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MONTHYEARNOC-AE-04001731, Request for Exemption for Cladding Material Specified in 10CFR50.44, 10CFR50.46 and 10CFR50 Appendix K2004-05-27027 May 2004 Request for Exemption for Cladding Material Specified in 10CFR50.44, 10CFR50.46 and 10CFR50 Appendix K Project stage: Request ML0418403042004-07-0101 July 2004 Westinghouse, Withholding from Public Disclosure, Request for Exemption from Provisions of 10 CFR 50.44, 10 CFR 50.46, & 10 CFR 50 Appendix K for Eight Lead Test Assemblies (Ltas) & Supporting Justification for South Texas Project Optimized Project stage: Approval ML0420404422004-07-19019 July 2004 Environmental Assessment - Optimized Ziro LTAs Project stage: Other NOC-AE-04001779, Response to Request for Additional Information Request for Exemption for Cladding Material Specified in 10CFR50.44, 10CFR50.46 and 10CFR50 Appendix K2004-08-23023 August 2004 Response to Request for Additional Information Request for Exemption for Cladding Material Specified in 10CFR50.44, 10CFR50.46 and 10CFR50 Appendix K Project stage: Response to RAI ML0429405192004-10-19019 October 2004 Southtexas Exemption: Commission Has Determined That the Granting of Thus Exemption Will Not Have a Significant Effect on the Quality of the Human Environment Project stage: Other ML0429405002004-10-19019 October 2004 Southtexas, Units 1 and 2 Exemption from the Requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix K and Section 50.46 Project stage: Approval ML0430704852004-11-10010 November 2004 Release of Exemption from the Requirements of Title 10 of the Code of Federal Regulations Project stage: Approval 2004-05-27
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Category:Exemption from NRC Requirements
MONTHYEARML23324A0102023-11-16016 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML23114A0152023-04-28028 April 2023 Exemption from the Requirements of 10 CFR 20.2206 (EPID L-2023-LLE-0009) (FRN) ML23094A2702023-04-27027 April 2023 Exemption from the Requirements of 10 CFR 20.2206 (EPID L-2023-LLE-0009) (Exemption) ML23094A2712023-04-27027 April 2023 Exemption from the Requirements of 10 CFR 20.2206 (EPID L-2023-LLE-0009) (Letter) ML23103A4322023-04-13013 April 2023 Request for Exemption from 10 CFR 20.2206(c) Due to Issues Obtaining Data ML22094A1762022-04-25025 April 2022 Letter, NRC Granting of Exemption to South Texas Project ISFSI from CoC 1032 for 1 MPC ML22070B1402022-03-11011 March 2022 Independent Spent Fuel Storage Installation Request for Exemption from Certificate of Compliance (CoC) Inspection Requirement for One Multipurpose Canister ML20330A3122020-12-10010 December 2020 Exemption from Annual Force-on-Force Exercise Requirement of 10 CFR Part 73, Appendix B, General Criteria for Security Personnel, Subsection VI.C.3(I)(1) (EPID L-2020-LLE-0205 (COVID-19)) ML20304A2862020-11-20020 November 2020 Federal Register Notice for COVID-19 October 2020 Group Exemptions ML20321A3312020-11-16016 November 2020 Request for a One-Time Exemption from 10 CFR 73, Appendix 8, Section VI, Subsection C.3.(1)(1) Regarding Annual Force-on-Force (FOF) Exercises, Due to Covid 19 Pandemic NOC-AE-20003767, Request for a One-Time Exemption from 10 CFR 73, Appendix 8, Section VI, Subsection C.3.(1)(1) Regarding Annual Force-on-Force (FOF) Exercises, Due to Covid 19 Pandemic2020-11-16016 November 2020 Request for a One-Time Exemption from 10 CFR 73, Appendix 8, Section VI, Subsection C.3.(1)(1) Regarding Annual Force-on-Force (FOF) Exercises, Due to Covid 19 Pandemic ML20224A2112020-08-11011 August 2020 Exemption Request from 10 CFR 50 Appendix E Due to COVID-19 Pandemic NOC-AE-20003756, Exemption Request from 10 CFR 50 Appendix E Due to COVID-19 Pandemic2020-08-11011 August 2020 Exemption Request from 10 CFR 50 Appendix E Due to COVID-19 Pandemic ML20177A6452020-07-15015 July 2020 FRN - Notice of Issuance of Multiple Exemptions Regarding Various Parts of 10 CFR Due to COVID-19 Impacts for June 2020 ML20155K6792020-06-18018 June 2020 Temporary Exemption from Certain Requirements of 10 CFR Part 73, Appendix B, General Criteria for Security Personnel, Section VI (EPID L-2020-LLE-0076 (COVID-19)) ML18129A1312018-03-0808 March 2018 Request for Exemption from the Requirements of 10 CFR 50.47 Without Enclosures 3 and 4 ML17037C8712017-07-11011 July 2017 Letter, Exemption from the Requirements of 10 CFR Part 50, Section 50.46 (CAC Nos. MF2402-MF2409) NOC-AE-13002954, Pilot Submittal and Request for Exemption for a Risk-Informed Approach to Resolve Generic Safety Issue (GSI)-1912013-01-31031 January 2013 Pilot Submittal and Request for Exemption for a Risk-Informed Approach to Resolve Generic Safety Issue (GSI)-191 ML1124206112011-10-28028 October 2011 Letter, Exemption from the Requirements of 10 CFR Section 50.46 and Appendix K to 10 CFR Part 50 to Allow the Use of Optimized Zirlo as Fuel Rod Cladding Material NRC-2011-0233, South Texas Project, Units 1 and 2 - Exemption from the Requirements of 10 CFR Section 50.46 and Appendix K to 10 CFR Part 50 to Allow the Use of Optimized Zirlo as Fuel Rod Cladding Material (TAC Nos. ME5365 and ME5366)2011-10-27027 October 2011 South Texas Project, Units 1 and 2 - Exemption from the Requirements of 10 CFR Section 50.46 and Appendix K to 10 CFR Part 50 to Allow the Use of Optimized Zirlo as Fuel Rod Cladding Material (TAC Nos. ME5365 and ME5366) ML1124206162011-10-27027 October 2011 Exemption from the Requirements of 10 CFR Section 50.46 and Appendix K to 10 CFR Part 50 to Allow the Use of Optimized Zirlo as Fuel Rod Cladding Material NRC-2010-0162, South Texas Project, Units 1 and 2 - Exemption from Certain Requirements of 10 CFR Part 26 Revised Fitness for Duty Rule Regarding Managing Fatigue During Severe Weather Conditions2010-07-0202 July 2010 South Texas Project, Units 1 and 2 - Exemption from Certain Requirements of 10 CFR Part 26 Revised Fitness for Duty Rule Regarding Managing Fatigue During Severe Weather Conditions ML1016901072010-07-0202 July 2010 Letter, Exemption from Certain Requirements of 10 CFR Part 26 Revised Fitness for Duty Rule Regarding Managing Fatigue During Severe Weather Conditions ML1016901142010-07-0202 July 2010 Exemption from Certain Requirements of 10 CFR Part 26 Revised Fitness for Duty Rule Regarding Managing Fatigue During Severe Weather Conditions NRC-2010-0060, South Texas Project, Units 1 and 2 - Exemption from Schedule for Compliance with 10 CFR Part 73 Physical Security Requirements (TAC Nos. ME2873 and ME2874)2010-03-0505 March 2010 South Texas Project, Units 1 and 2 - Exemption from Schedule for Compliance with 10 CFR Part 73 Physical Security Requirements (TAC Nos. ME2873 and ME2874) ML1003213142010-03-0505 March 2010 Cover Letter, Exemption from Schedule for Compliance with 10 CFR Part 73 Physical Security Requirements ML1003213202010-03-0505 March 2010 Exemption from Schedule for Compliance with 10 CFR Part 73 Physical Security Requirements NOC-AE-09002477, Revised Request for Exemption from Certain Requirements of the Fitness for Duty Rule for Managing Fatigue2009-10-14014 October 2009 Revised Request for Exemption from Certain Requirements of the Fitness for Duty Rule for Managing Fatigue NOC-AE-07002210, Request for Exemption from 10 CFR 50.82(a)(8)2007-09-19019 September 2007 Request for Exemption from 10 CFR 50.82(a)(8) ML0429405192004-10-19019 October 2004 Southtexas Exemption: Commission Has Determined That the Granting of Thus Exemption Will Not Have a Significant Effect on the Quality of the Human Environment 2023-04-28
[Table view] Category:Federal Register Notice
MONTHYEARML23279A0382023-10-30030 October 2023 Associated Independent Spent Fuel Storage Installation - Enclosure 1 -Order Approving Indirect Transfer of Licenses and Draft Conforming License Amendments (EPID L-2023-LLM-0004) (Order) ML23279A0342023-10-30030 October 2023 Associated Independent Spent Fuel Storage Installation - Order Approving Indirect Transfer of Licenses and Draft Conforming License Amendments (EPID L-2023-LLM-0004) (Letter) ML23188A1592023-07-14014 July 2023 the Associated ISFSI - Notice of Consideration of Approval of Indirect Transfer of Licenses and Conforming Amendments and Opportunity to Request a Hearing (EPID L-2023-LLM-0004) - FRN ML23114A0152023-04-28028 April 2023 Exemption from the Requirements of 10 CFR 20.2206 (EPID L-2023-LLE-0009) (FRN) ML23094A2712023-04-27027 April 2023 Exemption from the Requirements of 10 CFR 20.2206 (EPID L-2023-LLE-0009) (Letter) ML22293A0022022-11-30030 November 2022 Environmental Assessment and Finding of No Significant Impact Related to Alternate Disposal Procedures for Very Low-Level Radioactive Material - Transmittal Letter ML22293A0032022-11-30030 November 2022 Environmental Assessment and Finding of No Significant Impact Related to Alternate Disposal Procedures for Very Low-Level Radioactive Material - FRN ML22094A1772022-04-25025 April 2022 Federal Register Notice, NRC Granting of Exemption to South Texas Project ISFSI from CoC 1032 for 1 MPC ML20304A2862020-11-20020 November 2020 Federal Register Notice for COVID-19 October 2020 Group Exemptions ML20177A6452020-07-15015 July 2020 FRN - Notice of Issuance of Multiple Exemptions Regarding Various Parts of 10 CFR Due to COVID-19 Impacts for June 2020 ML19238A3692019-09-0303 September 2019 Biweekly Federal Register Notice - Applications and Amendments to Facility Operating Licenses and Combined Licenses Involving No Significant Hazards Considerations - Publication Date: 09/10/2019 ML19168A0842019-06-26026 June 2019 Biweekly Federal Register Notice - Applications and Amendments to Facility Operating Licenses and Combined Licenses Involving No Significant Hazards Considerations - Publication Date: 07/02/2019 ML19140A4562019-05-28028 May 2019 Biweekly Federal Register Notice - Applications and Amendments to Facility Operating Licenses and Combined Licenses Involving No Significant Hazards Considerations - Publication Date: 06/04/2019 ML18351A0022019-01-0202 January 2019 Biweekly Federal Register Notice - Applications and Amendments to Facility Operating Licenses and Combined Licenses Involving No Significant Hazards Considerations - Publication Date: 01/02/2019 NRC-2018-0287, Biweekly Federal Register Notice - Applications and Amendments to Facility Operating Licenses and Combined Licenses Involving No Significant Hazards Considerations - Publication Date: 01/02/20192019-01-0202 January 2019 Biweekly Federal Register Notice - Applications and Amendments to Facility Operating Licenses and Combined Licenses Involving No Significant Hazards Considerations - Publication Date: 01/02/2019 ML18173A1792018-08-0707 August 2018 OEDO-17-00070 - Notice of Issuance of Director'S Decision, 2.206 Petition for Emergency Enforcement Action Per 10 CFR 2.206 at Listed U.S. Reactors with Forged Components and Parts Manufactured at France'S AREVA-Le Creusot Forge and Japan C ML17146B1672017-09-28028 September 2017 FRN for Issuance of the Renewed Operating Licenses for South Texas Project, Units 1 and 2 ML17138A2762017-09-19019 September 2017 License Renewal Record of Decision ML17198A3292017-08-30030 August 2017 OEDO-17-00070 - Acknowledgement Letter, Paul Gunter, Beyond Nuclear, Petition for Emergency Enforcement Action Per 10 CFR 2.206 at Listed U.S. Reactors with Forged Components and Parts Manufactured at France'S AREVA-Le Creusot Forge and Jap ML17200A0652017-08-30030 August 2017 OEDO-17-00070 - Acknowledgement FRN, Paul Gunter, Beyond Nuclear, 2.206 Petition for Emergency Enforcement Action Per 10 CFR 2.206 at Listed U.S. Reactors with Forged Components and Parts Manufactured at France'S AREVA-Le Creusot Forge and NRC-2016-0092, South Texas Project, Units 1 and 2 - FRN: Exemption from the Requirements of 10 CFR 50.46 and 10 CFR Part 50, Appendix a, General Design Criteria 35, 38, 41 (CAC Nos. MF2402-MF2409)2017-07-11011 July 2017 South Texas Project, Units 1 and 2 - FRN: Exemption from the Requirements of 10 CFR 50.46 and 10 CFR Part 50, Appendix a, General Design Criteria 35, 38, 41 (CAC Nos. MF2402-MF2409) ML17037C8762017-07-11011 July 2017 FRN: Exemption from the Requirements of 10 CFR 50.46 and 10 CFR Part 50, Appendix a, General Design Criteria 35, 38, 41 (CAC Nos. MF2402-MF2409) ML17037C8712017-07-11011 July 2017 Letter, Exemption from the Requirements of 10 CFR Part 50, Section 50.46 (CAC Nos. MF2402-MF2409) ML16278A5992017-05-0202 May 2017 Environmental Assessment and Finding of No Significant Impact, Revise Licensing Basis as Documented in the UFSAR and Request for Exemptions, Risk-Informed Approach to Address GSI-191 (CAC MF2400 to MF2409) NRC-2016-0100, Biweekly Federal Register Notice - Applications and Amendments to Facility Operating Licenses and Combined Licenses Involving No Significant Hazards Considerations - Publication Date: May 24, 20162016-05-13013 May 2016 Biweekly Federal Register Notice - Applications and Amendments to Facility Operating Licenses and Combined Licenses Involving No Significant Hazards Considerations - Publication Date: May 24, 2016 ML16131A7952016-05-13013 May 2016 Biweekly Federal Register Notice - Applications and Amendments to Facility Operating Licenses and Combined Licenses Involving No Significant Hazards Considerations - Publication Date: May 24, 2016 ML16032A3872016-04-26026 April 2016 Draft Environmental Assessment and Finding of No Significant Impact, Revise Licensing Basis as Documented in the UFSAR and Request for Exemptions, Risk-Informed Approach to Address GSI-191 (CAC MF2400-MF2409) ML16032A4032016-04-26026 April 2016 FRN, Draft Environmental Assessment and Finding of No Significant Impact, Revise Licensing Basis as Documented in the UFSAR and Request for Exemptions, Risk-Informed Approach to Address GSI-191 (CAC MF2400-MF2409) ML15356A5992015-12-29029 December 2015 Biweekly Federal Register Notice - Applications and Amendments to Facility Operating Licenses and Combined Licenses Involving No Significant Hazards Considerations - Publication Date: January 5, 2016 ML15218A6252015-08-14014 August 2015 Biweekly FRN - Applications and Amendments to Facility Operating Licenses and Combined Licenses Involving No Significant Hazards Considerations - Publication Date: August 14, 2015 ML13252A4022013-11-19019 November 2013 STP FSEIS FRN (Update) ML13225A5572013-08-12012 August 2013 Rescission of Certain Security Orders Concerning Spent Nuclear Fuel in Transit ML12321A3112012-12-18018 December 2012 STP Units 1 and 2, LRA Review ML12321A3512012-12-18018 December 2012 Notice of Availability of the Dseis for Lr of STP, Units 1 and 2, for Public Comment ML12320A6032012-12-13013 December 2012 License Renewal Application Review (THC No. 201002271) ML12339A2652012-12-0505 December 2012 Notice of Availability of the Draft Plant-Specific Supplement 48 to the GEIS for License Renewal of Nuclear Plants Regarding South Texas Project, Units 1 and 2, (TAC ME5122, ME5123, ME4938, and ME4939) ML12195A0852012-12-0505 December 2012 Notice of Availability of the Draft Plant-Specific Supplement 48 to the GEIS for License Renewal of Nuclear Plants Regarding South Texas Project, Units 1 and 2, (TAC Nos. ME5122, ME5123, ME4938, and ME4939) ML12222A0232012-08-14014 August 2012 Letter, Withdrawal of License Amendment Request to Approve Revision to Fire Protection Program in Fire Hazards Analysis Report Related to Alternate Shutdown Capability ML12222A0262012-08-14014 August 2012 FRN - Withdrawal of License Amendment Request to Approve Revision to Fire Protection Program in Fire Hazards Analysis Report Related to Alternate Shutdown Capability NRC-2012-0196, South Texas Project, Units 1 and 2 - FRN - Withdrawal of License Amendment Request to Approve Revision to Fire Protection Program in Fire Hazards Analysis Report Related to Alternate Shutdown Capability (TAC Nos. ME6346 and ME6347)2012-08-14014 August 2012 South Texas Project, Units 1 and 2 - FRN - Withdrawal of License Amendment Request to Approve Revision to Fire Protection Program in Fire Hazards Analysis Report Related to Alternate Shutdown Capability (TAC Nos. ME6346 and ME6347) ML12056A0442012-03-12012 March 2012 Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Effective Immediately) - to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status NRC-2012-0067, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Effective Immediately) - to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status2012-03-12012 March 2012 Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Effective Immediately) - to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status NRC-2011-0233, South Texas Project, Units 1 and 2 - Exemption from the Requirements of 10 CFR Section 50.46 and Appendix K to 10 CFR Part 50 to Allow the Use of Optimized Zirlo as Fuel Rod Cladding Material (TAC Nos. ME5365 and ME5366)2011-10-27027 October 2011 South Texas Project, Units 1 and 2 - Exemption from the Requirements of 10 CFR Section 50.46 and Appendix K to 10 CFR Part 50 to Allow the Use of Optimized Zirlo as Fuel Rod Cladding Material (TAC Nos. ME5365 and ME5366) ML1124206162011-10-27027 October 2011 Exemption from the Requirements of 10 CFR Section 50.46 and Appendix K to 10 CFR Part 50 to Allow the Use of Optimized Zirlo as Fuel Rod Cladding Material ML1124113012011-10-0404 October 2011 FRN: General Notice. South Texas Project, Units 1 and 2 - Environmental Assessment and Finding of No Significant Impact, Proposed Exemption from 10 CFR 50.46 and 10 CFR 50 Appendix K to Allow Use of Optimized Zirlo as Fuel Rod Cladding Mate NRC-2011-0187, Biweekly Sholly Report - Applications and Amendments to Facility Operating Licenses Involving No Significant Hazards Considerations; Fr Publication Date: 8/23/20112011-08-11011 August 2011 Biweekly Sholly Report - Applications and Amendments to Facility Operating Licenses Involving No Significant Hazards Considerations; Fr Publication Date: 8/23/2011 ML1122302752011-08-11011 August 2011 Biweekly Sholly Report - Applications and Amendments to Facility Operating Licenses Involving No Significant Hazards Considerations; Fr Publication Date: 8/23/2011 ML1120917232011-08-0404 August 2011 FRN, Withdrawal of License Amendment Request, Revise Application of Control Risk Management Program in Technical Specification 3.7.7, Control Room Makeup and Cleanup Filtration System NRC-2011-0063, Individual Notice of Consideration of Issuance of Amendment, Revise Technical Specification 6.8.3.I, Containment Post Tensioning System Surveillance Program, Consistent with Updated Edition of ASME Code, Section Xi2011-03-15015 March 2011 Individual Notice of Consideration of Issuance of Amendment, Revise Technical Specification 6.8.3.I, Containment Post Tensioning System Surveillance Program, Consistent with Updated Edition of ASME Code, Section Xi ML1107405012011-03-15015 March 2011 Letter, Individual Notice of Consideration of Issuance of Amendment, Revise Technical Specification 6.8.3.I, Containment Post Tensioning System Surveillance Program, Consistent with Updated Edition of ASME Code, Section XI 2023-07-14
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7590-01-P UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION STP NUCLEAR OPERATING COMPANY SOUTH TEXAS PROJECT, UNIT NO. 1 AND 2 DOCKET NOS. 50-498 AND 50-499 EXEMPTION
1.0 BACKGROUND
The STP Nuclear Operating Company (STPNOC or the licensee) is the holder of Facility Operating License Nos. NPF-76 and NPF-80, which authorize operation of South Texas Project (STP), Units 1 and 2, respectively. The licenses provide, among other things, that the facility is subject to all rules, regulations, and orders of the Nuclear Regulatory Commission (NRC, the Commission) now or hereafter in effect.
The facility consists of two pressurized water reactors located in Matagorda County, Texas.
2.0 REQUEST/ACTION Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Section 50.44, specifies requirements for the control of hydrogen gas generated after a postulated loss-of-coolant accident (LOCA). Section 50.46 of 10 CFR contains acceptance criteria for the emergency core cooling system (ECCS) for reactors with zircaloy or ZIRLOTM clad fuel. Appendix K to 10 CFR Part 50 requires, among other things, that the Baker-Just equation be used to predict the rates of energy release, hydrogen concentration, and cladding oxidation from the metal-water reaction. Of these three regulations (10 CFR 50.44, 50.46, and Appendix K to 10 CFR Part 50), 10 CFR 50.44 is the only one that has undergone considerable changes relative to its
previous version, changes that became effective on January 1, 2004. Prior to that date, 10 CFR 50.44 specified requirements for the control of hydrogen gas generated after a postulated LOCA for reactors with zircaloy or ZIRLOTM clad fuel. The new regulation in 10 CFR 50.44 no longer identifies zircaloy or ZIRLOTM as requisite fuel cladding, nor does it identify the LOCA or 10 CFR 50.46 as bases. Because the intent of this exemption request relates solely to the specific types of cladding material specified in these regulations, no exemption is needed from the requirements of 10 CFR 50.44. As written, zircaloy or ZIRLOTM cladding continues to be the requisite fuel cladding that is explicitly identified in 10 CFR 50.46 and Appendix K to 10 CFR Part 50. Therefore, an exemption from the requirements of 10 CFR 50.46 and Appendix K to 10 CFR Part 50 is needed in order to irradiate up to eight lead test assemblies (LTAs) comprised of low tin (Optimized) ZIRLOTM at the STP, Units 1 and/or 2.
In summary, in a letter dated May 27, 2004 (Reference 1)1, as supplemented by letter dated August 23, 2004 (Reference 2)2, STPNOC requested an exemption from 10 CFR 50.44, Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors; 10 CFR 50.46, Acceptance Criteria for Emergency Core Cooling Systems for Light-Water Nuclear Power Reactors; and Appendix K to 10 CFR Part 50, ECCS Evaluation Models, which would allow irradiation of up to eight LTAs containing fuel rods, guide tubes, and instrumentation tubes fabricated with Optimized ZIRLOTM. Optimized ZIRLOTM is not within the 1
Letter from T. J. Jordan (South Texas) to U.S. Nuclear Regulatory Commission, "The South Texas Project, Units 1 and 2 Request for Exemption Pursuant to 10 CFR 50.12 Exemption to the Fuel Cladding Material Specified in 10 CFR 50.44, 10 CFR 50.46, and 10 CFR 50 Appendix K," Docket Nos. STN 50-498 and STN 50-499, May 27, 2004, ADAMS Accession No. ML041590200.
2 Letter from T. J. Jordan (South Texas) to U.S. Nuclear Regulatory Commission, "The South Texas Project, Units 1 and 2 Response to Request for Additional Information Regarding Exemption to Use a Low Tin Cladding," Docket Nos. STN 50-498 and STN 50-499, August 23, 2004, ADAMS Accession No. ML042430272.
licensing basis of the approved ZIRLOTM as described in WCAP-12610-P-A (Reference 3)3 for STP, Units 1 and 2. Irradiation of up to eight Optimized ZIRLOTM LTAs in STP Units 1 and/or 2 will provide data on fuel and material performance to support future licensing activities.
3.0 DISCUSSION The staff has previously reviewed exemption requests for LTA programs comprised of fuel with Optimized ZIRLOTM cladding material manufactured by Westinghouse Electric Company (Westinghouse). Exemptions from 10 CFR 50.46 and Appendix K to 10 CFR Part 50 for use of Optimized ZIRLOTM have been issued by the NRC staff for Millstone, Unit 3 (Reference 4)4, Catawba Station (Reference 5)5, and Calvert Cliffs, Unit 2 (Reference 6)6.
3.1 Material Evaluation 3.1.1 Fuel Mechanical Design Tin is a solid solution strengthener and -phase stabilizer present entirely in the base -
phase zirconium crystalline structure. Potential impacts of a reduced tin content on material properties include (1) a reduced tensile strength, (2) an increased thermal creep rate, (3) an increased irradiation growth rate, (4) a reduced :+ phase transition temperature, and (5) an 3
Westinghouse Electric Company Topical Report, WCAP-12610-P-A, "VANTAGE+ Fuel Assembly Reference Core Report," April 1995.
4 Letter from U.S. Nuclear Regulatory Commission to D. A. Christian (Dominion),
"Millstone Power Station, Unit No. 3, Exemption from the Requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 50.44,10 CFR 50.46, and 10 CFR Part 50, Appendix K,"
Docket No. 50-423, February 11, 2004, ADAMS Accession No. ML040070238.
5 Letter from U.S. Nuclear Regulatory Commission to D. M. Jamil (Duke), "Catawba Nuclear Station, Units 1 and 2 RE: Exemption from the Requirements of 10 CFR 50.44, 10 CFR 50.46, and 10 CFR 50 Appendix K," August 4, 2003, ADAMS Accession No. ML032060473.
6 Letter from U.S. Nuclear Regulatory Commission to P. E. Katz (Constellation), "Calvert Cliffs Nuclear Power Plant, Unit No. 2," December 3, 2002, ADAMS Accession No. ML022540002.
improved corrosion resistance. The slight reduction in tin content will not affect the size, shape, or distribution of any second phase or inter-metallic precipitates nor the overall microstructure of this developmental zirconium alloy. With a consistent microstructure, Optimized ZIRLOTM will exhibit material characteristics very similar to that of ZIRLOTM.
In Reference 2, the licensee provided information concerning their post-irradiation examination plan. In Reference 2, the licensee stated that their plan would be consistent with those of the other Optimized ZIRLOTM irradiation programs currently underway. As with the post-irradiation examinations involved in the other irradiation programs, the detailed examinations in the licensees Optimized ZIRLOTM irradiation program will be based on the fuel duty, cycle performance, need for specific information, and time available on site during refueling outages. The measured parameters will include rod profilometry, rod wear, assembly and rod growth, assembly bow, grid cell dimensions, and oxide thickness. As a result of these post-irradiation examinations, any negative aspects of the Optimized ZIRLOTM performance, including the potential impacts of reduced tin content identified above, will be identified and resolved. Furthermore, significant deviations from model predictions will be reconciled.
The fuel rod burnup and fuel duty experienced by the Optimized ZIRLOTM LTAs in STP, Units 1 and 2, will remain well within the operating experience base and applicable licensed limits for ZIRLOTM.
Utilizing currently approved fuel performance and fuel mechanical design models and methods, the STP, Units 1 and 2, and Westinghouse will perform cycle-specific reload evaluations to ensure that the Optimized ZIRLOTM LTAs satisfy design criteria.
Based upon the irradiation experience of LTAs with ZIRLOTM of a similar low tin content, expected performance due to similar material properties, and an extensive LTA post-irradiation examination program aimed at qualifying model predictions, the NRC staff finds the Optimized ZIRLOTM LTA mechanical design acceptable for STP, Units 1 and 2.
3.1.2 Core Physics and Non-LOCA Safety Analysis The STP, Units 1 and 2, exemption request relates solely to the specific types of cladding material specified in the regulations. Due to similar material properties, any impact of Optimized ZIRLOTM on the safety analysis models and methods is expected to be minimal.
Utilizing currently approved core physics, core thermal-hydraulics, and non-LOCA safety analysis models and methods, the licensee and Westinghouse will perform cycle-specific reload evaluations to ensure that the LTAs satisfy design criteria. Fuel management guidelines will require that LTAs be placed in non-limiting core locations. In Reference 2, the licensee described how the power peaking margin would be used to ensure that LTAs will not be limiting.
Based upon the use of approved models and methods, expected material performance, and the placement of LTAs in non-limiting core locations, the NRC staff finds that the irradiation of up to eight Optimized ZIRLOTM LTAs in STP, Units 1 and 2, will not result in unsafe operation nor violation of specified acceptable fuel design limits. Furthermore, in the event of a design-basis accident, these LTAs will not promote consequences beyond those currently analyzed.
3.2 ECCS Performance and Exemptions Pursuant to 10 CFR 50.12, the Commission may, upon application by any interested person or own initiative, grant exemptions from the requirements of 10 CFR Part 50 when (1) the exemptions are authorized by law, will not present an undue risk to public health or safety, and are consistent with the common defense and security; and (2) special circumstances are present. Special circumstances are present if application of the regulation in the particular circumstances would not serve the underlying purpose of the rule, or is not necessary to achieve the underlying purpose of the rule.
The underlying purpose of 10 CFR 50.46 is to establish acceptance criteria for ECCS performance. In Addendum 1 to WCAP-12610-P-A (Reference 7)7, Westinghouse demonstrates that the material properties of Optimized ZIRLOTM are similar to those of the currently approved ZIRLOTM cladding and that the ECCS acceptance criteria for ZIRLOTM clad fuel are also applicable to fuel with Optimized ZIRLOTM cladding. Ring compression tests performed by Westinghouse on Optimized ZIRLOTM demonstrate an acceptable retention of ductility up to 10 CFR 50.46 limits of 2200EF peak cladding temperature and 17 percent total oxidation. Utilizing currently approved LOCA models and methods, Westinghouse will perform cycle-specific reload evaluations to ensure that the Optimized ZIRLOTM LTAs satisfy 10 CFR 50.46 acceptance criteria.
Paragraph I.A.5 of Appendix K to 10 CFR Part 50 states that the rates of energy, hydrogen concentration, and cladding oxidation from the metal-water reaction shall be calculated using the Baker-Just equation. Since the Baker-Just equation presumes the use of zircaloy clad fuel, strict application of the rule would not permit use of the equation for the Optimized ZIRLOTM LTA cladding for determining acceptable fuel performance. Metal-water reaction tests performed by Westinghouse on Optimized ZIRLOTM (documented in Appendix B of Addendum 1 to WCAP-12610-P-A) demonstrate conservative reaction rates relative to the Baker-Just equation. Thus, application of Appendix K, Paragraph I.A.5, in these circumstances, is not necessary for the licensee to achieve the underlying purpose of the regulation.
Based upon the results of metal-water reaction tests and ring-compression tests, which ensure the applicability of ECCS models and acceptance criteria and the use of approved LOCA models to ensure that the Optimized ZIRLOTM LTAs satisfy 10 CFR 50.46 acceptance 7
Westinghouse Electric Company Topical Report, Addendum 1 to WCAP-12610-P-A and CENPD-404-P-A, "Optimized ZIRLO", February 2003.
criteria, the NRC staff finds it acceptable to grant an exemption from the requirements of 10 CFR 50.46 and Appendix K to 10 CFR Part 50 for the use of up to eight LTAs in STP, Units 1 and 2.
3.3 Special Circumstances In summary, the NRC staff has reviewed the licensees request for an exemption to allow up to eight LTAs containing fuel rods, guide thimble tubes, and instrumentation tubes fabricated with Optimized ZIRLOTM to be used in STP, Units 1 and 2. Based on the NRC staffs evaluation, as set forth above, the NRC staff considers that granting the proposed exemption will not defeat the underlying purpose of 10 CFR 50.46, or Appendix K to 10 CFR Part 50. Accordingly, special circumstances, are present pursuant to 10 CFR 50.12(a)(2)(ii).
3.4 Other Standards in 10 CFR 50.12 The NRC staff reviewed information provided by the licensee in References 1 and 2 to support the exemption request, and concluded that the use of Optimized ZIRLOTM would satisfy 10 CFR 50.12(a) as follows:
- 1) The requested exemption is authorized by law:
No law precludes the activities covered by this exemption request. The Commission, based on technical reasons set forth in rulemaking records, specified the specific cladding materials identified in 10 CFR 50.46 and 10 CFR Part 50, Appendix K. Cladding materials are not specified by statute.
- 2) The requested exemption does not present an undue risk to the public health and safety. As stated by the licensee in Reference 1:
The lead test assembly safety evaluation will ensure that these acceptance criteria are met following insertion of the assemblies containing Optimized ZIRLOTM material. Fuel assemblies using Optimized ZIRLOTM cladding will be evaluated using NRC-approved analytical methods and will address the changes in the cladding material properties. The safety analysis for the South Texas Project is supported by the applicable technical specifications. The South Texas Project reload cores containing Optimized ZIRLOTM cladding will continue to be operated in accordance with the operating limits specified in
the technical specifications. Lead test assemblies using Optimized ZIRLOTM cladding will be placed in non-limiting core locations. Therefore, this exemption will not pose an undue risk to public health and safety.
The NRC staff has evaluated these considerations as set forth in Section 3.1 and 3.2 of this Exemption. For the reasons set forth in Sections 3.1 and 3.2, the NRC staff concludes that Optimized ZIRLOTM may be used as a cladding material for up to eight LTAs to be placed in non-limiting core locations in STP, Units 1 and 2, and that an exemption from the requirements of 10 CFR 50.46 and 10 CFR Part 50, Appendix K, does not pose an undue risk to the public health and safety.
- 3) The common defense and security are not affected and, therefore, not endangered by this exemption.
4.0 CONCLUSION
Accordingly, the Commission has determined that, pursuant to 10 CFR 50.12(a), the exemption is authorized by law, will not present an undue risk to the public health and safety, and is consistent with the common defense and security. Also, special circumstances are present. Therefore, the Commission hereby grants STPNOC an exemption from the requirements of 10 CFR Part 50, Appendix K and Section 50.46, for the use of up to eight LTAs containing Optimized ZIRLOTM in STP, Units 1 and 2, up to a lead rod average burnup of 62,000 megawatt days per metric ton of uranium.
Pursuant to 10 CFR 51.32, the Commission has determined that the granting of this exemption will not have a significant effect on the quality of the human environment (69 FR 45352).
This exemption is effective upon issuance.
Dated at Rockville, Maryland, this 19th day of October 2004.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA/
Ledyard B. Marsh, Director Division of Licensing Project Management Office of Nuclear Reactor Regulation