ML110540371

Interest by Energy Northwest in Use of Weapons-Grade Plutonium Fuel (MOX)

ML110540371
Person / Time
Site:	Columbia
Issue date:	02/15/2011
From:	Clements T Friends of the Earth
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2010-02, EEN-MOX-002
Download: ML110540371 (12)

Text

OFriends of February 15, 2011 the Earth U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Re: COLUMBIA GENERATING STATION, DOCKET NO. 50-397 &

Interest by Energy Northwest in Use of Weapons-Grade Plutonium Fuel (MOX)

To Whom it Concerns:

I hereby submit this letter and attachment for the formal record concerning the license renewal application by Energy Northwest for the Columbia Generating Station. I request that this letter and attachments be placed in the record for docket number 50-397 and that they also be placed in ADAMS in the daily postings.

The document entitled "License Amendments for Loading Mixed Oxide (MOX) Lead Use Assemblies at a Boiling Water Reactor" (EN-MOX-002), dated October 28, 2009, was released to the public in response to a Freedom of Information Act request filed with Energy Northwest, as reflected in the attached documents from Energy Northwest. Though the MOX lead use assembly document has "Business Sensitive" printed across the top and "Official Use Only" across the bottom, the document is no longer of a sensitive nature as it was released to me via my FOIA request and is thus publicly available. :Plr -,%it-fir,os,

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I was alerted that the NRC was balking at placing the attached MOX lead use assembly document in ADAMS, as requested in a January 29, 2011 letter to the NRC. That letter included various attachments concerning MOX use in BWRs. This letter will clarify that the document of concern (EN-MOX-002) was released publicly and thus can be posted in ADAMS with the other documents indicating interest in MOX use by Energy Northwest.

It should be noted that Energy Northwest determined that for testing MOX "lead use assemblies" in a BWR that at least three irradiation cycles of two years each were necessary to validate the use of MOX.

Thank you for including this submission in the Energy Northwest license renewal docket and for placing it in ADAMS.

Sincerely, Tom Clements Southeastern Nuclear Campaign Coordinator Friends of the Earth 1112 Florence Street. Columbia, SC 29201

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Marian Kellett ENERGY Docment & Data Services P.O. Box 968, 964T Richland, WA 99352-0968 Ph. 509-377-8321 F. 509-377-2479 m kellett@energy-noarhmestcom March 4, 2010 Mr. Tom Clements 1112 Florence Street Columbia, SC 29201

Reference:

Energy Northwest Request for Public Records, Control Number 2010-02 received January 15, 2010

Dear Mr. Clements:

On January 15, 2010, Energy Northwest Document & Data Services received your Request for Public Records, Control Number 2010-02, for documents related to plutonium fuel (mixed oxide fuel, MOX) use in the Columbia Generating Station. Energy Northwest responded on January 20, 2010, and again on February 22, 2010, that the records would be transmitted to you on or before March 18, 2010.

Per the telephone conversation between yourself and Gail Dockter, Energy Northwest Document & Data Services Supervisor on February 22, 2010, you requested a partial transmittal of the documents currently available. The following attachments represent a partial transmittal of the records requested:

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ý Report No. EN-MOX-002, October 28, 2009

2. MOX Loading Procedures in Europe, Energy Northwest Comments

3. Major Steps during Fuel Receipt

4. Energy Northwest MOX Summary, August 17, 2009

5. MOX Fuel Board Presentation, June 2009

6. Report No. EN-MOX-001, May 28, 2009

7. MOX Fuel Long Term & Near Term Focus Presentation, May 14, 2009

8. MOX Status Presentation, Lisa Ferek April 28, 2009

9. Memorandum of Understanding between the Tennessee Valley Authority and Energy Northwest for Advanced Fuel Cycle Demonstration, March 2009 In your request, you ask that Energy Northwest waive the production fee. Unfortunately, as a public entity we are unable to honor your request without a gifting of public funds concern. However, to minimize your expense, we will transmit the documents via email.

Please advise should you also wish Energy Northwest to transmit the document via the U.S. Mail. The cost will be $.15 cents per page plus postage.

Mr. Tom Clements 1112 Florence Street Columbia, SC 29201 Page 2 of 2 March 4, 2010

Subject:

Energy Northwest Request for Public Records, Control Number 2010-02 received January 15, 2010 The remaining records are scheduled for transmittal on or before March 18, 2010. For further information, please contact Gail Dockter, Document & Data Services Supervisor at 509-377-2 99, or at jgdockter@energy-northwest.com.

adnan ellett, Manager Docume t & Data Services MK:jgd cc:

M Kellett, MD 964T Request for Public Records File

ENERGY NORTHWEST Date Received:

(:/l' REQUEST FOR PUBLIC RECORD C0tN REQUESTER Name:

Fax No.:

Telephone No.:

Date:

Tom Clements 803-834-3084 01-11-2010 Address: (Street)

Return form to:

1112 Florence Street Energy Northwest City:

State:

Zip Code:

Attention:

Columbia SC 29201 Document & Data Services, MD 964T P.O. Box 968 Email address:

Representing:

Richland, WA 99352 tomclements329@cs.com Friends of the Earth Nature of Request:

FAX: (509) 377-2479 E] Inspect Records ER Obtain a copy - to be provided at cost 0 Email a copy Phone: (509) 372-5248 Records Request (Be as specific as possible):

1. Memorandum of Understanding between Energy Northwest and the Tennessee Valley Authority (TVA) related to plutonium fuel (mixed oxide fuel, MOX) use in the Columbia Generating Station. I am aware this document exists.

2. Any agreement or communication between Energy Northwest and the Pacific Northwest National Laboratory related to MOX use.

3. Any presentations or documents on MOX use prepared by Mr. Ted Coates, S. K. Gambhir, Vice President, Technical Services, or J. V. Parrish, Chief Executive Officer, or other Energy Northwest staff. This request includes internal presentations or documents made for the use of staff, or presentations made to the Energy Northwest executive board or the Operations, Construction & Safety (OPS) Committee.

Given that the documents gathered under this request will be used for non-profit public interest use only and will help the public to understand the workings of Energy Northwest, I request a fee waiver for this request NOTE: By my signature I acknowledge that I am responsible for paying copying and other costs directly Incident to providing the requested records.

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Date:

Requester's Signature:

ENERGY NORTHWEST Manager, Responding Organization or N/A: I Date:

11 Request denied for the following reasons:

Attachments included:

5-Other Reviewý Date:

Leal Revi Date:

Requept i

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men & Data Services or Designee:

Date:

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ENERGY UJNORTHWEST Request for Public Records Control No 2010-02 Report No. EEN-MOX-002 October 28, 2009

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C REPORT NO. EN-MOX-002 LICENSE AMENDMENTS FOR LOADING MIXED OXIDE (MOX)

LEAD USE ASSEMBLIES AT A BOILING WATER REACTOR October 28, 2009 Prepared by Energy Northwest under TVA contract 76715 OFF-------

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EN-MOX-002 I. Background Energy Northwest (EN) is evaluating the potential irradiation of mixed oxide (MOX) fuel assemblies. Under a contract with the Tennessee Valley Authority (TVA), EN is performing tasks to evaluate the licensing of MOX fuel in a boiling water reactor (BWR). This report provides a discussion of the potential licensing amendments that would be required to install MOX lead use assemblies (LUA) at Columbia Generating Station (CGS).

II. Plant Licensing The following topics will need to be addressed in the CGS license amendment - or dispositioned as having no impact:

1. Operating License - No changes are required for CGS. The existing wording regarding special nuclear material adequately addresses the use of MOX fuel: "The Commission hereby licenses Energy Northwest to receive, possess and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report."

2. Technical Specifications (TS)

a. TS 4.2.1 Design Features, Reactor Core, Fuel Assemblies, needs to be changed to allow use of MOX as reactor fuel. Specifically, the existing TS wording "Each assembly shall consist of a matrix of Zircaloy clad fuel rods with an initial composition of depleted, natural, or slightly enriched uranium dioxide (U02) as fuel material...

will need to be revised to allow the use of LUAs containing Pu and uranium.

In addition, TS 4.2.1 requires that "lead fuel assemblies that have not completed representative testing may be placed in nonlimiting core regions." The nuclear design of the reactor core will need to ensure this limitation is observed.

b. TS 4.3.1.1 Design Features, Criticality, contains the requirements on keff for the spent fuel storage racks. No changes are required for CGS since these requirements just refer back to the FSAR. Specifically, 4.3.1.1.a states, "The spent fuel storage racks are designed and shall be maintained with kefsO. 95 if fully flooded with unborated water, which includes an allowance for uncertainties as described in Section 9.1.2 of the FSAR."

c. TS 4.3.1.2 Design Features, Criticality, contains the requirements on keff for the new fuel storage racks. Subparagraph (a) requires the new fuel storage racks be designed and maintained with keff<0.95 if fully flooded with unborated water.

Subparagraph (b) limits a maximum of 60 new fuel assemblies be stored in the new fuel storage racks arranged in 6 spatially separated zones. 10 CFR 73.55(1)(3)(v)(B) requires unirradiated MOX assemblies be stored in the spent fuel pool and not the new fuel storage vault. However, other plants have not had to modify their TS to include this limitation.

d. TS 5.6.3 Core Operating Limits Report (COLR) requires that the analytical methods used to determine the core operating limits be listed in this specification. Currently, CGS TS 5.6.3.b lists NEDO-32465-A, BWR Owners' Group Reactor Stability Detect "PtetAL-O-Y

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EN-MOX-002 and Suppress Solutions Licensing Basis Methodology and Reload Applications and NEDE-240 11-P-A and NEDE 24011-P-A-US, General Electric Standard Application for Reactor Fuel (GESTAR II) and Supplement for United States. Any methods utilized in the development of the core operating limits for MOX fuel that are not addressed under these approved reports, will need to be added to this TS.

e. TS 2.1.1.2 Reactor Core Safety Limits is typically evaluated each cycle as part of reload licensing. The safety limit may or may not change as a result of MOX fuel.

However, typically LUAs are placed in non-limiting core locations.

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TS 3.7 Plant Systems - No changes required for CGS. Certain plants have storage restrictions in the spent fuel pool based on enrichment, exposure and, in some cases, absorber rods. This specification would need to be modified to specifically allow MOX fuel storage in the racks.

3. Final Safety Analysis Report (FSAR)

a. Codes and Methods - FSAR Section 1.6 contains a listing of topical reports incorporated by reference into the CGS FSAR. Any new or revised codes and methods used to analyze the MOX fuel will need to be included as part of this listing.

In general, changes to codes and methods to allow the application to MOX fuel must be approved by the NRC and will be included in a license amendment either requested by the fuel vendor or licensee. The following codes will be used to analyze the MOX fuel:

" Lattice physics Steady-state reactor physics (core simulator)

Fuel rod thermal mechanical Advanced reactor transient and accident methods (possibly)

b. Fuel Design - FSAR Section 4.1.2.1 describes the reactor core including the fuel rod and fuel bundle design. The design description will need to be updated to include a discussion of the MOX fuel design. In general, changes to the fuel design to utilize MOX fuel must be approved by the NRC and will be included in a license amendment either requested by the fuel vendor or licensee.

c. Fuel Mechanical Design - FSAR Section 4.2 provides the fuel system mechanical design bases limits and references the applicable reports, codes and methods used to verify that the fuel remains within limits. Applicable topics are: stress/strain, fatigue, fretting wear, oxidation/hydriding/corrosion, dimensional changes, internal gas pressure, hydraulic loads, control rod reactivity, hydriding, cladding collapse, fretting wear, overheating of cladding, overheating of pellets, excessive fuel enthalpy, pellet-cladding interaction, bursting, mechanical fracturing, cladding embrittlement, violent expulsion of fuel, generalized cladding melt, fuel rod ballooning and structural deformation. The new/revised fuel rod thermal mechanical code will be used to analyze much of the aforementioned fuel rod behavior. In general, changes to codes and methods to allow the application to MOX fuel must be approved by the NRC and will be included in a license amendment

d. Fuel Nuclear Design - Plutonium (Pu) has a higher thermal absorption cross section compared with uranium which reduces control rod worth and integral fuel assembly

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Vrc-EN-MOX-002 absorber worth affecting shutdown margin. In addition, Pu has larger fission cross sections at high neutron energies which cause the coolant void coefficient of reactivity to be less negative for MOX fuel than for low enriched uranium (LEU) fuel.

FSAR Section 4.3 provides the fuel system nuclear design bases and references the applicable reports, codes and methods used to analyze the fuel. Applicable topics are nuclear design description, power distribution, reactivity coefficients, control requirements, shutdown reactivity, reactivity variations, control rod patterns and reactivity worths, and stability. The impact of MOX fuel on control rod worths and other reactivity coefficients will need to be addressed.

e. Neutron Fluence - Pu has a harder neutron energy spectrum which could enhance irradiation damage in the reactor pressure vessel and internals. FSAR section 4.3.2.8 discusses the reactor pressure vessel (RPV) irradiation calculations and results. In addition, FSAR section 5.3 describes the reactor vessel including materials, pressure-temperature (P-T) limits, and vessel integrity. The RPV peak fluence is used for development of the P-T limit curves. The impact of MOX fuel on vessel lifetime and the BWR vessel internals program (BWRVIP) will need to be addressed.

f.

Loss of Coolant Accident (LOCA) - Emergency Core Cooling System (ECCS)

Performance Evaluation - MOX fuel has reduced thermal conductivity compared with LEU fuel which causes the MOX fuel rods to operate with higher centerline temperatures for a given fuel rod power, increasing the initial fuel rod stored energy for LOCA and possibly resulting in the need for reduced power limits for MOX assemblies. FSAR Section 6.3.3 evaluates the ECCS performance using analytical methods in compliance with the requirements of 10 CFR 50 and Appendix K to show conformance to the acceptance criteria of 10 CFR 50.46. A summary description of the reload design basis LOCA analysis methods is provided in this section of the FSAR. A limiting reactor recirculation coolant (RRC) break is identified and then used in the ECCS heatup analyses to determine the maximum average planar linear heat generation rate (MAPLHGR) limits for the specific fuel type. The MAPLHGR limits calculated in this performance evaluation provide a basis to ensure conformance with the acceptance criteria of 10 CFR 50.46. In general, any new or revised methods for analyzing MOX fuel under LOCA conditions must be approved by the NRC. The LOCA methodology, input variables, break spectrum calculations, and results are reported in this section of the FSAR. The MAPLHGR limits will be reported in the COLR.

g. Criticality - MOX fuel has different isotopics and material properties from LEU fuel necessitating new criticality analysis for fuel storage and handling. FSAR section 9.1.2.3 describes the criticality safety analyses for the spent fuel pool racks. In general, the fuel vendor performs the criticality analysis for their fuel design with the utility reporting the results in its FSAR. Specific analyses need to be performed to model the MOX fuel isotopic concentrations. In the past, the NRC has placed restrictions on the use of various industry-standard codes for the analysis of MOX fuel. Therefore, the criticality analysis will, most likely, need to be included in the utility's license amendment for the use of MOX. Other criticality analysis may need to be completed but are not generally submitted to the NRC including MOX rod storage in a fuel rod storage basket.

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h. Decay Heat - Irradiated MOX fuel has a larger inventory of actinides than LEU fuel resulting in greater decay heat levels for cooling times greater than one year. FSAR section 9.1.3 describes the fuel pool cooling system capabilities. Any increase in decay heat levels will need to be addressed.

New Fuel Handling - FSAR sections 9.1.4.2.10 and 9.1.4.3 contain a description of the new fuel receipt process and the fuel handling safety evaluation, respectively.

The receipt of MOX fuel will need to be addressed especially if a new/different type of shipping container/cask is utilized. Generally the utility is not responsible for licensing/certification of the shipping cask although it must comply with the requirements of the cask Certificate of Compliance.

In addition, FSAR section 12.2 describes radiation sources and refers exclusively to spent fuel. However, fresh MOX fuel, especially reactor grade Pu, has a higher dose rate than normal LEU fuel such that inclusion in the list of radiation sources may be required to address the fuel receipt and handling operations that occur in air prior to placement in the fuel pool.

Finally, a drop of a fresh MOX bundle in air may need to be analyzed due to the isotopic differences between fresh LEU and MOX assemblies.

Reactivity and Power Distribution Anomalies - Inhomogeneities (Pu clusters) in MOX fuel may affect fuel behavior during reactivity accidents, especially at high burnups.

Any burnup limitations on MOX fuel will most likely be related to the reactivity insertion events. FSAR section 15.4.9 describes the control rod drop accident (CRDA) which is the limiting accident for a BWR relative to peak fuel enthalpy. This event is mitigated, in part, by an initial rod configuration that complies with the banked position withdrawal sequence (BPWS). The withdrawal (or insertion) sequence is implemented by the operator and enforced by the rod worth minimizer (RWM). An operator error in control rod movement will be detected and stopped by the RWM. Impact of the use of MOX fuel on the assumptions and results of the CRDA analysis will need to be addressed.

Other reactivity insertion accidents in FSAR section 15.4 include the rod withdrawal error, recirculation flow control failure with increasing flow, and misplaced bundle accident. These accidents are mitigated by establishing an operating limit minimum critical power ratio (MCPR) that limits the change in critical power ratio during the accident such that the safety limit MCPR is always preserved. Generally these accidents are re-evaluated on a cycle specific basis with the limits reported in the COLR.

k. Radiological Analyses - MOX fuel has reduced thermal conductivity compared with LEU fuel which causes the MOX fuel rods to operate with higher centerline temperatures for a given fuel rod power. Higher temperatures increase gas release from fuel pellets and, hence, fission product gap inventory, which may impact offsite dose calculations. In addition, MOX fuel has different fission product and actinide concentrations than LEU fuel which could also affect the radiological source term and accident consequences. CGS has implemented the alternative source term per 10 CFR 50.67 for use in the design basis radiological analyses. The impact of the use of MOX fuel on the accident source term and development of a bounding source

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EN-MOX-002 term will need to be included in the license amendment submittal. The following four accidents are analyzed for the radiological consequences:

FSAR 15.6.5 LOCA - The source term used for the design basis LOCA analysis is defined by the quantity, type and timing of the release of radioactivity from a damaged reactor core to the containment. The core inventory is based on an ORIGEN2 run and the release rates are consistent with Regulatory Guide (RG) 1.183, Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors.

" FSAR 15.7.4 Fuel Handling Accident (FHA) - The FHA involves the drop of a fuel assembly in the reactor vessel cavity over the reactor core during refueling operations. Fuel pin damage is postulated to occur to both the dropped assembly and to some portion of those assemblies impacted in the reactor core. The gap activity from the damaged pins is the radioactive source term for this event. Of this activity, all of the noble gases and only a fraction of the iodine are available for release based on the scrubbing effect of the water above the dropped fuel. The fission product inventory assumed to be gap activity is taken from RG 1.183.

FSAR 15.4.9 CRDA - The CRDA involves the rapid removal of a highest worth control rod resulting in a reactivity excursion. Consistent with the current licensing basis, 1.8% of the fuel pins in the full core are postulated to be damaged, with melting occurring in 0.77% of the damaged rods. The source term is composed of releases from melted fuel and the gap activity from the fuel pins postulated to be damaged. The core damage fractions and transport fractions for each radionuclide group are consistent with RG 1.183.

The iodine species released to the reactor coolant are assumed to be 95%

aerosol, 4.85% elemental, and 0.15% organic.

FSAR 15.6.4 Main Steam Line Break (MSLB) Outside Containment-The MSLB accident assumes the double-ended break of one main steam line outside the primary containment. The mass of coolant released is the amount in the steam line and connecting lines at the time of the break plus the amount passing through the main steam isolation valves prior to closure.

Two source term cases for the released coolant are considered. One is a pre-accident spike case of 4 micro-Ci/g dose equivalent (DE) 1-131 and the second is a maximum equilibrium case of 0.2 micro-Ci/g DEI-131. These source term assumptions are consistent with RG 1.183.

It should be noted that RG 1.183 contains the following note: 'The release fractions listed here have been determined to be acceptable for use with currently approved LWR fuel with a peak bumup up to 62,000 MWD/MTU. The data in this section may not be applicable to cores containing mixed oxide (MOX) fuel." The license amendment will need to justify the continued use of RG 1.183 release fractions.

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EN-MOX-002 Ill. Appendix K to Part 50 - ECCS Evaluation Models The regulations in Appendix K refer to "the thermal conductivity of the U02" and "the thermal conductance of the gap between the U02 and the cladding". There is no mention of Pu or MOX fuel. Therefore, an exemption must be granted by the NRC for the use of MOX fuel.

IV. Physical Security Plan The onsite physical protection requirements for un-irradiated MOX fuel assemblies are outlined in 10 CFR 73.55(l). The physical security plan must be updated to describe the operational and administrative controls to be implemented for the receipt, inspection, movement, storage and protection of un-irradiated MOX fuel.

1. Administrative Controls include the use of tamper-indicating devices during transport, a search of the MOX fuel for damage and unauthorized materials upon receipt, the presence of at least one armed security officer during the receipt and inspection activities, storage of MOX fuel within the fuel pool (so that access to MOX requires passage through at least two physical barriers and the water barrier), and implementation of a material control and accountability program that includes predetermined and documented storage locations for each MOX fuel assembly.

2. Physical Controls include the lockout of equipment and power supplies to equipment required for the movement and handling of un-irradiated MOX fuel assemblies when not in use, implementation of a two-person, line-of-sight rule within the fuel pool area when fuel handling equipment is not locked-out, conducting random patrols of areas containing the MOX fuel assemblies, control of locks by the security organization, and approval to remove locks by both the on-duty security shift supervisor and the operations shift manager.

3. Surveillance Requirements: 1) At least one armed security officer shall be present to observe activities involving the movement of un-irradiated MOX fuel assemblies before the removal of the locks from fuel handling equipment. 2) At least one armed security officer shall be present at all times until power is removed from equipment and locks are secured. 3) At least one armed security officer must be present and maintain constant surveillance of un-irradiated MOX fuel when not located in the fuel pool or reactor.

V. Certificate of Compliance for Spent Fuel Storage Casks Energy Northwest has installed an Independent Spent Fuel Storage Installation (ISFSI) under the general license requirements of 10 CFR 72.210 using an approved spent fuel storage cask listed in 10 CFR 72.214. The cask certificate of compliance (CoC) contains a listing of approved contents and design features. Energy Northwest's cask vendor has only requested and received approval to store a particular fuel design of BWR MOX fuel - 6x6 array containing up to 9 MOX rods with SO.635 wt% U235 and <1.578 wt% total fissile Pu.

Therefore, the holder of the CoC, the cask vendor, must prepare a license amendment request to update the allowable contents to include the storage of any proposed MOX LUA design (10x1O array). Required analyses include thermal, shielding, and criticality evaluations for the proposed fuel design. The results of these analyses are presented in the FSAR for the cask system.

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