Point Nuclear Plant L-2010-169 License Amendment Request No. 207 Page 17 of 17 Enclosure be placed on the use of each array noting that fuel of lower reactivity, i.e., greater burnup, than the maximum allowable may be placed in an array. The analysis demonstrated that the effective neutron multiplication factor (kerr) of all permissible fuel storage arrangements is less than 0.95 when the storage racks are assumed to be flooded with borated water. The analysis also demonstrated that the keff is less than 0.95 under all postulated accident conditions.

Finally, the analysis demonstrated that the keff of each fuel storage arrangement remains less than 1.0 when the pool is assumed to be flooded with unborated water.Although allowable fuel enrichment remains unchanged by this submittal, the analysis show that fresh fuel of up to 5.0 wt% U-235 could be stored in the cask area rack under fully flooded conditions and meet the applicable acceptance criteria.

The analysis also confirms that fresh fuel assemblies up to 4.7 wt% U-235 or up to 5.0 wt% U-235 with 16 or more IFBA rods or an equivalent amount of other burnable absorber could be placed anywhere in the new fuel storage rack.The analysis also demonstrated that a fuel rod basket can be placed in any fuel storage cell and in any region without restrictions.

10.0 References

1. Terry 0. Jones (FPL) to U.S. Nuclear Regulatory Commission (L-2005-247), License Amendment Request No. 178 -Spent Fuel Pool Boraflex Remedy, January 27, 2006 2. Brenda L. Mozafari (NRC) to J. A. Stall (FPL), "Issuance of Amendments Regarding Spent Fuel Pool Boraflex Remedy (TAC Nos. MC9740 and MC974 1)," July 17, 2007 3. W. Jefferson (FPL) to U.S. Nuclear Regulatory Commission (L-2009-133), "License Amendment Request 196: Alternative Source Term and Conforming Amendment," June 25, 2009.

Turkey Point Nuclear Plant License Amendment Request No. 207 Enclosure L-2010-169 Attachment I Page 1 of 24 Attachment 1 Turkey Point Units 3 and 4 License Amendment Request No. 207 Fuel Storage Criticality Analysis Oneratina License and Technical Specifications Markups DESIGN FEATURES 5.5 FUEL STORAGE 5.5.1 CRITICALITY 5.5.1.1 The spent fuel storage racks are designed and shall be maintained with: a. A ken less than 1.0 when flooded with unborated water, which includes an allowance for biases and uncertainties as described in UFSAR Chapter 9.b. A kef less than or equal to 0.95 when flooded with water borated to 659 ppm, which includes an allowance for biases and uncertainties as described in UFSAR Chapter 9.c. A nominal 10.6 inch center-to-center distance for Region I and 9.0 inch center-to-center distance for Region II for the two region spent fuel pool storage racks. A nominal 10.1 inch center-to-center distance in the east-west direction and a nominal 10.7 inch center-to-center distance in the north-south direction for the Region-l-cask area storage rack.d. A maximum enrichment loading for fuel assemblies of 4.5 weight percent of U-235.e. No restriction on storage of fresh or irradiated fuel assemblies in the cask area storage rack.N f. Fresh or irradiated fuel assemblies not stored in the cask area storage rack shall be stored in accordance with Specification 5.5.1.3 or configurations that have been shown to comply with Specification 5.5.1 .la and 5.5.1.1 b using the NRC approved methodology in UFSAR Chapter-9.

5.5.1.2 The racks for new fuel storage are designed to store fuel in a safe subcritical array and shall be maintained with: a. A nominal 21 inch center-to-center spacingto assure kef equal to or less than 0.98 for optimum moderation conditions and equal to or less than 0.95 for fully flooded conditions.

b. Fuel assemblies placed in the New Fuel Storage Area shall contain no more than 4.5 weight percent of U-235.TURKEY POINT -UNITS 3 & 4 5-5 AMENDMENT NOS. 234-AND-2£-

DESIGN FEATURES 5.5.1.3 Credit for burnup and cooling time is taken in determining acceptable placement locations for spent fuel in the two-region spent fuel racks. Fresh or irradiated fuel assemblies shall be stored in compliance with the following:

a. Any 2x2 array of Region I storage cells containing fuel shall comply with the storage patterns in Figure 5.5-1 and the requirements of Table 5.5-1 and 5.5-2, as applicable.

The reactivity rank of fuel assemblies in the 2x2 array (rank determined using Table 5.5-3) shall be equal to or less than that shown for the 2x2 array. ie b. Any 2x2 array of Region II storage cells containing fuel shall: i. Comply with the storage patterns in Figure 5.5-2 and the requirements of Table 5.5-1 and 5.5-2, as applicable.

The reactivity rank of fuel assemblies in the 2x2 array (rank determined using Table 5.5-3) shall be equal to or less than that shown for the 2x2 array, lracive ii. Have the same directional orientation for Metamic inserts in a contiguous group of 2x2 arrays where Metamic inserts are required, iii. Comply with the requirements of 5.5.1.3.c for cells adjacent to Region I racks, and iv. Comply with the requirements of 5.5.1.3.d for cells adiacent to the spent fuel pit walls.storage cells c. Any 2x2 array of Region II storage cells that interface with Region I shall comply with the rules of Figure 5.5-3. Arrays II-E and Il-F may interface with Region I without special restriction.

d. iarray of ego storage cells may adjoin a row o assem lies with a reactivity ranat--11-2 (or lo t is located in the outer row adjacent to the spent fuel pit wall. T r row of reactivity rank 11-2 r fuel assemblies need not contain any Meta rts or full length RCCAs, as long as the follow itional, requirements are i. Fuel is loaded to comply with the allo atterns defined in Figure 5.5-4, and ii. Arrays ll-E and li-F aded without any additional restriction o x2 array. Arrays ll-E and II-F ave empty cells, Meta"ic inserts, or RCCAs that restrict t ce with the ning reactivity rank 11-2 (or lower) fuel assemblies.

DRAINAGE 5.5.2 The spent fuel storage pit is designed and shall be maintained to prevent inadvertent draining of the pool below a level of 6 feet above the fuel assemblies in the storage racks.CAPACITY 5.5.3 The spent fuel pool storage racks are designed and shall be maintained with a storage capacity limited to no more than 1404 fuel assemblies in two region storage racks, and the cask area storage rack is designed and/shall be maintained with a storage capacity limited to no more than 131 fuel assemblies.

The total spent fuel pool storage capacity is limited to no more than 1535 fuel assemblies.

Any 2x2 array of Region II storage cells may adjoin assemblies that are located in the outer row adjacent to the spent fuel pit wall. The outer row of fuel assemblies facing the pool wall need not contain any Metamic inserts or full length RCCAs, as long as the fuel is loaded to comply with the allowable storage patterns defined in Figure 5.5-4.TURKEY POINT -UNITS 3 & 4 5-6 AMENDMENT NOS. 234-AND 229 REPLACE TABLE 5.5-1 WITH THE NEXTTWO PAGES'C 0 z C z cj0 Table 5.5-1 3lanketed Fuel -Minimum Required Fuel Assembly Bumup (Bu) as a Function of Enrichment (En) and Cooling Time (Ct)See note 1 for use of Table 5.5-1 Fuel Blanketed Fuel Blanketed Fuel Category Storage Curve Coefficients' Minimum BurnupI (GWd/MTU r Initial Enrichmente A BC D E F G CTime3 2.5 w% 3.0 o6 3.3 w% 4.0 w% 4.5 w%IN N/A NIA NIA NIA N/A NIA N/A N/A I NIA NIA N/A NIA 1-2 18.8602 -1.090486 0.266387 -].000474496

-0.158563 0.00314739

-30.1637 0 .7 16.60 20.20 27.83 32.62___2.5 9.87 16.11 19.59 26.96 31.57 5 9.60 15.67 19.06 26.19 30.62_" \ ._1_ 0 9.18 14.98 18.20 24.94 29.10\ _/ 15 8.92 14.52 17.62 24.08 28.04"_____20 8.82 14.30 17.32 23.61 27.45 I1-1 16.2639 -0.712257 0.175883 -0.00399237

-0.166686

".370969 -19.5118 0 16.70 22.87 26.40 34.15 39.25 2.5 16.13 22.10 25.52 32.99 37.90 5 15.62 21.43 24.74 31.96 36.70 1____ 10 14.82 20.34 23.49 30.32 34.78 ,,,,- _ _ _15 14.27 19.61 22.65 29.23 33.50-t__' \ 20 13.99 19.24 22.22 28.67 32.85-11-2 14.46001-0.372732 0.132275 -0.0061710-0.187813 0.00526411

-12.8293 20.99 27.20 30.83 39.05 44.69___2.5__,20.19 26.18 29.68 37.59 43.02 5 -_5 "4.9.48 25.28 28.67 36.32 41.57 ,_, 10 18i_ 23.85 27.07 34.35 39.32_ __ __ _15 17.50 22.89 26.04 33.11 37.94 20 17.04 2,42 25.56 32.62 37.44 11-3 15.4624 -0.501 -0.06553 0.00160009

-0.161078 0.00340497

-11.2483 0 24.27 30.63 34.32 42.58 48.18__ _' 2.5 23.17 29.33 3 .1 40.90 46.31'" ' 5 22.19 28.18 31.65 39.41 44.65 10 20.60 26.32 29.63 370O 41.97 ,___ _15 19.53 25.05 28.25 35.3 40.13 20 18.96 24.38 27.51 34.47 14 (3>Im z m z z 0

0 A M z C z rn m z-I Table 5.5-1 (continued)

Blanketed Fuel -Minimum Required Fuel Assembly Burnup (Bu) as a Function of Enrichment (En) and Coolina Time (Ct)See note I for use of Table 5.5-1 Fuel ,Blanketed Fuel -Blanketed Fuel Category Storage Curve Coefficients' Minimum Burnup 1 (GWdIMTU)

Initial Enrichment2 A B D EF G Cooling Time3 2.5 w% 3.09o 3.3 w% 4.0 w% 4.5 w%11-4 15.3172 -0.444842

-0.11Q63 0.00273060

-0.162664 0.00344467

-9.1868 0 26.33 32.76 36.52 44.96 50.73 ,_ , 2.5 2 31.34 34.98 43.16 48.73 5 4.00 30.08 33.61 41.55 46.96 10 22.25 28.04 31.41 38.97 44.09 21.06 26.67 29.92 37.20 42.14 Zz _ 0 20.44 25.94 29.13 36.27 41.10 11-5 15.1701 -0.387768

-0.163521 0.00394514

-1644 0.00345174

-7.VY3 0 28.37 34.89 38.71 47.35 53.29 ,, _ 2.5 27.02 33.34 37.05 45.41 51.15 ,___5 25.82 31.97 35.57 43.69 49.26 ,_ _10 23.90 29.77 33.20 40.93 46.22 is_15 22.60 28.28 31.59 39.05 44.14_ 20 21.93 27.50 30.75 38.06 43.05 11-6 13.4516 -0.078364

-0.266734 0.00288411

-0$7006 0 z,.00446530

-3.3460"ý 0 29.79 36.30 40.19 49.21 55.60 ,/ ""-2k,5 28.30 34.64 38.42 47.20 53.42 5 26.97 33.17 36.87 45.45 51.53 10 ",24.86 30.85 34.43 42.73 48.61 15 23.,44 29.35 32.88 41.05 46.85 20 22.7' 28.66 32.20 40.41 46.23 11-7 13.7900 -0.086680

.-"55570 0.00574698

-0.145745 0.00426994

-2.0705 0 31.86 2 42.49 51.70 58.23_ __2.5 30.17 36.6 40.53 49.50 55.86 ,,._ __5 28.67 35.02 81 47.58 53.80__ 10 26.31 32.45 36.1,, 44.60 50.61 15 24.76 30.80 34.41 "-76 48.67 20 24.03 30.09 33.70 42.0 47.99 Table 0-.5-1-(contiud Blanketed Fuel -Minimum Required Fuel Assembly Burnu, (Bu) as a Function of Enrichment (En) and Cooling Time (Ct)See note 1 for use of Table 5.5-1 Fuel Blanketed Fuel Blanketed Fuel Category Storage Curve Coefficients' Minimum Burnup 1 (GWdlMTU) for [n ial Enrichmente A C D E F G Cooling 2.5 w% 3.0 w% .w% 4.0 w% 4.5 w%11-8 14.1212 -0.094"0-

-0.448138 0.00877894

-0.143511 0.00402944

-0.7808 0 33.93 474 44.80 54.20 60.86"_ 2.5 32.04 8.67 42.63 51.80 58.29__--_ "N 5 30._ _ 36.86 40.74 49.71 56.06_ __ "_ _10 12.75 34.04 37.79 46.47 52.61"-_ 15 26.07 32.25 35.94 44.47 50.51_ 25.34 31.51 35.19 43.71 49.75 Z Notes 1. All relevant uncertainties are explicitly included in the critica lysis. F ance, no additional allowance for burnup uncertainty is required.

For a fuel assembly to meet the requirements a Fuel Category, the a-sembly burnup must exceed the "minimum burnup" given in the table for the assembly "cooling time" and "initial e ichment." Alternatively, the s cific minimum burnup required for each fuel assembly may be calculated from the following equation:

B -A x En + B x En 2 + C x Ct + D x Ct Ct x En + F x Ct 2 x En + G. Only cooling times of 0, 2.5, 5, 10, 15 and 20 years may be use ithis equation.

Actual cooling time (Ct) is rou ed down to the nearest value.2. Nominal central zone U-235 enrichm : Axial blanket material is not considered when determining ichment.3. Cooling time in years.4. Fresh unburned fuel u o 4.5 w% U-235 enrichment:

No burnup is required.

INSERTS FOR TABLE 5.5-l (PAGE 1 of 2), Table 5.5-1 Blanketed Fuel -Coefficients to Calculate the Minimum Required Fuel Assembly Burnup (Bu) as a Function of Enrichment (En) 2 and Coolina Time (Ctj 3 See notes 1-5 for use of Table 5.5-1 Fuel Category 4, 5 Coefficients 1-3 I1-1 11-2a 11-2b 11-2c 11-3 Al 3.94 -36.24 -25.34 -16.44 -4.202 21.29 A2 -6.213 33.85 24.57 16.93 6.41 -17.14 A3 2.867 -8.995 -6.372 -4.233 -1.332 5.681 A4 -0.2985 0.8217 0.5852 0.3995 0.1507 -0.511 A5 0.5688 0.6421 0.4329 0.4518 0.4025 -0.03822 A6 -0.2571 -0.4493 -0.2863 -0.3209 -0.2906 0.1354 A7 0.03994 0.1171 0.07647 0.08887 0.08382 -0.04176 A8 -0.001656

-0.009999

-0.006719

-0.007952

-0.007768 0.00387 A9 -31.8 2.918 -5.612 -9.132 -13.37 -34.54 A10 23.25 -2.415 6.56 11.58 16.96 38.72 All -3.643 3.949 1.51 -0.0305 -1.535 -7.927 A12 0.3011 -0.4073 -0.1932 -0.04359 0.08915 0.6882 INSERTS FOR TABLE 5.5-1.(PAGE 2 of 2).Table 5.5-1 (continued)

Blanketed Fuel -Coefficients to Calculate the Minimum Required Fuel Assembly Burnup (Bu) as a Function of Enrichment (En) 2 and Cooling Time (Ct) 3 See notes 1-5 for use of Table 5.5-1 Fuel Category Coefficients 11-4 11-5 11-6 11-7 11-8 Al 29.37 35.19 23.04 22.79 19.2 A2 -24.3 -29.28 -16.54 -15.59 -11.38 A3 7.817 9.348 5.604 5.376 4.194 A4 -0.7103 -0.8568 -0.512 -0.4954 -0.3908 A5 -0.07327 -0.1466 -0.02031 -0.04904 -0.1143 A6 0.1728 0.2426 0.1193 0.1427 0.1799 A7 -0.05314 -0.07373 -0.03703 -0.04334 -0.04983 A8 0.004935 0.00686 0.00344 0.004006 0.004345 A9 -34.59 -34.09 -14.9 -10.19 -4.624 A10 40.5 41.96 26.55 23.93 19.79 All -8.566 -9.168 -4.793 -4.151 -2.908 A12 0.7586 0.8309 0.4338 0.3871 0.2749 Notes: 1. All 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 Category, the assembly burnup must exceed the "minimum burnup" (GWD/MTU) given by the curve fit for the assembly "cooling time" and "initial enrichment".

The specific minimum burnup required for each fuel assembly is calculated from the following equation: Bu = (A 1 + A 2*En + A 3*En 2 + A 4*En 3)* exp [ -(A 5 + A 6*En + A 7*En 2 + A8*En 3)*Ct]+ A 9 + A10*En + A11*En 2 + A 1 2*En 3 2. Initial enrichment, En, is the nominal central zone U-235 enrichment.

Axial blanket material is not considered when determining enrichment.

Any enrichment between 2.0 and 5.0 may be used.3. Cooling time, Ct, is in years. Any cooling time between 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and 25 years may be used. An assembly with a cooling time greater than 25 years must use 25 years.4. Category I-1 is fresh unburned fuel up to 5.0 wt% U-235 enrichment.

No burnup is required.Category 1-2 is fresh unburned fuel up to 4.7 wt% U-235 enrichment, fresh unburned fuel up to 5.0 wt% U-235 that contains at least 16 IFBA rods (or an equivalent amount of other burnable absorber), or fuel up to 5.0 wt% U-235 with no burnable absorber rods burned to at least 500 MWD/MTU. For fuel with 16 IFBA rods (or an equivalent amount of other burnable absorber), no burnup is required but any amount of burnup is allowed.5. This Table applies for any blanketed fuel assembly.

REPLACE TABLE 5.5-2 WITH THE NEXT TWO PAGES--I c m-<0 z-I c z-=rn 90 z m z-n z 0",, Table 5.5-2 Non-Blanketed Fuel -Minimum Required Fuel Assembly Burnup (Bu) as a Function of Enrichment (En) and Cooling Time (Ct)See note 1 for use of Table 5.5-2 Fuel Non-Blanketed Fuel Non-Blanketed Fue Category Storage Curve Coefficients 1 Minimum Burnup' (GWd/MTU) fo nitial Enrichment 2 A B C D E F G Cooling 1.8 2.5 4.0 3.5 4.0___ __D__FG Time 3 w% w 0/1/ w% w% w%1-1 N NIA N/A N/A N/A N/A N/A A N/A NIA N/A 1-2 18.1371 -0.944126 0.25312 -0.00553408

-0.151450 0.00334051

-29.3574 0 0.P-- 10.08 16.56 22.56 28.08 2.5 ,4.18 9.79 16.08 21.90 27.25 5 0.14 9.53 15.66 21.33 26.52 4__,6 0.08 9.11 14.99 20.40 25.34 15 0.05 8.84 14.55 19.79 24.56_, / 20 0.03 8.70 14.33 19.48 24.16 1I-1 11.9800 0.158287 0.237665 -0.00688305

-0.192M 0.0049203

-14.2029 0 7.87 16.74 23.16 29.67 36.25_.__2.5 7.62 16.16 22.36 28.64 35.00_ _5 7.38 15.66 21.66 27.75 33.91 10 6.99 14.85 20.56 26.35 32.22____7 15 6.69 14.31 19.85 25.46 31.16"___,,__20 6.49 14.04 19.53 25.10 30.74 11-2 11.8419 0.287918 0.113820 -0.005276

-0.175033 0.00507248

-9.9305 0 12.32 21.47 28.19 35.04 42.04 11.84 20.71 27.22 33.87 40.67 ,,/t 5 11.41 20.04 26.38 32.86 39.49/ " 10 -.69 18.98 25.07 31.30 37.68 ,____'_15

10. 0,, 18.28 24.25 30.37 36.63 ,_ _20 9.83 .96 23.94 30.06 36.32 11-3 12.6055 0.36W8 -0.075193 0.00118870

-0.152297 0.00386780

-8.6212 0 15.24 25.1 32.45 39.93 47.59_ 2.5 14.42 24.08 13,20 38.50 45.98/ _5 13.70 23.14 30.1 37.25 44.58// 10 12.56 21.68 28.41 32 42.41/ 15 11.83 20.76 27.35 34.1, 41.07__20 11.51 20.38 26.92 33.65 E o.5 6 C m-o 90 M z cn z I z 0 CO,... Table 5.5-2 (continued)

Non-Blanketed Fuel -Minimum Requlred Fuel Assembly Burnup (Bu) as a Function of Enrichment (En) and Cooling Time (Ct)See note I for use of Table 5.5-2 Fuel Non-Blanketed Fuel Non-Blanketed Fuel Category ____Storm es Curve Coefficients'

_____Minimum Bumnup' (GWd/MTU) to jiltiai Enrichment 2 Cooling 1.8 2.5 ,3.0 3.5 4.0 A Time 3 w% w% w% w% w%11-4 12.6130 0.436168 -"t28105 0.00275389

-0.151579 0.00377707

-7.0392 0 17.08 34.73 42.45 50.39 62.5 .16. 26.03 33.36 40.90 48.67______ ____ _____ ____________

____ 6.31 24.99. 32.16 39.56 47.17..! __ ,,,,,,,,-1810 14.02 23.37 30.31 37.46 44.83-IS- 13.21 22.36 29.15 36.16 43.39---"20 12.88 21.96 28.70 35.67 42.85 11-5 12.6086 0.517311 -0.185177 0.00442008-0.

482 0.00367344

-5,3438 0 19.03 29.41 37.14 45.12 53.37___ _- _ 2.5 17.96 28.09 35.64 43.45 51.52 6 5 17.02 26.94 34.34 42.00 49.91 10 15.57 25.16 32.32 39.73 47.41... ,,,_ ""__ 15 14.67 24.05 31.06 38.33 45.86 20 14.32 23.62 30.58 37.80 45.27 11-6 17.1055 -0.116940 0.024104 -0.00410005

-062366 0.00761230 -lO.!JL 0 19.67 31.30 39.53 47.70 55.81-,, 2.5 18.61 29.81 37.74 45.61 53.42___ 17.67 28.51 36.18 43.79 51.35__ .. ... .. .. .-__ _10 .16.15 26.47 33.77 41.01 48.20_.___15 44.11 25.18 32.30 39.36 46.36 2 14. 24.63 31.76 38.83 45.85 11-7 17.5099 -0.130912

.143634 0.00199657

-0.235656 0.00625103

-9,1041 0 21.99 -85 42.25 50.58 58.84 ,_.....' ..... _ .2.5 20.65 32.1 40.25 48.31 56.29___5 19.48 30.63 '"Q.51 46.33 54.08_ __ ,,,, ,1_ 10 17.64 28.29 36.b2,, 43.28 50.68__ ,, 15 16.45 26.83 34.16 1.42 48.62________" .__ ""_ _ _20 15.93 26.25 33.54 47.92 Table 5.5-2 (continued)

Non-Blanketed Fuel -Minimum Required Fuel Assembly Burnup (Bu) as a Function of Enrichment En and Coolin Time C See note 1 for use of Table 5.5-2 Fuel Non-Blanketed Fuel Non-Blanketef d1uel Category Storage Curve Coefficients 1 Minimum Burnupl (GWdll for Initial Enrichmente A B C D E F G Cooling 1.8 -3.0 3.5 4.0 Time 3 w% wA% W% w% w%11-8 17.9109 -0.143928

-0.302 7 0.00796481

-0.209912 0.00492410

-7.4704 0 24 36.41 44.97 53.45 61.87 2.5 T2.69 34.45 42.76 51.01 59.17"_ 5 21.29 32.75 40.85 48.87 56.82 ,"-fO " ,0 19.13 30.11 37.86 45.55 53.16"___ _ _15 17.80 28.48 36.01 43.48 50.88_. _ _20 17.31 27.86 35.30 42.68 49.98 Notes 1. All relevant uncertainties are explicitly included in the icality analysis.

instance, no additional allowance for burnup uncertainty is required.

For a fuel assembly to meet the require nts of a Fuel Category, th ssembly burnup must exceed the "minimum burnup" given in the table for the assembly "cooling time" and -i ial enrichment." Alternatively, th ecific minimum burnup required for each fuel assembly may be calculated from the following equal n: Bu = A x En + B x En2 + C x Ct + D x 2 + E x Ct x En + F x Ct 2 x En + G. Only cooling times of 0, 2.5, 5, 10, 15 and 20 years may sed in this equation.

Actual cooling time (Ct) is nded down to the nearest value.2. Nominal U-235

3. Cooling time in years 4. Fresh unirradia fuel up to 4.5 w 0/6 U-235 enrichment:

No burnup is required.

INSERTS FOR TABLE 5.5-2 (PAGE:,1 -of .2), Table 5.5-2 Non-Blanketed Fuel -Coefficients to Calculate the Minimum Required Fuel Assembly Burnup (Bu)as a Function of Enrichment (En) 2 and Cooling Time (Ct) 3 See notes 1-4 for use of Table 5.5-2 Fuel Category Coefficients 1-3 I1-1 11-2a il-2b 11-2c 11-3 Al -35.18 -10.95 -85.44 -41.76 -3.86 -30.33 A2 37.24 7.053 101.1 47.68 2.495 32.89 A3 -12.45 -0.5508 -34.92 -15.55 1.017 -9.444 A4 1.414 0 3.869 1.687 -0.2178 0.9173 A5 1.318 -0.5039 0.262 0.5439 1.056 0.5915 A6 -0.7817 0.3565 -0.2987 -0.6332 -1.204 -0.663 A7 0.13 -0.05129 0.107 0.2377 0.4525 0.2469 A8 -0.00307 0 -0.0111 -0.02719 -0.05352 -0.02849 A9 -21.4 -25.13 42.21 2.733 -7.353 14.57 A10 12.42 18.47 -62.25 -14.23 -1.402 -22.93 All -0.3007 -0.9294 27.68 11.17 7.4 14.27 A12 0.008347 0 -3.139 -1.364 -1.051 -1.723 INSERTS FOR TABLE 5.5-21 (PAGE 2, of 2)V,, -I Table 5.5-2 (continued)

Non-Blanketed Fuel -Coefficients to Calculate the Minimum Required Fuel Assembly Burnup (Bu)as a Function of Enrichment (En) 2 and Cooling Time (Ct) 3 See notes 1-4 for use of Table 5.5-2 Fuel Category Coefficients 11-4 11-5 11-6 11-7 11-8 Al -35.55 -22.12 -20.42 -15.32 -82.47 A2 39.21 24.48 21.91 16.33 97.23 A3 -11.72 -6.23 -4.78 -2.554 -33.42 A4 1.18 0.5118 0.2802 -0.00474 3.782 A5 0.7689 0.7824 -0.6527 0.7264 0.4198 A6 -0.8497 -0.8901 0.8281 -0.7902 -0.3959 A7 0.3126 0.3369 -0.2977 0.2894 0.1245 A8 -0.03608 -0.04 0.03405 -0.03319 -0.01113 A9 21.35 18.32 -50.43 22.01 40.38 A10 -29.32 -26.14 56.6 -25.98 -44.56 All 16.73 16.25 -13.93 15.89 21.97 A12 -2.024 -2.038 1.453 -1.955 -2.568 Notes: 1. All 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 Category, the assembly burnup must exceed the "minimum burnup" (GWD/MTU) given by the curve fit for the assembly "cooling time" and "initial enrichment".

The specific minimum burnup required for each fuel assembly is calculated from the following equation: Bu = (A, + A 2*En + A 3*En 2 + A4*En 3)* exp [- (A 5 + A 6*En + A7*En 2 + As*En 3)*Ct ]+ A 9 + A10*En + Aii*En 2 + A 1 2*En 3 2. Initial enrichment, En, is the nominal U-235 enrichment.

Any enrichment between 1.8 and 4.0 may be used.3. Cooling time, Ct, is in years. Any cooling time between 10 years and 25 years may be used. An assembly with a cooling time greater than 25 years must use 25 years.4. This Table applies only for pre-EPU fuel assemblies without axial blankets.

If an unblanketed assembly is depleted at EPU conditions none of the burnup accrued at EPU conditions can be credited (i.e., only burnup accrued at pre-EPU conditions may be used as burnup credit).

REPLACE TABLE 5.5-3 WITH, THE NEXT PAGE-Table 5.5-3 Fuel Categories Ranked by Reactivity' Fuel Category Region I Region 11 11-6 11-8 Notes 1. ctivity Rank: Fuel Category is ranked in decreasing order of reactivity, e.g. 11-2 is less reac e an I1-1, etc.TURKEY POINT -UNITS 3 & 4 5-13 AMENDMENT NOS.-234-AND-29 INSERTFOR' TABLE 5.5-3, Table 5.5-3 Fuel Cateciories Ranked by Reactivity See notes 1-3 for use of Table 5.5-3 I-1 Region I 1-2 1-3 11-1 11-2a 11-2b 11-2c 11-3 Region II 11-4 11-5 11-6 11-7 11-8 High Reactivity Low Reactivity-Notes: 1. Reactivity Rank: Fuel Category is ranked by decreasing order of reactivity, e.g. Category 1-2 is less reactive than Category I-1, etc. The more reactive fuel categories require compensatory measures to be placed in Regions I & II of the SFP, i.e., use of water filled cells or Metamic inserts.2. Category I-1 is fresh fuel up to 5.0 wt% U-235. Category 1-2 is fresh fuel up to 4.7 wt% U-235 with no burnable absorber rods, fresh fuel up to 5.0 wt% U-235 with at least 16 IFBA rods (or an equivalent amount of other burnable absorber), or fuel up to 5.0 wt% U-235 with no burnable absorber rods burned to at least 500 MWD/MTU. For fuel with 16 IFBA rods (or an equivalent amount of other burnable absorber), no burnup is required but any amount of burnup is allowed.3. All Categories except I-1 and 1-2 are determined from Tables 5.5-1 and 5.5-2.

REPLACE FIGURE 5.5-1 n WITHTHE NEXT PAGE,", FIGURE 5.5-1 ALLOWABLE REGION I STORAGE ARRAYS ILLUSTRATION', 2 ,3,4 Array I-A._Checkerboard patterna oCategory I-1 assemblies adempty (water filled) ce'i; -Array I-B Category 1-2 assembly in every cell. 1-2 1-/ 1-2 Array I-C Category I-1 assemblies and Category 1-2 assemblies:

Each Category I-1 assembly shall have a full length RC in the assembly.

The number of Category I-1 assem is with RCCAs in the assemblies is unrestricted.

Notes: 1. Fuel Categories are det mined from Tables 5.5-1 and 5.5-2.2. Shaded cells indic the fuel assembly contains a full length RCCA.3. E indicates a mpty (water filled) cell.4. Attribute for each 2x2 array are as stated in the definition.

Diagram is for illustrative purposes onl TURKEY POINT -UNITS 3 & 4 5-14 AMENDMENT NOS.

INSERT FOR FIGURE 5.5-1 FIGURE 5.5-1 ALLOWABLE REGION I STORAGE ARRAYS See notes 1-4 for use of Figure 5.5-1 DEFINITION Array I-A Checkerboard pattern of Category I-1 assemblies and empty (water-filled) cells.Array I-B Category 1-3 assembly in every cell.ILLUSTRATION I-1 X X I-1 1-3 1-3 1-3 1-3 Array I-C Category 1-2 and 1-3 assemblies.

Each Category 1-2 shall have a full length RCCA in the assembly.1-2 1-3 1-2 1-2 1-3 1-3 1-3 1-3 Notes: 1. Category I-1 is fresh fuel enriched to 5.0 wt%. 1-2 is fresh fuel enriched to 4.7 wt%, fresh fuel enriched to 5.0 wt% with at least 16 IFBA rods (or an equivalent amount of other burnable absorber), or fuel up to 5.0 wt% with no burnable absorber rods burned to at least 500 MWD/MTU. Category 1-3 is determined from Tables 5.5-1 and 5.5-2. In all arrays, an assembly of lower reactivity can replace an assembly of higher reactivity.

2. Shaded cells indicate that the fuel assembly contains a full length RCCA.3. X indicates an empty (water-filled) cell.4. Attributes for each 2x2 array are as stated in the definition.

Diagram is for illustrative purposes only.

REPLACE FIGURE 5.5-2 WITH THE NEXT TWO PAGES FIGURE 5.5-2 ALLOWABLE REGION II STORAGE ARRAYS DEFINITIO

1.4 ILLUSTRATION

1 ,2.3,4 Array Il-A Category 11-I asse bly in three of every four cells: One of every four ce is empty (water-filled).

Array Il-B FT Category 11-2 assembly in ev cell: Two of every four cells contain a 12 I1 1 11-2 [1-2 11-Metamic insert (or full length R A in the assembly).

-2 2 [~jlJ[j3lj Array ll-C 11-3 11-5 Checkerboard pattern of Category 11-3 and -5 assemblies:

One of every four cells contains a Metamic in rt (or full length 11-5 111-3, 11-3 -5 RCCA in the assembly).

Metamic inserts (or R GAs) may be in either 11-3 or 11-5 cells.Array 11-D Category 11-4 assembly in every cell: One of every fo r4 114 cells contains a Metamic insert (or full length RCC in the assembly).

Array II-E 11-8 11-6 Checkerboard pattern of Category 11-6 d 11-8 assemblies.

-6 11-8 Array Il-F Category 11-7 assembly in ev ry cell. 11-7 11-11-7 11-7 Notes: 1. Fuel Cat ories are determined from Tables 5.5-1 and 5.5-2.2. Sha d cells indicate either a Metamic insert in the cell or the fuel assembly contains a full length R A.3. indicates an empty (water filled) cell.Attributes for each 2x2 array are as stated in the definition.

Diagram is for illustrative purposes only.TURKEY POINT -UNITS 3 & 4 5-15 AMENDMENT NOS. 234-ANi22 FIGURE 5.5-2 ALLOWABLE REGION II STORAGE ARRAYS See notes 1-4 for use of Figure 5.5-2 DEFINITION Array Il-A Category I1-1 assemblies in three of every four cells; One of every four cells is empty (water-filled).

Array Il-BI Checkerboard pattern of Category I1-1 and 11-3 assemblies with two of every four cells containing a Metamic insert or full length RCCA.Array II-B2 Category 11-2b assembly in every cell with two of every four cells containing a Metamic insert or full length RCCA.Array II-B3 Checkerboard pattern of Category 11-2a and 11-2c assemblies with two of every four cells containing a Metamic insert or full length RCCA.11-1 11-1 ILLUSTRATION X I1-1 1-1 11-3 11-3 I 1-I II-2c 112a 11-2b 11-2b 11-2a 11-2c Notes: 1. Fuel categories are determined from Tables 5.5-1 and 5.5-2. In all arrays, an assembly of lower reactivity can replace an assembly of higher reactivity.

2. Shaded cells indicate that the cell contains a Metamic insert or the fuel assembly contains a full length RCCA.3. X indicates an empty (water-filled) cell.4. Attributes for each 2x2 array are as stated in the definition.

Diagram is for illustrative purposes only.

INSERTS FOR FIGURE (PAGE 2 of 2)FIGURE 5.5-2 (continued)

ALLOWABLE REGION II STORAGE ARRAYS See notes 1-4 for use of Figure 5.5-2 DEFINITION Array Il-C 11-3 11-5 Checkerboard pattern of Category 11-3 and 11-5 assemblies with one 1 of every four cells containing a Metamic insert or full length RCCA. 11-5 Array II-D Category 11-4 assembly in every cell with one out of every four cells containing a Metamic insert or full length RCCA.Array II-E Checkboard pattern of Category 11-6 and 11-8 assemblies.

Array Il-F Category 11-7 assembly in every cell.ILLUSTRATION 11-5 11-3 11-3 11-5 114 11-4 11 -4 11-11-6 11-8 11-8 11-6 11-7 11-7 11-7 11-7 Notes: 1. Fuel categories are determined from Tables 5.5-1 and 5.5-2. In all arrays, an assembly of lower reactivity can replace an assembly of higher reactivity.

2. Shaded cells indicate that the cell contains a Metamic insert or the fuel assembly contains a full length RCCA.3. X indicates an empty (water-filled) cell.4. Attributes for each 2x2 array are as stated in the definition.

Diagram is for illustrative purposes only.

REPLACE FIGURE 5 5;-3 WITH THE NEXT PAGE FIGURE 5.5-3 ALLOWABLE INTERFACES BETWEEN REGION II -REGION I ARRAYS DEFINITI' N 1 , 4 ILLUSTRATION 1'2'3'4.5 Region I Rack 1-2 1-2 1-2 1-2 For Array Il-A, the mpty cell shall be in 1-I 1-221-211-2 the row adjacent to t- Region I Rack.1 1-1 E 11-1 E Array Il-A Region I Rack egion I Rack Region I Rack For Array Il-13, the reactivity rank of 1-\ 12 1-l-2 1-2 1-2 1-2 1-2 1-2 1-2 122 1\ -2 1-2 1-2 1-2 1 -2 I-2 I- I2 I2 I2 I-assemblies adjacent to the Region I rack I\ I a 1 1 -2 1-2 L 1-2 1-2 1-2 1-2 shall be reduced from a rank of 11-2 to a 11-4 11-4 .11 -4 11-4 11-4 4 1- F4 -4 11-4 11-4 11-4 reactivity rank of 11-4 or lower. The Array Il-B pattern shall have the required Metamic insert (or full length RCCA in the A y 1I-13 Array 11-B Array II-B assembly) placed in the row adjacent to the Region I rack.Region I Rack Region I Rack Region I Rack_1-2 1-2 1-2 1-2 ,- 2 1-2 1-2 [1-2 1-2 1-2 1-2 For Arrays II-C and II-D, the Metamic 1-2 [-21-21 1- 1-2 1-2 1-2 [ 1-2 1-2 1-2 insert (or full length RCCA in the 1- 11-5 11-3 11 11-5 ,, 1I3 1-35 11411,-4111-4 EI,,-assembly) shall be placed in the ro 11-5 11-3 11-5 11-3 I-ll 11-1 11-5 11-4 I11-4 I11-4 1II-4 adjacent to the Region I rack. I Array Il-C Array) \tC Array ll-D 1. Fuel Catego es are determined from Tables 5.5-1 and 5.5-2.2. Shaded ells indicate either a Metamic insert in the cell or the fuel assembly contains a full length R A.3. E in icates an empty (water filled) cell.4. ttributes for each 2x2 array are as stated in the definition.

Diagram is for illustrative purposes only.Region I Array 1-2 is depicted as the example; however, any Region I array is equally representative.

TURKEY POINT -UNITS 3 & 4 5-16 AMENDMENT NOS. -234-AND2-29 FIGURE 5.5-3 INTERFACE RESTRICTIONS BETWEEN REGION II AND REGION I ARRAYS See notes 1-5 for use of Figure 5.5-3 DEFINITION For Array Il-A, the empty cell shall be in the row adjacent to the Region I rack.ILLUSTRATION Region I Rack 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 11-1 X I-1 X I1-1 I1-1 11-1 I1-1 Array Il-A For Arrays requiring two inserts, there shall be an insert in at least every other cell in the row facing the Region I rack.Array I-Bl Region I Rack 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 11-2b 11-2b 11-2b. 11-2b Array 1I-B2 Region I Rack 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1 1 -5 1 1 ; 1 1 -5 1 1 3 11-3 11-5 11-3 11-5 Array Il-C Region I Rack 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 11-2c I11-2a 11-2c 11-2a Array II-B3 Region I Rack 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 11-4 11-4 11-4 1-4 11-4 11-4 11-4 11-4 Array II-D For Arrays requiring one insert, the insert shall be placed in the row facing the Region I rack.Region I Rack 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1-3 1 -3 y 11-5 11-3 Array 1I-C Notes: 1. Fuel categories are determined from Tables 5.5-1 and 5.5-2. In all arrays, an assembly of lower reactivity can replace an assembly of higher reactivity.

2. Shaded cells indicate that the cell contains a Metamic insert or the fuel assembly contains a full length RCCA.3. X indicates an empty (water-filled) cell.4. Attributes for each 2x2 array are as stated in the definition.

Diagram is for illustrative purposes only.Region I Array 1-3 is depicted as the example; however, any Region I array is allowed.5. Figure 5.5-3 is not applicable to the Region II -cask area rack interface.

REPLACE FIGURE 5.5-4 WITH THE NEXT PAGE FIGURE 5.5-4 ALLOWABLE REGION II STORAGE ADJACENT TO SPENT FUEL PIT WALLS ILLUSTRATION 1', 2 3.4 An assembly of rank I placed in the peripheral row of a RegibQ II storage rack shall not be adjacent a Region I storage rack.For Array II-A, the empty cell in the 2x2 II-A array shall be adjacent to the peripheral row that contains the category 11-2 assembly(s).

For Array Il-A only, the peripheral row may contain category I1-1 assemblies as the outer two rows will comply with Array II-A requirements.

For Array Il-B, the Metamic insert (or full length RCCA in the assembly)shall be adjacent to the peripheral row that contains the category 11-2 assembly(s).

For Arrays Il-C and II-D, Metamic insert (or full ler the assembly) shall be/4 peripheral row that .dnta category 11-2 asse ,bly(s 11-2 11-2 11-2 11-2 11-5 11-3 11-5 11-3 11-3 11-5 11-3 11-5 Array 11-C the Array Il-C Notes: 1. Fuj"Categories are determined from Tables 5.5-1 and 5.5-2.2. 5aded cells indicate either a Metamic insert in the cell or the fuel assembly contains a full length RCCA.3./E indicates an empty (water filled) cell.,A/ Attributes for each 2x2 array are as stated in the definition.

Diagram is for illustrative purposes only.TURKEY POINT -UNITS 3 & 4 5-17 AMENDMENT NOS. 234-ANB-229 INSERT FORI;FIGURE 5.5-4 FIGURE 5.5-4 ALLOWABLE EXCEPTIONS TO REGION II STORAGE ARRAYS WHEN ADJACENT TO SPENT FUEL PIT WALLS See notes 1-6 for use of Figure 5.5-4 DEFINITION For Arrays requiring two inserts, there shall be an insert in at least every other cell adjacent to the peripheral row containing the 11-2c assemblies.

For Arrays requiring one insert, the insert shall be adjacent to the peripheral row containing the 11-2b assemblies.

ILLUSTRATION SpentFulPtWl 11-2c 11-2c 11-2c 11-2c 11-2c 11-2c 11-2c 11-2c 11-2c 11-2 c 11-2c 11-2c 11-3 11-1 11-3 , 1-1 l-2b 11-2b~ ll-2b l1-2b 11-2c 11- 2a 112c 11-2a 11 11-3 I-2b 13-2 b 11 11 -2b I1-2a 11-2c II 2a iI 2c Array II-B1 Array II-B2 Array II-B3 Pi Wall 11-2b 11-5 11-3 11-2b I11-2b I11-2b I 11-2b 11-2b I 11-2b I 11-2b 11-2b I 11-2b I 11-2b I 11-2b 11-3 ý11I-5 11-5 11-4 11-4 11-4 11-4 11-4 11-5 11-3 11-4 Array Il-C Array Il-C Array II-D Notes: 1. Fuel categories are determined from Tables 5.5-1 and 5.5-2. Fuel category of rank 11-2b or lower reactivity can be placed in the peripheral row next to the spent fuel pit wall without inserts subject to the constraints listed here. For arrays requiring 2 inserts, the peripheral row must contain category II-2c or lower reactivity.

Alternatively, the peripheral row may contain inserts as required for any 2x2 array.2. Shaded cells indicate either a Metamic insert in the cell or the fuel assembly contains a full length RCCA.3. X indicates an empty (water-filled) cell.4. Attributes for each 2x2 array are as stated in the definition.

Diagram is for illustrative purposes only.5. There are no restrictions for placement of Arrays ll-E and Il-F.6. Any defined Region II array may be placed against the spent fuel pit wall or one of the additional configurations shown above may be used.

L-2010-169, Turkey Point, Units 3 and 4 - Fuel Storage Criticality Analysis

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1.4 ILLUSTRATION

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L-2010-169, Turkey Point, Units 3 and 4 - Fuel Storage Criticality Analysis

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1.4 ILLUSTRATION

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