BSEP 06-0128, Request for License Amendments Regarding Fuel Design and Storage Requirements for Areva Np Fuel

Request for License Amendments Regarding Fuel Design and Storage Requirements for Areva Np Fuel

ML070300372
Person / Time
Site:	Brunswick
Issue date:	01/22/2007
From:	Scarola J Progress Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 06-0128, TSC-2006-05
Download: ML070300372 (19)

Text

r

~j Progress Energy James Scarola Brnsick PresriPlnt VrnsicPresi en rPat Progress Energy Carolinas, Inc.

JAN 2 22007 SERIAL: BSEP 06-0 128 10OCFR 50.90 TSC-2006-05 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Docket Nos. 50-325 and 50-324/License Nos. DPR-71 and DPR-62 Request for License Amendments Regarding Fuel Design and Storage Requirements for ARE VA NP Fuel Ladies and Gentlemen:

In accordance with the Code of Federal Regulations, Title 10, Part 50.90, Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc.,

is requesting a revision to the Technical Specifications for the Brunswick Steam Electric Plant (BSEP), Unit Nos. I and 2. The proposed license amendments revise: (1) Technical Specification 4.2. 1, "Fuel Assemblies," to modify the fuel design description to encompass AREVA NP fuel assemblies, and (2) Technical Specification 4.3, "Fuel Storage," to remove nomenclature specific to Global Nuclear Fuels fuel storage criticality analysis methods.

An evaluation of the proposed license amendments is provided in Enclosure 1.

CP&L has evaluated the proposed changes in accordance with 10 CFR 50.9 1(a)(1), using the criteria in 10 CFR 50.92(c), and determined that these changes involve no significant hazards considerations.

CP&L is providing, in accordance with 10 CER 50.91 (b), a copy of the proposed license amendments to the designated representative for the State of North Carolina.

CP&L plans to begin receiving ARE VA NP fuel on December 4, 2007; therefore, NRC approval of the proposed amendments is requested by November 1, 2007, and once approved, the amendments shall be implemented within 30 days following issuance.

There are no regulatory commitments associated with this submittal. Please refer any questions regarding this submittal to Mr. Randy C. Ivey, Manager - Support Services, at (910) 457-2447.

P.O.Bos 10429 Southport, NC28461 T> 910.457.3698 F> 910.457.2803

'-~~

Document Control Desk

.BSEP 06-0 128 / Page 2 1 declare, under penalty of perjury, that the foregoing is true and correct. Executed on January 22, 2007.

Sincerely, James Scarola WRM/wrm

Enclosures:

1. Evaluation of License Amendment Requests

2. Marked-up Technical Specification Pages - Unit 1

3. Typed Technical Specification Pages - Unit 1

4. Typed Technical Specification Pages - Unit 2

Document Control Desk BSEP 06-0 128 / Page 3 cc (with enclosures):

U. S. Nuclear Regulatory Commission, Region 11 ATTN: Dr. William D. Travers, Regional Administrator Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, GA 30303-893 1 U. S. Nuclear Regulatory Commission ATTN: Mr. Eugene M. DiPaolo, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission (Electronic Copy Only)

ATTN: Mr. Stewart N. Bailey (Mail Stop OWEN 8B1) 11555 Rockville Pike Rockville, MID 20852-2738 Ms. Jo A. Sanford Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-05 10 Ms. Beverly 0. Hall, Section Chief Radiation Protection Section, Division of Environmental Health North Carolina Department of Environment and Natural Resources 3825 Barrett Drive Raleigh, NC 27609-7221

BSEP 06-0 128 Enclosure 1 Page 1 of 7 Evaluation of Proposed License Amendment Requests

Subject:

Request for License Amendments Regarding Fuel Design and Storage Requirements for ARE VA NP Fuel 1.0 Description This letter is a request to amend the Technical Specifications of Renewed Operating Licenses DPR-71 and DPR-62 for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2.

The proposed license amendments will revise: (1) Technical Specification 4.2.1, "Fuel Assemblies," to modify the fuel design description to encompass AREVA NP fuel assemblies, and (2) Technical Specification 4.3, "Fuel Storage," to remove nomenclature specific to Global Nuclear Fuels, Americas (GNT-A) fuel storage criticality analysis methods. These proposed Technical Specification changes are needed to support the transition to using AREVA NP fuel.

CP&L is planning to begin using AREVA N-P fuel starting with the BSEP, Unit 1 refueling outage scheduled for March 2008 and the BSEP, Unit 2 refueling outage scheduled for February 2009.

2.0 Proposed Changes Fuel Design Description Technical Specification 4.2.1, "Fuel Assemblies,", is being revised to provide a description that is compatible with both the ARE VA NP ATRIUMTM-10 and GNF-A fuel assemblies. The specific change to Technical Specification 4.2.1 is shown in bold typeface.

4.2.1 Fuel Assemblies The reactor shall contain 560 fuel assemblies. Each assembly shall consist of a matrix of Zircaloy clad fuel rods with an initial composition of natural or slightly enriched uranium dioxide (U0 2 ) as fuel material, gadolinia rods, water rods or channels, and a surrounding channel. Limited substitutions of zirconium alloy or stainless steel filler rods for fuel rods, in accordance with approved applications of fuel rod configurations, may be used. Fuel assemblies shall be limited to those fuel designs that have been analyzed with NRC staff approved codes and methods and have been shown by tests or analyses to comply with all safety design bases.

A limited number of lead test assemblies that have not completed representative testing may be placed in non-limiting core regions.

BSEP 06-0 128 Enclosure 1 Page 2 of 7 Stored Fuel Analysis Methods Technical Specification 4.3.1 is being revised to eliminate Technical Specification 4.3. 1.1.-b and Technical Specification 4.3.1.2.a, as shown below. The specific changes to Technical Specification 4.3.1 are shown in bold typeface.

4.3.1 Criticality 4.3. 1.1 The spent fuel storage racks are designed and shall be maintained with:

a. Pressurized Water Reactor (PWR) fuel assemblies having a maximum k-infinity of 1.41 in the normal reactor core configuration at cold conditions;

b. (Not used.)

C. keff *- 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties as described in Section 9.1 of the IJFSAR; and

d. Sufficient center to center distance between fuel assemblies placed in the storage racks to ensure the keff limit is not exceeded.

4.3.1.2 The new fuel storage racks are designed and shall be maintained with:

a. (Not used.)

b. keff *! 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties as described in Section 9.1 of the UIFSAR; C. keff *5 0.90 when in a dry condition, which includes an allowance for uncertainties as described in Section 9.1 of the UESAR; and

d. Sufficient center to center distance between fuel assemblies placed in storage racks to ensure the keff limits are not exceeded. contains a marked-up version of the Unit 1 Technical Specifications showing the proposed changes. Since Technical Specification Sections 4.2.1, 4.3. 1.1, and 4.3.1.2 for Unit 1 and Unit 2 are identical, only the mark-up for Unit 1 is provided. Enclosures 4 and 5 provide typed versions of the affected Unit 1 and Unit 2 Technical Specification pages, respectively.

These typed Technical Specification pages are to be used for issuance of the proposed amendments. There are no Technical Specification Bases changes associated with the changes to the fuel design description and the fuel storage criticality analysis methods.

B SEP 06-0 128 Enclosure 1 Page 3 of 7 3.0 Background On March 10, 2006, CP&L held a public meeting with the NRC to discuss plans to change the Brunswick Unit I and 2 reioad fuel supplier from GNF-A to ARE VA NP. A summary of this meeting was issued by the NRC on April 27, 2006 (i.e., Reference 1). As presented during the public meeting, CP&L plans included submittal of at least two separate license amendment applications to request the Technical Specification changes needed to support loading and use of the ATRIIJMTM-1O fuel assemblies.

This letter provides the proposed Technical Specification changes to allow for receipt and storage of the ATRIUMTM-1I fuel assemblies. Under a separate submittal (i.e., Reference 2), CP&L has submitted proposed changes necessary to incorporate the AREVA NP analytic methods, previously approved by the NRC, that will be used to establish core operating limits. If changes to the Minimum Critical Power Ratio (MCPR) Safety Lim-it (SL) values are required to support operation with the ATRIUMTM- 10 fuel, CP&L anticipates submittal of those MCPR SL changes in July 2007.

CP&L plans to begin receiving ARE VA fuel in December 2007, for loading during the Unit 1 refueling outage scheduled to begin in March 2008. To support the fuel receipt schedule, CP&L is requesting issuance of the proposed license amendments by November 1, 2007.

4.0 Technical Analysis Fuel Design Description Currently, Technical Specification 4.2.1, "Fuel Assemblies," provides a general description of fuel assembly designs in use at BSEP, Units 1 and 2. CP&L currently uses only GNF-A fuel, and the description in Technical Specification 4.2.1 is consistent with the physical characteristics of GNV-A fuel. A minor change is needed to Technical Specification 4.2.1 to revise the description of the fuel assemblies to be compatible with ARE VA NP ATRIUMTM-10 fuel. The ATRflJMTM-10 fuel assembly design uses a water channel to increase neutron moderation rather than the water rods used in GNIF-A designs. The Technical Specification 4.2.1 description is being modified to reference water channels as well as water rods so that the description is applicable to both GNF-A and ARE VA NP fuel.

Stored Fuel Analysis Methods Technical Specifications 4.3.1.1 and 4.3.1.2 address fuel storage criticality design criteria for the spent fuel pool racks and the new fuel storage racks, respectively. Brunswick Updated Final Safety Analysis Report (UVSAR), Sections 9.1.1, "New Fuel Storage," and 9.1.2, "Spent Fuel Storage," provide criticality criteria for the new fuel storage racks and spent fuel storage racks, respectively. The spent fuel pool storage racks are used for the storage of spent fuel and temporary storage of new fuel prior to loading in the reactor core.

BSEP 06-0128 Enclosure 1 Page 4 of 7 For the spent fuel pooi racks, the UFSAR criticality criterion specifies that the effective multiplication factor will be less than or equal to 0.95 (i.e., see IIFSAR Sections 9.1.2.1 and 9.1.2.3.2. 1). This cri terion is restated in Technical Specification 4.3. 1.1I.c. For the new fuel pool racks, the UFSAR criticality criterion specifies that the effective multiplication factor will be less than or equal to 0.90 for dry conditions and less than or equal to 0.95 for wet conditions (i.e., see UFSAR Section 9.1.1.3). This criterion is restated in Technical Specification 5.3.1.2.b and Technical Specification 5.3.1 .2.c.

Technical Specifications 4.3.1.1 and 4.3.1.2 prescribe the use of an in-core k-infinity criteria. As explained in Section 3.5 of NEDE-24011I-P-A, , General Electric StandardApplication for Reactor Fuel, the k-infinity criteria in Technical Specifications 4.3. 1.1Lb and 4.3.1.2.a are the uncontrolled lattice k-infinity criteria used in the GNIF criticality methodology to ensure the storage rack effective multiplication factor criteria (i.e., Technical Specification 4.3. 1.1Lc, Technical Specification 4.3.1.2.b, and Technical Specification 4.3.1.2.c) are satisfied for the GE fuel types. AREVA NP uses an in-pool k-effective criticality criteria, on an assembly basis, of less than or equal to 0.95, or less than or equal to 0.90 under dry conditions for the new fuel pool racks. AREVA determines the pool k-effective by using computer codes, such as KENO, and includes cycle-specific factors, such as fuel enrichments, gadolinia loadings, fuel types, and the worst (i.e., most conservative) credible conditions.

Until now, including the k-infinity methodology criteria has not been a problem because only GNF-A fuel was being used at BSEP, Units 1 and 2. However, with the introduction of ARE VA NP fuel at BSEP, if the GNE-A k-infinity criteria were to be retained, a distinction would need to be made so that Technical Specification 4.3. 1.1Lb and Technical Specification 4.3.1.2.a would apply only to GNE-A fuel. A review of Technical Specifications from several BWR facilities that already use both GNF-A and AREVA N-P fuel showed that that these facilities did not have vendor-specific acceptance cri teria equivalent to 4.3. 1.1Lb and 4.3.1.2.a in their Technical Specifications. The removal of the k-infinity criteria from the BSEP Technical Specifications will not impact the basic criticality criteria associated with the storage of irradiated fuel (i.e., Technical Specification 4.3. 1.1Lc) and new fuel (i.e., Technical Specification 4.3.1.2.b and Technical Specification 4.3.1.2.c). Therefore, to enhance clari ty and to ensure consistency with how these requirements have been handled at other BWR plants, the vendor-specific k-infinity criteria for BWR fuel is being eliminated in Technical Specification 4.3. 1.1Lb and 4.3.1.2.a. This change will make Technical Specification 4.3. 1.1 and 4.3.1.2 compatible with the storage of both GNE-A and ARE VA NP fuel.

5.0 Regulatory Safety Analysis 5.1 No Significant Hazards Consideration Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc., is submitting proposed amendments to support transition to AREVA NP fuel and core design and analysis services. The proposed amendments: (1) revise Technical

BSEP 06-0 128 Enclosure 1 Page 5 of 7 Specification 4.2. 1, "Fuel Assemblies," to modify the fuel design description to encompass the AREVA NP fuel assemblies, and (2) revise Technical Specification 4.3, "Fuel Storage," to remove nomenclature specific to Global Nuclear Fuels - Americas (GNF-A) analysis methods.

CP&L has evaluated whether or not a significant hazards consideration is involved with the proposed amendments by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

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

Response: No The proposed amendments revise the fuel bundle description contained in Technical Specification 4.2. 1, "Fuel Assemblies," to reflect both the existing fuel designs in use and the new AREVA NP fuel design. The change to the fuel assembly description involves a minor revision to reflect that ARE VA fuel assemblies have a water channel.

The proposed amendments also revise Technical Specification 4.3, "Fuel Storage," to remove criteria specific to GNF-A fuel storage criticality methods. The criticality analysis criteria being retained in Technical Specifications 4.3. 1.1 and 4.3.1.2 will continue to ensure that adequate criticality margins are maintained for new and spent fuel storage.

These changes do not involve any plant modifications or operational changes that could affect system reliability, performance, or possibility of an operator error. These requested changes do not affect any postulated accident precursors, do not affect the performance of any accident mitigation systems, and do not introduce any new accident initiation mechanisms.

Based on the above, the proposed amendments do not involve an increase in the probability or consequences of an accident previously evaluated.

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

Response: No As previously stated, the proposed amendments revise Technical Specification fuel bundle description and fuel storage rack criticality requirements to support receipt and storage of a new fuel bundle manufactured by a different vendor. Analytic methods will continue to be used to demonstrate the criticality acceptability of fuel being stored in the new and spent fuel storage racks. As such, the proposed amendments do not create the possibility of a new or different kind of accident from any accident previously evaluated.

BSEP 06-0 128 Enclosure 1 Page 6 of 7

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

Response: No The proposed amendments incorporate an administrative revision to the Technical Specification fuel bundle description and modify the fuel storage Technical Specification requirements to remove vendor-specific nomenclature for criticality analysis criteria.

Criticality analyses for new and spent fuel storage will continue to ensure compliance with fuel storage and criticality criteria described in the Updated Final Safety Analysis Report.

Therefore, the proposed amendments do not involve a significant reduction in a margin of safety.

Based on the above, CP&L concludes that the proposed amendments present no significant hazards consideration under the standards set forth in 10 CER 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

5.2 Applicable Regulatory Requirements/Criter~ia 10 CFR 50.36, "Technical Specifications," provides the regulatory requirements for the content required in a licensee's Technical Specifications. 10 CFR 50.36(c) delineates the items to be included in the Technical Specifications. 10 CFR 50.36(c)(4) requires that the design features include those features of the facility such as materials of construction and geometric arrangements, which, if altered or modified, would have a significant effect on safety and are not covered in categories described in paragraphs (c)(1), (2), and (3) of this section. Based on the above, the controls and analytical methods used for the fuel storage racks are included in Section 4 of the Technical Specifications.

The BSEP design was reviewed for construction under the "General Design Criteria for Nuclear Power Plant Construction" issued for comment by the Atomic Energy Commission (AEC) in July 1967 and is committed to meet the intent of the GDC, published in the Federal Register on May 21, 1971, as Appendix A to 10 CER Part 50. Controls and analytical methods will continue to be employed to ensure criticality in the fuel storage racks will be prevented. As such, conformance with GDC 62, "Prevention of criticality in fuel storage and handling," is not impacted by the proposed changes to fuel storage rack criticality requirements.

6.0 Environmental Considerations A review has determined that the proposed amendments would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendments do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released

BSEP 06-0 128 Enclosure 1 Page 7 of 7 offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendments meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 5 1.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendments.

7.0 References

1. "Summary of March 10, 2006, Meeting with Carolina Power & Light Company (CP&L),

Regarding the Fuel Transition Process and Licensing Submittals for Brunswick Steam Electric Plant, Units 1 and 2," dated April 27, 2006, ADAMS Accession Number ML061000574.

2. Letter from Mr. James Scarola (CP&L) to the Document Control Desk (NRC), "Request for License Amendments Regarding Linear Heat Generation Rate and Core Operating Limits Report References for ARE VA NP Fuel," dated January 22, 2007.

BSEP 06-0128 Enclosure 2 Markup of Technical Specification Pages - Unit I

Design Features 4.0 4.0 DESIGN FEATURES 4.1 Site Location 4.1.1 Site and Exclusion Areas The site area and exclusion area are the same area. This area is and shall be maintained as the area located within the site area boundary as shown in Figure 4.1-1.

4.1.2 Low Population Zone The low population zone is and shall be maintained as the area located within a circle with its center at the plant and a radius of two miles.

4.2 Reactor Core 4.2.1 Fuel AssembliesorCkxret The reactor shall contain 560 fuel assemblies. Each assembly sshall consist of aa matrix of Zircaloy clad fuel rods with an initial composition of natural or slightly enriched uranium dioxide (U0 2 ) as fuel material, gadol~inia rods, water rod and a surrounding channel. Limited substitutions of zirconium alloy or stainless steel filler rods for fuel rods, in accordance with approved applications of fuel rod configurations, may be used. Fuel assemblies shall be limited to those fuel designs that have been analyzed with NRC staff approved codes and methods and have been shown by tests or analyses to comply with all safety design bases. A limited number of lead test assemblies that have not completed representative testing may be placed in nonlimiting core regions.

4.2.2 Control Rod Assemblies The reactor core shall contain 137 cruciform shaped control rod assemblies. The control material shall be boron carbide or hafnium absorber material as approved by the NRC.

(continued)

Brunswick Unit 1 4.0-1 BruswckUni I4.-1Amendment No. (0

Design Features 4.0 4.0 DESIGN FEATURES (continued) 4.3 Fuel Storage 4.3.1 Criticality 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with:

a. Pressurized Water Reactor (PWR) fuel assemblies having a maximum k-infinity of 1.41 in the normal reactor core configuration at cold conditions;

c. kff *ý0.95 if fully flooded with unborated water, which includes an allowance for uncertainties as described in Section 9.1 of the UFSAR; and

d. Sufficient center to center distance between fuel assemblies placed in the storage racks to ensure the keff limit is not exceeded.

4.3.1.2 The new fuel storage racks are designed and shall be maintained with:

b. kef *! 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties as described in Section 9.1 of the UFSAR;

c. kff

• 0.90 when in a dry condition, which includes an allowance for uncertainties as described in Section 9.1 of the UFSAR; and

d. Sufficient center to center distance between fuel assemblies placed in storage racks to ensure the keff limits are not exceeded.

(nontinued)i Brunswick Unit 14.-Amnet 4.0-2 Amendment No.(2-9-5)

BSEP 06-0 128 Enclosure 3 Typed Technical Specification Page - Unit I

Design Features 4.0 4.0 DESIGN FEATURES 4.1 Site Location 4.1.1 Site and Exclusion Areas The site area and exclusion area are the same area. This area is and shall be maintained as the area located within the site area boundary as shown in Figure 4.1-1.

4.1.2 Low Population Zone The low population zone is and shall be maintained as the area located within a circle with its center at the plant and a radius of two miles.

4.2 Reactor Core 4.2.1 Fuel Assemblies The reactor shall contain 560 fuel assemblies. Each assembly shall consist of a matrix of Zircaloy clad fuel rods with an initial composition of natural or slightly enriched uranium dioxide (U0 2) as fuel material, gadolinia rods, water rods or channels, and a surrounding channel. Limited substitutions of zirconium alloy or stainless steel filler rods for fuel rods, in accordance with approved applications of fuel rod configurations, may be used. Fuel assemblies shall be limited to those fuel designs that have been analyzed with NRC staff approved codes and methods and have been shown by tests or analyses to comply with all safety design bases. A limited number of lead test assemblies that have not completed representative testing may be placed in nonlimiting core regions.

4.2.2 Control Rod Assemblies The reactor core shall contain 137 cruciform shaped control rod assemblies.

The control material shall be boron carbide or hafnium absorber material as approved by the NRC.

(continued)

Brunswick Unit 1 4.0-1 Bruswik Uit 4.-1Amendment No. I

Design Features 4.0 4.0 DESIGN FEATURES (continued) 4.3 Fuel Storage 4.3.1 Criticality 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with:

a. Pressurized Water Reactor (PWR) fuel assemblies having a maximum k-infinity of 1.41 in the normal reactor core configuration at cold conditions;

b. (Not used.)

c. keff!* 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties as described in Section 9.1 of the UFSAR; and

d. Sufficient center to center distance between fuel assemblies placed in the storage racks to ensure the keff limit is not exceeded.

4.3.1.2 The new fuel storage racks are designed and shall be maintained with:

a. (Not used.)

b. keff *ý0.95 if fully flooded with unborated water, which includes an allowance for uncertainties as described in Section 9.1 of the UFSAR;

c. k~ff *! 0.90 when in a dry condition, which includes an allowance for uncertainties as described in Section 9.1 of the UFSAR; and

d. Sufficient center to center distance between fuel assemblies placed in storage racks to ensure the k~ff limits are not exceeded.

(continued)

Brunswick Unit 1 4.0-2 Bruswik Uit 4.-2Amendment No. I

BSEP 06-0128 Enclosure 4 Typed Technical Specification Page - Unit 2

Design Features 4.0 4.0 DESIGN FEATURES 4.1 Site Location 4.1.1 Site and Exclusion Areas The site area and exclusion area are the same area. This area is and shall be maintained as the area located within the site area boundary as shown in Fig ure 4.1 -1.

4.1.2 Low Population Zone The low population zone is and shall be maintained as the area located within a circle with its center at the plant and a radius of two miles.

4.2 Reactor Core 4.2.1 Fuel Assemblies The reactor shall contain 560 fuel assemblies. Each assembly shall consist of a matrix of Zircaloy clad fuel rods with an initial composition of natural or slightly enriched uranium dioxide (U0 2 ) as fuel material, gadolinia rods, water rods or channels, and a surrounding channel. Limited substitutions of zirconium alloy or stainless steel filler rods for fuel rods, in accordance with approved applications of fuel rod configurations, may be used. Fuel assemblies shall be limited to those fuel designs that have been analyzed with NRC staff approved codes and methods and have been shown by tests or analyses to comply with all safety design bases. A limited number of lead test assemblies that have not completed representative testing may be placed in nonlimiting core regions.

4.2.2 Control Rod Assemblies The reactor core shall contain 137 cruciform shaped control rod assemblies.

The control material shall be boron carbide or hafnium absorber material as approved by the NRC.

(continued)

Brunswick Unit 2 4.0-1 Bruswik Uit 4.-1Amendment No. I

Design Features 4.0 4.0 DESIGN FEATURES (continued) 4.3 Fuel Storage 4.3.1 Criticality 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with:

a. Pressurized Water Reactor (PWR) fuel assemblies having a maximum k-infinity of 1.41 in the normal reactor core configuration at cold conditions;

b. (Not used.)

c. keff *ý0.95 if fully flooded with unborated water, which includes an allowance for uncertainties as described in Section 9.1 of the UFSAR; and

d. Sufficient center to center distance between fuel assemblies placed in the storage racks to ensure the keff limit is not exceeded.

4.3.1.2 The new fuel storage racks are designed and shall be maintained with:

a. (Not used.)

b. keff

• 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties as described in Section 9.1 of the UFSAR;

c. keff *ý0.90 when in a dry condition, which includes an allowance for uncertainties as described in Section 9.1 of the UFSAR; and

d. Sufficient center to center distance between fuel assemblies placed in storage racks to ensure the keff limits are not exceeded.

(continued)

Brunswick Unit 2 4.0-2 Bruswik Uit 4.-2Amendment No. I