ML080320284

License Amendment Request to Support Use of M5 Alloy

ML080320284
Person / Time
Site:	Palisades
Issue date:	01/31/2008
From:	Schwarz C Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML080320284 (15)

Text

Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 January 31,2008 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Palisades Nuclear Plant Docket 50-255 License No. DPR-20 License Amendment Request to Support Use of M5 Allov

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Entergy Nuclear Operations, Inc (ENO) requests Nuclear Regulatory Commission (NRC) review and approval of a proposed license amendment for the Palisades Nuclear Plant (PNP). EN0 proposes to revise Appendix A, Technical Specifications (TS), to change the description of fuel assemblies specified in TS 4.2.1, and add the Framatome Advanced Nuclear Power, Inc. (ANP) report, BAW-10240(P)-A, "hcorporation of M5 Properties in Framatome ANP Approved Methods," to the analytical methods referenced in TS 5.6.5.b to permit the use of M5 alloy for fuel rod cladding and fuel assembly structural components in future operating cycles. provides a detailed description of the proposed change, background and technical analysis, No Significant Hazards Consideration Determination, and Environmental Review Consideration. Enclosure 2 provides the revised TS pages reflecting the proposed change. Enclosure 3 provides the annotated TS pages showing the changes proposed.

E N 0 requests approval of the proposed license amendment request by March 1, 2009, with the amendment being implemented within 90 days.

27780 Blue Star Memorial Highway Covert, Michigan 49043-9530 Telephone: 269.764.2000

Document Control Desk Page 2 A copy of this request has been provided to the designated representative of the State of Michigan.

Summary of Commitments This letter contains no new commitments and no revisions to existing commitments.

I declare under penalty of perjury that the foregoing is true and correct. Executed on January 31, 2008.

Site vice President Palisades Nuclear Plant Enclosures (3)

CC Regional Administrator, Region Ill, USNRC Project Manager, Palisades, USNRC NRC Resident Inspector, Palisades, USNRC

ENCLOSURE 1 DESCRIPTION OF REQUESTED CHANGES

1.0 DESCRIPTION

Entergy Nuclear Operations, Inc (ENO) requests to amend Renewed Facility Operating License DPR-20 for the Palisades Nuclear Plant (PNP) to permit the use of M5 alloy for fuel rod cladding and fuel assembly structural components in future operating cycles. The proposed change would revise the Appendix A, Technical Specifications (TS), to change the description of fuel assemblies specified in TS 4.2.1, and add the Framatome Advanced Nuclear Power, Inc.

(ANP) report, BAW-10240(P)-A, "Incorporation of M5 Properties in Framatome ANP Approved Methods," to the analytical methods referenced in TS 5.6.5.b to permit the use of M5 alloy for fuel rod cladding and fuel assembly structural components in future operating cycles.

2.0 PROPOSED CHANGE

EN0 proposes to:

Revise TS 5.6.5.b to add BAW-10240(P)-A, "Incorporation of M5 Properties in Framatome ANP Approved Methods."

Add the M5 advanced alloy to the description of fuel assemblies in TS 4.2.1.

3.0 BACKGROUND

Currently, the fuel cladding used at the PNP is zircaloy-4, which is allowed by TS 4.2.1. Framatome ANP developed the M5 advanced fuel rod cladding and fuel assembly structural material. M5 is a binary zirconium alloy composed of zirconium and niobium (1 percent nominal). Alloy M5 has demonstrated superior corrosion resistance and reduced creep relative to both standard and low-tin zircaloy-4.

The M5 alloy would be used at the PNP for fuel rod cladding, as well as for fuel assembly spacer grids, fuel rod end plugs, and fuel assembly instrument tubes and guide bars.

4.0 TECHNICAL ANALYSIS

BAW-10240(P)-A (Reference 1) describes the incorporation of the Nuclear Regulatory Commission (NRC)-approved M5 material properties (References 2 and 3) into a set of NRC-approved mechanical analysis, small break loss-of-coolant accident (SBLOCA), and non-loss-of-coolant accident (non-LOCA) methodologies. Mechanical analysis methodology is summarized in

Reference 4; the SBLOCA methodology is summarized in Reference 5, and the non-LOCA methodologies are summarized in References 6 and 7.

The PNP TS 5.6.5.b currently includes three topical reports that were not considered in the evaluation presented in BAW-10240(P)-A:

Topical reports ANF-84-73 Appendix B (Reference 9) and ANF-89-151 (Reference 10) are non-LOCA transient analyses methodologies.

Topical report XN-NF-621(Reference 11) describes a departure from nucleate boiling (DNB) correlation applicable to a Bi-metallic spacer.

BAW-10240(P)-Ademonstrates that non-LOCA and DNB related topical reports do not require revision to address the use of M5 cladding since there is a negligible impact of the M5 cladding on non-LOCA transients and no impact on the DNB correlations. Therefore, continued reference to these three topical reports in the Palisades Technical Specifications is acceptable.

All required safety limits for future operating cycles at the PNP would continue to be analyzed using methodologies approved by the NRC. Therefore, this proposed change will have no adverse impact on plant safety.

5.0 REGULATORY SAFETY ANALYSIS 5.1 No Sianificant Hazards Consideration Entergy Nuclear Operations, Inc (ENO) has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment," as discussed below:

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

Response: No.

The proposed license amendment adds a Nuclear Regulatory Commission approved analytical method, BAW-10240(P)-A, "Incorporation of M5 Properties in Framatome ANP Approved Methods,"

used to determine the core operating limits, to Technical Specification (TS) 5.6.5.b and changes the description of fuel assemblies specified in TS 4.2.1 to allow use of the M5 alloy. The proposed amendment does not affect the acceptance criteria for any Final Safety Analysis Report (FSAR) safety analysis analyzed accidents and anticipated operational occurrences. As such, the proposed amendment does not increase the probability or consequences of an accident. The proposed amendment does not involve operation of the required structures, systems or Page 2 of 6

components (SSCs) in a manner or configuration different from those previously recognized or evaluated.

Therefore, operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No.

Use of M5 clad fuel will not result in changes in the operation or configuration of the facility. Topical report BAW-10240(P)-A describes, by reference, that the material properties of the M5 alloy are similar or better than those of zircaloy-4. Therefore, M5 fuel rod cladding and fuel assembly structural components will perform similarly to those fabricated from zircaloy-4, thus precluding the possibility of the fuel becoming an accident initiator and causing a new or different type of accident.

Since the material properties of M5 alloy are similar or better than those of zircaloy-4, there will be no significant changes in the types of any effluents that may be released off-site. There will not be a significant increase in occupational or public radiation exposure.

The proposed amendment does not involve operation of any required SSCs in a manner or configuration different from those previously recognized or evaluated. No new failure mechanisms will be introduced by the changes being requested.

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

Page 3 of 6

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

Response: No.

The proposed change will not involve a significant reduction in the margin of safety because it has been demonstrated that the material properties of the M5 alloy are not significantly different from those of zircaloy-4.

M5 alloy is expected to perform similarly or better than zircaloy-4 for all normal operating and accident scenarios, including both loss-of-coolant accident (LOCA) and non-LOCA scenarios. The proposed changes do not affect the acceptance criteria for any FSAR safety analysis analyzed accidents or anticipated operational occurrences. All required safety limits would continue to be analyzed using methodologies approved by the Nuclear Regulatory Commission.

Therefore, the proposed amendment would not involve a significant reduction in a margin of safety.

Based on the evaluation above, E N 0 concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

5.2 Applicable Reaulatorv Requirementslcriteria The proposed changes have been evaluated to determine whether applicable regulations and requirements continue to be met. Exemption from the requirements of 10 CFR 50.46, "Acceptance Criteria For Emergency Core Cooling Systems For Light-Water Nuclear Power Reactors," and 10 CFR 50, Appendix K, "ECCS Evaluation Models," for use of M5 fuel cladding for the Palisades Nuclear Plant was approved by the NRC on October 16,2006 (ADAMS accession # ML062560179). The proposed change does not require relief from other regulatory requirements, other than the TS change, and does not affect conformance with any General Design Criterion differently than described in the FSAR.

In conclusion, based on the considerations described above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Page 4 of 6

6.0 ENVIRONMENTAL CONSlDERATlON EN0 has determined that the proposed amendment 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 amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(~)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7.0 REFERENCES

1. BAW-10240(P)-A, Revision 0, ""corporation of M5 Properties in Framatome ANP Approved Methods," dated May 2004.

2. BAW-10227(P)(A) Revision 1, "Evaluation of Advanced Cladding and Structural Material(M5) in PWR Reactor Fuel," Framatome ANP, June 2003.

3. BAW-10231P-A, "COPERNIC Fuel Rod Design Computer Code," Framatome Cogema Fuels, April 2002.

4. EMF-92-116(P)(A) Revision 0, "Generic Mechanical Design Criteria for PWR Fuel Designs," Siemens Power Corporation, February 1999.

5. EMF-2328(P)(A) Revision 0, "PWR Small Break LOCA Evaluation Model, S-RELAP5 Based,"Framatome ANP Richland, Inc., March 2001 .

6. EMF-231O(P)(A) Revision 0, "SRP Chapter 15 Non-LOCA Methodology for Pressurized Water Reactors," Framatome ANP Richland Inc., May 2001.

7. EMF-1961(P)(A) Revision 0, "Statistical Setpointrrransient Methodology for Combustion Engineering Type Reactors," Siemens Power Corporation, July 2002.

8. EMF-2103 (P)(A), Revision 0, "Realistic Large Break LOCA Methodology for Pressurized Water Reactors," dated April 2003.

9. ANF-84-73 Appendix B (P)(A), "Advanced Nuclear Fuels Methodology for Pressurized Water Reactors: Analysis of Chapter 15 Events," Advanced Nuclear Fuels Corporation.

Page 5 of 6

lo. ANF-89-151(P)(A), "ANF-RELAP Methodology for Pressurized Water Reactors: Analysis of Non-LOCA Chapter 15 Events," Advanced Nuclear Fuels Corporation.

11. XN-NF-621(P)(A), "Exxon Nuclear DNB Correlation for PWR Fuel Designs,"

Exxon Nuclear Company.

12. Letter from L. Mark Padovan to Paul A. Harden, "Palisades Nuclear Plant -

Exemption From The Requirements of 10 CFR Part 50, Section 50.46, and Appendix K to 10 CFR Part 50 For Use of M5 Cladding (TAC NO. MC8576),"

dated October 16,2006. (ADAMS accession # ML062560179) 8.0 PRECEDENCE The NRC approved a similar license amendment request for Arkansas Nuclear One (ANO) Unit 1, Docket No. 50-313 (ADAMS accession # ML052380280), on September 12, 2005. Amendment 226 revised Technical Specification 4.2.1, which describes design features for fuel assembles, to allow use of M5 alloy as fuel rod cladding and fuel assembly structural material. Amendment 226 also included other changes to the AN0 Technical Specifications that are not applicable to Palisades.

Page 6 of 6

ENCLOSURE 2 LICENSE AMENDMENT REQUEST TO SUPPORT USE OF M5 FUEL CLADDING REVISED TECHNICAL SPECIFICATION PAGES 4.0-1 and 5.0-27 AND RENEWED OPERATING LICENSE PAGE CHANGE INSTRUCTIONS 3 Pages Follow

ATTACHMENT TO LICENSE AMENDMENT NO.

RENEWED FACILITY OPERATING LICENSE NO. DPR-20 DOCKET NO. 50-255 Remove the following pages of Appendix A Technical Specifications and replace with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT

Design Features 4.0 4.0 DESIGN FEATURES 4.1 Site Location The Palisades Nuclear Plant is located on property owned by Entergy Nuclear Palisades, LLC on the eastern shore of Lake Michigan approximately four and one-half miles south of the southern city limits of South Haven, Michigan. The minimum distance to the boundary of the exclusion area as defined in 10 CFR 100.3 shall be 677 meters.

4.2 Reactor Core 4.2.1 Fuel Assemblies The reactor core shall contain 204 fuel assemblies. Each assembly shall consist of a matrix of zircaloy-4 or M5 clad fuel rods with an initial composition of depleted, natural, or slightly enriched uranium dioxide (U02) as fuel material.

I Limited substitutions of zirconium alloy or stainless steel filler rods for fuel rods, in accordance with approved applications of fuel rod configurations, may be used.

Fuel assemblies shall be limited to those fuel designs that have been analyzed with applicable NRC staff approved codes and methods and shown by tests or analyses to comply with all fuel safety design bases. A limited number of lead test assemblies that have not completed representative testing may be placed in nonlimiting core regions. A core plug or plugs may be used to replace one or more fuel assemblies subject to the analysis of the resulting power distribution.

Poison may be placed in the fuel bundles for long-term reactivity control.

4.2.2 Control Rod Assemblies The reactor core shall contain 45 control rods. Four of these control rods may consist of part-length absorbers. The control material shall be silver-indium-cadmium, as approved by the NRC.

4.3 Fuel Storage 4.3.1 Criticality 4.3.1 . I The Region I fuel storage racks (See Figure B 3.7.16-1) are designed and shall be maintained with:

a. Fuel assemblies having a maximum planar average U-235 enrichment of 4.95 weight percent; Palisades Nuclear Plant 4.0-1 Amendment No. 4@,207,224,

Reporting Requirements 5.6 5.6 Reporting Requirements COLR (continued)

14. EMF-92-116(P)(A), "Generic Mechanical Design Criteria for PWR Fuel Designs," Siemens Power Corporation.

(LCOs 3.1.6, 3.2.1, 3.2.2, & 3.2.4)

15. EMF-2087(P)(A), "SEMIPWR-98: ECCS Evaluation Model for PWR LBLOCA Applications," Siemens Power Corporation.

(LCOs 3.1.6, 3.2.1, & 3.2.2)

16. ANF-87-150 Volume 2, "Palisades Modified Reactor Protection System Report: Analysis of Chapter 15 Events," Advanced Nuclear Fuels Corporation. [Approved for use in the Palisades design during the NRC review of license Amendment 118, November 15, 19881 (LCOs 3.1.6, 3.2.1, 3.2.2, & 3.4.1)

17. EMF-1961(P)(A), Revision 0, Siemens Power Corporation, July 2000, "Statistical SetpoinVTransient Methodology for Combustion Engineering Type Reactors." (LCOs 3.1.6, 3.2.1, 3.2.2, 3.2.4, &

3.4.1)

18. EMF-2328 (P)(A), Revision 0, Framatome ANP, lnc., March 2001, "PWR Small Break LOCA Evaluation Model, S-RELAP5 Based."

(LCOs 3.1.6, 3.2.1, & 3.2.2)

19. BAW-2489P, "Revised Fuel Assembly Growth Correlation for Palisades." (LCOs 3.1.6, 3.2.1, 3.2.2, & 3.2.4)

20. EMF-2103(P)(A), "Realistic Large Break LOCA Methodology for Pressurized Water Reactors." (LCOs 3.1.6, 3.2.1, & 3.2.2)

21. BAW-10240(P)-A, "Incorporation of M5 Properties in Framatome ANP Approved Methods." (LCOs 3.1.6, 3.2.1, 3.2.2, 3.2.4, & 3.4.1)

c. The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems limits, nuclear limits such as shutdown margin, transient analysis limits, and accident analysis limits) of the safety analysis are met.

d. The COLR, including any mid cycle revisions or supplements, shall be provided, upon issuance for each reload cycle, to the NRC.

Palisades Nuclear Plant 5.0-27 Amendment No. U39,W,289,213.,

a, a,

ENCLOSURE 3 LICENSE AMENDMENT REQUEST TO SUPPORT USE OF M5 FUEL CLADDING MARK-UP OF TECHNICAL SPECIFICATION PAGES 4.0-1 and 5.0-27 (showing proposed changes)

(additions are highlighted; deletions are strikethrough) 2 Pages Follow

Design Features 4.0 4.0 DESIGN FEATURES 4.1 Site Location The Palisades Nuclear Plant is located on property owned by Entergy Nuclear Palisades, LLC on the eastern shore of Lake Michigan approximately four and one-half miles south of the southern city limits of South Haven, Michigan. The minimum distance to the boundary of the exclusion area as defined in 10 CFR 100.3 shall be 677 meters.

4.2 Reactor Core 4.2.1 Fuel Assemblies The reactor core shall contain 204 fuel assemblies. Each assembly shall consist of a matrix of zircaloy-4 g W clad fuel rods with an initial composition of depleted, natural, or slightly enriched uranium dioxide (U02) as fuel material.

Limited substitutions of zirconium alloy or stainless steel filler rods for fuel rods, in accordance with approved applications of fuel rod configurations, may be used.

Fuel assemblies shall be limited to those fuel designs that have been analyzed with applicable NRC staff approved codes and methods and shown by tests or analyses to comply with all fuel safety design bases. A limited number of lead test assemblies that have not completed representative testing may be placed in nonlimiting core regions. A core plug or plugs may be used to replace one or more fuel assemblies subject to the analysis of the resulting power distribution.

Poison may be placed in the fuel bundles for long-term reactivity control.

4.2.2 Control Rod Assemblies The reactor core shall contain 45 control rods. Four of these control rods may consist of part-length absorbers. The control material shall be silver-indium-cadmium, as approved by the NRC.

4.3 Fuel Storage 4.3.1 Criticality 4.3.1 . I The Region I fuel storage racks (See Figure B 3.7.16-1) are designed and shall be maintained with:

a. Fuel assemblies having a maximum planar average U-235 enrichment of 4.95 weight percent; Palisades Nuclear Plant 4.0-1 Amendment No. W,287.,224

Reporting Requirements 5.6 5.6 Reportin9 Requirements COLR (continued)

14. EMF-92-116(P)(A), "Generic Mechanical Design Criteria for PWR Fuel Designs," Siemens Power Corporation.

(LCOs 3.1.6, 3.2.1, 3.2.2, & 3.2.4)

15. EMF-2087(P)(A), "SEM/PWR-98: ECCS Evaluation Model for PW R LBLOCA Applications," Siemens Power Corporation.

(LCOs 3.1.6, 3.2.1, & 3.2.2)

16. ANF-87-150 Volume 2, "Palisades Modified Reactor Protection System Report: Analysis of Chapter 15 Events," Advanced Nuclear Fuels Corporation. [Approved for use in the Palisades design during the NRC review of license Amendment 118, November 15, 19881 (LCOs 3.1.6,3.2.1,3.2.2,&3.4.1)

17. EMF-1961(P)(A), Revision 0, Siemens Power Corporation, July 2000, "Statistical Setpointrrransient Methodology for Combustion Engineering Type Reactors." (LCOs 3.1.6, 3.2.1, 3.2.2, 3.2.4, &

3.4.1)

18. EMF-2328 (P)(A), Revision 0, Framatome ANP, Inc., March 2001, "PWR Small Break LOCA Evaluation Model, S-RELAP5 Based."

(LCOs 3.1.6, 3.2.1, & 3.2.2)

19. BAW-2489P, "Revised Fuel Assembly Growth Correlation for Palisades." (LCOs 3.1.6, 3.2.1, 3.2.2, & 3.2.4)

20. EMF-2103(P)(A), "Realistic Large Break LOCA Methodology for Pressurized Water Reactors." (LCOs 3.1.6, 3.2.1, & 3.2.2)

21. BP;W-liO240(V}-A, *Incorporatlon of M5 Propeities in Framatome ANP Approved Methods." (LCOs 3.1.6,3.2.1,3.2.2,3.2.4, & 3.4.1)

c. The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems limits, nuclear limits such as shutdown margin, transient analysis limits, and accident analysis limits) of the safety analysis are met.

d. The COLR, including any mid cycle revisions or supplements, shall be provided, upon issuance for each reload cycle, to the NRC.

Palisades Nuclear Plant 5.0-27 Amendment No. 4W, +95,289,W, 222,229