ML090270022

Issuance of Amendment No. 129 Regarding the Use of Metamic as a Neutron Absorbing Material and Revised Loading Patterns in the Spent Fuel Pool

ML090270022
Person / Time
Site:	Harris
Issue date:	01/29/2009
From:	Vaaler M Plant Licensing Branch II
To:	Burton C Carolina Power & Light Co
Vaaler, Marlayna, NRR/DORL 415-1998
References
TAC MD8508
Download: ML090270022 (15)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 29, 2009 Chris L. Burton, Vice President Shearon Harris Nuclear Power Plant Carolina Power & Light Company Post Office Box 165, Mail Zone 1 New Hill, North Carolina 27562-0165 SUB..IECT: SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 - ISSUANCE OF AMENDMENT REGARDING THE USE OF METAMIC AS A NEUTRON ABSORBING MATERIAL AND REVISED LOADING PATTERNS IN THE SPENT FUEL POOL (TAC NO. MD8508)

Dear Mr. Burton:

The Nuclear Regulatory Commission (NRC, Commission) has issued the enclosed Amendment No. 129 to Renewed Facility Operating License No. NPF-63 for the Shearon Harris Nuclear Power Plant, Unit 1, in response to your application dated April 3, 2008, as supplemented by letters dated December 9,2008, and January 9,2009, to revise Technical Specification Section 5.6.3.b to allow a reconfiguration of the fuel racks in Spent Fuel Pool (SFP) C and allow the use of Metamic as an alternate neutron poison material in the new storage racks for SFP C and D.

The proposed amendment will: 1) revise the rack configuration in SFP C to allow the substitution of four previously approved (13 x 13 cell) Boiling Water Reactor racks with an equal number of (9 x 9 cell) Pressurized Water Reactor racks and 2) authorize the use of Metamic as an alternate spent fuel rack poison material.

A copy of the related safety evaluation is also enclosed. The Notice of Issuance will be included in the Commission's regular biweekly Federal Register notice.

arlayna Vaaler, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Rector Regulation Docket No. 50-400

Enclosures:

1. Amendment No. 129 to NPF-63

2. Safety Evaluation cc w/enclosures: Distribution via ListServ

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 CAROLINA POWER & LIGHT COMPANY, et al.

DOCKET NO. 50-400 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 129 Renewed License No. NPF-63

1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Carolina Power & Light Company (the licensee), dated April 3, 2008, as supplemented by letters dated December 9, 2008, and January 9, 2009, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

- 2

2.

Accordingly, the license is amended by changes to the Technical Specifications, as indicated in the attachment to this license amendment; and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-63 is hereby amended to read as follows:

(2)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, as revised through Amendment 1\\10. 1 29

,are hereby incorporated into this license. Carolina Power & Light Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/!f1IJ:>tn~~

Thomas H. BoycejChief Plant Licensing B' anch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License No. NPF-63 and the Technical Specifications Date of Issuance: January 29, 2009

ATTACHMENT TO LICENSE AMENDMENT NO.1 29 RENEWED FACILITY OPERATING LICENSE NO. NPF-63 DOCKET NO. 50-400 Replace page 4 of Renewed Operating License No. NPF-63 with the attached revised page 4.

The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Replace the following page of the Appendix A Technical Specifications with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Remove Page Insert Page 5-7b 5-7b

- 4 C.

This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect, and is subject to the additional conditions specified or incorporated below.

(1)

Maximum Power Level Carolina Power & Light Company is authorized to operate the facility at reactor core power levels not in excess of 2900 megawatts thermal (100 percent rated core power) in accordance with the conditions specified herein.

(2)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, as revised through Amendment No. 129, are hereby incorporated into this license. Carolina Power & Light Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3)

Antitrust Conditions Carolina Power & Light Company shall comply with the antitrust conditions delineated in Appendix C to this license.

(4)

Initial Startup Test Program (Section 14)1 Any changes to the Initial Test Program described in Section 14 of the FSAR made in accordance with the provisions of 10 CFR 50.59 shall be reported in accordance with 50.59(b) wit~lin one month of such change.

(5)

Steam Generator Tube Rupture (Section 15.6.3)

Prior to startup following the first refueling outage, Carolina Power & Light Company shall submit for NRC review and receive approval if a steam generator tube rupture analysis, including the assumed operator actions, which demonstrates that the consequences of the design basis steam generator tube rupture event for the Shearon Harris Nuclear Power Plant are less than the acceptance criteria specified in the Standard Review Plan, NUREG-0800, at '15.6.3 Subparts 11(1) and (2) for calculated doses from radiological releases. In preparing their analysis Carolina Power & Light Company will not assume that operators will complete corrective actions within the first thirty minutes after a steam generator tube rupture.

1The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report and/or its supplements wherein the license condition is discussed.

Renewed License No. NPF-63 Amendment NO.1 29

DESIGN FEATURES 5.6.3.b Pool "C" lS designed to contaln a combination of PWR and BWR assemblies.

Pool "C" can contain two 01 x 9 cell) and thirteen (9 X9 cell)

PWR racks for storage of 1251 PWR assemblies.

Pool "C" can contain two (8 x 13 cell), two (8 x 11 cell), six 03 x 11 cell), and flve 03 x 13 cell) BWR racks for storage of 2087 BWR assemblies.

The (9 x 9 cell) PWR racks and the (13 x 13 cell) BWR racks are dlmensioned to allow interchangeabillty between PWR or BWR storage rack styl es as requi red.

The racks in pool "C" wi 11 be installed as needed.

5.6.3.c Pool "0" contains a variable number of PWR storage spaces.

These racks will be installed as needed.

Pool "0" is designed for a maximum storage capacity of 1025 PWR assemblies.

5.6.3.d The heat load from fuel stored in Pools "C" and "0" shall not exceed 7.0 MBtu/hr.

5.7 COMPONENT CYCLIC OR TRANSIENT LIMIT 5.7.1 The components identified in Table 5.7-1 are designed and shall be malntained within the cyclic or transient limits of Table 5.7-1.

SHEARON HARRIS - UNIT 1 5-7b Amendment No. 129

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATIOI\\l BYTHE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 129 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-63 CAROLINA POWER &LIGHT COMPANY SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NO. 50-400

1.0 INTRODUCTION

By application dated April 3, 2008 (Agencywide Document and Management System (ADAMS)

Accession No. ML081010208), as supplemented by letters dated December 9, 2008, and January 9, 2009, Carolina Power & Light Company (the licensee), now doing business as Progress Energy Carolinas, Inc., requested changes to the Technical Specifications (TSs) for the Shearon Harris Nuclear Power Plant, Unit 1 (HNP). The supplemental letters provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the Nuclear Regulatory Commission (NRC, Commission) staff's original proposed no significant hazards consideration determination as published in the Federal Register on June 10,2008 (73 FR 32744).

The proposed amendment would revise TS Section 5.6.3.b to allow a reconfiguration of the fuel racks in Spent Fuel Pool (SFP) C and allow the use of Metamic as an alternate neutron poison material in the new spent fuel storage racks for SFP C and D. Specifically, the proposed amendment would: 1) revise the rack configuration in SFP C to allow the substitution of four previously approved (13 x 13 cell) Boiling Water Reactor (BWR) racks with an equal number of (9 x 9 cell) Pressurized Water Reactor (PWR) racks and 2) authorize the use of Metamic as an alternate spent fuel rack poison material.

The request is required to accommodate replacement of a select number of BWR fuel assembly storage modUles with PWR fuel assembly storage modules and to change the installed neutron absorber from Boral to MetamiC for the replacement modules in SFP C, as well as to change the installed neutron absorber from Boral to Metamic for any PWR modules not yet installed in SFP D. The analysis to support these changes was performed for the licensee by Holtec International, as HI-2073849, "Licensing Amendment Report for Change in Rack Neutron Absorber Material for Progress Energy (Proprietary)," which is Attachment 7 to the licensee's April 3, 2008, request.

The current TS requirements for SFP C and D was approved by HNP Amendment NO.1 03, dated December 21, 2000 (ADAMS Accession No. ML003779362). Currently, TS 5.6.1 4.a requires the SFP C and D effective multiplication factor (keff) to be less than or equal to 0.95 when flooded with unborated water. TS 5.6.1 4.c.1 restricts storage of PWR fuel assemblies

-2 based on a previously approved burnup/enrichment loading curve. TS 5.6.1 4.c.2 restricts storage of BWR fuel assemblies based on a Uranium 235 enrichment limit and standard cold core geometry infinite multiplication factor (kinf). TS 5.6.3.b limits the maximum storage in SFP C to 927 PWR fuel assemblies and 2763 BWR fuel assemblies. TS 5.6.3.c limits the maximum storage in SFP D to 1025 PWR fuel assemblies. TS 3/4.7.14 requires a minimum of 2000 parts per million (ppm) of soluble boron in all SFPs that contain nuclear fuel.

The licensee also committed to implement a coupon sampling program to confirm the capability of the MetamiC material to perform its intended safety function in the SFPs. The NRC staffs evaluation of the proposed revised rack configuration of SFP C, the use of MetamiC in the SFP C and D, and the surveillance program for the MetamiC is provided below.

2.0 REGULATORY EVALUATION

The following regulatory criteria are applicable to the licensee's request to revise the rack configuration of SFP C, use MetamiC as a neutron absorber in SFP C and D, and implement a MetamiC surveillance program:

Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix A, General Design Criterion (GDC) 61, "Fuel Storage and Handling and Radioactivity Control," states that the fuel storage and handling systems be designed to assure adequate safety under normal and postulated accident conditions.

10 CFR 50 Appendix A, GDC 62, "Prevention of Criticality in Fuel Storage and Handling," states that criticality in the fuel storage and handling system shall be prevented by physical systems or processes, preferably by the use of geometrically safe configurations.

10 CFR 50.68(b), "criticality accident requirements," along with HNP Amendment No. 103, state that SFP C and D are required to maintain keff no greater than 0.95 in the spent fuel pool storage racks when fully flooded by unborated water, including uncertainties at a 95 percent probability, 95 percent confidence level (95/95) under all conditions.

According to the Standard Review Plan Section 9.1.2, "Spent Fuel Storage," the review should also ensure that there are no potential mechanisms that will: (1) alter the dispersion of boron carbide (B4C) in the MetamiC panels, and/or (2) cause physical distortion of the tubes retaining the stored fuel assemblies.

3.0 TECHNICAL EVALUATION

3.1 Proposed Change In accordance with the current HNP TS 5.6.3.b requirements; SFP C can contain two (11 x 9 cell) and nine (9 x 9 cell) PWR storage modules and two (8 x 13 cell), two (8 x 11 cell),

six (13 x 11 cell), and nine (13 x 13 cell) BWR storage modules for a total of 927 PWR and 2763 BWR fuel assemblies. Not all of the allowed storage modules for SFP C and D have been installed to date. HNP is no longer accepting BWR fuel assemblies for storage from the Brunswick Nuclear Plant, as is authorized by the Operating License, and therefore the original quantity of BWR storage modules approved in HNP Amendment NO.1 03 is not required.

- 3 The requested change would reduce the number of (13 x 13 cell) BWR storage modules from nine to five while increasing the number of (9 x 9 cell) PWR storage modules from nine to thirteen for a revised total of 1251 PWR and 2087 BWR fuel assemblies allowed in SFP C. The specific number of storage modules for the currently empty SFP D is not specified in the current HNP TS, but a maximum storage capacity of 1025 PWR fuel assemblies is allowed; the capacity of SFP D is not being altered by the proposed amendment. The current TS indicate that the storage modules for both SFP C and D may be installed as needed.

The proposed amendment also requests the optional use of MetamiC as the spent fuel rack poison material since Boral, the material used as a neutron absorber poison material in the existing fuel storage racks, is not currently available for new rack construction.

3.2 Methodology There is no generic methodology for performing SFP criticality analyses. The criticality analysis methodology employed by Holtec International in the report HI-2073849, "Licensing Amendment Report for Change in Rack Neutron Absorber Material for Progress Energy," involved altering the previous methodology assumptions, as evaluated in HNP Amendment No. 103, such that the only change is the replacement of Boral with MetamiC as the installed neutron absorber. If the MetamiC is equal to or better with respect to the Boral, then the previous analysis is bounding and need not be repeated.

Therefore, the NRC staff did not revisit the original criticality analysis approved in HNP Amendment NO.1 03, but rather determined whether there was reasonable assurance that with everything else being identical, replacing Boral with MetamiC as the installed neutron absorber would result in equal or lower reactivity.

3.3 Computer Code Validation HI-2073849 uses the same computer codes and cross-section libraries as the original criticality analysis, so the computer code validation was not revisited in this evaluation.

3.4 Boral Versus MetamiC Comparison The NRC has previously evaluated the differences between Boral and MetamiC. In response to an Arkansas Nuclear One request, the NRC reviewed Holtec International report HI-2022871,

"Use of MetamiC in Fuel Pool Applications." The NRC issued the related safety evaluation report (SER) on June 17, 2008 (ADAMS Accession No. ML031681432).

Two things stand out in the Holtec International report HI-2022871 which indicate that with everything else being identical, replacing Boral with MetamiC as the installed neutron absorber would result in lower overall reactivity. The first is the B4C particle size. For MetamiC, the B4C particle size is much smaller than for Boral. This reduces the potential for neutron streaming between the particles. The second is the uncertainty in B4C content. The uncertainty in B4C content for Boral is approximately 8 percent, whereas it is 0.5 percent for MetamiC.

These items are consistent with the discussion of Boral and MetamiC in the Electric Power Research Institute (EPRI) Technical Report 1013721, "Handbook of Neutron Absorber Materials for Spent Nuclear Fuel Transportation and Storage Applications." However, as there is

- 4 variability within both Boral and MetamiC, determining whether or not replacing Boral with MetamiC would result in equal or lower overall reactivity requires a site specific comparison.

3.5 Shearon Harris SFP C and D Boral versus MetamiC Comparison The following table compares the HNP SFP C and D Boral versus MetamiC properties:

SFP C & D BORAL SFP C & D METAMIC Panel Density 2.641 gm/cmJ 2.642 gm/cmJ Panel Composition (wt %)

Aluminum 67.40 69.500 Carbon 7.08 6.630 Boron-10 4.59 4.368 (B-10 wt % of B)

(18.0)

(18.3)

Boron-11 20.92 19.501 Panel Thickness 0.098 +/- 0.006 inches 0.104 +/- 0.005 inches Nominal B-10 Areal Densitv 0.0302 gm/cm2 0.0304 gm/cm2 Minimum B-10 Areal Density 0.0280 gm/cm2 0.0280 gm/cm2 Panel Width 7.5 +/- 0.0625 inches 7.5 inches Shearon Hams SFP C and D Boral versus MetamlC Comparison of the areal density indicates that each panel would provide equivalent results in determining the reactivity of the storage modules. HI-2073849 includes one case, involving 5.0 weight percent Uranium 235 at 40.75 GWD/MTU of burnup, to validate that the panels provide equivalent results. The cases were run using the Monte Carlo technique in the MCNP-4A computer code. The original Boral indicated a keff of 0.91062 +/-.0008, while MetamiC indicated a keff of 0.90929 +/-.0008 (see Progress Energy E-mail dated January 9, 2009, ADAMS Accession No. ML090150545). After the Monte Carlo uncertainties are considered, the results for both neutron absorbers are very similar, with the small benefit of MetamiC attributable to the slight increase in B-10 areal density.

During a January 9,2009, conference call, the staff questioned the overall reliability of obtaining 18.3 weight percent as the B-10 fraction of the boron. The licensee indicated they were assured of receiving 18.3 weight percent B-1 0 as it was part of the procurement specification for the material. Therefore, the proper B-1 0 loading would be ensured by the licensee's 10 CFR Part 50 Appendix B Quality Assurance program.

During the teleconference, the licensee indicated there would be insufficient B-1 0 depletion due to neutron capture to challenge the B-10 18.3 weight percent assumptions used in the analysis; information included in the Holtec International Final Safety Analysis Report (FSAR) for the HI-STORM 100 Cask System, Revision 7 (ADAMS Accession No. ML082401620) was cited as justification. Specifically, B-10 depletion due to neutron capture is addressed in Holtec HI-STORM 100 Section 6.3.2, which indicates a miniscule depletion of B-10 due to neutron capture.

That information is based on a HI-STORM 100 "design basis" fuel assembly, which includes several years of cooling and decay time that would not be applicable to a SFP design basis fuel assembly. However, the amount of B-1 0 depletion outlined in HI-STORM 100 FSAR,

- 5 Revision 7, Section 6.3.2 is so small (2.6 E-09 B-10 atoms destroyed in 50 years) that even with an increase of several orders of magnitude in B-10 depletion, it would be unlikely to challenge the B-10 18.3 weight percent assumptions used in the MetamiC analysis. This information, coupled with the small increase in margin associated with the MetamiC used in the HNP SFP C and D, makes the proposed changes acceptable.

3.6 Conclusions on Rack Configuration Changes and Use of MetamiC The licensee's justification to utilize MetamiC as a neutron absorber in the new fuel storage modules for SFP C and D is based on changes from the previously approved analysis described in HNP Amendment NO.1 03. For this site specific case, the only difference in design was the change from Boral to MetamiC as the installed neutron absorber. The staff assessed the changes, but did not revisit the original analysis other than to obtain information regarding the physical description of the Boral. With the information provided, the staff concludes that there is reasonable assurance that for HNP, the MetamiC material will produce results equal to or better than those given in the original analysis.

All of the remaining analysis assumptions and conclusions regarding structural integrity, handling of heavy loads, material properties, radiological assessment, quality assurance, etc., as outlined and analyzed in HNP Amendment No.1 03 remain in effect and continue to bound the proposed change to MetamiC as the installed neutron absorber for the new fuel storage racks.

Therefore, the staff concludes that the use of MetamiC rather than Boral as the neutron absorber for the new fuel storage modules in HNP SFP C and D, is acceptable.

In accordance with the previously approved HNP Amendment NO.1 03, the fuel storage racks in SFP C and D may be installed on an "as needed" basis. In addition, the (13 x 13 cell) BWR storage modules and the (9 x 9 cell) PWR storage modules have been previously evaluated and approved for dimensional interchangeability "as required," per the conclusions of the SER accompanying HNP Amendment No. 103. The NRC staff has found that reducing the number of (13 x 13 cell) BWR storage modules from nine to five while increasing the number of (9 x 9 cell) PWR storage modules from nine to thirteen for a revised total of 1251 PWR and 2087 BWR fuel assemblies in SFP C is acceptable as the analysis conducted to support HNP Amendment No.1 03 remains bounding, and the overall number of fuel assemblies stored on SFP C will be decreased.

3.7 MetamiC Coupon Sampling Program MetamiC is a cermet composed primarily of B4C and aluminum (AI) 6061. A cermet is a composite material composed of ceramic and metallic materials. B4C is the constituent in the MetamiC known to perform effectively as a neutron absorber and AI 6061 is a marine-qualified alloy known for its resistance to corrosion. MetamiC has been approved by the NRC via Holtec International report H1-2022871 and its associated SER dated June 17, 2003, and introduced at a number of plants for SFP applications.

In its application dated April 3, 2008, the licensee provided a MetamiC Coupon Sampling Program which consists primarily of monitoring the physical properties of the absorber material by performing periodic physical inspection and neutron attenuation testing to confirm the ability of the material to perform its intended function.

-6 3.7.1 Program Description The purpose of the licensee's MetamiCcoupon surveillance program is to ensure that the physical and chemical properties of MetamiC behave in a similar manner as that described in a vendor topical report on simulated service performance of MetamiC. The coupon program will monitor how the MetamiCabsorber material properties change over time under the radiological, chemical, and thermal environment found in the SFP. This surveillance program will provide a means to detect any significant degradation in a timely manner that will allow for implementation of corrective actions prior to the material losing its ability to perform its intended function.

The surveillance program will use coupon samples, taken from the same material lot as used for rack construction, to monitor the performance of the neutron absorbing material. A total of 10 MetamiC coupons will be suspended from a mounting tree that is placed in a SFP cell and surrounded by spent fuel. Each coupon will be examined prior to insertion into the SFP to determine an initial condition that will be compared to the coupon condition when it is removed from the pool after exposure. The coupons will be individually removed from the SFP, examined, and compared to their initial condition on a prescribed schedule. There are a sufficient number of coupons to allow for 40 years of continuous surveillance.

3.7.2 Monitoring Changes in the Physical Properties and Testing of Coupons The specific criteria of the HNP surveillance program, a outlined in the licensee's April 3, 2008, application, are as follows:

1.

MetamiC coupon dimensions: 8 inches x 6 inches x 0.098 inch minimum thickness (0.104 inch nominal);

2.

Coupons are from the actual base panels with no welds; proximity to stainless steel (rack wall) is accomplished via bolt/stainless steel washer combination where the coupon is attached to the tree;

3.

Initial B4C content of the coupons is determined by measuring constituents during material manufacture;

4.

B4C measured content: 30.5 weight percent nominal with a minimum of 29.5 weight percent (not to exceed 31 weight percent);

5.

Boron in B4C shall contain a minimum of 18.3 weight percent of B-10;

6.

Coupon scratches and other surface anomalies will not be added to individual coupons since coupons are of the same lot/sections as the production MetamiC and will contain the same surface defects;

7.

Nominal B-10 areal density of 0.0304 g/cm2 (0.0302 g/cm2 minimum areal density);

8.

Any bubbling, blistering, cracking or flaking of the coupons, any dose changes to the coupons, the effects of any fluid movement and temperature fluctuations of

- 7 the pool water will all be addressed through visual observation, dimensional measurement, weight measurement and specific gravity measurements; any areal density changes of the coupons will be monitored through neutron attenuation measurements;

9.

Description of the anodizing process is not applicable since the MetamiC used in the racks is not anodized;

10.

Cleaning technique will include a demin wash prior to shipping/installation to ensure surfaces of MetamiC are thoroughly cleaned of all foreign items.

The following methods will be used to monitor the physical properties of the MetamiC coupons in the surveillance program:

1.

Visual observation and photography

2.

Neutron attenuation

3.

Dimensional measurements (length, width, thickness)

4.

Weight and specific gravity The most critical surveillance measurements are the neutron attenuation and coupon thickness changes, which act as an indication of swelling. The acceptance criterion for the neutron attenuation testing is a decrease of no more than 5 percent in Boron-10 content. The acceptance criterion for coupon thickness is that the thickness at any point does not exceed 10 percent of the initial coupon thickness. Changes in excess of either of these criteria will require an investigation and engineering analysis that may include early retrieval and measurement of one or more of the remaining MetamiC coupons to confirm the potential material degradation. If the deviation from the acceptance criteria is confirmed through examination of additional coupons, corrective actions may be required.

The visual examination and weight measurements are examined to identify early indications of potential MetamiC degradation. If surface pitting, corrosion, edge deteriation, or unacceptable weight loss are identified during surveillance, the coupon removal schedule may be accelerated to allow for more timely monitoring and trending of the phenomena.

The staff finds that these surveillance criteria are reasonable limits that will assure further evaluation before significant degradation of the MetamiC occurs.

3.8 Conclusions on the MetamiC Coupon Sampling Program Based on its review of the licensee's proposed Coupon Sampling Program, as well as previous analyses of the use of MetamiC as a neutron absorber, the staff concludes that the MetamiC neutron absorber is compatible with the environment of the SFP. Also, the staff finds that the proposed surveillance program, which includes visual, physical and confirmatory tests, is capable of detecting potential degradation of the Metamic material that could impair its neutron absorption capability. Therefore, the staff concludes that the MetamiC Coupon Sampling Program is an acceptable surveillance method to monitor possible degradation of the MetamiC material in an adequate timeframe to allow for compensatory measures to be taken.

- 8

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the State of North Carolina official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding as published in the Federal Register on June 10, 2008 (73 FR 32744). Accordingly, the 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 need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (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.

Principal Contributors: Kent Wood Matthew Yoder Da~: January 29, 2009

ML090270022 NRR-058 OFFICE LPL2-2/PM LPL2-2/LA CSGB/BC SRXB/BC OGC (NLO) LPL2-2/BC NAME MVaaler RSoia AHiser*

GCranston* LSubin TBoyce DATE 01/29/09 01/29/09 10/31/2008 1/14/2009 01/29/09 01/29/09

• by memo dated