RC-09-0068, License Amendment Request - LAR 09-00562, for Use of Optimized Zirlo Fuel Rod Cladding

License Amendment Request - LAR 09-00562, for Use of Optimized Zirlo Fuel Rod Cladding

ML091620072
Person / Time
Site:	Summer
Issue date:	06/09/2009
From:	Archie J South Carolina Electric & Gas Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR 09-00562, RC-09-0068
Download: ML091620072 (26)

Text

Jeffrey B. Archie Vice President, Nuclear Operations 803.345.4214 June 9, 2009 RC-09-0068 A SCANA COMPANY U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001

Subject:

VIRGIL C. SUMMER NUCLEAR STATION (VCSNS)

DOCKET NO. 50/395 OPERATING LICENSE NO. NPF-12 LICENSE AMENDMENT REQUEST - LAR 09-00562 License Amendment Request For Use Of Optimized Zirlo TM Fuel Rod Cladding Pursuant to 10 CFR 50.90, South Carolina Electric and Gas Company (SCE&G), acting for itself and as an agent for South Carolina Public Service Authority (Santee Cooper), hereby requests the following amendment for Virgil C. Summer Nuclear Station (VCSNS), Technical Specifications (TS). TS 5.3.1 addresses the reactor core assemblies that specify, "Each fuel assembly shall consist of 264 Zircaloy-4 or ZIRLOTM clad fuel rods..." the Enclosure proposes the following changes; 1) adding Optimized ZIRLO TM to the approved fuel rod cladding materials and 2) adding a Westinghouse topical report to the analytical methods used to determine the core operating limits previously reviewed and approved by the NRC identified in TS 6.9.1.11.

This change is consistent with the US Nuclear Regulatory Commission (NRC) allowed use of Optimized ZIRLO TM fuel cladding material in Westinghouse and Combustion Engineering Original Equipment Manufacturer (OEM) reactors as issued in Addendum 1-A to Topical Report WCAP-12610-P-A and CENPD-404-P-A, "Optimized ZIRLOTM."

To support the change and pursuant to 10 CFR 50.12, SCE&G is also requesting an exemption from certain requirements of 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" for VCSNS. The exemption request relates solely to the specific types of cladding material specified in these regulations for use in light water reactors. As written, the regulations presume the use of either Zircaloy or ZIRLOTM fuel rod cladding. The exemption request is required since Optimized ZIRLO TM has a slightly different composition than Zircaloy or ZIRLOTM. The exemption request is included as Attachment 1. The NRC has granted prior approval for use of Optimized ZIRLOTM fuel rod cladding to Entergy Operations Inc. Arkansas Nuclear One, Unit 2 (ML080370014) and Waterford Steam Electric Station, Unit 3 (ML080380004).

SCE&G requests approval of the proposed amendment by February 10, 2010 to support the next core design for the Spring 2011 core reload. Once approved, the amendment shall be implemented within 60 days.

This proposed change has been reviewed and approved by both the VCSNS Plant Safety Review Committee (PSRC) and the VCSNS Nuclear Safety Review Committee (NSRC).

SCE&G I Virgil C. Summer Nuclear Station

• P. 0. Box 88. Jenkinsville, South Carolina 29065.T (803) 345.5209 -www.scana.com A...4 (-(

Document Control Desk LAR/CR-09-00562 RC-09-0068 Page 2 of 2 In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated South Carolina Official.

If you should have any questions regarding this submittal, please contact Mr. Bruce L.

Thompson at (803) 931-5042.

I certify under penalty of perjury that the foregoing is true and correct.

/Executed on JMG/GAR/JBA/jhw/dr

Enclosures:

Evaluation of the Proposed Change(s)

Attachments: 4

1. Request for Exemption from the Provisions of 10 CFR 50.46 and 10 CFR Part 50 Appendix K to Allow Use of Optimized ZIRLO TM in Core Reload Applications

2. Proposed Technical Specification Changes (mark-up)

3. Proposed Technical Specification pages (Retyped)

4. List of Regulatory Commitments cc:

K. B. Marsh S. A. Byrne N. S. Cams J. H. Hamilton R. J. White K. J. Browne L. A. Reyes R. E. Martin T. P. O'Kelley Paulette Ledbetter NRC Resident Inspector K. M. Sutton NSRC RTS (CR-09-00562)

File (813.20)

PRSF (RC-09-0068)

Document Control Desk Enclosure LAR/CR-09-00562 RC-09-0068 Page 1 of 10

Subject:

LICENSE AMENDMENT REQUEST - LAR 09-00562 EVALUATION OF THE PROPOSED TECHNICAL SPECIFICATION CHANGE(S) TO SECTIONS 5.3.1 AND 6.9.1.11.

1.0 DESCRIPTION

This license amendment request (LAR) is a request to amend the Technical Specifications (TS) for Virgil C. Summer Nuclear Station (VCSNS).

The proposed change will revise the TS to allow the use of Optimized ZIRLO TM fuel rod cladding material. Acceptable fuel rod cladding material is identified in VCSNS TS 5.3.1, Reactor Core Assemblies.

The proposed change would revise TS 5.3.1 and TS 6.9.1.11 to add Westinghouse topical report WCAP-12610-P-A to the analytical methods used to determine the core operating limits previously reviewed and approved by the NRC.

An exemption from certain requirements of 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" is required to support this change. The exemption request is included as Attachment 1.

2.0 PROPOSED CHANGE

The proposed change will revise VCSNS TS 5.3.1 by adding Optimized ZIRLO TM as an acceptable fuel rod cladding material.

Additionally TS 6.9.1.11 is being revised to add WCAP-1 2610-P-A to the list of documents previously reviewed and approved by the NRC.

3.0 BACKGROUND

As the nuclear industry pursues longer operating cycles with increased fuel discharge burnup and fuel duty, the corrosion performance requirements for the nuclear fuel cladding become more demanding.

Optimized ZIRLOTM was developed to meet these needs and provides a reduced corrosion rate while maintaining the benefits of mechanical strength and resistance to accelerated corrosion from abnormal chemistry conditions.

In addition, fuel rod internal pressures (resulting from the increased fuel duty, use of integral fuel burnable absorbers, and corrosion/temperature feedback effects) have become more limiting with respect to fuel rod design criteria. Reducing the associated corrosion buildup and thus minimizing temperature feedback effects provides additional margin to the fuel rod internal pressure design criterion.

Optimized ZIRLOTM fuel cladding is different from standard ZIRLOTM in two respects: 1) the tin content is lower; and 2) the microstructure is different.

This difference in tin content and microstructure can lead to differences in some material properties and the industry has committed to provide irradiated data and validate fuel performance models ahead of burnups achieved in batch application.

Document Control Desk Enclosure LAR/CR-09-00562 RC-09-0068 Page 2 of 10 Optimized ZIRLOTM is described in Westinghouse topical report WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A "Optimized ZIRLOTM, July 2006 (Reference 1). The staff's safety evaluation for Optimized ZIRLOTM dated 6/10/2005 (ML051670395) requires licensees referencing Addendum 1-A to implement Optimized ZIRLO TM must comply with the ten (10) conditions and limitations listed within the safety evaluation. These conditions and limitations are addressed in Section 4.0. The NRC has allowed use of Optimized ZIRLO TM fuel cladding material in Westinghouse reactors as issued for Entergy Operations Inc. Arkansas Nuclear One, Unit 2 (ML080370014) and Waterford Steam Electric Station, Unit 3 (ML080380004).

4.0 TECHNICAL Westinghouse Electric Company, LLC (Westinghouse) topical report WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLO TM", provides the details and results of material testing of Optimized ZIRLOTM compared to standard ZIRLOTM as well as the material properties to be used in various models and methodologies when analyzing Optimized ZIRLO TM.

The NRC Safety Evaluation (SE) for the topical report contains ten conditions and limitations.

SCE&G will comply with these conditions and limitations as follows:

1. Until rulemaking to 10 CFR Part 50 addressing Optimized ZIRLO TM has been completed, implementation of Optimized ZIRLO TM fuel clad requires an exemption from 10 CFR 50.46 and 10 CFR Part 50 Appendix K RESPONSE: The exemption from 10 CFR 50.46 and 10 CFR Part 50, Appendix K is included as Attachment 1 of this LAR.

2. The fuel rod burnup limit for this approval remains at currently established limits:

62 GWd/MTU for Westinghouse fuel designs and 60 GWd/MTU for CE fuel designs.

RESPONSE: For any fuel using Optimized ZIRLO TM fuel cladding, the maximum fuel rod burnup limit for Westinghouse fuel designs will continue to be 62 GWd/MTU until such time that a new fuel rod burnup limit is approved for use.

3. The maximum fuel rod waterside corrosion, as predicted by the best-estimate model, will [proprietary limits included in topical report and proprietary version of safety evaluation] of hydrides for all locations of the fuel rod.

RESPONSE: The maximum fuel rod waterside corrosion for the fuel product using Optimized ZIRLOTM fuel cladding will be confirmed to be less than [proprietary limits

Document Control Desk Enclosure LAR/CR-09-00562 RC-09-0068 Page 3 of 10 included in topical report and proprietary version of safety evaluation] of hydrides for all locations of the fuel rod.

Confirmation of these modified limits for Optimized ZIRLOTM fuel cladding are required as part of the core reload process.

4. All the conditions listed in previous NRC SE approvals for methodologies used for standard ZIRLOTM and Zircaloy-4 fuel analysis will continue to be met, except that the use of Optimized ZIRLO TM cladding in addition to standard ZIRLOTM and Zircaloy-4 cladding is now approved.

RESPONSE: The fuel analysis of Optimized ZIRLO TM fuel cladding will continue to meet all conditions associated with approved methods. For VCSNS this is a current requirement and confirmation of these conditions is required as part of the core reload process.

5. All methodologies will be used only within the range for which ZIRLO TM and Optimized ZIRLOTM data were acceptable and for which the verifications discussed in Addendum 1 and responses to RAIs were performed.

RESPONSE

The application of ZIRLOTM and Optimized ZIRLOTM in approved methodologies will be made consistent with the approach accepted in WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A "Optimized ZIRLO TM," July 2006.

For VCSNS this is a current requirement and confirmation of these conditions is required as part of the core reload process.

6. The licensee is required to ensure that Westinghouse has fulfilled the following commitment: Westinghouse shall provide the NRC staff with a letter(s) containing the following information (Based on the schedule described in response to RAI #3):

a. Optimized ZIRLO TM LTA data from Byron, Calvert Cliffs, Catawba, and Millstone.

i. Visual ii. Oxidation of fuel rods iii. Profilometry iv. Fuel rod length

v. Fuel assembly length

b. Using the standard and Optimized ZIRLOTM database including the most recent LTA data, confirm applicability with currently approved fuel performance models (e.g., measured vs. predicted).

Confirmation of the approved models' applicability up through the projected end of cycle burnup for the Optimized ZIRLOTM fuel rods must be completed prior to their initial batch loading and prior to the startup of subsequent cycles. For

Document Control Desk Enclosure LAR/CR-09-00562 RC-09-0068 Page 4 of 10 example, prior to the first batch application of Optimized ZIRLO TM4, sufficient L TA data may only be available to confirm the models' applicability up through 45 GWd/MTU. In this example, the licensee would need to confirm the models up through the end of the initial cycle. Subsequently, the licensee would need to confirm the models based upon the latest LTA data, prior to re-inserting the Optimized ZIRLO TM fuel rods in future cycles. Based upon the LTA schedule, it is expected that this issue may only be applicable to the first few batch implementations since sufficient LTA data up through the burnup limit should be available within a few years.

RESPONSE: Westinghouse has provided the NRC with information related to test data and models in the following letters:

" Letter from J. A. Gresham (Westinghouse) to U.S. Nuclear Regulatory Commission, "SER Compliance With WCAP-12610-P-A and CENDP-404-P-A, Addendum 1-A, "Optimized ZIRLOTM," LTR-NRC-07-01, January 4, 2007.

" Letter from J. A. Gresham (Westinghouse) to U.S. Nuclear Regulatory Commission, "SER Compliance With WCAP-12610-P-A and CENDP-404-P-A, Addendum 1-A, "Optimized ZIRLO TM," LTR-NRC-07-58, November 6, 2007.

(ML073130556)

" Letter from J. A. Gresham (Westinghouse) to U.S. Nuclear Regulatory Commission, "SER Compliance With WCAP-12610-P-A and CENDP-404-P-A, Addendum 1-A, "Optimized ZIRLO TM," LTR-NRC-07-58 Rev. 1, February 5, 2008. (ML080390451)

" Letter from J. A. Gresham (Westinghouse) to U.S. Nuclear Regulatory Commission, "SER Compliance of WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLO TM," LTR-NRC-08-60, December 30, 2008.

LTA measured data and favorable results from visual examinations of once and twice-burned LTAs confirm, for at least two cycles of operation, that the current fuel performance models are applicable for Optimized ZIRLOTM fuel rods. Westinghouse will continue to provide additional data from the Optimized ZIRLO TM LTA programs to the NRC after new data for higher burnup/fluence become available. SCE&G will confirm that as higher burnups/fluences are achieved for Optimized ZIRLOTM clad fuel rods that the requirements of this condition will be met as it applies to VCSNS.

7. The licensee is required to ensure that Westinghouse has fulfilled the following commitment: Westinghouse shall provide the NRC staff with a letter containing the following information (Based on the schedule described in response to RAI #11):

a. Vogtle growth and creep data summary reports.

b. Using the standard ZIRLO TM and Optimized ZIRLO TM database including the most recent Vogtle data, confirm applicability with currently approved fuel performance models (e.g., level of conservatism in W rod pressure analysis, measured vs. predicted, predicted minus measured vs. tensile and compressive stress).

Document Control Desk Enclosure LAR/CR-09-00562 RC-09-0068 Page 5 of 10 Confirmation of the approved models' applicability up through the projected end of cycle burnup for the Optimized ZIRLOTM fuel rods must be completed prior to their initial batch loading and prior to the startup of subsequent cycles. For example, prior to the first batch application of Optimized ZIRLO T M, sufficient LTA data may only be available to confirm the models' applicability up through 45 GWd/MTU. In this example, the licensee would need to confirm the models up through the end of the initial cycle. Subsequently, the licensee would need to confirm the models based upon the latest LTA data, prior to re-inserting the Optimized ZIRLOTM fuel rods in future cycles. Based upon the L TA schedule, it is expected that this issue may only be applicable to the first few batch implementations since sufficient LTA data up through the burnup limit should be available within a few years.

RESPONSE: Westinghouse has provided the NRC with information related to test data and models in the following letters:

Letter from J. A. Gresham (Westinghouse) to U.S. Nuclear Regulatory Commission, "SER Compliance With WCAP-12610-P-A and CENDP-404-P-A, Addendum 1-A, "Optimized ZIRLOTM," LTR-NRC-07-01, January 4, 2007.

Letter from J. A. Gresham (Westinghouse) to U.S. Nuclear Regulatory Commission, "SER Compliance With WCAP-12610-P-A and CENDP-404-P-A, Addendum 1-A, "Optimized ZIRLO TM," LTR-NRC-07-58, November 6, 2007.

(ML073130556)

Letter from J. A. Gresham (Westinghouse) to U.S. Nuclear Regulatory Commission, "SER Compliance With WCAP-12610-P-A and CENDP-404-P-A, Addendum 1-A, "Optimized ZIRLO TM," LTR-NRC-07-58 Rev. 1, February 5, 2008. (ML080390451)

Letter from J. A. Gresham (Westinghouse) to U.S. Nuclear Regulatory Commission, "SER Compliance of WCAP-12610-P-A

& CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLOTM," LTR-NRC-08-60, December 30, 2008.

Currently, the data from two cycles of operation has been evaluated and the fuel rod creep models from fuel rod design codes have been used to predict the growth and creep performance of the samples. This information was provided to the NRC in the most recent informational letter (LTR-NRC-08-60) at the end of calendar year 2008.

SCE&G will confirm that as higher burnups/fluences are achieved for Optimized ZIRLOTM clad fuel rods that the requirements of this condition will be met as it applies to VCSNS.

8. The licensee shall account for the relative differences in unirradiated strength (YS and UTS) between Optimized ZIRLO TM and standard ZIRLOTM in cladding and structural analyses until irradiated data for Optimized ZIRLOTM have been collected and provided to the NRC staff

Document Control Desk Enclosure LAR/CR-09-00562 RC-09-0068 Page 6 of 10

a. For the Westinghouse fuel design analyses:

i.

The measured, unirradiated Optimized ZIRLO TM strengths shall be used for BOL analyses.

ii. Between BOL up to a radiation fluence of 3.0 x 1021 n/cm2 (E>1MeV),

pseudo-irradiated Optimized ZIRLOTM strength set equal to linear interpolation between the following two strength level points: At zero fluence, strength of Optimized ZIRLOTM equal to measured strength of Optimized ZIRLOTM and at a fluence of 3.0 x 1021 n/cm2 (E>IMeV),

irradiated strength of standard ZIRLOTM at the fluence of 3.0 x 102, n/crr (E> 1MeV) minus 3 ksi.

iii. During subsequent irradiation from 3. 0 x 1021 n/cm2 up to 12 x 1021 n/cm2, the differences in strength (the difference at a fluence of 3 x 102M n/crn2 due to tin content) shall be decreased linearly such that the pseudoirradiated Optimized ZIRLOTM strengths will saturate at the same properties as standard ZIRLOTM at 12 x 102' n/cm2.

b. For the CE fuel design analyses, the measured, unirradiated Optimized ZIRLOTM strengths shall be used for all fluence levels (consistent with previously approved methods).

RESPONSE: VCSNS is a Westinghouse fuel design therefore, 8.b does not apply.

The fuel analysis of Optimized ZIRLOTM clad fuel rods will use the yield strength and ultimate tensile strength as modified per Conditions 8.a.i, 8.a.ii, and 8.a.iii until such time that irradiated data for Optimized ZIRLOTM strengths have been collected and provided to the NRC.

SCE&G will confirm that as higher burnups/fluences are achieved for Optimized ZIRLOTM clad fuel rods that the requirements of this condition will be met as it applies to VCSNS.

9. As discussed in response to RAI #21, for plants introducing Optimized ZIRLO TM that are licensed with LOCBART or STRIKIN-II and have a limiting PCT that occurs during blowdown or early reflood, the limiting LOCBART or STRIKIN-I1 calculation will be rerun using the specified Optimized ZIRLO TM material properties. Although not a condition of approval, the NRC staff strongly recommends that, for future evaluations, Westinghouse update all computer models with Optimized ZIRLOTM specific material properties.

RESPONSE: VCSNS is not licensed with LOCBART or STRIKIN-II therefore, this condition and limitation does not apply.

Document Control Desk Enclosure LAR/CR-09-00562 RC-09-0068 Page 7 of 10

10. Due to the absence of high temperature oxidation data for Optimized ZIRLO TM, the Westinghouse coolability limit on PCT during the locked rotor event shall be

[proprietary limits included in topical report and proprietary version of safety evaluation].

RESPONSE: The Westinghouse limit on PCT during the locked rotor event will be assessed relative to the [proprietary limits included in topical report and proprietary version of safety evaluation] PCT limit as part of the core reload design process.

5.0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration SCE&G 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 change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed Technical Specification change is to add Optimized ZIRLOTM to the allowable or approved cladding materials to be used at Virgil C. Summer Nuclear Station (VCSNS). The proposed change of adding a cladding material does not result in an increase to the probability or consequences of an accident previously evaluated.

Technical Specifications (TS 5.3.1) address the reactor core assemblies that specify, "Each fuel assembly shall consist of 264 Zicaloy-4 or ZIRLOTM clad fuel rods..." The proposed change will add Optimized ZIRLO TM to the approved fuel rod cladding materials.

Additionally, reference to WCAP-12610-P-A, "VANTAGE + Fuel Assembly Reference Core Report," April 1995 & Proprietary) and WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLO TM," July 2006 (M Proprietary) will be included to the listing of documents previously reviewed and approved by the NRC within TS 6.9.1.11.

Westinghouse Electric

Company, LLC (Westinghouse) topical report WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A "Optimized ZIRLOTM,"

July 2006, provides the details and results of material testing of Optimized ZIRLOTM compared to standard ZIRLOTM as well as the material properties to be used in various models and methodologies when analyzing Optimized ZIRLOTM.

As the nuclear industry pursues longer operating cycles with increased fuel discharge burnup and fuel duty, the corrosion performance requirements for the nuclear fuel cladding become more demanding.

Optimized ZIRLOTM was developed to meet these needs and provides a reduced corrosion rate while

Document Control Desk Enclosure LAR/CR-09-00562 RC-09-0068 Page 8 of 10 maintaining the benefits of mechanical strength and resistance to accelerated corrosion from abnormal chemistry conditions.

In addition, fuel rod internal pressures (resulting from the increased fuel duty, use of integral fuel burnable absorbers, and corrosion/temperature feedback effects) have become more limiting with respect to fuel rod design criteria.

Reducing the associated corrosion buildup and thus minimizing temperature feedback effects, provides additional margin to the fuel rod internal pressure design criterion. Therefore, adding Optimized ZIRLOTM to the approved fuel rod cladding materials does not result in an increase to the probability or consequences of an accident previously evaluated.

The US Nuclear Regulatory Commission (NRC) has allowed use of Optimized ZIRLOTM fuel cladding material in Westinghouse fueled reactors provided that licensees ensure compliance with the conditions and limitations set forth within NRC Safety Evaluation (SE) for the topical report. The conditions and limitations are the current requirements and confirmation of these conditions is required as part of the core reload process.

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

Response: No.

The proposed Technical Specification change is to add Optimized ZIRLOTM to the allowable or approved cladding materials to be used at VCSNS. Optimized ZIRLOTM was developed to provide a reduced corrosion rate while maintaining the benefits of mechanical strength and resistance to accelerated corrosion from abnormal chemistry conditions. The fuel rod design bases are established to satisfy the general and specific safety criteria addressed within FSAR Chapter 15, Accident Analyses and TSs. The fuel rods are designed to prevent excessive fuel temperatures, excessive internal rod gas pressures due to fission gas releases, and excessive cladding stresses and strains. Westinghouse topical report WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A "Optimized ZIRLOTM,' July 2006, provides the details and results of material testing of Optimized ZIRLOTM compared to standard ZIRLOTM as well as the material properties to be used in various models and methodologies when analyzing Optimized ZIRLOTM.

The original design basis requirements have been maintained. Therefore, the change in material does not create the possibility of a new or different kind of accident or malfunction previously evaluated within the FSAR.

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

Response: No.

Document Control Desk Enclosure LAR/CR-09-00562 RC-09-0068 Page 9 of 10 The cladding material used in the fuel rods are designed and tested to prevent excessive fuel temperatures, excessive internal rod gas pressure due to fission gas releases and excessive cladding stresses and strains. Optimized ZIRLOTM was developed to meet these needs and provides a reduced corrosion rate while maintaining the benefits of mechanical strength and resistance to accelerated corrosion from abnormal chemistry conditions.

Westinghouse topical report WCAP WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A "Optimized ZIRLOTM,'1 July 2006, provides the details and results of material testing of Optimized ZIRLOTM compared to standard ZIRLOTM as well as the material properties to be used in various models and methodologies when analyzing Optimized ZIRLOTM. The NRC has allowed use of Optimized ZIRLO TM fuel cladding material detailed within this topical report as detailed within their Safety Evaluation (SE). The original design basis requirements have been maintained.

Therefore, the change in material does not result in a reduction in margin required to preclude or reduce the effects of an accident or malfunction previously evaluated in the FSAR.

Based on the above, SCE&G concludes that the proposed amendment present 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 Requlatory Requirements/Criteria The NRC has allowed use of Optimized ZIRLO TM fuel cladding material in Westinghouse Original Equipment Manufacturer (OEM) reactors provided that Licensees ensure compliance with the conditions and limitations set forth within NRC Safety Evaluation (SE) for the topical report.

Westinghouse topical report WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A "Optimized ZIRLOTM, July 2006, provides the details and results of material testing of Optimized ZIRLOTM compared to standard ZIRLOTM as well as the material properties to be used in various models and methodologies when analyzing Optimized ZIRLOTM.

Each of the limits and conditions were specifically addressed for their applicability to VCSNS within the technical section of this LAR. In summary, core reload evaluations ensure the acceptance criteria are met for all the limitations and conditions for the insertion of assemblies with fuel rods clad with Optimized ZIRLO TM under 10 CFR 50.59 requirements.

These assemblies will be evaluated using NRC approved methods and models to address the use of Optimized ZIRLO TM. Additionally, SCE&G will confirm that prior to initial batch loading and/or prior to the startup of subsequent cycles for Optimized ZIRLOTM clad fuel rods, the requirement conditions of NRC staff's SER items 6, 7 and 8 will be met as it applies to VCSNS.

The proposed change has been evaluated to validate those regulations and requirements continue to be met. SCE&G concurs with the NRC SER that an exemption from 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

Document Control Desk Enclosure LAR/CR-09-00562 RC-09-0068 Page 10 of 10 Models" is required. The request for exemption has been provided as Attachment 1 and provides the basis and justification for relief from these regulations.

In conclusion, based on the considerations discussed 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.

6.0 ENVIRONMENTAL CONSIDERATION

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 criterion for categorical exclusion set forth in 10 CFR 51.22(c)(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. WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLOTM,"

July 2006 (ML062080576).

2. Letter from H. N. Berkow (USNRC) to J. A. Gresham (Westinghouse), "Final Safety Evaluation for Addendum to Topical Report WCAP-12610-P-A and CENPD-404-P-A,

'Optimized ZIRLO TM'," June 10, 2005. (ML051670395)

3. Letter from J. A. Gresham (Westinghouse) to USNRC (Document Control Desk), "SER Compliance with WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A, 'Optimized ZIRLOTM'," LTR-NRC-07-1, January 4, 2007.

4. Letter from J. A. Gresham (Westinghouse) to USNRC (Document Control Desk), "SER Compliance with WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A, 'Optimized ZIRLO TM'," LTR-NRC-07-58, November 6, 2007. (ML073130556)

5. Letter from J. A. Gresham (Westinghouse) to USNRC (Document Control Desk), "SER Compliance with WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A, 'Optimized ZIRLO TM'," LTR-NRC-07-58 Rev. 1, February 5, 2008. (ML080390451)

6. Letter from J. A. Gresham (Westinghouse) to U.S. Nuclear Regulatory Commission, "SER Compliance of WCAP-12610-P-A & CENPD-404-P-A Addendum 1-A "Optimized ZIRLOTM," LTR-NRC-08-60, December 30, 2008.

Document Control Desk LAR/CR-09-00562 RC-09-0068 Page 1 of 5 VIRGIL C. SUMMER NUCLEAR STATION (VCSNS)

DOCKET NO. 50/395 OPERATING LICENSE NO. NPF-12 ATTACHMENT 1 REQUEST FOR EXEMPTION FROM THE PROVISIONS OF 10 CFR 50.46 AND 10 CFR PART 50 APPENDIX K TO ALLOW USE OF OPTIMIZED ZIRLO TM IN CORE RELOAD APPLICATIONS

Document Control Desk LAR/CR-09-00562 RC-09-0068 Page 2 of 5 Request for Exemption from the Provisions of 10 CFR 50.46 and 10 CFR Part 50 Appendix K to Allow Use of Optimized ZIRLOTM in Core Reload Applications 1.0 PURPOSE South Carolina Electric and Gas Company (SCE&G) requests an exemption from the provisions of 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" to allow the use of Optimized ZIRLOTM fuel rod cladding in future core reload applications for Virgil C. Summer Nuclear Station (VCSNS).

10 CFR 50.46 contains acceptance criteria for the emergency core cooling system (ECCS) for reactors that have fuel rods fabricated either with Zircaloy or ZIRLOTM. Appendix K to 10 CFR Part 50, paragraph I.A.5, requires the Baker-Just equation to be used to predict the rates of energy release, hydrogen concentration, and cladding oxidation for the metal-water reaction. The Baker-Just equation assumed the use of a zirconium alloy different than Optimized ZIRLOTM.

Therefore, an exemption to 10 CFR 50.46 and 10 CFR Part 50, Appendix K is required to support the use of Optimized ZIRLO TM fuel rod cladding. The exemption request relates solely to the specific cladding material specified in these regulations (i.e., fuel rods clad with Zircaloy or ZIRLOTM). This request will provide for the application of the acceptance criteria of 10 CFR 50.46 and Appendix K to 10 CFR Part 50 to fuel assembly designs utilizing Optimized ZIRLOTM fuel cladding.

2.0 BACKGROUND

As the nuclear industry pursues longer operating cycles with increased fuel discharge burnup and fuel duty, the corrosion performance requirements for the nuclear fuel cladding become more demanding. Optimized ZIRLOTM was developed to meet these needs and provides a reduced corrosion rate while maintaining the benefits of mechanical strength and resistance to accelerated corrosion from abnormal chemistry conditions.

In addition, fuel rod internal pressures (resulting from the increased fuel duty, use of integral fuel burnable absorbers, and corrosion/temperature feed back effects) have become more limiting with respect to fuel rod design criteria. Reducing the associated corrosion buildup and thus minimizing temperature feedback effects provides additional margin to the fuel rod internal pressure design criterion.

Technical Specification (TS) changes for VCSNS are required to allow the use of Optimized ZIRLOTM fuel rod cladding for core reload applications. The request for these changes is included within the Enclosure.

3.0 TECHNICAL JUSTIFICATION OF ACCEPTABILITY Westinghouse Electric Company, LLC (Westinghouse) topical report WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLOTM" (Reference 1) provides the details and results of material testing of Optimized ZIRLOTM compared to standard ZIRLOTM as well as the material properties to be used in various models and methodologies when analyzing Optimized ZIRLOTM.

The NRC Safety Evaluation (SE) (Reference 2) for the topical report contains ten conditions and limitations. The first condition and limitation requires an exemption from 10.CFR 50.46 and 10 CFR Part 50, Appendix K. Westinghouse has provided the NRC with information

Document Control Desk LAR/CR-09-00562 RC-09-0068 Page 3 of 5 related to test data and models (References 3, 4, 5, and 6) to address conditions and limitations 6 and 7. Condition and limitation 9 does not apply because VCSNS is not licensed with LOCBART or STRIKIN-II.

The remaining conditions and limitations will be addressed in the VCSNS TS changes and evaluations required to support core reload activities.

Since plant specific TS changes are required prior to utilizing Optimized ZIRLOTM, no new commitments are necessary to support NRC approval of this exemption request.

The core reload evaluations will ensure that acceptance criteria are met for all the other limitations and conditions for the insertion of assemblies with fuel rods clad with Optimized ZIRLOTM under 10 CFR 50.59 requirements. These assemblies will be evaluated using NRC approved methods and models to address the use of Optimized ZIRLOTM.

4.0 JUSTIFICATION OF EXEMPTION 10 CFR 50.12, "Specific exemptions," states that the NRC may grant exemptions from the requirements of the regulations of this part provided three conditions are met.

The three conditions are: 1) the exemption is authorized by law; 2) the exemption will not present an undue risk to the health and safety of the public; and 3) the exemption is consistent with the common defense and security.

The requested exemption to allow the use of Optimized ZIRLO TM fuel rod cladding material in addition to Zircaloy or ZIRLOTM for core reload applications at VCSNS satisfies these criteria as described below.

1. This exemption is authorized by law As required by 10 CFR 50.12 (a) (1), this requested exemption is "authorized by law." The selection of a specified cladding material in 10 CFR 50.46 and implied in 10 CFR Part 50, Appendix K, was adopted at the discretion of the Commission consistent with its statutory authority. No statute required the NRC to adopt this specification. Additionally, the NRC has the authority under Section 50.12 to grant exemptions from the requirements of Part 50 upon showing proper justification.

Furthermore, by submitting this exemption request, VCSNS does not seek an exemption from the acceptance and analytical criteria of 10 CFR 50.46 and 10 CFR Part 50, Appendix K. The intent of the request is solely to allow the use of criteria set forth in these regulations for application to the Optimized ZIRLOTM fuel rod cladding material.

2. This exemption will not present an undue risk to public health and safety The core reload evaluations will ensure that acceptance criteria are met for the insertion of assemblies with fuel rods clad with Optimized ZIRLOTM. Fuel assemblies using Optimized ZIRLOTM fuel rod cladding will be evaluated using NRC approved analytical methods and plant specific models to address the changes in the cladding material properties. The safety analysis for VCSNS is supported by the applicable site specific TSs. Reload cores are required to be operated in accordance with the operating limits specified in the TSs. Thus, the granting of this exemption request will not pose an undue risk to public health and safety.

Document Control Desk LAR/CR-09-00562 RC-09-0068 Page 4 of 5

3. This exemption is consistent with common defense and security As noted above, the exemption request is only to allow the application of the aforementioned regulations to an improved fuel rod cladding material. All the requirements and acceptance criteria will be maintained.

The special nuclear material in these assemblies is required to be handled and controlled in accordance with approved procedures. Use of full regions of Optimized ZIRLOTM fuel rod cladding in the VCSNS core will not affect plant operations and is consistent with common defense and security.

5.0 SPECIAL CIRCUMSTANCES SUPPORT THE ISSUANCE OF AN EXEMPTION 10 CFR 50.12(a)(2) states that the NRC will not consider granting an exemption to the regulations unless special circumstances are present. The requested exemption meets the special circumstances of 10 CFR 50.12(a)(2)(ii) which states that, "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."

In this particular circumstance, application of the subject regulations is not necessary to achieve the underlying purpose of the rule.

10 CFR 50.46 identifies acceptance criteria for ECCS performance at nuclear power plants.

Due to the similarities in the material properties of the Optimized ZIRLO TM and standard ZIRLOTM, the current ECCS analysis approach remains applicable. Westinghouse will perform an evaluation of the VCSNS core using LOCA methods approved for the site to ensure that assemblies with Optimized ZIRLO TM fuel rod cladding material meet all LOCA safety criteria.

The intent of 10 CFR Part 50, Appendix K, paragraph I.A.5 is to apply an equation for rates of energy release, hydrogen generation, and cladding oxidation from a metal-water reaction that conservatively bounds all post-LOCA scenarios (i.e., the Baker-Just equation). Application of the Baker-Just equation has been demonstrated to be appropriate for the Optimized ZIRLOTM alloy.

Due to the similarities in the composition of the Optimized ZIRLOTM and standard ZIRLOTM fuel rod cladding materials, the application of the Baker-Just equation will continue to conservatively bound all post-LOCA scenarios.

6.0 CONCLUSION

The acceptance criteria and requirements of 10 CFR 50.46 and 10 CFR Part 50, Appendix K currently are limited in applicability to the use of fuel rods clad with Zircaloy or ZIRLO TM.

10 CFR 50.46 and 10 CFR Part 50, Appendix K does not apply to the proposed use of Optimized ZIRLO TM fuel rod cladding material since Optimized ZIRLO TM has a slightly different composition than Zircaloy or ZIRLOTM.

With the approval of this exemption request, these regulations will be applied to Optimized ZIRLOTM.

In order to support the use of Optimized ZIRLOTM fuel rod cladding material, an exemption from the requirements of 10 CFR 50.46 and 10 CFR Part 50, Appendix K is requested. As required by 10 CFR 50.12, the requested exemption is authorized by law, does not present undue risk to public health and safety, and is consistent with common defense and security. Approval of this

Document Control Desk LAR/CR-09-00562 RC-09-0068 Page 5 of 5 exemption request does not violate the underlying purpose of the rule. In addition, special circumstances do exist to justify the approval of an exemption from the subject requirements.

7.0 REFERENCES

1. WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLOTM,I" July 2006.

2. Letter from H. N. Berkow (USNRC) to J. A. Gresham (Westinghouse), "Final Safety Evaluation for Addendum to Topical Report WCAP-12610-P-A and CENPD-404-P-A,

'Optimized ZIRLOTM'," June 10, 2005. (ML051670395)

3. Letter from J. A. Gresham (Westinghouse) to USNRC (Document Control Desk), "SER Compliance with WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A, 'Optimized ZIRLOTM', LTR-NRC-07-1, January 4, 2007.

4. Letter from J. A. Gresham (Westinghouse) to USNRC (Document Control Desk), "SER Compliance with WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A, 'Optimized ZIRLOTM'," LTR-NRC-07-58, November 6, 2007. (ML073130556)

5. Letter from J. A. Gresham (Westinghouse) to USNRC (Document Control Desk), "SER Compliance with WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A, 'Optimized ZIRLO TM'," LTR-NRC-07-58 Rev. 1, February 5, 2008. (ML080390451)

6. Letter from J. A. Gresham (Westinghouse) to U.S. Nuclear Regulatory Commission, "SER Compliance of WCAP-12610-P-A & CENPD-404-P-A Addendum 1-A "Optimized ZIRLO TM," LTR-NRC-08-60, December 30, 2008.

Document Control Desk LAR/CR-09-00562 RC-09-0068 Page 1 of 4 VIRGIL C. SUMMER NUCLEAR STATION (VCSNS)

DOCKET NO. 50/395 OPERATING LICENSE NO. NPF-12 ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

Proposed Technical Specification Changes Summary Replace the following pages of the Appendix A to Operating License Number NPF-12, Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages 5-6 6-16 6-16a Insert Pages 5-6 6-16 6-16a SCE&G - EXPLANATION OF CHANGES Page Affected Bar Description of Chanqe Reason for Change Section 5-6 5.3.1 1

Changed "Zircaloy-4 or Add Optimized ZIRLOTM to ZIRLO TM',

the approved fuel rod To "Zircaloy-4, ZIRLO TM, or cladding materials.

Optimized ZIRLO TM".

6-16 6.9.1.11.a.

N/A Moved 6.9.1.11.a and Repagination.

6.9.1.11.b.

6.9.1.11.b from page 6-16a to 6.16.

6-16a 6.9.1.11.f 1

Added new 6.9.1.11.f.

Add Westinghouse topical report WCAP-12610-P-A to the analytical methods used to determine the core operating limits previously reviewed and approved by the NRC

Document Control Desk LARICR-09-00562 RC-09-0068 Page 2 of 4 DESIGN FEATURES 5.3 Rg&MCTR Q=R Zircaloy-4, ZIRLOTM, or Optimized ZIRLOTM4

&&31 The mme ablaal~na 157 fuel asswr~iuu SAch fuel murabty sh-a L mansl of 264 ZIWIUJ" toU'tP cWelldfs rod. Wih an inMde cowpoulibn at uruanium db~de v a

MsdmUM WnfmtiAWWc1rusn o 4.95 We~gh percWd U-235 08 Wue MateWtL Lknhd assehly aiifguam as hll be to those dadgn tWhav ew been walyze witi upplIcabl. NWRC edC pou m athoc H and shown by luft or cyche-quaofte Aifloent lntegiu fuel bhumvie such OW tdo requirw=0n at Speciflteiors 541.10.8and 54 1.2.bareit. A Mraweof load tw sst b"o a

o Q~bM & WQASSEMESZircaloy-4, ZIRLOTM, Optimized ZIRLOTM S.3.2 The toeacor mre shAawdl ont 48 full length awnd rod assuuvibles. The ful lngth control rod non~eshall cowlito a riambie 142 &iches of absorber mastof. The n on~iaf valuovola shetwematetfal shaM be,60 peacen shie. 15 pevwift irwsnard 5 perce CaRnbyM. Al0~

co M~rd98Wdbe cbdvWith atulim sWUaltun 54-REACTOR CGOLAWTSSTM7111 QMrMPESP N

FEAUI "I4 The run=c coolent rig=ffIs dellgrou d and she be men~nUk~e

a.

lIn accotdmnce wih fti codt eqrenf epedlied In Sectw, 5.2 ct One PSAR, etiaflowae for non.a degradaUon piwmuazto the qf~iaab.SurWbnc Requftmente

6.

For apresawre of2488pf mnd r-For a teaperalur ot $500F. e=Wp for toe pwsmubwt whlc Is SWIF, SA.2 The tota water and Mtam f

ti

'tue of the reawtoclafitste aYZf 9614 *100 cael feel at an Inicatad Two of 587.40F.

B.5

-Mg=EOROLG1CAL TOWER LOCATION 5.5.1 The meteorolo"Ica tower maill be Iccaftil as shovm n ciiFlure 5.1-1.

SUMMIER - LINT I SUMME-U~i I

endMWI N& V Y665,

Document Control Desk LARICR-09-00562 RC-09-0068 Page 3 of 4 ADMINISTRATIVE CONTROLS 6.9.1.9 Not used.

6.9.1.10 Not used.

CORE OPERATING UMITS REPORT 6.9.1.11 Core operating linnits shall be established and diocwiented in the CORE OPERATING LIMITS REPORT prior to each reload cycle, or prior to avy rermaiing portion of a reload cycle, for the following:

a.

Moderator Temperature Coefficient 0 OL and EOL Limits and 300 ppm surveillance limit for Specification 34.1.1.3,

b.

Shutdown Rod Insertion IUnit for Specification 3/4.1.3.5,

c.

Cordrol Rod Insertion Limits for Specification 3(4.1.3.6,

d.

Axial Fux Difference Limits, target band, and APL00for Specification 314.2.1,

e.

Heat Flux Hot Channel Factor, F.*, K(z), W(z), AP-O, W(z)m, and FQ(z) manufacturing/measurement uncertainties for Specification 3/4_2.2,

f.

Nuclear Enthalpy Rise Hlot Channel Factor, F*', Power Factor Multiplier, PF*,

and F; measurement uncertaities limibs for Specification 3142.3.

The analytical methods used to determine the core operating I Emits shall.be those previously reviewed and approved by the NRC, specifically thsm described n the foblowing documents:

a.

WCAP-9272-P-A -WEST1NGHOUSE RELOAD SAFETY EVALUATION METHIODOLOGY,' July 1985 (W Proprietary).

(Methodology for Specifications 3.1.1.3 - Moderator Temperature Coefficient, 3.1.3.5 - Shutdown Rod Insertion Limits, 3.1.3.6 - Control Rod Insertion Limits, 3.2.1 - Axial Flux Difference, 3.2.2 - Heat Flux Hot Channel Factor, and 3.2.3 -

RCS Flow Rate and Nuclear Enthalpy Rise Hot Channel Factor.)

b.

WCAP-10216-P-A, Rev. 1A, "RELAXATION OF CONSTANT AXIAL OFFSET CONTROL FQ SURVEILLANCE TECHNICAL SPECIFICATION," February 1994 (W Proprietary).

(Methodology for Specifications 3.2.1 - Axial Flux Difference (Relaxed Axial Offset Control) and 3.2.2 - Heat Flux Hot Channel Factor (FQ Methodology for W(z) surveillance requirements).)

\\Moved from next AmendmeNo 79, --, !94, page 6-16a 14?, 44 175 SUMMER -UNIT 1 6-16

Document Control Desk LAR/CR-09-00562 RC-09-0068 Page 4 of 4 ADMINISTRATIVE CXNTROLS F

Moved to previous page 6-16 CORE OPERATING LIMITS REPORT (Continued)

I Methodology for Specifications 3.1.1.3 - Moderator Temperature coemf

-Shutdown Rod Insertion Uimits, 3.1.3.6 - Control Rod 1 Umts 312.1 Difference, 3.22-Heat Flux Hot Chai r, and 3.2.3 -

RCS Flow clear EnRhalpy Rise Iot actor.)

b.

WCAP-10216-P-A, Rev. 1A, OF CONSTANT AXIAL OFFSET CONTROL Fa SURVEIL C

SPECIFICATION,- February 1994 (W Proprietary).

for Specifications 3.2.1 - Axial Flux Dffed Axial Control) and 12.2 - Heat Flux Hot Channel Factor (Fo Me for W(z) surveillance requirements).)

c.

WCAP-12945-P-A, Volume 1 (Revision 2) through Volumes 2 through 5 (Revision 1) "Code Qualification Document for Best Estimate LOCA Analysis,-

March 1998 (Wesftfiiuse Proprietary).

Lipaulo, N. U0 to NRC Document Control Desk, NSD-NRC-96-4746, -Re-Analysis Work Plans Using Final Best Estimate Methodology" dated 6/1311996.

(Methodology for Specification 3.2 Heat Flux Hot Channel Factor.)

d.

WCAP-12472-P-A, 'BEACON CORE MONITORING AND OPERATIONS SUPPORT SYSTEM, August 1994, (W Prprietay).

(Methodology for Specifications 3.22 - Heat Flux Hot Channel Factor, 3.2.3 -

RCS Flow Rate and Nuclear Enthalpy Rise Hot Channel Factor, and 3.2.4 -

Quadrant Power Tit Ratio.)

e.

WCAP-13749-P-A, "Safety Evaluation Supporting the Conditional Exemption of the Most Negative EOL Moderator Temperature Coefficiiet Meamement,"

March 1997, (Westinghouse Proprietary).

(Methodology for Specification 3.1.1.3 - Moderator Temperature Coefient.)

The core operating limits shall be deter-irrned so that all applcable limnits (e.g., fuel thermal-mechanical limits, core therma-hydrau licn-its, nuclear limits such as shutdown margin, and transient and accident analysis limits) of the safety analysis are met The CORE OPERATING LIMITS REPORT. induding any mid-cvde revisions or sunolements

f.

WCAP-12610-P-A, 'VANTAGE + Fuel Assembly Reference Core Report," April 1995 (W Proprietary). WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLO TM," July 2006 & Proprietary).

(Methodology for Specification 3.2.2 - Heat Flux Hot Channel Factor.)

SUMMER - UNIT 1 6-16a Amendment No. 88, 121,133,14-2, 4W9 176

Document Control Desk LAR/CR-09-00562 RC-09-0068 Page 1 of 4 VIRGIL C. SUMMER NUCLEAR STATION (VCSNS)

DOCKET NO. 50/395 OPERATING LICENSE NO. NPF-12 ATTACHMENT 3 PROPOSED TECHNICAL SPECIFICATION PAGES (RETYPED)

DESIGN FEATURES 5.3 REACTOR CORE FUEL ASSEMBLIES 5.3.1 The core shall contain 157 fuel assemblies. Each fuel assembly shall consist of 264 Zircaloy-4, ZIRLOTM, or Optimized ZIRLOTM clad fuel rods with an initial composition of uranium dioxide with a maximum nominal enrichment of 4.95 weight percent U-235 as fuel material. Limited substitutions of Zircaloy-4, ZIRLOTM, or Optimized ZIRLOTM and/or stainless steel filler rods for fuel rods, if justified by a cycle specific reload analysis using an NRC-approved methodology, may be used. Fuel assembly configurations shall be limited to those designs that have been analyzed with applicable NRC staff-approved codes and methods, and shown by tests or cycle-specific reload analyses to comply with all fuel safety design bases. Reload fuel shall contain sufficient integral fuel burnable absorbers such that the requirements of Specifications 5.6.1.1a.2 and 5.6.1.2.b are met. A limited number of lead test assemblies that have not completed representative testing may be placed in non-limiting core locations.

CONTROL ROD ASSEMBLIES 5.3.2 The reactor core shall contain 48 full length control rod assemblies. The full length control rod assemblies shall contain a nominal 142 inches of absorber material. The nominal values of absorber material shall be 80 percent silver, 15 percent indium and 5 percent cadmium. All control rods shall be clad with stainless steel tubing.

5.4 REACTOR COOLANT SYSTEM DESIGN PRESSURE AND TEMPERATURE 5.4.1 The reactor coolant system is designed and shall be maintained:

a.

In accordance with the code requirements specified in Section 5.2 of the FSAR, with allowance for normal degradation pursuant to the applicable Surveillance Requirements,

b.

For a pressure of 2485 psig, and

c.

For a temperature of 6500F, except for the pressurizer which is 6800F.

VOLUME 5.4.2 The total water and steam volume of the reactor coolant system is 9914 +/- 100 cubic feet at an indicated Tavg of 587.40F.

5.5 METEOROLOGICAL TOWER LOCATION 5.5.1 The meteorological tower shall be located as shown on Figure 5.1-1.

SUMMER - UNIT 1 5-6 Amendment No. 27, 6-, 62, 7, 4*6,116, 119, 4 6,

ADMINISTRATIVE CONTROLS 6.9.1.9 Not used.

6.9.1.10 Not used.

CORE OPERATING LIMITS REPORT 6.9.1.11 Core operating limits shall be established and documented in the CORE OPERATING LIMITS REPORT prior to each reload cycle, or prior to any remaining portion of a reload cycle, for the following:

a.

Moderator Temperature Coefficient BOL and EOL Limits and 300 ppm surveillance limit for Specification 3/4.1.1.3,

b.

Shutdown Rod Insertion Limit for Specification 3/4.1.3.5,

c.

Control Rod Insertion Limits for Specification 3/4.1.3.6,

d.

Axial Flux Difference Limits, target band, and APLND for Specification 3/4.2.1,

e.

Heat Flux Hot Channel Factor, FT, K(z), W(z), APLNO, W(Z)BL, and Fa(z) manufacturing/measurement uncertainties for Specification 3/4.2.2,

f.

Nuclear Enthalpy Rise Hot Channel Factor, FT,,

Power Factor Multiplier, PFAH, and FNH measurement uncertainties limits for Specification 3/4.2.3.

The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:

a.

WCAP-9272-P-A, 'WVESTINGHOUSE RELOAD SAFETY EVALUATION METHODOLOGY," July 1985 (W Proprietary).

(Methodology for Specifications 3.1.1.3 - Moderator Temperature Coefficient, 3.1.3.5 - Shutdown Rod Insertion Limits, 3.1.3.6 - Control Rod Insertion Limits, 3.2.1 - Axial Flux Difference, 3.2.2 - Heat Flux Hot Channel Factor, and 3.2.3 -

RCS Flow Rate and Nuclear Enthalpy Rise Hot Channel Factor.)

b.

WCAP-10216-P-A, Rev. 1A, "RELAXATION OF CONSTANT AXIAL OFFSET CONTROL Fa SURVEILLANCE TECHNICAL SPECIFICATION," February 1994 (W Proprietary).

(Methodology for Specifications 3.2.1 - Axial Flux Difference (Relaxed Axial Offset Control) and 3.2.2 - Heat Flux Hot Channel Factor (Fa Methodology for W(z) surveillance requirements).)

SUMMER - UNIT 1 6-16 Amendment No. 9,88,04, 11:7,1142,176, I

ADMINISTRATIVE CONTROLS CORE OPERATING LIMITS REPORT (Continued)

c.

WCAP-12945-P-A, Volume 1 (Revision 2) through Volumes 2 through 5 (Revision 1) "Code Qualification Document for Best Estimate LOCA Analysis,"

March 1998 (Westinghouse Proprietary).

Liparulo, N. (W) to NRC Document Control Desk, NSD-NRC-96-4746, "Re-Analysis Work Plans Using Final Best Estimate Methodology" dated 6/13/1996.

(Methodology for Specification 3.2.2 - Heat Flux Hot Channel Factor.)

d.

WCAP-12472-P-A, "BEACON CORE MONITORING AND OPERATIONS SUPPORT SYSTEM," August 1994, (W Proprietary).

(Methodology for Specifications 3.2.2 - Heat Flux Hot Channel Factor, 3.2.3 -

RCS Flow Rate and Nuclear Enthalpy Rise Hot Channel Factor, and 3.2.4 -

Quadrant Power Tilt Ratio.)

e.

WCAP-13749-P-A, "Safety Evaluation Supporting the Conditional Exemption of the Most Negative EOL Moderator Temperature Coefficient Measurement,"

March 1997, (Westinghouse Proprietary).

(Methodology for Specification 3.1.1.3 - Moderator Temperature Coefficient.)

f.

WCAP-12610-P-A, "VANTAGE + Fuel Assembly Reference Core Report," April 1995 (W Proprietary). WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, "Optimized ZIRLOT"," July 2006 (W Proprietary).

(Methodology for Specification 3.2.2 - Heat Flux Hot Channel Factor.)

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

The CORE OPERATING LIMITS REPORT, including any mid-cycle revisions or supplements there to shall be provided upon issuance, for each reload cycle, to the NRC Document Control Desk with copies to the Regional Administrator and Resident Inspector.

SUMMER - UNIT 1 6-16a Amendment No. 88, 121, 133,4 2,

169,

, v

Document Control Desk LAR/CR-09-00562 RC-09-0068 Page 1 of 1 VIRGIL C. SUMMER NUCLEAR STATION (VCSNS)

DOCKET NO. 50/395 OPERATING LICENSE NO. NPF-12 ATTACHMENT 4 LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by Virgil C. Summer Nuclear Station (VCSNS) in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

Please direct questions regarding these commitments to Mr. Bruce L. Thompson at (803) 931-5042.

Commitment Due Date The core reload' process for VCSNS will ensure the conditions Continuous, until the and limitations of the NRC SER for Optimized ZIRLO TM as contingency requirements of addressed in Enclosure are met when a batch of Optimized the conditions and limitations ZIRLO TM is implemented.

have been satisfied.

SCE&G will confirm that Westinghouse will provide additional Continuous, until the LTA confirmatory data associated with LTA programs at other data up through the fuel facilities prior to subsequent cycles of operation with Optimized burnup limit applicable for ZIRLO TM fuel rod cladding.

VCSNS has been provided to the NRC.