ML093140092
| ML093140092 | |
| Person / Time | |
|---|---|
| Site: | Catawba, McGuire, Mcguire  |
| Issue date: | 10/29/2009 |
| From: | Brandi Hamilton Duke Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML093140092 (22) | |
Text
Duke BRUCE H.HAMILTON Vice President
- Energy. McGuire Nuclear Station Duke Energy MG01 VP / 12700 Hagers Ferry Road Huntersville, NC 28078 980-875-5333 980-875-4809 fax bruce.hamilton@duke-energy.corn October 29, 2009 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION: Document Control Desk
SUBJECT:
Duke Energy Carolinas (DEC), LLC McGuire Nuclear Station (MNS), Units 1 and 2 Docket Nos. 50-369, 50-370 Catawba Nuclear Station (CNS), Units 1 and 2 Docket Nos. 50-413, 50-414 License Amendment Request (LAR) Proposing Deletion of Facility Operating License (FOL) Condition Limiting Maximum Fuel Rod Burnup to 60 Giga-Watt Days per Metric Ton Uranium (GWd/MTU).
Pursuant to 10 CFR 50.90, DEC is submitting a LAR applicable to a FOL condition currently contained in FOL NPF-9 for MNS Unit 1, FOL NPF-17 for MNS Unit 2, FOL NPF-35 for CNS Unit 1, and FOL NPF-52 for CNS Unit 2. The specific changes that are proposed in this amendment will delete the license condition located in Appendix B of the respective Unit's FOL which restricts the maximum fuel rod average burnup to 60 gigawatt days per metric ton uranium (GWd/MTU) until the completion of an NRC environmental assessment supporting an increased limit. The NRC has completed an environmental assessment supporting peak-rod fuel burnup up to and including 62 GWd/MTU.
Deletion of the subject FOL condition will provide DEC the opportunity to increase maximum fuel rod average burnup up to and including 62 GWd/MTU in the future and increase fuel management flexibility.
oo(
www. duke-energy.com
October 29, 2009 Nuclear Regulatory Commission Page 2 of 4 provides a description of the proposed change, the technical justification for the change, a No Significant Hazards Consideration evaluation pursuant to 10 CFR 50.92(c), an Environmental Assessment, and attachments la, 1 b, and lc.
Attachments 1a and lb to Enclosure 1: Provide a marked up copy of the existing FOL Appendix B for MNS Units 1 and 2 and CNS Units 1 and 2, respectively. The marked up copies show the proposed changes. Retyped (clean) FOL pages will be provided to the NRC immediately prior to issuance of the approved amendment. c provides a summary of NUREG/CR-6703 Conclusions and an Evaluation of these conclusions with respect to McGuire and Catawba Nuclear Stations.
In accordance with DEC internal procedures and the Quality Assurance Topical Report, the proposed amendment has been reviewed and approved by the MNS and CNS Plant Operations Review Committee and the DEC Corporate Nuclear Safety Review Board.
Pursuant to 10CFR50.91, a copy of this LAR has been forwarded to the appropriate North and South Carolina state officials.
Implementation of the changes proposed at MNS and CNS will result in the need to revise both of the stations' Updated Final SafetyAnalysis Reports (UFSAR). The necessary UFSAR revisions will be made in accordance with 10 CFR 50.71(e).
There are no regulatory commitments contained in this submittal.
Duke requests that NRC review and approval of this LAR be completed by March 31, 2010. Duke has determined that a 30-day implementation grace period will be sufficient to implement this LAR.
Please direct any questions you may have in this matter to J.W. Bryant at (980) 875-4162.
Sincerely, B. H. Hamilton Enclosures
October 29, 2009 Nuclear Regulatory Commission Page 3 of 4 xc w/ Attachments:
L. A. Reyes Administrator, Region II U.S. Nuclear Regulatory Commission Sam Nunn Atlanta Federal Center 61 Forsyth Street, Suite 23T85 Atlanta, GA 30303 J. B. Brady NRC Senior Resident Inspector McGuire Nuclear Station G. A. Hutto III NRC Senior Resident Inspector Catawba Nuclear Station J. H. Thompson (addressee only)
U.S. Nuclear Regulatory Commission Mail Stop 0-8 G9A Washington, DC 20555-0001 S. E. Jenkins, Manager Division of Radioactive Waste Management Bureau of Land and Waste Management Dept of Health and Environmental Control 2600 Bull Street Columbia, SC 29201 B. 0. Hall, Senior Chief Division of Radiation Section 1645 Mail Service Center Raleigh, NC 27699-1645
October 29, 2009 Nuclear Regulatory Commission Page 4 of 4 Bruce H. Hamilton affirms that he is the person who subscribed his name to the foregoing statement, and that all the matters and facts set forth herein are true and correct to the best of his knowledge.
Bruce H. Hamilton, Vice President, McGuire Nuclear Station Subscribed and sworn to me: I o q-Date Notary Public My commission expires:
Date N
Enclosure 1 Page 1 of 8 EVALUATION OF THE PROPOSED CHANGE
Subject:
License Amendment Request to Delete Facility Operating License Condition Limiting Maximum Fuel Rod Burnup to 60 Giga-Watt Days per metric Ton Uranium
1.0 DESCRIPTION
2.0 PROPOSED CHANGE
3.0 BACKGROUND
4.0 TECHNICAL ANALYSIS
5.0 REGULATORY SAFETY ANALYSIS 5.1 NO SIGNIFICANT HAZARDS CONSIDERATION 5.2 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA 5.3 PRECEDENTS
6.0 ENVIRONMENTAL CONSIDERATION
7.0 , REFERENCES
Enclosure 1 Page 2 of 8
1.0 DESCRIPTION
This evaluation supports a request to amend McGuire Nuclear Station (MNS) Unit 1 Facility Operating License (FOL) No. NPF-9, MNS Unit 2 FOL No. NPF-17, Catawba Nuclear Station (CNS) Unit 1 FOL No. NPF-35, and CNS Unit 2 FOL No. NPF-52. The specific changes that are proposed in this amendment will delete the license condition located in Appendix B of the respective Unit's FOL which restricts the maximum rod average burnup to 60 gigawatt days per metric ton uranium (GWd/MTU) until the completion of an NRC environmental assessment supporting an increased limit. The NRC has completed an environmental assessment supporting peak-rod fuel burnup up to and including 62 GWd/MTU 1. As stated in the NRC assessment, maximum peak-rod limitations envelope core average burnup limitations.
Deletion of the subject FOL condition will provide Duke Energy Corporation (DEC) the opportunity to increase maximum rod average burnup up to and including 62 GWd/MTU for fuel used in core reloads at MNS and CNS.
2.0 PROPOSED CHANGE
S The proposed amendment would delete the following condition contained in Appendix B of the MNS Unit 1 and Unit 2 FOLs and in Appendix B of the CNS Unit 1 and Unit 2 FOLs:
"The maximum rod average burnup for any rod shall be limited to 60 GWd/mtU until the completion of an NRC environmental assessment supporting an increasedlimit."
No changes to the MNS or CNS Technical Specifications (TS) or the TS Bases are necessary to support this amendment request.
3.0 BACKGROUND
3.1 Background
In 1999, the NRC approved and issued Amendment No. 188 to the MNS Unit 1 FOL No.
NPF-9 and Amendment No. 169 to the MNS Unit 2 FOL No. NPF-17 2. Also at that time, the NRC approved and issued Amendment No. 180 to the CNS Unit 1 FOL No. NPF-35 and Amendment No. 172 to the CNS Unit 2 FOL No. NPF-52 3. These amendments revised various sections of the MNS and CNS TS's to permit transition from the use of Framatome Cogema Mark-BW fuel for MNS and CNS core reloads to the use of Westinghouse RFA fuel. Concurrent with the approval of the referenced amendments, the NRC also approved Topical Report DPC-NE-2009-P-A, "Duke Power Company NUREG/CR-6703, "Environmental Effects of Extending Fuel Burnup Above 60 GWd/MTU,"
dated January 2001, ADAMS Accession No. ML010310298.
2 Letter, F. Rinaldi (USNRC) to H. B. Barron (Duke Energy),
Subject:
McGuire Nuclear Station Units 1 and 2, Re: Issuance of Amendments (TAC Nos. MA2411 and MA2412), dated September 22, 1999.
3 Letter, P. S. Tam (USNRC) to G. R. Peterson (Duke Energy),
Subject:
Catawba Nuclear Station Units 1 and 2, Re: Issuance of Amendments (TAC Nos. MA2359 and MA2361), dated September 22, 1999.
Enclosure 1 Page 3 of 8 Westinghouse Fuel Transition Report". The transition to 100% use of Westinghouse RFA fuel for MNS and CNS core reloads has been completed. 4 In approving the 1999 amendments, the NRC found that the DEC design limits and thermal-mechanical analysis methodologies discussed in DPC-NE-2009-P-A supported a rod average burnup limit up to and including 62 GWd/MTU for the RFA fuel design.
However, from an environmental perspective, the NRC stated in the SEs for these amendments that the NRC generic environmental assessment regarding fuel burnup in place at that time had only considered fuel exposures up to 60 GWd/MTU.
Consequently, as part of the amendments, the NRC imposed a license condition for both CNS and MNS limiting maximum fuel rod average burnup to the 60 GWd/MTU value until the NRC completed an environmental assessment supporting an increased limit.
That license condition is currently described in Appendix B of the MNS and CNS FOLs.
In 2001, the NRC completed an environmental assessment supporting a maximum peak-rod fuel burnup up to and including 62 GWd/MTU. As stated in the NRC assessment, peak-rod limitations envelope core average burnup limitations. In 2003, the NRC also issued an SE approving an extension of the burnup limit for Framatome Cogema Mark-BW fuels up to and including 62 GWd/MTU5 . Therefore, DEC is proposing to delete the current condition in Appendix B of the MNS and CNS FOLs which limits maximum rod average burnup at both MNS and CNS to 60 GWd/MTU.
Upon deletion of this license condition, it will be acceptable, from both a methodology and environmental perspective, for MNS and CNS to increase the maximum rod average burnup up to and including 62 GWd/MTU for fuel used in core reloads.
4.0 TECHNICAL ANALYSIS
As stated in Enclosure 1 Section 3.0 - "Background", approved 1999 amendments revised various sections of the MNS and CNS TS's to permit transition from the use of Framatome Cogema Mark-BW fuels for MNS and CNS core reloads to the use of Westinghouse RFA fuel. The transition to 100% use of Westinghouse RFA fuel for MNS and CNS core reloads has been completed. Concurrent with the approval of the 1999 amendments, the NRC also approved Topical Report DPC-NE-2009-P-A, "Duke Power Company Westinghouse Fuel Transition Report". In approving this Topical Report, the NRC determined the current DEC design limits and thermal-mechanical analysis methodologies discussed in DPC-NE-2009-P-A support a rod average burnup limit up to and including 62 GWd/MTU for the Westinghouse RFA fuel design. In 2003, the NRC also issued an SE approving an extension of the burnup limit for Framatome Cogema Mark-BW fuels up to and including 62 GWd/MTU.
Upon approval of the 1999 amendments, DEC was unable to increase maximum rod average burnup to as high as 62 GWd/MTU since the NRC generic environmental assessment in place at that time regarding fuel burnup had only considered fuel exposures up to 60 GWd/MTU. In 2001, the NRC issued NUREG/CR-6703 -
"Environmental Effects of Extending Fuel Burnup Above 60 GWd/MTU" which provided an environmental assessment supporting a maximum peak-rod fuel burnup up to and including 62 GWd/MTU. As stated in the NRC assessment, maximum peak-rod limitations envelope core average burnup limitations. Therefore, DEC is proposing to 4 CNS currently has 4 Westinghouse new generation fuel Lead Test Assemblies (LTA) in use in 5Letter, These LTAs will be discharged in 1 EOC1 8 (scheduled to end December 2009).
Unit 1.
H. N. Berkow (USNRC) to J. F. Mallay (Framatome ANP),
Subject:
Safety Evaluation of Framatome ANP Topical Report BAW-10186P-A, Revision 1, Supplement 1, "Extended Burnup Evaluation" (TAC Nos MB3650 and MB7548), dated June 18, 2003.
Enclosure 1 Page 4 of 8 delete the current MNS and CNS FOLs Appendix B condition which limits maximum rod average burnup at both MNS and CNS to 60 GWd/MTU. Deletion of the subject FOL condition will provide DEC the opportunity to increase maximum rod average burnup up to and including 62 GWd/MTU in the future and increase fuel management flexibility.
4.1 Evaluation of NUREG/CR-6703 With Respect To MNS and CNS The NUREG/CR-6703 environmental assessment concluded there are no significant adverse environmental impacts associated with extending peak rod fuel burnup up to and including 62 GWd/MTU. The assumptions and analysis methodologies contained in the environmental assessment envelope the fuel design and the analysis methods utilized at MNS and CNS. A summary of the 2001 NRC environmental assessment conclusions and an evaluation of these conclusions with respect to MNS and CNS are summarized in Attachment 1c to Enclosure 1.
4.2 Summary Upon approval of this LAR by the NRC and deletion of the MNS and CNS FOL condition currently limiting maximum rod average burnup to 60 GWd/MTU, it will be acceptable, from both a methodology and environmental perspective, to increase maximum rod average burnup up to and including 62 GWd/MTU for fuel used in core reloads at MNS and CNS. This limitation will become part of the MNS and CNS license bases governed by previous NRC SEs related to approval of MNS and CNS fuel analysis methodologies and the SE associated with this LAR. Fuel cycle specific reload calculations that confirm all fuel design criteria are satisfied will continue to be performed and documented each cycle. All current fuel design, core design, and safety analysis limits will continue to be met.
Implementation of this LAR will result in a need to revise both the MNS and CNS Updated Final Safety Analysis Reports (UFSAR) to include a discussion of the new fuel burnup limit.
5.0 REGULATORY SAFETY ANALYSIS The changes which delete an additional condition currently contained in the MNS and CNS FOLs are being proposed in accordance with the timeframe contained in the condition itself. The proposed changes delete a condition which limits fuel burnup, consistent with NUREG/CR-6703. This document provides the regulatory basis for extending fuel burnup at nuclear power plants.
5.1 No Significant Hazards Consideration Upon approval of this LAR by the NRC and deletion of the MNS and CNS FOL Appendix B condition currently limiting maximum rod average burnup to 60 GWd/MTU, it will be acceptable from both a methodology and environmental perspective to increase maximum rod average burnup up to and including 62 GWd/MTU for fuel used in core reloads at MNS and CNS. DEC has made the determination that this LAR involves a No Significant Hazards Consideration by applying the three standards set forth in 10 CFR 50.92(c), "Issuance of amendment," as discussed below:
Enclosure 1 Page 5 of 8
- 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
Deletion of the MNS and CNS FOL Appendix B conditions currently limiting maximum rod average burnup to 60 GWd/MTU does not add, delete, or modify any MNS or CNS systems, structures, or components (SSCs). The proposed amendment would effectively allow future increases in the MNS and CNS maximum rod average burnup limit up to and including 62 GWd/MTU using existing fuel management methods, analyses, and models that have been reviewed and approved by the NRC. Maximum average rod burnup limits will continue to be maintained within safe and acceptable limits using these fuel management methods and models.
Increasing the MNS and CNS maximum rod average burnup limit does not affect the thermal hydraulic response or the radiological consequences of any previously evaluated accident. The fuel rod design criteria will continue to be met at the maximum burnup limits allowed utilizing the current fuel management, analysis, and evaluation processes. An increase to the maximum rod average burnup limit will not increase the likelihood of a malfunction of nuclear fuel since the fuel currently used at MNS and CNS has been designed to support a maximum rod average burnup up to and including 62 GWd/MTU. Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
The proposed amendment would delete MNS and CNS FOL Appendix B condition which currently limits maximum rod average burnup to 60 GWd/MTU. The proposed amendment would effectively allow future increases in the MNS and CNS maximum rod average burnup limit up to and including 62 GWd/MTU using existing fuel management methods, analyses, and models that have been reviewed and approved by the NRC.
The proposed amendment does not change the design function of the nuclear fuel or create any credible new failure mechanisms or malfunctions for the nuclear fuel. Fuel rod design criteria will continue to be met at the maximum burnup limits allowed under the fuel management methods and models that have been previously reviewed and approved by the NRC. Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
The proposed amendment would delete a MNS and CNS FOL Appendix B condition which currently limits maximum rod average burnup to 60 GWd/MTU. The proposed amendment would effectively allow future increases in the MNS and CNS maximum rod
Enclosure 1 Page 6 of 8 average burnup limit up to and including 62 GWd/MTU using existing fuel management methods, analyses, and models that have been reviewed and approved by the NRC.
The proposed amendment does not result in altering or exceeding a design basis or safety limit for the plant. All current fuel design criteria will continue to be satisfied, and the safety analysis of record, including evaluations of the radiological consequences of design basis accidents, will remain applicable. Radiological consequences have been evaluated consistent with methodologies approved by the NRC.
Based on the above, Duke concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10CFR50.92(c), and, accordingly, a finding of "No Significant Hazards Consideration" is justified.
5.2. Applicable Regulatory Requirements/Criteria As discussed in the MNS and CNS UFSAR Section 4.3, applicable General Design Criterion (GDC) from 10 CFR 50, Appendix A include the following:
GDC 10 - "Reactor design", which requires that "The reactor core and associated coolant, control, and protection systems shall be designed with appropriate margin to assure that specified acceptable fuel design limits are not exceeded during any condition of normal operation, including the effects of anticipated operational occurrences."
GDC 61 - "Fuel storage and handling and radioactivity control", which requires, in part, that "The fuel storage and handling, radioactive waste, and other systems which may contain radioactivity shall be designed to assure adequate safety under normal and postulated accident conditions."
Other applicable regulatory criteria are as follows:
10 CFR 51.52 Table S-4 "Environmental Effects of Transportation of Fuel and Waste" 10 CFR 71 "Packaging and Transportation of Radioactive Material" Compliance with the above GDC requirements and applicable regulatory criteria will continue to be met upon approval and implementation of this LAR. All current fuel design criteria will continue to be satisfied, and the safety analysis of record, including evaluations of the radiological consequences of design basis accidents, will remain applicable. Radiological consequences have been evaluated consistent with methodologies approved by the NRC.
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.
Enclosure 1 Page 7 of 8 5.3 PRECEDENTS Below are NRC-approved precedent licensing actions for other stations which provided for deletion of requirements similar to the MNS and CNS FOL Appendix B license condition:
" Kewaunee Power Station amendment dated July 2, 2007 and related NRC SE dated July 2, 2008 (TAC No. MD6085).
- Surry Power Station amendment dated March 6, 2007 and related NRC SE dated December 10, 2007 (TAC Nos. MD4716 and MD4717).
6.0 ENVIRONMENTAL CONSIDERATION
The proposed license amendment request is supported by a formal NRC environmental assessment as documented in NUREG/CR-6703 - "Environmental Effects of Extending Fuel Burnup Above 60 GWd/MTU". Further, the proposed amendment does not involve a significant hazards consideration nor significantly increase the types and amounts of effluents that may be released offsite, nor significantly increase individual or cumulative occupational radiation exposures. Therefore, the proposed amendment meets the criteria given in 10 CFR 51.22(c)(9) for a categorical exclusion from the requirement for performing an Environmental Assessment/Impact Statement.
7.0 REFERENCES
- 1. NUREG/CR-6703, "Environmental Effects of Extending Fuel Burnup Above 60 GWd/MTU," dated January 2001, ADAMS Accession No. ML010310298.
- 2. Letter, F. Rinaldi (USNRC) to H. B. Barron (Duke Energy),
SUBJECT:
McGuire Nuclear Station Units 1 and 2, Re: Issuance of Amendments (TAC Nos. MA2411 and MA2412), dated September 22, 1999.
- 3. Letter, P. S. Tam (USNRC) to G. R. Peterson (Duke),
SUBJECT:
Catawba Nuclear Station Units 1 and 2, Re: Issuance of Amendments (TAC Nos. MA2359 and MA2361), dated September 22, 1999.
Subject:
Safety Evaluation of Framatome ANP Topical Report BAW-10186P-A, Revision 1, Supplement 1, "Extended Burnup Evaluation" (TAC Nos MB3650 and MB7548),
dated June 18, 2003.
- 5. Letter, Gerald T. Bischof (Vice President - Nuclear Engineering, Virginia Electric and Power Company) to U. S. Nuclear Regulatory Commission -
SUBJECT:
Surry Power Station, Units 1 and 2, Proposed Increase In The Lead Rod Average Burnup Limit, dated March 6, 2007.
SUBJECT:
Surry Power Station, Unit NOS. 1 and 2, Environmental Assessment Related To Your Application For License Amendment Regarding Increase In The Lead Rod Average Burnup Limit (TAC Nos. MD4716 AND MD4717),
dated December 10, 2000.
Enclosure 1 Page 8 of 8
- 7. Letter, Gerald T. Bischof (Vice President - Nuclear Engineering, Dominion Energy Kewaunee Inc) to U. S. Nuclear Regulatory Commission,
SUBJECT:
Kewaunee Power Station, Deletion of License Condition 2.C(5), Fuel Burnup, dated July 2, 2007.
- 8. Letter, J. Cushing (USNRC) to D. A. Christian (Dominion Energy Kewaunee, Inc),
SUBJECT:
Kewaunee Power Station - Issuance of Amendment RE: Deletion of License Condition on Fuel Burnup (TAC NO. MD6085), dated July 2, 2008.
- 9. Topical Report DPND-DPC-NE-2009-PA, "Duke Power Company Westinghouse Fuel Transition Report, Revision 2A."
- 10. Letter, F. Rinaldi (NRC) to H. B. Barron (McGuire Nuclear Station), finding use of high burnup methodology described in topical report BAW-10186P-A acceptable for reload licensing application at McGuire, March 3, 1999.
- 11. Letter, P. S. Tam (NRC) to G. R. Peterson (Catawba Nuclear Station), finding use of high burnup methodology described in topical report BAW-10186P- A acceptable for reload licensing application at Catawba, March 3, 1999.
Attachment la to Enclosure I Marked Up Pages of The Existing FOL for MNS
APPENDIX B ADDITIONAL CONDITIONS FACILITY OPERATING LICENSE NO. NPF-9 Duke Energy Carolinas, LLC shall comply with the following conditions on the schedules noted below:
Amendment Additional Implementation Number Conditions Date 184 The schedule for the performance of new and Within 90 days of revised surveillance requirements shall be as the date of this follows: amendment For surveillance requirements (SRs) that are new in Amendment No. 184 the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment No. 184. For SRs that existing prior to Amendment No. 184, including SRs with modified acceptance criteria and SRs whose intervals of performance are being extended, the first performance is due at the end of the first surveillance interval that begins on the date the surveillance was last performed prior to implementation of amendment No. 184. For SRs that existed prior to Amendment No. 184, whose intervals of performance are being reduced, the first reduced surveillance interval begins upon completion of the first surveillance performed after implementation of Amendment No. 184.
tO'.UTe Renewed Ucense No. NPF-9 Amendment No.L*[t-.,1 e
-131- I.
APPENDIX B ADDITIONAL CONDITIONS FACILITY OPERATING LICENSE NO. NPF-17 Duke Energy Carolinas, LLC shall comply with the following conditions on the schedules noted below:
Amendment Additional Implementation Number Conditions Date 166 The schedule for the performance of new and Within 90 days of revised surveillance requirements shall be as the date of this follows: amendment For surveillance requirements (SRs) that are new in' Amendment No- 166 the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment No. 166. For SRs that existed prior to Amendment No. 166, including SRs with modified acceptance criteria and SRs whose intervals of performance are being extended, the first performance is due at the end of the first surveillance interval that begins on the date the surveillance was last performed prior to implementation of amendment No. 166. For SRs that existed prior to Amendment No. 166, whose intervals of performance are being reduced, the first reduced surveillance interval begins upon completion of the first surveillance performed after implementation of Amendment No. 166.
19Te mum ro a rage urn for any rod &1 With' 30 a-ysof/
be* ited to 60 dlmtU unti comple ofan d of amen nt C enviro increased Ii tal a nt support an 7-Renewed License No. NPF-17 Amendment No. ter B-1 iI
Attachment lb to Enclosure I Marked Up Pages of The Existing FOL for CNS
Amendment Implementation Number Additional Condition Date 173 The schedule for the performance of new and By January 31, 1999 revised surveillance requirements shall be as follows:
For surveillance requirements (SRs) that are new in Amendment No. 173 the firsti performance is due at the end of the first surveillance interval that begins at implementation of Amendment No. 173. For SRs that existing prior to Amendment No. 173, including SRs with modified acceptance criteria and SRs who intervals of performance are being extended, the first performance is due at the end of the first surveillance interval that begins on the date the surveillance was last performed prior to implementation of amendment No. 173. For SRs that existed prior to Amendment No. 173, whose intervals of performance are being reduced, the first reduced surveillance interval begins upon completion of the firstofsurveillance after implementation Amendmentperformed No. 173 . '
/
10The m imum rod av e bumup r any rod 7 Within days of shal e limited to GWdlmtU til the,/ date amen coppletion of YanqRC environ lental ssessment s porting an i eased limit In associato-n Wi e CS sump iner - in 30 days of modification and Generic Safety Issue (GSI)- date of amendment 191 requirements: and no later than December 31, 2007
- 1. Unit 1 shall enter Mode 5 for the outage to install the sump strainer modification no later than May 19, 2008 and
- 2. The Unit I sump strainer modification shall be completed prior to entry into Mode 4 after May 19, 2008.
Amendment No. CL4-r"W
Amendment Implementation Number Additional Condition Date 165 The schedule for the performance of new and By January 31, 1999 revised surveillance requirements shall be as follows:
For surveillance requirements (SRs) that are new in Amendment No. 165 the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment No. 165. For SRs that existing prior to Amendment No. 165, including SRs with modified acceptance criteria and SRs who intervals of performance are being extended, the first performance is due at the end of the first surveillance interval that begins on the date the surveillance was last performed prior to implementation of amendment No. 165. For SRs that existed prior to Amendment No. 165, whose intervals of performance are being reduced, the first reduced surveillance interval begins upon t a -oentry completion of the first surveillance performed Ce o t auter implementation of Amendment NoA165lter 172e maximr rod averaCioiumupnanyodxp Withine3faysroft shall belIited to 60 */lmtU u~lthe / date o menme m
compl on of an N environentaleaag rasssment supowr4incothmaS limitg .
24Fo*r 'steam gen-erato (SG) integrity Prnio to any entry assessments, the ratio of 2.5 will be used in into Mode 4 during tcompletion of both the Condition Monitoring Cycle 17 operation (CM) and the Operational Assessment (OA) upon implementation of the Interim Alternate Repair Criterion (IARC). For example, for the CM assessment, the component of leakage from the lower 4 inches of the most limiting SG during the prior cycle of operation Vill be multiplied by a factor of 2.5 and added to the total leakage from any other source andbe compared to the allowable accident analysis leakage assumption. For the 0A, the difference in leakage from the allowable limit during the limiting design basis accident minus the leakage from the other sources will be divided by 2.5 and compared to the observed leakage. An administrative limit will be established to not exceed the calculated value.
Renewed Ucense No. NPF-52 Amendment No. L LoA,,r]
Attachment lc to Enclosure I Page 1 of 4
.Summary of NUREG/CR-6703 Conclusions and Evaluation of These Conclusions With Respect To MNS and CNS
Attachment 1c to Enclosure I Page 2 of 4 Summary of NUREG/CR-6703 Conclusions and Evaluation of These Conclusions With Respect To MNS and CNS NUREG/CR-6703 Conclusion Summary Evaluation With Respect To MNS and CNS Does NUREG/CR-6703 Conclusion Envelope MNS and CNS?
The NUREG/CR-6703 environmental assessment Analyses of the core, assembly, and rod Yes concluded that increasing fuel burnup above 60 GWd/MTU radionuclide inventories for MNS and CNS changes the radionuclide mixture in the reactor fuel. specifically accounted for the increase in burnup up Whereas the activities of short-lived fission products tend to a maximum average rod burnup of 62 GWd/MTU.
to remain constant or decrease slightly, the activities These analyses determined that, for a maximum associated with activation products and actinides tends to peak-rod fuel burnup up to and including 62 increase. GWd/MTU, any results from an increase in radionuclide inventories would remain bounded by current NRC regulations and guidance.
The NUREG/CR-6703 environmental assessment With regard to gap release fractions, the applicable Yes concluded that increasing fuel burnup above 60 GWd/MTU safety and radiological analyses performed for MNS tends to increase the gap release fraction. However, the and CNS comply with the relevant current NRC gap release fractions predicted to occur at 62 GWd/MTU guidance. Therefore, the increases in fission remain below fractions assumed in current NRC guidance. product gap release fraction predicted to occur at 62 GWd/MTU in the 2001 NRC environmental assessment would be bounded by current regulations and guidance.
The NUREG/CR-6703 environmental assessment The MNS and CNS coolant activity performance Yes concluded that increasing fuel burnup above 60 GWd/MTU record exhibits the general trend described here.
is not likely to increase environmental impacts from normal Therefore, it is expected the environmental impacts reactor operations because coolant activity has been from normal operation at MNS and CNS would not decreasing as fuel burnup has been increasing. This increase by allowing a maximum fuel rod average decrease is attributed to the reduction in the number of burnup up to and including 62 GWd/MTU.
fuel failures as a result of better quality control in fuel fabrication.
Attachment 1c to Enclosure 1 Page 3 of 4 Summary of NUREG/CR-6703 Conclusions and Evaluation of These Conclusions With Respect To MNS and CNS NUREG/CR-6703 Conclusion Summary Evaluation With Respect To MNS and CNS Does NUREGICR-6703 Conclusion Envelope MNS and CNS?
The NUREG/CR-6703 environmental assessment It is expected that allowing a maximum fuel rod Yes concluded that increasing fuel burnup above average burnup up to and including 62 GWd/MTU 60 GWd/MTU decreases the rate of discharge of fuel to at MNS and CNS would result in these benefits with the spent fuel pool. This will preserve space in the spent respect to rate of discharge of fuel, preservation of fuel pool postponing the need to remove spent fuel from spent fuel pool space, spent fuel removal frequency, the pool. It also reduces the total heat load on the spent and spent fuel pool cooling heat load.
fuel pool cooling system.
The NUREG/CR-6703 environmental assessment It is expected that allowing a maximum fuel rod Yes concluded that increasing fuel burnup above 60 GWd/MTU average burnup up to and including 62 GWd/MTU reduces the requirement for mining and processing at MNS and CNS would result in these benefits with uranium ore and fabrication of fuel assemblies. As a respect to fuel assembly related mining, processing, result, environmental consequences associated with the and fabrication.
front end of the fuel cycle should decrease.
The NUREG/CR-6703 environmental assessment With regard to accidents involving a release of Yes concluded that increasing fuel burnup above 60 GWd/MTU reactor coolant, the MNS and CNS TS limits on will not change limits on coolant activity. Consequently, allowable coolant activity will not change.
the potential environmental impacts of postulated LOCAs Consequently, the potential environmental impacts and PWR steam generator tube rupture accidents are of these accidents, which assume reactor coolant unchanged. activities are at the TS limits, will be unchanged.
The NUREG/CR-6703 environmental assessment MNS and CNS analyses which evaluate the impact Yes concluded that increasing fuel burnup above of a fuel handling accident assume radionuclide 60 GWd/MTU increases the potential environmental inventories corresponding to a maximum fuel rod impacts from a fuel handling accident. However, the average burnup of 62 GWd/MTU. These analyses doses calculated for fuel handling accidents remain well demonstrate that the doses calculated for these fuel below regulatory limits, handling accidents remain below regulatory limits.
Attachment Ic to Enclosure 1 Page 4 of 4 Summary of NUREG/CR-6703 Conclusions and Evaluation of These Conclusions With Respect To MNS and CNS NUREG/CR-6703 Conclusion Summary Evaluation With Respect To MNS and CNS Does NUREG/CR-6703 Conclusion Envelope MNS and CNS?
The NUREG/CR-6703 environmental assessment Internal processes and procedures ensure dose Yes concluded that increasing fuel burnup above rates from shipping casks for MNS and CNS are 60 GWd/MTU does not significantly change the potential maintained within applicable regulatory limits. With environmental impacts of incident-free transportation of regard to spent fuel transportation accidents, the spent nuclear fuel or the accident risks associated with environmental impact conclusions of NUREG/CR-spent fuel transportation if the fuel is cooled for five years 6703 are applicable. With respect to any future after discharge from the reactor. Doses associated with transportation of MNS and CNS fuel discharged incident-free transportation of spent fuel with burnup to 75 from the reactor, DEC will comply with regulations GWd/MTU are bounded by the doses in 10CFR51.52, and requirements at time of transport Table S-4 if dose rates from the shipping casks are maintained within regulatory limits.
The NUREG/CR-6703 environmental assessment Allowing MNS and CNS to increase maximum fuel Yes concluded that increasing fuel burnup above rod average burnup up to and including 60 GWd/MTU has an economical benefit. 62 GWd/MTU for fuel rods used in core reloads at MNS and CNS could reduce the amount of fuel required per unit of electricity generated. It is expected this could provide an economic benefit to.
MNS and CNS related to front-end and back-end fuel cycle costs.